Terms and conditions Brasil

Welcome to El Dorado!

These Terms and Conditions (hereinafter, the “Terms”) govern access to and use of the El Dorado Services by Users residing in the Federative Republic of Brazil. In these Terms, “we”, “us”, “El Dorado” or “Company” refers to El Dorado Labs PY Inc. “You” or “User” refers to any person who accesses or uses any of the Services through our website, mobile applications or any other application when available (collectively, the “Sites”).

These Terms are divided into two chapters:

  • Chapter I – P2P Service: exchange of Crypto Assets between Users under the peer-to-peer model, exclusively with fiat currencies other than the Brazilian Real (BRL).
  • Chapter II – Send with Electronic Payment Provider: purchase (On-Ramp) and sale (Off-Ramp) transactions of USDT with Brazilian Reais (BRL), provided by an Electronic Payment Provider authorized by the Banco Central do Brasil (BCB).

By using the Platform, by accessing or using our Services, and/or by electronically and expressly accepting these Terms, you express your consent to and acceptance of them. If you do not accept these Terms, do not access the Sites or use the Services offered by El Dorado.

DEFINITIONS

The following definitions apply to these Terms in their entirety:

  • Agreement: the agreement that You and El Dorado enter into so that El Dorado can provide the Services.
  • Advertiser: the User in charge of creating buy and sell ads within the P2P market.
  • BCB: Banco Central do Brasil, the regulatory and supervisory authority of Virtual Asset Service Providers in Brazil.
  • BRL / Brazilian Real: legal tender of the Federative Republic of Brazil.
  • Consideration: the fee in Crypto Assets that You will pay El Dorado for the Services.
  • Crypto Assets: tokens, cryptocurrencies or other encrypted digital assets with a given value that are based on blockchain and cryptography technologies and are issued and managed in a decentralized manner.
  • Secure Device: defined in Section 1 of the Common Provisions.
  • Fiat Money / Fiat Currency: legal tender issued by a central bank or monetary authority.
  • 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 of the transaction. These costs may also include node maintenance, engineering costs necessary to ensure operations, and other related operating costs.
  • Off-Ramp: transaction through which the User transfers USDT from their El Dorado wallet to the Electronic Payment Provider and receives BRL in return through the selected local payment method.
  • On-Ramp: transaction through which the User delivers BRL to the Electronic Payment Provider, through the enabled local payment method, and receives USDT in return in their El Dorado wallet.
  • P2P: the Crypto Asset exchange model through which you negotiate and carry out your transactions directly with other Users using the Platform’s escrow system.
  • Platform: the website, application or software development, regardless of its name, that allows you to access the El Dorado Services. The Platform’s name, format and operation may vary as El Dorado deems appropriate.
  • Electronic Payment Provider or Provider: an entity duly authorized by the BCB as a Virtual Asset Service Provider to provide On-Ramp and Off-Ramp services, under the regulations in force on the matter. Its integration within the Platform allows the User to buy and sell USDT with BRL.
  • Services: jointly, the P2P Service governed by Chapter I and the Send with Electronic Payment Provider feature governed by Chapter II.
  • USDT: Tether, a stable-value digital asset (stablecoin) issued on blockchain.
  • User or You: the natural or legal person residing in Brazil who uses the Services.
  • Identity Verification: the process of verifying your identity carried out by El Dorado, which ensures that there is a real person behind the intended transaction and verifies that they are who they claim to be, preventing the creation of false identities or the commission of fraud.

WHAT DO YOU NEED TO USE THE SERVICES?

In order to give your consent and enter into this Agreement, you must meet the following requirements:

  • Be over 18 years of age.
  • Have the capacity to enter into a contract.
  • Reside in the Federative Republic of Brazil.
  • Create an account on the Platform.
  • Have read and accepted these Terms.
  • Have successfully completed Identity Verification.
  • Have the selected identity document in its original, physical form.
  • Use a Secure Device to access the Platform.

COMMON PROVISIONS

The following provisions apply both to the P2P Service (Chapter I) and to the Send with Electronic Payment Provider feature (Chapter II).

1. What is a Secure Device and why is it mandatory for accessing the Platform?

The User shall be responsible for accessing the Platform only through a Secure Device, meaning one that meets the following minimum conditions:

  • User ownership: the device must be personally owned and under the User’s exclusive control. Shared or public-access 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 prevent 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 public-access computer (for example, internet cafés, libraries or shared kiosks) nor 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: the Platform must be accessed only through secure and trusted networks (for example, Wi-Fi with WPA2/WPA3 protection or higher).
  • Physical security: the User must take reasonable measures to prevent unauthorized physical access to their Secure Device.
  • Not virtual or emulated: the Platform must be accessed 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 accepted.
  • Not rooted or jailbroken: the device must not circumvent the restrictions imposed by the manufacturer or carrier. 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 will be considered a breach of these Terms and may result in El Dorado suspending or restricting access to the Services.

2. How do you create an account and what does it imply?

When accessing the Platform you must complete all fields of the registration form with valid and true 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. Your account will allow you to see the details of each transaction you have carried out and your Crypto Asset balance.

Please bear in mind the following rules:

  • You will guarantee and be responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the personal data you provide. You will also be liable for any loss, damage or inconvenience caused by providing false, erroneous or inaccurate information. You accept and acknowledge that the accounts created may be disabled or limited if El Dorado determines that incorrect, false or inaccurate information has been provided.
  • If your information changes in a way that may affect any of the Services offered by the Platform, you must update it through the means provided for that purpose.
  • Your account is personal, unique and non-transferable. Both to register and to log in to the Platform, you must enter your email address, to which we will send a one-time code (OTP) to verify your identity and complete access. You must keep this code absolutely confidential and safeguarded.
  • El Dorado shall not be liable for unauthorized access to your account arising from the misuse, loss or lack of confidentiality of the OTP code or the registered email address.
  • If you lose access to the registered email address, you will also lose access to your El Dorado account, without any liability for El Dorado, since the safekeeping and protection of the email address is the sole responsibility of the User.
  • If your account holds funds, El Dorado will return them in accordance with Annex A of these Terms.
  • 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 rule is detected, El Dorado reserves the right to suspend or permanently cancel the account involved, with no possibility of appeal. Non-transferability is essential to guarantee the security and integrity of the Platform.
  • You undertake to notify El Dorado immediately, through a suitable and reliable means, of any unauthorized use of your account, as well as of any access to it by unauthorized third parties.

3. Can El Dorado cancel or suspend your account?

El Dorado may cancel, suspend or disable any account when any of the following events occurs:

  • False, incorrect, inaccurate or erroneous information is found.
  • El Dorado has well-founded suspicions or confirms that you sold or transferred your account.
  • You breach any of your obligations regarding the Platform.
  • Your account was opened with a temporary email address, or contains the word “eldorado” or similar.
  • You carry out or participate in an illegal transaction. In this case, we will notify the competent authorities of the irregularity so that the relevant actions may be initiated.
  • You use inappropriate language in your interactions. Inappropriate language means language that is disrespectful or affects the honor and good name of people.

If your account is suspended, El Dorado will freeze your Crypto Asset balance until the reason for the suspension has been resolved. You will be able to use it again when your account is reactivated.

El Dorado reserves the right to suspend any account under investigation for suspicious transactions, until it carries out the relevant inquiries, in order to safeguard the security of all Users.

If your account is cancelled, suspended or disabled, El Dorado will have a maximum period of fifteen (15) business days to send your Crypto Assets to an external wallet you own, on the corresponding networks. This does not apply if you have carried out an illegal transaction, in which case you authorize El Dorado to freeze your Crypto Assets and deliver them to the competent authority. You may only withdraw your Crypto Asset balance once El Dorado has deducted any amount you owe to other Users or to El Dorado as Consideration. For more information, see Annex A.

Unless the suspension or cancellation of the account is due to illegal transactions, the User may appeal the decision within twelve (12) business days, providing sufficient evidence. El Dorado will have fifteen (15) business days from receipt of the appeal to respond to it.

4. Why do we verify your identity?

To create an account on the Platform, we will ask you to send us a photo of your identity document and any other data El Dorado deems relevant, in order to ensure that all our transactions are secure and are carried out with the people they claim to be. Through the Identity Verification process, we ensure that the person attempting to open an account on the Platform actually exists and is who they claim to be. We also verify that they have no link to illegal activities. In this way we prevent fraudulent transactions or transactions that could use you as an instrument to commit crimes.

The photo of your identity document is sensitive personal data and, in some cases, we will carry out biometric processing on it. You are not obliged to share it, but if you do not, we will not be able to verify your identity and you will not be able to access our Services.

If you do not successfully complete Identity Verification, you will not be able to access our Services and we will notify you in a timely manner.

For more information, see our personal data processing policy, available here: https://eldorado.io/legal/privacy-policy

5. What should I know about compliance levels?

El Dorado has established four compliance levels for the purpose of knowing its Users. This process, commonly known as KYC (“Know Your Customer”), is used by financial institutions and other entities to verify the identity of their customers, ensuring that they really are who they claim to be. This verification is essential to prevent fraud, money laundering and other illicit activities.

Starting at level one, El Dorado begins requesting the information and documentation necessary to operate on the Platform, which allows continued use and an increase in transaction volume. Therefore, it is crucial that the User provides truthful and accurate information from the outset. Otherwise, they could be unable to use the Platform. In addition, when required, the User must submit original, valid documentation in good condition.

The User is obliged to comply with the transaction levels corresponding to each El Dorado compliance level. Without meeting the established limits, no User may advance to the next level. For more information, see Annex B.

6. Crypto Asset deposits and withdrawals

6.1. Withdrawals to external wallets

The User may withdraw Crypto Assets from their El Dorado wallet to any other external wallet, whether or not they own it. The withdrawal must be made on the networks accepted and operational on the Platform. The User assumes responsibility for withdrawing their Crypto Assets to external wallets. These transactions ARE NOT REVERSIBLE.

6.2. Deposits from external wallets

The User may deposit Crypto Assets from an external wallet to their El Dorado wallet. The deposit must be made on the network corresponding to the El Dorado wallet, and with the Crypto Asset corresponding to that wallet, to ensure it is credited. El Dorado has no responsibility for the source wallets, and the User assumes responsibility for making the deposits. These transactions ARE NOT REVERSIBLE.

6.3. What happens if you make a withdrawal from your El Dorado wallet to a wallet you do not own?

Transactions executed directly on the network are irreversible. El Dorado is not responsible for the withdrawal of funds to incorrect wallets or wallets not owned by the User.

6.4. What happens if you make a deposit to your El Dorado wallet with an unsupported Crypto Asset or network?

The User is solely responsible for ensuring that any deposit made to their 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 networks not enabled by the Platform will not be considered valid or effective. In such cases, El Dorado shall not be liable under any circumstances for the loss, blocking or non-crediting of the funds, nor 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.
  • Using a blockchain network not enabled for the token sent (for example, sending USDT through a network other than the one authorized by the Platform).
  • Sending from smart contracts not compatible with or not recognized by the Platform.

El Dorado assumes no obligation of recovery or compensation in these cases. However, it may, at its sole discretion and on an exceptional basis, attempt the recovery process for the funds involved, provided that the value of the erroneous deposit is equal to or greater than ten US dollars (USD 10 or its equivalent in USDT) and that the User has formally reported the incident.

This process is subject to:

  • The technical and operational capabilities at the time.
  • The traceability of the transaction.
  • The availability of resources from the technical team.
  • The absence of legal or network restrictions preventing recovery.

If El Dorado decides to attempt recovery, a fee equal to three percent (3%) of the value of the erroneous deposit will apply, which may not be less than five US dollars (USD 5 or its equivalent in USDT), plus the applicable network fee. The total amount will be deducted from the recovered value before it is returned to the User.

El Dorado will have a maximum period of ten (10) business days, from the date on which the User formally reports the incident to the official Customer Service (ATC) channel, to report whether or not it will proceed with the recovery attempt.

Therefore, 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.

6.5. What happens if your withdrawal or deposit transaction is under review?

If your blockchain deposit or withdrawal shows the status “Under Review”, it is because El Dorado must investigate the transaction further. In that case, you must contact us through the in-app support chat to follow up on your case. Some reasons may be:

  • Errors with the corresponding blockchain provider.
  • Internal errors with our application that must be reviewed in detail.
  • Considerable risk levels in the source or destination wallet.

6.6. What happens if the transaction is linked to a wallet with a considerable risk level?

If your transfer corresponds to a deposit from a wallet with a considerable risk level, the Compliance team will initiate an Enhanced Verification process to validate the source of the funds:

  • If the verification is approved, the deposit will be credited to your El Dorado wallet.
  • If the verification is not approved, or the deposit is rejected for regulatory compliance reasons, risk analysis or any other applicable cause, you must provide an external wallet, not linked to El Dorado and that does NOT currently present a considerable risk level, for the return of the Crypto Assets. El Dorado will have a maximum period of fifteen (15) business days, from identification of the rejection, to send the corresponding Crypto Assets to the external wallet provided.

When the balance to be returned is less than 1 USDT, or in any case is an amount lower than the value of the corresponding fee for the withdrawal or movement of funds, El Dorado will not be able to process the return, taking into account the operational conditions associated with such movement. The User declares that they understand and accept this condition, releasing El Dorado from any liability arising from the impossibility of processing such return.

If your transfer corresponds to a withdrawal and the external wallet provided presents compliance or risk alerts, or is rejected for any reason, El Dorado will review and determine the process to follow for the particular case. This process may include, among other measures, the withholding or freezing of the corresponding funds. The User understands and accepts that the application of these measures will not give rise to any liability for El Dorado.

CHAPTER I – P2P SERVICE

1. What is the P2P Service?

The P2P Service is a Platform feature that allows registered Users to buy or sell Crypto Assets directly with each other, under a peer-to-peer (P2P) model in which the Platform’s escrow system acts as a guarantee for the transaction, holding the funds until one of the parties confirms that they have received the funds in their local currency account outside the Platform.

You understand that El Dorado does not provide you with investment advice or consulting of any kind, and is not responsible for the use or interpretation of the information provided to you by the Platform. Nor is it an entity that buys or sells Crypto Assets to you directly, nor does it act as an intermediary in the foreign exchange market. You declare and acknowledge that you understand the risks inherent to Crypto Asset transactions.

2. Enabled fiat currencies

For Users residing in Brazil, the P2P Service is not enabled for buying or selling Crypto Assets with Brazilian Reais (BRL). P2P transactions may only be carried out with the fiat currencies of the other countries in which El Dorado operates, as reported on the Platform from time to time.

USDT purchase and sale transactions with BRL may only be carried out through the Send with Electronic Payment Provider feature, governed by Chapter II of these Terms.

The User acknowledges and accepts that they may not publish ads, open orders or agree with their counterparty on payments in BRL within the P2P Service. Any transaction in breach of this provision will be considered a breach of these Terms and may result in the cancellation of the order, the resolution of the dispute against the infringing party and the suspension or cancellation of the account.

3. What transactions can you carry out through the P2P Service?

On the Platform you may sell and buy Crypto Assets in P2P format. In this section we explain how:

  1. When you want to sell or buy Crypto Assets, you must first choose the Crypto Asset you want to buy or sell, according to the offer made by another User through the Platform. You accept and acknowledge that the offer may change at any time in terms of price, payment method, among others.
  2. You must then choose the amount you want to buy or sell.
  3. Once these details are confirmed, the Platform will show you the price of the Crypto Asset you want to buy or sell and its conversion into the enabled fiat currency you want to use as a means of payment, in accordance with Section 2. You accept and acknowledge that the price may change at any time.
  4. The Platform will ask you whether you are sure you want to carry out this transaction.
  5. Once you have confirmed it, a chat will open in which you can communicate with the buyer or seller, as applicable, and finalize the details of the transaction.
  6. At this point, El Dorado will freeze the Crypto Assets subject to the transaction, in order to ensure that the seller transfers them and the buyer pays for them in order to receive them.
  7. If you are the seller, once you have been paid, you must mark the transaction as paid so that El Dorado releases the frozen Crypto Assets. If you are the buyer and the seller does not mark the transaction as paid, you may write to us at soporte@eldorado.io with the proof of payment, or through the other official customer service channels, so that El Dorado can check the information and proceed to release the Crypto Assets.
  8. When the transaction has been successfully completed, both Users will have the option to rate their counterparty.
  9. Finally, Users will see the new balance reflected on the Platform.

You may have a maximum of three (3) active orders simultaneously.

By way of exception, from the moment the price offered by either party is accepted and the start of a transaction is formally confirmed, the Platform places a temporary hold on the traceability of the Crypto Assets and fixes the price for the period between acceptance and verification of the payment in fiat money.

You may cancel the transaction up until you have paid or been paid. Once the transaction has been marked as paid, you may not cancel or modify it.

If you cancel more than three (3) orders, you will receive a message indicating that you will not be able to trade for twenty-four (24) hours.

El Dorado will not allow you to carry out transactions that exceed your available balance.

El Dorado may at any time modify, suspend, cancel or delist one or more of the Crypto Assets, wallets or networks available on the Platform. For these purposes, El Dorado will send, by any written means, a notice informing the date on which the Crypto Asset will be closed or delisted and, therefore, on which the wallets associated with that Crypto Asset will be closed. The User must follow the recommendations, including withdrawing the available balance in the wallet that will no longer be supported, failing which they will lose it.

4. What should I take into account when publishing ads?

To publish a buy or sell ad on El Dorado you must complete Identity Verification on the Platform and have read and accepted these Terms. You must also comply with the following considerations:

  • Respect and honor the price set in the ad.
  • Keep the negotiation within the Platform at all times.
  • Be clear and concise about payment methods and negotiation conditions.
  • Publish ads only in the fiat currencies enabled under Section 2, without including BRL or BRL payment methods.
  • Keep exchange rates in line with market reality.
  • Respect your counterparty during the negotiation.

El Dorado reserves the right to remove or pause ads it considers fraudulent or that violate the considerations set out above.

5. What should I take into account when publishing ads as a seller or market maker?

To publish a sell ad on El Dorado you must:

  • Complete at least five (5) transactions as a buyer.
  • Trade with at least three (3) different sellers or market makers.
  • Have transacted a volume of at least 250 USDT.
  • Reach compliance level 2 (see Annex B).
  • Complete seven (7) days of active trading on the Platform.

If the system detects that an Advertiser has been inactive for more than twelve (12) hours, their ads will no longer be displayed until they are back online. Ads will be automatically paused if the Advertiser has not shown activity in the application for a period of twenty-four (24) hours.

6. What are the dispute resolution criteria?

Users may initiate the dispute process at any time they consider that they disagree with an ongoing transaction. When initiating it, the User must contact the support team to inform it of the dispute and explain their case.

The Dispute Resolution team will diligently request proof of payment, static screenshots and/or screen recordings, chat messages and any other form of verification that allows the conflict to be resolved.

Resolution criteria in favor of the Advertiser:

  • The Advertiser duly made the payment to the agreed account and following the instructions provided by the party who initiated the dispute.
  • The party who initiated the dispute does not provide reliable evidence that they did not receive the payment.
  • The party who initiated the dispute does not respond.

El Dorado may resolve or cancel a disputed transaction in favor of either party taking into account the following criteria:

  • The Advertiser has not made full payment for the Crypto Assets.
  • The Advertiser sent a fake receipt.
  • The payment was made without following the terms and conditions previously established by both parties.
  • A payment method was used that is not supported by El Dorado or that was not the one established in the exchange.
  • The payment was made in BRL or in a fiat currency not enabled for the transaction, in accordance with Section 2.
  • One of the parties acts with the intention of keeping funds sent that did not comply with the terms and conditions.

The process of collecting information and evidence to resolve the conflict may take up to forty-eight (48) hours, depending on the complexity of each case.

If you disagree with the resolution of the dispute, you may appeal it by contacting soporte@eldorado.io by email. You will have a maximum of three (3) business days to submit the information and evidence, and the team will have ten (10) business days to verify the case.

7. How much will You pay El Dorado?

7.1. Types of fees

El Dorado has a system of variable fees based on the value of the transaction you carry out, which are:

a) Fees for regular transactions within the Platform: advertiser fee and beneficiary fee.

b) Fees for withdrawals to external wallets: applicable to withdrawals made through the networks available on El Dorado:

  • Arbitrum
  • Tempo
  • Ethereum
  • Optimism
  • Polygon
  • BNB Chain
  • Tron

7.2. Prior information to the User

The aforementioned fees may be variable and, in any case, will be made known to the User before each transaction is confirmed. It is the User’s responsibility to review them before initiating the corresponding transaction.

7.3. Collection of fees

In order to secure the Consideration for the Services provided, upon completion of a transaction, El Dorado will deduct from your account the Consideration and any applicable Network Fee or Gas Fee. This deduction will be automatically reflected on the Platform.

7.4. Fee updates

El Dorado reserves the right to update the value of the Consideration at any time. The updated value will be reported to the User in accordance with Section 7.2 and will only apply to transactions confirmed after such update.

7.5. Promotional fees

Notwithstanding the foregoing, El Dorado reserves the right, at its sole discretion, to offer lower differential fees as a promotional measure for certain users, without this giving rise to any liability for such differences.

8. What happens if the transaction is not completed?

El Dorado will only charge the Consideration if a transaction is successfully completed through the Platform. If it is not completed, you will not be charged anything.

9. Specific obligations of the User in the P2P Service

In addition to the general obligations set out in these Terms, the User undertakes to:

  • Allow El Dorado to deduct the Consideration from each successfully completed transaction.
  • Answer directly to the Users with whom they enter into Crypto Asset purchase and sale contracts for the obligations arising from them.
  • Not make or accept payments in BRL within the P2P Service.
  • Carefully read the terms and conditions published by each merchant in their ads and comply with them. It is your sole responsibility to read and understand those conditions before opening an order. If you do not comply with them and a dispute is opened, you could lose it for not following the merchant’s instructions. If those conditions include any that are discriminatory, disrespectful or require the payment of an additional fee, contact us and report the situation.

10. El Dorado’s liability in the P2P Service

El Dorado shall not be liable for Users’ breaches of the Crypto Asset purchase and sale contracts arising from the use of the Platform. El Dorado is not responsible for the suitability of your counterparty and only makes available to the buyer and the seller the space and technological infrastructure to carry out the transaction.

El Dorado undertakes to unfreeze and transfer the Crypto Assets to the buyer once the seller marks the transaction as paid, or when the sending User gives the order to remit to the beneficiary.

CHAPTER II – SEND WITH ELECTRONIC PAYMENT PROVIDER

1. Acceptance of the Terms of the Service

By using the Send with Electronic Payment Provider feature (the “Service”), the User accepts this Chapter, as well as the terms and conditions of the Electronic Payment Provider, which will be made available to the User on the Platform before each transaction is initiated. If the User does not agree with them, they must not use the Service.

2. Description of the Service

The Service is an El Dorado feature that allows Platform Users to:

a) On-Ramp: buy USDT with BRL through the Electronic Payment Provider, and receive USDT in their El Dorado wallet.

b) Off-Ramp: sell USDT from their El Dorado balance through the Electronic Payment Provider, and receive BRL through the selected payment method.

Both transactions are carried out according to the parameters entered by the User, including the amount and the selected payment method.

The Electronic Payment Provider is duly authorized by the Banco Central do Brasil (BCB), as the regulatory and supervisory authority of Virtual Asset Service Providers, to provide On-Ramp and Off-Ramp services, under the regulations in force on the matter.

El Dorado only makes its platform available to facilitate access to the Service. El Dorado does not participate in the fiat payment transaction, does not carry out currency exchange or receive fiat money directly from Users, and is not an authorized exchange agent. The price shown on the Platform corresponds to the Electronic Payment Provider’s rate and may vary at the time the order is initiated. It is the User’s responsibility to verify the price before confirming the transaction.

3. Terms and conditions of the Electronic Payment Provider

By using the Service, the User also accepts the terms and conditions of the Electronic Payment Provider, which will be visible to them on the Platform before initiating the transaction. It is the User’s responsibility to read and understand them before confirming any transaction. In the event of conflict between these Terms and those of the Provider, regarding the execution of the fiat payment transaction, those of the Provider shall prevail.

4. Processing of Identity Verification (KYC) information

By accepting these Terms, the User expressly authorizes El Dorado to share with the Electronic Payment Provider the information and documentation associated with their Identity Verification (KYC) process, so that the Provider can carry out its own verification and due diligence process, in accordance with the regulations applicable to it.

The User also acknowledges and accepts that:

a) The Provider may, if it deems it necessary, request additional information or documentation from them, directly or through El Dorado, which the User undertakes to provide in a timely manner.

b) Their transactions through the Service are subject to the approval of their KYC by the Provider, in accordance with its own criteria and policies.

c) The approval, rejection, limitation or request for additional information by the Provider is its sole responsibility and not El Dorado’s. El Dorado has no involvement in that decision and shall not be liable for any damages that may arise from it.

5. Availability

The Service will be available only to Users residing in Brazil and for transactions in BRL. El Dorado reserves the right to expand, modify, suspend or restrict the Service at any time and without prior notice, for operational, regulatory, compliance or security reasons.

6. Eligibility

To access the Service, the User must:

  • Be of legal age.
  • Have an active El Dorado wallet with the KYC verification level required for this modality.
  • For Off-Ramp, have USDT available in their El Dorado balance.

7. Operation

7.1. USDT purchase and sale transactions with BRL will be carried out exclusively through the Electronic Payment Provider, since the P2P Service is not enabled for BRL transactions.

7.2. Before confirming the transaction, the Platform will show the User the reference price, the amount to be received and the Provider’s terms and conditions.

7.3. On-Ramp (purchase of USDT with BRL). To buy USDT with BRL, the User must follow these steps:

a) Select on the Platform the option to buy USDT with BRL and indicate the amount in BRL they wish to pay or the amount in USDT they wish to receive.

b) If it is the first time they use the service, accept the terms and conditions of the Electronic Payment Provider and authorize El Dorado to share with the Provider the identity verification information and documentation necessary to provide the service.

c) Review the quote: the reference price, the applicable fees and the final amount of USDT to be received. The quote is provided by the Electronic Payment Provider and has a limited validity, which will be indicated on the Platform.

d) Confirm the transaction within the quote’s validity period. If the quote expires or is updated before the User confirms, or at the same moment they confirm, the order will be automatically cancelled, at no cost to the User, and a new quote must be requested. Once the transaction is confirmed, the Platform will display the Pix payment instructions (QR code or “copia e cola” key) generated by the Provider.

e) Make the Pix payment within the period indicated in the instructions, from a bank or payment account held by the User and registered under their own CPF.

f) Once the Provider confirms receipt of the payment, it will execute the conversion and send the USDT to the User’s El Dorado wallet. Before crediting them to the User’s balance, El Dorado may carry out the applicable compliance checks on the funds received.

g) If the payment is made outside the indicated period, for an amount different from that of the order, or from an account not held by the User, the Provider may reject the transaction and return the funds to the source account, in accordance with its own terms and conditions.

7.4. Off-Ramp (sale of USDT for BRL). To sell USDT and receive BRL, the User must follow these steps:

a) Select on the Platform the option to sell USDT for BRL and indicate the amount in USDT they wish to sell or the amount in BRL they wish to receive.

b) If it is the first time they use the service, accept the terms and conditions of the Electronic Payment Provider and authorize El Dorado to share with the Provider the identity verification information and documentation necessary to provide the service.

c) Indicate the destination Pix key, which must correspond to an account held by the User and registered under their own CPF.

d) Review the quote: the reference price, the applicable fees and the final amount in BRL to be received. The quote is provided by the Electronic Payment Provider and has a limited validity, which will be indicated on the Platform.

e) Confirm the transaction within the quote’s validity period. If the quote expires or is updated before the User confirms, or at the same moment they confirm, the order will be automatically cancelled, with no USDT debited and at no cost to the User, and a new quote must be requested. By confirming a valid order, the User authorizes El Dorado to debit the USDT from their balance and send it to the Provider.

f) Before sending, El Dorado may carry out the applicable compliance checks on the transaction and on the Provider’s wallet to which the funds will be sent.

g) Once the USDT is received, the Provider will execute the conversion and transfer the BRL via Pix to the account indicated by the User.

h) If the transaction cannot be completed for reasons attributable to the Provider or to the destination account, the USDT or its equivalent will be returned to the User’s El Dorado balance, in accordance with the Provider’s terms.

7.5. Crediting time: [TBD]. In all cases, the actual processing time may vary depending on the operational availability of the Provider and of local financial institutions, maintenance, technical incidents or regulatory compliance requirements.

8. Payment Method

The payment methods enabled for BRL transactions will be those that El Dorado and the Provider enable for that purpose, and will be reported on the Platform. The use of third-party payment methods is not permitted.

El Dorado reserves the right to modify the enabled payment methods at any time. Such modifications will be communicated through the Platform.

9. Operational Limits

El Dorado will inform the User in a timely manner of the existence of any operational limit on their account. The approval of any increase will be subject to the evaluation of the Electronic Payment Provider at its sole discretion, without any obligation to grant such increase.

10. Fees

Fees will be shown at the time the transaction is confirmed on the Platform. The User’s acceptance of the transaction constitutes their acceptance of any fee or charge applied to it.

11. Monitoring

Transactions carried out through the Service are subject to internal monitoring by El Dorado and the Provider. In the event of alerts, unusual behavior or for operational or regulatory needs, El Dorado or the Provider may require additional information from the User before processing or releasing a transaction. The User undertakes to respond to such request in a timely manner and within the terms indicated.

12. User Responsibilities

The User is responsible for verifying that the data entered in each transaction is correct before confirming any transaction. The User undertakes to use the Service exclusively with funds of lawful origin and not to use it for activities that contravene applicable law.

The User declares and guarantees that the information provided within the framework of the Service is true, complete and up to date. Breach of this obligation releases El Dorado from any liability arising from the transaction and may result in the immediate suspension of the Service, the withholding of funds and the exercise of the corresponding legal actions.

13. Requests, Complaints and Claims

The User may submit requests, complaints or claims related to the Service through the service channels enabled by El Dorado. When the request concerns the execution of the fiat payment transaction or the approval of the KYC by the Provider, El Dorado may forward it to the Provider. If the response falls to El Dorado, it will be answered within fifteen (15) business days following its receipt.

FINAL PROVISIONS

The following provisions apply to these Terms in their entirety.

1. What obligations do You acquire by accepting these Terms?

  • Have legal capacity to carry out Crypto Asset transactions.
  • Complete the Platform forms with true and reliable information.
  • Not violate any law, regulation, decree or circular under the applicable law.
  • Assess the risks of each of the transactions you carry out through the Platform and make an informed decision about them, since El Dorado is not a financial services or advisory platform.
  • Have no links to illicit activities, money laundering or terrorist financing.
  • Use only resources derived from legitimate activities.

2. What obligations does El Dorado acquire by accepting these Terms?

  • Provide the infrastructure for the proper functioning of the Platform.
  • Respond in a timely manner to your requests, complaints or claims.
  • Make its best efforts to ensure the security of transactions through the Platform.
  • Keep your information confidential until the purchase and sale contract has been entered into.
  • Inform the relevant authorities of any irregularity that arises or that Users commit through the use of the Platform.

3. What is El Dorado’s liability under this Agreement?

El Dorado is not responsible for fluctuations in the value of Crypto Assets and does not guarantee stability in their value, nor returns on the Crypto Assets you acquire.

You accept and acknowledge that you may not claim from El Dorado for any damage or loss you suffer from the use of the Platform.

Users accept that the Services provided by the Platform are an “as is” service, which means that there is no warranty whatsoever, express or implied, regarding the provision of the Services. No information that Users have received by any means from El Dorado or any of its representatives or officers, in addition to these Terms, shall engage El Dorado’s liability or constitute any warranty regarding the Services. For this reason, the only remedy Users will have in relation to the Services provided by the Platform will be to stop using it.

El Dorado shall not be liable:

  • When Users provide incorrect, inaccurate, outdated or false identity data or information. This includes, without limitation, damages of any nature that may be due to the impersonation of a third party by a User in any type of communication or transaction carried out through the Platform. Notwithstanding the foregoing, El Dorado undertakes to make its best efforts to prevent such situations from occurring.
  • When the Services are suspended, interrupted or cut off due to corrective or preventive maintenance of the Platform.
  • When urgent modifications necessary on the Platform must be made.
  • For Users’ breach of the Crypto Asset purchase and sale contracts entered into between them.
  • For loss of profits from transactions not carried out by Users, lost earnings, pecuniary losses or loss of information.
  • For any cost, loss or damage caused to Users as a result of the improper use of the Services.
  • For any error, interruption or delay in data transmission.
  • For illegal actions committed by Users.
  • For the loss of value of Crypto Assets.

In any case, El Dorado’s liability shall be limited to 10,000 USDT.

4. What happens if the Platform fails?

If you have any problem with the Platform, you may send us a communication at soporte@eldorado.io indicating the problem, and we will make our best efforts to help you solve it.

El Dorado is not responsible for any damage, loss or harm caused by Platform failures arising from the server or the Internet. Nor shall El Dorado be liable for any virus that may infect Users’ equipment as a result of accessing or using 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, Internet failures or 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. El Dorado shall not be responsible for any error or omission that Users commit within the Platform.

5. Do you have any warranty for the Services?

Users accept and acknowledge that El Dorado is an intermediation platform that has no relationship with Users other than these Terms. Therefore, it is not in a position to guarantee the suitability, truthfulness or effectiveness of the information provided by Users, nor can it guarantee the suitability of your counterparty. Notwithstanding the foregoing, El Dorado will make its best efforts to validate the information sent by Users.

In addition, Crypto Assets fluctuate constantly and, therefore, El Dorado cannot guarantee that the Crypto Assets you hold on the Platform will retain their value over time.

6. What is your responsibility under this Agreement?

You will be solely responsible to other Users for compliance with the obligations you acquire by entering into the corresponding contracts and by accepting these Terms.

7. What happens if El Dorado or You breach your obligations?

You will hold El Dorado harmless from any claim and any administrative, judicial or extrajudicial proceeding arising in connection with your obligations under this Agreement. If El Dorado must bear any cost arising from any administrative, judicial or extrajudicial claim initiated by a User or any other third party, El Dorado may deduct from your account the equivalent in Crypto Assets of such costs, without requiring your prior authorization.

If You breach any of your obligations towards El Dorado, you will be liable for the damages you cause to it, under the terms established by law. Likewise, if El Dorado breaches any of its obligations towards you, El Dorado will be liable for the damages it causes you, under the terms established by law.

8. What should you do if you have a request, complaint or claim?

Requests, complaints or claims related to the Platform’s Services may be filed through the El Dorado website, using the complaints and claims button. The foregoing is without prejudice to the provisions of Section 13 of Chapter II for requests related to the Provider.

Users, or a third party on their behalf, after identification, may file their direct claims free of charge.

El Dorado will record and individualize the claim by assigning it a number, which we will inform you of through any communication channel we consider suitable.

El Dorado may forward the request, complaint or claim to a third party when it concerns information or a service not provided directly by El Dorado.

If the response falls to El Dorado, we will respond within fifteen (15) business days following its receipt.

9. How do we protect intellectual property?

The Platform, the solutions and the designs, graphics, texts, images, distinctive signs, source code, object code and other content you have access to on the Platform are owned by El Dorado and are protected by intellectual and industrial property. The access El Dorado gives you to the Platform does not imply any assignment of industrial property rights and/or copyright over it. 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 causes.

10. How will we handle your personal data?

During the provision of the Services, El Dorado will ask you for certain personal data, for which you must accept El Dorado’s personal data processing policy, available at: https://eldorado.io/legal/privacy-policy

El Dorado undertakes to comply with the data protection rules of all the countries where it operates.

11. What is El Dorado’s relationship with external websites?

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 or legality).

El Dorado is not responsible for any of these external websites linked from its website. This includes the information, opinions expressed, advice or statements, advertising material and accessibility of such sites, as well as any possible consequences of their use, such as damage, losses, failures and problems. You are solely responsible.

External websites have their own terms of use and policies. Before using their services, content, information or any other material, you must review their policies, rules, terms and regulations. 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.

12. What additional conditions apply when the Platform is accessed through a mini app in another application?

In cases where the Platform’s Services are offered through integrated environments or embedded third-party 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 their behalf, those steps or transactions necessary for the proper functioning of the selected channel. This includes, but is not limited to, Crypto Asset exchanges (Swap) and transfers between blockchain networks (Bridge).

By virtue of the foregoing, by accepting these Terms, the User grants El Dorado an express mandate with representation to act on their behalf. This mandate covers the execution of Swap and Bridge transactions, as well as any other actions, steps or transactions that, reasonably and depending on the technical or functional circumstances of the channel used, may be required in the future to ensure the continuity, effectiveness and proper provision of the Services requested through such integrated environments or embedded solutions.

Since these integrations seek to offer agility in transactions, El Dorado may enable the automatic release feature. With this feature, once the time the Market Taker has to mark the order as received has elapsed, the funds are released automatically, even if they have not been marked as received. It is the User’s sole responsibility to verify the funds received and mark the order as paid within the time set for that purpose. Funds will never be released automatically before this time has elapsed.

El Dorado shall not be liable, in any way, for funds released through this feature. If the User states that they have not received the payment, they must file a request as provided in these Terms. El Dorado reserves the right to review the request and make a decision on the return of funds.

13. How long does this Agreement last and when can it be terminated?

This Agreement will remain in force for as long as you use the Services. If you wish to terminate it, you must stop using the Services and cancel your account on the Platform. If you want us to delete your information from our database, you must send us a communication to that effect. In any case, we will not be able to delete some of your personal data due to legal requirements.

El Dorado may stop providing its Services to you and suspend your access to the Platform if you breach these Terms or if El Dorado identifies that you do not comply with its security policies.

14. What law will apply to this Agreement?

  1. These Terms and Conditions, and any relationship between the User and El Dorado Labs PY Inc. (“El Dorado”) arising from them, are governed by and construed in accordance with the laws of the Republic of Panama, excluding its conflict of laws rules.
  2. If the User resides in the Federative Republic of Brazil, nothing in these Terms and Conditions limits or excludes the rights granted to them by the mandatory Brazilian consumer protection rules, in particular Law No. 8,078/1990 (Consumer Protection Code), or the rights granted to them by Law No. 13,709/2018 (General Personal Data Protection Law) regarding the processing of their personal data. In the event of conflict between these Terms and Conditions and such rules, the latter shall prevail to the extent necessary to guarantee those rights.
  3. The exchange services and virtual asset services provided to the User in Brazil are executed by AVENIA SOCIEDADE PRESTADORA DE SERVICOS DE ATIVOS VIRTUAIS LTDA, under its own authorization and in accordance with its own terms and conditions, which the User accepts separately and which are governed by the law indicated therein. El Dorado is not a party to those services nor does it provide them.

15. Where will the Parties receive notices?

You will receive notices at the email address or mobile phone number you registered in the registration form.

El Dorado will receive notices at soporte@eldorado.io.

16. How will we resolve disputes arising from this Agreement?

DISPUTE RESOLUTION

  1. Handling of claims. The User may submit any inquiry or claim through the application’s support channels or by email to soporte@eldorado.io. El Dorado will respond within fifteen (15) business days following its receipt. This procedure is voluntary and is not a prerequisite for the User to go to the competent administrative or judicial authorities.
  2. Users residing in Brazil. A User residing in Brazil may, at their choice, bring any action arising from these Terms and Conditions before the courts of their domicile, pursuant to Article 101, item I, of the Consumer Protection Code, or go to the competent consumer protection bodies. Actions brought by El Dorado against a User residing in Brazil will be filed before the courts of the User’s domicile.
  3. Arbitration. No provision of these Terms and Conditions obliges the User to submit their disputes to arbitration. The parties may only resort to arbitration if, once the dispute has arisen, the User expressly accepts it in writing.

17. How are these Terms modified?

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 their responsibility to periodically review the application to learn about such changes. Continued use of the Platform, or express acceptance within it, will be deemed full and binding acceptance of the new conditions of the Services.

These Terms, as well as any of their annexes, shall prevail over any other prior agreement, verbal or written, entered into regarding the subject matter of the Agreement.

Last updated: October 28, 2026.

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EL SUEÑO LATINO:

El Dorado Dollar Dream $