Terwilliger
TERMS OF SERVICE
PLEASE READ THIS DISCLAIMER CAREFULLY BEFORE USING OUR SERVICES

Last updated: 02/03/2026

These Terms of Service (“Terms”) govern your access to and use of the website https://terwilliger.io (“Website”) operated by Terwilliger s.r.o., a company incorporated in the Czech Republic (registration number 22293191), with registered office at Děčínská 552/1, Střížkov, 180 00 Praha 8, Czech Republic (“Terwilliger”, “we”, “our”, “us”).

By accessing or browsing this Website, you confirm that you have read, understood, and agree to these Terms.

This Website is informational only. Terwilliger s.r.o. does not provide any services to the public.

1. PURPOSE OF THE WEBSITE

The Website describes Terwilliger s.r.o.’s corporate activity as a proprietary trader on third-party P2P platforms using only its own capital.

The Website does not:

  • offer crypto-asset services;
  • onboard users;
  • provide accounts or balances;
  • execute orders for users;
  • enable buying or selling of virtual assets;
  • provide custody, exchange, or transfer services;
  • provide any regulated services under MiCA, PSD2, or other financial-services laws.

Nothing on this Website constitutes an offer, solicitation, or advertisement of services.

2. DEFINITIONS

Website — The informational website operated by Terwilliger.

Proprietary Trading — Virtual-asset trading conducted exclusively using Terwilliger’s own capital and not on behalf of any third party.

Virtual Asset — A digital representation of value (e.g., BTC, ETH, USDT) traded by Terwilliger solely for its own account.

Third-Party Platforms — Independent exchanges or P2P marketplaces where Terwilliger conducts trades.

Counterparty — A person or entity with whom Terwilliger transacts on a third-party platform. Counterparties are not “clients” of Terwilliger.

KYC (Know-Your-Counterparty) — Information Terwilliger may request from a counterparty solely for AML/CFT purposes.

3. REGULATORY STATUS

Terwilliger s.r.o. operates exclusively as a proprietary P2P liquidity provider.

We do not provide services to the public and do not act as:

  • an exchange;
  • a custodian;
  • an intermediary;
  • an investment service provider;
  • a payment institution;
  • an on-ramp or off-ramp provider.

Terwilliger does not:

  • execute orders on behalf of clients;
  • hold client assets;
  • hold fiat or virtual assets for others;
  • accept deposits or withdrawals;
  • perform swaps or conversions for others.

Terwilliger is subject to AML/CFT obligations under Czech and EU law strictly in relation to its own proprietary trading activity.

4. AML / CFT COMPLIANCE AND KYC OF COUNTERPARTIES

Although Terwilliger does not provide customer services, AML/CFT laws require due diligence on counterparties involved in trades on third-party platforms.

Accordingly, Terwilliger may:

  • assess AML/CFT risks associated with a counterparty;
  • request identity verification or information confirming the legitimacy of a transaction;
  • request origin-of-funds documentation;
  • decline a trade or cancel an order if information is not provided or appears suspicious;
  • file suspicious-activity reports with competent authorities when required.

These actions:

  • do not establish a service relationship;
  • do not convert the counterparty into a “client”;
  • are performed strictly for legal AML/CFT compliance.

Terwilliger does not create accounts, maintain balances, or provide onboarding on this Website.

5. NO SERVICES PROVIDED TO USERS

You acknowledge and agree that Terwilliger:

  • does not offer any services via this Website;
  • does not interact with users as customers;
  • does not manage assets or transactions for users;
  • does not provide investment, legal, or tax advice;
  • is not responsible for any actions taken by users on external P2P platforms.

Any references to trading activity relate solely to Terwilliger’s internal corporate operations.

6. THIRD-PARTY PLATFORMS

Terwilliger conducts all trading exclusively on external P2P platforms that:

  • are operated by independent entities;
  • have their own terms, fees, and compliance rules;
  • are responsible for onboarding and verifying their own users.

Terwilliger has no control over:

  • the availability or reliability of these platforms;
  • deposit/withdrawal systems;
  • user interfaces or dispute processes;
  • blockchain network conditions.

Your interactions with third-party platforms are solely between you and those platforms.

7. PROHIBITED USE OF THE WEBSITE

You must not use the Website:

  • to misrepresent that Terwilliger provides services;
  • to impersonate Terwilliger on any platform;
  • to engage in fraud, scams, or solicitation;
  • to violate AML/CFT laws;
  • to contact users claiming affiliation with Terwilliger;
  • to imply that KYC requests made for AML reasons create a service relationship.

Any misuse of the Website may result in reporting to law enforcement.

8. INTELLECTUAL PROPERTY

All content on the Website—including text, branding, logos, and design—is the property of Terwilliger or its licensors.

You may not copy, modify, distribute, or reproduce it without written permission.

9. PRIVACY AND DATA PROTECTION

The Website does not collect personal data unless you voluntarily contact us.

Any KYC/AML data collected from a counterparty during P2P trades is:

  • collected only when legally required;
  • used exclusively for AML/CFT compliance;
  • stored securely and retained for statutory periods;
  • never used for marketing or profiling;
  • not associated with any service offering.

Terwilliger complies with the EU General Data Protection Regulation (GDPR).

10. DISCLAIMER OF WARRANTIES

The Website is provided “as is” and “as available” without warranties of any kind.

Terwilliger makes no guarantee that:

  • the Website will be uninterrupted or error-free;
  • the information will be complete or up to date;
  • external platforms will operate correctly or reliably.
11. LIMITATION OF LIABILITY

To the maximum extent permitted by Czech law, Terwilliger shall not be liable for:

  • indirect, incidental, special, punitive, or consequential damages;
  • lost profits or opportunities;
  • reliance on Website information;
  • actions taken on third-party platforms;
  • delays, outages, or blockchain-network issues.

Your sole remedy is to discontinue use of the Website.

12. AMENDMENTS TO THE TERMS

Terwilliger may amend these Terms at any time.

The most recent version will be posted on this Website.

Continued use of the Website constitutes acceptance of any new Terms.

13. GOVERNING LAW AND JURISDICTION

These Terms are governed by the laws of the Czech Republic.

Any disputes shall be resolved exclusively by the courts of the Czech Republic, Prague.

14. CONTACT INFORMATION

Email: info@terwilliger.io

Website: https://terwilliger.io

ANNEX 1 — RISK DISCLOSURE

Virtual-asset trading involves significant risks, including:

  • substantial price volatility;
  • loss of value;
  • regulatory changes affecting trading conditions;
  • technical failures, cyber-attacks, or blockchain congestion;
  • delays or failures of third-party platforms.

The information on this Website is not investment advice.

ANNEX 2 — PROHIBITED MISUSE

You may not use the Website in connection with:

  • illegal activities;
  • impersonation of Terwilliger;
  • fraud, scams, or solicitation;
  • money laundering or terrorist financing;
  • misrepresentation of Terwilliger’s business model;
  • attempts to obtain unauthorized data or access.

© Terwilliger s.r.o. – All rights reserved.