Version: 2.4 | Last Updated: August 6, 2026
This document establishes the Terms and Conditions (hereinafter the "Terms and Conditions") that will govern the relationship between the applicable Blink entity (as identified in the Contracting Entity section below) (hereinafter "Blink") and you as a User (hereinafter the "User"); for the use of the services provided by Blink through the Wallet (as defined below).
Your agreement is with one of the following Blink entities, depending on your status and country of residence:
Throughout these Terms and Conditions, "Blink" refers to the applicable contracting entity based on your status and country of residence. References to specific entities (e.g., "Blink El Salvador, S.A. de C.V.," "Blink US LLC," or "Blink LLC") are used where provisions apply only to users of that entity. Provisions that refer to "Blink" generally apply to all entities and their respective users.
For purposes of these Terms and Conditions, a “US Person” means: (a) any natural person who is a citizen or national of the United States, a lawful permanent resident of the United States, or an individual whose primary residence is in the United States; (b) any entity organized or incorporated under the laws of the United States or any state or territory thereof; (c) any trust of which a trustee is a US Person, or any estate the income of which is subject to United States federal income tax; or (d) any entity, regardless of its place of incorporation or registration, whose primary operations, principal place of business, or predominant end-user base is located in the United States. Where you are a US Person, whether by reason of individual status or entity classification, your contracting entity is Blink US LLC and the US-specific provisions of these Terms and Conditions apply to you.
The Platform and its underlying technology are developed and maintained by Blink Technologies, LLC (Próspera Permit No. 85348155380061), a limited liability company organized under the Roatán Common Law Code of Próspera ZEDE, with registered address at Beta Building, Oficina 6, Próspera ZEDE, St. John’s Bay, Roatán, Islas de Bahía 34101, Honduras ("Blink Technologies"). Blink Technologies is an affiliate of the Blink entities and licenses the technology and provides infrastructure services to Blink El Salvador, S.A. de C.V., Blink US LLC, and Blink LLC. Blink Technologies provides technology infrastructure and delegated custody services on behalf of the applicable Blink entity, under the direction and supervisory oversight of that entity pursuant to a Master Licensing and Services Agreement. The applicable Blink entity retains regulatory responsibility for the safeguarding of customer assets and maintains oversight of Blink Technologies’ custody operations, including audit rights and regulatory access. Your contractual relationship is with the applicable Blink entity identified above — not with Blink Technologies directly.
The acceptance of these Terms and Conditions by the User is necessary for the use of the Wallet. In case the User does not agree with them, it is requested to refrain from the use of the Wallet; otherwise they will be understood as accepted and will apply what is established herein.
By accepting the Terms and Conditions, the User understands and approves the sending of text messages (SMS), push notifications, emails, among others from Blink and/or third parties that it determines, all directly or indirectly related to the use of the Wallet and its products, services, customer service, updates, bugs, etc.
The information and data entered into the Wallet is used for the purposes described in Section 6 (Informed Consent — Protection of Personal Data) and, in full detail, in the Blink Privacy Policy.
These Terms and Conditions govern the contract for the provision of Bitcoin and digital asset wallet services, card services through Partner Services, and other related services entered into by and between Blink and You, in your own capacity and on your own behalf. By accessing and/or using Blink’s Services and the Wallet (as defined below), or any other electronic means enabling you to use any Service provided by Blink, you accept these Terms and Conditions, which shall be valid and effective upon your use of the Services.
The User acknowledges and agrees that Blink may modify these Terms and Conditions at any time, provided that it gives prior notice through the Wallet to its Users with at least 30 (thirty) days’ notice. For material changes, Blink will clearly identify the modifications and request the User’s affirmative acceptance; if the User does not accept, the User may terminate their account without penalty during the notice period. For non-material changes, continued use of the Platform after the notice period constitutes acceptance. The User undertakes to periodically review the Terms and their applicability.
For the avoidance of doubt, changes to the availability of Services, features, modes of operation, or Supported Assets (as defined in Section 7.6) in any jurisdiction — including the restriction, suspension, or discontinuation of any Service in a jurisdiction pursuant to these Terms and Conditions — are changes in service availability, not modifications of these Terms and Conditions, and are governed by the notice and exit provisions of Section 17 (and Sections 7.6 and 7.7, where applicable) rather than by the modification-notice mechanism in the preceding paragraph.
The use and access to our site or our Services are not permitted from those states or jurisdictions where, in accordance with various legal and regulatory prohibitions, (i) it is not possible to carry out such operations with Bitcoin or card services, or (ii) where Blink considers that there is a risk of operation by conducting transactions in certain jurisdictions and/or where Blink considers that such operations are not feasible. Depending on the location of the User’s connection, some Services may not be available. Blink shall not be liable for the actions taken by User in contravention of this provision. Blink employs geo-restriction measures to limit access to Services based on the User’s location. Users must not circumvent these restrictions. If a User accesses Services that are not available in their jurisdiction, Blink may suspend or terminate the User’s account without liability.
For Users whose contracting entity is Blink El Salvador, S.A. de C.V., the services are directed towards Salvadorans and duly identified foreigners, and the relationship shall be governed by Salvadoran law. For Users whose contracting entity is Blink US LLC, the relationship shall be governed by the laws of the State of Wyoming (the US service limitations stated in the Contracting Entity section apply). For Users whose contracting entity is Blink LLC, the relationship shall be governed by the laws of Próspera ZEDE. Not all Services, features, or modes of operation are available in all jurisdictions. Blink restricts and limits the availability of specific features, including Custodial Mode, Non-Custodial Mode, the Dollar Balance, the Blink Card, or other Services, based on the User’s location and applicable regulatory requirements. Regardless of your contracting entity, all Users are subject to the jurisdiction-specific provisions set forth in these Terms. Card services provided through Partner Services are subject to the governing law provisions of the applicable Cardholder Agreement.
Blink may from time to time offer additional services, programs, or features not described in these Terms and Conditions. Such services will be governed by their own terms and conditions, which will be made available to eligible Users within the Wallet or through other channels. To the extent of any conflict with these Terms and Conditions, the terms governing such additional services will take priority with respect to those services.
For the purposes of these Terms and Conditions, the terms set forth below shall have the following meaning:
"API" (Application Programming Interface) means the Blink programmatic interface, including the GraphQL API, webhooks, OAuth2 integrations, and any related developer tools, documentation, and endpoints made available at dev.blink.sv or such other URL as Blink may designate, through which Users may access the Services programmatically. The API is available only in Custodial Mode.
"Backup Phrase" means the recovery phrase (also known as a seed phrase or mnemonic) generated when a User activates Non-Custodial Mode, which is the sole means of recovering access to the User’s non-custodial funds. Blink does not store or have access to the User’s Backup Phrase.
"Blink" refers to the applicable contracting entity (Blink El Salvador, S.A. de C.V., Blink US LLC, or Blink LLC, as applicable) as identified in the Contracting Entity section above.
"Cardholder Agreement" is the agreement governing the use of the Blink Card, available at Blink Card Cardholder Agreement.
"Blink Card" is a Visa-branded card issued by Third National, LLC, a lender licensed by the Commonwealth of Puerto Rico (the "Issuing Bank"), with Signify Holdings, Inc. (the "Program Manager") acting as program manager and issuing sponsor, and Blink Technologies providing the technology platform (the "Technology Provider" in connection with the card program). The Blink Card currently operates in Funded Mode; a Credit Mode may be activated in the future. Its features, modes, and use are described in Section 3.2 and governed by the Cardholder Agreement.
"Custodial Mode" means the mode of operation in which the User’s Bitcoin Balance and Dollar Balance are held and managed by Blink (through Blink Technologies as its infrastructure service provider) on behalf of the User. In Custodial Mode, Blink maintains custody of the User’s funds and the User does not hold private keys directly.
"Dollar Balance" means the USD-equivalent balance feature available within the Wallet, which allows Users to hold, send, and receive a stable USD-denominated balance. The Dollar Balance operates differently depending on the User’s selected mode: in Custodial Mode, it uses Stablesats (a hedging-based mechanism that maintains USD-equivalent value); in Non-Custodial Mode, it uses stablecoins held on the Non-Custodial Protocol.
"Non-Custodial Mode" means the mode of operation in which the User’s Bitcoin Balance and Dollar Balance are held using the Non-Custodial Protocol, where the User retains control of their funds through cryptographic keys. Custody and control in Non-Custodial Mode are addressed in Sections 2.5, 7.4, and 10.3. Non-Custodial Mode is available only through the Wallet and is not available via the API.
"Non-Custodial Protocol" means the Spark protocol (developed by Lightspark), a federated state chain Layer 2 protocol built on Bitcoin, or such other non-custodial protocol as Blink may support from time to time. The Non-Custodial Protocol enables Users to send, receive, and hold Bitcoin and supported stablecoins where the User retains control of their cryptographic keys rather than Blink maintaining custody. The protocol operates through a federated network of operators; see Section 7.4(c) for associated risks.
"Partner Agreements" are the separate agreements between the User and Blink’s Partners that govern the use of Partner Services, including the Cardholder Agreement for the Blink Card. Partner Agreements are made available in the Wallet and linked in the Related Documents section below.
"Partner Services" are products and services made available through the Platform that are offered and provided by third parties ("Partners") rather than by Blink directly. Partner Services are governed by separate Partner Agreements between the User and the respective Partner.
"Platform" means, collectively, the Wallet and the API, and any other interface, website, or access method through which Blink makes the Services available to Users.
"Stablesats" is the technology underlying the Dollar Balance feature when operating in Custodial Mode. Stablesats maintain a USD-equivalent value through hedging positions on third-party platforms that reference an underlying asset, where $1 in Stablesats equals $1 USD worth of satoshis. Stablesats are not legal tender, are not stablecoins, and are not backed by a State or government entity. Stablesats are not used in Non-Custodial Mode.
"User" means any natural or legal person who meets the criteria defined by Blink, creates an account, accepts these Terms and Conditions, and accesses the Services through the Platform (whether via the Wallet, the API, or any other supported access method), as well as compliance with any other requirement that the owner of the service determines.
"Wallet" (also referred to as the "App" or "Application") means the digital wallet application for mobile phones and other devices, owned and operated by Blink, through which the User may perform various activities such as: (a) make bitcoin or money transfers in real time between users; (b) pay for utilities such as drinking water, electricity, telephone services, and internet; (c) manage the receipt of incoming payments; (d) apply for and use Partner Services, including the Blink Card and related card services; hereinafter the "Services". The Wallet supports both Custodial Mode and Non-Custodial Mode. The Wallet is one of the interfaces through which Users may access the Services; the API provides an alternative programmatic interface to Custodial Mode Services only. The availability of Services, interfaces, modes, and features is governed by the Applicable Terms section and Sections 2.6, 7.6, and 17.
2.1 User Responsibility. The User will be entirely responsible for the transactions that he decides to carry out in the Wallet, as well as the entry and download of information since it is considered that it is the property of the user, so it is within his domain and possession. Likewise, you understand and accept that in case Blink must face an administrative or judicial process as a result of the transactions or information entered or downloaded by the User, he will be directly involved in the process and depending on the results of the same he must personally respond to them.
2.2 Information Validation and Monitoring. The User accepts that Blink reserves the right to use all means of requesting validation of information that it deems proportionate and convenient, in order to guarantee the correct use of the Wallet.
Blink, directly or through authorized natural or legal persons, may actively monitor all activities, components, operations, and solutions related to the Wallet and its Information Resources, as permitted by applicable law. "Information Resources" means the information to which access is granted and the computer, physical, and/or active information resources that compose, form part of, or support the Wallet. The purposes of such monitoring include: (a) preventing cybersecurity risks; (b) protecting Users and the integrity of the Wallet; (c) ensuring compliance with these Terms and Conditions; (d) complying with applicable regulations on intellectual property, data protection, AML/CFT, consumer protection, and applicable financial regulatory requirements; and (e) preventing unauthorized or illegal actions.
If violations of these Terms and Conditions, applicable regulations, or irregular behavior are identified, Blink may take administrative, civil, criminal, and/or precautionary measures as permitted by the applicable legal framework, including but not limited to the suspension and/or immediate elimination of access. Such measures may include actions to analyze, investigate, track, collect evidence, and defend against attacks or irregular behavior. The User understands and accepts that they must respond civilly, criminally, and administratively to any irregular action, including those that may affect third parties, and must provide total indemnity and hold Blink harmless from all consequences arising from their action or omission.
2.3 Data Accuracy. The User understands and accepts that all the data and information that enters or to which it is processed through the Wallet and that it makes available to Blink will have a preliminary validation that it is totally true, so by accepting these Terms and Conditions the User expressly empowers Blink, its processors and other technology intermediaries to use it in the context of the Terms and Conditions in force, as well as on the occasion of the operation, support and maintenance of the Wallet and for the provision of the Services to the User, as permitted by the applicable legal system. When the information refers to personal data, the informed consent of the User included herein will apply.
2.4 Mobile Application Requirements. The User understands and accepts that many of the functionalities of the Wallet will be found in the mobile application for which he must bear in mind the following conditions:
a) The operating system of the mobile phone must be free of vulnerabilities and it is solely responsible for ensuring that your mobile phone is updated to the latest version of the respective operating system, that it is free of any code and/or malicious program, that the respective patches indicated by its manufacturers have been applied and that it has antivirus and antimalware applications suitable for the device concerned.
b) Currently the Wallet will be used only by natural persons over eighteen (18) years of age, so in this act parents or legal guardians are requested to take the appropriate measures to avoid access to it. In case the foregoing is ignored and any minor manages to register in the Wallet, it will be understood that he does it under the direct authorization of his legal representatives, being these responsible for each of the actions or omissions carried out by said minors, being considered for all purposes, that the respective actions or omissions were carried out by the Users responsible for the account.
c) The Wallet requires a stable, secure and good speed internet connection to provide the best user experience. Blink is not and will not be responsible, in any case, for transactions that the User cannot carry out because they lack an internet connection that complies with the conditions described above.
d) The User understands and accepts that, due to the nature of bitcoin, the transfers made through the Wallet are final and irreversible, so that once the respective transaction has been concluded, it cannot be reversed or canceled.
2.5 Custodial and Non-Custodial Modes. The Wallet offers two modes of operation: Custodial Mode and Non-Custodial Mode (each as defined in Section 1). The User acknowledges and accepts that:
a) The availability of each mode may vary by jurisdiction and over time. In some jurisdictions only one mode may be available; in others, either or both modes, or particular features within a mode, may be unavailable, limited, or discontinued. Blink reserves the right to determine which modes and features are available in each jurisdiction based on regulatory requirements and operational considerations, and to change those determinations as regulatory requirements evolve, subject to the notice and exit provisions of Section 17 where existing Users are affected.
b) Users may select their preferred mode within the Wallet where both modes are available. Users may hold balances in both modes simultaneously where supported.
c) Custodial Mode and Non-Custodial Mode have fundamentally different characteristics regarding custody, risk, and the User’s responsibilities. In Custodial Mode, Blink holds funds on behalf of the User and can assist with account recovery. In Non-Custodial Mode, the User holds their own funds and Blink cannot access, recover, or restore them under any circumstances. The User is solely responsible for understanding these differences before selecting a mode.
d) Certain features and services may be available only in one mode. In particular, the API operates exclusively in Custodial Mode, and Non-Custodial Mode is available only through the Wallet application.
e) The Dollar Balance operates differently in each mode: using Stablesats (a hedging-based mechanism) in Custodial Mode, and stablecoins on the Non-Custodial Protocol in Non-Custodial Mode. Each carries its own distinct risk profile as described in Section 7.
2.6 Identity Verification. Blink may request at the time of creating an account a photograph of the User with movement, as well as any suitable identity document such as proof of life and identity verification. The User undertakes to provide Blink with any information necessary to comply with the established security mechanisms.
Identity verification and liveness checks are performed by third-party identity verification providers, as identified in the Blink Privacy Policy. The provider used for your verification may depend on your jurisdiction, the type of verification required, or other operational factors. By completing the identity verification process, the User acknowledges and consents to the transmission of their personal data — including government-issued identification documents, facial images, and biometric data (facial geometry) — to the applicable provider for processing in accordance with that provider's privacy notice (as linked in the Blink Privacy Policy) and the Blink Privacy Policy. The User’s biometric data will be retained and destroyed in accordance with the retention schedule described in the Blink Privacy Policy. For complete details on the processing of personal data in connection with identity verification, including jurisdiction-specific biometric data disclosures, see the Blink Privacy Policy.
Blink may also request documentation evidencing a User's country or countries of residence (for natural persons) or a User's jurisdiction of incorporation, registered office, and ownership and control structure (for legal persons). Blink uses such documentation, together with other account signals, to determine the jurisdiction(s) attributed to a User's account, and the attributed jurisdiction(s) determine which Services, features, and modes are available to the User under these Terms and Conditions. Users must disclose all current residences accurately and completely and keep such information up to date; provision of false, incomplete, or misleading residence or incorporation information is a breach of these Terms and Conditions. Where a User's documentation or account signals evidence more than one current residence, Blink may apply the most restrictive availability determination among the relevant jurisdictions.
2.7 Background Checks. The User authorizes Blink or a third party contracted by it, to request at any time and without prior notice, commercial, banking, financial and/or reputational references of its own, to review any public or private database as part of the study requirements and in general, to make the respective analysis of all Users of the Wallet, in any repository of physical or digital information, as well as to inquire about the behavior of such Users, as permitted by applicable regulations.
2.8 Transactions Responsibility. For the security of our Users, we do not assume any responsibility, nor shall we be held liable in any manner, for any transmission of Cryptoassets that has been carried out in accordance with the instruction and information provided by the User. The User acknowledges and agrees that transfers from their Wallet, regardless of the identity of the beneficiary or recipient of such operation, are carried out under their sole responsibility, and except to the extent prohibited by applicable law, Blink shall not be held responsible. Losses due to fraudulent or accidental transactions may not be recoverable, and additionally, once they have been confirmed, the User will be obligated to fulfill them. Blink bears no responsibility for any operations carried out by Users when they are fraudulent or accidental or result from negligence on the part of Users in safeguarding their public access keys or private passwords, as established in these Terms and Conditions. Card transactions are subject to the dispute and fraud protection provisions in the Cardholder Agreement.
2.9 Lawful Use. The User acknowledges and guarantees that the income used for the various transactions within the Wallet comes from lawful activities, also guarantees that he is not involved in money laundering, financing of terrorism, or other illegal activities and that, he knows of the existence of anti-laundering and anti-corruption laws and decrees where any type of fraud or illegality that he intends with the use of the Wallet could have civil, criminal and any other sanctions that the law indicates, in addition to the closure, suspension and deletion of your account.
2.10 Taxes. The User understands and accepts that it will be at his account the payment of all taxes, fees, contributions, services, tax species or any other current or future tax charges levied on Blink services.
2.11 Registration. To be able to use the Wallet, as well as all Services, you must be of legal age or, failing that, access under the supervision and consent of your parents or legal guardian. Any access or use by persons legally incapable of contracting is prohibited and the responsibility of their legal representative. The Blink Card is available only to individuals aged 18 and over regardless of parental or guardian consent. By continued use of the Wallet, as well as acceptance of these Terms and Conditions, the User acknowledges and agrees that they must be registered in accordance with Blink's applicable policies. Any access or use by persons under eighteen (18) years of age or otherwise legally incapable of contracting is prohibited and the responsibility of their legal representative. By continued use of the Wallet, as well as acceptance of these Terms and Conditions, the User acknowledges and agrees that they must be registered in accordance with Blink’s applicable policies.
It will be necessary to create an account on the platform to use some of our Services. For this purpose, you will be asked for a password and a username, as well as some data for registration. You must provide accurate, complete, and up-to-date information. In the event that such information undergoes modifications, you agree that it will be your responsibility to keep it up to date and updated; always ensuring that it is complete and accurate information. Failure to do so constitutes a violation of the Conditions and could result in the immediate cancellation of the account.
Upon registration, each User will receive an internal code which, along with their registered email and registered phone number, will serve as identifying and individualizing data of the User to the Platform. In order to access the Platform, it will be necessary for you to undergo an identity verification process that may be carried out by Us or through third parties. As a username, you may not use the name of another person or entity over which you have no rights, nor any name or mark whose rights belong to another person or entity unless you have the proper authorization, nor any name that is offensive, vulgar, or obscene. Additionally, the opening of accounts to robots or automated methods is prohibited.
Subject to these Terms and Conditions, and all our policies, the User is granted a personal, limited, non-exclusive, non-transferable, and fully revocable license to use our Services.
3.1 Partner Services Overview. Some products and services available through the Wallet are provided by third-party Partners rather than by Blink directly. By applying for or utilizing Partner Services, the User accepts the applicable Partner Agreements, which are separate agreements between the User and the respective Partner. Some Partner Services may not be available to the User depending on the level of identity verification the User has completed, and Blink reserves the right to require any level of or additional identity verification to access any Partner Service, in its sole discretion.
3.2 Blink Card. As part of the Partner Services, Users may apply for the Blink Card and associated Card Balance (as defined in the Cardholder Agreement). The Blink Card is issued by the Issuing Bank, with the Program Manager acting as issuing sponsor, and the Technology Provider providing the technology platform. The Cardholder Agreement governing use of the Blink Card is available at Blink Card Cardholder Agreement. By applying for the Blink Card, the User authorizes: (a) credit underwriting, identity verification, and eligibility checks (including credit checks and review of financial information); (b) sharing of necessary information with the Issuing Bank, the Program Manager, and the Technology Provider; and (c) credit bureau reporting (including payment history, account status, balances owed, and any default or delinquency information) in accordance with applicable law and the Cardholder Agreement. The User acknowledges that the Blink Card currently operates in Funded Mode (prepaid), and that Credit Mode (a collateral-backed credit facility issued by the Issuing Bank) may be activated in the future in accordance with the Cardholder Agreement. The authorizations granted in this Section 3.2 (including credit underwriting, credit checks, credit bureau reporting, and sharing of financial information) apply to the Blink Card in Funded Mode. Upon activation of Credit Mode, Blink or its Partners will request the User’s separate consent for any additional credit underwriting, credit checks, or credit bureau reporting required for Credit Mode, in accordance with applicable law. Use of the Blink Card is subject to the terms, fees, and conditions set forth in the Cardholder Agreement, which shall govern in the event of any conflict with these Terms and Conditions regarding card services.
3.3 Additional Partner Services. Additional Partner Services may be added from time to time and will be subject to their respective Partner Agreements.
4.1 Availability. Blink provides the API as an alternative means of accessing the Services. The API operates exclusively in Custodial Mode — Non-Custodial Mode is not available via the API. Users whose contracting entity is Blink US LLC are not eligible for API access; this Section 4 does not apply to US users. The API allows Users to programmatically send and receive Bitcoin and Stablesats via the Lightning Network and on-chain, manage wallet balances, and integrate Blink’s Services into third-party applications, websites, and systems. API documentation is available at dev.blink.sv or such other URL as Blink may designate.
4.2 API Credentials. To access the API, Users must register an account and obtain authentication credentials (including API keys, tokens, or OAuth2 credentials). Users are solely responsible for the security and confidentiality of their API credentials. Any activity conducted using a User’s API credentials shall be deemed authorized by that User. Users must notify Blink immediately if they believe their API credentials have been compromised.
4.3 Permitted Use. The API may be used to build applications, integrations, and services that interact with the Services, provided such use complies with these Terms and Conditions, applicable law, and any usage guidelines published in the API documentation. Users shall not: (a) use the API for any unlawful purpose or in violation of these Terms; (b) attempt to circumvent rate limits, authentication mechanisms, or other technical restrictions; (c) reverse engineer, decompile, or otherwise attempt to derive the source code of the API (except to the extent permitted by applicable open-source licenses); (d) use the API in a manner that could damage, disable, or impair the Services or interfere with other Users’ access; or (e) resell or redistribute access to the API as a standalone service without Blink’s prior written consent; (f) use the API to operate, facilitate, or provide a money services business, money transmission service, payment processing service, or any similar financial service to third parties, whether licensed or unlicensed, without Blink’s prior written approval and evidence of all required regulatory licenses in each jurisdiction of operation; (g) use the API to offer custodial wallet services, payment facilitation, or transaction processing to the User’s own customers or end users in any jurisdiction where such Services are not available due to regulatory or licensing limitations; or (h) fail to maintain all regulatory licenses, registrations, and authorizations required by applicable law in connection with the User’s use of the API and the Services.
4.4 Rate Limits and Availability. Blink may impose rate limits, usage quotas, or other technical restrictions on API access at any time. The API is provided on an "as-is" and "as-available" basis. Blink does not guarantee uninterrupted or error-free API availability and shall not be liable for any downtime, latency, or service degradation affecting the API.
4.5 Third-Party Applications. Users who integrate the API into third-party applications are responsible for ensuring that their applications comply with these Terms and Conditions and applicable law. Users shall not represent or imply that their third-party applications are endorsed, certified, or sponsored by Blink unless expressly authorized in writing. Users are responsible for providing their own terms of service and privacy policies to the end users of their third-party applications.
4.6 Open Source. Certain components of Blink’s software are available under open-source licenses as described in Section 19 (IP Rights). The availability of open-source components does not alter or expand the rights granted under these Terms with respect to the API or the Services.
4.7 Modifications and Deprecation. Blink reserves the right to modify, update, or deprecate any part of the API at any time, with reasonable notice where practicable. Blink will endeavor to provide advance notice of breaking changes through the API documentation or developer communication channels, but shall not be liable for any costs or disruptions arising from API changes.
4.8 Applicability of General Terms. Except as specifically addressed in this Clause, all other provisions of these Terms and Conditions apply equally to Users accessing the Services via the API, including but not limited to provisions relating to transactional limits, data protection, regulatory compliance, security, and prohibited activities.
The User acknowledges and accepts that Blink reserves the right to establish limits on amounts to transfer and receive money. For card transactions, limits will be established by the Issuing Bank and the Program Manager based on the User’s Available Balance, Collateral, and other factors as detailed in the Cardholder Agreement. For wallet transactions, limits will be subject to the provisions of current legislation, levels of transactionality, risk policy, as well as any internal policy of the operating company of the wallet.
To the extent permitted by applicable law, Blink will not be liable for the impossibility to carry out transactions by the User, regardless of whether that transaction could not be carried out due to insufficient funds, error in information provided by the User, services suspended, internet connection problems, temporary or permanent defects in the User’s mobile phone or cell phone service, technological failures of Blink’s own infrastructure or third parties, due to suspicious transaction, or any other cause within Blink’s normal operational scope. For liability limitations arising from events beyond Blink’s control, see Section 13 (Force Majeure).
Blink, in order to better manage the information shared by Users, has a policy of protection of personal data and informed consent which has as its maximum premise the respect of the rights of the User, with total transparency and in compliance with the applicable regulations on the protection of personal data. For the purposes of information to the User, Blink is established as responsible for the personal data obtained by the use of the Wallet.
By accepting these Terms and Conditions, the User expressly authorizes Blink to collect, use, store, share, transfer (including internationally), and otherwise process the User’s personal data — including, for security purposes only, sensitive and biometric data — for the purposes, on the legal bases, and with the recipients described in the Blink Privacy Policy, which forms part of these Terms and Conditions. This authorization includes processing by Blink Technologies as Blink’s technology and infrastructure service provider, and sharing with Partners, service providers, and credit bureaus and financial institutions as necessary for the Services and Partner Services, in each case as described in the Blink Privacy Policy. Blink remains responsible for the protection of User data, and the User may exercise their rights by contacting Blink directly (privacy@blink.sv).
The authorization granted in this clause may be revoked at any time by the User, sending an email to the address support@blink.sv. The User may also request access, rectification, cancellation, deletion and/or opposition of the shared information. The User understands and accepts that any request and modification of information will not be retroactive, so it will enter into force in our databases 5 business days from the date of the request. The effects of retroactivity will be extended to the transactions made, as well as any internal or external investigation process that is in process. At the time of expressing his desire for revocation, the User accepts that he will not be able to continue using the Wallet and its services, proceeding to delete his account.
For complete details on how Blink collects, uses, stores, shares, and protects your personal data — including jurisdiction-specific data protection rights under applicable law — see the Blink Privacy Policy. In the event of any conflict between this Section 6 and the Blink Privacy Policy regarding the collection, use, or protection of personal data, the Blink Privacy Policy shall prevail.
The Dollar Balance feature enables Users to hold a USD-equivalent balance within their Wallet. The Dollar Balance operates differently depending on whether the User is in Custodial Mode or Non-Custodial Mode.
7.1 Dollar Balance in Custodial Mode (Stablesats). In Custodial Mode, the Dollar Balance uses Stablesats — a hedging-based mechanism that maintains USD-equivalent value through positions on third-party platforms. This provides a stablecoin-like experience, allowing Users to send, receive, and hold a stable USD-denominated balance, without the additional expenses and complexities often associated with stablecoins. Users may transfer between their Bitcoin Balance and Dollar Balance within the Wallet, subject to a spread at transfer.
7.2 Dollar Balance in Non-Custodial Mode (Stablecoins). In Non-Custodial Mode, the Dollar Balance holds stablecoins on the Non-Custodial Protocol. Unlike Stablesats, these are actual stablecoin tokens held directly by the User through the Non-Custodial Protocol, not hedging-based positions. The User retains control of these stablecoins through their cryptographic keys, and Blink does not have custody of or access to these funds. The stablecoin currently supported is USDB, issued by Brale, Inc. The specific stablecoin(s) supported may change from time to time as determined by Blink and the Non-Custodial Protocol. The User acknowledges that stablecoins supported in Non-Custodial Mode are issued by third parties and may be subject to issuer-level token controls as described in Section 7.4(b). Holding a stablecoin through the Non-Custodial Protocol means the User holds the token with their own cryptographic keys, but it does not place the token beyond the reach of controls maintained by the token's issuer.
7.3 Risks — Custodial Mode (Stablesats). The Dollar Balance in Custodial Mode relies on third-party platforms for the execution of hedging positions. The User acknowledges and accepts the following risks:
a) In the event of negative occurrences on the exchange (including but not limited to exchange insolvency, regulatory action, technical failure, or market disruption), collateral Bitcoin may become unrecoverable and the funds held in the User’s Dollar Balance could be lost in whole or in part, or become subject to legal proceedings;
b) Blink and Blink Technologies conduct ongoing monitoring, improvements, and risk assessments aimed at reducing the inherent risks associated with offering the Dollar Balance, but cannot guarantee the safety of funds held in the Dollar Balance;
c) Blink will not be responsible for the performance in the provision of services of third-party exchange providers, the custody of balances used for hedging operations, refunds or payments, fees or taxes, or changes in any associated security protocol; and
d) Blink and any of its third-party providers may limit or restrict the use of the Dollar Balance when detecting any operation that is outside their established parameters, and will not be responsible for any failure or loss in which any transaction in question is involved.
7.4 Risks — Non-Custodial Mode (Stablecoins). The Dollar Balance in Non-Custodial Mode relies on the Non-Custodial Protocol and third-party stablecoin issuers. The User acknowledges and accepts the following risks:
a) The User is solely responsible for the security of their Backup Phrase and cryptographic keys. If the Backup Phrase is lost, stolen, or destroyed, Blink cannot recover the User’s funds under any circumstances;
b) The value, redeemability, and transferability of stablecoins held in Non-Custodial Mode depend on the stablecoin issuer and the underlying reserve assets. In addition, the issuer of a supported stablecoin may maintain and unilaterally exercise token-level controls independently of Blink and independently of the User's cryptographic keys, including: (i) denylisting an address (preventing it from sending or receiving the stablecoin); (ii) freezing the stablecoin (rendering it non-transferable); and (iii) clawback (removing the stablecoin from an address). If an issuer exercises such controls, the User may be unable to transfer, redeem, or otherwise dispose of the affected stablecoin even though the User retains their Backup Phrase and keys. The User's control over stablecoins in Non-Custodial Mode is accordingly qualified in a way that the User's control over bitcoin in Non-Custodial Mode is not. While Blink conducts due diligence in selecting supported stablecoins, Blink does not control, and is not responsible for, the exercise or non-exercise of issuer-level token controls, and does not guarantee the solvency, reserves, or regulatory status of any stablecoin issuer, each of which may change after initial selection;
c) The Non-Custodial Protocol is a third-party technology that Blink does not control. While the protocol is designed so that no single operator can unilaterally access User funds, risks remain including potential protocol vulnerabilities, operator collusion, or disruptions to the protocol’s network;
d) The availability and functionality of stablecoins on the Non-Custodial Protocol may change due to protocol upgrades, regulatory developments, or decisions by the stablecoin issuer; and
e) Blink is not responsible for any loss of funds resulting from the User’s failure to secure their Backup Phrase, protocol-level vulnerabilities, stablecoin issuer failures, or any other circumstance arising from the non-custodial nature of the service.
7.5 General. The only way to store value with no counterparty risk is to hold bitcoin in self-custody on the Bitcoin base layer according to best practices. All means of transacting and storing value through the Platform, including the Dollar Balance in both Custodial Mode and Non-Custodial Mode, involve some level of risk. Not all Dollar Balance modes may be available in all jurisdictions or to all Users.
7.6 Changes to Supported Assets. Blink determines, in its discretion and in light of applicable regulatory requirements, which digital assets (each a "Supported Asset") are supported through the Platform, in which jurisdictions, and in which modes. Blink may cease supporting an asset in one or more jurisdictions, or globally, at any time (a "Support Withdrawal"). Where Blink effects a Support Withdrawal for a stablecoin held by Users in Non-Custodial Mode, the following applies:
a) Sequenced withdrawal. Blink will generally implement the Support Withdrawal in stages: first disabling new acquisition of the asset through the Platform (while existing holdings remain visible and disposals remain available); then providing affected Users an exit window of no less than 30 days, with in-app notice describing the exit options available to them, which may include transferring the balance of the asset to the User’s Bitcoin Balance in-app (where available), sending the asset to another compatible wallet, and redeeming the asset directly with its issuer subject to the issuer’s terms; then disabling the in-app transfer of the asset to the Bitcoin Balance; and finally removing the asset’s balance display and remaining functionality from the Platform. As part of these stages, Blink may also disable the Platform’s interfaces for receiving the asset — including the generation of new receiving addresses and payment requests (invoices) — from a date stated in the applicable notice. The User acknowledges that amounts sent to receiving addresses generated or shared before such disablement may nevertheless settle to the User on the Non-Custodial Protocol outside Blink’s control, and that following removal of support such amounts will not be displayed in, or manageable through, the Wallet.
b) Effect of completion. Upon completion of a Support Withdrawal, the asset ceases to be a Supported Asset in the affected jurisdiction(s). Users who have not disposed of the asset retain it on the Non-Custodial Protocol under their own keys, but Blink no longer displays the asset or facilitates transactions in it, and the User's ability to deal with the asset thereafter depends on third-party wallets and tools, the Non-Custodial Protocol, and the issuer (including the issuer-level token controls described in Section 7.4(b)). Retention of a stablecoin after a Support Withdrawal is not equivalent to holding bitcoin in self-custody.
c) No forced disposal. Blink will not transfer, redeem, or otherwise dispose of a User's non-custodial asset holdings on the User's behalf in connection with a Support Withdrawal. Any transfer or disposal must be initiated by the User.
d) Interaction with service discontinuation. Where a Support Withdrawal occurs in connection with a discontinuation of Services in a jurisdiction under Section 17, the timelines in the applicable Section 17 notice govern, provided that the exit window in paragraph (a) is not shortened.
7.7 Discontinuation of the Dollar Balance; Required-Action Screens.
a) Discontinuation. Blink may discontinue the Dollar Balance feature, in either or both modes, in any jurisdiction or globally, where Blink determines that discontinuation is required or appropriate in light of applicable regulatory requirements or operational considerations. In Custodial Mode, discontinuation takes effect through the transfer of the User’s Dollar Balance to the User’s Bitcoin Balance: because the Dollar Balance in Custodial Mode is a USD-equivalent value maintained through hedging (Section 7.1), upon this transfer the User’s value is displayed and settled as its bitcoin equivalent at the then-applicable rate, after which the Dollar Balance feature is no longer available to the User. In Non-Custodial Mode, discontinuation is effected as a Support Withdrawal of the relevant stablecoin under Section 7.6. Where a User holds a Dollar Balance in Custodial Mode and has not completed the transfer by the final deadline stated in the notices given to that User, Blink may complete the transfer of the User’s remaining Dollar Balance to the User’s Bitcoin Balance on or after that deadline, at the then-applicable rate determined in the same manner as User-initiated transfers and recorded per account. This consequence and the applicable deadline will be stated in the notices given to the User, which are subject to Section 17.2 (the latest date communicated to the User governs, and dates never move earlier); Blink will not complete a transfer under this paragraph for any User whose notices did not state this consequence. The underlying value is at all times bitcoin: completion of the transfer ends the USD-equivalent display and settlement, and Blink unwinds its associated hedge on its own side. Following completion, the resulting balance remains held for the User in accordance with Section 10 and, after any final deadline under Section 17, may be recovered through the Claims Process (Section 17.5).
b) Required-action screens. Where the Dollar Balance is being discontinued for a User who holds a Dollar Balance, Blink may display a screen on opening the Wallet, or on accessing an affected feature, that requires the User to address their Dollar Balance before continuing to use other features of the Wallet. The screen will show the User’s Dollar Balance and its bitcoin equivalent and offer the transfer of that balance to the User’s Bitcoin Balance — in Custodial Mode, the transfer described in paragraph (a), confirmed by the User in the flow; in Non-Custodial Mode, an in-app transfer of the supported stablecoin balance to the User’s Bitcoin Balance, initiated by the User. In Non-Custodial Mode, a required-action screen does not withdraw or replace the other exit options communicated to the User under Section 7.6(a) (self-transfer to another compatible wallet; redemption with the issuer subject to the issuer’s terms), and completion of any exit option — or reduction of the relevant balance to zero by any means — satisfies the requirement.
c) Effect on funds. A required-action screen restricts access to features of the Wallet pending the User’s action; it does not restrict the User’s funds. Custodial balances remain held for the User in accordance with Section 10 while the screen is displayed, and funds held in Non-Custodial Mode remain under the User’s own keys at all times.
Blink will manage with the highest level of confidentiality the information shared by the User. It will only be disclosed for the purposes of compliance with a court order or requirement of any competent authority in accordance with applicable laws. Likewise, the information shared will not be used for purposes other than those established in the Terms and Conditions developed herein.
In accordance with Blink’s Anti-Money Laundering and Counter-Terrorist Financing ("AML/CFT") scheme, we adhere to the applicable legislation in the relevant jurisdictions and the international criteria issued by the Financial Action Task Force on Money Laundering.
The User acknowledges that Blink will strictly comply with the requirements formulated by any competent authority, pursuant to which additional requirements may exist beyond those established in these Terms and Conditions. These requirements may be related to the level of operational, legal, reputational, geographical, or predominant activity risk, among others. Such requirements must be fully complied with in order to establish and/or, as the case may be, continue to provide the Services. Compliance with personal data requirements made by competent authority shall at all times be subject to the provisions of our Privacy Policy and applicable legislation.
In the event that there is suspicion that your Wallet is not compliant with any AML/CFT provision, whether national or international, Blink shall have the right to carry out any review and audit action that we deem necessary or appropriate, such as requesting and collecting any necessary or deemed appropriate information or documentation, as well as reporting, at our sole discretion, any activity to any authority and, if necessary, take any action or carry out any act implicitly or explicitly contemplated in the Terms and Conditions or applicable legislation, including but not limited to the temporary or total suspension of any Wallet, Blink Card, and/or access to the Wallet.
For Users whose contracting entity is Blink El Salvador, S.A. de C.V.: Blink reserves the right to request any additional information, with the intention of determining or corroborating the declared or operated transactional profile of its Users as well as the origin and destination of the funds involved in the operations that the User carries out on our platform or for any other related or convenient purpose, and if the necessary information is not received, Blink may suspend or terminate the Services and/or the contractual relationship with the User, including their access to the Wallet. The resources that Users transfer to the Wallet must in any case come from and may be reintegrated into deposit accounts opened at the authorized financial institution in accordance with the applicable regulations. Otherwise, upon legal or judicial resolution to that effect, the User waives all funds held in the Wallet as determined by the competent authorities. Blink will establish standardized application programming interfaces that enable connectivity and access of other interfaces developed or managed by the financial institution and by third parties specialized in information technology, in order to share various data and information as provided for in the applicable regulations, as well as to determine the Users.
Sanctions-based access controls. Blink maintains controls designed to comply with applicable sanctions programs and with Blink's own sanctions policy. The User acknowledges and accepts that:
a) Access to hosted Services is assessed at each session based on the location of the User's live connection, resolved to country level from the connection's IP address at session start. This assessment operates independently of, and in addition to, the jurisdiction attributed to the User's account: sanctions controls follow the live connection, regardless of the User's verified phone country, residence or incorporation documentation, or selected mode of operation, including where the User is travelling.
b) If a session's connection resolves to a jurisdiction subject to comprehensive sanctions or otherwise treated as restricted under Blink's sanctions policy, Blink will block access for that session and display a restriction notice. In Custodial Mode, access to the account is blocked for the session; last-known balance information may be displayed for information only. In Non-Custodial Mode, hosted features are blocked for the session, while local wallet functions — keys, signing, and locally stored balance information — remain available, consistent with Section 10.3 (Blink cannot restrict funds held in Non-Custodial Mode).
c) Session blocking releases automatically when a subsequent session connects from an unrestricted location; no restriction state persists from a blocked session by reason of the blocking alone. Blink records the country-level determination and its provenance, not raw IP addresses, and handles such records in accordance with the Blink Privacy Policy.
d) Blink may additionally decline to make the Wallet, account creation, or particular features available to users in, or connections from, restricted jurisdictions, including through app-storefront availability and download restrictions.
e) Measures taken under this Section are compliance measures required or considered necessary by Blink under applicable law and policy. Blink shall not be liable for any inability to access hosted Services, transact, or complete an operation during a blocked session, and such measures do not constitute a breach of these Terms and Conditions by Blink.
10.1 Custodial Mode — Bitcoin. In Custodial Mode, the Wallet operates as a full reserve wallet; Blink, through Blink Technologies as its custodial and infrastructure service provider, maintains bitcoin reserves intended to equal or exceed the amount of funds held in customer Bitcoin Balances, and remains in position to enable 100% of customer funds to be withdrawn at any time, subject to reasonable processing times and all other terms and conditions (i.e. transaction limits, compliance with applicable laws and regulations).
Important Custody Disclosure: Your contracting Blink entity is responsible for the custody of customer Bitcoin in Custodial Mode. To fulfill this obligation, it has delegated physical custody operations to Blink Technologies, LLC, which holds customer Bitcoin as agent and sub-custodian on behalf of your contracting Blink entity and under its ongoing supervision. Customer Bitcoin is maintained in segregated custody, separate from Blink Technologies’ own assets. In the event of Blink Technologies’ insolvency, customer Bitcoin is contractually excluded from Blink Technologies’ estate. While legal and beneficial ownership of customer Bitcoin remains with the customer at all times, Users should be aware that in an insolvency scenario, the treatment of custodied assets may be subject to legal proceedings in the applicable jurisdiction(s).
Bitcoin held in customer Bitcoin Balances is considered property of the customer and is not considered assets of Blink or Blink Technologies. Neither Blink nor Blink Technologies uses bitcoin from customer balances to fund its own operations, and neither rehypothecates customer bitcoins. The majority of bitcoins are held in geographically distributed multisig custody. Some amount of bitcoins are held in a hot wallet to enable processing of payments.
10.2 Custodial Mode — Dollar Balance. Bitcoin held in customers’ Dollar Balances in Custodial Mode is considered property of the customer and is not considered assets of Blink. Blink is not using funds from customers’ Dollar Balances to fund its own operations. In order to provide the Dollar Balance feature in Custodial Mode, some portion of the funds held by users in Dollar Balances may be transferred to a third-party platform for hedging operations and therefore are not held in custody by Blink (see Section 7). Funds held in Dollar Balances in Custodial Mode rely on exchange partners and are subject to higher counterparty risk. If the exchange service is denied or disrupted for any reason, Blink may have to limit withdrawal access from Dollar Balances.
10.3 Non-Custodial Mode. In Non-Custodial Mode, the User holds Bitcoin and stablecoins directly through the Non-Custodial Protocol. Blink does not have custody of, access to, or control over funds held in Non-Custodial Mode. The User’s funds are secured by their cryptographic keys, which are derived from the User’s Backup Phrase. Ownership and control of bitcoin in Non-Custodial Mode rest entirely with the User. Ownership of stablecoins in Non-Custodial Mode rests with the User, subject to the issuer-level token controls described in Section 7.4(b), which operate independently of the User's keys and of Blink. Blink itself does not have the technical ability to freeze, seize, transfer, or recover any funds held in Non-Custodial Mode, including at the request of the User. If a User loses their Backup Phrase and all associated backup methods, the funds are permanently and irreversibly lost.
10.4 Blink Card. The Card Balance (as defined in the Cardholder Agreement) is the dedicated balance within the User’s Blink Wallet, denominated in BTC or USD as selected by the User. Funding and settlement mechanics, custody of the Card Balance in each mode, Collateral arrangements (when Credit Mode is active), and any outstanding amounts owed to the Issuing Bank are governed by the Cardholder Agreement (Sections 3–4 thereof).
11.1 General Security Responsibilities. The proper use, handling, and safeguarding of signatures, private keys, Backup Phrases, access codes, passwords, and any other access data to your Wallet and any Partner Services including Blink Card information are your responsibility. Blink shall not be held responsible for any lack of diligence, negligence, or incompetence on the part of the Users in controlling and caring for these, as well as for the potential consequences that this may imply, including, but not limited to, possible loss of funds or information.
11.2 Account Security. Upon registering on the Platform, for your own security, the User must generate a password which will serve as an authentication factor, and it must be composed of at least eight consecutive characters, including alphanumeric and special characters. Additionally, Blink will assign each User, at the time of Wallet opening, a personal identification number which will serve as an authentication factor for the approval of Cryptoasset operations. Blink shall not be liable in any case for the misuse of the authentication methods used by the User at their discretion. Blink is not responsible for phishing, identity theft, cyberattacks, or any type of attack of which the User is a victim. Nor shall it be liable for acts of third parties affecting the Wallet, the global internet network, or any other interconnection platform in general.
11.3 Non-Custodial Mode — Backup Phrase and Key Management. Users operating in Non-Custodial Mode bear sole and absolute responsibility for securing their Backup Phrase and any associated cryptographic keys. The User acknowledges and accepts that:
a) The Backup Phrase is the only means of recovering access to funds held in Non-Custodial Mode. Blink does not store, have access to, or maintain any copy of the User’s Backup Phrase or private keys;
b) The User must securely store their Backup Phrase using one or more of the following methods made available through the Wallet: (i) manual recording of the Backup Phrase (written on paper or other physical medium), (ii) iCloud backup (for iOS devices), (iii) Google account backup (for Android devices), or (iv) password manager storage. The User is solely responsible for the security of whichever backup method(s) they choose;
c) If the User loses their Backup Phrase and all backup copies are lost, compromised, or inaccessible, the User’s funds held in Non-Custodial Mode will be permanently and irreversibly lost. Blink has no ability to recover, reset, or restore access to non-custodial funds under any circumstances;
d) The User must not share their Backup Phrase with any third party. Blink will never ask the User for their Backup Phrase by any means; and
e) Blink is not liable for any loss of funds resulting from the User’s failure to adequately secure their Backup Phrase, the compromise of the User’s backup storage method, or any unauthorized access to the User’s Backup Phrase by third parties.
11.4 Custodial Mode — Account Protection. Only for the purpose of safeguarding security in the User’s account when Blink has any indication that it may have been compromised by an unauthorized third party, as well as any act that limits, restricts, or prevents any person on equal terms from contracting any product or services complying with Blink’s requirements, Blink may temporarily restrict access to the Wallet to any person, including access to their Wallet. For this, Blink will send the User an alert through the Wallet informing them of such situation so that they can make the corresponding clarification. This capability applies only to Custodial Mode; Blink cannot restrict access to funds held in Non-Custodial Mode. (A stablecoin issuer may, however, exercise the token-level controls described in Section 7.4(b) with respect to stablecoins, independently of Blink.)
11.5 Password Recovery. The User or password recovery process will only be carried out through the steps established by Blink, taking into account the highest security standards. This process may only be initiated by the User and will never be initiated by Blink. Under no circumstances will Blink ask its Users, by postal mail, email, or by telephone, to reveal the credentials or passwords that the User uses to access their Wallet. Password recovery restores access to the Blink account; it does not restore access to funds held in Non-Custodial Mode, which requires the Backup Phrase.
11.6 General Precautions. It is the responsibility of the User not to share or provide their identification data, credentials, and access keys to third parties, as well as to ensure that they enter their data or credentials in the secure and certified address. Access to Blink’s official site is the responsibility of the User; Blink will not, under any circumstances, be responsible for the security of the connection from which the User accesses it.
As a result of the above, it is the responsibility of the User to notify Blink if they believe or suspect that their Wallet or credentials may be compromised, or if a third party is acting on their behalf, for which they must create a support ticket and select the option that best fits their request. Additionally, the User undertakes to take all necessary or convenient measures requested by Blink, as well as to follow the procedures established by Blink to regain control of their account, under penalty of losing it definitively.
It is possible that, due to technological factors, scheduled maintenance, or other factors, whether within or beyond our control, the Wallet or other Services may be temporarily interrupted. While we will endeavor to address such factors if they occur, to the extent permitted by applicable law, Blink shall not be liable for damages and losses resulting from such interruptions. Blink maintains contingency processes designed to promote continuity of, and access to, the Services; this Section applies equally to interruptions, failures, or errors attributable to Blink’s technology service providers.
In the event of an event described in this paragraph, Blink will issue a communication indicating the steps to follow. Blink reserves the right to reverse any operation that has been carried out as a result of a service interruption or failure in the operation of electronic communications, commercial facilities, storage facilities, recording mechanisms, or other components of the Services. In these circumstances, operations will be reviewed on a case-by-case basis, and Blink will inform you via the email address provided by the User if any of your operations are affected by this situation.
Blink shall not be liable for any failure or delay in the performance of its obligations under these Terms and Conditions to the extent that such failure or delay is caused by circumstances beyond Blink’s reasonable control, including but not limited to: fortuitous events, force majeure, acts of hostility or war, rebellion, insurrection, revolution, confiscation, nationalization, destruction or requisition arising from any act of de facto authority or civil or military law, acts of terrorism, subversion or guerrilla activity, strikes, civil unrest, confinement orders, pandemics, epidemics, natural disasters, failure of third-party infrastructure or telecommunications providers, or government sanctions.
During any period of force majeure, Blink’s affected obligations shall be suspended. Blink will use commercially reasonable efforts to mitigate the effects of any force majeure event, resume performance as soon as reasonably practicable, and notify Users through available channels of any material disruption to the Services.
By using the Services and Partner Services, the User agrees not to engage in any of the following prohibited activities:
a) Use the Blink Card for illegal gambling, money laundering, or purchase of cryptocurrency except through authorized Blink services;
b) Engage in manufactured spending or other activities designed to artificially generate rewards or circumvent credit limits;
c) Open or attempt to open more than one (1) active Blink Account or Blink Card account at any time;
d) Attempt to gain unauthorized access to any other User’s account or Blink Card; upload malicious code; or otherwise damage, disable, overburden, modify, tamper with, impair, or compromise the Services, the Platform, or any related systems;
e) Reverse engineer, decompile, or otherwise attempt to derive the source code of the Services, Partner Services, the Wallet, the API, or the Website (except to the extent permitted by applicable open-source licenses);
f) Provide Blink or its Partners with any false, inaccurate, or misleading information;
g) Intercept, monitor, damage, or modify any communication not intended for the User; collect or harvest information or data from the Services or Partner Services; or attempt to decipher any transmissions to or from the servers running the Services or Partner Services;
h) Sell, rent, lease, distribute, market, or use the Services and/or Partner Services for any unauthorized commercial purpose;
i) Remove, obscure, or alter any copyright notices, trademarks, or other proprietary rights notices affixed to or contained within the Services, Partner Services, the Platform, or the Website;
j) Infringe the intellectual property rights of Blink, Blink Technologies, the Partners, or any third party in relation to the User’s use of the Services or Partner Services; or
k) Transmit any communication that is defamatory, offensive, or otherwise objectionable in connection with the use of the Services or Partner Services.
l) Use the Services to operate, directly or indirectly, an unlicensed money services business, money transmission service, payment processing platform, or custodial wallet service for third-party end users in any jurisdiction where the User does not hold all required regulatory licenses, or in any jurisdiction where such Services are unavailable due to regulatory or licensing requirements.
Blink is entitled, in its sole discretion, immediately and without prior notice, to suspend the provision of the Services and/or Partner Services (in whole or in part) and/or terminate these Terms and Conditions if Blink determines that the User is acting in breach of this Section. The foregoing does not limit any other rights that Blink may have under these Terms and Conditions, the Partner Agreements, or applicable law.
IMPORTANT — PLEASE READ CAREFULLY. THIS SECTION REQUIRES MOST DISPUTES TO BE RESOLVED BY BINDING ARBITRATION AND WAIVES THE RIGHT TO PARTICIPATE IN A CLASS ACTION.
Any claim, dispute, or controversy between the User and Blink (including its affiliates, successors, and assignees, as well as Blink Technologies in its capacity as technology service provider) arising out of or relating in any way to these Terms and Conditions, the Wallet, the Services, the API, or the User’s use thereof shall be subject to final binding arbitration as provided in this Section, except for matters that may be brought in small claims court and except where mandatory arbitration of consumer disputes is prohibited by the law applicable to the User. Card-specific disputes are governed by the dispute resolution and arbitration provisions of the Cardholder Agreement, which control over this Section to the extent of any conflict.
The arbitration shall be conducted before a single neutral arbitrator. The forum, governing arbitration rules, and seat of arbitration are determined by the User’s contracting entity:
a) For Users whose contracting entity is Blink El Salvador, S.A. de C.V.: arbitration shall take place in San Salvador, El Salvador, under Salvadoran law and the rules of an arbitration provider agreed upon by the parties or, in the absence of agreement, designated by the competent authority in accordance with Salvadoran law;
b) For Users whose contracting entity is Blink US LLC: arbitration shall take place in Cheyenne, Wyoming (or such other location as the parties may mutually agree), administered by a recognized arbitration provider (such as the American Arbitration Association (AAA) or JAMS) under the rules of the selected provider, and governed by the laws of the State of Wyoming and the Federal Arbitration Act; and
c) For Users whose contracting entity is Blink LLC: arbitration shall take place in Próspera ZEDE, Roatán, Bay Islands, Republic of Honduras, under the laws of Próspera ZEDE and the rules of an arbitration provider designated by Blink in accordance with Próspera ZEDE law.
Class Action Waiver. The User and Blink agree that any arbitration shall be conducted in individual capacity only and not as a class, collective, consolidated, or representative action. To the fullest extent permitted by applicable law, the User waives the right to participate as a plaintiff or class member in any class, collective, consolidated, or representative proceeding against Blink. The arbitrator shall have no authority to consolidate claims of multiple parties or to preside over any form of class or representative proceeding.
Survival. This Section shall survive the termination of these Terms and Conditions and any transfer or assignment of the User’s account, the Blink Card, or any related obligations.
Lost or Stolen Card, Mobile Phone, and Fraudulent Use. If the User’s Blink Card or mobile phone containing the Wallet is lost or stolen, or if the User suspects unauthorized access to their account, the User must contact Blink Customer Support immediately so that the card and account can be suspended. Card fraud protections (including any limits on liability for unauthorized charges when reported promptly) are detailed in the Cardholder Agreement. The User is responsible for securing the Blink Card and the mobile device on which the Wallet is installed.
Billing Errors and Disputes. For wallet services: except as provided by applicable law, all transactions are final. If the User believes Blink has charged them in error, the User must submit a written request to Blink Customer Support within 90 days of the relevant charge. For Blink Card transactions: the User has the right to dispute transactions as provided in the Cardholder Agreement and applicable law. Blink will investigate and respond in accordance with applicable regulatory timelines and the procedures set forth in the Cardholder Agreement. For US users, the User’s rights under Regulation E of the Electronic Fund Transfer Act, and any equivalent protections under applicable law, are preserved and are not limited by these Terms and Conditions.
Complaints. To make a complaint about the User’s Blink account, the Blink Card, the Services, or the Partner Services, contact Blink Customer Support at support@blink.sv. Regulatory complaint pathways are listed in Section 21 (Regulatory Contacts).
User Breach and Blink’s Remedies. A User may be in breach of these Terms and Conditions if they engage in any conduct that violates these Terms, the applicable Partner Agreements, or applicable law, including failure to make Blink Card payments when required (including, upon activation of Credit Mode, failure to pay any amount owed under the Cardholder Agreement). If the User breaches these Terms, Blink may, in its sole discretion: (a) suspend or close the User’s Blink account and/or Blink Card; (b) report delinquencies and other negative information to consumer credit reporting agencies in accordance with the Cardholder Agreement and applicable law (including, for the avoidance of doubt, when Credit Mode is active); and (c) take any other action that Blink deems necessary to protect itself, its Partners, and other Users. Blink may terminate these Terms (i.e., cancel the User’s Blink account, the Blink Card, and the Services) at any time with notice as required by applicable law.
Closing the User’s Account. The User may close their Blink account at any time by contacting Blink Customer Support (support@blink.sv). Closure procedures depend on the products and modes the User has used:
a) Custodial Mode (Wallet): the User must reduce their custodial balance to zero before closure;
b) Non-Custodial Mode (Wallet): the User is solely responsible for retaining their Backup Phrase prior to closing their Blink account; once the Blink account is closed, Blink cannot recover, restore, or assist with access to funds held in Non-Custodial Mode under any circumstances; and
c) Blink Card: any outstanding balance must be paid in full; the Blink Card account cannot be closed while an outstanding balance remains. Upon activation of Credit Mode, any credit obligations must likewise be satisfied in full prior to closure or, if not satisfied, will continue to be owed in accordance with the Cardholder Agreement.
Where Blink discontinues Services in the User's jurisdiction, Section 17 governs the applicable dates, exit paths, and the treatment and recovery of any remaining balances.
Effects of Termination. Upon any termination of the User’s Blink account, all rights granted under these Terms and Conditions and any Partner Agreement shall cease immediately. Blink Card obligations and any credit obligations under the Cardholder Agreement shall survive termination until paid in full. The arbitration provision in Section 15 shall survive termination. Blink shall not be liable to the User or any third party for the termination of the account, the Services, or any Partner Services.
17.1 Discontinuation. Blink may restrict, suspend, or discontinue any or all Services, features, or modes in any jurisdiction where Blink determines that continued provision is not permitted, not feasible, or not appropriate in light of applicable legal and regulatory requirements or operational considerations. Where existing Users are affected, Blink will provide notice through the Wallet (which may include a persistent in-app notice and/or push notification) stating the applicable dates.
17.2 Dates. The dates applicable to a User are those stated in the notices and persistent in-app surfaces addressed or displayed to that User. Where different dates have been communicated, the latest date communicated to the User governs. Deadlines communicated to a User will not be moved earlier; they may be extended, in which case the extended date governs.
17.3 Wind-down of features. During a discontinuation period, Blink may restrict features progressively — for example, by disabling transfers between balances, disabling receipt of incoming payments as of a stated cutoff date (in Non-Custodial Mode, by disabling the Platform’s receiving interfaces, including the generation of new receiving addresses and payment requests), and restricting account access after a stated final deadline — provided that the User's ability to withdraw or otherwise exit their funds remains available at all times up to the final deadline stated to the User. Depending on the jurisdiction and mode, the exit paths made available may include migration to Non-Custodial Mode (where available) and withdrawal to an external wallet or address. Nothing in this Section requires Blink to continue offering any particular exit path where doing so is not permitted by applicable law.
17.4 Residual balances remain the User's property. Discontinuation of Services does not affect the ownership of customer funds. Custodial balances remaining after a final deadline continue to be held for the User in accordance with Section 10 (including the full-reserve and segregation commitments therein) and do not become assets of Blink, and no fee is charged against a residual balance by reason of the discontinuation itself. Funds held in Non-Custodial Mode are unaffected by discontinuation of custodial Services and remain under the User’s own keys (subject, for stablecoins, to Section 7.4(b)).
17.5 Claims Process. After a final deadline, a User with a remaining custodial balance may recover it through Blink's claims process (the "Claims Process") by contacting Blink Customer Support at support@blink.sv. Recovery is subject to verification of the claimant's entitlement to the account, satisfaction of applicable legal and regulatory requirements (including AML/CFT and sanctions screening), and reasonable processing times. For accounts opened without identity verification, entitlement may be established by possession and control of the account credential or registered device, with additional proportionate verification required above thresholds set by Blink for fraud-prevention purposes. Blink may specify the form and channel of payout available under the Claims Process in light of the requirements applicable to the User's jurisdiction.
17.6 Relationship to other provisions. Section 16A applies in addition to, and does not limit, Blink's rights under Section 14 (Prohibited Use), Section 16 (When Things Go Wrong), and the "Applicable Terms" section. Card services and other Partner Services are governed by the applicable Partner Agreements, including their own termination and wind-down provisions. This Section 16A and the User's rights to residual balances under it survive termination of these Terms and Conditions.
In the event that a competent authority declares illegal, void, or unenforceable these terms and conditions, whether in whole or in part, in accordance with applicable law, the remaining provisions of the terms and conditions shall be deemed applicable and enforceable. These terms and conditions, together with the documents listed in Section 22 (Related Documents), constitute the entire agreement and understanding between the parties in relation to the services.
The technology underlying the Platform and the Services, including all software, systems, features, functionality, APIs, and associated intellectual property, is owned by Blink Technologies and/or its licensors. Blink operates the Platform and provides the Services to Users under a license from Blink Technologies. All intellectual property rights in and to the technology — including any creation, idea, invention, improvement, know-how, concept, algorithm, protocol, data, processes, procedures, methods, techniques, formulas, systems, tools, compositions, codes, software, prototypes, documents, components, or any other information authored by Blink Technologies or derived as a consequence of the operation of the Platform — whether patentable or subject to copyright protection or any other type of intellectual or industrial property rights, are the property of Blink Technologies and/or its licensors. Blink Technologies retains the right to initiate any action or take any measure of any nature to obtain registration and protection of such intellectual property before any authority.
The Platform contains open-source software components distributed under the respective licenses of those components. By using the Platform, you acknowledge and agree to abide by the terms and conditions of all open-source licenses applicable to such components. These licenses are provided to you on an "as-is" basis without warranties of any kind, either express or implied, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose. You further acknowledge that the source code for such open-source components is freely available and may be subject to modification and redistribution under the terms of the respective licenses.
The Blink brand, trademarks, logos, and trade names are the property of Blink Technologies and are licensed to the Blink entities for use in connection with the Services. All materials and data on the site and any other website owned, operated, licensed, or controlled by Blink or Blink Technologies shall be considered confidential information and intellectual property of Blink Technologies and/or its affiliates; therefore, we reserve all rights over them. All materials included on the site, including but not limited to data compilations and software, are protected by copyright laws.
The use, creation, or imitation of logos of any brand within the Website and the Wallet is prohibited. We also reserve the right to remove any comments or attachments made to the Website and the Wallet by an unauthorized User and/or third party. The use of Links, Deeplinking, and Framing is prohibited on the Website and the Wallet. Non-compliance with these prohibitions shall constitute a violation of intellectual property rights over the Contents and rights over Industrial Property.
Any discrepancy, disagreement, difference, conflict, controversy, or dispute arising between the parties shall be submitted to the applicable governing law as determined by the User’s contracting entity (the laws of the Republic of El Salvador for users of Blink El Salvador, S.A. de C.V., the laws of the State of Wyoming for users of Blink US LLC, or the laws of Próspera ZEDE for users of Blink LLC).
Prior to an administrative or judicial action, the direct treatment route will be attempted in the following way: on the occasion of a claim on the part of the User, he will have the possibility to share it through the following channels:
Email: support@blink.sv
Blink will have a period of 3 working days counted from the day following the notification to provide a detailed response on the resolution of the disagreement raised by the User.
For Users whose contracting entity is Blink El Salvador, S.A. de C.V.: Subject to Section 15 (Arbitration and Class Action Waiver), and only for matters not subject to arbitration thereunder: In the event of a legal action, both parties expressly agree to submit to the jurisdiction and tribunals of the Republic of El Salvador, and to the domicile and special jurisdiction of San Salvador; expressly waiving any other jurisdiction that by reason of their present or future domiciles or that for any other reason may correspond to them.
For Users whose contracting entity is Blink US LLC: Subject to Section 15 (Arbitration and Class Action Waiver), and only for matters not subject to arbitration thereunder: In the event of a legal action, both parties expressly agree to submit to the jurisdiction and courts of the State of Wyoming, and the laws of the State of Wyoming shall apply. Each party expressly waives any other jurisdiction that by reason of their present or future domiciles or for any other reason may correspond to them.
For Users whose contracting entity is Blink LLC: Subject to Section 15 (Arbitration and Class Action Waiver), and only for matters not subject to arbitration thereunder: In the event of a legal action, both parties expressly agree to submit to the jurisdiction and courts of Próspera ZEDE, Roatán, Bay Islands, Republic of Honduras, and the laws of Próspera ZEDE shall apply. Each party expressly waives any other jurisdiction that by reason of their present or future domiciles or for any other reason may correspond to them.
For card-specific disputes, the procedures outlined in the Cardholder Agreement will apply, including applicable regulatory dispute resolution timelines and the arbitration and governing law provisions therein. Blink LLC is licensed and regulated solely by the Roatán Financial Services Authority (RFSA) under Próspera ZEDE law. Blink LLC does not hold regulatory authorizations in any other jurisdiction. Users outside of Próspera ZEDE access the Services on their own initiative and are responsible for determining whether their use of the Services complies with the laws of their jurisdiction of residence. Nothing in these Terms deprives any User of mandatory consumer protection rights that apply under the laws of their country of residence.
For Users whose contracting entity is Blink El Salvador, S.A. de C.V.
For complaints about matters that have not been resolved by Blink El Salvador, the User has the right to contact the User Service Office of the Superintendency of the Financial System of El Salvador through the following channels:
Portal: https://ssf.gob.sv/atencion-al-publico/
Phone and WhatsApp SSF: 2699-9999
Correo SSF: atencionalusuario@ssf.gob.sv
Address: Avenida Albert Einstein, Urbanización Lomas de San Francisco, No. 17, Distrito de Antiguo Cuscatlán,
Municipio de La Libertad Este, Departamento de La Libertad.
Horario de atención: de lunes a viernes de 8:30 a.m. a 4:30 p.m. Sin cerrar al mediodía.
For Users whose contracting entity is Blink US LLC
Blink US LLC does not hold financial services licenses in its own name. Card services are provided under the licensing of the Issuing Bank and Program Manager. For card-related regulatory complaints, US users may contact:
Consumer Financial Protection Bureau (CFPB): www.consumerfinance.gov
Wyoming Division of Banking: wyomingbankingdivision.wyo.gov
For Users whose contracting entity is Blink LLC
The User may contact the Roatán Financial Services Authority (RFSA) through the following channels:
Website: www.rfsa.hn
Email: gsp@prospera.hn
Phone: +504 92216815
Address: Beta Building, Beta District, Próspera ZEDE, Roatán, Bay Islands, Republic of Honduras
For general support inquiries, contact Blink support at support@blink.sv. For data protection inquiries, contact privacy@blink.sv. For card disputes and chargebacks, contact disputes@blink.sv.
The following documents form part of these Terms and Conditions. Please review them carefully:
By using the Services, including any Partner Services such as the Blink Card, you acknowledge that you have read, understood, and agree to these Terms and Conditions and all related documents linked above.
