Naba Web3 Wallet — Terms of Service

Version 1.0, effective from May 8, 2026

PLEASE READ THESE TERMS OF SERVICE CAREFULLY AND CONSIDER WHETHER YOU HAVE ANY MISUNDERSTANDING OF THE TERMS OF SERVICE. ONCE YOU HAVE INDICATED YOUR CONSENT TO THE TERMS OF SERVICE, YOU THEREBY ACCEPT THESE TERMS OF SERVICE AND ENTER INTO A LEGALLY BINDING AGREEMENT WITH US GOVERNING THE TERMS AND CONDITIONS OF YOUR USE OF THE WALLET. IF YOU DISAGREE WITH ANY OF THE PROVISIONS OF THESE TERMS OF SERVICE OR DO NOT UNDERSTAND IT IN FULL, PLEASE DO NOT AGREE WITH THESE TERMS OF SERVICE AND IMMEDIATELY CEASE TO USE THE WALLET IN CASE YOU HAVE ALREADY STARTED TO USE IT (UNLESS YOU UNDERSTAND THE TERMS AND AGREE WITH IT). YOU MAY ADDRESS ALL OF YOUR QUESTIONS OR CONCERNS IN CONNECTION WITH THE TERMS OF SERVICE AT THE FOLLOWING PHYSICAL ADDRESS: BUILDING A1, DUBAI DIGITAL PARK, DUBAI SILICON OASIS, DUBAI, UNITED ARAB EMIRATES.

1. General Terms

1.1. These terms of service (“Terms”), being effective from May 8, 2026 (“Effective Date”), govern your (“you” or “your” or “User(s)”) use of the Wallet, and how we, Devnull FZCO, a free zone company organized and existing under the laws of the United Arab Emirates, holding commercial license No. 30069 issued by the Dubai Integrated Economic Zones Authority (DIEZ) and registered in the IFZA free zone, having its registered office at Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates (“Company”, “we”, “our” or “us”), provide services related to the Naba Web3 Wallet (“Services”, “Wallet” or “Naba Wallet”). Both Company and User collectively referred to as the “Parties” and individually as the “Party”.

By visiting, accessing and using the Wallet and any and all associated program interfaces and (or) mobile applications, you acknowledge and consent that:

i. you have the right, capacity and authority to accept these Terms;
ii. you have read and understood these Terms;
iii. you have no objections with regard to the policies and practices outlined in these Terms;
iv. you are bound by these Terms, along with any additional policies, including the Privacy Policy, as well as the terms of use of any integrating hosted services that are available to you via the Wallet, even if not explicitly referenced in these Terms. If you disagree with any part of these Terms or if these Terms conflict with the laws applicable in the country of your residence or citizenship, or if you are not willing to accept these Terms in full, you should not use the Wallet and must cease using it immediately;
v. we may update these Terms from time to time. The revised Terms will take effect when posted at https://wallet.naba.ae/terms, unless otherwise specified. Continued use of the Wallet after such updates will be considered as acceptance of the revised Terms. We may notify you of the changes by means other than publication, but we are not obliged to procure such notification;
vi. We process your personal data according to Applicable Laws and our Privacy Policy. Please find the actual version of the Privacy Policy at https://wallet.naba.ae/privacy. If you disagree with any of the provisions of the Privacy Policy, or do not understand it in full, please do not give your consent with these Terms and Privacy Policy, and immediately cease to use the Wallet, if you have already started such use.

For the purposes of these Terms, “Applicable Laws” means all applicable laws, regulations, rules, orders, decrees and circulars of the United Arab Emirates and the Emirate of Dubai, including but not limited to UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), UAE Federal Decree-Law No. 34 of 2021 on Combatting Rumours and Cybercrimes, and any laws or regulations applicable to you in your jurisdiction of residence or citizenship.

2. The Wallet

Naba Wallet is a free of charge, decentralised, non-custodial, seedless Web3 wallet built natively for ADI Chain that allows you to manage, send, and receive various digital assets, such as cryptocurrencies, securely. We do not hold or have access to your private keys. We do not hold or manage your digital assets, providing you with full control over your funds. We do not possess the technical ability to block, reverse, or monitor your transactions. You are solely responsible for your activity using the Wallet and any risk of loss at all times.

As a decentralised, seedless and privacy-preserving wallet, Naba Wallet features:

a. Decentralised Architecture:

i. Blockchain Integration: the Wallet interacts directly with ADI Chain and, where applicable, other blockchains, leveraging their decentralised and distributed ledger technology;
ii. Peer-to-Peer Transactions: Users can engage in peer-to-peer transactions without the need for an intermediary. Transactions are broadcasted and verified by the network nodes.

b. Seedless Self-Custody and Key Management:

i. Users retain control over access to their Wallet accounts, which are implemented using account abstraction and smart contract-based accounts. The Wallet is seedless, meaning no traditional seed phrase or mnemonic is generated, displayed, or required to be stored by the User;
ii. Access to the Wallet and authorisation of transactions is performed through authentication on the User’s device (such as PIN, biometrics, passkeys, or similar methods);
iii. Cryptographic keys used for transaction authorisation are generated and securely stored on the User’s device, leveraging the device’s secure enclave, trusted execution environment, or equivalent hardware-backed security where available;
iv. Such keys are encrypted and protected using security mechanisms provided by the User’s device and operating system (including, where applicable, PIN codes, biometrics, and secure hardware modules). Access to these keys requires successful authentication on the device;
v. Account recovery, where offered, is implemented through cryptographic mechanisms (such as social recovery, device-linked recovery, or passkey-based recovery) that do not grant the Company any access to or custody over the User’s keys or funds.

c. Identity and Privacy by Design (ZK):

i. UAE Pass Integration: access to certain functionalities of the Wallet may require identity verification via UAE Pass, the national digital identity service of the United Arab Emirates;
ii. Zero-Knowledge Proofs: identity verification is performed using zero-knowledge cryptography. The Company does not receive, store, or have access to your Emirates ID number, full name, date of birth, photograph, or other personal data held by UAE Pass. The Company only receives a cryptographic proof confirming that a unique, real, eligible person has authenticated, without revealing the underlying identity attributes;
iii. Minimal Data Footprint: the Wallet is engineered so that personally identifiable information processed by us is minimised by design. Where personal data is processed, it is processed in accordance with our Privacy Policy and the PDPL.

d. Security Measures: Communication between the Wallet and the User is encrypted to protect user data and transaction details. The Wallet is open-source, and its source code is publicly available for independent review.

e. No Custodial Control: the Company does not custody or control the User’s funds. Private keys remain in the User’s possession on the User’s device, reducing the risk of hacking or unauthorised access associated with centralised custodial services. The Company does not act as a financial institution, exchange, broker, custodian, or money services business.

3. Eligibility Criteria

In order to be eligible to use the Services, you warrant and represent that you meet the following cumulative eligibility criteria to access and use the Services:

i. You are at least eighteen (18) years of age or older;
ii. You are legally competent to enter into a binding contract with the Company under these Terms in accordance with the laws and regulations that apply to you, including laws on the capacity to enter into a legal agreement;
iii. You are not a person or entity, who reside in, are citizens of, are incorporated in, or have a registered office in locations that are subject to the Sanction Lists. “Sanction Lists” means any sanctions designations listed on economic, trade, embargo lists published by the international organisations, as well as any state and governmental authorities of any jurisdiction, including, but not limited to the lists of comprehensive trade or economic sanctions, embargoes, or similar restrictive measures administered or enforced by the United Arab Emirates (including the Executive Office for Control & Non-Proliferation and the UAE Local Terrorist List), the United Nations, the United States (including, without limitation, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC)), the European Union (or any of its Member States), the United Kingdom, or any other authority with relevant jurisdiction, or any domestic financial sanctions regime;
iv. You are not subject to any economic sanctions according to the United Nations Security Council Sanctions List, the UAE Local Terrorist List, the list of specially designated nationals maintained by OFAC, the denied persons or entity list of the U.S. Department of Commerce or any similar list maintained by any other relevant sanctions authority in the jurisdiction of your residence and/or citizenship;
v. You do not act on behalf of another person or legal entity that is included in the abovementioned Sanction Lists.

You must not use the Services if according to the laws of the jurisdiction of your current location/residence, the use of such kind of services is not allowed and will be regarded as illegal. By accepting these Terms and using Naba Wallet, you warrant that you are only using our Services with the funds that rightfully belong to you and were obtained on the basis of valid legal transactions (not criminal, fictitious or pretended).

4. Access and Use of the Wallet

To gain access to the Wallet, a User needs a personal account at the Wallet. Such an account is created when a User completes the onboarding process at the Wallet, which may include identity verification through UAE Pass.

The onboarding process may be changed by us from time to time in order to meet the requirements of Applicable Laws or our business or commercial needs.

Each time you provide any information for onboarding at the Wallet (including but not limited to information relating to your residence), you warrant us that such information is valid, true and accurate.

Only after completion of the onboarding, the User may log into its account at the Wallet.

Users are responsible for securely safeguarding access to their device, authentication factors (PIN, biometrics, passkeys), and any recovery credentials offered by the Wallet. Loss of access to your device, authentication factors, or recovery credentials may result in the loss of funds. You own and control your account and are solely responsible for safeguarding it; we do not store or have access to your private keys, recovery credentials, or funds. We are not responsible for any loss or theft of your private key(s), authentication credentials, or any funds stored in your wallet.

Users must independently verify transaction details, including recipient addresses and amounts, before confirming any cryptocurrency transaction. You accept and acknowledge that we are not responsible for any errors or omissions that you make in connection with any digital asset transaction initiated via our Wallet.

You must ensure that you have an adequate balance in your Wallet account to complete transactions before initiating a transaction. We shall not be liable for any failed transactions due to insufficient funds in your Wallet account or network fees associated with your transaction using the Wallet.

You may not use the Wallet for any illegal, fraudulent, or otherwise prohibited activities. In case if the Company learns about the illegal nature of activities for which our Service is used, we reserve the right to restrict, block or refuse provision of the Services to you. The list of such prohibited activities includes but is not limited to: unlawful activity, fraud, money laundering, terrorist financing, handling of criminal proceeds, intellectual property infringement, abusive activity, abusive actions against others, or any activity that violates Applicable Laws.

5. Third Party Services

The Wallet may include in-app/in-service access to certain third-party services, including token swaps, bridges, fiat on- or off-ramps, services to display balances in fiat currency, identity providers (including UAE Pass), or other integrated hosted services, which are offered by one or more third parties (“Third Party Services”).

Reference to a Third Party Service, including, but not limited to, providing a description or reference via hyperlink inside the Wallet, shall in no event be construed as an endorsement or promotion of such third party products or services by us.

We retain the exclusive right to add to, modify, or cancel the availability of any Third Party Services. We do not verify, curate or control any Third Party Services, and will have no responsibility for Third Party Services including, but not limited to, Third Party Services availability. You access, rely upon or use any Third Party Services at your own risk. We have no responsibility for Third Party Services that may be misleading, incomplete, erroneous, offensive, indecent, or otherwise objectionable to you or under the law in your jurisdiction. The choice to use a Third Party Service is your own, and you are solely responsible for ensuring that your reliance or use is in compliance with all applicable laws. Dealing or correspondence with any third party that provides such service is solely between you and that third party. Third Party Services may require you complete additional registrations, KYC procedures, verifications and checks, including identity verification from within the Wallet, or using third party platforms and interfaces.

In any case, your use of a Third Party Service shall be subject to a separate agreement between you and that third party and is not covered by these Terms. It is your responsibility to review the applicable terms of use of such services, including but not limited to eligibility requirements, restrictions related to certain localities, restricted persons, or any other eligibility-related conditions. You must independently decide whether to accept such terms and continue using the Third Party Service. You are solely responsible for reviewing these terms and ensuring that you meet all requirements set forth therein.

We reserve the right to change, suspend, remove, disable, or impose access restrictions or limits on the use of any Third Party Service at any time without notice.

6. Fees and Third-Party Charges

You use the Services free of charge. However, certain Third Party Services such as token swaps, bridges, fiat on- or off-ramps, or other integrated hosted services, may be subject to fees, commissions, spreads or other charges imposed by such Third Parties.

In addition, transactions conducted through blockchain networks (including ADI Chain) may require payment of network fees, which are determined by the applicable blockchain network and are not charged, imposed, or retained by us. For the avoidance of doubt, unless expressly stated otherwise, we do not receive any portion of blockchain network fees.

We do not control and are not responsible for any fees, commissions, exchange rates, spreads, or other charges imposed by Third Party Service providers or arising from the operation of any blockchain network. Any such amounts may vary at any time. Before initiating any transaction, you are solely responsible for reviewing and accepting all applicable fees and charges.

7. Limitations, Warranties and Disclaimers

WE DO NOT PROVIDE INVESTMENT OR FINANCIAL ADVICE OR CONSULTING SERVICES. WE ARE SOLELY THE PROVIDER OF THE SOFTWARE AND WE DO NOT ADVISE OR MAKE RECOMMENDATIONS ABOUT ENGAGING IN DIGITAL ASSET TRANSACTIONS OR OPERATIONS. DECISIONS TO ENGAGE IN TRANSACTIONS OR PERFORM OPERATIONS INVOLVING DIGITAL ASSETS SHOULD BE TAKEN ON YOUR OWN ACCORD.

You alone assume the sole responsibility of evaluating the merits and risks associated with your use of the Services, or any related service before making any decisions based on market information or content. You agree not to hold the Company, its agents liable for any possible claim for damages arising from any decision you make based on information made available to you through the Services, the Wallet, or any related service.

You acknowledge and agree that we have no control over, and no duty to take any action regarding: failures, disruptions, errors, or delays in the processing of digital assets that you may experience while using the Services; the risk of failure of hardware, software, and Internet connections; the risk of malicious software being introduced or found in the software underlying the Services; the risk that third parties may obtain unauthorised access to information stored within your wallet, including, but not limited to your wallet address, and private key(s); and the risk of unknown vulnerabilities in or unanticipated changes to the applicable blockchain networks.

You release us from all liability related to any losses, damages, or claims arising from user error such as forgotten authentication credentials, lost devices, incorrectly constructed transactions, or mistyped wallet addresses; server failure or data loss; unauthorised access to the Wallet; bugs or other errors in the Wallet software; and any unauthorised third party activities, including, but not limited to, the use of viruses, phishing, brute forcing, or other means of attack against the Wallet. We make no representations concerning any Third Party Services contained in or accessed through our Services. Any other terms, conditions, warranties, or representations associated with such content, are solely between you and such organisations and/or individuals.

The Wallet is provided on an “as is” and “as available” basis, and we make no warranties or representations of any kind, whether express or implied, including without limitation, any warranties of merchantability, fitness for a particular purpose, or non-infringement.

8. Indemnification and Limitation of Liability

You use the Services free of charge. Thus, you agree to indemnify and hold harmless the Company, its affiliates, subsidiaries, parent companies, contractors, licensors, and their respective directors, officers, employees, and agents (collectively, the “Indemnified Parties”) from and against any claims, actions, proceedings, investigations, demands, suits, costs, expenses and damages (including attorneys’ fees, fines or penalties imposed by any regulatory authority) arising out of or related to: (i) your use of the Services or conduct in connection with the Services, (ii) your breach or our enforcement of these Terms, or (iii) your violation of any applicable law, regulations of any jurisdiction or rights of any third party during your use of the Services.

To the maximum extent permitted by applicable law, in no event shall the Indemnified Parties be liable for any incidental, indirect, special, punitive, consequential or similar damages or liabilities whatsoever (including, without limitation, damages for loss of data, property information, revenue or profits, whether it be for business or financial benefit) arising out of or in connection with the access and use of any Services, any performance or nonperformance of the Services or any other product, Services or other items provided by or on behalf of Company whether under contract, statute, strict liability or other theory, except to the extent of a final judicial determination that such damages were a result of the gross negligence, fraud, willful misconduct or intentional violation of the law.

You indemnify and accept full release of liability of Indemnified Parties for your use of Third Party Services.

NOTWITHSTANDING THE FOREGOING, IF THE LIABILITY OF THE INDEMNIFIED PARTIES CANNOT BE EXCLUDED COMPLETELY UNDER LAW, IN NO EVENT SHALL THE LIABILITY OF INDEMNIFIED PARTIES, EITHER SEPARATE OR CUMULATIVE, ARISING OUT OF OR IN CONNECTION WITH THE SERVICES, ANY PERFORMANCE OR NONPERFORMANCE OF THE SERVICES OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM PROVIDED BY OR ON BEHALF OF THE COMPANY WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY, EXCEED 10,000.00 USD (TEN THOUSAND UNITED STATES DOLLARS).

9. Liability of Users

You shall be solely liable for any damage resulting from any improper use of Services, infringement of copyrights, proprietary rights, or any other harm resulting from such use of the Services. The foregoing provisions of this section are for the benefit of the Company, its subsidiaries, affiliates, and agents and licensors, and each shall have the right to assert and enforce such provisions directly or on its own behalf.

We reserve the right to terminate or suspend your access to the Wallet without notice for any reason, including violation of these Terms.

10. Risk Disclosure

In using the Services, you understand and acknowledge that underlying blockchain protocols, smart contracts, and DeFi protocols are subject to inherent risks and that you use the Services at your own risk. You shall, therefore, carefully consider whether the use of the Wallet is suitable for you in light of your circumstances and financial resources.

You accept the risk of loss associated with your digital assets as a result of using the Service. Company is not able to control or safeguard your assets on decentralised protocols. While using the Services, your digital assets are not subject to any regulatory or consumer protection scheme, or arrangement for protection against losses. There may be partial or total loss of your digital assets arising out of the Service, including due to the nature of the service, as well as reasons outside of our control. Company in no circumstances shall be liable to you for such losses, and there may be no remedy available in case of loss of your digital assets, including and up to a total loss of digital assets.

You also acknowledge that the Company is not liable for the defamatory, offensive, or illegal conduct of other users, and that you alone are assuming the risk of injury from the foregoing, to the fullest extent of the law.

You further acknowledge the volatility risk of digital assets, the risk of regulatory changes that may affect the legality or use of digital assets in your jurisdiction, smart contract risk (including bugs, exploits, and economic attacks), bridge and cross-chain risk, and the risk that the value of digital assets may fluctuate substantially or fall to zero.

11. License

In your use of the Services, we grant you a non-exclusive, non-sublicensable and non-transferable license to use Naba Wallet for your personal use only.

The Naba Wallet client software is open-source and is made available under the license set forth in its source code repository at https://github.com/Naba-Finance. Your use of the open-source components is governed by the applicable open-source license. The Terms set forth herein govern your use of the hosted Services made available by the Company at https://wallet.naba.ae and through the official Company-published mobile applications.

Except as otherwise expressly permitted in these Terms or in the applicable open-source license, you will not: rent, lease, distribute, sell, sublicense, transfer, or provide access to the hosted Services for the benefit of any third party in a manner that competes with the Company; incorporate the hosted Services into a product or service you provide to a third party without our prior written consent; circumvent mechanisms in the Wallet intended to limit your use; remove or obscure any proprietary or other notices contained in the Wallet; or use the Wallet for competitive analysis to build competitive products that infringe our rights or the rights of third parties.

12. Taxes

You understand and are fully aware that using the Service performed may have certain tax and legal implications and you take full liability for any tax or legal consequences that might arise from transactions pertaining to your assets. It is your sole responsibility for paying any taxes applicable to you in relation to using the Wallet. The Company does not and cannot advise you on the tax consequences of your use of the Wallet. The Company makes no representations in relation to tax liabilities. We also assume no responsibility for your tax liability or for collecting, reporting, withholding or remitting any taxes arising from the Wallet that you may use. In case we are obliged under applicable law or voluntarily decide to report to any government authorities any information that is related to your tax obligations, you undertake to provide us with the requested documents, data and information.

13. Force Majeure

We will not be liable for delays in performance or for non-performance due to unforeseen circumstances or causes beyond our reasonable control, including but not limited to acts of God, war, civil unrest, government restrictions, blockchain network outages, hard forks, regulatory changes, or cyberattacks. You furthermore agree and understand that in the event of a market disruption, we may, in our sole discretion, do one or more of the following: (i) suspend access to the Services; or (ii) prevent you from completing any actions via the Services. We are not liable for any losses suffered by you resulting from such actions.

14. Entire Agreement, Other Terms

These Terms are the entire agreement between you and the Company relating to the Services. If any provision of these Terms is held to be void, invalid, unenforceable or illegal, the other provisions shall continue in full force and effect.

The headings contained in these Terms are for reference purposes only and shall not affect the meaning or interpretation of these Terms.

The failure of Company to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision in that or any other instance.

If any provision of these Terms shall be determined to be invalid or unenforceable under any rule, law, or regulation of any local, state, or federal government agency, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of these Terms shall not be affected. If such construction is not possible, the invalid or unenforceable portion will be severed from these Terms but the rest of the Terms will remain in full force and effect.

15. Notices

Any notice to us in connection with these Terms shall be in English and delivered to us by electronic mail at legal@naba.ae.

Any notice to you in connection with these Terms shall be in English and delivered to you at your e-mail address to which your account is linked or at the relevant section of the Wallet relating to the notices to you.

A notice given by e-mail will be effective upon receipt and shall be deemed to have been received on the next Business Day after being sent by e-mail, if a notice is given by e-mail (as recorded on the device from which the sender sent the e-mail), unless the sender receives an automated message that the e-mail has not been delivered, provided that where delivery occurs outside normal working hours (being 9.00 a.m. to 6.00 p.m. Gulf Standard Time, Sunday to Thursday in the United Arab Emirates), the notice shall be deemed to have been received at the start of normal working hours on the next following Business Day.

We will process your notice as soon as reasonably practicable, but in any event within 15 Business Days from the date of its receipt by us, and will resolve the issue in good faith.

16. Governing Law

These Terms are governed by the federal laws of the United Arab Emirates as applicable in the Emirate of Dubai, without giving effect to any conflicts of law principles.

For the avoidance of doubt, these Terms will not be governed by the United Nations Convention on Contracts for the International Sale of Goods, the application of which is expressly excluded, as the Terms contemplate no sale of goods.

17. Dispute Resolution

Unless otherwise set forth in these Terms, any dispute, controversy or claim arising out of or in connection with these Terms, or a breach, termination or invalidity of these Terms, must be settled by negotiation between the Parties, and if it remains not resolved within 60 calendar days, it shall be referred to and finally resolved by the competent courts of the Emirate of Dubai, United Arab Emirates.

Notwithstanding anything contrary to the above, any Party to these Terms may seek injunctive or other equitable relief from the courts for matters related to privacy, intellectual property or security of the normal operation of the Wallet.

The Parties to these Terms waive their rights to a jury trial or class action for any dispute arising out of these Terms.

18. Contact

Devnull FZCO Building A1, Dubai Digital Park, Dubai Silicon Oasis Dubai, United Arab Emirates Commercial License No. 30069 (DIEZ)

E-mail: legal@naba.ae Website: https://wallet.naba.ae