In these Terms, "we", "us", "El Dorado" or "the Company" refers to EL DORADO LABS PY INC or its affiliates, subsidiaries or related companies (as specified in the table in Annex C hereto), and "our" shall be construed accordingly. "You" refers to any person who accesses or uses any of the Services that may be accessed through our website, mobile applications or any other application when available (collectively, the "Sites").
By using the platform, by accessing or using our Services, and/or by electronically and expressly accepting these terms and conditions, you express your consent to and acceptance of them.
If you do not accept the terms and conditions of use set out herein, do not access this site and do not use the services offered by El Dorado.
El Dorado Empresas is a self-custodial business-use platform through which the User retains, at all times, exclusive control over its digital assets, private keys and access credentials.
Through El Dorado Empresas, Users may, among other functionalities:
a) Operate and hold stablecoins, which includes sending, receiving and holding digital assets denominated in stablecoins, such as USDC, directly in wallets controlled by the User.
b) Execute international payments through the SWIFT network, reaching more than one hundred and twenty (120) countries, in accordance with the applicable operating and regulatory conditions.
c) Execute instant international payments, including payments to the People’s Republic of China and to more than fifty (50) additional countries, subject to the availability of the integrated payment providers.
El Dorado Empresas is designed to serve the operational needs of legal entities and organizations that require, among other things:
i) Internal control mechanisms that allow different roles and permissions to be defined and managed, including the ability for authorized members of the organization to propose, approve and execute payments.
ii) Basic traceability of operations, allowing identification of, among other elements, which users execute transactions, the date and time of execution, the destination of the funds, the amounts involved and the users who approve such operations.
iii) Execution of international and instant payments to a broad set of jurisdictions, through third-party payment service providers.
iv) Receipt of payments, through accounts created and managed by third-party service providers, subject to the terms, conditions and validations applicable by such providers.
The User acknowledges and accepts that certain functionalities of the Product depend on services provided by third parties, so that their availability, scope and conditions may vary in accordance with what is established by such third parties and by the regulations applicable in each jurisdiction.
For the purposes of these Terms and Conditions, the words and expressions indicated below shall have the meaning assigned to them in this section, whether used in the singular or the plural:
“Agreement”: the agreement that You and El Dorado enter into so that El Dorado may provide the Services.
“Approver”: A natural person authorized by the User to approve transactions, payments or operations within the Platform, in accordance with the roles and permissions defined by the User.
“Wallet”: A self-custodial technological means that allows the User to store, receive, send and manage digital assets, the private keys of which are controlled exclusively by the User.
“Consideration”: the fee in crypto-assets that You will pay to El Dorado for the Services.
“Secure Device”: Defined within these terms and conditions.
“El Dorado”: EL DORADO LABS PY INC, or the legal entity that operates the Platform, as applicable.
“El Dorado Empresas” or the “Product”: The self-custodial business platform offered by El Dorado, which enables the management of digital assets, the execution of payments and the administration of financial operations as set forth in these Terms and Conditions.
“Team Member”: Any natural person who acts on behalf of or representing the User within the Platform, including, without limitation, proposers, approvers and executors of payments.
“Network Fee”: Costs associated with the use of blockchain networks, which may vary depending on external factors such as network congestion. They will be disclosed at the time the transaction is carried out. These costs may also include: node maintenance, engineering costs necessary to ensure operations, and other related operating costs.
“Operations”: Any action carried out through the Platform, including the sending, receipt and custody of digital assets, the execution of international payments, instant payments and other enabled transactions.
“International Payments”: Transfers of funds made to or from jurisdictions other than that of the User, including those executed through the SWIFT network or other payment systems integrated into the Platform.
“Instant Payments”: Transfers of funds processed on an accelerated or immediate basis, subject to the availability and conditions of the integrated payment service providers.
“Platform”: The technological infrastructure, interfaces, applications, systems and digital services through which El Dorado Empresas is offered. The name of the Platform, its format and operation may vary as El Dorado deems appropriate.
“Payment Service Provider”: An independent third party that provides payment processing services, receiving accounts, international transfers or other complementary financial services.
“Self-Custodial”: An operating model in which the User maintains exclusive control over its digital assets, private keys and access credentials, without El Dorado having custody, control or access to the User’s funds.
“Stablecoins”: Digital assets whose value is linked or referenced to a fiat currency or other underlying asset, such as USDC.
“Traceability”: The Platform’s ability to record and display basic information about Operations, including data such as the users involved, dates, amounts, destinations and approvals.
“User”: A legal entity that registers for and uses El Dorado Empresas for business, commercial or operational purposes, acting through its representatives and authorized Team Members.
“Identity Validation”: refers to the identity validation process carried out by El Dorado, which ensures that there is a real person behind the intended operation and verifies that such person is who they claim to be, preventing the creation of false identities or the commission of fraud. This process may include a business (corporate) verification.
To access and use El Dorado Empresas (the “Service”), the User represents, warrants and undertakes to comply with the following requirements, on a continuous basis throughout the term of its relationship with El Dorado:
• Nature of the User. The Service is intended exclusively for legal entities duly incorporated and validly existing under the laws of their jurisdiction of incorporation. The User represents that it uses the Service solely for business, commercial or professional purposes, and not for personal or consumer purposes.
• Capacity and Representation. The User represents that the persons acting on its behalf within the Platform have the legal powers and internal authorizations necessary to bind it, including the creation of accounts, the assignment of roles, and the execution, approval or proposal of Operations.
• Registration and Accuracy of Information. To use the Service, the User must complete the registration process and provide truthful, complete, up-to-date and verifiable information, including corporate information, contact details and any other information required by El Dorado or by the Payment Service Providers. The User undertakes to keep such information up to date and acknowledges that El Dorado may suspend or limit access to the Service in the event of incomplete, inaccurate or misleading information.
• Regulatory Compliance. The User undertakes to comply at all times with applicable law, including, without limitation, rules on the prevention of money laundering, terrorist financing, international sanctions, export controls and applicable financial regulations in the relevant jurisdictions. El Dorado may require additional information, documentation or verifications (including KYC/KYB processes) as a condition for access to or the continuity of the Service. The identity validation process may be carried out directly by El Dorado or through its payment service providers.
• Lawful Use of the Service. The User undertakes not to use the Service for unlawful, fraudulent or legally prohibited activities, nor for Operations that infringe the rights of third parties, international sanctions or applicable regulatory restrictions.
• Responsibility regarding the Self-Custodial Model. The User acknowledges and accepts that El Dorado Empresas operates under a self-custodial model, so that the User is solely responsible for the custody, management and security of its private keys, access credentials and digital assets. El Dorado has no access to, control over or custody of the User’s funds, nor can it recover digital assets in the event of loss of keys, unauthorized access or User errors.
• Dependence on Third Parties. The User acknowledges that certain functionalities of the Service depend on third-party Payment Service Providers, whose conditions, validation processes, execution times and availability are not controlled by El Dorado. Access to the Service may be subject to acceptance of and compliance with the terms and conditions of such third parties.
• Suspension or Restriction of the Service. El Dorado reserves the right to suspend, limit or deny access to the Service, on a temporary or permanent basis, when it reasonably determines that the User does not comply with these requirements, with applicable regulations or with the Terms and Conditions.
The purpose of this Agreement is to govern the terms and conditions under which El Dorado makes the El Dorado Empresas platform available to the User, so that the latter may, within the framework of its business activities and under its exclusive responsibility, access and use the Service for the operational management of crypto-assets and the execution of financial operations, including, without limitation, self-custodial custody, purchase and sale, exchange, sending, receipt and remittance of crypto-assets (the “Crypto-assets”), as well as the execution of international and instant payments.
Access to and use of the Service shall be conditional upon the User having created an account on the Platform, having successfully passed the applicable Identity Validation, verification and regulatory compliance processes (including, where applicable, KYC/KYB processes), and having fully accepted these Terms and Conditions.
Operations carried out through the Platform may be subject to the payment of commissions, fees or any other consideration in favor of El Dorado, as duly disclosed through the Platform or through specific agreements entered into with the User.
The User acknowledges and accepts that El Dorado does not provide financial, investment, legal, tax or any other type of advisory or consulting services, nor does it issue recommendations regarding the convenience, timeliness or suitability of the Operations. The information, tools and functionalities available on the Platform are purely operational in nature and do not constitute professional advice.
Likewise, the User acknowledges and accepts that El Dorado does not act as a direct buyer or seller of Crypto-assets on its own account, nor as a financial intermediary, currency exchange agent, broker, agent or representative of the User. The Operations may involve the participation of Payment Service Providers or third-party technological infrastructure, whose actions are independent of El Dorado and are governed by their own terms and conditions.
The User represents that it understands and accepts the business nature of the Service, the self-custodial model of the Platform, as well as the inherent risks associated with holding, using and operating with Crypto-assets and with the execution of international payments, including, without limitation, market, technological, operational and regulatory risks, and that it decides to use the Service on an informed basis and under its exclusive responsibility.
The User shall be responsible for accessing the Platform only through a Secure Device, understood as one that meets the following minimum conditions:
• User ownership: The device must be personally owned and under the exclusive control of the User. Shared or publicly accessible devices are not considered secure.
• Trusted acquisition: The Secure Device must have been acquired through legitimate and trustworthy suppliers, in order to guarantee its authenticity and avoid tampering.
• Protected credentials: The device’s access credentials (passwords, PIN, biometrics, security tokens, second authentication factor, among others) must be kept strictly confidential and may not be shared with third parties.
• Exclusive use: The device may not be a publicly accessible computer (e.g., internet cafés, libraries, shared kiosks) or be available for use by unauthorized persons.
• Secure configuration: The Secure Device must run a current operating system, supported by its manufacturer and with up-to-date security patches.
• Protected confidential data: Sensitive information related to the Platform must not be stored on removable or insecure media without adequate protection measures, such as encryption or access controls.
• Connection to trusted networks: Access to the Platform must be made only through secure and trusted networks (for example, Wi-Fi with WPA2/WPA3 protection or higher).
• Physical security: The User must adopt reasonable measures to prevent unauthorized physical access to its Secure Device.
• Not virtual or emulated: Access to the Platform must be made only from a real physical device (phone, tablet or computer). Access from programs or environments that simulate a device, such as emulators or virtual machines, is not permitted.
• Not cloud-managed: The use of devices managed through cloud platforms that allow the use of physical devices managed by third-party services is not permitted.
• Not rooted or jailbroken: The device must not circumvent the restrictions imposed by the manufacturer or operator. Devices with superuser or administrator access to the operating system could allow unauthorized actions and, consequently, are not compatible with access to the Platform.
The use of a device that does not meet these conditions shall be considered a breach of these Terms and Conditions, and may give rise to the suspension or restriction of access to the services by El Dorado.
When accessing the Platform, the legal representative or person authorized by the company must complete all fields of the registration form, with valid and truthful data, in order to use all the Services provided by the Platform. The Platform may, at any time, request the information it deems necessary to verify the information provided.
The following rules apply to the service:
• The User guarantees and is responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the data provided. Likewise, it shall be liable for any harm, damage or inconvenience caused by the provision of false, erroneous or inaccurate information, and accepts and acknowledges that the accounts created may be disabled or limited if El Dorado determines that incorrect, false or inaccurate information has been provided.
• If the information undergoes any change that may affect any of the Services offered by the Platform, the User must update it through the means provided for that purpose.
• The account is personal, unique and non-transferable, over which absolute confidentiality must be maintained, since El Dorado shall not be liable for any loss or damage arising as a result of the insecurity of the account.
• The user account registered on our platform is personal and non-transferable. Under no circumstances is the assignment, transfer, rental, gift or sale of the account to third parties permitted. If any action involving a breach of this clause is detected, we reserve the right to permanently suspend or cancel the account involved, without the possibility of appeal. Non-transferability is essential to guarantee the security and integrity of our platform.
• The User undertakes to notify El Dorado immediately, by a suitable and reliable means, of any unauthorized use of the account, as well as any access to it by unauthorized third parties.
• The User understands and accepts that the identity verification process may be carried out by third parties, including the Payment Service Providers, so that the personal data provided as part of the process will be processed directly by the Payment Service Provider, and El Dorado will act as a data processor.
• The User may select whether to create an organization or join an existing company. In the first case, the User must complete the requested information, which will be verified, and will receive a response by email. If the User wishes to join an existing company or organization, the User must enter the invitation code provided by the company.
• Upon completing the identity verification process, the User receives a Wallet that allows it to carry out Transactions.
El Dorado may cancel, suspend or disable any account when any of the following events occurs:
• False, incorrect, inaccurate or erroneous information is found.
• If El Dorado reasonably suspects or verifies that the account has been sold or transferred.
• The User breaches any of its obligations regarding the Platform.
• The User carries out or participates in an illegal operation. In this case, we will notify the competent authorities of the irregularity so that the relevant actions may be initiated.
• The User uses inappropriate language in the course of its interactions. Inappropriate language is understood to be language that is disrespectful or that affects the honor and good name of others.
If your account is suspended, El Dorado will freeze your Crypto-asset balance until the reason for which your account was suspended has been resolved, and you will be able to use them again once your account is reactivated.
El Dorado reserves the right to suspend any account that is under investigation for suspicious transactions, until it carries out the relevant inquiries, in order to safeguard the security of all our users.
If your account is cancelled, suspended or disabled, El Dorado will have a maximum of up to fifteen (15) business days to send your Crypto-assets to an external wallet, on the corresponding networks, unless you have carried out an illegal operation, in which case you authorize El Dorado to freeze the Crypto-assets you hold and deliver them to the competent authority. You may only withdraw your Crypto-asset balance once El Dorado has deducted any amount owed to other Users or to El Dorado as Consideration.
Where the suspension or cancellation of the account is not due to illegal operations, the user has the possibility to appeal the decision within a period of 12 business days, providing sufficient evidence. El Dorado will have 15 business days from receipt of the appeal to respond to it.
Likewise, in the event that a deposit is rejected for any reason, but especially for compliance and risk-analysis reasons, El Dorado will have a maximum of up to fifteen (15) business days to send your Crypto-assets to an external wallet.
When the balance to be withdrawn is less than 1 USDT, or in any case an amount lower than the corresponding fee for the withdrawal or movement of those funds, El Dorado may withdraw those funds from the wallet and dispose of them.
At El Dorado you may find the following services:
The Platform allows the User to operate and hold stablecoins, including, without limitation, USDC, through a self-custodial model.
For such purposes, the User may:
d) Send and receive stablecoins, making transfers of digital assets to or from compatible wallet addresses, in accordance with the technical conditions of each applicable blockchain network.
e) Hold stablecoins in its Wallet, retaining exclusive control over the Crypto-assets, private keys and associated access credentials.
The User acknowledges and accepts that El Dorado has no custody, control or access over the User’s Crypto-assets, nor can it intervene in, reverse or recover transactions once they have been executed on the corresponding network.
The Platform allows the User to execute international payments through the SWIFT network, reaching more than one hundred and twenty (120) countries, subject to the operational, regulatory and technical availability of the integrated Payment Service Providers.
Such payments may be subject to:
• Validation and regulatory compliance processes;
• Processing times inherent to the SWIFT network and to the financial institutions involved;
• Commissions, bank charges or additional costs applicable by third parties.
The User acknowledges that El Dorado does not control the crediting times, rejections, returns or holds that may occur as a result of banking, regulatory or compliance policies of third parties.
The User acknowledges and accepts that every SWIFT payment order must necessarily follow the operational flow below:
• Creation: The User generates the operation request through its dashboard.
• Multisig Authorization: The request must be approved in accordance with the multiple-signature (Multisig) configuration defined by the User for its team.
• Processing: Once the internal approvals have been completed, the order acquires the status of “in process”.
• Execution and Settlement: After validation, the order is sent to the banking network for final execution.
Processing Times and Delays: The User understands that international transfers are not instantaneous. Payments via SWIFT may take up to six (6) business days to be processed and credited to the beneficiary’s account. This period begins to run only once the order has successfully completed the Multisig approval process and the initial compliance validations.
External Factors and Disclaimer of Liability: Such payments are subject to:
• Validation and regulatory compliance (AML/KYC/KYB) processes of both El Dorado and third parties.
• Processing times inherent to the SWIFT network and to the financial institutions involved.
• Deductions for commissions, correspondent bank charges or additional costs applicable by third parties unrelated to the Platform.
The User acknowledges that El Dorado does not control and is not responsible for the crediting times, rejections, returns or holds resulting from banking, regulatory or compliance policies of third parties.
Order Statuses: Every payment request may result in one of the following final statuses, without liability for the Platform:
• Approved: The payment has been successfully processed.
• Rejected by Compliance: When the operation does not pass the security or regulatory compliance filters.
• Rejected for Erroneous Data: When the beneficiary information or the banking data provided by the User is incorrect, incomplete or invalid.
El Dorado Empresas allows the User to execute international payments on an instant or accelerated basis, subject to the availability of the integrated Payment Service Providers.
These payments are processed through third-party infrastructures and are subject to:
• Availability by country and jurisdiction;
• Regulatory compliance validations;
• Operational, technical or regulatory limits.
El Dorado does not guarantee the permanent availability of this functionality in all jurisdictions, nor immediate execution in all cases.
The Platform allows the User to configure and manage different roles and permissions for Team Members, including the power to:
• Propose payments or Operations;
• Approve payments or Operations;
• Execute payments or Operations.
The User is solely responsible for the correct assignment, supervision and revocation of such permissions, as well as for the Operations carried out by its Team Members within the Platform.
The Platform makes available to the User a wallet functionality with a multiple-signature or Multisig scheme. This allows payment requests not to be executed immediately, but instead to require the approval of a certain number of team members (approvers), according to the configuration established by the account Administrator.
The User, through its administrator users, is solely responsible for:
• Defining the number of signatures required (quorum) to validate a transaction.
• Assigning “creator”, “approver” or “administrator” roles and permissions to the individuals it designates.
• Keeping the list of authorized persons up to date, immediately removing those individuals who cease to belong to the organization or whose powers have been revoked.
The User acknowledges and accepts that any payment instruction that has completed the approval process configured in the Multisig scheme will be considered a legitimate, binding and irrevocable order issued directly by the Company. El Dorado has no obligation or ability to verify whether a specific approver acted within their internal legal powers or whether there was a breach of trust.
El Dorado is released from all liability in the following cases:
• If a transaction is approved by a team member who should not have had access (failure in the custody of corporate credentials).
• If the signature configuration chosen by the User results in the blocking of funds (for example, if a number of signatures is required from persons who no longer have access to their keys and there are no backup administrators).
• If there is collusion or fraudulent action among the team members designated by the User to approve transactions.
Each team member is responsible for the security of their own access and, where applicable, their own private keys linked to the Multisig scheme. The compromise of one of these accounts does not give rise to any claim against El Dorado, it being the User’s responsibility to suspend such credentials immediately from the administration panel.
El Dorado Empresas offers basic traceability functionalities that allow the User to view operational information related to the Operations carried out through the Platform, including, among other elements:
• Identity of the Team Member who proposes, approves or executes an Operation;
• Date and time of execution;
• Amount of the Operation;
• Destination of the funds.
The User acknowledges that such traceability is informational and operational in nature, and does not constitute an accounting, financial auditing or comprehensive regulatory compliance system.
The User may execute international and instant payments, as well as receive payments, through accounts created and managed by third-party Payment Service Providers.
These accounts and services are subject to:
• Validation, approval and monitoring processes of the Payment Service Provider itself;
• Its independent terms and conditions;
• Regulatory and operational limitations applicable in each jurisdiction.
The User acknowledges that El Dorado is not responsible for acts, omissions, decisions or failures attributable to such Payment Service Providers.
When initiating an international payment request, the Platform will show the User an approximate amount in the destination currency. The User acknowledges and accepts that:
• Initial Estimate: The amounts shown in the dashboard when creating the request are merely indicative and are based on the exchange rates in effect at that time.
• Exchange Difference: Due to the volatility of the digital-asset and currency markets, as well as processing times, the final amount settled and credited to the beneficiary may vary from the initial estimate.
• Acceptance of Risk: The User assumes the risk of any exchange-rate fluctuation (exchange difference) that occurs between the time the order is approved (Multisig) and its effective execution by the Payment Service Provider.
In the event that an international payment operation is rejected, the treatment of the funds and the commissions will depend on the reason for the rejection, in accordance with the following rules:
A. Rejection for Compliance: If the transaction is rejected by El Dorado’s Compliance department or by the Payment Service Provider following a risk analysis or regulatory validation:
• Refund: The principal amount will be refunded to the User’s Wallet.
• Commissions: The refund will include the service commission paid to El Dorado.
• Deductions: The refunded amount will be subject to adjustments for the exchange difference generated during the period in which the order was in process. El Dorado will not cover losses arising from market fluctuation in these cases.
If your payment appears with the status “Under Review”, it is because El Dorado or the Payment Service Provider must investigate the transaction further. Some reasons may be:
• Errors with the payment beneficiary.
• Internal errors with our App that must be reviewed in detail.
• Considerable risk levels of the destination wallet or bank account.
If the transfer has a considerable risk level, the regulatory compliance department will proceed to request an Enhanced verification process, in which the User must justify the origin of the funds. If the verification is approved, the payment will proceed. If it is not approved, the procedure explained below for Transaction rejections will follow.
B. Rejection for Erroneous or Incomplete Data: If the transaction cannot be completed because the User incorrectly entered the beneficiary data, SWIFT/BIC codes, account numbers or any other necessary information:
• Refund: The principal amount will be refunded to the User’s Wallet.
• Commissions: The commission paid for processing the transaction will not be refunded, as it covers the operating and network costs incurred for the execution attempt.
• Deductions: As in the previous case, the refund may be lower than the original amount due to the exchange difference generated by the fluctuation of the assets between the creation and the rejection of the order.
Transactions executed directly on the network are irreversible, and El Dorado is not responsible for the withdrawal of funds to wrong wallets or to wallets that are not owned by the user.
The User is solely responsible for ensuring that any deposit made to its Wallet within the Platform is made only in the crypto-assets and networks expressly supported by El Dorado, as indicated in the application interface or in the official communication channels.
Any deposit involving unsupported crypto-assets or the use of networks not enabled by the Platform will not be considered valid or effective. In such cases, El Dorado will not be liable under any circumstances for the loss, blocking or non-crediting of the funds, or for errors arising from the incorrect use of incompatible assets or networks.
This includes, by way of example but not limitation:
• Sending a token not listed or authorized by El Dorado.
• The use of a blockchain network not enabled for the token sent.
• Sending from smart contracts that are not compatible or not recognized by the Platform.
El Dorado assumes no obligation to recover or compensate in these cases. However, it may, at its sole discretion and on an exceptional basis, attempt the process of recovering the funds involved, provided that the value of the erroneous deposit is equal to or greater than ten US dollars (USD 100 or its equivalent in USDT) and that the User has formally reported the incident.
This process is conditional upon:
• The technical and operational capabilities available at the time;
• The traceability of the transaction;
• The availability of resources on the part of the technical team;
• And the absence of legal or network restrictions that prevent recovery.
In the event that El Dorado decides to attempt recovery, a commission equivalent to three percent (3%) of the value of the erroneous deposit will apply, in no case being less than five US dollars (USD 25 or its equivalent in USDT), plus the applicable network fee. The total amount will be deducted from the recovered value before its return to the User.
El Dorado will have a maximum period of ten (10) business days counted from the date on which the User formally reports the incident to the official Customer Service (ATC) channel, to inform whether or not it will proceed with the recovery attempt.
In view of the foregoing, the User is advised to carefully verify, before making any deposit:
• That the crypto-asset is supported by the Platform.
• That the network used matches the one enabled for that crypto-asset.
• That only the wallet addresses and parameters specified in the application are used.
El Dorado has a system of variable commissions based on the value of the transaction; for this reason, when the User requests a transaction, the costs associated with it will be shown in the transaction confirmation.
General provision on commissions. In order for El Dorado to secure the consideration for the Services provided, upon completing an operation on the blockchain, we will deduct from the Wallet balance the Consideration and any applicable Network fee or Gas Fee, and this deduction will be automatically reflected on the Platform. Likewise, for transactions involving payments in FIAT money, whether via the SWIFT network or instant, the corresponding commission will be deducted from the Wallet balance at the time the Transaction request is made.
El Dorado reserves the right to update the value of the Consideration. If this occurs, it will be notified through the Platform, and the new value will apply only to operations carried out after such update.
• To have the legal capacity to carry out purchase, sale and remittance operations of Crypto-assets, as well as to dispose of the funds of the company to which it is linked.
• To allow El Dorado to deduct the Consideration from each Transaction.
• To complete the Platform forms with true and reliable information.
• Not to violate any law, regulation, decree or circular in accordance with applicable law.
• El Dorado is not a financial services or advisory Platform, so the User undertakes to assess the risks of each of the operations it carries out through the Platform and to make an informed decision about them.
• To have no links to illicit activities, money laundering or terrorist financing.
• The resources used for the Transactions must come from legitimate activities.
• El Dorado provides the User with a self-custodial Wallet. This means that the User is the sole and exclusive holder of the private keys, recovery (seed) phrases or access credentials linked to its USDC assets. El Dorado does not store, does not have access to, and does not hold any backup copy of such keys or recovery phrases. It is the sole responsibility of the User to:
• Safeguard its private keys and recovery phrases in a safe place out of the reach of third parties.
• Implement internal security measures to prevent unauthorized access by team members or external actors.
• Understand that control of the Wallet depends exclusively on possession of these credentials.
The User acknowledges and accepts that:
• In the event of loss, misplacement or forgetting of the private keys or recovery phrases, El Dorado will not be able to restore access to the wallet or recover the funds contained therein. The loss of the keys is equivalent to the definitive loss of the assets.
• If a third party gains access to the private keys due to negligence, theft or computer attacks (phishing, malware) on the User’s devices, such third party may dispose of the funds without El Dorado having the technical ability to reverse the transactions or block the wallet.
El Dorado is released from any liability for the loss of funds, unauthorized access or any harm arising from the negligent management of the private keys by the User or its team.
• To provide the infrastructure for the correct functioning of the Platform.
• To respond in a timely manner to your queries or complaints made through the channels provided for this purpose.
• To use its best efforts to guarantee the security of transactions through the Platform.
• To maintain the confidentiality of your information until the purchase-and-sale or donation contract has been entered into.
• To inform the relevant authorities of any irregularity that arises or that is committed by Users in connection with the use of the Platform.
• General Limitation of Liability: El Dorado acts exclusively as a technological facilitator that provides an interface for the management of digital assets and the instruction of international payments. In no event shall El Dorado, its directors, employees or agents be liable for indirect, incidental, special or consequential damages, including, among others, loss of profits, data or business opportunities.
• Liability regarding Third-Party Providers: The User acknowledges that the execution of the services depends on Payment Service Providers. Therefore: El Dorado does not guarantee the uninterrupted availability of the services provided by such Payment Service Providers; and El Dorado shall not be liable for technical failures, operational delays or insolvency of the integrated Payment Service Providers.
Exclusion of Liability for the SWIFT Network and Banking System: El Dorado has no control over and assumes no liability whatsoever for:
• The functioning, delays or errors of the SWIFT network.
• The unilateral decisions of correspondent banks or beneficiaries to hold, reject or freeze funds due to internal compliance policies.
• Errors in the final settlement arising from incorrect information provided by the User.
User Errors and Multisig Configuration: El Dorado is released from all liability for:
• Transactions sent to wrong wallet addresses or bank accounts by the User.
• The improper use of approval powers by the members of the User’s team according to its Multisig configuration.
• The User’s loss of access to the account or to the self-custodial wallet.
• Technological Failures and Force Majeure: El Dorado shall not be liable for any damage or loss caused by viruses, denial-of-service (DDoS) attacks, or other technologically harmful materials that may infect the User’s computer equipment, as well as for events of force majeure or fortuitous event that prevent the normal provision of the service.
• Regulatory Compliance: El Dorado reserves the right to block access to the platform or suspend transactions, without any liability, when there are well-founded suspicions of illicit activities, or when so required by a competent authority or by the risk protocols of its Providers.
Users accept that the Services provided by the Platform are provided on an “as is” basis, which means that there is no express or implied warranty whatsoever regarding the provision of the Services.
No information that Users may have received by any means from El Dorado or any of its representatives or officers, in addition to these terms and conditions, shall engage the liability of El Dorado or represent any warranty regarding the Services.
For this reason, the only recourse that Users will have in relation to the Services provided by the Platform will be to stop using the Platform.
If you are experiencing any failure with the Platform, you may send us a communication at soporte@eldorado.io indicating the problem, and we will use our best efforts to help resolve it.
El Dorado is not responsible for any damage, harm or loss caused by failures of the Platform arising from the server or the Internet. El Dorado will also not be responsible for any virus that may infect the Users’ equipment as a result of access to or use of the Platform, or as a result of any transfer of data, files, images, texts or audio contained therein. El Dorado does not guarantee continuous or uninterrupted access to and use of the Platform.
The Platform may occasionally be unavailable due to technical difficulties or Internet failures, or due to any other circumstance; in such cases, efforts will be made to restore it as quickly as possible, without any liability being attributable to El Dorado as a result. El Dorado will not be responsible for any error or omission that Users commit within the Platform.
The User undertakes to indemnify, defend and hold harmless El Dorado, its affiliated companies, directors, employees, agents and suppliers (hereinafter, the “Indemnified Parties”), against any claim, demand, legal action, loss, damage, liability, cost or expense (including, but not limited to, reasonable attorneys’ fees and court costs) arising out of or related to:
• Breach of the Terms: Any violation by the User or its team members of these Terms and Conditions, or of any policy incorporated by reference.
• Use of the Platform: The improper, illegal or unauthorized use of the Platform, the Dashboard or the Wallet by the User.
• Erroneous Data: Any harm caused to third parties or to El Dorado arising from the provision of false, incomplete or erroneous information during the KYB process or in the creation of international payment requests.
• Team Configuration (Multisig): Internal disputes between the User and its team, or claims arising from the authorization of payments through the multiple-signature configuration chosen by the User.
• Violation of Laws: The infringement of any law, regulation or third-party rights (including intellectual property rights or money-laundering and terrorist-financing prevention laws) committed by the User.
In the event that a claim arises that gives rise to this indemnity obligation, El Dorado will notify the User as soon as possible. El Dorado reserves the right to assume the exclusive defense and control of any matter subject to indemnification by the User, which shall not release the User from its payment obligations for the expenses incurred in such defense.
The indemnification obligations contained in this clause shall remain in effect even after the termination of the contractual relationship between the User and El Dorado or the closure of the User’s account.
Official Claims Channel: In the event that the User has any disagreement, doubt or complaint related to the Services (including SWIFT payment statuses, Dashboard errors or doubts about the balance of its Wallet), it must channel such request exclusively through the email address: soporte@eldorado.io or through the support module within the Dashboard.
Claim Requirements: For a claim to be processed, the User must provide the following minimum information:
• Company Name and User ID.
• Detailed description of the incident.
• Reference number of the payment request (if applicable).
• Screenshots or documents supporting the claim (for example, sending receipts or error messages).
Response Times: El Dorado undertakes to:
• Acknowledgment of receipt: Notify receipt of the claim within a maximum period of forty-eight (48) business hours.
• Resolution or Final Response: Provide a definitive response within a period of fifteen (15) business days.
• Note: In highly complex cases involving investigations with correspondent banks (SWIFT network) or external providers, this period may be extended up to thirty (30) business days, always notifying the User of the extension.
SWIFT Payment Investigation: The User acknowledges that, once a payment has been processed by the Provider and sent to the banking network, any subsequent investigation (such as the issuance of an MT103 receipt or fund tracing) is subject to the times and possible administrative costs imposed by the intervening banks, which must be covered by the User if the error is not attributable to El Dorado.
Exhaustion of the Direct Channel: The User agrees to exhaust this direct claims procedure before initiating any mediation, arbitration or legal action detailed in the Dispute Resolution Clause. El Dorado will not process claims that have not been formally submitted through the channels described herein.
Irrevocability of Instructions: Once a payment order has passed the Multisig approval process and has been executed on the banking network, the User acknowledges that the instruction is irrevocable. El Dorado does not guarantee the possibility of stopping, cancelling or reversing a SWIFT payment in transit.
The Platform, the solutions and the designs, graphics, texts, images, distinctive signs, source code and object code and other content to which you have access on the Platform are the property of El Dorado and are protected by intellectual and industrial property law. The access that El Dorado gives you to the Platform does not imply any assignment of the industrial property rights and/or copyright over the Platform. You must refrain from modifying, disassembling, decompiling or reverse-engineering the Platform; if you do so, you will indemnify El Dorado for the damages this generates.
During the provision of the Services, El Dorado will request certain personal data, for which the User must accept El Dorado’s personal data processing policy, available at www.eldorado.io
El Dorado undertakes to comply with the data protection regulations of all the countries in which it operates.
The El Dorado Site may contain external links to third-party websites on the Internet. El Dorado has no control over these external websites and their content is not checked against any criteria (for example, authenticity, integrity, legality, etc.).
El Dorado is not responsible for any of these external websites that are linked from the El Dorado website with respect to the information, opinions expressed, advice or statements, advertising material, accessibility and any possible consequences of the use of these third-party sites, such as damages, losses, failures and problems. You are solely responsible.
The external website has separate terms of use and policies. Before using their services, content, information or any other material from these external websites, you must review their policies, rules, terms and regulations, and you are solely responsible for taking the necessary precautions to ensure that anything you decide to use is free of viruses, worms, Trojan horses and other destructive elements.
In those cases where the platform’s services are offered through integrated environments or third-party embedded solutions (such as mini-apps), the user acknowledges and accepts that, due to the technical nature of such integration, El Dorado may carry out, on the user’s behalf, those actions or operations necessary for the correct functioning of the selected channel, including, but not limited to: crypto-asset exchanges (Swap) and transfers between blockchain networks.
By virtue of the foregoing, the user grants El Dorado, by accepting these Terms and Conditions, an express mandate with representation to act on the user’s behalf, not only in the execution of the operations mentioned above (Swap and Bridge), but also in those other actions, procedures or operations that, reasonably and according to the technical or functional circumstances of the channel used, may be required in the future to guarantee the continuity, effectiveness and correct provision of the services requested through such integrated environments or embedded solutions.
This Agreement will remain in effect while the Services are used. If the user wishes to terminate this agreement, it must stop using the Services and cancel its account on the Platform; and if it wishes us to delete its information from our database, it must send us a communication stating so. In any case, we will not be able to delete some of its personal data due to legal requirements.
El Dorado may cease providing its Services to you and suspend access to the Platform if you breach these terms and conditions, or if El Dorado identifies that you do not comply with its security policies.
These Terms and Conditions, as well as any contractual relationship between El Dorado and the User, shall be governed by and construed in accordance with the laws in force of the Republic of Panama, excluding any rule that refers to the application of foreign law.
Amicable Resolution: Before initiating any legal or arbitration proceedings, the Parties undertake to attempt to resolve any dispute, controversy or claim arising from this agreement through good-faith negotiations. The User must send a formal notice of dispute to El Dorado’s legal support email, and the parties will have a period of thirty (30) calendar days to reach an agreement.
Arbitration: Once the period mentioned in the preceding point has elapsed without a solution having been reached, any controversy, difference or claim arising from these Terms and Conditions, their performance, execution, termination or interpretation, shall be definitively resolved through Arbitration at Law, in accordance with the following rules:
• Arbitration Center: The arbitration will be administered by the Centro de Solución de Conflictos (CESCON) or, failing that, by the Centro de Conciliación y Arbitraje de Panamá (CeCAP) of the Chamber of Commerce, Industries and Agriculture of Panama.
• Rules: The Arbitration Rules in force of the selected center at the time of filing the request shall apply.
• Tribunal: The Arbitral Tribunal will be composed of a single (1) arbitrator appointed by mutual agreement of the parties or, failing that, by the Arbitration Center.
• Seat and Language: The seat of the arbitration will be Panama City and the proceedings will be conducted entirely in the Spanish language.
• Cost: The costs of the arbitration and the arbitrator’s fees will be borne by the losing party, without prejudice to what the arbitral award decides regarding the award of costs.
Ordinary Jurisdiction: In the event that, for any legal reason, the arbitration is not applicable or is declared null, the parties irrevocably submit to the exclusive jurisdiction of the competent courts of Panama City, Republic of Panama, expressly waiving any other venue or jurisdiction that may correspond to them by reason of their present or future domiciles.
Waiver of Class Actions: The User accepts that any claim against El Dorado must be brought individually and not as part of a class action or collective lawsuit.
The User will receive notices at the email address or mobile phone number registered in the registration form.
El Dorado will receive notices at soporte@eldorado.io.
Any modification, update or adjustment to the conditions of the services will be notified to the User in a timely manner through the application, also referred to as the Platform.
The User accepts and acknowledges that it is its responsibility to periodically review the application to learn of such changes. Continued use of the Platform, or express acceptance within it, shall be understood as full and binding acceptance of the new conditions of the service.
These Terms and Conditions, as well as any of their annexes, shall prevail over any other prior agreement, verbal or written, entered into with respect to the subject matter of the Agreement. For any matter not provided for in these terms and conditions, the provisions of the general terms and conditions of the Platform shall apply.
EL SUEÑO LATINO:
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