Terms of Use

Last updated: 23 September 2026

These Terms of Use (“Terms”) are a legal agreement between you and GBA SERVICE GROUP LIMITED (“we”, “us”, “our”) governing your use of the Rock Pay mobile application and related services (the “Service”). Please read them carefully.

1. About these Terms

By creating an account or using the Service, you agree to these Terms and to our Privacy Policy. If you do not agree, do not use the Service.

2. The Service

Rock Pay lets you hold USDT (Tether) on the TRON network (the “TRC20” standard), receive USDT to a deposit address we assign to you, and send USDT to other TRC20 addresses. The Service supports only USDT on the TRON network. We may add, change or remove features at any time.

We are not a bank and do not accept deposits of fiat currency. Balances held through the Service are not bank deposits and are not protected by any deposit protection or insurance scheme. We do not provide investment, financial, legal or tax advice.

3. Eligibility

To use the Service you must:

• be at least 18 years old and have full legal capacity to enter into these Terms;
• use the Service only for yourself, and not on behalf of another person or business;
• not be located in, or a resident or national of, any country or territory where use of the Service is prohibited, or subject to comprehensive sanctions; and
• not be named on, or owned or controlled by anyone named on, any sanctions list maintained by the United Nations, Hong Kong, the United States, the European Union, the United Kingdom or any other relevant authority.

We may refuse to open an account or provide the Service in any jurisdiction at our discretion.

4. Your account and security

You sign in with your email address and a one-time code. You are responsible for keeping your email account, device and app passcode secure, and for all activity under your account. You must give us accurate information and keep it up to date. Tell us immediately at info@gbagroupservices.com if you suspect unauthorised access. You may have only one account.

5. Identity verification

We are required to verify the identity of our users. Before you can deposit or send USDT, you must successfully complete identity verification, which includes providing a valid government-issued identity document, a selfie and a liveness check through our verification provider. We may ask for additional information or documents at any time, including information about the source of your funds. We may decline or revoke verification at our discretion, and we may not be able to tell you the reason.

6. Your balance

USDT you deposit is held by us on your behalf, and your balance in the app reflects the amount of USDT we hold for you. You remain the owner of the USDT credited to your balance. We may hold users’ USDT together in wallets we control and move it between our wallets for operational and security reasons, while keeping records of each user’s balance. You do not receive a private key or seed phrase, and you can move your USDT only through the Service.

7. Deposits

• Send only USDT on the TRON (TRC20) network to your Rock Pay deposit address. Tokens or coins sent on any other network, or any asset other than USDT, may be permanently lost, and we are not obliged to recover them.
• Deposits are credited after they are confirmed on the blockchain; the time this takes depends on the network.
• We may delay, hold or return a deposit where required by law or where we suspect fraud or other unlawful activity.

8. Transfers

• You can send USDT to any valid TRC20 address, subject to minimum amounts, limits and checks that we may apply.
• You are responsible for entering the correct destination address and amount. Before you confirm, the app shows the network fee and the total that will be deducted.
• Blockchain transactions are irreversible. Once a transfer is broadcast to the network, we cannot cancel, reverse or recover it. We are not responsible for USDT sent to a wrong or unintended address.
• We may delay, refuse or block a transfer if we are required to by law, if the destination is associated with sanctions, fraud or other illegal activity, or if we suspect your account has been compromised.

9. Fees

Sending USDT involves a fee, which covers the cost of the TRON network and may include a service fee. The applicable fee is shown in the app before you confirm each transfer and is deducted from your balance. We may change our fees at any time; changes apply only to transactions made after the change is shown in the app.

10. Prohibited use

You must not use the Service to:

• break any law or regulation, including laws on money laundering, terrorist financing, sanctions, fraud, gambling or tax evasion;
• send or receive proceeds of crime, or funds from or to anyone subject to sanctions;
• act on behalf of another person, or let anyone else use your account;
• provide false or misleading information, or use another person’s identity;
• interfere with, attack, reverse engineer, or gain unauthorised access to the Service or its systems; or
• use the Service in any way that could harm us, our users or third parties.

11. Risks

Using digital assets involves risk. You understand and accept that:

• USDT is issued by a third party (Tether), not by us. Its value may not always equal one US dollar, and we are not responsible for the issuer, its reserves or its actions, including freezing tokens.
• The TRON network is operated by third parties. Network congestion, failures, forks or attacks may delay or prevent transactions or change fees.
• Laws governing digital assets are changing and may affect our ability to provide the Service in your country.
• You are responsible for any taxes that apply to your use of the Service.

12. Suspension and closure

We may suspend, restrict or close your account, or freeze your balance, if: we are required to by law or by an authority; you breach these Terms; we suspect fraud, unauthorised access or illegal activity; you do not complete verification; or we stop offering the Service. Where the law allows, we will tell you and explain how you can withdraw any balance that is not subject to a legal restriction.

You can close your account at any time from Settings → Delete account in the app, or as described on our account deletion page. Please send your remaining balance to another wallet before you delete your account — deletion is permanent, and any balance left in the account may not be recoverable.

13. Intellectual property

The Service, including the Rock Pay name, logo, app and website, is owned by us or our licensors. We grant you a personal, limited, non-exclusive, non-transferable and revocable licence to use the app on devices you own or control, for its intended purpose and in line with these Terms and the rules of the app store you downloaded it from.

14. Disclaimers

To the fullest extent permitted by law, the Service is provided “as is” and “as available”, without warranties of any kind, whether express or implied, including warranties of merchantability, fitness for a particular purpose and non-infringement. We do not guarantee that the Service will be uninterrupted, error-free or secure, or that any blockchain transaction will be completed within a certain time.

15. Limitation of liability

To the fullest extent permitted by law: (a) we will not be liable for any indirect, incidental, special, consequential or punitive loss, or for any loss of profits, revenue, data or goodwill; (b) we will not be liable for losses caused by events outside our reasonable control, including failures of the blockchain, third-party services or your device, or by your own mistakes, such as sending to a wrong address or network; and (c) our total liability to you for all claims relating to the Service will not exceed the greater of the fees you paid us in the 12 months before the claim arose and USD 100. Nothing in these Terms limits liability that cannot be limited under applicable law, including liability for fraud or for death or personal injury caused by negligence.

16. Indemnity

You agree to compensate us for any claims, losses, liabilities and reasonable costs (including legal fees) arising from your breach of these Terms, your misuse of the Service or your violation of any law or the rights of a third party.

17. Changes to these Terms

We may update these Terms from time to time. We will post the new version on this page and change the “Last updated” date. If the changes are significant, we will notify you in the app or by email before they take effect. If you continue to use the Service after the changes take effect, you accept the updated Terms. If you do not agree, you must stop using the Service and close your account.

18. Governing law and disputes

These Terms are governed by the laws of the Hong Kong Special Administrative Region. Before starting any formal proceedings, please contact us at info@gbagroupservices.com so we can try to resolve the issue. If we cannot resolve it within 60 days, the courts of Hong Kong will have exclusive jurisdiction, unless mandatory consumer protection laws in your country of residence give you the right to bring proceedings there.

19. General

These Terms and our Privacy Policy are the entire agreement between you and us about the Service. If any part of these Terms is found unenforceable, the rest remains in effect. If we do not enforce a right, we do not give it up. You may not transfer your rights under these Terms without our consent; we may transfer ours to an affiliate or successor. These Terms are written in English; any translation is for convenience only.

If you downloaded the app from Apple’s App Store, you also acknowledge that these Terms are between you and us, not Apple; Apple is not responsible for the app or its content, has no obligation to provide maintenance or support, and is not responsible for any claims relating to the app. Apple and its subsidiaries are third-party beneficiaries of these Terms and may enforce them against you.

20. Contact us