> ## Documentation Index
> Fetch the complete documentation index at: https://docs.cdp.coinbase.com/llms.txt
> Use this file to discover all available pages before exploring further.
# Individual User Agreement for Coinbase Services
**User Agreements for Coinbase Services Accessed Through a Third-Party Provider**
***
On this page\
**→ [Individual User Agreement for Coinbase Services Accessed Through a Third-Party Provider](#individual-user-agreement)**\
**→ [Business User Agreement for Coinbase Services Accessed Through a Third-Party Provider](#business-user-agreement)**
***
#### **Not sure which one applies to you?**
#### If you're using Coinbase services accessed through a third-party provider as an individual — including buying, selling, or trading crypto for yourself — the [Individual User Agreement](#individual-user-agreement) applies. If you are an authorized representative of a company which is using Coinbase services accessed through a third-party provider for commercial, business purposes your activities are subject to the [Business User Agreement](#business-user-agreement). **Regardless of which agreement applies to you, you are bound to an arbitration agreement, jury trial waiver, and class action waiver. Please review the terms carefully.**
***
## **Individual User Agreement for Coinbase Services Accessed Through a Third-Party Provider**
## *Last updated: July 1, 2026*
This is a User Agreement between you (also referred to herein as “**User**,” or “customer”) and Coinbase, Inc. ("**Coinbase**," “we,” “us,” and “our”). This User Agreement ("**Agreement**" or “**User Agreement**”) governs your use of the services provided by Coinbase described below and such other services that may be offered by Coinbase from time to time ("**Coinbase Services**" or "**Services**"). By signing up to use a Coinbase Account (as defined below) through a Provider (as defined below), you agree that you have read, understand, and accept all of the terms and conditions contained in this Agreement including our [Privacy Policy](https://www.coinbase.com/legal/privacy), [U.S. Financial Privacy Notice](https://www.coinbase.com/legal/financial-privacy), [Cookie Policy](https://www.coinbase.com/legal/cookie), [Prohibited Use Policy](https://www.coinbase.com/legal/prohibited_use) and E-Sign Disclosure and Consent Policy in Appendix 2.
You are interacting with Coinbase Services through an application provided to you by a third-party Provider. The Provider’s application communicates with Coinbase through an application programming interface (“**API**”), with **Coinbase performing certain back-end services on your behalf**. By using the Services, you authorize the Provider to act as your agent in accessing and providing instructions to your Coinbase Account for the purpose of facilitating the Services defined herein. The Provider is not an agent of Coinbase, and nothing in this relationship authorizes the Provider to make any representations, warranties, or commitments on behalf of Coinbase or otherwise bind Coinbase in any way. You acknowledge that your relationship with the Provider, including use of the Provider’s application, is governed by a separate agreement between you and the Provider, to which Coinbase is not a party. This Agreement governs your use of the Coinbase Account, which is established with and held directly by Coinbase.
**Important Definitions:** As used throughout this Agreement, the following terms have the following meanings.
“**Bank Partner**” means any third-party depository institution with which Coinbase maintains pooled or virtual accounts in order to receive fiat currency deposits to support the Services.
“**Coinbase Account**” or “your account” means the digital asset account established with and held directly by Coinbase (which includes your Digital Asset Wallet, defined below) that you access and use through a Provider’s application to utilize the Coinbase Services.
“**Coinbase Platform**” or “Platform” means the collective software, APIs, infrastructure, and systems provided by Coinbase to facilitate the Coinbase Services. For purposes of this Agreement, the Platform exclusively refers to the back-end services, APIs, and infrastructure that power your custodial account and authorized transactions. This User Agreement applies only to your interaction with the Platform through a Provider’s application. Access to Coinbase services through Coinbase’s direct websites or applications (including, but not limited to, coinbase.com and the Coinbase mobile application) are subject to a separate user agreement, and are not governed by this Agreement.
“**Deposit Instructions**” means any bank account number, routing number, virtual account number, or other payment details that Coinbase or a Bank Partner allocates for the purpose of receiving fiat currency that will be converted to Supported Digital Assets and credited to your Coinbase Account.
“**Digital Asset**” means any digital asset (including a virtual currency or virtual commodity) which is a digital representation of value based on (or built on top of) a cryptographic protocol of a computer network.
“**Provider**” means the third-party company that provides the front-end application and user interface through which you access the Coinbase Platform and use the Coinbase Services. The Provider is solely responsible for its own application, services, disclosures, customer service, and its relationship with you.
"**Supported Digital Asset**" means only those particular Digital Assets listed as available to trade or custody in your Digital Asset Wallet (as defined below). Services and supported assets may vary by jurisdiction.
**Amendment of these Terms:** We may amend or modify this Agreement at any time by posting the revised agreement on our website, providing a copy to you through the Provider application in which you access Coinbase Services, and/or by other means (a “**Revised Agreement**”). The Revised Agreement shall be effective as of the time it is posted but will not apply retroactively. Your continued use of the Services after the posting of a Revised Agreement constitutes your acceptance of such Revised Agreement. If you do not agree with any such modification, your sole and exclusive remedy is to terminate your use of the Services and close your Coinbase Account.
**Dispute Resolution: PLEASE BE AWARE THAT SECTION 7 (CUSTOMER FEEDBACK, QUERIES, COMPLAINTS, AND DISPUTE RESOLUTION) AND APPENDIX 4 OF THIS AGREEMENT, CONTAIN PROVISIONS GOVERNING HOW TO RESOLVE DISPUTES BETWEEN YOU AND COINBASE. AMONG OTHER THINGS, APPENDIX 4 INCLUDES AN AGREEMENT TO ARBITRATE WHICH REQUIRES, WITH LIMITED EXCEPTIONS, THAT ALL DISPUTES BETWEEN YOU AND US SHALL BE RESOLVED BY BINDING AND FINAL ARBITRATION. APPENDIX 4 ALSO CONTAINS A CLASS ACTION AND JURY TRIAL WAIVER. PLEASE READ SECTION 7 AND APPENDIX 4 CAREFULLY.**
**No Investment Advice or Brokerage:** For the avoidance of doubt, Coinbase does not provide investment, tax, or legal advice, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. Coinbase may provide educational information about Supported Digital Assets, as well as Digital Assets not supported by Coinbase, in order to assist users in learning more about such Digital Assets. Information may include, but is not limited to, blog posts, articles, links to third-party content, news feeds, tutorials, and videos. The information provided by Coinbase through the Coinbase Platform, coinbase.com, any other Coinbase website, or any such third-party sites does not constitute investment advice, financial advice, trading advice, or any other sort of advice, and you should not treat any of the associated content as such. Coinbase does not recommend that any Digital Asset should be bought, earned, sold, or held by you. Coinbase will not be held responsible for the decisions you make to buy, sell, or hold Digital Assets based on the information provided by Coinbase. *You acknowledge and agree that Coinbase is not responsible for any investment, tax, or legal advice, recommendations, or information provided to you by the Provider or through the Provider’s application.*
Coinbase does not broker trades on your behalf unless otherwise specified on a specific product. All Coinbase trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures.
**Acknowledgement of Risk:** As with any asset, the value of Digital Assets can increase or decrease and there can be a substantial risk that you lose money buying, selling, holding, or investing in Digital Assets. You should consult your financial advisor, legal or tax professional regarding your specific situation and financial condition and carefully consider whether trading or holding Digital Assets is suitable for you.
Coinbase is not registered with the U.S. Securities and Exchange Commission and does not offer securities services in the United States or to U.S. persons. You acknowledge that Digital Assets are not subject to protections or insurance provided by the Federal Deposit Insurance Corporation or the Securities Investor Protection Corporation.
**Overlap with Other Coinbase Accounts:** This Agreement governs only your Coinbase Account and Services accessed through your Provider, and it does not affect any separate, direct Coinbase account you may hold (e.g., accounts accessed through coinbase.com or the Coinbase mobile application), which remain governed by their own applicable user agreements. In the event of any conflict between the terms of this Agreement and the terms of any other user agreement governing a separate Coinbase account, the terms of that separate user agreement will control with respect to that separate account.
**1. Account Setup**
**1.1. Eligibility**. To be eligible to use the Coinbase Services, you must be at least 18 years old, and reside in the United States. There are certain features which may or may not be available to you depending on your location and other criteria. You understand that the availability of Coinbase Services through a Provider is subject to the Provider’s own policies, including its eligibility and geographic restrictions, as well as the scope of services the Provider has elected to provide.
**1.2. Registration of Coinbase Account**. You must register for a Coinbase Account through the Provider’s application to use the Coinbase Services. You will need to complete certain verification procedures before you are permitted to use the Coinbase Services. By registering or using a Coinbase Account you agree and represent that you have created your Coinbase Account and you will use your Coinbase Account only for yourself, and not on behalf of any third party, unless you have obtained prior written approval from Coinbase. You are fully responsible for all activity that occurs under your Coinbase Account. We may, in our sole discretion, refuse to open a Coinbase Account, suspend or terminate any Coinbase Account, suspend or terminate the sending of Digital Assets from your account, or suspend or terminate the trading of Digital Assets in your account. Please see Section 6 below for more information.
**1.3. Consent to Access, Processing and Storage of Your Personal Data & Identity Verification**. During registration for your Coinbase Account, or at any other time deemed necessary by Coinbase, you acknowledge and agree that the Provider collects information from you and you expressly authorize the Provider to transmit to Coinbase all information we require (the “**KYC Data**”) for the purposes of identity verification, providing Coinbase Services to you, and the detection of money laundering, terrorist financing, fraud, or any other financial crimes and permit us to keep a record of such information. Coinbase will use the KYC Data to run its own identity verification procedures, sanctions screening, and monitoring program. Coinbase reserves the right to require further information from you, and to reject, restrict, or suspend your account regardless of the Partner’s own KYC decisions or determinations. You represent and warrant that the KYC Data provided by you to your Provider and subsequently forwarded to Coinbase is accurate and authentic. The KYC Data may include certain personal information, including, but not limited to, your name, address, telephone number, e-mail address, date of birth, taxpayer identification number, government identification, and information regarding your bank account (such as the name of the bank, the account type, routing number, and account number). You also direct Coinbase to share information back to your Provider for the purposes of facilitating the Services you have requested through the Provider’s application, including information about the status of your account, transaction details, and risk flags, for the purposes of facilitating the Services, identity verification, risk management, and compliance with legal and regulatory obligations.
In connection with providing the Services, you understand and agree that Coinbase may engage one or more Bank Partners to hold pooled or virtual accounts and to issue Deposit Instructions. Where required to open, maintain, or service those accounts and Deposit Instructions, you expressly authorize Coinbase to share your personal information, including KYC Data and, where applicable, information about your ownership or control of a legal entity, with its Bank Partners and their service providers. This data-sharing may include the information listed above in this Section 1.3 and any updates you later provide. Bank Partners will use this information solely to provide account, payment, sanctions, and compliance services to Coinbase and to comply with their own legal and regulatory obligations.
You consent to us accessing, processing and retaining any personal information you provide to us for the purpose of us providing Coinbase Services to you. This consent is not related to, and does not affect, any rights or obligations we or you have in accordance with data protection laws, privacy laws and regulations. You can withdraw your consent at any time by closing your account with us. However, we may retain and continue to process your personal information if we reasonably believe it is necessary in order to comply with laws or regulations. In providing us with this or any other information that may be required, you confirm that the information is accurate and authentic. You agree to keep your Provider updated if any of the information you provide changes. **You authorize us to make inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries.** When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full. This is an identity check only and should have no adverse effect on your credit rating. We reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request. You further agree and authorize Coinbase and its affiliates to internally share your KYC Data, account data, transaction history, risk flags, and compliance scores with other Coinbase product lines and business units for the purposes of detecting, preventing, and responding to fraud, abuse, money laundering, terrorist financing, or other financial crimes, and ensuring compliance with applicable laws, sanctions programs, and internal policies. See our [Privacy Policy](https://www.coinbase.com/legal/privacy), [U.S. Financial Privacy Notice](https://www.coinbase.com/legal/financial-privacy), and [Cookie Policy](https://www.coinbase.com/legal/cookie) for more information on how we process your personal data and the rights you have in respect of this.
**1.4. Access.** The Coinbase Services you access through a Provider may become degraded or unavailable during times of significant volatility or volume. This could result in significant support response time delays. Coinbase has no control over the Provider’s application availability or service quality, and is not responsible for any losses arising from disruptions to the Provider’s application. Although we strive to provide you with excellent service, we do not represent that Coinbase Services will be available without interruption and we do not guarantee that any order or instruction will be executed, accepted, recorded, or remain open. Coinbase shall not be liable for any losses resulting from or arising out of delays in processing transactions, inability to execute transactions, or lack of timely response from Coinbase customer support. For example, if you are locked out of your Coinbase Account, it is possible that the value or price of the Digital Assets in your account might go down before your access is restored. Coinbase shall not be liable for any alleged losses that you suffer from a drop in Digital Asset values or prices.
**1.5. Withdrawal of Provider Authorization.** You may withdraw your authorization for the Provider to access your Coinbase Account or transmit instructions and data on your behalf by revoking the Provider's access permissions within the Provider’s application or by closing your Coinbase Account as described in Section 6.9. If you revoke the Provider’s authority, the Provider will no longer be able to transmit instructions to Coinbase or share new information with us; however, Coinbase reserves the right to retain data previously transmitted to us in accordance with our Privacy Policy, U.S. Financial Privacy Notice, and all applicable laws and regulations. You acknowledge that the Provider is solely responsible for the administration and functionality of its revocation mechanism, and Coinbase is not liable for any failure or delay by the Provider to properly process or communicate your revocation instruction.
**2. Hosted Wallet and Custodial Services**
**2.1. Product Scope and Limitations.** The Coinbase Services you access through your Provider are limited to those capabilities provided by Coinbase to your Provider via Coinbase’s API. These services may include the ability to: (i) establish and manage a Digital Asset Wallet; (ii) engage in Supported Digital Asset purchases, sales, and conversions; (iii) execute Digital Asset Transfers; and (iv) fund your account and withdraw funds via our fiat conversion services, as described in Section 2.10 (Fiat Conversion) and Section 3.1 (Fiat Funding and Withdrawals). You acknowledge that this Agreement does not grant you access to any services or products made available on Coinbase’s direct retail platforms (such as coinbase.com or the Coinbase mobile application), including but not limited to Staking Services, Coinbase Card products, USDC Rewards, Coinbase One, or any other retail-only features, unless such service is explicitly offered to you via your Provider and is governed by its own separate addendum or terms. The availability of any specific service, asset, or feature may vary depending on your Provider, your account type, and your jurisdiction.
**2.2. Hosted Wallet Services.** As part of your Coinbase Account, Coinbase will provide qualifying users with hosted Digital Asset wallet(s), each of which is an account for holding Supported Digital Assets (“**Digital Asset Wallet**”). You may also elect to use other products and services; additional rules associated with such product(s) and services(s) may apply.
**2.3. Hosted Digital Asset Wallet.** Your Digital Asset Wallet allows you to store, track, transfer, and manage your balances of Supported Digital Assets. We securely store Digital Asset private keys, which are used to process transactions, in a combination of online and offline storage. As a result of our security protocols, it may be necessary for us to retrieve private keys or related information from offline storage in order to facilitate Digital Asset Transfers (as defined below) in accordance with your instructions, and you acknowledge that this may delay the initiation or crediting of such Digital Asset Transfers.
**2.4. Supported Digital Assets.** Your Digital Asset Wallet is intended solely for proper use of Supported Digital Assets as designated on the Platform. ***Under no circumstances should you attempt to use your Digital Asset Wallet to store, send, request, or receive any assets other than Supported Digital Assets. Coinbase assumes no responsibility in connection with any attempt to use your Digital Asset Wallet with Digital Assets that we do not support. You acknowledge and agree that Coinbase is not liable for any unsupported Digital Asset that is sent to a wallet associated with your Coinbase Account. Coinbase may in its sole discretion terminate support for any particular Digital Asset. If you do not sell or send such Digital Asset off Platform before Coinbase terminates its support for such Digital Asset, then Coinbase may, in its discretion, remove such Digital Asset from your Digital Asset Wallet and credit your Digital Asset Wallet the equivalent market value of a Supported Digital Asset minus transaction costs.***
**2.5. Supplemental Protocols Excluded.** Unless otherwise specifically announced on the Coinbase Platform or as set forth in this Agreement, Supported Digital Assets excludes all other protocols and/or functionality which supplement or interact with the Supported Digital Asset. This exclusion includes but is not limited to: metacoins, colored coins, side chains, or other derivative, enhanced, or forked protocols, tokens, or coins or other functionality, such as staking, protocol governance, and/or any smart contract functionality, which may supplement or interact with a Supported Digital Asset. Do not use your Coinbase Account to attempt to receive, request, send, store, or engage in any other type of transaction or functionality involving any such protocol as the Coinbase Platform is not configured to detect, secure, or process these transactions and functionality. Any attempted transactions in such items will result in loss of the item. *You acknowledge and agree that other than as set forth in this Agreement supplemental protocols are excluded from Supported Digital Assets and that Coinbase has no liability for any losses related to supplemental protocols.*
**2.6. Fungibility of Certain Digital Assets.** You acknowledge and agree that Coinbase may hold Supported Digital Assets in your Digital Asset Wallets in a variety of different ways, including across multiple blockchain protocols, such as layer two networks, alternative layer one networks, or side chains. In connection with its holding of Supported Digital Assets in your Digital Asset Wallets, Coinbase may transfer such Digital Assets off of the primary blockchain protocol and hold such Digital Assets on shared blockchain addresses, controlled by Coinbase, on alternative blockchain protocols in forms compatible with such protocols. You agree that all forms of the same Digital Asset that are held and made available across multiple blockchain protocols may be treated as fungible and the equivalent of each other, without regard to (a) whether any form of such Digital Asset is wrapped or (b) the blockchain protocol on which any form of such Digital Asset is stored.
**2.7. Operation of Digital Asset Protocols.** Coinbase does not own or control the underlying software protocols which govern the operation of Digital Assets. Generally, the underlying protocols are open source, and anyone can use, copy, modify, and distribute them. We assume no responsibility for the operation of the underlying protocols and do not guarantee the functionality or security of network operations. In particular, the underlying protocols may be subject to sudden changes in operating rules (including “forks”). Any such operating changes may materially affect the availability, value, functionality, and/or the name of the Digital Assets in your Digital Asset Wallet or other wallet. Coinbase does not control the timing and features of these operating changes. It is your responsibility to make yourself aware of upcoming operating changes and you must carefully consider publicly available information and information that may be provided by Coinbase or your Provider in determining whether to continue to use a Coinbase Account for the affected Digital Asset. In the event of any such operational change, Coinbase reserves the right to take such steps as may be necessary to protect the security and safety of assets held on the Coinbase Platform, including without limitation, temporarily suspending operations for the involved Digital Asset(s); Coinbase will endeavor to provide you notice of its response to any material operating change; however, such changes are outside of Coinbase’s control and may occur without notice to Coinbase. Coinbase’s response to any operating change is subject to its sole discretion and may include deciding not to support any new Digital Asset, fork, or other actions. ***You acknowledge and accept the risks of operating changes to Digital Asset protocols and agree that Coinbase is not responsible for such operating changes and not liable for any loss of value you may experience as a result of such changes in operating rules. You acknowledge and accept that Coinbase has sole discretion to determine its response to any operating change and that we have no responsibility to assist you with unsupported currencies or protocols. You further acknowledge and accept that Coinbase has no responsibility to support new Digital Asset forks or operating changes for Digital Assets.***
**2.8. Digital Asset Custody and Title.** All Supported Digital Assets held in your Digital Asset Wallet are custodial assets held by Coinbase for your benefit, as described in further detail below.
**2.8.1. Ownership.** Title to Supported Digital Assets shall at all times remain with you and shall not transfer to Coinbase. All interests in Digital Assets we hold for Digital Asset Wallets are held for customers, are not property of Coinbase, and are not subject to claims of Coinbase’s creditors. As owner of the Supported Digital Assets in your Digital Asset Wallet, you shall bear all risk of loss of such Supported Digital Assets. Coinbase shall have no liability for Supported Digital Asset fluctuations or loss. None of the Supported Digital Assets in your Digital Asset Wallet are the property of, or shall or may be loaned to, Coinbase; Coinbase does not represent or treat assets in user’s Digital Assets as belonging to Coinbase. Coinbase may not grant a security interest in the Supported Digital Assets held in your Digital Asset Wallet. Except as required by law, or except as provided herein, Coinbase will not sell, transfer, loan, hypothecate, or otherwise alienate Supported Digital Assets in your Digital Asset Wallet unless instructed by you (and, when so instructed by you, only where permitted by law).
**2.8.2 Application of the Uniform Commercial Code.** All Supported Digital Assets credited to the Digital Asset Wallet will be treated as “financial assets” under Division 8 of the California Uniform Commercial Code (“Division 8”). Coinbase is a “securities intermediary” as used in Division 8 with respect to Supported Digital Assets, and your Digital Asset Wallet is a “securities account” as used in Division 8. As stated in Division 8, “the characterization of a person, business, or transaction for purposes of this division does not determine the characterization of the person, business, or transaction for purposes of any other law, regulation, or rule,” including the United States Commodity Exchange Act and any federal, state, or foreign securities law or regulation. Coinbase will comply with your instructions with respect to your Supported Digital Assets, subject to the terms of this User Agreement.
**2.8.3. Control and Customer Instructions.** You control the Digital Assets held in your Digital Asset Wallet. At any time, subject to outages, downtime, protocol requirements, time to conduct blockchain operations to fulfill your request, and other applicable policies, you may withdraw your Supported Digital Assets by instructing Coinbase, through your Provider’s application, to debit the applicable Supported Digital Asset from your Digital Asset Wallet and transfer the Digital Assets to a different blockchain address. As long as you continue to hold Supported Digital Assets with Coinbase, Coinbase shall retain control over electronic private keys associated with blockchain addresses operated by Coinbase, including the blockchain addresses used to hold the Supported Digital Assets credited to your Digital Asset Wallet.
**2.8.4. Omnibus Accounts.** In order to more securely and effectively custody assets, Coinbase may use shared blockchain addresses, controlled by Coinbase, to hold Supported Digital Assets for Digital Asset Wallets on behalf of customers and/or held on behalf of Coinbase. Although we maintain separate ledgers for users’ Coinbase Accounts and Coinbase accounts held by Coinbase for its own benefit, Coinbase shall have no obligation to create a segregated blockchain address for your Supported Digital Assets.
**2.8.5. Governance and Voting.** For certain Digital Assets, the underlying protocols offer stakers the ability to vote on matters related to the governance of protocol-level issues. Coinbase may or may not support voting for such assets, and may cease supporting voting at any time in its discretion. Coinbase will comply with your instruction to vote your Supported Digital Assets to the extent Coinbase or its affiliate supports voting for such Supported Digital Assets. In certain cases, Coinbase may vote on your behalf where Coinbase or the applicable protocol does not support delegated voting; in those instances, Coinbase will vote with the protocol’s recommendation.
**2.9. USDC Wallets.** You may elect to buy USD Coin (“USDC”) from Coinbase, a Digital Asset issued by Circle Internet Financial (“Circle”) and supported by Coinbase. You are the owner of the balance of your USDC Wallet. Coinbase is not the issuer of USDC, does not hold reserves for USDC, and has no obligation to repurchase your USDC for USD. You can redeem your USDC with Circle, and Coinbase may also elect to repurchase your USDC in exchange for USD. You agree to be bound by the terms of the Circle USDC User Agreement (located at [https://www.circle.com/legal/usdc-terms](https://www.circle.com/legal/usdc-terms)), which provides additional obligations, undertakings, and limitations with respect to USDC. You acknowledge that, under this Agreement, Coinbase does not offer you any rewards or interest on USDC held in your Digital Asset Wallet. Your Provider may, in its sole discretion and under a separate agreement with you, offer rewards or other incentives on your USDC balance. You agree that any such rewards or incentives are provided solely by the Provider, and Coinbase has no obligation or liability related to such rewards, including their calculation, payment, or forfeiture.
**2.10. Fiat Conversion.** Coinbase does not maintain a user-facing, stored-value fiat currency wallet for customers accessing Services through a Provider. Your Coinbase Account is intended to hold Supported Digital Assets only. All fiat transfers made to your account are immediately converted to Supported Digital Assets (for example, USDC) which are credited to your Digital Asset Wallet. To the extent any fiat balances are briefly maintained for users (if at all), they are solely incidental to these immediate conversion and transfer services, and Coinbase is not a general purpose fiat account provider to you. Coinbase shall not be liable for the unavailability, suspension, rejection, delay, return, recall, reversal, or restriction of any Deposit Instructions or related fiat transfer, or for any hold, review, freeze, or other action taken by any Bank Partner or applicable payment rail in connection with the services provided by any Bank Partner.
Your Provider may utilize Deposit Instructions (for example, an account and routing number) from Coinbase or a Bank Partner that allow you, your Provider, or another payer to send fiat currency to an account held by Coinbase or a Bank Partner for the purpose of funding your Coinbase Account. These Deposit Instructions are a funding mechanism only. Fiat currency sent to Deposit Instructions associated with your Coinbase Account, once received and credited by Coinbase, is converted to Supported Digital Assets (for example, USDC) and recorded in your Digital Asset Wallet as described above. USDC and other Digital Assets are not bank deposits, are not insured by the Federal Deposit Insurance Corporation, and may lose value.
**3. Payment Services, Purchase & Sale Transactions, and Credit Transactions**
**3.1 Fiat Funding and Withdrawals.** Access to one or more payment methods (fiat rails) may be provided by your Provider, and fiat funding to your account is received by Coinbase using one or more Bank Partners. In all cases, fiat funds sent to Deposit Instructions associated with your Coinbase Account are received into accounts held by or for Coinbase and are not held for you as a separate bank account or stored-value wallet. Coinbase will process fiat transactions where explicitly instructed by you via your Provider. Coinbase has no responsibility for bank, payroll, or card arrangements you may have with your Provider, and is not responsible for processing errors incurred by your Provider. Fiat currency transferred to your account via instructions from your Provider’s application will be immediately converted to a Supported Digital Asset (e.g., USDC) and credited to your Digital Asset Wallet, as further described in Section 2.10 (Fiat Conversion). Deposit Instructions provided in connection with your Coinbase Account may only be used to receive payments for your own benefit. You must not use Deposit Instructions to operate a payment service or to receive or hold funds on behalf of your own customers or other end-clients, or otherwise act as a money transmitter, payment processor, or similar service provider. For withdrawals from your Coinbase Account, your Provider may initiate batched sweep instructions on a periodic or scheduled cadence for the conversion of Supported Digital Assets (such as USDC) and payout of fiat currency. You acknowledge that Coinbase is reliant on the Provider for the initiation and timing of these batched sweeps, and that delays can occur due to bank holidays, cut-off times, or decisions made by the Provider regarding the batching schedule. You agree that Coinbase is not responsible for any market volatility, price changes, or missed opportunities that occur during a delay caused by the Provider’s initiation or scheduling of these batched sweeps. Coinbase is only responsible for correctly executing the sweep instructions once they are authenticated and received from your Provider.
You acknowledge that Deposit Instructions, including any virtual account number, account and routing number, or similar payment details made available in connection with your Coinbase Account, may be issued, operated, monitored, or supported by one or more Bank Partners and their service providers. Bank Partners and their service providers operate and secure their own systems, networks, payment rails, and data-processing environments. To the maximum extent permitted by applicable law, Coinbase shall not be liable for, and you assume the risk of, any act, omission, outage, unavailability, delay, rejection, return, recall, reversal, hold, review, freeze, unauthorized access, Security Breach, data incident, or other failure occurring at or caused by any Bank Partner or its service providers in connection with Deposit Instructions or other Bank-Partner-backed services.
**3.2. Transactions on the Coinbase Platform.** When you buy or sell Supported Digital Assets on the Coinbase Platform, you are not buying Supported Digital Assets from Coinbase or selling Supported Digital Assets to Coinbase. Coinbase acts as the agent, transacting on your behalf, to facilitate that purchase or sale between you and other counterparties. You agree that instructions delivered to Coinbase via your Provider's application are deemed authorized by you. Coinbase’s duty is to execute the authenticated instructions it receives, but Coinbase is not liable for any failure, delay, or error in execution caused by the Provider mis-collecting, mis-formatting, or mis-routing the instructions before they reach the Coinbase Platform. All instructions for Digital Asset purchase or sales must be submitted to Coinbase via your Provider. Coinbase reserves the right to cancel any transaction not confirmed by you within five (5) seconds after Coinbase quotes a transaction price. A purchase of Supported Digital Assets generally will initiate on the business day we receive your instructions. Purchased Supported Digital Assets will usually be deposited in your Digital Asset Wallet instantly and can be exchanged for other Digital Assets. You can sell Supported Digital Assets and instruct Coinbase to deposit the proceeds into your Digital Asset Wallet. Supported Digital Asset purchases and sales on the Coinbase Platform are collectively referred to herein as “**Digital Asset Transactions**”. If Coinbase cannot complete your Digital Asset Transaction for any reason (such as price movement, market latency, inability to find a counterparty for your transaction, or order size), Coinbase will reject the order and notify your Provider of such rejection.
**3.3. Fees.** Your Provider may charge you fees in connection with your use of Coinbase Services. The total fee you see may include amounts retained by your Provider, amounts used to compensate Coinbase, network fees, spreads, or other costs. You acknowledge that Coinbase may receive fees or other compensation from your Provider under a separate agreement in connection with your use of Coinbase Services. These wholesale fees are not charged to you directly under this Agreement. Coinbase may charge network fees (for example, miner fees) and other costs to your Provider to process Digital Asset Transactions. To the extent any of those amounts are passed through to you, they will be included in the total fee disclosed by your Provider. Fees applicable to your use of Coinbase Services (as charged and disclosed by your Provider) may change from time to time. Where required by applicable law, your Provider (or Coinbase acting through your Provider) will provide you with any legally required notice of fee changes through your Provider’s customer communication channels. You acknowledge that Coinbase is not responsible for and does not set the pricing of the fees charged to you by your Provider and is not liable for any refund of fees collected by your Provider, even if a transaction is canceled or reversed.
**3.4. Unauthorized and Incorrect Transactions.** When a transaction occurs using your credentials or other authentication factors for your access to the Coinbase Services through your Provider’s application, we will assume that you authorized such transaction, unless you notify us otherwise. If you believe you did not authorize a particular transaction or that a transaction was incorrectly carried out, you must contact your Provider as soon as possible using the support channels your Provider makes available. If your Provider cannot resolve the dispute, you must follow the Formal Complaint Process described in Section 7, below. It is important that you regularly check your account with your Provider, your Digital Asset Wallet, and your transaction history to ensure you notify your Provider as soon as possible of any unauthorized or incorrect transactions. Reporting an unauthorized transaction does not guarantee your Provider or Coinbase will be able to reverse the transaction or reimburse you for the transaction.
**3.5. Reversals & Cancellations.** You cannot cancel, reverse, or change any transaction marked as complete or pending. The Provider, not Coinbase, manages fiat payments to the Coinbase Services. As such, the Provider is responsible for addressing issues arising if your payment is not successful, if your payment method has insufficient funds, or if you reverse a payment made from funds in your bank account. We reserve the right to refuse to process, or to cancel, correct, clawback, or reverse, any Digital Asset Transaction or transfers in our sole discretion, even after funds have been debited from your account(s), in response to a subpoena, court order, or other government order; or if we suspect the transaction may: involve money laundering, terrorist financing, fraud, or any other type of financial crime; be erroneous; or relate to a Prohibited Use or a Prohibited Business as set forth in the [Prohibited Use Policy](https://www.coinbase.com/legal/prohibited_use). In such instances, Coinbase will reverse the transaction and we are under no obligation to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction. Where fiat deposits are made via Deposit Instructions associated with your Coinbase Account, you understand that such deposits may be subject to reversal, return, or recall under applicable network and banking rules, and that Coinbase may be required or permitted to honor such reversals or returns. In that event, Coinbase may debit or restrict your Coinbase Account, or take other actions described in this Agreement, to reflect the reversal or return.
**4. Digital Asset Transfers**
**4.1. In General.** Your Digital Asset Wallet enables you to send Supported Digital Assets to, and request, receive, and store Supported Digital Assets from, third parties by giving instructions through your Provider. Your transfer of Supported Digital Assets between your other Digital Asset wallets (including wallets off the Coinbase Platform) and to and from third parties is a “**Digital Asset Transfer**”. We recommend customers send a small amount of Supported Digital Assets as a test before sending a significant amount of Supported Digital Assets.
**4.2. Pending Transactions.** Once a Digital Asset Transfer is submitted to a Digital Asset network, the transaction will be unconfirmed and remain in a pending state for a period of time sufficient to allow confirmation of the transaction by the Digital Asset network. A Digital Asset Transfer is not complete while it is in a pending state. Pending Digital Asset Transfers that are initiated via your Provider will reflect a pending transaction status and are not available to you for use while the transaction is pending.
**4.3. Inbound Digital Asset Transfers.** When you or a third party sends Digital Assets to a Coinbase Wallet from an external wallet not hosted on Coinbase (“**Inbound Transfers**”), the person initiating the transaction is solely responsible for executing the transaction properly, which includes ensuring that the Digital Asset being sent is a Supported Digital Asset that conforms to the particular wallet address to which funds are directed, including any required Destination Tag/Memo. **By initiating an Inbound Transfer, you attest that you are transacting in a Supported Digital Asset that conforms to the particular wallet address to which funds are directed. For example:**
* **If you select an Ethereum wallet address to receive funds, you attest that you are initiating an Inbound Transfer of Ethereum alone, and not any other Digital Asset such as Bitcoin or Ethereum Classic.**
* **If you select a Bitcoin wallet address to receive funds, you attest that you are initiating an Inbound Transfer of Bitcoin alone, and not any other Digital Asset such as Bitcoin Cash or Ethereum.**
**Coinbase incurs no obligation whatsoever with regard to unsupported Digital Assets sent to a Coinbase Account or with regard to Supported Digital Assets sent to an incompatible Digital Asset wallet address. If you send unsupported Digital Assets to a Coinbase Account or Supported Digital Assets to an incompatible Digital Asset wallet address, then you will lose those Digital Assets.** For some lost Digital Assets, Coinbase may in its sole discretion offer the option to attempt a recovery. We may charge fees to process the recovery attempt on your behalf. We will calculate all fees at our discretion, and notify you of the applicable fees at or before the time you authorize the recovery attempt. The actual amount recovered may differ from the estimated recovery amount. Coinbase does not evaluate the authenticity, safety, or security of unsupported Digital Assets. You acknowledge and agree that Coinbase is not liable for any loss incurred during the recovery attempt or subsequent use of the recovered Digital Asset.
Coinbase may from time to time determine types of Digital Assets that will be supported or cease to be supported. You acknowledge and agree that you may be required to pay network or miner’s fees in order for an Inbound Transfer transaction to be successful. Insufficient network fees may cause an Inbound Transfer to remain in a pending state on a decentralized network outside of Coinbase’s control, and we are not responsible for delays or loss incurred as a result of an error in the initiation of the transaction and cannot reverse such transactions.
**4.4. Outbound Digital Asset Transfers.** When you send Supported Digital Assets from your Coinbase Account to an external wallet (“**Outbound Transfers**”), such transfers are executed at your instruction by Coinbase. You should verify all transaction information prior to submitting instructions to us through the Partner’s application. Coinbase shall bear no liability or responsibility in the event you enter an incorrect blockchain destination address, incorrect Destination Tag/Memo, or if you send your Supported Digital Assets to an incompatible wallet. We do not guarantee the identity or value received by a recipient of an Outbound Transfer. Digital Asset Transfers cannot be reversed once they have been broadcast to the relevant Digital Asset network, although they may be in a pending state, and designated accordingly, while the transaction is processed by network operators. Coinbase does not control the Digital Asset network and makes no guarantees that a Digital Asset Transfer will be confirmed by the network. We may cancel or refuse to process any pending Outbound Digital Asset Transfers as required by law or any court or other authority to which Coinbase is subject in any jurisdiction. Additionally, we may require you to wait some amount of time after completion of a transaction before permitting you to use further Coinbase Services and/or before permitting you to engage in transactions beyond certain volume limits.
**4.5. Debts.** In the event that there are outstanding amounts owed to us hereunder, including in your Coinbase Account, Coinbase reserves the right to debit your Coinbase Account accordingly and/or to withhold amounts from funds you may transfer between your Coinbase Accounts.
**5. Data Protection and Security**
**5.1. Personal Data.** You acknowledge that we may process personal data in relation to you (if you are an individual), and personal data that you have provided or in the future provide to us in relation to your employees and other associated individuals, including data provided to us by your Provider and data shared with Bank Partners as described in Section 1.3, in connection with this Agreement, or the Coinbase Services. Accordingly, you represent and warrant that: (i) your disclosure to us of any personal data relating to individuals other than yourself was or will be made in accordance with all applicable data protection and data privacy laws, and such data are accurate, up to date and relevant when disclosed; (ii) before providing any such personal data to us, you have read and understood our Privacy Policy and U.S. Financial Privacy Notice, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided a copy of that Privacy Policy and U.S. Financial Privacy Notice (as amended from time to time), to that individual; and (iii) if from time to time we provide you with a replacement version of the Privacy Policy and U.S. Financial Privacy Notice, you will promptly read that notice and provide a copy to any individual whose personal data you have provided to us.
**5.2. Security Breach.** If you suspect that your Coinbase Account or any of your security details have been compromised or if you become aware of any fraud or attempted fraud or any other security incident (including a cyber-security attack) affecting you and/or Coinbase (collectively a "**Security Breach**"), you must notify your Provider immediately and provide accurate and up to date information throughout the duration of the Security Breach. You must take any steps that we or your Provider reasonably require to reduce or manage any Security Breach. Prompt reporting of a Security Breach does not guarantee that Coinbase will reimburse you for any losses suffered or be liable to you for any losses suffered as a result of the Security Breach. Without limiting any other provision of this Agreement, you acknowledge and agree that Bank Partners and their service providers may receive, process, store, transmit, and secure your information in connection with Deposit Instructions and other Bank-Partner-backed services. To the maximum extent permitted by applicable law, neither Coinbase nor any Bank Partner or its service providers will be liable to you for any loss, damage, claim, cost, or expense arising out of or relating to any Security Breach, unauthorized access, data breach, or other security incident occurring in the systems or environment of any Bank Partner or its service providers.
**5.3. Computer Viruses.** We shall not bear any liability, whatsoever, for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from Coinbase. Always log into your Coinbase Account(s) through your Provider’s application to review any transactions or required actions if you have any uncertainty regarding the authenticity of any communication or notice.
**5.4 Provider Security Breach.** We shall not bear any liability, whatsoever, for any damage or interruptions caused by any breach, fraud, attempted fraud, virus or malicious code, or any other attack on your Provider that interrupts or interferes with your use of the Coinbase Services.
**6. General Obligations, Taxes, Designating a Fiduciary and Termination**
**6.1. Limited Platform License and Trademarks.** Coinbase and its affiliates own all right, title, and interest in and to the Coinbase Platform and Coinbase Services, including all associated software, APIs, and related technology. Subject to this Agreement, Coinbase grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Coinbase Platform through your Provider’s application solely to access the Coinbase Services for your own personal use. Coinbase and its licensors reserve all rights not expressly granted. “Coinbase Marks” (including the COINBASE name and associated logos) are trademarks of Coinbase or its licensors. You may not use any Coinbase Marks in any manner without Coinbase’s prior written consent. You agree you will not copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Platform, in whole or in part without the prior written consent of Coinbase.
**6.2. Information Accuracy.** Although we intend to provide accurate and timely information on the Coinbase Platform, the Coinbase Platform may not always be entirely accurate, complete or current and may also include technical inaccuracies or typographical errors. In an effort to continue to provide you with as complete and accurate information as possible, information may be changed or updated from time to time without notice, including without limitation information regarding our policies, products and services. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the Platform are your sole responsibility and we shall have no liability for such decisions. Information provided by third parties, including historical price and supply data for Digital Assets, is for informational purposes only and Coinbase makes no representations or warranties to its accuracy. Links to third-party materials (including without limitation websites) may be provided as a convenience but are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any third-party materials or on any third-party sites accessible or linked to the Platform.
**6.3. Third-Party and Provider Access.** You will access your Coinbase Account through your Provider’s applications and interfaces. Your Provider is solely responsible for its own apps, websites, APIs, authentication flows, security controls, and customer support. Granting your Provider the ability to transmit instructions or information to Coinbase on your behalf does not relieve you of your obligations under this Agreement. If you authorize *any* third party to access or connect to your Coinbase Account (whether your Provider or another third party, for example, by using that third party’s app or service), you are fully responsible for all actions and omissions of that third party. Coinbase is not responsible for, and you agree to indemnify Coinbase for, any loss or liability arising from such third-party access, except to the extent caused by Coinbase’s failure to perform its obligations under this Agreement.
**6.4. Transaction Limits.** The use of the Coinbase Services through your Provider’s application may be subject to transaction, volume, velocity, or other limits set by Coinbase, your Provider, or both. These limits may differ among customers and may depend on factors such as the verification steps you have completed, the payment methods you use, and other factors. Coinbase and your Provider may change, reduce, or refuse to apply any limits, as they deem necessary for compliance, risk management, security, or other legitimate business reasons.
**6.5. Unclaimed Property.** If Coinbase is holding Supported Digital Assets in your Coinbase Account, and has no record of you accessing the Services for several years, applicable law may require Coinbase to deliver any such funds (or their USD equivalent) to the applicable state or jurisdiction as unclaimed property.
**6.6. Authentication and Security; Contact Information.** You acknowledge and agree that your Provider is solely responsible for all authentication, credential management, and identity and access management (IAM) controls related to your access to the Coinbase Services through their application. Because the Provider controls your login credentials and system access, Coinbase is not liable for losses resulting from a compromise of the Provider’s systems, your devices, or your login credentials utilized through the Provider’s application, as further detailed in Section 8.1. You are responsible for creating strong credentials and maintaining security and control of any electronic devices, IDs, email addresses, passwords, hints, personal identification numbers (PINs), API keys or any other codes that you use to access your Provider’s application. Coinbase does not control your Provider’s IAM or device security measures. Any loss or compromise of your Provider’s login credentials or device security may result in unauthorized access to your Coinbase Account and loss or theft of assets. You must keep your contact information up to date with your Provider to receive notices or alerts. **You should never allow remote access or share your computer and/or computer screen with someone else when you are logged on to your Coinbase Account. Coinbase is not liable for any loss that you may sustain due to the compromise of your Provider’s authentication systems or your personal login credentials (including passwordless credentials such as Passkeys and any other means of authentication) of for your failure to follow or act on any notices or alerts we or your Provider may send. In the event you believe your Coinbase Account has been compromised, contact your Provider immediately.**
**6.7. Taxes.** The tax treatment of Digital Asset transactions is uncertain, and it is your responsibility to determine what taxes, if any, arise from transactions using Coinbase Services under this Agreement. Users are solely responsible for reporting and paying any applicable taxes arising from transactions using Coinbase Services, and acknowledge that Coinbase does not provide investment, legal, or tax advice governing these transactions. You understand that Coinbase shall report information with respect to your transactions, payments, transfers, or distributions made by or to you with respect to your activities using Coinbase Services to a tax or governmental authority to the extent such reporting is required by applicable law. Coinbase also shall withhold taxes applicable to your transactions or to payments or distributions made or deemed made to you to the extent such withholding is required by applicable law. From time to time, Coinbase may require your Provider to ask you for tax documentation or certification of your taxpayer status as required by applicable law, and any failure by you to comply with this request in the time frame identified may result in withholding and/or remission of taxes to a tax authority as required by applicable law. You should conduct your own due diligence and consult your own tax advisors before making any decisions with respect to Digital Asset transactions.
**6.8. Designating a Fiduciary (Death or Incapacity).** Your Provider may offer a mechanism for you to designate a fiduciary, or for a third party to notify us of your death or incapacity and submit supporting documentation. If you or your representative provide such a designation or documentation to your Provider, you authorize Coinbase to rely on any information and documents that the Provider transmits to us on your behalf. Coinbase has no obligation to act on a designation or documentation until we actually receive it in a form satisfactory to us, whether directly from you or your representative, or indirectly through your Provider. For security and legal reasons, if we receive legal documentation confirming your death, or other information leading us to believe you have died, we may freeze your Coinbase Account. During this time, no transactions may be completed until: (i) your designated fiduciary has opened a new Coinbase Account, as further described below, and the entirety of your Coinbase Account has been transferred to such new account; or (ii) we have received proof in a form satisfactory to us that you have not died. If we have reason to believe you may have died but we do not have proof of your death in a form satisfactory to us, you authorize us to make inquiries, whether directly or through third parties, that we consider necessary to ascertain whether you have died. Upon receipt by us of proof satisfactory to us that you have died, your designated fiduciary will be required to open a new Coinbase Account in order to gain access to the contents of your Coinbase Account. If you have not designated a fiduciary, then we reserve the right to (i) treat as your fiduciary any person entitled to inherit your Coinbase Account, as determined by us upon receipt and review of the documentation we, in our sole discretion, deem necessary or appropriate, including (but not limited to) a will, a living trust or a small estate affidavit; or (ii) require an order designating a fiduciary from a court having competent jurisdiction over your estate. In the event we determine, in our sole discretion, that there is uncertainty regarding the validity of the fiduciary designation, we reserve the right to require an order resolving such issue from a court of competent jurisdiction before taking any action relating to your Coinbase Account. Nothing in this Section 6.9 limits Coinbase’s ability to communicate directly with your fiduciary, estate representative, or heirs, or to rely on information and documentation they provide, even where your Provider is involved in receiving or transmitting communications or documents on their behalf.
**6.9. Suspension, Termination, and Cancellation.** Coinbase may suspend, restrict, or terminate your access to any or all of the Coinbase Services, and/or deactivate or cancel your Coinbase Account(s), with immediate effect for any reason at its sole discretion and is under no obligation to disclose the details of its decision to take such action with you. This includes, without limitation, suspension or termination based on risk associated with your Provider’s program or controls, or the termination or material restriction of Coinbase’s relationship with your Provider. You acknowledge that Coinbase's decision to take certain actions, including limiting access to, suspending, or closing your account for any reason in our sole discretion, may be based on confidential criteria that are essential to Coinbase's risk management and security protocols, including risk management and security protocols related to your Provider’s program and controls. You agree that Coinbase is under no obligation to disclose the details of its risk management and security procedures to you. You will be permitted to transfer Supported Digital Assets or funds associated with your hosted Digital Asset Wallet(s) for ninety (90) days after Account deactivation or cancellation unless such transfer is otherwise prohibited (i) under applicable law, including but not limited to applicable sanctions programs; or (ii) by a facially valid subpoena or court order. You may close your Coinbase Account at any time by following the procedures established by your Provider for account closure. As an alternative, you may contact Coinbase directly via the Formal Complaint Process (Section 7.2) to initiate account closure. You authorize us to cancel or suspend any pending transactions at the time of account closure. Coinbase may discontinue or change any product, service, or feature, in its sole discretion, at any time. Should your Provider terminate its relationship with us, or should Coinbase terminate its relationship with the Provider for any reason, your Coinbase Account(s) will be closed. You will be permitted to withdraw your Supported Digital Assets or funds associated with your hosted Digital Asset Wallet(s) for ninety (90) days following the date of closure, which withdrawal process will be facilitated by the Provider or, where required by law, by Coinbase directly. The Provider is responsible for communicating the withdrawal process to you.
**6.10. Export Controls and Sanctions.** Your use of the Coinbase Services is subject to applicable law including but not limited to export restrictions, end-user restrictions, antiterrorism laws, and economic sanctions. By sending, receiving, buying, selling, trading, or storing Digital Assets through the Coinbase Platform or Services, you agree that you will comply with all applicable laws. You are not permitted to acquire Digital Assets or use any of the Coinbase Services if doing so would violate applicable laws and regulations, including but not limited to those of the United Nations Security Council, the United States (including prohibiting dealings with sanctioned persons identified by the U.S. Department of the Treasury’s Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons (“**SDN**”), or other U.S. non-SDN restricted or prohibited parties lists, and those prohibiting dealings with persons organized, resident, or located in comprehensively sanctioned jurisdictions), and/or any other applicable federal, state, municipal or local laws and regulations (each as amended from time to time).
**7. Customer Feedback, Queries, Complaints, and Dispute Resolution**
**7.1. Contact and Support.** The Provider is your first line of support and is responsible for handling all feedback, general questions, and technical issues relating to your use of the Coinbase Services through the Provider's application. You agree to contact your Provider first to attempt to resolve any issue, as Coinbase does not provide first-line customer support. If your Provider cannot resolve a dispute, you must follow the Formal Complaint Process described in Section 7.2. Coinbase requires that all legal documents (including civil subpoenas, complaints, and small claims) be served on our registered agent for service of process. Current contact information for our registered agent in each state can be found [here](https://www.cscglobal.com/cscglobal/pdfs/CSC-registered-agent-addresses.pdf). Please note that our registered agent will accept service only if the entity identified as the recipient of the document identically matches the name of the entity registered with the Secretary of State and for which our registered agent is authorized to accept service (Coinbase, Inc.). By accepting service of a legal document, Coinbase does not waive any objections we may have and may raise in response to such document.
**7.2. Formal Complaint Process.** You may contact Coinbase directly for formal complaints only after you have attempted to resolve the issue with your Provider, or if the matter relates specifically to Coinbase’s statutory or regulatory obligations. If your Provider cannot resolve the dispute, or if the dispute relates specifically to a statutory or regulatory obligation of Coinbase, you agree to use the Formal Complaint Process set forth below before filing any arbitration claim or small claims action as described further in Appendix 4 below. You must complete the Formal Complaint Process before filing any arbitration or small claims action. If you do not complete it, then you agree that your claim or action must be dismissed from arbitration or small claims court.
**7.2.1. Procedural Steps.** In the event that the dispute is not resolved through your contact with the Provider, you may then contact Coinbase Support at 1-888-908-7930. If we cannot resolve the dispute through Coinbase Support, you agree to submit a formal written complaint to [support@coinbase.com](mailto:support@coinbase.com) describing your dispute, how you would like us to resolve the complaint, and any other relevant information. If you prefer to send a written complaint via mail, please include as much information as possible in describing your complaint and how you would like us to resolve the complaint, including your support case number and any other relevant information to Coinbase, Inc., 228 Park Ave S #23008, New York, NY, 10003. We will acknowledge receipt of your complaint form after you submit it. A Coinbase customer relations agent will review and evaluate your complaint based on the information you have provided and information in the possession of Coinbase. The Formal Complaint Process is completed when Coinbase responds to your complaint or forty-five (45) business days after the date we receive your complaint, whichever occurs first.
**7.3. Arbitration.** You agree to be bound by the Arbitration Agreement in Appendix 4 to this Agreement.
**8. Liabilities & Indemnification**
**8.1. Release; Provider and Third-Party Responsibility; Indemnification.** To the maximum extent permitted by applicable law, you release Coinbase, its affiliates, Bank Partners, other service providers, and each of their respective officers, directors, agents, joint venturers, employees and representatives from any and all claims, demands and damages (actual and consequential) of every kind and nature arising out of or in any way connected with any dispute you have with (i) your Provider or its affiliates, (ii) any Bank Partner or Bank Partner service provider, (iii) any other user of Coinbase services, or (iv) any other third party whose products or services you use in connection with your Coinbase Account, except to the extent such dispute arises from Coinbase’s failure to perform its obligations under this Agreement. You understand that you access your Coinbase Account through your Provider’s applications and identity and access management systems. Your Provider is solely responsible for its own authentication flows, credential management, device and application security, and user‑support processes. To the maximum extent permitted by applicable law, Coinbase is not responsible for, and will not be liable for, any loss or unauthorized transaction that results from: (i) compromise of your Provider’s systems, credentials, or identity and access management controls; (ii) compromise of your devices, networks, or login credentials, in each case where Coinbase processed the relevant instructions in accordance with its standard security procedures and had no reason to doubt their authenticity; (iii) the Provider application’s downtime or performance issues; (iv) inaccuracies in any fees, disclosures, or marketing materials presented by the Provider; or (v) failures in the Provider’s customer support. If you authorize any other third party to access or connect to your Coinbase Account, you are fully responsible for all actions and omissions of that third party. You agree to indemnify and hold Coinbase, its affiliates and service providers, and each of their respective officers, directors, agents, joint venturers, employees and representatives harmless from any claim, demand, loss, damage, cost or expense (including reasonable attorneys’ fees and any fines, fees or penalties imposed by any regulatory authority) arising out of or related to: (i) your breach of this Agreement; (ii) your violation of any applicable law, rule or regulation; or (iii) any claim brought by your Provider or any other third party in connection with your misuse of Coinbase Services or your failure to comply with your separate agreement(s) with them. You further agree to indemnify and hold Coinbase harmless from any claim or loss arising from Coinbase’s reliance on inaccurate, incomplete, or fraudulent information transmitted to Coinbase by you or by your Provider on your behalf. You agree that instructions received by Coinbase via the API from your Provider constitute the authoritative and binding instructions regarding your Coinbase Account, and Coinbase shall not be responsible for resolving any conflict between such API instructions and any other communication received from you or your Provider through separate channels. Without limiting the foregoing, to the maximum extent permitted by applicable law, Coinbase is not responsible for, and you release the foregoing parties from, any loss, unauthorized transaction, claim, or liability arising out of or relating to any act, omission, outage, delay, rejection, return, recall, reversal, hold, review, freeze, restriction, Security Breach, unauthorized access, data incident, or other failure of any Bank Partner or Bank Partner service provider in connection with Deposit Instructions or other Bank-Partner-backed services.
**8.2. Limitation of Liability; No Warranty.** IN NO EVENT SHALL COINBASE, ITS AFFILIATES, BANK PARTNERS AND SERVICE PROVIDERS, OR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES OR REPRESENTATIVES, BE LIABLE (I) FOR ANY AMOUNT GREATER THAN THE VALUE OF THE SUPPORTED DIGITAL ASSETS ASSOCIATED WITH YOUR DIGITAL ASSET WALLET AT THE TIME OF THE EVENT OR CIRCUMSTANCE GIVING RISE TO YOUR CLAIM OR (II) FOR ANY LOST PROFITS, LOSS OF GOODWILL OR REPUTATION, LOSS OF DATA, DIMINUTION IN VALUE OR BUSINESS OPPORTUNITY, ANY LOSS, DAMAGE, CORRUPTION OR BREACH OF DATA OR ANY OTHER INTANGIBLE PROPERTY OR ANY SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, OR CONSEQUENTIAL DAMAGES, WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, ARISING OUT OF OR IN CONNECTION WITH ANY USE OF THE COINBASE PLATFORM OR THE COINBASE SERVICES, OR THIS AGREEMENT, EVEN IF COINBASE HAS BEEN ADVISED OF OR KNEW OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES, AND NOTWITHSTANDING THE FAILURE OF ANY AGREED OR OTHER REMEDY OF ITS ESSENTIAL PURPOSE, EXCEPT TO THE EXTENT OF A FINAL JUDICIAL DETERMINATION THAT SUCH DAMAGES WERE A RESULT OF COINBASE’S GROSS NEGLIGENCE, FRAUD, WILLFUL MISCONDUCT OR INTENTIONAL VIOLATION OF LAW. THIS MEANS, BY WAY OF EXAMPLE ONLY (AND WITHOUT LIMITING THE SCOPE OF THE PRECEDING SENTENCE), THAT IF YOU CLAIM THAT COINBASE FAILED TO PROCESS A BUY OR SELL TRANSACTION PROPERLY, YOUR DAMAGES ARE LIMITED TO NO MORE THAN THE LESSER OF THE VALUE OF THE SUPPORTED DIGITAL ASSETS AT ISSUE IN THE TRANSACTION OR THE TOTAL VALUE OF THE SUPPORTED DIGITAL ASSETS ASSOCIATED WITH YOUR DIGITAL ASSET WALLET, AND THAT YOU MAY NOT RECOVER FOR LOST PROFITS, LOST BUSINESS OPPORTUNITIES, DIMINUTION IN VALUE OR OTHER TYPES OF SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, EXEMPLARY, PUNITIVE OR CONSEQUENTIAL DAMAGES OR ANY DAMAGES ARISING OUT OF OR RELATING TO DIGITAL ASSETS THAT ARE NOT SUPPORTED DIGITAL ASSETS. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
THE COINBASE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, COINBASE SPECIFICALLY DISCLAIMS ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND/OR NON-INFRINGEMENT. COINBASE DOES NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT ACCESS TO THE COINBASE PLATFORM, ANY PART OF THE COINBASE SERVICES, OR ANY OF THE MATERIALS CONTAINED THEREIN, WILL BE CONTINUOUS, UNINTERRUPTED, TIMELY, OR ERROR-FREE. COINBASE DOES NOT GUARANTEE THAT ANY ORDER OR INSTRUCTION WILL BE EXECUTED, ACCEPTED, RECORDED OR REMAIN OPEN. EXCEPT FOR THE EXPRESS STATEMENTS SET FORTH IN THIS AGREEMENT, YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU HAVE NOT RELIED UPON ANY OTHER STATEMENT OR UNDERSTANDING, WHETHER WRITTEN OR ORAL, WITH RESPECT TO YOUR USE AND ACCESS OF THE COINBASE SERVICES AND COINBASE PLATFORM. WITHOUT LIMITING THE FOREGOING, YOU HEREBY UNDERSTAND AND AGREE THAT COINBASE WILL NOT BE LIABLE FOR ANY LOSSES OR DAMAGES ARISING OUT OF OR RELATING TO: (I) ANY INACCURACY, DEFECT OR OMISSION OF DIGITAL ASSET PRICE DATA, OR ANY ERROR, DELAY OR INTERRUPTION IN THE TRANSMISSION OF SUCH DATA; (II) VIRUSES OR OTHER MALICIOUS SOFTWARE OBTAINED BY ACCESSING SYSTEMS OPERATED BY US OR ON OUR BEHALF OR ANY OF THE COINBASE SERVICES; (III) GLITCHES, BUGS, ERRORS, OR INACCURACIES OF ANY KIND IN SYSTEMS OPERATED BY US OR ON OUR BEHALF OR ANY OF THE COINBASE SERVICES; OR (IV) A SUSPENSION OR OTHER ACTION TAKEN WITH RESPECT TO YOUR COINBASE ACCOUNT.
WITHOUT LIMITING THE FOREGOING, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, COINBASE AND ITS BANK PARTNERS MAKE NO REPRESENTATION OR WARRANTY WITH RESPECT TO THE CONTINUED AVAILABILITY, SECURITY, ERROR-FREE OPERATION, OR FREEDOM FROM INTERRUPTION OF ANY DEPOSIT INSTRUCTIONS, VIRTUAL ACCOUNT NUMBER, FIAT ACCOUNT, PAYMENT RAIL, OR OTHER BANK-PARTNER-BACKED SERVICE, AND WILL NOT BE LIABLE FOR ANY LOSS, DAMAGE, OR CLAIM ARISING OUT OF OR RELATING TO ANY EVENT OCCURRING AT THE LEVEL OF A BANK PARTNER OR ITS SERVICE PROVIDERS.
Bank Partners and their service providers are intended third-party beneficiaries of Sections 3.1, 5.2, 8.1, and 8.2, solely to the extent those provisions relate to Bank-Partner-backed services, and may enforce those provisions directly.
Coinbase will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts are processed in a timely manner but Coinbase makes no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control.
IF YOU ARE A NEW JERSEY RESIDENT, the provisions of this Section 8.2 are intended to apply only to the extent permitted under New Jersey law.
The foregoing limitations of damages, liability and no warranty provisions set forth above in this Section 8.2 are fundamental elements of the basis of the bargain between Coinbase and you.
**9. General Provisions**
**9.1. Entire Agreement.** This Agreement, the Privacy Policy, U.S. Financial Privacy Notice, E-Sign Disclosure and Consent Policy, Prohibited Use Policy, and Appendices incorporated by reference herein comprise the entire understanding and agreement between you and Coinbase as to the subject matter hereof, and supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), between you and Coinbase. Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.
**9.2. Assignment.** We reserve the right to assign our rights without restriction, including without limitation to any Coinbase affiliates or subsidiaries, or to any successor in interest of any business associated with the Coinbase Services. In the event that Coinbase is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. You may not assign any rights and/or licenses granted under this Agreement. Any attempted transfer or assignment by you in violation hereof shall be null and void. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns.
**9.3. Severability.** If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law, or regulation of any local, state, or federal government agency, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of this Agreement shall not be affected.
**9.4. Survival.** All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, sections pertaining to suspension or termination, Coinbase Account cancellation, debts owed to Coinbase, general use of the Coinbase Platform, disputes with Coinbase, and general provisions, shall survive the termination or expiration of this Agreement.
**9.5. Force Majeure.** We shall not be liable for delays, failure in performance or interruption of service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to, significant market volatility, act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, pandemic, other catastrophe or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.
**9.6. Non-Waiver of Rights.** This Agreement shall not be construed to waive rights that cannot be waived under applicable laws, including applicable state money transmission laws in the state where you are located. In addition, our failure to insist upon or enforce strict performance by you of any provision of this Agreement or to exercise any right under this Agreement will not be construed as a waiver or relinquishment to any extent of our right to assert or rely upon any such provision or right in that or any other instance.
**9.7. Relationship of the Parties.** Coinbase is an independent contractor for all purposes. Nothing in this Agreement is intended to or shall operate to create a partnership or joint venture between you and Coinbase, or authorize you to act as agent of Coinbase.
**9.8. Governing Law.** You and we agree that the laws of the State of California, without regard to principles of conflict of laws, will govern the Agreement and any Dispute, except to the extent governed by the Federal Arbitration Act or other applicable federal law.
**9.9. Class, Collective, Representative, and Mass Action Waiver and Jury Trial Waiver.** You and Coinbase agree that, except as specified in the Batch Arbitration Provision set forth above, each of us may bring claims against the other only on an individual basis and not on a class, representative, or collective basis or as part of a mass action (such as a mass arbitration), and the parties hereby waive all rights to bring or to participate in such actions in arbitration or in court to the maximum extent permitted by applicable law. This provision does not prevent you or Coinbase from participating in a class-wide settlement of claims. YOU AND WE AGREE TO WAIVE OUR RIGHTS TO A JURY TRIAL. To the extent that any Dispute proceeds in court, and to the maximum extent permitted by applicable law, you and we agree to waive any right to a jury trial and have such matter resolved by a judge (also known as a bench trial).
**9.10 Forum Selection.** Unless you and Coinbase agree otherwise, to the maximum extent permitted by applicable law, the state and federal courts in New York, New York (except for small claims courts, in which case you and we agree to resolve our Disputes in a small claims court of competent jurisdiction) will have exclusive jurisdiction over any Dispute that is not subject to arbitration or over any action involving the applicability or enforceability of the Dispute Resolution section 7 or any portion of the Dispute Resolution section (including the Arbitration Agreement, Appendix 4). You and Coinbase consent to the exclusive jurisdiction of these courts and waive any objections as to: (1) personal jurisdiction or (2) the laying of venue in such courts because of inconvenient forum or any other basis or right to seek to transfer or change venue of any such action to another court.
***
### **APPENDIX 1: Verification Procedures and Limits**
As a regulated financial services company, we are required to identify users of the Coinbase Services and to comply with applicable anti-money laundering (“AML”), sanctions, and related laws and regulations in the jurisdictions in which we operate. This ensures we remain in compliance with KYC/AML laws and other regulatory obligations, which is necessary for us to be able to continue to offer the Coinbase Services. You acknowledge that your Provider collects identity information and documentation on our behalf (the KYC Data) which is forwarded to Coinbase for verification. Coinbase collects and verifies information about you in order to: (i) protect Coinbase and the community from fraudulent users; (ii) to keep appropriate records of Coinbase's customers; and (iii) to comply with applicable legal, regulatory, and sanctions obligations. Your daily or weekly conversion limits, withdrawal and trading limits, and limits on transactions from a linked payment method are based on the identifying information and/or proof of identity you provide to Coinbase. In addition, the Provider through which you access the Coinbase Services may apply its own transaction or other limits, which are separate from, and may be in addition to or more restrictive than, any limits that Coinbase applies.
All customers who wish to use Coinbase Services are required to establish a Coinbase Account by completing any registration and identity‑verification steps that we, or your Provider acting on our behalf, may require from time to time. These steps, and the information and documentation requested, may vary depending on the Coinbase Services you use, the way you access them, and the jurisdiction in which you are located.
Notwithstanding any minimum verification procedures established for Coinbase Services, Coinbase may require you to provide or verify additional information, or to wait some amount of time after completion of a transaction, before permitting you to use any Coinbase Services and/or before permitting you to engage in transactions beyond certain volume limits.
If you have any questions about the limits that apply to your use of the Coinbase Services through a Provider, you should contact your Provider using the support channels it makes available to you.\
Coinbase may, in its discretion, require you to submit to enhanced due diligence ("EDD") before permitting you to use certain Coinbase Services or to engage in transactions beyond certain volume limits. Additional fees and costs may apply, and Coinbase does not guarantee that we will raise any applicable limits if requested.
***
### **APPENDIX 2: E-Sign Disclosure and Consent**
This policy describes how Coinbase delivers communications to you electronically, either directly or through your Provider. In most cases, communications will be delivered to you through your Provider’s application or other customer communication channels established by your Provider. However, Coinbase may also provide communications to you directly where appropriate or required by law. We may amend this policy at any time by providing a revised version on our website and/or through your Provider. The revised version will be effective at the time we or your Provider post it or otherwise make it available. We or your Provider will provide you with prior notice of any material changes via our website, your Provider’s application or website, or other communication channels.
**Electronic Delivery of Communications**
You agree and consent to receive electronically all communications, agreements, documents, notices and disclosures (collectively, "Communications") that we provide in connection with your Coinbase Account(s) and your use of Coinbase Services. You agree that we may provide Communications to you directly, or that your Provider may provide Communications to you on our behalf. Communications include, for example:
* Terms of use and policies you agree to (e.g., the Coinbase User Agreement, Privacy Policy and U.S. Financial Privacy Notice), including updates to these agreements or policies;
* Account details, history, transaction receipts, confirmations, and any other account or transaction information relating to your use of Coinbase Services (including where surfaced to you through your Provider);
* Legal, regulatory, and tax disclosures or statements we may be required to make available to you; and
* Responses to claims or customer support inquiries filed in connection with your Account or your use of Coinbase Services.
You consent to the use of electronic signatures in connection with your use of the Services.
Where applicable, we or your Provider may make tax forms and related documents available to you electronically and may ask you to consent to electronic or paperless delivery of such forms in accordance with applicable law. Information about how to access such documents and how to change your delivery preferences (if permitted) will be provided in the Provider application or website through which you access the Coinbase Services. As a general matter, Communications will be delivered to you through your Provider. In some cases, we may also deliver Communications directly using one or more of the following methods: (i) by posting them on coinbase.com; (ii) by emailing them to the email address associated with your account with your Provider or otherwise provided to us; or (iii) by any other electronic means that we or your Provider notify you of from time to time.
**Hardware and Software Requirements**
In order to access and retain electronic Communications, you will need the following computer hardware and software:
* A device with an Internet connection;
* A compatible device and operating system that are supported by your Provider;
* The current version of your Provider’s application installed and properly configured;
* A valid email address (your primary email address on file with your Provider or otherwise provided to us); and
* Sufficient storage space to save past Communications or an installed printer to print them.
**How to Withdraw Your Consent**
You may withdraw your consent to receive Communications electronically by contacting us at 1-888-908-7930. If you fail to provide or if you withdraw your consent to receive Communications electronically, Coinbase reserves the right to immediately close your Coinbase Account or charge you additional fees for paper copies.
**Updating your Information**
It is your responsibility to provide a true, accurate and complete e-mail address and your contact information, and to keep such information up to date. You agree to keep your contact information (including your primary email address) up to date with your Provider, and you authorize us to rely on the most recent contact information for you that we receive from your Provider. You understand and agree that if Coinbase sends you an electronic Communication but you do not receive it because your primary email address on file with your Provider is incorrect, out of date, blocked by your service provider, or you are otherwise unable to receive electronic Communications, Coinbase (and, where applicable, your Provider) will be deemed to have provided the Communication to you.
You may update your information by updating your contact details in your Provider’s application.
***
## **APPENDIX 3: State License Disclosures**
Coinbase maintains licenses to engage in money transmission activities in many states, and these licenses may impact our provision and your use of certain Coinbase Services depending on where you live. Coinbase's licenses and corresponding required disclosures can be found on the [Coinbase Licenses](https://coinbase.com/legal/licenses) page, which is incorporated by reference.
If you live in the following jurisdictions, we are required to provide you with the following information:
**Alaska**
If your issue is unresolved by Coinbase, Inc., 1-888-908-7930, please submit formal complaints with the State of Alaska, Division of Banking & Securities.
Please download the form here: [https://www.commerce.alaska.gov/web/portals/3/pub/DBSGeneralComplaintFormupdated.pdf](https://www.commerce.alaska.gov/web/portals/3/pub/DBSGeneralComplaintFormupdated.pdf)
Submit formal complaint form with supporting documents: Division of Banking & Securities PO Box 110807 Juneau, AK 99811-0807
If you are an Alaska resident with questions regarding formal complaints, please email us at [dbs.licensing@alaska.gov](mailto:dbs.licensing@alaska.gov) or call Nine Zero Seven Four Six Five Two Five Two One
**Arizona**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, lnc.'s money transmission activity, you may complete an Online Complaint Form as stated on the File a Complaint against a Financial Institution or Enterprise page: [https://difi.az.gov/complaint](https://difi.az.gov/complaint)
Or you may call the AZ Financial Institutions Division: (602) 771-2800 | Toll-free: (800) 544-0708
**Arkansas**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930.
If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file a complaint at: [https://securities.arkansas.gov/file-a-complaint-2/](https://securities.arkansas.gov/file-a-complaint-2/) or contact the Arkansas Securities Department at:
1 COMMERCE WAY, SUITE 402 LITTLE ROCK, ARKANSAS 72202 TELEPHONE: (501) 324-9260 FACSIMILE: (501) 324-9268
**California**
Please note the following disclosures for California resident customers of Coinbase, Inc.:
Please [see here](https://www.coinbase.com/legal/insurance) information regarding insurance available to Coinbase for certain assets on the Coinbase platform.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to unauthorized, fraudulent, and accidental transactions or transfers may not be recoverable.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
Following each transaction, your Provider will provide you with a receipt, trade ticket, or other evidence of the transaction. You can access these records in your account.
Virtual currency is not legal tender in California or the United States, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Please [see here](https://status.coinbase.com/) for information regarding current and historical availability/outages of Coinbase platform products and services.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you have an unresolved complaint regarding Coinbase, Inc., you can direct your complaint to the California Department of Financial Protection and Innovation:
Online: [https://dfpi.ca.gov/submit-a-complaint/](https://dfpi.ca.gov/submit-a-complaint/)\
DFPI consumer complaints email: [Ask.DFPI@dfpi.ca.gov](mailto:Ask.DFPI@dfpi.ca.gov)\
Toll Free: (866) 275-2677
Paper complaint forms can be mailed to the Department of Financial Protection and Innovation:
Attn: Consumer Services\
651 Bannon Street, Suite 300\
Sacramento, CA 95811
**Colorado**\
[MO7 Customer Notice - COLORADO MONEY TRANSMITTERS ACT](https://banking.colorado.gov/sites/banking/files/documents/MT_Customer_Notice_MO7_English_Spanish_03.2026_AccO.pdf)\
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Colorado Division of Banking.
The Complaint Process is available here: [https://banking.colorado.gov/consumers/file-a-complaint](https://banking.colorado.gov/consumers/file-a-complaint)
Colorado Division of Banking 1560 Broadway, Suite 975, Denver, CO 80202 Phone: 303-894-7575 Fax: 303-894-7570 E-mail: [DORA\_BankingWebsite@state.co.us](mailto:DORA_BankingWebsite@state.co.us)
**Connecticut**\
Please note the following disclosures associated with virtual currency:
**WARNING: LOSSES DUE TO FRAUDULENT OR ACCIDENTAL TRANSACTIONS MAY NOT BE RECOVERABLE AND TRANSACTIONS IN VIRTUAL CURRENCY ARE IRREVERSIBLE.**
Virtual currency is not backed or insured by the government and accounts and value balances are not subject to Federal Deposit Insurance Corporation, National Credit Union Administration or Securities Investor Protection Corporation protections.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which may not be the date or time when the customer initiates the virtual currency transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the permanent and total loss of the value of a particular virtual currency, if the market for that virtual currency disappears.
The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in a significant loss over a short period of time.
Any bond maintained by Coinbase for the benefit of the customers of Coinbase may not be sufficient to cover all losses incurred by such customers.
Virtual currency transactions are irreversible and are used by persons seeking to defraud customers, including, but not limited to, a person impersonating a customer's loved one, threatening jail time, stating that a customer's identity has been stolen, insisting that a customer withdraw money from the customer's bank account and purchase cryptocurrency or alleging a customer's personal computer has been hacked.\
If you have a complaint or questions, please contact Coinbase, Inc. Support at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, you may submit a formal complaint via [https://help.coinbase.com/en/contact-us/submit-a-complaint](https://help.coinbase.com/en/contact-us/submit-a-complaint). You may also contact the Connecticut Department of Banking at [https://portal.ct.gov/dob/consumer/consumer-complaints/money-transmitter](https://portal.ct.gov/dob/consumer/consumer-complaints/money-transmitter) with any complaints.
**District of Columbia**\
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Department at:
District of Columbia Department of Insurance, Securities and Banking 1050 First St., NE, Suite 801 Washington, DC 20002 Phone: (202) 727-8000 Fax: (202) 354-1085 E-mail: [disbcomplaints@dc.gov](mailto:disbcomplaints@dc.gov)
[Consumer Complaint Form Mail-in Version](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB%20Consumer%20Complaints_final%20fillable.pdf)
**Florida**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930[.](https://help.coinbase.com/en/contact-us.) If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Florida Office of Financial Regulation at: Online: [https://flofr.gov/sitePages/FileAComplaint.htm](https://flofr.gov/sitePages/FileAComplaint.htm). To file your complaint, you will need to register electronically through Online Services. A valid email address is required.
Florida Office of Financial Regulation - Consumer Finance 200 E. Gaines Street, Tallahassee, FL 32399-0376 850-487-9687
FL Office of Financial Regulation Complaint Portal: [https://flofr.gov/sitePages/FileAComplaint.htm](https://flofr.gov/sitePages/FileAComplaint.htm)
**Georgia**
Licensed by The Georgia Department of Banking and Finance. (Lic. # 42796/ NMLS# 1163082).
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930[.](https://help.coinbase.com/en/contact-us) If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Georgia Department of Banking and Finance - Consumer Resources: [https://consumer.georgia.gov/resolve-your-dispute/how-do-i-file-complaint](https://consumer.georgia.gov/resolve-your-dispute/how-do-i-file-complaint)
**Illinois**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Illinois Division of Banking at:
[https://idfpr.illinois.gov/admin/dfi/dficomplaint.html](https://idfpr.illinois.gov/admin/dfi/dficomplaint.html)
**Kansas**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Office of the State Bank Commissioner.
If submitting electronically, submit your complaint here: [https://www.osbckansas.org/consumers/file-a-complaint/](https://www.osbckansas.org/consumers/file-a-complaint/)
Mail or fax the completed consumer assistance form and attachments to:
Kansas Office of the State Bank Commissioner: Attn: Consumer Affairs 700 SW Jackson St, Suite 300 Topeka, KS 66603 Fax: (785) 371-1229 Email: [complaints@osbckansas.org](mailto:complaints@osbckansas.org)
**Louisiana**
Please note the money transmission license issued to Coinbase, Inc. by the Louisiana Office of Financial Institutions does not cover the exchange or transmission of virtual currency.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Office of Financial Institutions.
All complaints must be submitted in writing. To file a complaint, please complete the complaint form and send to [OFI](http://www.ofi.state.la.us/) by mail, email, or fax.
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the value of virtual currency.
Transaction in virtual currency may be irreversible, and accordingly, losses due to fraudulent or accidental transactions may not be recoverable.
Some virtual currency transactions may be immediately effective when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange legal tender for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency if the market for the virtual currency declines or collapses for an extended period of time.
Any surety bond required by law for the benefit of customers may not be sufficient to cover all losses incurred by customers.
Customers should perform research before purchasing or investing in virtual currency.
Please see Coinbase’s Global Privacy Policy and U.S. Financial Privacy Notice, which describes how Coinbase collects, uses and discloses personal information.
**Maryland**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Maryland Department of Labor.
The Commissioner of Financial Regulation for the State of Maryland will accept all questions or complaints from Maryland residents regarding License No. 12-1163082 and NMLS ID: 1163082 by contacting the Commissioner's office at: 500 North Calvert Street, Suite 402, Baltimore, Maryland 21202, or (888) 784-0136. Additional information about Coinbase, Inc. may be obtained at [www.nmlsconsumeraccess.org](http://www.nmlsconsumeraccess.org/)
**Minnesota**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Minnesota Department of Commerce.
To make a complaint, please make a call contacting the following:
Minnesota Department of Commerce 85 8th Place East, Suite 208 Saint Paul, MN 55101 (Local) 651-539-1500 (Complaints) 651-539-1600
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
**Mississippi**
The Mississippi Department of Banking & Consumer Finance recommends that you attempt to resolve your complaint with the financial institution first by contacting Coinbase, Inc. at 1-888-908-7930 to allow the opportunity to resolve the issue(s). If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file your complaint online at [https://dbcf.ms.gov/complaint-form/](https://dbcf.ms.gov/complaint-form/)
**Nevada**
Coinbase, Inc. is licensed by the Nevada Department of Business and Industry as a money transmitter. At this time, the Nevada Department of Business and Industry does not license or regulate services related to virtual currency, including but not limited to virtual currency transmission or exchange which may be conducted by Coinbase.
If you have a question or complaint, please first contact the consumer assistance division of Coinbase at (888) 908-7930, or at its mailing address: 228 Park Ave S #23008, New York, NY, 10003. If you have an unresolved question or complaint regarding the money transmission services provided by Coinbase, you may contact the Nevada Department of Business and Industry at (702) 486-4120.
**New York**
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the use, transfer, exchange, and value of virtual currency.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency should the market for that virtual currency disappear.
There is no assurance that a person who accepts a virtual currency as payment today will continue to do so in the future.
The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in significant loss over a short period of time.
The nature of virtual currency may lead to an increased risk of fraud or cyber attack.
The nature of virtual currency means that any technological difficulties experienced by Coinbase may prevent the access or use of a customer’s virtual currency.
Any bond or trust account maintained by Coinbase for the benefit of its customers may not be sufficient to cover all losses incurred by customers.
Coinbase, Inc. is regulated and licensed as a money transmitter by the New York State Department of Financial Services. If you have a question or complaint, please first contact the consumer assistance division of Coinbase at (888) 908-7930, or at its mailing address: 228 Park Ave S #23008, New York, NY, 10003.
For unresolved/written complaints, you may mail a complaint to New York State Department of Financial Services, Consumer Services Division, One State Street, New York, NY 10004-1417, (800) 342-3736, email: [consumers@dfs.ny.gov](mailto:consumers@dfs.ny.gov), website: [www.dfs.ny.gov/complaint](https://www.dfs.ny.gov/complaint).
**North Dakota**
Coinbase, Inc. is licensed by the North Dakota Department of Financial Institutions as a money transmitter. If you have a question or complaint, please first contact the consumer assistance division of Coinbase at (888) 908-7930, or at its mailing address: 228 Park Ave S #23008, New York, NY, 10003. If you have an unresolved question or complaint regarding the money transmission services provided by Coinbase, you may contact the North Dakota Department of Financial Institutions at (701) 328-9933.
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
**Rhode Island**
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
**Tennessee**
Coinbase, Inc. is licensed by the Tennessee Department of Financial Institutions as a money transmitter.
The Tennessee Department of Financial Institutions does not regulate virtual currency. Please note that this license and the required surety bond do not cover the transmission of virtual currency. The Tennessee Department of Financial Institutions does not regulate virtual currency. Tennessee’s Money Transmitter License and the required surety bond do not cover the transmission of virtual currency. However, any company that offers to exchange, administer, or maintain virtual currencies for sovereign currency may be subject to state regulation and licensing as well as federal regulation.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, please direct your complaint to: [https://www.tn.gov/tdfi/tdfi-how-do-i/file-a-complaint.html](https://www.tn.gov/tdfi/tdfi-how-do-i/file-a-complaint.html) or call the Tennessee Department of Financial Institutions at 1-800-778-4215
**Texas**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, please direct your complaint to: [https://www.dob.texas.gov/money-services-businesses/how-file-complaint](https://www.dob.texas.gov/money-services-businesses/how-file-complaint)
Virginia Coinbase, Inc. is licensed by the Virginia State Corporation Commission as a money transmitter, but such license does not cover the transmission of virtual currency (Bitcoin).
**Washington**
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent, mistaken or accidental transactions may not be recoverable. If you believe you did not authorize a particular transaction or that a transaction was incorrectly carried out, you must contact us as soon as possible. Reporting an unauthorized transaction does not guarantee Coinbase will be able to reverse the transaction or reimburse you for the transaction.
The nature of virtual currency may lead to an increased risk of fraud or cyber attack.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, you may file it by contacting the Washington Department of Financial Institutions at [https://dfi.wa.gov/consumers/money-services-complaint](https://dfi.wa.gov/consumers/money-services-complaint)
***
### **APPENDIX 4: DISPUTE RESOLUTION (INCLUDING ARBITRATION AGREEMENT; CLASS ACTION WAIVER; JURY TRIAL WAIVER; FORUM SELECTION CLAUSE)**
Disputes Defined. “Disputes” are defined as any dispute, claim, or disagreement arising out of or relating in any way to our relationship with you, the Services, the Coinbase Platform, any Communications you receive, any products or services sold or distributed through the Coinbase Platform, or the User Agreement. The term “Disputes” is intended to be interpreted broadly. The provisions below describe which Disputes belong in arbitration, small claims court, or a court of general jurisdiction.
Pre-Filing Formal Complaint Requirement. Before an arbitration demand or small claims action is filed, you and we agree to exhaust the Formal Complaint Process. *See* Section 7.1, above.
Arbitration Agreement. You and we agree to arbitrate all Disputes in binding arbitration except for the following types of Disputes:
*1. Disputes about whether the Dispute is arbitrable.* You and we agree that any Disputes arising out of or related to the interpretation or application of the Arbitration Agreement, including Disputes about the enforceability, revocability, scope, or validity of the Dispute Resolution section or any portion of the Dispute Resolution section (including the Arbitration Agreement) shall be resolved in a court of competent jurisdiction, not arbitration. This includes, but is not limited to, any dispute about whether the Batch Arbitration provision applies to the Dispute.
*2. Disputes that are within the jurisdiction of a small claims court.* You and we agree that if a Dispute could be brought in a small claims court in the county or parish in which you reside, then it *must* be brought in that small claims court, not arbitration, provided that it remains in that court and is not removed or appealed to a court of general jurisdiction.
*3. Disagreements about whether a Dispute is within the jurisdiction of a small claims court.* You and we agree that any disagreement about whether a Dispute is within the jurisdiction of a small claims court will be resolved by the small claims court in the first instance. Disagreements about whether a Dispute is within the jurisdiction of a small claims court may otherwise be resolved in a court of competent jurisdiction, but only after you or we have exhausted resolution from the small claims court.
*4. Disputes about or related to infringement or misuse of intellectual property (“IP”) rights (e.g., trademarks, trade dress, domain names, trade secrets, copyrights, and patents).* You and we agree that you or Coinbase must resolve IP Disputes outside of arbitration (e.g., in a court of competent jurisdiction). This means, for example, if you have a Dispute that contains an IP cause of action, which is not arbitrable under this agreement, and other causes of action that are arbitrable, then the arbitrable causes of action must proceed in arbitration and the IP cause of action must proceed outside of arbitration consistent with the other terms of the User Agreement. You and we agree that all IP Disputes shall not be stayed solely on the grounds that there exists a pending arbitration of arbitrable causes of action.
*5. Disputes about whether you or we have violated state or federal securities laws.* In the event that there is a Dispute about whether you or we have violated state or federal securities laws, you and we agree that such Disputes shall be resolved by a court of competent jurisdiction. This means, for example, if you have a Dispute that contains causes of action under the state or federal securities laws and other causes of action that are arbitrable, then the arbitrable causes of action must proceed in arbitration and the state or federal securities laws causes of action must proceed in a court of competent jurisdiction.
Arbitration Procedure. You and we agree that arbitration under this Arbitration Agreement will, depending on the circumstance, be administered by the American Arbitration Association (“AAA”) subject to the AAA’s Consumer Arbitration Rules then in effect, except as modified by this Arbitration Agreement. If the AAA is unable or unwilling to administer the arbitration consistent with the Arbitration Agreement, or if the Dispute is part of a Batch Arbitration, you and we agree that JAMS will administer the arbitration subject to the JAMS Rules and Procedures then in effect, including any Mass Arbitration Procedures and Guidelines applicable to the Dispute, except as modified by this Arbitration Agreement. You and we agree that if JAMS is unable or unwilling to administer the arbitration consistent with the Arbitration Agreement, and the parties cannot agree on an alternative provider that will do so, then you or we may petition a court of competent jurisdiction to appoint an administrator that will do so. The AAA and JAMS rules are available at [https://adr.org/Rules](https://adr.org/Rules) and [https://www.jamsadr.com/adr-rules-procedures/](https://www.jamsadr.com/adr-rules-procedures/). You and we agree that the User Agreement evidences a transaction involving interstate commerce and notwithstanding any other provision with respect to the applicable substantive law, the Federal Arbitration Act, 9 U.S.C. § 1 *et seq.* and federal arbitration law (not state arbitration law) will govern any proceedings regarding enforcement of this Arbitration Agreement. Any applicable limitations periods (including statutes of limitations) shall apply in arbitration like in court. You and we agree that an arbitral award shall have no preclusive effect in any other proceeding involving other Users. You and we (and your and our counsel, if represented) agree to work together in good faith to ensure that arbitration remains efficient and cost-effective for all parties. The arbitrator shall have the authority to award sanctions against parties and their counsel consistent with the standard set forth in Federal Rule of Civil Procedure 11.
Severability. You and we agree to sever arbitrable Disputes (which shall be resolved in arbitration) from Disputes that are not arbitrable (which shall be resolved in court); you and we also agree that if any provision of this Arbitration Agreement is found unenforceable, then that portion of the Arbitration Agreement shall be severed and the remainder of the Arbitration Agreement shall continue to control. Notwithstanding the foregoing, if the “Batch Arbitration” provision would otherwise apply to the Dispute, but a court of competent jurisdiction determines that the “Batch Arbitration” provision is unenforceable as to the Dispute or a portion of the Dispute (and all appeals have been exhausted or the ruling is otherwise final) or JAMS or a JAMS arbitrator refuses to apply all of the provisions of the Batch Arbitration provision as written, then the affected Dispute or portion of the Dispute cannot proceed in arbitration and may proceed in a court of competent jurisdiction consistent with the other terms of the User Agreement unless the parties agree otherwise in writing.
Confidentiality. You and we agree that any information exchanged between us in an arbitration may be used solely for that arbitration. You and we agree that we may not, for example, use information you or we obtained from the other party in one arbitration proceeding in another arbitration proceeding. You and we also agree to keep any information exchanged between us in any arbitration proceeding confidential between us, you, your and our attorneys, and the arbitrator. To the extent additional persons require access to information exchanged for purposes of the arbitration, you and we agree to negotiate in good faith for the entry of a protective order that will impose similar confidentiality obligations.
Arbitrator Appointment. Any arbitrator appointed under the Arbitration Agreement will be selected by the parties from the AAA or JAMS’s roster of arbitrators. If the matter is proceeding before JAMS, then you and we agree that the arbitrator shall be appointed in accordance with JAMS’s strike and rank process set forth in Rule 15 of the Comprehensive Arbitration Rules & Procedures. If the matter is proceeding before AAA, you and we agree that the arbitrator will be appointed through a strike and rank process consistent with the approach taken by JAMS in Rule 15 of the Comprehensive Arbitration Rules & Procedures.
Attorneys’ Fees and Costs. The parties shall bear their own attorneys’ fees and costs in arbitration unless the arbitrator finds that either the substance of the Dispute or the relief sought in the Dispute was frivolous or was brought for an improper purpose (as measured by the standards set forth in Federal Rule of Civil Procedure 11(b)). If you or Coinbase need to invoke the authority of a court of competent jurisdiction to compel arbitration, then the party that obtains an order compelling arbitration in such action shall have the right to collect from the other party its reasonable costs, necessary disbursements, and reasonable attorneys' fees incurred in securing an order compelling arbitration. The prevailing party in any court action relating to whether either party has satisfied any condition precedent to arbitration, including the Formal Complaint Process, is entitled to recover their reasonable costs, necessary disbursements, and reasonable attorneys’ fees and costs.
Waiver of Class, Collective, Representative, Mass Actions, and Other Non-Individualized Relief. YOU AND COINBASE AGREE THAT, EXCEPT AS SPECIFIED IN THE BATCH ARBITRATION PROVISION SET FORTH BELOW, EACH OF US MAY BRING CLAIMS AGAINST THE OTHER ONLY ON AN INDIVIDUAL BASIS AND NOT ON A CLASS, REPRESENTATIVE, OR COLLECTIVE BASIS, AND THE PARTIES HEREBY WAIVE ALL RIGHTS TO HAVE ANY DISPUTE BE BROUGHT, HEARD, ADMINISTERED, RESOLVED, LITIGATED, OR ARBITRATED ON A CLASS, COLLECTIVE, REPRESENTATIVE, OR MASS ACTION (SUCH AS A MASS ARBITRATION) BASIS. ONLY INDIVIDUAL RELIEF IS AVAILABLE, AND DISPUTES OF MORE THAN ONE CUSTOMER OR USER CANNOT BE ARBITRATED, LITIGATED, OR CONSOLIDATED WITH THOSE OF ANY OTHER CUSTOMER OR USER. Subject to this Arbitration Agreement, the arbitrator may award declaratory or injunctive relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by the party's individual claim. Notwithstanding anything to the contrary in this Arbitration Agreement, if a court decides by means of a final decision, not subject to any further appeal or recourse, that the limitations of this provision entitled “Waiver of Class and Other Non-Individualized Relief,” are invalid or unenforceable as to a particular claim or request for relief (such as a request for public injunctive relief), you and Coinbase agree that that particular claim or request for relief (and only that particular claim or request for relief) shall be severed from the arbitration and may be litigated in a court of competent jurisdiction consistent with the other terms of the User Agreement. This provision does not prevent you or Coinbase from participating in a class-wide settlement of claims.
Batch Arbitration. You and we agree to abide by this Batch Arbitration provision in the event that: (a) there are twenty-five (25) or more individual arbitration demands of substantially similar nature filed by us against you and other customers or by you and others against us and (b) such arbitration demands are filed with the assistance of the same law firm, group of law firms, or organizations. You and we agree that arbitration demands will not be deemed “substantially similar” if they involve claims seeking relief in connection with alleged losses of assets arising from different facts and circumstances. Arbitration demands that trigger the application of this Batch Arbitration provision can be administered in arbitration only pursuant to the provisions of this Batch Arbitration Provision. *See* Severability, above.
1\. If this Batch Arbitration provision is triggered, then JAMS shall:
a. administer the arbitration demands in batches;
b. appoint a single, different arbitrator for each batch unless the parties agree otherwise; and
c. provide for the resolution of each batch as a single consolidated arbitration with one set of filing and administrative fees due per side per batch, one procedural calendar, one in-person or video hearing (if any) in a format to be determined by the arbitrator that shall be convenient for the parties. You and we agree that if the Dispute is subject to this Batch Arbitration process, you will personally appear at any hearing (with counsel, if you are represented).
2\. The number of batches will depend on the number of arbitration demands that were filed. The batching methodology is set forth below:
a. If there are more than 25 but fewer than 2,000 arbitrations, then there will be 20 batches.
b. If there are 2,000 or more arbitrations, then they will be batched into batches of 100 arbitrations per batch.
c. In deciding which arbitration demands will go in which batch, JAMS shall make the batches as equal as possible in terms of cumulative amount demanded and number of arbitration demands.
3\. You and Coinbase (and your and our counsel, if represented) agree to cooperate in good faith with JAMS to implement the Batch Arbitration process including the payment of single filing and administrative fees for each Batch, as well as any steps to minimize the burdens and costs of arbitration. You and Coinbase (and your and our counsel, if represented) agree to work together in good faith throughout the Batch Arbitration process to streamline procedures, modify the number of arbitrations to proceed per batch as appropriate, increase efficiencies, and seek to resolve Disputes.
4\. You and we agree that arbitrations administered pursuant to this Batch Arbitration provision may be administered concurrently to the extent administratively feasible.
5\. Arbitrators appointed pursuant to this Batch Arbitration provision shall issue separate awards for each Coinbase User involved in a batched proceeding.
6\. This Batch Arbitration provision shall in no way be interpreted as authorizing a class, collective and/or mass arbitration or action of any kind, or arbitration involving joint or consolidated claims under any circumstances, except as expressly set forth in this provision.
***
## **Business User Agreement for Coinbase Services Accessed Through a Third-Party Provider**
## *Last updated: July 1, 2026*
This User Agreement ("**Agreement**" or “**User Agreement**”) between Coinbase, Inc. ("**Coinbase**," “we,” “us,” and “our”) and the entity you represent (“**you**”, “your”, “your company”, “user,” or “customer”) governs your use of the services provided by Coinbase described below and such other services that may be offered by Coinbase from time to time ("**Coinbase Services**" or "**Services**") to Coinbase Business customers. By signing up to use a Business Account (as defined below) through a Provider (as defined below), you agree that you have read, understand, and accept all of the terms and conditions contained in this Agreement including our [Privacy Policy](https://www.coinbase.com/legal/privacy), [Cookie Policy](https://www.coinbase.com/legal/cookie), [Prohibited Use Policy](https://www.coinbase.com/legal/prohibited_use) and E-Sign Disclosure and Consent Policy in Appendix 1.
You are interacting with Coinbase Services through an application provided to you by a third-party Provider. The Provider’s application communicates with Coinbase through an application programming interface (“**API**”), with **Coinbase performing certain back-end services on your behalf**. By using the Services, you authorize the Provider to act as your agent in accessing and providing instructions to your Business Account for the purpose of facilitating the Services defined herein. The Provider is not an agent of Coinbase, and nothing in this relationship authorizes the Provider to make any representations, warranties, or commitments on behalf of Coinbase or otherwise bind Coinbase in any way. You acknowledge that your relationship with the Provider, including use of the Provider’s application, is governed by a separate agreement between you and the Provider, to which Coinbase is not a party. This Agreement governs your use of the Business Account, which is established with and held directly by Coinbase.
**Important Definitions**: As used throughout this Agreement, the following terms have the following meanings.
“**Authorized Representative**” means the executive officer, senior manager or other individual applying for your Business Account with authority to transact and exercise control over your account.
“**Bank Partner**” means any third-party depository institution with which Coinbase maintains pooled or virtual accounts in order to receive fiat currency deposits to support the Services.
“**Business Account**” or “your account” means the digital asset account established with and held directly by Coinbase (which includes your Digital Asset Wallet, defined below) that you access and use through a Provider’s application to utilize the Coinbase Services.
“**Coinbase Platform**” or “Platform” means the collective software, APIs, infrastructure, and systems provided by Coinbase to facilitate the Coinbase Services. For purposes of this Agreement, the Platform exclusively refers to the back-end services, APIs, and infrastructure that power your custodial account and authorized transactions. This User Agreement applies only to your interaction with the Platform through a Provider’s application. Access to Coinbase services through Coinbase’s direct websites or applications (including, but not limited to, coinbase.com and the Coinbase mobile application) are subject to a separate user agreement, and are not governed by this Agreement.
“**Deposit Instructions**” means any bank account number, routing number, virtual account number, or other payment details that Coinbase or a Bank Partner allocates for the purpose of receiving fiat currency that will be converted to Supported Digital Assets and credited to your Business Account.
“**Digital Asset**” means any digital asset (including a virtual currency or virtual commodity) which is a digital representation of value based on (or built on top of) a cryptographic protocol of a computer network.
“**Provider**” means the third-party company that provides the front-end application and user interface through which you access the Coinbase Platform and use the Coinbase Services. The Provider is solely responsible for its own application, services, disclosures, customer service, and its relationship with you.
"**Supported Digital Asset**" means only those particular Digital Assets listed as available to trade or custody in your Digital Asset Wallet (as defined below). Services and supported assets may vary by jurisdiction.
**Amendment of these Terms**: We may amend or modify this Agreement at any time by posting the revised agreement on our website, providing a copy to you through the Provider application in which you access Coinbase Services, and/or by other means (a “**Revised Agreement**”). The Revised Agreement shall be effective as of the time it is posted but will not apply retroactively. Your continued use of the Services after the posting of a Revised Agreement constitutes your acceptance of such Revised Agreement. If you do not agree with any such modification, your sole and exclusive remedy is to terminate your use of the Services and close your Business Account.
**Dispute Resolution: PLEASE BE AWARE THAT SECTION 7 (CUSTOMER FEEDBACK, QUERIES, COMPLAINTS, AND DISPUTE RESOLUTION)] CONTAINS PROVISIONS GOVERNING HOW TO RESOLVE DISPUTES BETWEEN YOU AND COINBASE. AMONG OTHER THINGS, SECTION 7.3 INCLUDES AN AGREEMENT TO ARBITRATE WHICH REQUIRES, WITH LIMITED EXCEPTIONS, THAT ALL DISPUTES BETWEEN YOU AND US SHALL BE RESOLVED BY BINDING AND FINAL ARBITRATION. PLEASE READ SECTION 7 CAREFULLY.**
**No Investment Advice or Brokerage**: For the avoidance of doubt, Coinbase does not provide investment, tax, or legal advice, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your investment objectives, financial circumstances, and risk tolerance. Coinbase may provide educational information about Supported Digital Assets, as well as Digital Assets not supported by Coinbase, in order to assist users in learning more about such Digital Assets. Information may include, but is not limited to, blog posts, articles, links to third-party content, news feeds, tutorials, and videos. The information provided by Coinbase through the Coinbase Platform, coinbase.com, any other Coinbase website, or any such third-party sites does not constitute investment advice, financial advice, trading advice, or any other sort of advice, and you should not treat any of the associated content as such. Coinbase does not recommend that any Digital Asset should be bought, earned, sold, or held by you. Coinbase will not be held responsible for the decisions you make to buy, sell, or hold Digital Assets based on the information provided by Coinbase. *You acknowledge and agree that Coinbase is not responsible for any investment, tax, or legal advice, recommendations, or information provided to you by the Provider or through the Provider’s application.*
Coinbase does not broker trades on your behalf unless otherwise specified on a specific product. All Coinbase trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures.
**Acknowledgement of Risk**: As with any asset, the value of Digital Assets can increase or decrease and there can be a substantial risk that you lose money buying, selling, holding, or investing in Digital Assets. You should consult your financial advisor, legal, or tax professional regarding your specific situation and financial condition and carefully consider whether trading or holding Digital Assets is suitable for you.
Coinbase is not registered with the U.S. Securities and Exchange Commission and does not offer securities services in the United States or to U.S. persons or entities. You acknowledge that Digital Assets are not subject to protections or insurance provided by the Federal Deposit Insurance Corporation or the Securities Investor Protection Corporation.
**Overlap with Other Coinbase Accounts:** This Agreement governs only your Business Account and Services accessed through your Provider, and it does not affect any separate, direct Coinbase account you may hold (e.g., accounts accessed through coinbase.com or the Coinbase mobile application), which remain governed by their own applicable user agreements. In the event of any conflict between the terms of this Agreement and the terms of any other user agreement governing a separate Coinbase account, the terms of that separate user agreement will control with respect to that separate account.
**1. Account Setup**
**1.1. Eligibility**. To be eligible to use the Coinbase Services, your company must be (i) a C-corporation, a multi-member LLC or such other entity as Coinbase in its sole discretion offer the Services to from time to time; (ii) incorporated or otherwise formed in the United States; and (ii) located in the United States with a verifiable address. The Authorized Representative must (i) be at least 18 years old; (ii) be authorized to perform legally-binding actions on behalf of your company, including contractual formation and transaction execution; (iii) have the full power, authority and capacity to access and use the Services; and (iv) have the appropriate sophistication, expertise, and knowledge necessary to understand the nature and risks, and make informed decisions, in respect of Digital Assets and the Services.There are certain Coinbase Services that may or may not be available to you depending on your location and other criteria.
**1.2. Registration of Business Account**. You must register for a Business Account through the Provider’s application to use the Coinbase Services. As a regulated financial service company operating in the US we are required to identify users on our platform. You will need to complete certain verification procedures before you are permitted to use the Coinbase Services. This ensures we remain in compliance with applicable anti-money laundering (“**AML**”) and governmental sanctions laws in the jurisdictions in which we operate, something that is necessary for us to be able to continue to offer Digital Asset services to our customers. Coinbase collects and verifies information about you and individuals at your company in order to: (i) protect Coinbase and the community from fraudulent users; and (ii) to keep appropriate records of Coinbase's customers. You consent to promptly providing such information as Coinbase may reasonably request from time to time regarding: (a) your company’s policies, procedures, and activities which relate to the Services, in each case to the extent reasonably necessary for Coinbase to comply with any applicable laws, rules, and regulations (including money laundering statutes, regulations and conventions of the United States or other jurisdictions), or the guidance or direction of, or request from, any regulatory authority or financial institution.
By registering or using a Business Account you agree and represent that your Authorized Representative has created your Business Account and your company will use your Business Account only for your company’s purposes, and not on behalf of any third party, unless you have obtained prior written approval from Coinbase. You are fully responsible for all activity that occurs under your Business Account. We may, in our sole discretion, refuse to open a Business Account, suspend or terminate any Business Account, suspend or terminate the sending of Digital Assets from your account, or suspend or terminate the trading of Digital Assets in your account. Please see Section 6 below for more information.
**1.3. Consent to Access, Processing and Storage of Your Personal Data & Identity Verification.** During registration for your Business Account, or at any other time deemed necessary by Coinbase, you acknowledge and agree that the Provider collects information from you and you expressly authorize the Provider to transmit to Coinbase all information we require (the “**KYB Data”**) for the purposes of identity / company verification, providing Coinbase Services to you, and the detection of money laundering, terrorist financing, fraud, or any other financial crimes and permit us to keep a record of such information. Coinbase will use the KYB Data to run its own verification procedures, sanctions screening, and monitoring program. Coinbase reserves the right to require further information from you, and to reject, restrict, or suspend your Business Account regardless of the Partner’s own KYB decisions or determinations. You represent and warrant that the KYB Data provided by you to your Provider and subsequently forwarded to Coinbase is accurate and authentic.
The KYB Data may include certain information about your company including, but not limited to, incorporation documents, taxpayer identification, place of business, finances including bank account information (such as the name of the bank, the account type, routing number, and account number), and company ownership. We may also require personal information about your Authorized Representative and owners of your company, including, but not limited to, name, residential address, telephone number, e-mail address, date of birth, social security number, and government identification. You also acknowledge and agree that Coinbase may share information back to your Provider for the purposes of facilitating the Services you have requested through the Provider’s application, including information about the status of your Business Account, transaction details, and risk flags, for the purposes of facilitating the Services, verification, risk management, and compliance with legal and regulatory obligations.
In connection with providing the Services, you understand and agree that Coinbase may engage one or more Bank Partners to hold pooled or virtual accounts and to issue Deposit Instructions. Where required to open, maintain, or service those accounts and Deposit Instructions, you expressly authorize Coinbase to share your personal information, including KYB Data with its Bank Partners and their service providers. This data-sharing may include the information listed above in this Section 1.3 and any updates you later provide. Bank Partners will use this information solely to provide account, payment, sanctions, and compliance services to Coinbase and to comply with their own legal and regulatory obligations.
You, your Authorized Representative, and your company’s owners consent to us accessing, processing and retaining any business and personal information you provide to us for the purpose of us providing Coinbase Services to you. This consent is not related to, and does not affect, any rights or obligations we or you have in accordance with data protection laws, privacy laws and regulations. You can withdraw your consent at any time by closing your Business Account. However, we may retain and continue to process the business and personal information you have provided if we reasonably believe it is necessary in order to comply with laws or regulations. In providing us with this or any other information that may be required, you and your Authorized Representative confirm that the information is accurate and authentic. You and your Authorized Representative agree to keep your Provider updated if any of the information you provide changes. **You and your Authorized Representative authorize us to make inquiries, whether directly or through third parties, that we consider necessary to verify the business or personal information you provided or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries**. When we carry out these inquiries, you and your Authorized Representative acknowledge and agree that the business and personal information you provided may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full. This is an identity check only and should have no adverse effect on your Authorized Representative or your company’s credit ratings. We reserve the right at all times to monitor, review, retain and/or disclose any information you provided as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request. You further agree and authorize Coinbase and its affiliates to internally share your KYB Data, account data, transaction history, risk flags, and compliance scores with other Coinbase product lines and business units for the purposes of detecting, preventing, and responding to fraud, abuse, money laundering, terrorist financing, or other financial crimes, and ensuring compliance with applicable laws, sanctions programs, and internal policies. See our [Privacy Policy](https://www.coinbase.com/legal/privacy) and [Cookie Policy](https://www.coinbase.com/legal/cookie) for more information on how we process the business and personal data you have provided and the rights you have in respect of this.
**1.4. Access**. The Coinbase Services you access through a Provider may become degraded or unavailable during times of significant volatility or volume. This could result in significant support response time delays. Coinbase has no control over the Provider’s application availability or service quality, and is not responsible for any losses arising from disruptions to the Provider’s application. Although we strive to provide you with excellent service, we do not represent that Coinbase Services will be available without interruption and we do not guarantee that any order or instruction will be executed, accepted, recorded, or remain open. Coinbase shall not be liable for any losses resulting from or arising out of delays in processing transactions, inability to execute transactions, or lack of timely response from Coinbase customer support. For example, if you are locked out of your Business Account, it is possible that the value or price of the Digital Assets in your account might go down before your access is restored. Coinbase shall not be liable for any alleged losses that you suffer from a drop in Digital Asset values or prices.
**1.5 Withdrawal of Provider Authorization.** You may withdraw your authorization for the Provider to access your Business Account or transmit instructions and data on your behalf by revoking the Provider's access permissions within the Provider’s application or by closing your Business Account as described in Section 6.9. If you revoke the Provider’s authority, the Provider will no longer be able to transmit instructions to Coinbase or share new information with us; however, Coinbase reserves the right to retain data previously transmitted to us in accordance with our Privacy Policy and all applicable laws and regulations. You acknowledge that the Provider is solely responsible for the administration and functionality of its revocation mechanism, and Coinbase is not liable for any failure or delay by the Provider to properly process or communicate your revocation instruction.
**2. Hosted Wallet and Custodial Services**
**2.1. Product Scope and Limitations.** The Coinbase Services you access through your Provider are limited to those capabilities provided by Coinbase to your Provider via Coinbase’s API. These services may include the ability to: (i) establish and manage a Digital Asset Wallet; (ii) engage in Supported Digital Asset purchases, sales, and conversions; (iii) execute Digital Asset Transfers; and (iv) fund your Business Account and withdraw funds via our fiat conversion services, as described in Section 2.10 (Fiat Conversion) and Section 3.1 (Fiat Funding and Withdrawals). You acknowledge that this Agreement does not grant you access to any services or products made available on Coinbase’s direct retail platforms (such as coinbase.com or the Coinbase mobile application), including but not limited to Staking Services, Coinbase Card products, USDC Rewards, Coinbase One, or any other retail-only features, unless such service is explicitly offered to you via your Provider and is governed by its own separate addendum or terms. The availability of any specific service, asset, or feature may vary depending on your Provider, your account type, and your jurisdiction.
**2.2. Hosted Wallet Services.** As part of your Business Account, Coinbase will provide qualifying users with hosted Digital Asset wallet(s), each of which is an account for holding Supported Digital Assets (“**Digital Asset Wallet**”). You may also elect to use other products and services; additional rules associated with such product(s) and services(s) may apply.
**2.3. Hosted Digital Asset Wallet**. Your Digital Asset Wallet allows you to store, track, transfer, and manage your balances of Supported Digital Assets. We securely store Digital Asset private keys, which are used to process transactions, in a combination of online and offline storage. As a result of our security protocols, it may be necessary for us to retrieve private keys or related information from offline storage in order to facilitate Digital Asset Transfers (as defined below) in accordance with your instructions, and you acknowledge that this may delay the initiation or crediting of such Digital Asset Transfers.
**2.4. Supported Digital Assets**. Your Digital Asset Wallet is intended solely for proper use of Supported Digital Assets as designated on the Platform. ***Under no circumstances should you attempt to use your Digital Asset Wallet to store, send, request, or receive any assets other than Supported Digital Assets. Coinbase assumes no responsibility in connection with any attempt to use your Digital Asset Wallet with Digital Assets that we do not support. You acknowledge and agree that Coinbase is not liable for any unsupported Digital Asset that is sent to a wallet associated with your Business Account. Coinbase may in its sole discretion terminate support for any particular Digital Asset. If you do not sell or send such Digital Asset off Platform before Coinbase terminates its support for such Digital Asset, then Coinbase may, in its discretion, remove such Digital Asset from your Digital Asset Wallet and credit your Digital Asset Wallet the equivalent market value of a Supported Digital Asset minus transaction costs.***
**2.5. Supplemental Protocols Excluded**. Unless otherwise specifically announced on the Coinbase Platform or as set forth in this Agreement, Supported Digital Assets excludes all other protocols and/or functionality which supplement or interact with the Supported Digital Asset. This exclusion includes but is not limited to: metacoins, colored coins, side chains, or other derivative, enhanced, or forked protocols, tokens, or coins or other functionality, such as staking, protocol governance, and/or any smart contract functionality, which may supplement or interact with a Supported Digital Asset. Do not use your Business Account to attempt to receive, request, send, store, or engage in any other type of transaction or functionality involving any such protocol as the Coinbase Platform is not configured to detect, secure, or process these transactions and functionality. Any attempted transactions in such items will result in loss of the item. *You acknowledge and agree that other than as set forth in this Agreement supplemental protocols are excluded from Supported Digital Assets and that Coinbase has no liability for any losses related to supplemental protocols.*
**2.6. Fungibility of Certain Digital Assets**. You acknowledge and agree that Coinbase may hold Supported Digital Assets in your Digital Asset Wallets in a variety of different ways, including across multiple blockchain protocols, such as layer two networks, alternative layer one networks, or side chains. In connection with its holding of Supported Digital Assets in your Digital Asset Wallets, Coinbase may transfer such Digital Assets off of the primary blockchain protocol and hold such Digital Assets on shared blockchain addresses, controlled by Coinbase, on alternative blockchain protocols in forms compatible with such protocols. You agree that all forms of the same Digital Asset that are held and made available across multiple blockchain protocols may be treated as fungible and the equivalent of each other, without regard to (a) whether any form of such Digital Asset is wrapped or (b) the blockchain protocol on which any form of such Digital Asset is stored.
**2.7. Operation of Digital Asset Protocols**. Coinbase does not own or control the underlying software protocols which govern the operation of Digital Assets. Generally, the underlying protocols are open source, and anyone can use, copy, modify, and distribute them. We assume no responsibility for the operation of the underlying protocols and do not guarantee the functionality or security of network operations. In particular, the underlying protocols may be subject to sudden changes in operating rules (including “forks”). Any such operating changes may materially affect the availability, value, functionality, and/or the name of the Digital Assets in your Digital Asset Wallet or other wallet. Coinbase does not control the timing and features of these operating changes. It is your responsibility to make yourself aware of upcoming operating changes and you must carefully consider publicly available information and information that may be provided by Coinbase or your Provider in determining whether to continue to use a Business Account for the affected Digital Asset. In the event of any such operational change, Coinbase reserves the right to take such steps as may be necessary to protect the security and safety of assets held on the Coinbase Platform, including without limitation, temporarily suspending operations for the involved Digital Asset(s); Coinbase will endeavor to provide you notice of its response to any material operating change; however, such changes are outside of Coinbase’s control and may occur without notice to Coinbase. Coinbase’s response to any operating change is subject to its sole discretion and may include deciding not to support any new Digital Asset, fork, or other actions. ***You acknowledge and accept the risks of operating changes to Digital Asset protocols and agree that Coinbase is not responsible for such operating changes and not liable for any loss of value you may experience as a result of such changes in operating rules. You acknowledge and accept that Coinbase has sole discretion to determine its response to any operating change and that we have no responsibility to assist you with unsupported currencies or protocols. You further acknowledge and accept that Coinbase has no responsibility to support new Digital Asset forks or operating changes for Digital Assets.***
**2.8. Digital Asset Custody and Title**. All Supported Digital Assets held in your Digital Asset Wallet are custodial assets held by Coinbase for your benefit, as described in further detail below.
**2.8.1. Ownership**. Title to Supported Digital Assets shall at all times remain with you and shall not transfer to Coinbase. All interests in Digital Assets we hold for Digital Asset Wallets are held for customers, are not property of Coinbase, and are not subject to claims of Coinbase’s creditors. As owner of the Supported Digital Assets in your Digital Asset Wallet, you shall bear all risk of loss of such Supported Digital Assets. Coinbase shall have no liability for Supported Digital Asset fluctuations or loss. None of the Supported Digital Assets in your Digital Asset Wallet are the property of, or shall or may be loaned to, Coinbase; Coinbase does not represent or treat assets in user’s Digital Assets as belonging to Coinbase. Coinbase may not grant a security interest in the Supported Digital Assets held in your Digital Asset Wallet. Except as required by law, or except as provided herein, Coinbase will not sell, transfer, loan, hypothecate, or otherwise alienate Supported Digital Assets in your Digital Asset Wallet unless instructed by you (and, when so instructed by you, only where permitted by law).
**2.8.2 Application of the Uniform Commercial Code**. All Supported Digital Assets credited to the Digital Asset Wallet will be treated as “financial assets” under Division 8 of the California Uniform Commercial Code (“Division 8”). Coinbase is a “securities intermediary” as used in Division 8 with respect to Supported Digital Assets, and your Digital Asset Wallet is a “securities account” as used in Division 8. As stated in Division 8, “the characterization of a person, business, or transaction for purposes of this division does not determine the characterization of the person, business, or transaction for purposes of any other law, regulation, or rule,” including the United States Commodity Exchange Act and any federal, state, or foreign securities law or regulation. Coinbase will comply with your instructions with respect to your Supported Digital Assets, subject to the terms of this User Agreement.
**2.8.3. Control and Customer Instructions**. You control the Digital Assets held in your Digital Asset Wallet. At any time, subject to outages, downtime, protocol requirements, time to conduct blockchain operations to fulfill your request, and other applicable policies, you may withdraw your Supported Digital Assets by instructing Coinbase, through your Provider’s application, to debit the applicable Supported Digital Asset from your Digital Asset Wallet and transfer the Digital Assets to a different blockchain address. As long as you continue to hold Supported Digital Assets with Coinbase, Coinbase shall retain control over electronic private keys associated with blockchain addresses operated by Coinbase, including the blockchain addresses used to hold the Supported Digital Assets credited to your Digital Asset Wallet.
**2.8.4. Omnibus Accounts**. In order to more securely and effectively custody assets, Coinbase may use shared blockchain addresses, controlled by Coinbase, to hold Supported Digital Assets for Digital Asset Wallets on behalf of customers and/or held on behalf of Coinbase. Although we maintain separate ledgers for customers’ accounts and accounts held by Coinbase for its own benefit, Coinbase shall have no obligation to create a segregated blockchain address for your Supported Digital Assets.
**2.8.5. Governance and Voting**. For certain Digital Assets, the underlying protocols offer stakers the ability to vote on matters related to the governance of protocol-level issues. Coinbase may or may not support voting for such assets, and may cease supporting voting at any time in its discretion. Coinbase will comply with your instruction to vote your Supported Digital Assets to the extent Coinbase or its affiliate supports voting for such Supported Digital Assets. In certain cases, Coinbase may vote on your behalf where Coinbase or the applicable protocol does not support delegated voting; in those instances, Coinbase will vote with the protocol’s recommendation.
**2.9. USDC Wallets**. You may elect to buy USD Coin (“USDC”) from Coinbase, a Digital Asset issued by Circle Internet Financial (“Circle”) and supported by Coinbase. You are the owner of the balance of your USDC Wallet. Coinbase is not the issuer of USDC, does not hold reserves for USDC, and has no obligation to repurchase your USDC for USD. You can redeem your USDC with Circle, and Coinbase may also elect to repurchase your USDC in exchange for USD. You agree to be bound by the terms of the Circle USDC User Agreement (located at [https://www.circle.com/legal/usdc-terms](https://www.circle.com/legal/usdc-terms)), which provides additional obligations, undertakings, and limitations with respect to USDC. You acknowledge that, under this Agreement, Coinbase does not offer you any rewards or interest on USDC held in your Digital Asset Wallet. Your Provider may, in its sole discretion and under a separate agreement with you, offer rewards or other incentives on your USDC balance. You agree that any such rewards or incentives are provided solely by the Provider, and Coinbase has no obligation or liability related to such rewards, including their calculation, payment, or forfeiture.
**2.10. Fiat Conversion.** Coinbase does not maintain a user-facing, stored-value fiat currency wallet for customers accessing Services through a Provider. Your Business Account is intended to hold Supported Digital Assets only. All fiat transfers made to your account are immediately converted to Supported Digital Assets (for example, USDC) which are credited to your Digital Asset Wallet. To the extent any fiat balances are briefly maintained for users (if at all), they are solely incidental to these immediate conversion and transfer services, and Coinbase is not a general purpose fiat account provider to you. Coinbase shall not be liable for the unavailability, suspension, rejection, delay, return, recall, reversal, or restriction of any Deposit Instructions or related fiat transfer, or for any hold, review, freeze, or other action taken by any Bank Partner or applicable payment rail in connection with the services provided by any Bank Partner.
Your Provider may utilize Deposit Instructions (for example, an account and routing number) from Coinbase or a Bank Partner that allow you, your Provider, or another payer to send fiat currency to an account held by Coinbase or a Bank Partner for the purpose of funding your Business Account. These Deposit Instructions are a funding mechanism only. Fiat currency sent to Deposit Instructions associated with your Business Account, once received and credited by Coinbase, is converted to Supported Digital Assets (for example, USDC) and recorded in your Digital Asset Wallet as described above. USDC and other Digital Assets are not bank deposits, are not insured by the Federal Deposit Insurance Corporation, and may lose value.
**3. Payment Services, Purchase & Sale Transactions, and Credit Transactions**
**3.1 Fiat Funding and Withdrawals.** Access to one or more payment methods (fiat rails) may be provided by your Provider, and fiat funding to your account is received by Coinbase using one or more Bank Partners. In all cases, fiat funds sent to Deposit Instructions associated with your Business Account are received into accounts held by or for Coinbase and are not held for you as a separate bank account or stored-value wallet. Coinbase will process fiat transactions where explicitly instructed by you via your Provider. Coinbase has no responsibility for bank, payroll, or card arrangements you may have with your Provider, and is not responsible for processing errors incurred by your Provider. Fiat currency transferred to your account via instructions from your Provider’s application will be immediately converted to a Supported Digital Asset (e.g., USDC) and credited to your Digital Asset Wallet, as further described in Section 2.10 (Fiat Conversion). Deposit Instructions provided in connection with your Business Account may be used only to fund your own Business Account with funds owned by you and for your own disclosed business purposes. You may not use Deposit Instructions to receive, hold, pool, or transmit funds beneficially owned by any third party, including your own customers or other end clients, or to operate a money transmission, payment processing, payment facilitation, or similar service. For withdrawals from your Business Account, your Provider may initiate batched sweep instructions on a periodic or scheduled cadence for the conversion of Supported Digital Assets (such as USDC) and payout of fiat currency. You acknowledge that Coinbase is reliant on the Provider for the initiation and timing of these batched sweeps, and that delays can occur due to bank holidays, cut-off times, or decisions made by the Provider regarding the batching schedule. You agree that Coinbase is not responsible for any market volatility, price changes, or missed opportunities that occur during a delay caused by the Provider’s initiation or scheduling of these batched sweeps. Coinbase is only responsible for correctly executing the sweep instructions once they are authenticated and received from your Provider.
You acknowledge that Deposit Instructions, including any virtual account number, account and routing number, or similar payment details made available in connection with your Business Account, may be issued, operated, monitored, or supported by one or more Bank Partners and their service providers. Bank Partners and their service providers operate and secure their own systems, networks, payment rails, and data-processing environments. To the maximum extent permitted by applicable law, Coinbase shall not be liable for, and you assume the risk of, any act, omission, outage, unavailability, delay, rejection, return, recall, reversal, hold, review, freeze, unauthorized access, Security Breach, data incident, or other failure occurring at or caused by any Bank Partner or its service providers in connection with Deposit Instructions or other Bank-Partner-backed services.
**3.2. Transactions on the Coinbase Platform.** When you buy or sell Supported Digital Assets on the Coinbase Platform, you are not buying Supported Digital Assets from Coinbase or selling Supported Digital Assets to Coinbase. Coinbase acts as the agent, transacting on your behalf, to facilitate that purchase or sale between you and other counterparties. You agree that instructions delivered to Coinbase via your Provider's application are deemed authorized by you. Coinbase’s duty is to execute the authenticated instructions it receives, but Coinbase is not liable for any failure, delay, or error in execution caused by the Provider mis-collecting, mis-formatting, or mis-routing the instructions before they reach the Coinbase Platform. All instructions for Digital Asset purchase or sales must be submitted to Coinbase via your Provider. Coinbase reserves the right to cancel any transaction not confirmed by you within five (5) seconds after Coinbase quotes a transaction price. A purchase of Supported Digital Assets generally will initiate on the business day we receive your instructions. Purchased Supported Digital Assets will usually be deposited in your Digital Asset Wallet instantly and can be exchanged for other Digital Assets. You can sell Supported Digital Assets and instruct Coinbase to deposit the proceeds into your Digital Asset Wallet. Supported Digital Asset purchases and sales on the Coinbase Platform are collectively referred to herein as “**Digital Asset Transactions**”. If Coinbase cannot complete your Digital Asset Transaction for any reason (such as price movement, market latency, inability to find a counterparty for your transaction, or order size), Coinbase will reject the order and notify your Provider of such rejection.
**3.3. Fees.** Your Provider may charge you fees in connection with your use of Coinbase Services. The total fee you see may include amounts retained by your Provider, amounts used to compensate Coinbase, network fees, spreads, or other costs. You acknowledge that Coinbase may receive fees or other compensation from your Provider under a separate agreement in connection with your use of Coinbase Services. These wholesale fees are not charged to you directly under this Agreement. Coinbase may charge network fees (for example, miner fees) and other costs to your Provider to process Digital Asset Transactions. To the extent any of those amounts are passed through to you, they will be included in the total fee disclosed by your Provider. Fees applicable to your use of Coinbase Services (as charged and disclosed by your Provider) may change from time to time. Where required by applicable law, your Provider (or Coinbase acting through your Provider) will provide you with any legally required notice of fee changes through your Provider’s customer communication channels. You acknowledge that Coinbase is not responsible for and does not set the pricing of the fees charged to you by your Provider and is not liable for any refund of fees collected by your Provider, even if a transaction is canceled or reversed.
**3.4. Unauthorized and Incorrect Transactions.** When a transaction occurs using your credentials or other authentication factors for your access to the Coinbase Services through your Provider’s application, we will assume that you authorized such transaction, unless you notify us otherwise. If you believe you did not authorize a particular transaction or that a transaction was incorrectly carried out, you must contact your Provider as soon as possible using the support channels your Provider makes available. If your Provider cannot resolve the dispute, you must follow the Formal Complaint Process described in Section 7, below. It is important that you regularly check your account with your Provider, your Digital Asset Wallet, and your transaction history to ensure you notify your Provider as soon as possible of any unauthorized or incorrect transactions. Reporting an unauthorized transaction does not guarantee your Provider or Coinbase will be able to reverse the transaction or reimburse you for the transaction.
**3.5. Reversals & Cancellations.** You cannot cancel, reverse, or change any transaction marked as complete or pending. The Provider, not Coinbase, manages fiat payments to the Coinbase Services. As such, the Provider is responsible for addressing issues arising if your payment is not successful, if your payment method has insufficient funds, or if you reverse a payment made from funds in your bank account. We reserve the right to refuse to process, or to cancel, correct, clawback, or reverse, any Digital Asset Transaction or transfers in our sole discretion, even after funds have been debited from your account(s), in response to a subpoena, court order, or other government order; or if we suspect the transaction may: involve money laundering, terrorist financing, fraud, or any other type of financial crime; be erroneous; or relate to a Prohibited Use or a Prohibited Business as set forth in the [Prohibited Use Policy](https://www.coinbase.com/legal/prohibited_use). In such instances, Coinbase will reverse the transaction and we are under no obligation to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction. Where fiat deposits are made via Deposit Instructions associated with your Business Account, you understand that such deposits may be subject to reversal, return, or recall under applicable network and banking rules, and that Coinbase may be required or permitted to honor such reversals or returns. In that event, Coinbase may debit or restrict your Business Account, or take other actions described in this Agreement, to reflect the reversal or return.
**4. Digital Asset Transfers**
**4.1. In General.** Your Digital Asset Wallet enables you to send Supported Digital Assets to, and request, receive, and store Supported Digital Assets from, third parties by giving instructions through your Provider. Your transfer of Supported Digital Assets between your other Digital Asset wallets (including wallets off the Coinbase Platform) and to and from third parties is a “**Digital Asset Transfer**”. We recommend customers send a small amount of Supported Digital Assets as a test before sending a significant amount of Supported Digital Assets.
**4.2. Pending Transactions.** Once a Digital Asset Transfer is submitted to a Digital Asset network, the transaction will be unconfirmed and remain in a pending state for a period of time sufficient to allow confirmation of the transaction by the Digital Asset network. A Digital Asset Transfer is not complete while it is in a pending state. Pending Digital Asset Transfers that are initiated via your Provider will reflect a pending transaction status and are not available to you for use while the transaction is pending.
**4.3. Inbound Digital Asset Transfers.** When you or a third party sends Digital Assets to a Coinbase Wallet from an external wallet not hosted on Coinbase (“**Inbound Transfers**”), the person initiating the transaction is solely responsible for executing the transaction properly, which includes ensuring that the Digital Asset being sent is a Supported Digital Asset that conforms to the particular wallet address to which funds are directed, including any required Destination Tag/Memo. **By initiating an Inbound Transfer, you attest that you are transacting in a Supported Digital Asset that conforms to the particular wallet address to which funds are directed. For example:**
* **If you select an Ethereum wallet address to receive funds, you attest that you are initiating an Inbound Transfer of Ethereum alone, and not any other Digital Asset such as Bitcoin or Ethereum Classic.**
* **If you select a Bitcoin wallet address to receive funds, you attest that you are initiating an Inbound Transfer of Bitcoin alone, and not any other Digital Asset such as Bitcoin Cash or Ethereum.**
**Coinbase incurs no obligation whatsoever with regard to unsupported Digital Assets sent to a Business Account or with regard to Supported Digital Assets sent to an incompatible Digital Asset wallet address. If you send unsupported Digital Assets to a Business Account or Supported Digital Assets to an incompatible Digital Asset wallet address, then you will lose those Digital Assets.** For some lost Digital Assets, Coinbase may in its sole discretion offer the option to attempt a recovery. We may charge fees to process the recovery attempt on your behalf. We will calculate all fees at our discretion, and notify you of the applicable fees at or before the time you authorize the recovery attempt. The actual amount recovered may differ from the estimated recovery amount. Coinbase does not evaluate the authenticity, safety, or security of unsupported Digital Assets. You acknowledge and agree that Coinbase is not liable for any loss incurred during the recovery attempt or subsequent use of the recovered Digital Asset.
Coinbase may from time to time determine types of Digital Assets that will be supported or cease to be supported. You acknowledge and agree that you may be required to pay network or miner’s fees in order for an Inbound Transfer transaction to be successful. Insufficient network fees may cause an Inbound Transfer to remain in a pending state on a decentralized network outside of Coinbase’s control, and we are not responsible for delays or loss incurred as a result of an error in the initiation of the transaction and cannot reverse such transactions.
**4.4. Outbound Digital Asset Transfers.** When you send Supported Digital Assets from your Business Account to an external wallet (“**Outbound Transfers**”), such transfers are executed at your instruction by Coinbase. You should verify all transaction information prior to submitting instructions to us through the Partner’s application. Coinbase shall bear no liability or responsibility in the event you enter an incorrect blockchain destination address, incorrect Destination Tag/Memo, or if you send your Supported Digital Assets to an incompatible wallet. We do not guarantee the identity or value received by a recipient of an Outbound Transfer. Digital Asset Transfers cannot be reversed once they have been broadcast to the relevant Digital Asset network, although they may be in a pending state, and designated accordingly, while the transaction is processed by network operators. Coinbase does not control the Digital Asset network and makes no guarantees that a Digital Asset Transfer will be confirmed by the network. We may cancel or refuse to process any pending Outbound Digital Asset Transfers as required by law or any court or other authority to which Coinbase is subject in any jurisdiction. Additionally, we may require you to wait some amount of time after completion of a transaction before permitting you to use further Coinbase Services and/or before permitting you to engage in transactions beyond certain volume limits.
**4.5. Debts.** In the event that there are outstanding amounts owed to us hereunder, including in your Business Account, Coinbase reserves the right to debit your Business Account accordingly and/or to withhold amounts from funds you may transfer between your Business Accounts.
**5. Data Protection and Security**
**5.1. Business & Personal Data**. You acknowledge that we may process the business and personal data that you have provided or in the future provide to us in relation to your Authorized Representative and other individuals associated with your company, including data provided to us by your Provider and data shared with Bank Partners as described in Section 1.3, in connection with this Agreement, or the Coinbase Services. Accordingly, you represent and warrant that: (i) your disclosure to us of any personal data relating to individuals was or will be made in accordance with all applicable data protection and data privacy laws, and such data is accurate, up to date and relevant when disclosed; (ii) before providing any such personal data to us, you have read and understood our Privacy Policy, and have (or will at the time of disclosure have) provided a copy of that Privacy Policy (as amended from time to time), to any individual to whom you have shared their data with Coinbase; and (iii) if from time to time we provide you with a replacement version of the Privacy Policy, you will promptly read that notice and provide a copy to any individual whose personal data you have provided to us.
**5.2. Security Breach.** If you suspect that your Business Account or any of your security details have been compromised or if you become aware of any fraud or attempted fraud or any other security incident (including a cyber-security attack) affecting you and/or Coinbase (collectively a "**Security Breach**"), you must notify your Provider immediately and provide accurate and up to date information throughout the duration of the Security Breach. You must take any steps that we or your Provider reasonably require to reduce or manage any Security Breach. Prompt reporting of a Security Breach does not guarantee that Coinbase will reimburse you for any losses suffered or be liable to you for any losses suffered as a result of the Security Breach. Without limiting any other provision of this Agreement, you acknowledge and agree that Bank Partners and their service providers may receive, process, store, transmit, and secure your information in connection with Deposit Instructions and other Bank-Partner-backed services. To the maximum extent permitted by applicable law, neither Coinbase nor any Bank Partner or its service providers will be liable to you for any loss, damage, claim, cost, or expense arising out of or relating to any Security Breach, unauthorized access, data breach, or other security incident occurring in the systems or environment of any Bank Partner or its service providers.
**5.3. Computer Viruses.** We shall not bear any liability, whatsoever, for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from Coinbase. Always log into your Business Account(s) through your Provider’s application to review any transactions or required actions if you have any uncertainty regarding the authenticity of any communication or notice.
**5.4 Provider Security Breach.** We shall not bear any liability, whatsoever, for any damage or interruptions caused by any breach, fraud, attempted fraud, virus or malicious code, or any other attack on your Provider that interrupts or interferes with your use of the Coinbase Services.
**6. General Obligations, Taxes, Updating an Authorized Representative and Termination**
**6.1. Limited Platform License and Trademarks.** Coinbase and its affiliates own all right, title, and interest in and to the Coinbase Platform and Coinbase Services, including all associated software, APIs, and related technology. Subject to this Agreement, Coinbase grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Coinbase Platform through your Provider’s application solely to access the Coinbase Services for your own personal use. Coinbase and its licensors reserve all rights not expressly granted. “Coinbase Marks” (including the COINBASE name and associated logos) are trademarks of Coinbase or its licensors. You may not use any Coinbase Marks in any manner without Coinbase’s prior written consent. You agree you will not copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Platform, in whole or in part without the prior written consent of Coinbase.
**6.2. Information Accuracy.** Although we intend to provide accurate and timely information on the Coinbase Platform, the Coinbase Platform may not always be entirely accurate, complete or current and may also include technical inaccuracies or typographical errors. In an effort to continue to provide you with as complete and accurate information as possible, information may be changed or updated from time to time without notice, including without limitation information regarding our policies, products and services. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the Platform are your sole responsibility and we shall have no liability for such decisions. Information provided by third parties, including historical price and supply data for Digital Assets, is for informational purposes only and Coinbase makes no representations or warranties to its accuracy. Links to third-party materials (including without limitation websites) may be provided as a convenience but are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any third-party materials or on any third-party sites accessible or linked to the Platform.
**6.3. Third-Party and Provider Access.** You will access your Business Account through your Provider’s applications and interfaces. Your Provider is solely responsible for its own apps, websites, APIs, authentication flows, security controls, and customer support. Granting your Provider the ability to transmit instructions or information to Coinbase on your behalf does not relieve you of your obligations under this Agreement. If you authorize *any* third party to access or connect to your Business Account (whether your Provider or another third party, for example, by using that third party’s app or service), you are fully responsible for all actions and omissions of that third party. Coinbase is not responsible for, and you agree to indemnify Coinbase for, any loss or liability arising from such third-party access, except to the extent caused by Coinbase’s failure to perform its obligations under this Agreement.
**6.4. Transaction Limits.** The use of the Coinbase Services through your Provider’s application may be subject to transaction, volume, velocity, or other limits set by Coinbase, your Provider, or both. These limits may differ among customers and may depend on factors such as the verification steps you have completed, the payment methods you use, and other factors. Coinbase and your Provider may change, reduce, or refuse to apply any limits, as they deem necessary for compliance, risk management, security, or other legitimate business reasons.
**6.5. Unclaimed Property.** If Coinbase is holding Supported Digital Assets in your Business Account, and has no record of you accessing the Services for several years, applicable law may require Coinbase to deliver any such funds (or their USD equivalent) to the applicable state or jurisdiction as unclaimed property.
**6.6. Authentication and Security; Contact Information.** You acknowledge and agree that your Provider is solely responsible for all authentication, credential management, and identity and access management (IAM) controls related to your access to the Coinbase Services through their application. Because the Provider controls your login credentials and system access, Coinbase is not liable for losses resulting from a compromise of the Provider’s systems, your devices, or your login credentials utilized through the Provider’s application, as further detailed in Section 8.1. You are responsible for creating strong credentials and maintaining security and control of any electronic devices, IDs, email addresses, passwords, hints, personal identification numbers (PINs), API keys or any other codes that you use to access your Provider’s application. Coinbase does not control your Provider’s IAM or device security measures. Any loss or compromise of your Provider’s login credentials or device security may result in unauthorized access to your Business Account and loss or theft of assets. You must keep your contact information up to date with your Provider to receive notices or alerts. **You should never allow remote access or share your computer and/or computer screen with someone else when you are logged on to your Business Account. Coinbase is not liable for any loss that you may sustain due to the compromise of your Provider’s authentication systems or your personal login credentials (including passwordless credentials such as Passkeys and any other means of authentication) of for your failure to follow or act on any notices or alerts we or your Provider may send. In the event you believe your Business Account has been compromised, contact your Provider immediately.**
**6.7. Taxes.** The tax treatment of Digital Asset transactions is uncertain, and it is your responsibility to determine what taxes, if any, arise from transactions using Coinbase Services under this Agreement. Users are solely responsible for reporting and paying any applicable taxes arising from transactions using Coinbase Services, and acknowledge that Coinbase does not provide investment, legal, or tax advice governing these transactions. You understand that Coinbase shall report information with respect to your transactions, payments, transfers, or distributions made by or to you with respect to your activities using Coinbase Services to a tax or governmental authority to the extent such reporting is required by applicable law. Coinbase also shall withhold taxes applicable to your transactions or to payments or distributions made or deemed made to you to the extent such withholding is required by applicable law. From time to time, Coinbase may require your Provider to ask you for tax documentation or certification of your taxpayer status as required by applicable law, and any failure by you to comply with this request in the time frame identified may result in withholding and/or remission of taxes to a tax authority as required by applicable law. You should conduct your own due diligence and consult your own tax advisors before making any decisions with respect to Digital Asset transactions.
**6.8. Updating Authorized Representative**. For security reasons, if we receive legal documentation confirming your Authorized Representative is no longer entitled to access your Business Account, we will freeze your Business Account and during this time, no transactions may be completed until: (i) a new Authorized Representative has been identified by you; and (ii) we have received proof in a form satisfactory to us that the new Authorized Representative is entitled to access your Account.
**6.9. Suspension, Termination, and Cancellation.** Coinbase may suspend, restrict, or terminate your access to any or all of the Coinbase Services, and/or deactivate or cancel your Business Account(s), with immediate effect for any reason at its sole discretion and is under no obligation to disclose the details of its decision to take such action with you. This includes, without limitation, suspension or termination based on risk associated with your Provider’s program or controls, or the termination or material restriction of Coinbase’s relationship with your Provider. You acknowledge that Coinbase's decision to take certain actions, including limiting access to, suspending, or closing your account for any reason in our sole discretion, may be based on confidential criteria that are essential to Coinbase's risk management and security protocols, including risk management and security protocols related to your Provider’s program and controls. You agree that Coinbase is under no obligation to disclose the details of its risk management and security procedures to you. You will be permitted to transfer Supported Digital Assets or funds associated with your hosted Digital Asset Wallet(s) for ninety (90) days after Account deactivation or cancellation unless such transfer is otherwise prohibited (i) under applicable law, including but not limited to applicable sanctions programs; or (ii) by a facially valid subpoena or court order. You may close your Business Account at any time by following the procedures established by your Provider for account closure. As an alternative, you may contact Coinbase directly via the Formal Complaint Process (Section 7.2) to initiate account closure. You authorize us to cancel or suspend any pending transactions at the time of account closure. Coinbase may discontinue or change any product, service, or feature, in its sole discretion, at any time. Should your Provider terminate its relationship with us, or should Coinbase terminate its relationship with the Provider for any reason, your Business Account(s) will be closed. You will be permitted to withdraw your Supported Digital Assets or funds associated with your hosted Digital Asset Wallet(s) for ninety (90) days following the date of closure, which withdrawal process will be facilitated by the Provider or, where required by law, by Coinbase directly. The Provider is responsible for communicating the withdrawal process to you.
**6.10. Export Controls and Sanctions.** Your use of the Coinbase Services is subject to applicable law including but not limited to export restrictions, end-user restrictions, antiterrorism laws, and economic sanctions. By sending, receiving, buying, selling, trading, or storing Digital Assets through the Coinbase Platform or Services, you agree that you will comply with all applicable laws. You are not permitted to acquire Digital Assets or use any of the Coinbase Services if doing so would violate applicable laws and regulations, including but not limited to those of the United Nations Security Council, the United States (including prohibiting dealings with sanctioned persons identified by the U.S. Department of the Treasury’s Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons (“**SDN**”), or other U.S. non-SDN restricted or prohibited parties lists, and those prohibiting dealings with persons organized, resident, or located in comprehensively sanctioned jurisdictions), and/or any other applicable federal, state, municipal or local laws and regulations (each as amended from time to time).
**6.11 Representations.** You agree that your company is not a resident in nor organized under the laws of any country with which transactions or dealings are prohibited by governmental sanctions imposed by the U.S., the United Nations, the European Union, the United Kingdom, or any other applicable jurisdiction (collectively, “**Sanctions Regimes**”), nor is it owned or controlled by a person, entity or government prohibited under an applicable Sanctions Regime. You further agree that your company shall remain in full compliance with all applicable laws, rules, and regulations in each jurisdiction in which your company operates or otherwise uses the Services, including U.S. securities laws and regulations, as well as any applicable state and federal laws, including with applicable AML, anti-terrorist, anti-bribery/corruption, and Sanctions Regime laws and regulations, including, but not limited to, the Bank Secrecy Act, as amended by the USA PATRIOT Act (collectively, “**AML and Sanctions Laws and Regulations**”), and that your company shall remain in good standing with all relevant government agencies, departments, regulatory, and supervisory bodies in all relevant jurisdictions in which your company does business, and you will immediately notify your Provider and Coinbase if you cease to be in good standing with any regulatory authority. You further agree that your company has implemented ongoing customer sanctions screening against applicable Sanctions Regimes lists and that your company will not instruct or otherwise cause Coinbase to hold any assets or engage in any transaction that would cause Coinbase to violate applicable AML and Sanctions Laws and Regulations. You further agree to provide Coinbase with information upon request required by Coinbase to satisfy its AML and Sanctions Regime obligations and that by executing this Agreement, your company provides written consent to allow Coinbase to request and obtain (via your Provider or directly) any and all beneficial owner information regarding your company that is maintained on any national beneficial ownership registry, including, but not limited to, the Beneficial Ownership Information Registry maintained by the U.S. Financial Crimes Enforcement Network (“FinCEN”), in order to assist the Coinbase Entities in complying with their anti-money laundering and customer due diligence obligations, with the understanding that the Coinbase Entities will only use such information for those purposes and will maintain the information pursuant to the confidentiality provisions of this Agreement. Finally, your company agrees that it shall use the Services for commercial, business purposes only, limited to activities disclosed in the due diligence information submitted to your Provider and/or forwarded to Coinbase, and shall not include any personal, family or household purposes, and that your company will promptly notify your Provider and Coinbase in writing in the event you intend to use the Services in connection with any business activities not previously disclosed to your Provider or Coinbase.
**7. Customer Feedback, Queries, Complaints, and Dispute Resolution**
**7.1. Contact and Support.** The Provider is your first line of support and is responsible for handling all feedback, general questions, and technical issues relating to your use of the Coinbase Services through the Provider's application. You agree to contact your Provider first to attempt to resolve any issue, as Coinbase does not provide first-line customer support. If your Provider cannot resolve a dispute, you must follow the Formal Complaint Process described in Section 7.2. Coinbase requires that all legal documents (including civil subpoenas and complaints) be served on our registered agent for service of process. Current contact information for our registered agent in each state can be found [here](https://www.cscglobal.com/cscglobal/pdfs/CSC-registered-agent-addresses.pdf). Please note that our registered agent will accept service only if the entity identified as the recipient of the document identically matches the name of the entity registered with the Secretary of State and for which our registered agent is authorized to accept service (Coinbase, Inc.). By accepting service of a legal document, Coinbase does not waive any objections we may have and may raise in response to such document.
**7.2. Formal Complaint Process.** You may contact Coinbase directly for formal complaints only after you have attempted to resolve the issue with your Provider, or if the matter relates specifically to Coinbase’s statutory or regulatory obligations. If your Provider cannot resolve the dispute, or if the dispute relates specifically to a statutory or regulatory obligation of Coinbase, you agree to use the Formal Complaint Process set forth below before filing any arbitration claim as described further in Section 7.3 below. You must complete the Formal Complaint Process before filing any arbitration action. If you do not complete it, then you agree that your claim or action must be dismissed from arbitration.
**7.2.1. Procedural Steps.** In the event that the dispute is not resolved through your contact with the Provider, you may then contact Coinbase Support at 1-888-908-7930. If we cannot resolve the dispute through Coinbase Support, you agree to submit a formal written complaint to [support@coinbase.com](mailto:support@coinbase.com) describing your dispute, how you would like us to resolve the complaint, and any other relevant information. If you prefer to send a written complaint via mail, please include as much information as possible in describing your complaint and how you would like us to resolve the complaint, including your support case number and any other relevant information to Coinbase, Inc., 228 Park Ave S #23008, New York, NY, 10003. We will acknowledge receipt of your complaint form after you submit it. A Coinbase customer relations agent will review and evaluate your complaint based on the information you have provided and information in the possession of Coinbase. The Formal Complaint Process is completed when Coinbase responds to your complaint or forty-five (45) business days after the date we receive your complaint, whichever occurs first.
**7.3. Arbitration**. Any claim arising out of or relating to this Agreement, or the breach, termination, enforcement, interpretation or validity thereof, including any determination of the scope or applicability of the agreement to arbitrate as set forth in this Section 7.3, shall be determined by arbitration in the state of California or another mutually agreeable location, before one neutral arbitrator. The arbitration shall be administered by JAMS pursuant to its Comprehensive Arbitration Rules and Procedures, and the award of the arbitrator (the “**Award”**) shall be accompanied by a reasoned opinion. Judgment on the Award may be entered in any court having jurisdiction. This Agreement shall not preclude the parties from seeking provisional relief, including injunctive relief, in any court of competent jurisdiction. Seeking any such provisional relief shall not be deemed to be a waiver of such party’s right to compel arbitration. The parties expressly waive their right to a jury trial to the extent permitted by applicable law. Neither party has the right to arbitrate on a class or representative basis any dispute, controversy, or claim arising out of relating to this Agreement.
**7.3.1. Arbitration Fees**. In any arbitration arising out of or related to this Agreement, the arbitrator shall award to the prevailing party, if any, as determined by the arbitrator, all of its costs and fees. “Costs and fees” mean all reasonable pre-award expenses of the arbitration, including the arbitrator’s fees, administrative fees, travel expenses, out-of-pocket expenses such as copying and telephone, court costs, witness fees, and attorneys’ fees.
**7.3.2. Choice of Law.** The Parties acknowledge that this Agreement evidences a transaction involving interstate commerce. Notwithstanding the provision herein with respect to applicable substantive law, any arbitration conducted pursuant to the terms of this Agreement shall be governed by the Federal Arbitration Act (9 U.S.C. §§ 1-16).
**8. Liabilities & Indemnification**
**8.1. Release; Provider and Third-Party Responsibility; Indemnification. T**o the maximum extent permitted by applicable law, if you have a dispute with (i) your Provider or its affiliates, (ii) any Bank Partner or Bank Partner service provider, (iii) any other user of the Coinbase Services, or (iv) any other third party whose products or services you use in connection with your Business Account, you release Coinbase, its affiliates, Bank Partners, other service providers, and each of their respective officers, directors, agents, joint venturers, employees and representatives from any and all claims, demands and damages (actual and consequential) of every kind and nature arising out of or in any way connected with any such dispute, except to the extent such dispute arises from Coinbase’s failure to perform its obligations under this Agreement. You understand that you access your Business Account through your Provider’s applications and identity and access management systems. Your Provider is solely responsible for its own authentication flows, credential management, device and application security, and user-support processes. To the maximum extent permitted by applicable law, Coinbase is not responsible for, and will not be liable for, any loss or unauthorized transaction that results from: (i) compromise of your Provider’s systems, credentials, or identity and access management controls; (ii) compromise of your devices, networks, or login credentials, or those of your Authorized Representative, in each case where Coinbase processed the relevant instructions in accordance with its standard security procedures and had no reason to doubt their authenticity; (iii) the Provider application’s downtime or performance issues; (iv) inaccuracies in any fees, disclosures, or marketing materials presented by the Provider; or (v) failures in the Provider’s customer support. If you authorize any other third party to access or connect to your Business Account, you are fully responsible for all actions and omissions of that third party. You agree to indemnify and hold Coinbase, its affiliates and service providers, and each of their respective officers, directors, agents, joint venturers, employees and representatives harmless from any claim, demand, loss, damage, cost or expense (including reasonable attorneys’ fees and any fines, fees or penalties imposed by any regulatory authority) arising out of or related to: (i) your breach of this Agreement; (ii) your violation of any applicable law, rule or regulation; or (iii) any claim brought by your Provider or any other third party in connection with your misuse of Coinbase Services or your failure to comply with your separate agreement(s) with them. You further agree to indemnify and hold Coinbase harmless from any claim or loss arising from Coinbase’s reliance on inaccurate, incomplete, or fraudulent information transmitted to Coinbase by you or by your Provider on your behalf. You agree that instructions received by Coinbase via the API from your Provider constitute the authoritative and binding instructions regarding your Business Account, and Coinbase shall not be responsible for resolving any conflict between such API instructions and any other communication received from you or your Provider through separate channels. Without limiting the foregoing, to the maximum extent permitted by applicable law, Coinbase is not responsible for, and you release the foregoing parties from, any loss, unauthorized transaction, claim, or liability arising out of or relating to any act, omission, outage, delay, rejection, return, recall, reversal, hold, review, freeze, restriction, Security Breach, unauthorized access, data incident, or other failure of any Bank Partner or Bank Partner service provider in connection with Deposit Instructions or other Bank-Partner-backed services.
**8.2. Limitation of Liability; No Warranty**. IN NO EVENT SHALL COINBASE, ITS AFFILIATES, BANK PARTNERS AND SERVICE PROVIDERS, OR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES OR REPRESENTATIVES, BE LIABLE (I) FOR ANY AMOUNT GREATER THAN THE VALUE OF THE SUPPORTED DIGITAL ASSETS ASSOCIATED WITH YOUR DIGITAL ASSET WALLET AT THE TIME OF THE EVENT OR CIRCUMSTANCE GIVING RISE TO YOUR CLAIM OR (II) FOR ANY LOST PROFITS, LOSS OF GOODWILL OR REPUTATION, LOSS OF DATA, DIMINUTION IN VALUE OR BUSINESS OPPORTUNITY, ANY LOSS, DAMAGE, CORRUPTION OR BREACH OF DATA OR ANY OTHER INTANGIBLE PROPERTY OR ANY SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, OR CONSEQUENTIAL DAMAGES, WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, ARISING OUT OF OR IN CONNECTION WITH ANY USE OF THE COINBASE PLATFORM OR THE COINBASE SERVICES, OR THIS AGREEMENT, EVEN IF COINBASE HAS BEEN ADVISED OF OR KNEW OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES, AND NOTWITHSTANDING THE FAILURE OF ANY AGREED OR OTHER REMEDY OF ITS ESSENTIAL PURPOSE, EXCEPT TO THE EXTENT OF A FINAL JUDICIAL DETERMINATION THAT SUCH DAMAGES WERE A RESULT OF COINBASE’S GROSS NEGLIGENCE, FRAUD, WILLFUL MISCONDUCT OR INTENTIONAL VIOLATION OF LAW. THIS MEANS, BY WAY OF EXAMPLE ONLY (AND WITHOUT LIMITING THE SCOPE OF THE PRECEDING SENTENCE), THAT IF YOU CLAIM THAT COINBASE FAILED TO PROCESS A BUY OR SELL TRANSACTION PROPERLY, YOUR DAMAGES ARE LIMITED TO NO MORE THAN THE LESSER OF THE VALUE OF THE SUPPORTED DIGITAL ASSETS AT ISSUE IN THE TRANSACTION OR THE TOTAL VALUE OF THE SUPPORTED DIGITAL ASSETS ASSOCIATED WITH YOUR DIGITAL ASSET WALLET, AND THAT YOU MAY NOT RECOVER FOR LOST PROFITS, LOST BUSINESS OPPORTUNITIES, DIMINUTION IN VALUE OR OTHER TYPES OF SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, EXEMPLARY, PUNITIVE OR CONSEQUENTIAL DAMAGES OR ANY DAMAGES ARISING OUT OF OR RELATING TO DIGITAL ASSETS THAT ARE NOT SUPPORTED DIGITAL ASSETS. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
THE COINBASE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, COINBASE SPECIFICALLY DISCLAIMS ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND/OR NON-INFRINGEMENT. COINBASE DOES NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT ACCESS TO THE COINBASE PLATFORM, ANY PART OF THE COINBASE SERVICES, OR ANY OF THE MATERIALS CONTAINED THEREIN, WILL BE CONTINUOUS, UNINTERRUPTED, TIMELY, OR ERROR-FREE. COINBASE DOES NOT GUARANTEE THAT ANY ORDER OR INSTRUCTION WILL BE EXECUTED, ACCEPTED, RECORDED OR REMAIN OPEN. EXCEPT FOR THE EXPRESS STATEMENTS SET FORTH IN THIS AGREEMENT, YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU HAVE NOT RELIED UPON ANY OTHER STATEMENT OR UNDERSTANDING, WHETHER WRITTEN OR ORAL, WITH RESPECT TO YOUR USE AND ACCESS OF THE COINBASE SERVICES AND COINBASE PLATFORM. WITHOUT LIMITING THE FOREGOING, YOU HEREBY UNDERSTAND AND AGREE THAT COINBASE WILL NOT BE LIABLE FOR ANY LOSSES OR DAMAGES ARISING OUT OF OR RELATING TO: (I) ANY INACCURACY, DEFECT OR OMISSION OF DIGITAL ASSET PRICE DATA, OR ANY ERROR, DELAY OR INTERRUPTION IN THE TRANSMISSION OF SUCH DATA; (II) VIRUSES OR OTHER MALICIOUS SOFTWARE OBTAINED BY ACCESSING SYSTEMS OPERATED BY US OR ON OUR BEHALF OR ANY OF THE COINBASE SERVICES; (III) GLITCHES, BUGS, ERRORS, OR INACCURACIES OF ANY KIND IN SYSTEMS OPERATED BY US OR ON OUR BEHALF OR ANY OF THE COINBASE SERVICES; OR (IV) A SUSPENSION OR OTHER ACTION TAKEN WITH RESPECT TO YOUR BUSINESS ACCOUNT.
WITHOUT LIMITING THE FOREGOING, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, COINBASE AND ITS BANK PARTNERS MAKE NO REPRESENTATION OR WARRANTY WITH RESPECT TO THE CONTINUED AVAILABILITY, SECURITY, ERROR-FREE OPERATION, OR FREEDOM FROM INTERRUPTION OF ANY DEPOSIT INSTRUCTIONS, VIRTUAL ACCOUNT NUMBER, FIAT ACCOUNT, PAYMENT RAIL, OR OTHER BANK-PARTNER-BACKED SERVICE, AND WILL NOT BE LIABLE FOR ANY LOSS, DAMAGE, OR CLAIM ARISING OUT OF OR RELATING TO ANY EVENT OCCURRING AT THE LEVEL OF A BANK PARTNER OR ITS SERVICE PROVIDERS.
Bank Partners and their service providers are intended third-party beneficiaries of Sections 3.1, 5.2, 8.1, and 8.2, solely to the extent those provisions relate to Bank-Partner-backed services, and may enforce those provisions directly.
Coinbase will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts are processed in a timely manner but Coinbase makes no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control.
The foregoing limitations of damages, liability and no warranty provisions set forth above in this Section 8.2 are fundamental elements of the basis of the bargain between Coinbase and you.
**9. General Provisions**
**9.1. Entire Agreement**. This Agreement, the Privacy Policy, E-Sign Disclosure and Consent Policy, Prohibited Use Policy, and Appendices incorporated by reference herein comprise the entire understanding and agreement between you and Coinbase as to the subject matter hereof, and supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), between you and Coinbase. Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement. This Agreement is a legal, valid, and binding obligation, enforceable against your Company in accordance with its terms.
**9.2. Assignment**. We reserve the right to assign our rights without restriction, including without limitation to any Coinbase affiliates or subsidiaries, or to any successor in interest of any business associated with the Coinbase Services. In the event that Coinbase is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. You may not assign any rights and/or licenses granted under this Agreement. Any attempted transfer or assignment by you in violation hereof shall be null and void. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns.
**9.3. Severability**. If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law, or regulation of any local, state, or federal government agency, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of this Agreement shall not be affected.
**9.4. Survival**. All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, sections pertaining to suspension or termination, Business Account cancellation, debts owed to Coinbase, general use of the Coinbase Platform, disputes with Coinbase, and general provisions, shall survive the termination or expiration of this Agreement.
**9.5. Governing Law**. You agree that the laws of the State of California, without regard to principles of conflict of laws, will govern this Agreement and any dispute, except to the extent governed by federal law.
**9.6. Force Majeure**. We shall not be liable for delays, failure in performance or interruption of service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to, significant market volatility, act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, pandemic, other catastrophe or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.
**9.7. Non-Waiver of Rights**. This Agreement shall not be construed to waive rights that cannot be waived under applicable laws, including applicable state money transmission laws in the state where you are located. In addition, our failure to insist upon or enforce strict performance by you of any provision of this Agreement or to exercise any right under this Agreement will not be construed as a waiver or relinquishment to any extent of our right to assert or rely upon any such provision or right in that or any other instance.
**9.8. Relationship of the Parties**. Coinbase is an independent contractor for all purposes. Nothing in this Agreement is intended to or shall operate to create a partnership or joint venture between you and Coinbase, or authorize you to act as agent of Coinbase.
***
#### **APPENDIX 1: E-Sign Disclosure and Consent**
This policy describes how Coinbase delivers communications to you electronically, either directly or through your Provider. In most cases, communications will be delivered to you through your Provider’s application or other customer communication channels established by your Provider. However, Coinbase may also provide communications to you directly where appropriate or required by law. We may amend this policy at any time by providing a revised version on our website and/or through your Provider. The revised version will be effective at the time we or your Provider post it or otherwise make it available. We or your Provider will provide you with prior notice of any material changes via our website, your Provider’s application or website, or other communication channels.
**Electronic Delivery of Communications**
You agree and consent to receive electronically all communications, agreements, documents, notices and disclosures (collectively, "Communications") that we provide in connection with your Business Account(s) and your use of Coinbase Services. You agree that we may provide Communications to you directly, or that your Provider may provide Communications to you on our behalf. Communications include, for example:
* Terms of use and policies you agree to (e.g., the Coinbase User Agreement, Privacy Policy and U.S. Financial Privacy Notice), including updates to these agreements or policies;
* Account details, history, transaction receipts, confirmations, and any other account or transaction information relating to your use of Coinbase Services (including where surfaced to you through your Provider);
* Legal, regulatory, and tax disclosures or statements we may be required to make available to you; and
* Responses to claims or customer support inquiries filed in connection with your Account or your use of Coinbase Services.
You consent to the use of electronic signatures in connection with your use of the Services.
Where applicable, we or your Provider may make tax forms and related documents available to you electronically and may ask you to consent to electronic or paperless delivery of such forms in accordance with applicable law. Information about how to access such documents and how to change your delivery preferences (if permitted) will be provided in the Provider application or website through which you access the Coinbase Services. As a general matter, Communications will be delivered to you through your Provider. In some cases, we may also deliver Communications directly using one or more of the following methods: (i) by posting them on coinbase.com; (ii) by emailing them to the email address associated with your account with your Provider or otherwise provided to us; or (iii) by any other electronic means that we or your Provider notify you of from time to time.
**Hardware and Software Requirements**
In order to access and retain electronic Communications, you will need the following computer hardware and software:
* A device with an Internet connection;
* A compatible device and operating system that are supported by your Provider;
* The current version of your Provider’s application installed and properly configured;
* A valid email address (your primary email address on file with your Provider or otherwise provided to us); and
* Sufficient storage space to save past Communications or an installed printer to print them.
**How to Withdraw Your Consent**
You may withdraw your consent to receive Communications electronically by contacting us at 1-888-908-7930. If you fail to provide or if you withdraw your consent to receive Communications electronically, Coinbase reserves the right to immediately close your Business Account or charge you additional fees for paper copies.
**Updating your Information**
It is your responsibility to provide a true, accurate and complete e-mail address and your contact information, and to keep such information up to date. You agree to keep your contact information (including your primary email address) up to date with your Provider, and you authorize us to rely on the most recent contact information for you that we receive from your Provider. You understand and agree that if Coinbase sends you an electronic Communication but you do not receive it because your primary email address on file with your Provider is incorrect, out of date, blocked by your service provider, or you are otherwise unable to receive electronic Communications, Coinbase (and, where applicable, your Provider) will be deemed to have provided the Communication to you.
You may update your information by updating your contact details in your Provider’s application.
***
## **APPENDIX 2: State License Disclosures**
Coinbase maintains licenses to engage in money transmission activities in many states, and these licenses may impact our provision and your use of certain Coinbase Services depending on where you live. Coinbase's licenses and corresponding required disclosures can be found on the [Coinbase Licenses](https://coinbase.com/legal/licenses) page, which is incorporated by reference.
If you live in the following jurisdictions, we are required to provide you with the following information:
**Alaska**
If your issue is unresolved by Coinbase, Inc., 1-888-908-7930, please submit formal complaints with the State of Alaska, Division of Banking & Securities.
Please download the form here: [https://www.commerce.alaska.gov/web/portals/3/pub/DBSGeneralComplaintFormupdated.pdf](https://www.commerce.alaska.gov/web/portals/3/pub/DBSGeneralComplaintFormupdated.pdf)
Submit formal complaint form with supporting documents: Division of Banking & Securities PO Box 110807 Juneau, AK 99811-0807
If you are an Alaska resident with questions regarding formal complaints, please email us at [dbs.licensing@alaska.gov](mailto:dbs.licensing@alaska.gov) or call Nine Zero Seven Four Six Five Two Five Two One
**Arizona**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, lnc.'s money transmission activity, you may complete an Online Complaint Form as stated on the File a Complaint against a Financial Institution or Enterprise page: [https://difi.az.gov/complaint](https://difi.az.gov/complaint)
Or you may call the AZ Financial Institutions Division: (602) 771-2800 | Toll-free: (800) 544-0708
**Arkansas**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930.
If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file a complaint at: [https://securities.arkansas.gov/file-a-complaint-2/](https://securities.arkansas.gov/file-a-complaint-2/) or contact the Arkansas Securities Department at:
1 COMMERCE WAY, SUITE 402 LITTLE ROCK, ARKANSAS 72202 TELEPHONE: (501) 324-9260 FACSIMILE: (501) 324-9268
**California**
Please note the following disclosures for California resident customers of Coinbase, Inc.:
Please [see here](https://www.coinbase.com/legal/insurance) information regarding insurance available to Coinbase for certain assets on the Coinbase platform.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to unauthorized, fraudulent, and accidental transactions or transfers may not be recoverable.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
Following each transaction, your Provider will provide you with a receipt, trade ticket, or other evidence of the transaction. You can access these records in your account.
Virtual currency is not legal tender in California or the United States, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you have an unresolved complaint regarding Coinbase, Inc., you can direct your complaint to the California Department of Financial Protection and Innovation:
Online: [https://dfpi.ca.gov/submit-a-complaint/](https://dfpi.ca.gov/submit-a-complaint/)\
DFPI consumer complaints email: [Ask.DFPI@dfpi.ca.gov](mailto:Ask.DFPI@dfpi.ca.gov)\
Toll Free: (866) 275-2677
Paper complaint forms can be mailed to the Department of Financial Protection and Innovation:
Attn: Consumer Services\
651 Bannon Street, Suite 300\
Sacramento, CA 95811
**Colorado**\
[MO7 Customer Notice - COLORADO MONEY TRANSMITTERS ACT](https://banking.colorado.gov/sites/banking/files/documents/MT_Customer_Notice_MO7_English_Spanish_03.2026_AccO.pdf)\
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Colorado Division of Banking.
The Complaint Process is available here: [https://banking.colorado.gov/consumers/file-a-complaint](https://banking.colorado.gov/consumers/file-a-complaint)
Colorado Division of Banking 1560 Broadway, Suite 975, Denver, CO 80202 Phone: 303-894-7575 Fax: 303-894-7570 E-mail: [DORA\_BankingWebsite@state.co.us](mailto:DORA_BankingWebsite@state.co.us)
**Connecticut**\
Please note the following disclosures associated with virtual currency:
**WARNING: LOSSES DUE TO FRAUDULENT OR ACCIDENTAL TRANSACTIONS MAY NOT BE RECOVERABLE AND TRANSACTIONS IN VIRTUAL CURRENCY ARE IRREVERSIBLE.**
Virtual currency is not backed or insured by the government and accounts and value balances are not subject to Federal Deposit Insurance Corporation, National Credit Union Administration or Securities Investor Protection Corporation protections.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which may not be the date or time when the customer initiates the virtual currency transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the permanent and total loss of the value of a particular virtual currency, if the market for that virtual currency disappears.
The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in a significant loss over a short period of time.
Any bond maintained by Coinbase for the benefit of the customers of Coinbase may not be sufficient to cover all losses incurred by such customers.
Virtual currency transactions are irreversible and are used by persons seeking to defraud customers, including, but not limited to, a person impersonating a customer's loved one, threatening jail time, stating that a customer's identity has been stolen, insisting that a customer withdraw money from the customer's bank account and purchase cryptocurrency or alleging a customer's personal computer has been hacked.\
If you have a complaint or questions, please contact Coinbase, Inc. Support at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, you may submit a formal complaint via [https://help.coinbase.com/en/contact-us/submit-a-complaint](https://help.coinbase.com/en/contact-us/submit-a-complaint). You may also contact the Connecticut Department of Banking at [https://portal.ct.gov/dob/consumer/consumer-complaints/money-transmitter](https://portal.ct.gov/dob/consumer/consumer-complaints/money-transmitter) with any complaints.
**District of Columbia**\
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Department at:
District of Columbia Department of Insurance, Securities and Banking 1050 First St., NE, Suite 801 Washington, DC 20002 Phone: (202) 727-8000 Fax: (202) 354-1085 E-mail: [disbcomplaints@dc.gov](mailto:disbcomplaints@dc.gov)
[Consumer Complaint Form Mail-in Version](https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB%20Consumer%20Complaints_final%20fillable.pdf)
**Florida**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930[.](https://help.coinbase.com/en/contact-us.) If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Florida Office of Financial Regulation at: Online: [https://flofr.gov/sitePages/FileAComplaint.htm](https://flofr.gov/sitePages/FileAComplaint.htm). To file your complaint, you will need to register electronically through Online Services. A valid email address is required.
Florida Office of Financial Regulation - Consumer Finance 200 E. Gaines Street, Tallahassee, FL 32399-0376 850-487-9687
FL Office of Financial Regulation Complaint Portal: [https://flofr.gov/sitePages/FileAComplaint.htm](https://flofr.gov/sitePages/FileAComplaint.htm)
**Georgia**
Licensed by The Georgia Department of Banking and Finance. (Lic. # 42796/ NMLS# 1163082).
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930[.](https://help.coinbase.com/en/contact-us) If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Georgia Department of Banking and Finance - Consumer Resources: [https://consumer.georgia.gov/resolve-your-dispute/how-do-i-file-complaint](https://consumer.georgia.gov/resolve-your-dispute/how-do-i-file-complaint)
**Illinois**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Illinois Division of Banking at:
[https://idfpr.illinois.gov/admin/dfi/dficomplaint.html](https://idfpr.illinois.gov/admin/dfi/dficomplaint.html)
**Kansas**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Office of the State Bank Commissioner.
If submitting electronically, submit your complaint here: [https://www.osbckansas.org/consumers/file-a-complaint/](https://www.osbckansas.org/consumers/file-a-complaint/)
Mail or fax the completed consumer assistance form and attachments to:
Kansas Office of the State Bank Commissioner: Attn: Consumer Affairs 700 SW Jackson St, Suite 300 Topeka, KS 66603 Fax: (785) 371-1229 Email: [complaints@osbckansas.org](mailto:complaints@osbckansas.org)
**Louisiana**
Please note the money transmission license issued to Coinbase, Inc. by the Louisiana Office of Financial Institutions does not cover the exchange or transmission of virtual currency.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Office of Financial Institutions.
All complaints must be submitted in writing. To file a complaint, please complete the complaint form and send to [OFI](http://www.ofi.state.la.us/) by mail, email, or fax.
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the value of virtual currency.
Transaction in virtual currency may be irreversible, and accordingly, losses due to fraudulent or accidental transactions may not be recoverable.
Some virtual currency transactions may be immediately effective when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange legal tender for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency if the market for the virtual currency declines or collapses for an extended period of time.
Any surety bond required by law for the benefit of customers may not be sufficient to cover all losses incurred by customers.
Customers should perform research before purchasing or investing in virtual currency.
Please see Coinbase’s Global Privacy Policy and U.S. Financial Privacy Notice, which describes how Coinbase collects, uses and discloses personal information.
**Maryland**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Maryland Department of Labor.
The Commissioner of Financial Regulation for the State of Maryland will accept all questions or complaints from Maryland residents regarding License No. 12-1163082 and NMLS ID: 1163082 by contacting the Commissioner's office at: 500 North Calvert Street, Suite 402, Baltimore, Maryland 21202, or (888) 784-0136. Additional information about Coinbase, Inc. may be obtained at [www.nmlsconsumeraccess.org](http://www.nmlsconsumeraccess.org/)
**Minnesota**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file it by contacting the Minnesota Department of Commerce.
To make a complaint, please make a call contacting the following:
Minnesota Department of Commerce 85 8th Place East, Suite 208 Saint Paul, MN 55101 (Local) 651-539-1500 (Complaints) 651-539-1600
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
**Mississippi**
The Mississippi Department of Banking & Consumer Finance recommends that you attempt to resolve your complaint with the financial institution first by contacting Coinbase, Inc. at 1-888-908-7930 to allow the opportunity to resolve the issue(s). If you still have an unresolved complaint regarding Coinbase, Inc.'s money transmission activity, you may file your complaint online at [https://dbcf.ms.gov/complaint-form/](https://dbcf.ms.gov/complaint-form/)
**Nevada**
Coinbase, Inc. is licensed by the Nevada Department of Business and Industry as a money transmitter. At this time, the Nevada Department of Business and Industry does not license or regulate services related to virtual currency, including but not limited to virtual currency transmission or exchange which may be conducted by Coinbase.
If you have a question or complaint, please first contact the consumer assistance division of Coinbase at (888) 908-7930, or at its mailing address: 228 Park Ave S #23008, New York, NY, 10003. If you have an unresolved question or complaint regarding the money transmission services provided by Coinbase, you may contact the Nevada Department of Business and Industry at (702) 486-4120.
**New York**
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the use, transfer, exchange, and value of virtual currency.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency should the market for that virtual currency disappear.
There is no assurance that a person who accepts a virtual currency as payment today will continue to do so in the future.
The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in significant loss over a short period of time.
The nature of virtual currency may lead to an increased risk of fraud or cyber attack.
The nature of virtual currency means that any technological difficulties experienced by Coinbase may prevent the access or use of a customer’s virtual currency.
Any bond or trust account maintained by Coinbase for the benefit of its customers may not be sufficient to cover all losses incurred by customers.
Coinbase, Inc. is regulated and licensed as a money transmitter by the New York State Department of Financial Services. If you have a question or complaint, please first contact the consumer assistance division of Coinbase at (888) 908-7930, or at its mailing address: 228 Park Ave S #23008, New York, NY, 10003.
For unresolved/written complaints, you may mail a complaint to New York State Department of Financial Services, Consumer Services Division, One State Street, New York, NY 10004-1417, (800) 342-3736, email: [consumers@dfs.ny.gov](mailto:consumers@dfs.ny.gov), website: [www.dfs.ny.gov/complaint](https://www.dfs.ny.gov/complaint).
**North Dakota**
Coinbase, Inc. is licensed by the North Dakota Department of Financial Institutions as a money transmitter. If you have a question or complaint, please first contact the consumer assistance division of Coinbase at (888) 908-7930, or at its mailing address: 228 Park Ave S #23008, New York, NY, 10003. If you have an unresolved question or complaint regarding the money transmission services provided by Coinbase, you may contact the North Dakota Department of Financial Institutions at (701) 328-9933.
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
**Rhode Island**
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
**Tennessee**
Coinbase, Inc. is licensed by the Tennessee Department of Financial Institutions as a money transmitter.
The Tennessee Department of Financial Institutions does not regulate virtual currency. Please note that this license and the required surety bond do not cover the transmission of virtual currency. The Tennessee Department of Financial Institutions does not regulate virtual currency. Tennessee’s Money Transmitter License and the required surety bond do not cover the transmission of virtual currency. However, any company that offers to exchange, administer, or maintain virtual currencies for sovereign currency may be subject to state regulation and licensing as well as federal regulation.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, please direct your complaint to: [https://www.tn.gov/tdfi/tdfi-how-do-i/file-a-complaint.html](https://www.tn.gov/tdfi/tdfi-how-do-i/file-a-complaint.html) or call the Tennessee Department of Financial Institutions at 1-800-778-4215
**Texas**
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, please direct your complaint to: [https://www.dob.texas.gov/money-services-businesses/how-file-complaint](https://www.dob.texas.gov/money-services-businesses/how-file-complaint)
Virginia Coinbase, Inc. is licensed by the Virginia State Corporation Commission as a money transmitter, but such license does not cover the transmission of virtual currency (Bitcoin).
**Washington**
Please note the following disclosures associated with virtual currency:
Virtual currency is not legal tender in the United States, is not backed by the United States government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent, mistaken or accidental transactions may not be recoverable. If you believe you did not authorize a particular transaction or that a transaction was incorrectly carried out, you must contact us as soon as possible. Reporting an unauthorized transaction does not guarantee Coinbase will be able to reverse the transaction or reimburse you for the transaction.
The nature of virtual currency may lead to an increased risk of fraud or cyber attack.
If you have a complaint, please contact Coinbase, Inc. at 1-888-908-7930. If you still have an unresolved complaint regarding Coinbase, Inc. money transmission activity, you may file it by contacting the Washington Department of Financial Institutions at [https://dfi.wa.gov/consumers/money-services-complaint](https://dfi.wa.gov/consumers/money-services-complaint)