Effective date: December 17, 2025
These Terms and Conditions supplement Coinmetro’s General Terms of Service (the “Terms”, available: https://www.coinmetro.com/terms-of-use) and apply specifically to the “Internal Transfers” product (hereinafter also the “Product”). In case of conflict, these Terms and Conditions prevail for the Product. All capitalised terms have the meaning given in the Terms unless stated otherwise.
1. General
1.1 The Product is offered by Coinmetro OÜ, an Estonian company (registry number 14448371), with its principal office at Tartu mnt 84a-203, Tallinn 10112, Estonia (“Coinmetro”).
1.2 On the Coinmetro Platform, an Internal Transfer is a process by which supported crypto-assets are transferred off-chain and instantly from one Coinmetro Account to another Coinmetro Account, or are made available for claim by an invited recipient subject to the conditions in these Terms and Conditions.
1.3 The Product is intended to enable Users (the term “User” is used interchangeably with “client” or “customer” in the context of the Terms and these Terms and Conditions) to send supported crypto-assets instantly and without transfer fees to other Users, including (where available) to recipients who are not yet Coinmetro clients via a secure invitation flow and escrow holding mechanism.
1.4 By using the Product, the User accepts and agrees to these Terms and Conditions, the Terms, and Coinmetro’s Privacy Policy.
1.5 Coinmetro will provide the Product with due skill, care, and diligence and in accordance with applicable legal and regulatory requirements.
1.6 Nothing in the Internal Transfers functionality shall be interpreted as Coinmetro providing a payment service, electronic money service, issuance of electronic money, or any regulated fiat-based transfer service. Internal Transfers relate exclusively to crypto-assets and are governed solely by the legal framework applicable to crypto-asset service providers, including current local VASP rules and MiCA requirements. The Product does not support transfers of fiat currency or stablecoins that may qualify as “e-money tokens” under MiCA; accordingly, the Product does not constitute electronic money issuance or require an electronic money institution licence.
2. Definitions
For the purposes of these Terms and Conditions:
2.1 “Sending User” means a registered Coinmetro client who has completed applicable KYC/AML verification steps and who initiates an Internal Transfer.
2.2 “Registered Receiving User” means a recipient who is a registered Coinmetro client and has completed applicable KYC/AML verification steps and who is marked as the recipient in the respective Internal Transfer.
2.3 “Non-Registered Receiving User” means a recipient who is not registered with Coinmetro at the time the Sending User initiates the Internal Transfer and who is invited to register in order to claim the transfer.
2.4 “MetroTag” means a unique identifier associated with a Coinmetro client account, used to facilitate Internal Transfers.
2.5 “Escrow” means an internal, off-chain holding state within Coinmetro’s systems under which a transfer to a Non-Registered Receiving User is held pending claim, cancellation, expiry, or compliance review outcome.
2.6 “Supported Assets” means those crypto-assets that Coinmetro makes eligible from time to time for Internal Transfers through the Product interface.
3. Product Description & Eligibility
3.1 Only Supported Assets may be sent using the Product. Coinmetro may add or remove Supported Assets at any time based on legal, regulatory, risk, liquidity, or operational considerations.
3.2 Unless Coinmetro expressly enables otherwise in the Product interface, the Product does not support: (i) fiat transfers; (ii) stablecoin transfers; (iii) transfers to external wallets or other platforms; or (iv) bulk internal transfers.
3.3 Internal Transfers are off-chain transfers within Coinmetro’s ledger and are not on-chain transactions. Blockchain confirmations, gas/network fees, and external wallet address controls are not applicable to Internal Transfers.
4. How Internal Transfers Work
4.1 Transfers to Registered Receiving Users
4.1.1 A Sending User may send Supported Assets to a Registered Receiving User using one or more identifiers made available in the Product interface (including MetroTag and/or other verified identifiers such as phone number or email address, as and when such identifiers are enabled and made discoverable in the Product interface by the User).
4.1.2 Coinmetro will apply validation controls intended to reduce misdirection risk. However, the Sending User remains responsible for ensuring that the recipient identifier is correct.
4.1.3 Once confirmed by the Sending User, an Internal Transfer to a Registered Receiving User is processed immediately, and the relevant assets are credited to the recipient’s Coinmetro wallet.
4.2 Transfers to Non-Registered Receiving Users (Invitation + Escrow)
4.2.1 Where enabled, a Sending User may initiate an Internal Transfer to a Non-Registered Receiving User by providing an invitation identifier (such as an email address or phone number) as supported in the Product interface.
4.2.2 Upon initiation of such a transfer:
(a) the relevant Supported Assets are debited from the Sending User and held in Escrow; and
(b) Coinmetro will notify the Non-Registered Receiving User of the pending transfer and provide instructions on how to register an account and complete KYC/AML verification in order to claim the transfer.
4.2.3 To claim the transfer, the Non-Registered Receiving User must: (i) create a Coinmetro Account, and (ii) successfully complete KYC/AML verification and any other onboarding checks required by Coinmetro.
4.2.4 Transfers to Non-Registered Receiving Users are held in Escrow for 7 days from initiation (or such other period as shown in the Product interface). If the transfer is not claimed within that period, the transfer will automatically expire and the assets will be returned to the Sending User.
4.2.5 Coinmetro may send reminders/notifications to the recipient and sender regarding pending, expiring, expired, claimed, cancelled, or refunded transfers.
5. Cancellation, Errors, and Statuses
5.1 The Sending User may cancel an Internal Transfer that is still pending and unclaimed (see Cl 4.2.3). Upon cancellation, the relevant assets will be returned to the Sending User, subject to any applicable compliance holds or investigations.
5.2 Once the transfer is claimed and completed, it cannot be cancelled or reversed except where required by law, regulatory direction, fraud prevention controls, or error correction processes under the Terms.
5.3 The Platform may display status labels (e.g., pending, completed, claimed, cancelled, expired/auto-returned, failed, refunded, in review). Such labels are indicative of processing state and do not limit Coinmetro’s rights under these Terms and Conditions or the Terms.
5.4 Coinmetro is not responsible for losses or disputes resulting from the Sending User entering incorrect recipient details or selecting the wrong recipient, except to the extent required by applicable law.
6. Fees, Limits, and Balance Checks
6.1 Coinmetro does not currently charge a specific fee for Internal Transfers. Coinmetro may introduce or change fees for Internal Transfers in the future, but will disclose such fees in the Product interface and/or in the Terms and Conditions before they apply.
6.2 Coinmetro may impose minimum and/or maximum limits for Internal Transfers and may change such limits from time to time. Limits may apply per transfer and/or over a period of time (daily/weekly/monthly), and may be differentiated based on account type, verification level, risk profile, or jurisdiction.
6.3 If the Sending User’s available balance is insufficient to complete the transfer, Coinmetro can not process the transfer but may provide options for the Sending User to add funds so that a new Internal Transfer may be initiated.
7. Suspension, Reversal and Authentication of Transfers
7.1 Coinmetro may restrict or block access to the Product and/or delay, suspend, block, reverse (where possible), or place in review any Internal Transfer where Coinmetro reasonably determines that it is necessary to comply with applicable law, sanctions, AML/CTF obligations, fraud prevention, or internal risk controls.
7.2 The User must use the security features and authentication methods made available by Coinmetro (which include strong customer authentication or equivalent controls) to authorise Internal Transfers. Coinmetro may treat any Internal Transfer instruction authenticated through the User’s credentials and/or authentication method as authorised by the User. The User must promptly notify Coinmetro if the User believes their account, credentials, or device has been compromised or an Internal Transfer was unauthorised, and Coinmetro may suspend the Product pending investigation.
7.3 Where required by applicable law (including, where applicable, Regulation (EU) 2023/1113, “Travel Rule”), Coinmetro may collect, verify, retain, and transmit information relating to the originator and beneficiary of a crypto-asset transfer and may restrict, delay, or refuse Internal Transfers if such information cannot be obtained or verified.
8. Disclaimers, Risks & Service Conditions
8.1 Operational risk. Internal Transfers may be affected by system downtime, maintenance, technical faults, or third-party service disruptions (e.g., messaging or notification delivery), and may be delayed, suspended, or fail.
8.2 Identity and social engineering risk. Users are responsible for taking appropriate precautions against impersonation, phishing, and scams. Coinmetro may provide validation and warnings, but does not guarantee that the intended recipient is the party controlling a specific identifier.
8.3 Service changes. Coinmetro may amend, suspend, or discontinue the Product (in whole or in part), or change Supported Assets, workflows, holding periods, or eligibility rules, with or without notice, where required for legal, regulatory, security, or operational reasons.
8.4 Transfer service conditions and client rights. Coinmetro will maintain procedures for the initiation, execution, cancellation (where permitted), and tracking of Internal Transfers, including status information shown in the Platform. Coinmetro may refuse, delay, or suspend an Internal Transfer where required by applicable law or to manage security, fraud, or financial crime risk, and will provide the User with status updates through the Platform where reasonably practicable.
9. Indemnity & Liability
9.1 The User agrees to indemnify, defend, and hold harmless Coinmetro, its affiliates, officers, employees, agents, and service providers (the “Released Parties”) from claims, losses, damages, liabilities, or costs (including legal fees) arising from misuse of the Product, violation of these Terms and Conditions, the Terms, or applicable law, or third-party claims related to the User’s actions.
9.2 The Released Parties are not liable for losses due to: (i) user error (including incorrect recipient details); (ii) price movements or volatility; (iii) technical failures, downtime, or delays; (iv) third-party systems (including communications channels); or (v) compliance actions taken in good faith.
9.3 Liability cap. Coinmetro’s total liability for any claim or series of related claims arising under these Terms and Conditions shall not exceed the value of the transfer amount in dispute at the time the relevant transfer was initiated, subject always to any different limitation or exclusion in the Terms.
10. Communications, Notices & Updates
10.1 All notices under these Terms and Conditions shall be in English.
10.2 Coinmetro may deliver notices via the Platform and/or email to the User’s registered address. Notices are deemed received when published or successfully sent.
10.3 Coinmetro may revise or update these Terms and Conditions from time to time. Continued use of the Product constitutes acceptance of the updated terms.
11. Personal Data & Privacy
11.1 Processing of personal data under this Product is governed by the Coinmetro Privacy Policy.
11.2 By using the Product, the User acknowledges that Coinmetro may process personal data, make disclosures, maintain records, and send communications necessary for the provision of the Product and for compliance with legal and regulatory obligations (including sending invitations and notifications to recipient identifiers provided by the Sending User), in each case in accordance with the Coinmetro Privacy Policy and applicable law.
12. Governing Law & Dispute Resolution
12.1 These Terms and Conditions and any disputes arising hereunder are governed by the laws of the Republic of Estonia.
12.2 Any unresolved dispute shall be submitted to the exclusive jurisdiction of the courts of Estonia.
13. Severability
If any provision of these Terms and Conditions is held invalid or unenforceable, that provision will be severed, and the remainder shall continue in full force and effect.
14. Acknowledgement
By using the Product, the User expressly acknowledges and agrees that:
- Internal Transfers are off-chain platform transfers and not blockchain transactions;
- the User is responsible for verifying recipient identifiers and transfer details;
- these Terms and Conditions operate together with the Terms and the Coinmetro Privacy Policy.
- Coinmetro may apply compliance controls including delays, holds, refusals, and/or information requirements to process transfers.