T&Cs - External Wallet Access and Key Management Service

1. Purpose and Scope

These Terms and Conditions (the "Terms") govern the use of the external wallet access and key management functionality (the "Service") made available through the Kleos platform and operated by Kleos Ireland SR Limited ("Kleos"), a company incorporated under the laws of Ireland with its registered office in Ireland.

The Service enables users to create, access, recover, or import self-custodial blockchain wallets within the Kleos interface using integrated cryptographic and authentication infrastructure. The Service facilitates secure key generation, distributed key management mechanisms, and transaction signing capabilities necessary to interact with public blockchain networks.

The Service is provided solely as a technical interface and orchestration layer to facilitate user-initiated blockchain interactions. Wallets created or accessed through the Service are self-custodial in nature and remain under the control of the user. Nothing in these Terms shall be interpreted as constituting custody, safeguarding, deposit-taking, crypto-asset custody services, regulated wallet services, payment services, investment services, or any other regulated financial activity under applicable law. Kleos does not take possession or control of users' private keys or crypto-assets and does not execute transactions on behalf of users.

These Terms govern solely the relationship between you and Kleos in connection with your use of the Service and form a separate agreement from the Vaults Terms and Conditions, where applicable.

2. Service Description

The Service enables users to:

create a new blockchain wallet using integrated cryptographic key infrastructure;
access or recover a wallet using supported authentication methods;
sign blockchain transactions directly within the Kleos interface.

Kleos may integrate third-party key management or cryptographic infrastructure providers to enable secure key generation, encryption, storage fragmentation, or authentication flows. Such providers operate independently and facilitate technical processes only.

At no time does Kleos have access to users' unencrypted private keys.

3. Non-Custodial Nature

Wallets created or accessed through the Service are self-custodial wallets. Users retain ultimate control over their private keys, authentication credentials, and recovery mechanisms.

Kleos does not:

store private keys in plain form;
initiate transactions on behalf of users;
access wallet funds;
recover lost private keys.

Loss of access credentials, compromise of authentication methods, or failure of recovery mechanisms may result in permanent loss of access to crypto-assets.

4. Third-Party Infrastructure

The Service may integrate or rely upon independent third-party cryptographic, authentication, or blockchain infrastructure providers in order to enable secure wallet creation, access, key management, transaction signing, or recovery mechanisms.

Such infrastructure may include, where applicable, distributed key management systems, multi-party computation (MPC) technologies, encrypted key storage frameworks, authentication providers, cloud-based redundancy mechanisms, or other cryptographic coordination layers designed to enhance security and usability.

These third-party providers operate independently from Kleos and provide technical infrastructure only. They do not act as custodians, deposit-takers, fiduciaries, or asset managers in relation to users' crypto-assets. The architecture implemented through such providers may involve fragmentation, encryption, or distribution of cryptographic key material; however, ultimate control of wallet access remains dependent on user authentication credentials and recovery mechanisms.

Kleos does not control, audit on an ongoing basis, or guarantee the internal systems, security architecture, availability, resilience, operational continuity, or cybersecurity posture of any third-party infrastructure provider. The performance of the Service may depend in part on the proper functioning of such external systems.

To the maximum extent permitted by applicable law, Kleos shall not be liable for any loss, disruption, delay, inaccessibility, or security incident arising from or attributable to the failure, compromise, unavailability, misconfiguration, or discontinuation of third-party infrastructure providers. This includes, without limitation, failures in authentication services, cloud storage systems, distributed key management components, cryptographic coordination layers, or other external technical dependencies.

Nothing in this Article shall be interpreted as creating any partnership, agency, joint venture, or contractual relationship between users and such third-party providers through Kleos. Any reliance on third-party infrastructure.

5. User Responsibilities and Risk Acknowledgment

By accessing or using the Service, you acknowledge and agree that you bear sole and exclusive responsibility for the security, confidentiality, and proper management of your wallet authentication methods, recovery credentials, devices, and associated accounts.

You are solely responsible for safeguarding:

your authentication credentials (including but not limited to email accounts, passcodes, biometric access, multi-factor authentication methods, or similar access controls);
any recovery phrases, backup files, recovery keys, encrypted key fragments, or account restoration data associated with your wallet;
the security of any cloud storage accounts, hardware devices, or third-party services used in connection with wallet access.

Compromise, loss, theft, misdirection, unauthorized disclosure, phishing attacks, social engineering, SIM-swapping, device malware, cloud account breaches, or failure to properly secure your authentication credentials or recovery mechanisms may result in permanent and irreversible loss of access to your wallet and the crypto-assets associated with it.

You further acknowledge and accept that:

blockchain transactions are irreversible once confirmed on the relevant network;
wallet access is dependent on the integrity of your authentication and recovery credentials;
Kleos does not store private keys in plain form and does not have unilateral ability to reconstruct or recover lost credentials;
Kleos cannot reverse transactions, restore lost access, retrieve private keys, freeze assets, or recover crypto-assets transferred to incorrect addresses;
cryptographic systems, distributed key management mechanisms, and authentication-based recovery processes may fail or become inaccessible due to technical errors, third-party infrastructure disruptions, regulatory changes, or force majeure events.

You agree to implement and maintain appropriate security measures, including the use of secure devices, updated operating systems, strong authentication methods, and protection against malware and unauthorized access. You assume full responsibility for monitoring your wallet activity and promptly taking appropriate action in the event of suspected compromise.

To the maximum extent permitted by applicable law, you accept that any loss arising from failure to maintain adequate security practices, compromised credentials, unauthorized access, or improper use of the Service shall be borne solely by you.

6. Support Limitations

Any support provided by Kleos in connection with the Service is limited strictly to technical issues arising within the Kleos interface and its directly controlled systems. Support is provided on a reasonable-efforts basis and does not constitute monitoring, safeguarding, or management of user wallets or crypto-assets.

Kleos cannot and does not provide assistance with:

compromised authentication credentials, including email accounts, devices, biometric access, passcodes, or multi-factor authentication failures;
lost, inaccessible, or improperly stored recovery credentials, encrypted key fragments, or backup data;
unauthorized access resulting from phishing, malware, SIM-swapping, social engineering, or device-level security breaches;
failures, disruptions, or unavailability of third-party cryptographic, authentication, or cloud-based infrastructure;
issues arising from the use of wallets on external platforms, decentralized applications, or third-party blockchain services;
losses resulting from incorrectly executed, misdirected, or irreversible blockchain transactions.

Kleos does not provide key recovery services, escrow services, asset tracing, forensic investigations, or remediation services in the event of wallet compromise. Users acknowledge that certain incidents may be technically irreversible and beyond the operational control of Kleos.

7. Fees

The Service is provided free of charge unless expressly stated otherwise within the Kleos platform.

Kleos does not charge subscription fees, custody fees, or direct usage fees specifically for wallet creation, access, or key management functionality. However, use of the Service may involve standard blockchain network transaction fees ("gas fees") or third-party infrastructure costs imposed by public blockchain networks or external service providers. Such fees are determined independently of Kleos and are borne solely by the user.

Kleos reserves the right to introduce fees for certain enhanced features or functionalities in the future, subject to prior notice where required by applicable law.

8. Liability

The Service is provided on a best-effort basis and as a technical interface only. Kleos does not guarantee uninterrupted availability, error-free operation, continuous access, or complete resilience of the Service or any integrated third-party infrastructure.

To the maximum extent permitted by applicable law, Kleos shall not be liable for any direct or indirect loss, damage, or claim arising from or related to:

loss, compromise, or unauthorized use of authentication credentials or recovery data;
device-level breaches, malware infections, SIM-swapping incidents, or unauthorized account access;
failure, disruption, compromise, or discontinuation of third-party cryptographic, authentication, cloud, or distributed key management infrastructure;
blockchain network congestion, forks, consensus failures, validator attacks, or other protocol-level events;
irreversible or incorrectly executed blockchain transactions;
regulatory changes or restrictions affecting wallet functionality;
user error, negligence, or failure to implement appropriate security measures.

Kleos does not assume responsibility for safeguarding crypto-assets and does not insure or underwrite user losses. Nothing in these Terms shall exclude or limit liability for fraud, willful misconduct, gross negligence, or any liability that cannot be lawfully excluded under applicable law.

9. Modification and Termination

Kleos reserves the right to modify, suspend, restrict, or discontinue the Service, in whole or in part, at any time for legal, regulatory, security, operational, technical, or business reasons.

Such modifications may include changes to authentication mechanisms, cryptographic infrastructure integrations, supported blockchain networks, recovery processes, or security requirements. Where reasonably possible and where required by applicable law, Kleos will provide prior notice through appropriate communication channels, including in-platform notifications or website announcements.

Suspension or discontinuation of the Service does not affect blockchain transactions that have already been executed, which remain governed by the logic of the relevant blockchain network and smart contracts.

10. Governing Law

These Terms and any dispute, claim, or controversy arising out of or in connection with them, including non-contractual obligations, shall be governed by and construed in accordance with the laws of Ireland.

Subject to mandatory consumer protection provisions applicable in your jurisdiction of residence, the courts of Ireland shall have exclusive jurisdiction to resolve disputes arising from or in connection with these Terms.

Nothing in this Article limits any mandatory rights you may have under applicable consumer protection laws.