Terms of Service

These Terms of Service (“Terms”) are a legally binding agreement between you, whether personally or on behalf of an entity (“you”), and Terminal 3 HK Limited (“Terminal 3,” “Company,” “we,” “us,” “our”), a data freedom company that makes fully private data freely composable. They govern your access to and use of our websites, applications (web and mobile), software development kits, application programming interfaces, and related products and services that link to these Terms (collectively, the “Services”).

By accessing or using the Services, you confirm that you have read, understood, and agreed to be bound by these Terms. If you do not agree, you may not access or use the Services.

How to read these Terms. Sections 1–7 and 14–24 apply to everyone who uses the Services, including visitors to our website. Sections 8–13 contain additional terms that apply only if you hold a Terminal 3 identity account (an “Account”) accessed through one of our enterprise customers (each, a “Relying Organization”). Where a section applies only to Account holders, it says so.

1.1  Terminal 3 provides confidential-computing infrastructure that lets enterprises and developers store, process, and verify sensitive data without taking custody of it. Through a Relying Organization, you may also hold an Account — a reusable digital identity through which you control how your identity data is accessed and shared.

1.2  These Terms govern your use of the Services. If you hold an Account, the additional terms in Sections 8–13 also apply to you and your Account, and they continue to apply to your Account even if your relationship with any particular Relying Organization ends.

1.3  If you reach your Account through a Relying Organization, each Relying Organization’s own terms and privacy notice govern your relationship with that organization; these Terms and the Terminal 3 Privacy Policy govern your relationship with Terminal 3. If there is a conflict between these Terms and a Relying Organization’s terms with respect to your Terminal 3 Account and the identity data in it, these Terms control. Nothing in a Relying Organization’s terms can reduce the rights these Terms give you in your Account.

1.4  The handling of your personal data is described in the Terminal 3 Privacy Policy at Terminal 3 Privacy Policy, which forms part of and is incorporated into these Terms. Supplemental terms, policies, or documents that we post or make available in connection with the Services (for example, an Acceptable Use Policy or product-specific terms such as our Developer Terms) are incorporated into these Terms by reference; where such supplemental terms conflict with these Terms for the relevant product, the supplemental terms control for that product.

1.5  You do not pay Terminal 3 to browse our website or to hold an Account. Where the Services are made available to you in connection with a Relying Organization’s subscription to Terminal 3, your access is provided on that basis.

2.1  Website and general use. By accessing or using the Services, including by browsing our website, you agree to these Terms. We may change or modify these Terms from time to time as described in Section 22.

2.2  Account acceptance (Account holders). When you create or use an Account through a Relying Organization, you accept both that Relying Organization’s terms and these Terms. These Terms are presented to you directly, by name, as part of that flow, and your acceptance of them is recorded (including the version accepted and the date and time of acceptance). Your acceptance of a Relying Organization’s terms does not, on its own, constitute acceptance of these Terms; these Terms apply to your Account because you have accepted them directly.

2.3  Electronic communications and signatures. Visiting the Services, sending us emails, and completing online forms are electronic communications. You consent to receive communications from us electronically, and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically satisfy any legal requirement that such communications be in writing. You agree to the use of electronic records, electronic signatures, and electronic acceptance, and you waive any rights or requirements under any laws that require an original (non-electronic) signature, to the extent permitted by applicable law and subject to your mandatory rights under Section 19.

3.1  You must not be a minor in the jurisdiction in which you reside, and you represent that you are not. The Account is not available to minors.

3.2  You represent that you have the legal capacity to agree to these Terms and, where you act on behalf of another person or an entity, that you have the authority to bind that person or entity.

4.1  The information provided through the Services is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or would subject us to any registration requirement. Those who choose to access the Services from such locations do so on their own initiative and are responsible for compliance with local law to the extent it applies.

4.2  When you use the Services, you may also be using the services of one or more third parties. Your use of those third-party services may be subject to the separate policies, terms, and fees of those third parties. Terminal 3 does not control, and is not responsible for, the methods, accuracy, or acts of third-party providers, including identity-verification providers.

4.3  We may change, modify, suspend, or discontinue all or part of the Services at any time. We will not be liable for any modification, suspension, or discontinuance of the Services, except to the extent any liability cannot lawfully be excluded. This Section 4.3 is subject to Sections 19 and 20.

5.1  Our intellectual property. We are the owner or licensee of all intellectual property rights in the Services, including all source code, databases, functionality, software, website and application designs, text, graphics, and other content (the “Content”), as well as the trademarks, service marks, and logos in the Services (the “Marks”). The Content and Marks are protected by law and are provided “as is” for your permitted use of the Services.

5.2  Permitted use. Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable license to access and use our website and its Content for ordinary viewing and internal evaluation purposes. You may not copy, reproduce, aggregate, republish, upload, post, publicly display, scrape, resell, license, or otherwise exploit any part of the Services, Content, or Marks for any commercial purpose without our prior written permission, and you may not interfere with the operation or security of the website. Authorized access through our APIs and software development kits, under the applicable product terms (including our Developer Terms), is permitted.

5.3  We reserve all rights not expressly granted to you in and to the Services, Content, and Marks. Any breach of this Section is a material breach of these Terms and your right to use the Services will terminate immediately.

By using the Services, you represent and warrant that: (a) all information you provide is true, accurate, current, and complete, and you have the right to provide it; (b) you will maintain the accuracy of that information and update it as necessary; (c) you are not a minor in the jurisdiction in which you reside and you have the legal capacity to agree to these Terms; (d) you will not use the Services for any unlawful or unauthorized purpose; and (e) your use of the Services will not violate any applicable law or regulation.

You agree that you will not, and will not attempt to:

• (a) provide false, inaccurate, or misleading information, impersonate any person or entity, or misrepresent your affiliation with any person or entity;
• (b) access, or try to access, another user’s account or data, or use the credentials of another user;
• (c) trick, defraud, or mislead Terminal 3, a Relying Organization, or any other user, including any attempt to obtain another user’s credentials or sensitive account information;
• (d) circumvent, disable, interfere with, or attempt to defeat the security, cryptographic controls, or governance controls of the Services;
• (e) introduce or transmit any virus, malware, or other harmful code, or otherwise interfere with, disrupt, or place an undue burden on the Services or the networks and systems connected to them;
• (f) systematically retrieve data or content from the Services, or use any automated means, scripts, bots, scrapers, or data-mining or extraction tools, to create or compile a collection, compilation, or database, or to republish Content, without our written permission;
• (g) decipher, decompile, disassemble, or reverse engineer any software comprising or making up part of the Services, except to the extent applicable law permits this notwithstanding this restriction; or
• (h) use the Services for any unlawful purpose or in any manner inconsistent with applicable law or regulation, or engage in any activity we designate as prohibited in an Acceptable Use Policy.

This section and Sections 9–13 apply only if you hold a Terminal 3 identity Account.

8.1  Your Account, and any credentials, keys, or authentication factors associated with it, are personal to you. You are responsible for activity that occurs under your Account, and you agree to keep your credentials and authentication factors confidential.

8.2  You may not sell, transfer, sublicense, or otherwise make your Account or profile available to any other person.

8.3  If you become aware of any unauthorized access to or use of your Account, you agree to notify us promptly using the contact details in Section 24. We are not responsible for loss arising from unauthorized use of your Account where you have failed to keep your credentials confidential, except to the extent such loss results from our own failure to provide reasonable security or cannot lawfully be excluded.

9.1  All Terminal 3 products are built on T3 Network, our confidential-computing layer. As a result, the following protections apply to identity data processed through your Account:

• (a) Client-side encryption. Identity data is encrypted using AES-256-GCM within the client software before it leaves your device.
• (b) Threshold key management. Encryption keys are split across multiple independent nodes using threshold cryptography (ML-KEM, FIPS 203). Decryption requires a quorum of nodes, so no single party — including Terminal 3 — can decrypt your data on its own, and the compromise of any single node does not expose your data.
• (c) Hardware-secured computation. Computation is performed inside Trusted Execution Environments (Intel TDX), hardware-isolated regions where data is processed without plaintext being accessible to applications, to the surrounding operating system, or to Terminal 3’s infrastructure operators.
• (d) Jurisdictional data residency. Data can be pinned to a specific jurisdiction so that it is stored and processed within that region.
• (e) Verifiable audit trail. Data access, computation, policy evaluation, and credential verification are recorded in a tamper-evident, cryptographically linked audit ledger that can be independently verified.

9.2  The technical and organizational protections we apply, and how we handle your personal data, are described in more detail in the Terminal 3 Privacy Policy.

10.1  Your Account may hold two kinds of identity data, which are treated differently:

• (a) Private User Data — identity data protected by cryptographic controls that you authorize. You control access to it. Terminal 3 cannot access, change, or delete your Private User Data without your authorization, except where technically necessary to provide, secure, or support the Services, or where required by law. It is held in protected, access-controlled environments.
• (b) Regulated User Data — identity data that the law requires to be collected and kept, such as data for identity verification, anti–money-laundering, counter–terrorist-financing, sanctions screening, or fraud prevention. This data is held in controlled record-keeping environments (“Regulatory Vaults”) and may be accessed, kept, or disclosed only as required by law or by a valid and verified legal or regulatory process. Because the law requires it to be retained, you may not be able to delete Regulated User Data on request.

10.2  You represent that the identity data you provide is accurate and that you have the right to provide it.

10.3  Verification of your identity may be performed by independent third-party providers (for example, document-verification or sanctions-screening services). Terminal 3 does not control, and is not responsible for, the methods or accuracy of those third-party providers.

11.1  Your Terminal 3 identity may be reused with more than one Relying Organization over time. Each Relying Organization’s own terms and privacy notice govern your relationship with that organization; these Terms govern your relationship with Terminal 3 for the underlying Account.

11.2  You normally access and manage your Account through a Relying Organization’s flow. You may also contact Terminal 3 directly, at any time, to exercise the rights described in these Terms, using the contact details in Section 24.

12.1  If a Relying Organization stops using Terminal 3, your Account and the identity data in it remain, unless you instruct that it be deleted (subject to legally required retention of Regulated User Data). Your Private User Data stays under your cryptographic control. If you continue to authorize Terminal 3, we may continue to hold and process your data as you authorize or as the law requires.

12.2  You may instruct deletion of your Private User Data at any time by contacting Terminal 3 directly (Section 24), subject to legally required retention of Regulated User Data. Where technically feasible, we will provide your personal data to you, or transfer it, at your request.

13.1  Subject to Section 10 and the legally required retention of Regulated User Data, you may request access to, correction of, or deletion of your identity data, and may withdraw authorizations you have given, by contacting Terminal 3 directly (Section 24).

13.2  The handling of your personal data, including your rights under applicable data-protection law, is described in the Terminal 3 Privacy Policy at Terminal 3 Privacy Policy and in the privacy notice of your Relying Organization.

14.1  We may suspend or close your access to the Services or your Account if you breach these Terms, if doing so is required or reasonably necessary to prevent fraud or comply with the law, if (for Account holders) your identity cannot be verified, or if our relationship with a third-party provider whose technology we use to provide the Services changes or ends in a way that affects the Services or your Account. Where lawful and practical, we will tell you.

14.2  You may stop using the Services at any time. If you hold an Account, you may instruct deletion of your Private User Data as described in Section 12.

14.3  Legally required Regulated User Data may be retained after suspension or closure. Sections 5, 10, 15, 16, 17, 18, 19, 20, 21, 23, and 24, and any other provisions that by their nature should survive, survive termination of these Terms.

15.1  To the fullest extent permitted by law, the Services are provided on an “as is” and “as available” basis, and your use of the Services is at your own risk. We do not guarantee that the Services will always be available, uninterrupted, secure, or error-free.

15.2  To the fullest extent permitted by law, we disclaim all warranties, express or implied, in connection with the Services and your use of them, including the implied warranties of merchantability, fitness for a particular purpose, and non-infringement. Without limiting the foregoing, we assume no liability or responsibility for: (a) errors, mistakes, or inaccuracies of content; (b) unauthorized access to or use of our servers or any personal or financial information stored on them, except to the extent caused by our failure to provide reasonable security; (c) any interruption or cessation of transmission to or from the Services; (d) any bugs, viruses, or harmful code transmitted to or through the Services by any third party; or (e) the acts, methods, or accuracy of any third-party provider, including identity-verification providers.

15.3  This Section 15 is subject to Sections 19 and 20.

16.1  To the fullest extent permitted by law, Terminal 3 and its directors, employees, and agents will not be liable to you for any indirect, incidental, consequential, special, exemplary, or punitive damages, or for any loss of profit, revenue, or data, arising out of or relating to the Services, your Account, or these Terms, even if advised of the possibility of such damages.

16.2  To the fullest extent permitted by law, Terminal 3’s total aggregate liability to you for all claims arising out of or relating to the Services, your Account, or these Terms, on any basis, will not exceed the greater of (a) HK$1,000 or (b) the total amount, if any, received by Terminal 3 from or in connection with you in the twelve (12) months before the event giving rise to the claim.

16.3  Nothing in these Terms excludes or limits our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be excluded or limited. The exclusions and limitations in this Section 16 apply only to the maximum extent permitted by law and are subject to Sections 19 and 20.

17.1  To the extent permitted by law, you agree to indemnify and hold harmless Terminal 3 HK Limited and its affiliates, officers, directors, agents, and employees from and against any third-party claim, and any resulting loss, liability, damage, or reasonable expense (including reasonable legal fees), to the extent arising out of: (a) information or identity data you provide that is false or that you did not have the right to provide; (b) your fraud, your unlawful use of the Services, or your violation of the rights of a third party; or (c) your breach of these Terms.

17.2  This Section 17 does not apply to the extent a claim arises from Terminal 3’s own breach, negligence, or wrongful act, and it is subject to and limited by your mandatory consumer rights under Section 19. We will use reasonable efforts to notify you of any claim subject to this Section and may, at our option, assume the defense and control of such claim.

18.1  We reserve the right to change, revise, update, suspend, discontinue, or otherwise modify the Services at any time, and to remove or change Content, without notice. We have no obligation to update any information on the Services.

18.2  We cannot guarantee the Services will be available at all times. We may experience hardware, software, or other problems, or need to perform maintenance, resulting in interruptions, delays, or errors. To the fullest extent permitted by law and subject to Sections 16 and 19, we are not liable for any loss or inconvenience caused by your inability to access or use the Services during any downtime or discontinuance.

19.1  Nothing in these Terms limits or excludes any rights you have under the mandatory consumer-protection or data-protection laws of the place where you live that cannot lawfully be limited or excluded. Where any part of these Terms conflicts with those mandatory rights, those rights prevail and the remainder of these Terms continues to apply.

20.1  We would like the chance to resolve any concern before it becomes a formal dispute. If you have a dispute with us relating to the Services, your Account, or these Terms, please contact us first at legal@terminal3.io, and we will try in good faith to resolve it with you.

20.2  If we cannot resolve the dispute informally, it will be governed by Section 21 (Governing law). Nothing in this Section 20 limits or excludes any right you have to bring proceedings in the courts of, or under the laws of, your country of residence where mandatory consumer-protection law gives you that right, and nothing in this Section 20 requires you to waive any such right.

21.1  These Terms are governed by the laws of Hong Kong, and the courts of Hong Kong have jurisdiction over any dispute arising out of or in connection with them, subject always to Sections 19 and 20.

22.1  We may update these Terms from time to time and will update the “Last Updated” date shown above. For material changes, we will take reasonable steps to bring the change to your attention, which (for Account holders) may include requiring you to accept the updated Terms before you continue to use your Account. Your continued use of the Services after an update takes effect means you accept the updated Terms, subject to your mandatory rights under Section 19.

23.1  Entire agreement. These Terms, together with the Terminal 3 Privacy Policy and any supplemental terms or policies incorporated by reference, constitute the entire agreement between you and Terminal 3 regarding the Services and your Account, and supersede any prior agreement on that subject.

23.2  Severability. If any provision or part of a provision of these Terms is held to be unlawful, void, or unenforceable, that provision or part is severed, and the remaining provisions continue in full force and effect.

23.3  No waiver. Our failure to exercise or enforce any right or provision of these Terms is not a waiver of that right or provision.

23.4  Assignment. You may not assign or transfer these Terms or your Account. We may assign our rights and obligations under these Terms, including in connection with a merger, acquisition, or sale of assets, provided your rights under these Terms are not reduced.

23.5  Force majeure. We will not be liable for any delay or failure to perform caused by events beyond our reasonable control.

23.6  Interpretation. These Terms will not be construed against us merely because we drafted them. No joint venture, partnership, employment, or agency relationship is created between you and us by these Terms or your use of the Services.

24.1  You can contact us about the Services, your Account, your privacy rights, or these Terms at privacy@terminal3.io. For legal notices and disputes, you may contact us at legal@terminal3.io.

24.2  These Terms are between you and Terminal 3 HK Limited.