Privacy Policy
This Privacy Policy explains how [COMPANY NAME] ("Toka", "we", "us") collects, uses, shares and protects personal data when you visit our website, join our early access list or use the Toka virtual card (the "Services").
1. Who we are
The data controller is [COMPANY NAME], registered in [JURISDICTION] under number [NUMBER], with its registered address at [ADDRESS]. You can contact us at [privacy@yourdomain.com].
2. Data we collect
• Data you give us: email address, preferred coin and network, messages you send to support.
• Account and card data: card balance, transaction history, top-up and wallet addresses, card status.
• Technical data: IP address, device and browser type, language, time zone, approximate location derived from your IP address or browser settings, cookies and similar identifiers.
• Where required by law or our issuing partner: additional identification information, which we only request when strictly necessary.
3. Why we use your data
• To create your account, issue and operate your virtual card (performance of a contract).
• To manage the early access list and the welcome bonus program (performance of a contract and our legitimate interest).
• To prevent fraud, abuse, money laundering and terrorist financing (legal obligation and legitimate interest).
• To show the website in your language and improve our Services (legitimate interest).
• To send you product news and offers, where you have agreed (consent, which you can withdraw at any time).
4. Language and location detection
Our website automatically selects English or Spanish based on your browser language and time zone. This happens in your browser. Your language choice may be stored locally on your device so the website remembers it. We do not use this to track your precise location.
5. Who we share data with
We share personal data only as needed with: our card issuing partner [ISSUER NAME] and the card network [VISA / MASTERCARD]; payment processors and blockchain service providers; hosting, email and analytics providers; professional advisers; and authorities where we are legally required to do so. We do not sell your personal data.
6. International transfers
Our service providers may process data outside your country. Where this happens, we use appropriate safeguards required by applicable law, such as standard contractual clauses.
7. How long we keep data
We keep personal data for as long as your account is active and afterwards for as long as needed to meet legal, accounting and anti-money laundering obligations, normally [5] years after the end of our relationship. Early access list data is deleted [12] months after the list closes if you do not open an account.
8. Your rights
Depending on your country, you may have the right to access, correct, delete or export your data, to object to or restrict processing, and to withdraw consent. To exercise your rights, write to [privacy@yourdomain.com]. You may also complain to your local data protection authority.
9. Cookies
We use essential cookies to make the website work and, with your consent where required, analytics cookies to understand how the website is used. You can control cookies in your browser settings.
10. Security
We use encryption, access controls and other technical and organisational measures to protect your data. No method of transmission over the internet is completely secure, but we work to protect your information.
11. Children
The Services are not intended for anyone under 18 years of age. We do not knowingly collect data from minors.
12. Changes
We may update this Privacy Policy. We will post the new version on this page and, for important changes, notify you by email.
Terms of Use
These Terms of Use govern your use of the Toka website and the Toka virtual card. By joining the early access list, creating an account or using the card, you agree to these Terms. Please read them carefully.
1. About Toka
Toka is a brand operated by [COMPANY NAME] ([JURISDICTION]). The Toka card is a virtual prepaid card issued by [ISSUER NAME] under a license from [VISA / MASTERCARD]. Toka is not a bank, and card balances are not bank deposits.
2. Eligibility
You must be at least 18 years old, have full legal capacity and not be resident in a restricted jurisdiction. Restricted jurisdictions include countries subject to international sanctions and [LIST OF RESTRICTED COUNTRIES]. We may refuse or close an account at our discretion where required by law or by our partners.
3. Your account
You register with your email address. You are responsible for keeping your login details secure and for all activity on your account. Tell us immediately at [support@yourdomain.com] if you suspect unauthorised access.
4. Verification
Toka does not require standard identity verification (KYC) to open an account. However, we or our issuing partner may request information or documents where required by applicable law, to prevent fraud, or if unusual activity is detected. If you do not provide it, we may limit or suspend your card.
5. Top-ups
You can top up your balance with USDT, USDC, BTC, ETH and SOL on the supported networks: TRON (TRC-20), Ethereum (ERC-20), Solana and BNB Smart Chain (BEP-20). Crypto is converted to the card currency [USD] at the rate shown at the time of top-up. Always check the coin and network before sending: funds sent to the wrong address or network may be lost permanently and cannot be recovered by Toka.
6. Fees
Card issuance is free. A fee of 1–2% of each purchase amount applies depending on your plan (Standard 2%, Gold 1.5%, Black 1%). Other fees may apply, including currency conversion of [X]% and [OTHER FEES]. Blockchain network fees are set by the network. The current fee schedule is always available on our website and in your account.
7. Using the card
You can use the card online, for subscriptions, and in stores through Apple Pay and Google Pay, wherever [VISA / MASTERCARD] is accepted, within your plan limits. Merchants decide whether to accept a payment. You must not use the card for illegal goods or services, gambling where prohibited, or any activity that breaches these Terms or applicable law.
8. Limits
Spending and top-up limits depend on your plan and are shown in your account. We may change limits for security, legal or risk reasons.
9. Refunds and disputes
Merchant refunds are credited to your card balance. If you do not recognise a transaction, contact us within [60] days. We will investigate with our issuing partner under the card network rules.
10. Withdrawal of balance
[YOUR POLICY: describe whether and how unused balance can be withdrawn back to crypto, and any applicable fees.]
11. Suspension and closing
You may close your account at any time. We may suspend or close your account or card if required by law, if we suspect fraud, money laundering or misuse, or if you breach these Terms. Where allowed, we will return any remaining eligible balance in line with our withdrawal policy.
12. Liability
To the extent permitted by law, Toka is not liable for losses caused by blockchain network failures, incorrect transfers made by you, merchant actions, crypto price movements, or events beyond our reasonable control. Nothing in these Terms limits liability that cannot be limited by law.
13. Changes to these Terms
We may update these Terms. We will notify you of important changes at least [30] days in advance by email or in your account. If you continue to use the Services after the changes take effect, you accept the updated Terms.
14. Governing law
These Terms are governed by the laws of [JURISDICTION]. Disputes will be resolved by the courts of [CITY / JURISDICTION], unless mandatory consumer protection laws in your country provide otherwise.
Welcome Bonus Rules: up to $500
These rules explain how the Toka welcome bonus for new users works. The promotion is organised by [COMPANY NAME]. By taking part, you accept these rules and the Terms of Use.
1. Promotion period
The promotion runs from [START DATE] until [END DATE]. Every new user who meets the conditions below during this period can receive the bonus.
2. Who can take part
The promotion is open to new users aged 18 or older who are not resident in a restricted jurisdiction, who registered or joined the waitlist during the promotion period, and who issue their first Toka card within [NUMBER] days of registration. Only one bonus is allowed per person, device, email and payment source.
3. Bonus amount
Eligible participants receive a welcome balance of up to $500. The exact amount depends on [YOUR CONDITION, for example: the amount of the first top-up, a tiered table, or a random draw]. [INSERT TABLE OR METHOD, e.g. top-up of $50 = $X bonus; top-up of $500 = $Y bonus.] Not every participant will receive the maximum amount.
4. How the bonus is credited
The bonus is credited to your Toka card balance after your card is issued and [ANY ADDITIONAL CONDITION, e.g. first top-up is confirmed], normally within [NUMBER] hours. You will see the credited amount in your account.
5. Using the bonus
[YOUR POLICY: e.g. The bonus can be spent on card purchases. The bonus cannot be withdrawn to crypto until you have made purchases totalling $X, and it expires if not used within X days.]
6. Abuse and fraud
We may refuse, cancel or reclaim a bonus if we detect multiple accounts, fake or temporary email addresses, automated sign-ups, use of VPNs to bypass restrictions, chargeback abuse or any other attempt to abuse the promotion.
7. Changes and ending the promotion
We may change or end the promotion early if required by law, by our partners, or due to abuse, with notice on this page. Bonuses already credited in line with these rules will not be affected.
8. Taxes
You are responsible for any taxes that may apply to the bonus in your country.
9. Contact
Questions about the promotion: [support@yourdomain.com].
Risk Disclosure & AML Policy
Please read this disclosure before using Toka. It explains the main risks of crypto assets and how we work to prevent financial crime.
1. Crypto price risk
Crypto assets are volatile. Their value can fall quickly and significantly. When you top up, your crypto is converted at the rate at that time, and the card balance is not exposed to later price movements, but any crypto you hold elsewhere remains exposed.
2. Blockchain and transfer risk
Blockchain transactions are irreversible. Sending funds to a wrong address, on an unsupported network or with an incorrect memo may result in permanent loss. Network congestion can delay top-ups and increase network fees.
3. Not a bank deposit
Your card balance is not a bank deposit and is not covered by deposit guarantee schemes. Funds are held by our issuing partner [ISSUER NAME] under its regulatory framework.
4. Regulatory risk
Rules on crypto assets and payment cards change across Asia and Latin America. New rules may require us to change, restrict or stop parts of the Services in some countries.
5. Stablecoin risk
Stablecoins such as USDT and USDC aim to keep a stable value but may lose their peg to the US dollar.
6. Anti-money laundering
Toka and its partners comply with applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws. We monitor transactions and screen wallet addresses against sanctions lists and known illicit sources. We may delay, block or report transactions that appear suspicious, and request additional information.
7. Sanctions
The Services may not be used by persons or entities subject to sanctions, or in sanctioned jurisdictions. We will block any such activity.
8. Prohibited use
You must not use Toka for fraud, money laundering, terrorist financing, illegal goods or services, or to avoid sanctions or legal obligations. Violations lead to immediate account closure and may be reported to authorities.
9. Your responsibility
Only use funds you can afford to lose exposure on, keep your account secure, and never share your login codes with anyone. Toka staff will never ask for your password or one-time codes.
These documents are a template prepared for the Toka website. Text in [BRACKETS] must be completed, and all documents must be reviewed by a qualified lawyer in your jurisdiction and approved by your card issuing partner before publication.