Arc Onramp Terms Of Use

Last Updated:
September 16, 2026

These Arc Onramp Terms of Use (these “Terms”) constitute a binding legal agreement between you (“you” or “your”) and Circle Technology Services, LLC (on behalf of itself and any other affiliates to the extent relevant) (“Circle”, “we”, “our” or “us”) governing your access to and use of Arc Onramp.

Arc Onramp is a technology interface enabling access to services that allow you to acquire digital assets using fiat currency and to complete identity verification, onboarding and related compliance checks (collectively, the “Third-Party Onramp Services”). The Third-Party Onramp Services are offered by independent third-party providers (each, an “Onramp Provider”) and not by Circle. Arc Onramp may be presented to you within a Circle interface or embedded within an application, website or other interface operated by a third-party developer (each, a “Developer”) that has integrated the Circle onramp kit. These Terms apply to your use of Arc Onramp however you reach it.

If you are an individual accessing or using Arc Onramp on behalf of, or for the benefit of, any corporation, partnership or other entity with which you are associated (an “Organization”), then you are agreeing to these Terms on behalf of yourself and such Organization, and you represent and warrant that you have the legal authority to bind such Organization to these Terms.

By clicking or tapping to accept these Terms, or by otherwise accessing or using Arc Onramp, you agree that you have read, understood and accept (i) all of the terms and conditions contained in these Terms, (ii) with respect to actions taken on the Arc blockchain, the Arc Network Terms of Use, (iii) the Circle Privacy Policy , (iv) the Circle Cookie Policy , (v) the Circle E-Sign Consent Policy, and (vi) any applicable additional terms or policies that are presented, linked, or otherwise made available to you through Arc Onramp, whether provided by Circle or a third party (“Additional Terms”) . If you do not accept these Terms, you may not access or use Arc Onramp.

Arc Onramp is separate from, and does not give you access to, the Arc Portal. If you access Arc Onramp through the Arc Portal, the Arc Portal Terms of Use also apply to your use of the Arc Portal. 

PLEASE BE AWARE THAT SECTION 20 CONTAINS PROVISIONS GOVERNING HOW TO RESOLVE DISPUTES BETWEEN YOU AND CIRCLE. AMONG OTHER THINGS, SECTION 20 INCLUDES AN AGREEMENT TO ARBITRATE WHICH REQUIRES, WITH LIMITED EXCEPTIONS, THAT ALL DISPUTES BETWEEN YOU AND US SHALL BE RESOLVED BY BINDING AND FINAL ARBITRATION. SECTION 20 ALSO CONTAINS A CLASS ACTION AND JURY TRIAL WAIVER. PLEASE READ SECTION 20 CAREFULLY.

UNLESS YOU OPT OUT OF THE AGREEMENT TO ARBITRATE WITHIN THIRTY (30) DAYS: (a) YOU WILL ONLY BE PERMITTED TO PURSUE DISPUTES OR CLAIMS AND SEEK RELIEF AGAINST US ON AN INDIVIDUAL BASIS, NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS OR REPRESENTATIVE ACTION OR PROCEEDING, AND YOU WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION; AND (b) YOU ARE WAIVING YOUR RIGHT TO PURSUE DISPUTES OR CLAIMS AND SEEK RELIEF IN A COURT OF LAW AND TO HAVE A JURY TRIAL. 

  1. Arc Onramp
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    1. Arc Onramp is the technology, application programming interfaces and user interfaces through which information is transmitted between you, the applicable Onramp Provider and that Onramp Provider’s identity verification vendor.  Arc Onramp currently supports the purchase of digital assets using fiat currency. It does not currently support the conversion of digital assets into fiat currency, and Circle has no obligation to make any such functionality available. Circle is not responsible for any losses, costs or damages arising from the absence of any functionality, or from any change to the functionality available through Arc Onramp.
    2. Arc Onramp may be made available in whole or in part, and as separate components, and Circle may add, modify, suspend, restrict, condition or discontinue Arc Onramp, any component of it, any Onramp Provider, any supported digital asset, any supported blockchain or any supported payment method, at any time, in its sole discretion and with or without notice.
    3. Arc Onramp is non-custodial. At no time does Circle hold, control or custody your fiat funds or your digital assets via Arc Onramp.
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  2. Circle’s Role; No Regulated Services
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    1. The Third-Party Onramp Services are provided by the Onramp Providers, not by Circle. Circle does not provide payment processing, fiat currency conversion, money transmission, virtual account or deposit services, identity verification, know-your-customer (“KYC”), know-your-business (“KYB”), anti-money-laundering (“AML”), sanctions screening, transaction monitoring, customer due diligence or any other compliance or regulated financial service via Arc Onramp.
    2. Each Onramp Provider performs its own onboarding, identity verification and compliance checks in its own capacity as the regulated service provider, and makes its own decisions about whether to accept you as its customer, whether to process a transaction, and on what terms. Circle does not make, review, influence, reverse or appeal those decisions.
    3. Nothing in these Terms creates any partnership, joint venture, agency, advisory, fiduciary, employment, brokerage or other similar relationship between you and Circle, and Circle does not undertake to act on your behalf or in your best interests.
    4. Circle is not a party to, and is not responsible for, your agreement with any Onramp Provider, any Developer or any other third party, and is not responsible for the acts, omissions, decisions, fees, exchange rates, processing times, approvals, rejections, suspensions, terminations or performance of any of them.
    5. Circle is not responsible for any third-party content, links or interfaces through which Arc Onramp may be accessed or displayed, and your use of any Developer's interface is governed by that Developer's own terms.
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  3. Eligibility
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    1. By accessing or using Arc Onramp, you represent and warrant that:
      1. you are at least 18 years old and have reached the age of majority in your place of residence;
      2. if you are acting on behalf of an Organization, that Organization is not a charity or other not-for-profit entity, and you are authorized to bind it;
      3. you are located in, and will access Arc Onramp from, a jurisdiction in which Arc Onramp and the applicable Third-Party Onramp Service are then available (the “Supported Jurisdictions”), as set out in the Onramp Provider Schedule;
      4. you are not a Sanctions Target and you are not organized, located or resident in a Restricted Territory;
      5. you will not use Arc Onramp or any Third-Party Onramp Service to benefit or support any Restricted Territory or Sanctions Target; and
      6. all information you provide to Circle, to any Onramp Provider or to any identity verification vendor is true, accurate, current and complete.

For the purposes of these Terms, “Restricted Territory” means a region, territory or country subject to Sanctions; “Sanctions” means any legal requirement imposing sanctions, restrictions or prohibitions that is administered or enforced by the U.S. Government (including the U.S. Department of the Treasury’s Office of Foreign Assets Control, the U.S. Department of Commerce or the U.S. Department of State, and including designation as a “specially designated national” or blocked person), the United Nations Security Council, and all other relevant international sanctions authorities, including any executive orders issued in relation to the imposition of sanctions; and “Sanctions Target” means any person or entity that is: (A) included on any list of designated persons maintained by any governmental, regulatory authority or law enforcement department, court, agency, commission, board, tribunal, crown corporation or other law, rule or regulation making entity pursuant to Sanctions, (B) organized, located or resident in a Restricted Territory, or (C) otherwise the target of any Sanctions such that a person is prohibited from dealing with such person or entity, including as a result of being owned or controlled by any person or persons described in the foregoing subsection (A) or (B).

  1. Availability of Arc Onramp and of any Third-Party Onramp Service varies by jurisdiction, by Onramp Provider and by payment method, and is subject to each Onramp Provider’s own eligibility requirements. The availability of Arc Onramp in your jurisdiction is not a representation that any transaction is lawful, suitable or appropriate for you.
  1. Onramp Providers and Provider Terms
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    1. Your use of a Third-Party Onramp Service is governed by the applicable Onramp Provider’s terms and policies. A list of the then-current Onramp Providers, their respective roles, and their respective terms and policies are set out in the Onramp Provider Schedule attached to these Terms (the “Onramp Provider Schedule”). Circle may update the Onramp Provider Schedule from time to time by posting a revised version, and the then-current version of the Onramp Provider Schedule forms part of these Terms.
    2. Before you can use a Third-Party Onramp Service, you may be required to review and accept the applicable Onramp Provider’s own terms of service, privacy policy and other disclosures, and the terms of one or more of that Onramp Provider’s own service partners (for example, a bank or a custodian). Those terms are agreements between you and the applicable third party.
    3. Circle does not control, operate, endorse, guarantee, audit or verify any Onramp Provider or any Third-Party Onramp Service. The presentation, listing, ordering or default selection of an Onramp Provider within Arc Onramp does not constitute a recommendation, suitability determination or ranking by Circle.
  1. Restricted Use
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    1. You agree to comply with all applicable laws, regulations, sanctions, anti-money-laundering requirements, anti-corruption rules, export controls, tax rules and other legal requirements in connection with your use of Arc Onramp and any Third-Party Onramp Service.
    2. You may not access or use Arc Onramp or any Third-Party Onramp Service to engage in or facilitate unlawful, fraudulent, deceptive, manipulative, abusive, infringing or otherwise prohibited conduct, including money laundering, sanctions evasion, terrorist financing, market manipulation, unauthorized access, malware distribution, interference with systems, or infringement of third-party rights, or in connection with blocked addresses, darknet markets, illegal goods or services, stolen funds, or other prohibited transactions or restricted activities that Circle or an Onramp Provider identifies.
    3. You may not use Arc Onramp on behalf of any other person, provide false or misleading information in any onboarding or verification flow, attempt to circumvent any eligibility, geographic or verification control, or access Arc Onramp by automated means except as expressly permitted by Circle in writing.
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  2. Identity Verification and Onboarding
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    1. To use a Third-Party Onramp Service you will be required to complete identity verification, sanctions screening and other onboarding requirements set by the applicable Onramp Provider.
    2. Identity verification is performed for compliance purposes only. It is not a credit check, a background check or a credit score check, it does not affect your credit or credit score, and a decision not to onboard you is not an adverse action taken by Circle.
    3. An Onramp Provider may approve, decline, delay, suspend, limit or terminate your onboarding or any transaction, and may request additional information or documentation, in each case in its own discretion and in accordance with its own terms and legal obligations.
    4. You will not be given access to a Third-Party Onramp Service before the applicable Onramp Provider has accepted your onboarding.
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  3. Transactions, Quotes and Fees
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    1. Circle currently charges you no fee for access to or use of Arc Onramp. Onramp Providers, payment networks, banks, card issuers and blockchain networks may charge fees, spreads, foreign exchange margins or other costs in connection with a transaction, and those amounts are payable to and determined by those third parties.
    2. Any price, quote, fee, exchange rate, limit, processing time or availability information displayed through Arc Onramp is provided for convenience only, may be supplied by the applicable Onramp Provider or another third party, and may differ from the amounts ultimately charged or delivered.
    3. You are solely responsible for reviewing and authorizing each transaction, including the amount, the payment method, the digital asset, the blockchain network and the destination wallet address, before you confirm it. Circle has no ability to reverse, cancel, recall or recover a transaction or any digital assets.
    4. Transactions may fail, be delayed, be rejected or be reverted, including as a result of an Onramp Provider’s compliance decision, payment network conditions, insufficient funds, blockchain network conditions, smart contract behavior or other reasons outside Circle’s control. You may still incur fees charged by third parties even if a transaction fails, and Circle will not be responsible for those fees.
    5. Any transaction history, status or similar information made available through Arc Onramp is provided for convenience and informational purposes only, may be incomplete or inaccurate, and is not a tax form, statement or report. You are solely responsible for maintaining your own records and for determining, reporting and paying any taxes arising from your use of Arc Onramp.
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  4. Your Information and Privacy
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    1. Your use of the Arc Onramp is subject to the Privacy Policy, Cookie Policy, and any feature-specific privacy disclosures presented in or through the Arc Onramp, each as updated from time to time.
    2. If you access, connect to, interact with, or use a Third-Party Onramp Service, you may provide information directly to that Onramp Provider or authorize Circle to facilitate a connection or interaction with that third party.  Your use of any such third-party service is subject to that third party’s own terms, privacy notices, and practices. 
    3. You acknowledge that Circle may collect, use and disclose and otherwise process information that you provide via Arc Onramp to the extent necessary to operate and improve Arc Onramp, to fulfill its obligations under these Terms, and to comply with applicable law, in each case, in accordance with the Privacy Policy.
    4. You and Circle agree that neither is the data processor of the other party under any applicable Data Protection Law (which means, collectively, all legal requirements that apply to processing of personal data under or in connection with these Terms, including applicable international, national, federal, state, provincial, and local laws, rules, regulations, directives and governmental requirements relating to privacy, data protection, or security), nor are you and us acting together as joint data controllers. You and Circle further agree that no monetary or other valuable consideration is provided to either party in exchange for any personal data and that data sharing conducted pursuant to these Terms does not constitute a sale of personal data under any applicable Data Protection Law.

    5. You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Circle or its service provider, solely for the purposes of identifying you or your wireless device and to prevent fraud. For more information regarding your wireless carrier's use of your personal information, please refer to your wireless carrier's privacy policy
    6. Solely in respect of the transmission of Verification Information, the applicable Onramp Provider determines the purposes and means of processing and Circle acts on its behalf. Circle determines the purposes and means of, and acts independently in respect of, User Information and the information it processes for operating and securing Arc Onramp, authenticating access, preventing fraud, providing support and handling complaints, administering compliance and meeting its own legal and regulatory obligations.  Your use of any such third-party service is subject to that third party’s own terms, privacy notices, and practices. 
    7. You consent to receive communications from Circle in connection with Arc Onramp electronically, including by display in the onramp flow and by email, in accordance with the Circle E-Sign Consent Policy. 
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  5. Suspension and Termination
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    1. Circle may suspend or terminate your access to Arc Onramp (or any part of it) at any time, including where Circle reasonably believes that you have breached these Terms, that your use presents a legal, regulatory, security or fraud risk, or where an Onramp Provider has suspended or terminated your access to its services. Where practicable and not prohibited by law or by a legal, regulatory or security constraint, Circle will notify you of a suspension or termination and, for a breach capable of cure that is not a breach of Section 3 (Eligibility) or Section 5 (Restricted Use), will allow you a reasonable opportunity to cure before terminating.
    2. You may stop using Arc Onramp at any time. Termination of these Terms does not terminate any agreement between you and an Onramp Provider or affect any transaction already submitted.
    3. On termination or suspension: (a) the license and other rights granted under these Terms end; (b) you must immediately stop using Arc Onramp; and (c) the provisions identified in Section 25 survive.
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  6. No Advice; No Recommendation

Information displayed through Arc Onramp, including any price, rate, fee, limit, quote or comparative information, is provided for convenience only. It is not investment advice, financial advice, legal advice, tax advice, a recommendation, a solicitation, a promise of performance or a best-execution undertaking by Circle. Circle does not guarantee that you will receive the best available price, exchange rate, fee level, processing time or outcome. You are responsible for evaluating the available options and determining whether any transaction is appropriate for you.

  1. Assumption of Risk
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    1. You acknowledge and accept the following risks of using Arc Onramp:
      1. digital asset transactions are irreversible, and assets sent to an incorrect, incomplete or incompatible address will be permanently lost;
      2. digital assets are subject to significant price volatility, and their value may fall as well as rise;
      3. you are solely responsible for the security of the wallet and credentials you use, and loss of your private keys will result in the loss of your digital assets;
      4. Arc Onramp, an Onramp Provider, a payment network or an underlying blockchain network may experience cyber-attacks, surges in activity, outages, forks or other operational or technical difficulties that may interrupt, delay or prevent a transaction, and Circle has no ability or obligation to prevent, mitigate or resolve those events;
      5. Circle may, in its sole discretion, add, modify, suspend, or discontinue support for Arc Onramp at any time without notice. Circle will not be liable for any damages, losses, costs, fines, penalties, or expenses of any kind, whether or not reasonably foreseeable, arising out of or relating to any such change, suspension, or discontinuation of support.
      6. smart contracts and blockchain technology are a relatively new and comparatively untested technology, and further risks may materialize that Circle cannot anticipate; and
      7. regulatory action could adversely affect the availability of Arc Onramp, any Third-Party Onramp Service, any digital asset or any blockchain network.
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  2. Intellectual Property
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    1. As between you and Circle, Circle owns all right, title and interest in and to Arc Onramp, including its software, content, design, user interfaces, documentation, trademarks, logos and other intellectual property rights, together with any derivative works or enhancements thereof.
    2. Subject to your continued compliance with these Terms, Circle grants you a limited, revocable, non-exclusive, non-transferable, non-sublicensable right to access and use Arc Onramp for its intended purpose.
    3. You may not, and may not permit any third party to, copy, modify, reverse engineer, decompile, disassemble, scrape, mirror, frame, lease, sell, sublicense, redistribute or create derivative works from Arc Onramp, or access Arc Onramp in order to build a similar or competing product or service.
    4. If you submit comments, suggestions, ideas or other feedback regarding Arc Onramp, you agree that Circle may perpetually and freely use that feedback, in any manner and for any purpose, without restriction, attribution, compensation or obligation to you.
       
  3. Force Majeure
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    1. Circle’s obligations under these Terms may be suspended, in whole or in part, to the extent Circle is prevented or delayed from performing by any event or circumstance beyond its reasonable control (a “Force Majeure Event”). Circle will use commercially reasonable efforts to notify you of any Force Majeure Event materially affecting Arc Onramp and may take such actions as it deems appropriate to mitigate its impact. Circle will not be liable for any delay, suspension or failure to perform its obligations under these Terms to the extent resulting from a Force Majeure Event.
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  4. Disclaimer of Warranties
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    1. ARC ONRAMP IS PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT REPRESENTATION, WARRANTY OR CONDITION OF ANY KIND, WHETHER EXPRESS, IMPLIED OR STATUTORY. TO THE FULLEST EXTENT PERMITTED BY LAW, CIRCLE AND ITS SUPPLIERS AND LICENSORS DISCLAIM ALL IMPLIED WARRANTIES, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT.
    2. CIRCLE DOES NOT WARRANT OR GUARANTEE THAT ARC ONRAMP: (A) IS ACCURATE, RELIABLE OR CORRECT; (B) WILL MEET YOUR REQUIREMENTS; (C) WILL BE AVAILABLE AT ANY PARTICULAR TIME OR LOCATION, WILL BE UNINTERRUPTED, WILL BE ERROR-FREE, OR WILL BE WITHOUT DEFECT OR SECURE OR THAT ANY DEFECTS OR ERRORS WILL BE CORRECTED; OR (D) IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. CIRCLE MAKES NO REPRESENTATION OR WARRANTY OF ANY KIND REGARDING ANY ONRAMP PROVIDER, ANY THIRD-PARTY ONRAMP SERVICE, ANY IDENTITY VERIFICATION VENDOR, ANY DEVELOPER OR ANY OTHER THIRD PARTY, OR THEIR RESPECTIVE PRODUCTS, SERVICES, SECURITY, LEGALITY, AVAILABILITY OR PERFORMANCE.
    3. NOTHING IN THESE TERMS EXCLUDES OR LIMITS ANY WARRANTY, CONDITION, RIGHT OR REMEDY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO SOME OR ALL OF THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU.
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  5. Limitation of Liability
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    1. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL CIRCLE BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES, INCLUDING DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES, THAT RESULT FROM THE USE OF, INABILITY TO USE, OR UNAVAILABILITY OF ARC ONRAMP. IN ALL CASES, CIRCLE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE THAT IS NOT REASONABLY FORESEEABLE. UNDER NO CIRCUMSTANCES WILL CIRCLE BE RESPONSIBLE FOR ANY DAMAGE, LOSS, OR INJURY RESULTING FROM HACKING, TAMPERING, OR OTHER UNAUTHORIZED ACCESS OR USE OF ARC ONRAMP, OR THE INFORMATION CONTAINED THEREIN. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CIRCLE ASSUMES NO LIABILITY OR RESPONSIBILITY FOR ANY (I) ERRORS, MISTAKES, OR INACCURACIES OF ARC ONRAMP; (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO OR USE OF ARC ONRAMP; (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION STORED THEREIN; (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM ARC ONRAMP; (V) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT MAY BE TRANSMITTED TO OR THROUGH ARC ONRAMP; AND/OR (VI) ANY ERRORS OR OMISSIONS IN ANY DATA OR FOR ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY DATA POSTED, EMAILED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE THROUGH ARC ONRAMP. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE TOTAL LIABILITY OF CIRCLE IS LIMITED TO $100. THIS LIMITATION OF LIABILITY SECTION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR ANY OTHER BASIS, EVEN IF CIRCLE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.
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  6. Release
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    1. To the fullest extent permitted by applicable law, you release Circle and its officers, directors, employees, agents, successors and assigns from all claims, demands and damages of every kind arising out of or relating to your dealings with any Onramp Provider, identity verification vendor, Developer or other third party in connection with Arc Onramp. Nothing in this release limits or releases Circle’s liability for its own gross negligence, recklessness or intentional misconduct, or for any liability that applicable law prohibits from being released.
    2. IF YOU ARE A CALIFORNIA RESIDENT, YOU WAIVE CALIFORNIA CIVIL CODE SECTION 1542 IN CONNECTION WITH THE FOREGOING, WHICH STATES: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.”
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  7. Indemnification
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    1. You will indemnify, defend and hold harmless Circle and its employees, directors, officers, agents, affiliates and representatives from and against any and all claims, costs, losses, damages, judgments, tax assessments, penalties, interest and expenses (including reasonable attorneys’ fees) arising out of any claim, action, audit, investigation, inquiry, or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach of your representations, warranties, or obligations set forth in these Terms, including any violation of our terms or policies; (b) your wrongdoing, misuse, or other wrongful or improper use of Arc Onramp or any Third-Party Onramp Service; (c) your violation of any third-party right, including any privacy, publicity or intellectual property right; (d) your violation of any legal requirement of the United States or any other country; (e) any other party’s access and/or use of Arc Onramp with your unique name, password, private key or other appropriate security code, or (f) your fraud, gross negligence or willful misconduct. 
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  8. Changes to These Terms
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    1. Circle may amend these Terms at any time by posting the revised version on a Circle website, through Arc Onramp, or by other electronic communication. Your continued use of Arc Onramp after the revised version becomes effective constitutes your acceptance of the revised version. If you do not agree to be bound by the updated Terms, then you may not access or use Arc Onramp.
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  9. Assignment

These Terms, and any rights and licenses granted hereunder, may not be transferred or assigned by you, and any attempted transfer or assignment will be null and void. Circle may assign these Terms without your consent, including to any Circle affiliate or subsidiary.

  1. Dispute Resolution; Arbitration Agreement; Class Action Waiver

Please read this Section 20 (the “Arbitration Agreement”) carefully. It is part of your contract with Circle and affects your rights. It contains procedures for mandatory binding arbitration and a class action waiver.

  1. Applicability of Arbitration Agreement. Subject to the terms of this Arbitration Agreement, you and Circle agree that any disagreement, controversy, or claim arising out of or relating in any way to your access to or use of Arc Onramp, any communications you receive, any products sold or distributed through Arc Onramp, or these Terms or prior versions of these Terms (each, a “Dispute”) will be resolved by binding arbitration, rather than in court, except that: (1) you and Circle may assert claims or seek relief in small claims court if such claims qualify and remain in small claims court; and (2) you or Circle may seek equitable relief in court for infringement or other misuse of intellectual property rights (such as trademarks, trade dress, domain names, trade secrets, copyrights, and patents). For purposes of this Arbitration Agreement, “Dispute” will also include disputes that were not noticed at the time you first became subject to these Terms but that arose or involve facts occurring before the existence of this or any prior versions of these Terms as well as claims that may arise after the termination of these Terms. 
  2. Informal Dispute Resolution. There might be instances when a Dispute arises between you and Circle. If that occurs, Circle is committed to working with you to reach a prompt, low‐cost and mutually beneficial resolution. You and Circle agree to participate in good faith informal efforts to resolve Disputes before starting an arbitration or initiating an action in small claims court (“Informal Dispute Resolution”). You and Circle agree that as part of these efforts, either party has the option to ask the other to meet and confer telephonically (“Informal Dispute Resolution Conference”). If you are represented by counsel, your counsel may participate in the conference, but you must also personally participate.

To initiate Informal Dispute Resolution, a party must give notice in writing to the other party (“Notice”). Such Notice to Circle should be sent by email to arbitration@circle.com. The Notice must include: (1) your name, telephone number, mailing address, e‐mail address associated with your account (if you have one), and wallet address(es) used to access Arc Onramp; (2) the name, telephone number, mailing address and e‐mail address of your counsel, if any; and (3) a description of the Dispute, including the specific relief sought. Circle will send Notice, including a description of the Dispute, to your email address or regular address on file. It is your responsibility to ensure your email and regular address are correct and remain up to date. The Notice must be signed by the party initiating the Dispute (i.e., either you personally or a Circle representative). 

The Informal Dispute Resolution process lasts 45 days and is a mandatory precondition to commencing arbitration. The Informal Dispute Resolution Conference, if requested by either party, shall be individualized such that a separate conference must be held each time either party initiates a Dispute, even if the same law firm or group of law firms or organizations represents multiple users in similar cases, unless all parties agree; multiple individuals initiating a Dispute cannot participate in the same Informal Dispute Resolution Conference unless all parties agree. 

The statute of limitations and any filing deadlines shall be tolled while the parties engage in Informal Dispute Resolution.

  1. Waiver of Trial in Front of Judge or Jury. YOU AND CIRCLE HEREBY WAIVE ANY CONSTITUTIONAL AND STATUTORY RIGHTS TO SUE IN COURT AND HAVE A TRIAL IN FRONT OF A JUDGE OR A JURY. You and Circle are instead electing that all Disputes shall be resolved by arbitration under this Arbitration Agreement, except as specified in Section 20.1. There is no judge or jury in arbitration, and court review of an arbitration award is subject to very limited review. 
  2. Waiver of Class and Other Non-Individualized Relief. YOU AND CIRCLE MAY BRING CLAIMS AGAINST THE OTHER ONLY ON AN INDIVIDUAL BASIS AND NOT ON A CLASS, REPRESENTATIVE, OR COLLECTIVE BASIS, AND THE PARTIES HEREBY WAIVE ALL RIGHTS TO HAVE ANY DISPUTE BE BROUGHT, HEARD, ADMINISTERED, RESOLVED, OR ARBITRATED ON A CLASS, COLLECTIVE, OR REPRESENTATIVE BASIS. ONLY INDIVIDUAL RELIEF IS AVAILABLE. Subject to this Arbitration Agreement, the arbitrator may award declaratory or injunctive relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by the party’s individual claim. Nothing in this paragraph is intended to, nor shall it, affect the terms and conditions under Section 20.9. Notwithstanding anything to the contrary in this Arbitration Agreement, if a final decision, not subject to any further appeal or recourse, determines that the limitations of this Section 20.4 are invalid or unenforceable as to a particular claim or request for relief (such as a request for public injunctive relief), you and Circle agree that that particular claim or request for relief (and only that particular claim or request for relief) shall be severed from the arbitration and may be litigated in the courts located in the State of Delaware. The parties agree that any claims or requests for relief that are severed from an arbitration may not proceed in litigation and shall be stayed until all Disputes between the parties that remain in arbitration are finally resolved. All other Disputes shall be arbitrated, or litigated in small claims court. This Section 20.4 does not prevent you or Circle from participating in a class-wide or mass settlement of claims.
  3. Rules and Forum. These Terms evidence a transaction involving interstate commerce; and notwithstanding any other provision herein with respect to the applicable substantive law, the Federal Arbitration Act, 9 U.S.C. § 1 et seq., will govern the interpretation and enforcement of this Arbitration Agreement, including the procedures governing Batch Arbitration (defined below), and any arbitration. If Informal Dispute Resolution does not resolve satisfactorily within forty-five (45) days after receipt of a Notice, or after completion of the Informal Dispute Resolution Conference, if requested, you and Circle agree that either party shall have the right to finally resolve the Dispute through binding arbitration. 

The arbitration will be administered by the National Arbitration & Mediation (“NAM”) in accordance with the NAM Comprehensive Dispute Resolution Rules and Procedure (the “NAM Comprehensive Rules”) in effect at the time of arbitration, except as supplemented, where applicable, by the NAM Mass Filing Supplemental Dispute Resolution Rules and Procedures (the “NAM Mass Filing Rules”; together with the NAM Comprehensive Rules, the “NAM Rules”), and as modified by this Arbitration Agreement. The NAM Rules are currently available at https://www.namadr.com/resources/rules-fees-forms/.

A party who wishes to initiate arbitration must provide the other party with a request for arbitration (the “Demand”). The Demand must include: (1) the name, telephone number, mailing address, e‐mail address of the party seeking arbitration, as well as the wallet address(es) and/or email address(es) associated with any applicable account; (2) a statement of the legal claims being asserted and the factual bases of those claims; (3) a description of the remedy sought and an accurate, good‐faith calculation of the amount in controversy in United States Dollars; (4) a statement certifying completion of the Informal Dispute Resolution process as described above; and (5) a statement certifying that the requesting party will pay any necessary filing fees in connection with such arbitration. Any Demand you send to Circle should be sent by email to arbitration@circle.com. Circle will provide the Demand to your email address on file. It is your responsibility to keep your contact information up to date.

If the party requesting arbitration is represented by counsel, the Demand shall also include counsel’s name, telephone number, mailing address, and email address. Such counsel must also sign the Demand. By signing the Demand, counsel certifies to the best of counsel’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, that, consistent with the standards set forth in Federal Rule of Civil Procedure 11(b): (1) the Demand is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of dispute resolution; (2) the claims, defenses and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law; and (3) the factual and damages contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery (“Counsel’s Certification”). 

Unless you and Circle otherwise agree, or the Batch Arbitration process discussed in Section 20.9 is triggered, the arbitration, including any in-person arbitration hearing, will be conducted in the city where you reside. Subject to the NAM Rules, the arbitrator may direct a limited and reasonable exchange of information between the parties, consistent with the expedited nature of arbitration. If NAM is not available to arbitrate, the parties will select an alternative arbitral forum. Your responsibility to pay any NAM fees and costs will be solely as set forth in the applicable NAM fee schedules (the “Fee Schedules”). 

You and Circle agree that all materials and documents exchanged during the arbitration proceedings shall be kept confidential and shall not be shared with anyone except the parties’ attorneys, accountants, or business advisors, and then subject to the condition that they agree to keep all materials and documents exchanged during the arbitration proceedings confidential. 

You and Circle agree that at least 14 days before the date set for an arbitration hearing, any party may serve an offer in writing upon the other party to allow judgment on specified terms. If the offer made by one party is not accepted by the other party, and the other party fails to obtain a more favorable award, the other party shall not recover any post-offer costs to which they otherwise would be entitled and shall pay the offering party’s costs from the time of the offer.

  1. Arbitrator. The arbitrator will be either a retired judge or an attorney licensed to practice law in the state of Delaware and will be selected by the parties from NAM’s roster of consumer dispute arbitrators. If the parties are unable to agree upon an arbitrator within thirty-five (35) days of delivery of the Demand, then NAM will appoint the arbitrator in accordance with NAM Rules, provided that if the Batch Arbitration process under Section 20.9 is triggered, NAM, without soliciting input or feedback from any party, will appoint the arbitrator for each batch, subject to your right to object to that appointment.
  2. Authority of Arbitrator. The arbitrator shall have exclusive authority to resolve any Dispute, including, without limitation, disputes regarding the interpretation or application of the Arbitration Agreement, including the enforceability, revocability, scope, or validity of the Arbitration Agreement or any portion of the Arbitration Agreement, except that all Disputes regarding Section 20.4, including any claim that all or part of Section 20.4 is unenforceable, illegal, void or voidable, or that Section 20.4 has been breached, shall be decided by a court of competent jurisdiction and not by an arbitrator. The arbitrator shall have the authority to grant motions dispositive of all or part of any Dispute. The arbitrator shall issue a written award and statement of decision describing the essential findings and conclusions on which the award is based, including the calculation of any damages awarded. The award of the arbitrator is final and binding upon you and us. Judgment on the arbitration award may be entered in any court having jurisdiction.
  3. Attorneys’ Fees and Costs. Unless fee shifting is specifically authorized by law or by the NAM Rules, the parties shall bear their own attorneys’ fees and costs in arbitration unless the arbitrator finds that either the substance of the Dispute or the relief sought in the Demand was frivolous or was brought for an improper purpose (as measured by the standards set forth in Federal Rule of Civil Procedure 11(b)). To the extent, following a presentation on the merits, on its own motion or a party’s, and after affording a reasonable opportunity to respond, an arbitrator determines that a party who commenced arbitration did not bring its claim(s) consistent with Counsel’s Certification and the standards set forth in Federal Rule of Civil Procedure 11(b), the parties agree that the arbitrator shall, as part of its award, impose sanctions by ordering that the initiating party reimburse the responding party for all arbitration filing and administrative fees and arbitrator costs the responding party incurred under the Fee Schedules. If you or Circle need to invoke the authority of a court of competent jurisdiction to compel arbitration, then the party that obtains an order compelling arbitration in such action shall be entitled to recover from the other party its reasonable costs, necessary disbursements, and reasonable attorneys’ fees incurred in securing an order compelling arbitration.
  4. Batch Arbitration. To increase the efficiency of administration and resolution of arbitrations, you and Circle agree that in the event that there are twenty-five (25) or more individual Demands of a substantially similar nature filed against Circle by or with the assistance of the same law firm, group of law firms, or organizations, within a reasonably proximate period of time, for example, a ninety (90) day period, NAM shall (1) administer the arbitration demands in batches of 100 Demands per batch (or, if between twenty-five (25) and ninety-nine (99) individual Demands are filed, a single batch of all those Demands, and, to the extent there are fewer than 100 Demands remaining after the batching described above, a final batch consisting of the remaining Demands); (2) appoint one arbitrator for each batch; and (3) provide for the resolution of each batch on a consolidated basis with one set of filing and administrative fees due per batch, one procedural calendar, one hearing (if any) in a place to be determined by the arbitrator, and one final award, which will provide for any and all relief to which the arbitrator determines each individual party is entitled (“Batch Arbitration”). NAM shall administer all batches concurrently, to the extent possible.

All parties agree that Demands are of a “substantially similar nature” if they arise out of or relate to the same event or factual scenario and raise the same or similar legal issue(s) and seek the same or similar relief. To the extent the parties disagree on the application of the Batch Arbitration process, the disagreeing party shall advise NAM, and NAM shall appoint a sole standing Procedural Arbitrator or, should the circumstances so require, an Emergency Arbitrator, according to the NAM Rules, to determine the applicability of the Batch Arbitration process (the Procedural Arbitrator or Emergency Arbitrator, the “Administrative Arbitrator”). In an effort to expedite resolution of any such dispute by the Administrative Arbitrator, the parties agree the Administrative Arbitrator may set forth such procedures as are necessary to resolve any disputes promptly. The Administrative Arbitrator’s fees shall be paid by Circle.

You and Circle agree to cooperate in good faith with NAM to implement the Batch Arbitration process including the payment of single filing and administrative fees for batches of Demands, as well as any steps to minimize the time and costs of arbitration, which may include: (1) the appointment of a discovery special master to assist the arbitrator in the resolution of discovery disputes; and (2) the adoption of an expedited calendar of the arbitration proceedings.

This Batch Arbitration provision shall in no way be interpreted as authorizing or creating a class, collective, and/or representative arbitration or action of any kind, except as expressly set forth in this provision, and nothing about the Batch Arbitration process will preclude any party from participating in any arbitration administered according to that process.

  1. 30-Day Right to Opt Out. You have the right to opt out of the provisions of this Arbitration Agreement by sending written notice of your decision to opt out to arbitration@circle.com, within thirty (30) days after first becoming subject to this Arbitration Agreement. Your notice must include your name and address, the email address and wallet address(es) used to access Arc Onramp, and an unequivocal statement that you want to opt out of this Arbitration Agreement. Any opt-out notice will be effective only if you send it yourself, on an individual basis, and opt out notices from any third-party purporting to act on your behalf will have no effect on your or Circle’s rights. If you opt out of this Arbitration Agreement, all other parts of these Terms will continue to apply to you. Opting out of this Arbitration Agreement has no effect on any arbitration agreements that you may currently have with us, including any previous versions of this Arbitration Agreement to which you agreed and did not timely opt out, which will remain in effect, and has no effect on any arbitration agreements with us you may enter in the future.
  2. Invalidity, Expiration. Except as provided in Section 20.4 if any part or parts of this Arbitration Agreement (other than Section 20.9) are found under the law to be invalid or unenforceable, then such specific part or parts shall be of no force and effect and shall be severed, and the remainder of the Arbitration Agreement shall continue in full force and effect. However, if Section 20.9 is found under the law to be invalid or unenforceable then, in that case, the entire Arbitration Agreement shall be void, and the parties agree that all Disputes will be heard in the state or federal courts located in Wilmington, Delaware. You further agree that any Dispute that you have with Circle as detailed in this Arbitration Agreement must be initiated within the applicable statute of limitation for that claim or controversy, or it will be forever time barred. Likewise, you agree that all applicable statutes of limitation will apply to such arbitration in the same manner as those statutes of limitation would apply in the applicable court of competent jurisdiction. You and Circle agree that any Dispute must commence within one (1) year after the cause of action accrues; otherwise, such cause of action is permanently barred.
  3. Modification. You and we agree that Circle retains the right to modify this Arbitration Agreement in the future. Any such changes will be posted on Arc Onramp, and you should check for updates regularly. Notwithstanding any provision in these Terms to the contrary, we agree that if Circle makes any future material change to this Arbitration Agreement, it will notify you. Your continued use of Arc Onramp, including the acceptance of products and services offered on Arc Onramp following the posting of changes to this Arbitration Agreement, constitutes your acceptance of any such changes. If you have previously agreed to a version of these Terms with an arbitration agreement and you did not validly opt out of arbitration then, changes to this Arbitration Agreement do not provide you with a new opportunity to opt out of your previous agreement to arbitrate. Circle will continue to honor any valid opt outs of the Arbitration Agreement that you made to a prior version of these Terms.
  1. Governing Law

These Terms are governed by Delaware law without regard to its choice of law or conflicts of law principles and/or as applicable the federal law of the United States. Any arbitration related to any Dispute will be governed by the Federal Arbitration Act, as set forth above.

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  1. Order of Precedence
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    1. These Terms govern your access to and use of Arc Onramp. In the event of a conflict: (a) the Privacy Policy controls with respect to the collection, use and processing of your personal information; (b) an Onramp Provider’s terms control as between you and that Onramp Provider with respect to the Third-Party Onramp Service it provides; and (c) a Developer’s terms control as between you and that Developer with respect to that Developer’s interface. No terms of any third party amend, supersede or override these Terms as between you and Circle.
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  2. General
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    1. These Terms and any applicable terms or policies incorporated by reference, constitute the complete agreement between you and Circle regarding Arc Onramp and supersede all prior oral and written discussions.
    2. If any provision of these Terms is held invalid or unenforceable by a court of competent jurisdiction, that provision will be enforced to the maximum extent permissible and the remaining provisions will remain in full force and effect.
    3. No waiver by Circle of any term of these Terms will be deemed a further or continuing waiver of that term or any other term.
    4. Section headings are for convenience only and do not affect the interpretation of these Terms.
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  3. Support

For questions relating to Arc Onramp, please visit help.arc.io. Matters within an Onramp Provider's control must be raised directly with the applicable Onramp Provider. Any dispute between you and an Onramp Provider, a Developer, or any other third party is solely between you and that third party.

  1. Survival

The provisions of these Terms that by their nature should survive termination or suspension will survive, including Section 2 (Circle’s Role; No Regulated Services), Section 7 (Transactions, Quotes and Fees), Section 8 (Your Information and Privacy), Section 11 (Assumption of Risk), Section 12 (Intellectual Property), Section 14 (Disclaimer of Warranties), Section 15 (Limitation of Liability), Section 16 (Release), Section 17 (Indemnification), Section 19 (Assignment), Section 20 (Dispute Resolution; Arbitration Agreement; Class Action Waiver), Section 21 (Governing Law), Section 22 (Order of Precedence), Section 23 (General) and this Section 25.

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ONRAMP PROVIDER SCHEDULE

Last Updated: September 16, 2026

Fiat onramp availability varies by region and is subject to each provider's eligibility requirements.

Transak Limited (and its Affiliates) — Processes card, Apple Pay, and Google Pay purchases, and is in the fiat flow of funds.

BVNK / Lead Bank — Provides virtual account number and payment processing. Fiat you send is credited to a virtual account subledger within the BVNK / Lead Bank structure, and BVNK converts and sends the resulting stablecoin to your wallet.

Socure — Collects and verifies identity (KYC) information on behalf of the payment processors in the onramp flow.

Socure is a service provider to the payment processors. Its privacy notice describes how identity information is handled.

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