Effective 23 July 2026.
These terms form an agreement between you and Tengo's operating entity, Novastra Digital Ireland Limited (the "Company"). By creating an account or using Tengo, you agree to them. Please also read our Risk disclosure and Privacy notice, which are part of these terms.
Tengo is a technology product: software that lets you hold assets in on-chain accounts you control and spend against them with a payment card. Tengo is not a bank, a custodian, a money-services business, an e-money institution, or an investment adviser, and nothing in the product is investment advice or a recommendation. We do not hold your funds and we do not take deposits.
At launch, Tengo is available to residents of the European Economic Area who are at least 18 years old and who complete identity verification (KYC). You may not use Tengo if you are a sanctioned person, are acting for a sanctioned person, or are located in a jurisdiction where Tengo or the underlying assets are not offered — see the Risk disclosure for the current exclusions (the United States is excluded without exception). Card issuance and identity verification are also subject to the issuer's own eligibility rules.
The Tengo card is issued through Gnosis Pay and its regulated partner (Monavate) pursuant to a licence from Visa. Tengo is not the card issuer. Card issuance is subject to the issuer's eligibility rules and identity verification, and the issuer's cardholder terms apply alongside these terms. "Visa" and "Robinhood" are trademarks of their respective owners; Tengo is an independent product and is not affiliated with, endorsed by, or sponsored by Visa Inc. or Robinhood Markets, Inc.
Your assets sit in on-chain accounts controlled by your keys. You can export your keys at any time. We cannot move your funds out of your accounts: the agent's on-chain permissions let it fund your card and manage positions inside your own account, and never let it withdraw your assets to anyone else. Because your accounts are self-custodial, we cannot recover keys you lose or reverse transactions you authorise — export and store your keys safely.
When you spend against your portfolio, you deposit assets and set a limit for how much may be drawn against them. Within that limit, Tengo's agent borrows a stablecoin against your deposited assets through an on-chain lending market (Morpho) on your behalf, and uses it to fund your card. Your assets are pledged as collateral, not sold. The agent can top up and repay to help manage the position's health, but this is automation, not a guarantee (see section 6). The agent's authority is bounded by on-chain permission contracts you can inspect, and you can end it at any time by repaying and withdrawing.
Whether this activity constitutes regulated consumer credit in your country, and any pre-contractual disclosures that follow from that, are being confirmed with counsel (to be confirmed).
Borrowing against your collateral accrues interest at the on-chain market rate, which is variable and shown in the app before you borrow. If the value of your collateral falls far enough relative to what you owe, part of it can be sold (liquidated) to repay the debt — potentially at a loss, at a bad moment, and with a liquidation penalty. Automation may fail to prevent this. You are responsible for monitoring your positions. This is not a bank deposit and is not protected by any deposit-guarantee or investor-compensation scheme. See the Risk disclosure.
Tengo may charge fees for its service; where it does, the app shows the current fee before you act. You may also incur third-party costs outside Tengo's control — issuer and card network fees, on-chain transaction (gas) fees, foreign-exchange spreads, and interest on borrowing. The full fee schedule is being finalised (to be confirmed).
You agree to give accurate information, to safeguard your keys and credentials, to use Tengo only for lawful purposes, and to keep your contact details current. You are responsible for any taxes that apply to your activity. You are responsible for transactions you or your agent authorise from your account.
You must not use Tengo for any illegal activity, fraud, money laundering, terrorist financing, or dealings with sanctioned persons or jurisdictions; to circumvent geographic restrictions or identity verification; to abuse, overload, or interfere with the service or the agent; or to reverse-engineer the service in order to harm it or other users. We may refuse or reverse activity that breaches this section where we are able to.
We may add, change, suspend, or discontinue features, and we may suspend or terminate your access where required by law, to manage risk, or where you materially breach these terms. Because your accounts are self-custodial, you can stop using Tengo and repay and withdraw your assets at any time, and you keep control of your on-chain assets even if your access to the Tengo app ends.
The service is provided "as is" and "as available". We do not warrant that it will be uninterrupted or error-free. On-chain protocols, stablecoins, oracles, the card issuer, and other third parties are outside our control, and their failure can cause loss. Nothing in the product is investment, legal, or tax advice.
To the fullest extent permitted by law, Tengo is not liable for indirect or consequential loss, or for loss arising from on-chain protocol failure, third-party services, market movements, liquidation, or your loss of keys. Any aggregate liability is limited (cap to be confirmed). Nothing in these terms limits or excludes liability that cannot be limited or excluded under applicable law — including liability for death or personal injury caused by negligence, for fraud, or your mandatory rights as a consumer in the EEA.
These terms are governed by the laws of Ireland, without prejudice to the mandatory consumer-protection rights of the country of your habitual residence (Rome I, Art. 6). Nothing here removes your right to bring proceedings in your local courts where the law gives you that right. EEA consumers may also use the European Commission's Online Dispute Resolution platform. For complaints, contact us first at the address below.
We may update these terms. We will make the current version available here and, for material changes, give reasonable advance notice. If you continue to use Tengo after a change takes effect, you accept the updated terms; if you do not agree, you can stop and withdraw your assets.
We handle personal data as described in our Privacy notice, which forms part of these terms. The data controller is the Company, Novastra Digital Ireland Limited.
16.1 The operating company (EEA). Tengo is operated by Novastra Digital Ireland Limited, a private company limited by shares incorporated under the laws of Ireland, registered with the Companies Registration Office (CRO) under company number 88541, having its registered office at 25 North Wall Quay, Dublin 1, D01 H104, Ireland (the "Company"). VAT No. IE 885014AA. Legal contact: legal@novastra.ie; consumer support: support@novastra.ie.
16.2 The holding company. Novastra Holding B.V., a private limited liability company (besloten vennootschap) incorporated under the laws of the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 2074, having its registered office at Herengracht 450, 1017 CA Amsterdam, The Netherlands (the "Parent").
16.3 Corporate relationship. The Parent holds 100% of the issued share capital of the Company. The Parent and the Company are parties to an Intercompany Services Agreement dated 1 March 2026, under which the Parent provides intellectual-property licensing to the Company on arm's-length terms. The Company acts as data controller under the GDPR; processing by the Parent is governed by the Intra-Group Data Processing Agreement dated 1 March 2026.