Due Network, S.L. | Client Terms
Last updated: 21 April 2026.
1. Introduction
Due Network, S.L. ("Due Network") is a limited liability company incorporated under Spanish law, with Tax Identification Number (CIF) B-16407272 and registered office at Paseo de la Castellana, 91, 4th floor, door 1, 28046 Madrid, Spain, registered with the Madrid Commercial Registry, Volume 46865, folio 73, Section 8. Due Network is authorised as a Crypto-Asset Service Provider by the Spanish Securities Market Commission (CNMV) and is registered as a CASP in the ESMA register.
Due Network SL operates exclusively for users in the European Union, providing Services to facilitate the purchase and exchange of Digital Assets through our On Ramp & Off Ramp product.
These Terms and Conditions, together with our Privacy Policy, govern the relationship and constitute a legal agreement between:
- You, the Client ("Client")
- Us, Due Network, S.L. ("Due")
By entering into this agreement, you accept that we will provide you with crypto-asset related services (services that allow you to exchange fiat currency for crypto-assets, or vice versa). We may also work with other Due group companies ("Due Group companies") and with third parties (e.g., exchanges, payment service providers or banks) to provide the services (hereinafter, "external associated providers") due to the international nature of the services provided.
For the sake of clarity, if you use only the Services provided by a Due Group entity, this Agreement is entered into between you and that entity. However, if you use Services provided by more than one Due Group entity, this Agreement is entered into between you and the corresponding entity with respect to the specific Services you use from each of them.
Depending on your location and/or the location of your beneficiary, these services are provided by Due and/or our external associated providers. We will always indicate the entity providing the relevant services and the corresponding terms before you confirm your transaction.
The Client acknowledges having read, understood and fully accepted these Terms and Conditions together with the Privacy Policy; otherwise, the Client must refrain from using the Due Platform and requesting Due's services.
Due maintains a Conflicts of Interest Management Policy, a summary of which can be found here.
2. Account Creation and Client Admission Policy
To use our crypto-asset services, you must register for an "Account" (the "Account" or "Due Account") and successfully complete the registration process on our online platform (the "Due Platform"), which may be in the form of a web application available at app.due.network or a mobile application.
To register, we will request the information necessary for KYC/KYB verifications. You represent and warrant that the information will be provided truthfully, accurately and completely. The data we may request includes, without limitation:
- If you are a legal entity: legal name of the entity, tax identification number or registration number, country of incorporation or residence, operational address, details of the legal representative and authorised representatives, business activity, etc.
- If you are a natural person: full name, nationality, country of residence, legal address, identity document and contact details.
We may also request that you provide additional information to comply with legal and regulatory obligations. You represent and warrant that all information provided in accordance with these Terms is true, accurate and not misleading in any respect. If any information changes, it is your obligation to update such information as soon as possible. Failure to provide such information, if we request it, in a timely manner may result in the suspension (until you provide such information) or closure of your Account.
We reserve the right to retain your account registration information after you cancel your Account for business and regulatory compliance purposes, subject to applicable laws and regulations.
Persons or entities located in sanctioned, high-risk or non-cooperative jurisdictions, or included on national or international sanctions lists, will not be able to access the Services.
The following will also not be admitted as users and/or clients: persons who refuse to identify themselves correctly or to provide the required documentation when requested; natural persons found to have submitted false documentation; natural persons whom the entity becomes aware of, through the Authorities or other means, as being connected to money laundering operations; natural persons included on official lists of persons or entities subject to a prohibition on operating; natural persons known to be linked to terrorist groups or organisations and, in general, to criminal activities; any others that Due may decide for justified reasons.
To effectively use the services provided by Due, the user must have a smartphone mobile phone that allows them to receive text messages, calls, use the camera and install applications, as well as sufficient storage space. Registration using a virtual phone number is not permitted.
2.1 Client Representations and Warranties
By accessing or using your Account and these services, you represent and warrant that:
- you are at least 18 years of age or of legal age in your country of residence;
- you will only use our services for legitimate purposes;
- you are acting on your own behalf if you register as a natural person, or in the capacity of legal representative or authorised agent if you register as a legal entity;
- you have ownership and control of the wallets provided;
- the use of these services in your jurisdiction is permitted by applicable law;
- you do not reside in, nor act on behalf of, any person or entity in jurisdictions where Due Network is not authorised to offer or promote its services;
- you also understand that there are additional representations and warranties made by you elsewhere in (or by reference in) these Terms and that any false representation on your part constitutes a breach of these Terms.
If you are in a jurisdiction where local regulations restrict or prohibit access to our services, you must not access or use them. Due Network may refuse to provide services in areas where local laws or regulatory restrictions apply.
When registering to use the Account on behalf of an entity, you represent and warrant that:
- such legal entity is duly organised and validly existing under the applicable laws of the jurisdiction of its organisation;
- you are duly authorised by such legal entity to act on its behalf; and
- such organisation (and any affiliated entity) must not have been previously suspended or removed from the Due Platform or any other service or product offered by Due or its affiliated entities.
By using our services, you acknowledge that Due relies on these representations and warranties in providing you with our services, and that any breach of these representations and warranties may result in account suspension, termination or other consequences determined by Due at our sole discretion.
2.2 Right of Withdrawal
In accordance with Law 22/2007, of 11 July, on the distance marketing of financial services to consumers, the Client who qualifies as a consumer shall have the right to withdraw from this contract within 14 calendar days from its conclusion, without stating reasons and without penalty, except with respect to those crypto-asset exchange transactions whose price depends on fluctuations in the financial markets that the provider cannot control, which are excluded from the right of withdrawal pursuant to Article 10.2.a) of said Law. To exercise the right of withdrawal, the Client must notify support@due.network. In the event of withdrawal from the framework contract, transactions already executed will not be affected.
3. Services
Due Network SL provides, as a Crypto-Asset Service Provider, the following services:
(i) exchange of fiat currency for crypto-assets.
(ii) exchange of crypto-assets for crypto-assets.
The accepted fiat currencies are: Euro (€) and Pound Sterling (£).
The accepted crypto-assets are: USDC and EURC, both issued by Circle.
You may consult the white papers of the accepted crypto-assets and their environmental impact here.
The list of accepted crypto-assets may change without prior notice. Please confirm the accepted networks for sending and receiving crypto-assets at the time of placing the Order.
Due Network does not provide custody services for crypto-assets or fiat currency. You must have your own wallet to send and receive your crypto-assets in the exchange process. You must have a fiat currency account for sending or receiving currency in the exchange process.
3.1 Limits
Due may establish, modify or apply operational limits to the Services at any time, including, but not limited to, per-transaction limits, daily, monthly or annual limits, and specific limits by client type, channel, payment method or crypto-asset.
Such limits may be implemented based on regulatory compliance requirements, anti-money laundering and counter-terrorism financing (AML/CFT) obligations, risk management considerations, regulatory, operational or security requirements.
The Client acknowledges and accepts that the application or modification of such limits shall not constitute a breach of contract and shall not give rise to any right to compensation.
3.2 Order Cancellation
Once an Order has been accepted, it shall be irrevocable unless expressly agreed otherwise or where permitted by law. We will execute your Order and, save for exceptions, you will not be able to cancel it.
Sometimes, for reasons beyond our control, we may not be able to execute the Order for you. If this happens, we will let you know. We shall not be liable for any loss you may incur as a result.
3.3 Rejection of Your Instructions
We may reject your exchange order for any reason and at our sole discretion. We will let you know as soon as possible. If we do so, we shall not be liable for any loss you may incur as a result.
3.4 Self-Hosted Wallets (Unhosted Wallets)
When the Client uses the Services to send or receive crypto-assets to or from self-hosted wallets (unhosted wallets), the Client represents and warrants that:
a) the Client is the owner of, or has legitimate control over, the wallet when acting on their own behalf; or
b) when acting on behalf of a third party (i.e., where the wallet is owned or controlled by such third party), the Client has valid authorisation to carry out the transaction and knows the identity of the beneficiary.
Where legally required, Due may request additional information about the ownership or control of the wallet, including declarations, technical verifications or other reasonable mechanisms in accordance with applicable law.
Due reserves the right to reject or suspend any transaction where the required information is not provided or where there are reasonable doubts about its accuracy or legality. In cases where settlement has not yet occurred, Due may also cancel or not complete the transaction.
For crypto-asset transfers where the beneficiary is a third party other than the Client, the Client must provide, at a minimum, the identification information required under applicable law. If the information provided does not match the information received by the destination VASP, the transaction may not be completed and may be rejected.
The Client acknowledges that Due may analyse destination addresses using blockchain analytics tools (KYT), apply internal consistency checks and perform sanctions screenings before executing the transfer.
Due may reject or suspend transfers to third parties where, at its sole discretion, adequate levels of regulatory or risk comfort are not achieved.
3.5 Fees
Registration and access to Due's web Platform and mobile application is free of charge.
You agree to be responsible for and to pay any fee, commission and/or transaction cost in connection with the provision of our services as set out below. You may consult our Fee Policy at the following link.
3.6 Exchange Rate
The exchange rate applied to your transaction (and any spread) is determined by a price oracle at the time you initiate an order. Before you confirm the order, we will show you: (i) the exchange rate to be applied; (ii) a clear breakdown of the gross price; (iii) the fees charged by Due; and (iv) the net amount you will receive/send. The displayed price is only binding after you confirm the transaction.
3.7 Suspension or Termination of Your Account
If your Due Account is suspended or terminated for any reason, we will also suspend your ability to access the services provided by Due Network and/or the Due Group entities.
Any crypto-asset that you have previously purchased and deposited in your self-custody crypto-asset wallet will remain yours, but you will not be able to access the crypto-asset buying and selling services on our Platform.
Due may suspend the Services, in whole or in part, immediately and as a preventive measure when:
a) the user fails to provide required information;
b) there are indications of regulatory non-compliance or unusual or suspicious transactions are detected;
c) the suspension is required by a competent authority; or
d) such suspension is necessary to protect the security of the system or third parties;
e) breach of the Terms and Conditions;
f) non-acceptance of the Terms and Conditions, Privacy Policy or service pricing;
g) at the express request of the user.
Any preventive suspension shall not give rise to any right to compensation.
3.8 Risks
You declare that you have read, understood and accepted the Risks associated with crypto-asset operations as detailed here.
3.9 Market Integrity and Prohibited Conduct
The Client undertakes not to engage in, attempt to engage in, or contribute to any conduct that may constitute market abuse in relation to crypto-assets, including, without limitation:
a) transactions using inside information or the misuse of inside information relating to crypto-assets (insider dealing);
b) the unlawful disclosure of inside information to third parties;
c) market manipulation, including the dissemination of false or misleading information, the execution of fictitious orders or the artificial creation of supply or demand conditions for a crypto-asset.
Due has internal systems and procedures in place for the prevention and detection of conduct that may constitute market abuse. Where Due detects reasonable indications of any of the conduct described above, it may:
(i) suspend or cancel the affected transactions or orders immediately;
(ii) restrict or suspend the Client's access to the Services;
(iii) report such indications to the competent authority (CNMV)
without this giving rise to any right to compensation on the part of the Client.
4. Changes to the Terms and Conditions
We may occasionally make changes to these Terms and Conditions. We will publish details of any changes we make in the revised Terms and publish them on our website. The revised Terms and Conditions will apply immediately from the time they are published unless otherwise indicated, and you will be able to see the update date at the beginning of the document.
We may also send you an email to inform you of changes to our Terms and Conditions, and it is your responsibility to ensure that any contact details we hold for you are correct and up to date.
Continued use of our services after the effective date of any changes to the Terms and Conditions will be deemed acceptance of such changes. Therefore, if you are satisfied with our updated Terms and Conditions, no action is required. If you do not agree with the revised Terms, you must stop using our services immediately and notify us in writing so that we can close your Account.
5. Intellectual Property and Trademark Use
The website, its Platform and mobile application, as well as Due's API connection, its source code and the content it hosts are protected by national and international intellectual and industrial property laws. They may not be exploited, reproduced, distributed, modified, publicly communicated, assigned or transformed, unless express written authorisation from the rights holders is obtained.
The design, images, signs, distinctive signs, trade name, trademarks, logos, products and services contained in Due are protected by Industrial Property law.
Access to this website does not grant users any right or title over the intellectual or industrial property rights or the content it hosts. Users who access this Due Platform may not copy, modify, distribute, transmit, reproduce, publish, assign or sell the aforementioned elements or create new products or services derived from the information obtained without the express written authorisation of Due.
The alteration of the content or structure of this Due website by the user is strictly prohibited.
Due reserves the right to take such legal action as may be appropriate against users who violate or infringe intellectual and industrial property rights.
6. Limitation of Liability
We exercise reasonable care to ensure that our services are uninterrupted and continuously accessible. We provide our crypto-asset services on an as-is basis. You use these services at your own risk; we cannot guarantee (except as required by applicable law) that our services will operate without interruptions, failures or technical errors. In providing our services, we also rely on our external associated providers and have no control over their services.
Due Network shall not be liable to you for any damage, interruption or service failure on the Due Platform caused by factors beyond its control, nor for any loss, whether direct or indirect, arising in connection with your use of our crypto-asset services.
You are solely responsible for complying with all your tax and legal obligations arising from the use of the Due Platform. Due Network assumes no responsibility for the Client's compliance with such obligations or for the consequences resulting from non-compliance.
We also assume no responsibility for the actions or omissions of any of our external partners. We shall not be liable for any loss you incur or costs you must pay as a result of legal or regulatory requirements, or events beyond our control.
In cases where the transaction is rejected because the originating crypto-asset service provider has not received the originator's information, after due request for this information, due to the application of Regulation (EU) 2023/1113 (Travel Rule), the crypto-assets will be returned to the address from which they were received. As this return entails costs not attributable to Due, a processing fee may be applied to this return in the currency or crypto-asset received in accordance with our Fee Policy.
Unless otherwise provided by law, Due Network's liability for direct damages arising from proven breaches of these Terms shall be limited, to the extent permitted by law, to the amount of fees actually paid by the Client to Due Network in the twelve (12) months prior to the event giving rise to the claim. This limitation does not apply to liabilities that cannot be limited by law.
Due does not provide any type of advice to the user in any field, whether tax, financial, economic, accounting, commercial or any other. Therefore, the decisions adopted by the user are made personally on their own initiative and do not arise from any activity or promotional offer by Due.
Any incident in the operations of banking entities shall be the exclusive responsibility of such entities. Likewise, any incident arising from the use of payment methods and reception of legal tender shall be the sole responsibility of the provider thereof.
Notwithstanding the foregoing, in cases where an error may occur during the crypto-asset purchase and sale process, the user may contact Due's support service.
Due shall not assume any liability for damages or losses that may be suffered as a consequence of events that could not have been foreseen, or which, if foreseen, were unavoidable, whether due to force majeure or unforeseeable circumstances.
7. Third-Party Links and External Websites
Due's website contains links to third-party websites, which are governed by their own terms and conditions. Due shall not be held responsible for the operations that such third parties may carry out with Due's users.
8. Voluntary Access
Due Network is a CASP authorised by the CNMV and registered with ESMA to operate in the European Union. As such, the products and services provided by Due Network on the Due Platform are authorised in the European Union. Depending on your jurisdiction, Due Network may not be authorised to promote our products and services without a licence.
Nothing in this clause shall be construed as limiting Due Network's obligations under MiCA where the Services are considered to be provided in the European Union.
If you reside in a jurisdiction where Due Network is not expressly authorised and you still wish to use our products and services, by accepting these Terms, you are also confirming that you have read and understood the foregoing and that you are accessing the Due Platform on your own initiative without active promotion or solicitation by Due Network, our affiliates or any representative within the European Union or any other jurisdiction where we are not authorised to promote our products and services.
You represent and warrant:
- You have initiated contact with us of your own free will and without any prior solicitation, advertising or direct marketing by Due Network;
- Your decision to use our products and services on the Due Platform is based solely on independent interest and research; and
- You understand that our products and services are not intended for clients within jurisdictions where we are not authorised to operate.
We shall not be liable for any regulatory or legal obligation arising from the use of our services within a restricted jurisdiction.
9. Customer Service
You may contact us by email at: support@due.network, where our team will be able to resolve any query or issue in the provision of the service.
Complaints and Claims
If you wish to file a formal complaint, please follow the instructions here.
In accordance with Regulation (EU) 524/2013, we inform you that the European Commission provides an online dispute resolution platform, accessible at https://ec.europa.eu/consumers/odr. Without prejudice to the foregoing, any dispute may be submitted to the competent courts in accordance with Section 15 of these Terms.
Whistleblowing Channel
This is a specific channel for reporting certain facts that may constitute specific criminal offences on a confidential or anonymous basis. To file a formal report, please follow the instructions here.
10. Digital Operational Resilience and ICT Incidents
Due Network implements ICT risk management and incident response measures in accordance with applicable regulatory standards and best practices and complies with Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector.
11. Processing of Personal Data
We process your personal data to provide you with our crypto-asset services and to comply with legal and regulatory obligations. For AML/CFT and regulatory reporting purposes, we process identification and transaction data under applicable legal obligations (GDPR legal basis: compliance with a legal obligation; where relevant, processing may also be based on legitimate interests).
Personal data may be disclosed to competent authorities (including SEPBLAC, Banco de España and/or CNMV), law enforcement agencies and to service providers acting under contract and subject to appropriate safeguards. Data may be transferred outside the EEA where necessary for the provision of services or in compliance with legal obligations; such transfers will be carried out under appropriate legal mechanisms (e.g., adequacy decisions, standard contractual clauses).
Retention periods for identification and transaction records are those required by applicable law (minimum 10 years for AML records, unless otherwise provided).
For full details on your rights and our practices, please consult our Privacy Policy.
12. Transfer and Assignment
The Client may not assign, in any manner, the rights and obligations arising from these Terms and Conditions.
We may transfer or assign all our rights and obligations under these Terms and Conditions to any third party without your permission and without prior notice, without this implying any modification to the obligations assumed by the Client.
13. Taxes
You may be required to pay taxes or costs arising from the purchase of crypto-assets. Due Network is not responsible for collecting such amounts, making payments on your behalf or providing tax returns on your behalf.
The Client is solely responsible for complying with any tax obligation arising from the use of the Services.
Due may disclose information related to the Client's transactions to national or international tax or regulatory authorities where required by applicable legislation, including, without limitation, MiCA, CARF or other local reporting obligations.
Due does not provide tax advice nor guarantee the tax treatment of any transaction carried out through the Services.
14. Severability
If for any reason any provision of these Terms and Conditions is deemed void, this shall not affect the remaining provisions of the contract, which shall remain in force for the period established.
15. Governing Law
This agreement shall be governed by the laws of Spain.
Both parties, expressly waiving any other jurisdiction that may apply, submit any interpretation or dispute arising from this contract to the Courts that, according to the applicable legal system, are competent.
In the event that versions exist in several languages, the Spanish version shall prevail; any translation is provided for informational purposes only.