Is Zengo safe? What its own terms say
Is Zengo safe to use for casino deposits?
Zengo's terms disclaim custody but do not settle who holds key material. Its terms name no gambling rule (zengo.com, read 2026-10-07), which is an absence, not a permission. Contracting party: Zengo Ltd. 7 points are not verified. No primary-source incident is recorded. Liability: excluded for all loss. Chains named: Bitcoin, Ethereum, BNB Chain, Solana, Tron, TON, Base and Polygon.
Documents last checked Reviewed by CryptoGuardz Register Desk, editorial desk
Disclosure: CryptoGuardz has no commercial relationship with Zengo, earns nothing if you install it, and has not contacted the company or given it notice of this entry. Every statement below is either a verbatim quote from a document Zengo publishes or a statement about a public record, and both carry the date they were read. Corrections go to the corrections page.
1. What this means for you
Consequences first, in the conditional, each one produced by a clause in a document Zengo publishes itself. Every line links to that clause, quoted in full and dated. None of them is a claim that Zengo can move your coins on chain: the terms disclaim that power and this register takes them at their word on it.
- Your access to the app can be withdrawn if Zengo decides to withdraw it The suspension clause enumerates grounds, and one of them is the expiry of a contract between Zengo and a technology partner, which is nothing you control.
- Your keys are not on your device at all if you created the wallet with a Google or Apple account Zengo's own help centre states it holds one of the two parts of the encryption key and that the private key sits in a Zengo-operated enclave. The binding document does not distinguish the two wallet types.
- You are contracting with someone you cannot name if you use the swap, the on-ramp or the staking inside the app 1 sub-service clauses are recorded across 1 kinds of service, and most of the counterparties are identified in the terms only as a third party.
- You are relying on a document that does not describe the product if you read only the terms The recovery model the marketing pages describe is not the recovery model the binding document describes.
2. What this entry records, and what it does not
This register publishes no number for a wallet. The payout score on the casino register has five defined components and a published arithmetic; no equivalent instrument exists here. What follows is a field-by-field account of what was read, where and when.
| Binding terms | Read in full6 clauses captured verbatim across 5 topics, retrieved 2026-10-07 |
|---|---|
| Contracting entity | Zengo Ltd.Israel. The agreement gives a registered address in Tel Aviv, chooses Israeli law and gives the Tel-Aviv-Jaffa courts exclusive jurisdiction. No arbitration clause. |
| Custody position in the terms | Does not settle who holds key materialCannot be answered with a single value. There is no single private key. Zengo's own agreement states its servers hold one of two key shares, the Server Share, and that a transaction requires both. Zengo therefore holds key material and cannot transact alone, and the user cannot transact without Zengo's servers. The register's self-custody reading does not fit this model and the file records it as a two-party arrangement. |
| Sub-services | 1 clauses recordedSwap. A count of recorded clauses, not of distinct companies. |
| Code audit | Not measuredNo security audit, source review or reproducible-build check has been carried out or read by this register. A wallet's safety is largely decided there, and nothing on this page speaks to it. |
| First-party test | Not measuredNo transaction has been signed, no swap executed and no recovery flow run through this product by this register. |
| Default node provider | Not disclosedNo RPC or node provider is named in any primary document retrieved. |
3. What we could not verify
Every entry carries this section. The gaps are published because a reader deserves the limits of the check as well as its results.
- The identity of the Trustee holding the Master Decryption Key, and whether the GitHub repository named in the agreement exists and is maintained. Not checked.
- Whether Zengo can refuse to co-sign a transaction with its Server Share, for example for a sanctioned address. The agreement retrieved contains no clause either reserving or denying that power, but the architecture makes it technically possible. Recorded as an open question, not a finding.
- Sanctions restrictions. No OFAC or sanctioned-country clause was found in the User Agreement.
- Named swap, on-ramp and staking providers. The agreement names none; the privacy policy names service providers such as Hubspot, Fathom.io, Google and Firefly but no crypto counterparties.
- The prediction-market provider. The agreement describes prediction-market access without naming the operator.
- Where the 3D FaceLock biometric data is stored and by whom. The privacy policy retrieved does not say.
- Documented incidents. No primary-source incident was located. Absence here is absence of a search result, not evidence of no incident.
4. Who you are contracting with
The binding document names a company and states where it is registered or which law governs. The detail and the clause are below.
| Named counterparty | Zengo Ltd.source · retrieved 2026-10-07 |
|---|---|
| Jurisdiction | Israel. The agreement gives a registered address in Tel Aviv, chooses Israeli law and gives the Tel-Aviv-Jaffa courts exclusive jurisdiction. No arbitration clause. |
| Relationships disclosed | The agreement names a Trustee that holds the Master Decryption Key for release if the company cannot continue operating. The Trustee's identity was not captured in this pass. No corporate affiliates named. |
Zengo Ltd., registered at Derech Menachem Begin 121-123, 30th Floor, Tel Aviv (TEL AVIV, SARONA), Israelzengo.com
Regardless of your place of residence or where you access or use Zengo from, these Terms and your use of Zengo will be governed by and construed solely in accordance with the laws of the State of Israel.zengo.com
5. The custody claim, and what the binding document says
The homepage sells the wallet as self-custodial. The claims "only", "always recoverable" and "never hacked" are Zengo's marketing and are recorded as quotes, not as facts.
The only self-custodial wallet with no private key vulnerability. Powered by MPC, always recoverable, never hacked.zengo.com · 2026-10-07
Zengo uses distributed security, by which our servers hold a key share ("Server Share") to sign transactions, while the other share is on the User's mobile device ("Device Share"). Only when both Shares interact, a Transaction can take place.zengo.com · 2026-10-07
This means that Zengo is unable to access Users' Assets without their volition and consent.zengo.com
6. Recovery, and where the terms and the marketing differ
| Cloud or hosted backup offered | yes |
|---|---|
| What is stored | A recovery file, which Zengo states is not a private key, plus email authentication as a mandatory factor and a 3D FaceLock biometric scan as a recommended factor. Zengo separately holds the Server Share on its own servers. |
| Where | The recovery file sits in the user's default personal cloud: Google Drive on Android, iCloud Drive on iPhone. The Server Share sits on Zengo's servers. |
| Changes the custody position | yesRecorded as true on the strength of Zengo's own User Agreement and privacy policy: recovery and signing both depend on a Server Share held by Zengo, so the backup does not return the wallet to sole user control. The recovery file alone cannot restore a wallet without Zengo's servers, and Zengo states it cannot restore a wallet without the file. If Zengo stops operating, the agreement provides for a Trustee to publish a Master Decryption Key. |
The Zengo app also creates a unique recovery file and stores it in your default personal cloud storage system, depending on your operating system (Google Drive for Android and iCloud Drive for iPhone).intercom.help
In addition, in the event that the company is unable to continue operating, the Trustee will publish certain software data (the "Master Decryption Key") on https://github.com/Zengo-Trustee/Server-key-release, that will allow each Beneficiary to combine the their individual Device Share along with its relevant Server Share, in order to assist the Beneficiaries to withdraw their funds from their wallet.zengo.com
This means that Zengo is unable to access Users' Assets without their volition and consent.zengo.com
The homepage calls the wallet self-custodial and always recoverable. The User Agreement states Zengo's servers hold one of the two key shares and that both are needed to sign. The help centre says Zengo has no access to the recovery file. These are consistent with each other only as a two-party model: neither side can act alone. The marketing word self-custodial does not describe that model, and the binding document does not use it in the passages retrieved.
7. The app is not the wallet
1 clauses, each one a place where the product routes a user to a counterparty the user never contracts with by name, under terms the user never opens. The count is of recorded clauses and not of distinct companies: two entries can name the same counterparty and each still be a separate thing the terms permit.
Zengo can also be used to interact with certain third party services, decentralized applications ("DApp(s)") and platforms.zengo.com
8. Withdrawing your access to the interface
Your keys are yours. The software you reach them through is licensed, and the licence can be withdrawn. 1 clauses are recorded on this point.
We may temporarily or permanently suspend the use of or revoke your account, if we believe you have violated these Terms or exhibit behavior that raises suspicion of criminal activity.zengo.com
Because Zengo's Server Share is needed to sign, suspension of the account affects the ability to transact, not only the interface. The agreement does not state whether a suspended user can still use the Trustee route.
9. Who can block an address
Zengo claims no power to block an address in the documents read. No clause in the documents read discloses that another party in the stack can freeze or blacklist an address either. That is an absence of disclosure, not a guarantee that no such party exists.
10. What the terms say about gambling
Position recorded: not disclosed. No clause naming gambling, betting, casinos or wagering was found in the documents read. That is an absence in the documents, not a permission, and the general prohibition on unlawful use still applies.
The card side of the same question is on the card register, and the casino side on KYC on withdrawal.
11. Chains it names
Of the eight chains this register filters on, Zengo names 8: Bitcoin, Ethereum, BNB Chain, Solana, Tron, TON, Base, Polygon. Not named on the pages read: none. The sentence introduces a table whose network column names Bitcoin (BTC), Ethereum (ETH), Binance Smart Chain (BSC), Solana (SOL), Tron (TRX), Ton (Ton), Base (BASE) and Polygon. Binance Smart Chain is recorded as BNB Chain. The table rows were read but are not sentences and are not quoted.
Below is a list of the supported assets supported by Zengo and the appropriate networks for each cryptocurrency:help.zengo.com
12. Liability, amendment, arbitration and where you can use it
The liability clause excludes liability for all loss rather than capping it at a figure. It is the clause that decides what the rest of the document is worth.
IN ANY EVENT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, OUR TOTAL, MAXIMUM AND AGGREGATE LIABILITY TO YOU FOR DIRECT DAMAGES SHALL BE LIMITED TO HALF THE FEES YOU PAID US (IF ANY) IN THE TWELVE MONTHS PRECEDING THE EVENT PURPORTEDLY GIVING RISE TO THE CLAIM.zengo.com
For a user who paid no fees, the cap is zero.
We may revise these Terms (beyond the terms, rules and policies explained in our user guide), in whole or in part, at any time.zengo.com
You may not access or use the App, the Platform or any of our services if you are a citizen or a resident of any of the following restricted regions and jurisdictions in the US: Alaska, Florida, Hawaii, Kentucky, Louisiana, Minnesota, North Dakota and Rhode Island.zengo.com
What the provider states it processes, and who it passes it to. Recorded because a wallet that never touches a key can still see every address you hold.
Using Secure Multi-Party Computation (MPC), we create two parts ("Shares") that can be used together to perform the functionality of a private key. One of the Shares will be stored on your mobile device and the second Share will be stored on our servers.zengo.com
If you wish to activate your Zengo App user account with the back-up feature, as further explained in our Terms, you will need to provide your biometric data of your facial image, which is a mathematical representation of your face.zengo.com
13. Public record
No incident is recorded for Zengo. That is not a clean bill of health. No primary source, meaning a company disclosure, a public vulnerability register entry or a regulator action, was located within this collection. Absence of a record here is the absence of a search result.
14. Who should avoid Zengo
Anyone who intends to create a wallet by signing in with a Google or Apple account while believing the custody position described on the marketing pages applies to them. By Zengo's own documentation it does not, and the binding document does not record the distinction.
Related entries
Or read the whole wallet register, the card register, the same method applied to exchanges and to crypto casinos, the clause library at clause watch, or how this register works.