Holding assets is a business. Describing wallets is a sentence.

If the issuer or an affiliate can move user assets, freeze them, or recover them, you may be in a custody or safeguarding fact pattern. If users hold keys and you cannot, say that carefully — and live with the support consequences. If a third party holds, name them, and do not call them “our vault” unless they are. If a pad takes assets into a sale contract, that is custody and an offering rail. We will not be that rail.

We do not custody. We do not run wallets. We do not write “safe custody” as a claim unless the evidence is a named provider and counsel is happy with the wording. Safe is a prohibited cousin of guaranteed.