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For the purposes of these Terms and Conditions (the "T&C"), the following terms shall have the meaning set forth below:
User: A natural person holding an active account with El Dorado.
Platform: El Dorado's App or Web App.
Self-Custodial Wallet: A Platform service that allows the User to make on-chain deposits and withdrawals/transfers of Crypto Assets, whereby the User alone manages and controls 100% of such funds.
Crypto Asset: USDT (Tether) and/or USDC (USD Coin), or other digital assets that El Dorado enables for this service.
Network: The blockchain network through which a Crypto Asset transaction is processed (for example, Ethereum, Arbitrum, Tron, among others enabled by El Dorado).
Deposit: A transaction whereby the User sends Crypto Assets to their Self-Custodial Wallet within the Platform.
Withdrawal / Transfer: A transaction whereby the User sends Crypto Assets from their Self-Custodial Wallet to an External Wallet.
External Wallet: A Crypto Asset address or account that does not belong to El Dorado's Platform, to or from which the User carries out Withdrawals or Transfers.
Secure Access / Passkey: Authentication technology based on cryptographic keys that allows the User to securely confirm their transactions.
The Self-Custodial Wallet is a Platform service offered by El Dorado that allows the User to make on-chain deposits and withdrawals/transfers of Crypto Assets (USDT/USDC), without El Dorado having access to, control over, or custody of such funds. The User is solely responsible for the management, security, and disposition of their Crypto Assets.
Through the Self-Custodial Wallet, the User may:
To access and use the Self-Custodial Wallet, the User must:
4.1 The User may make Deposits and Withdrawals/Transfers of Crypto Assets exclusively on the Networks and in the Crypto Assets enabled by El Dorado, as indicated on the Platform's interface or through its official communication channels.
4.2 Every Withdrawal/Transfer transaction must be confirmed by the User through Secure Access (Passkey). Such confirmation constitutes the User's express consent to carry out the relevant transaction.
4.3 It shall be the User's sole responsibility to verify that the information associated with each Deposit and Withdrawal/Transfer is correct prior to confirming the transaction.
4.4 Once a transaction has been confirmed through Secure Access (Passkey), it may not be reversed, modified, or cancelled.
4.5 All transactions are initiated, authorized, and executed exclusively by the User. As the Self-Custodial Wallet is a self-custodied service, El Dorado does not intervene in, execute, or control any transaction carried out by the User, and does not have access to the User's funds, the User being solely responsible for the transactions they carry out.
4.6 Any fee, network fee (gas fee), or other cost associated with a Deposit or Withdrawal/Transfer transaction will be disclosed to the User prior to confirming such transaction, through the Platform's interface.
5.1 The Self-Custodial Wallet service allows transactions to be confirmed through Secure Access (Passkey). When configuring their Passkey, the User's device automatically generates two cryptographic keys: a public key, which is sent to and stored on El Dorado's servers, and a private key, which remains securely stored on the User's device through the key manager available on it. The private key is never shared with or accessible to El Dorado, and, accordingly, the User is fully responsible for safeguarding the private key.
5.2 To confirm a transaction, the User must authenticate using their fingerprint, Face ID, PIN, or physical key, depending on the method configured on their device. The User is solely responsible for maintaining physical and logical control over their device and private key.
5.3 Access to, or confirmation of, a transaction carried out through a linked Secure Access shall be deemed, for all legal purposes, an action carried out directly by the account holder.
5.4 El Dorado shall not be liable for any loss of access resulting from the loss, theft, damage, or replacement of a device, where the User has not previously completed the recovery process indicated by the Platform.
6.1 El Dorado may reject a Deposit for any reason, including specifically for regulatory compliance and risk analysis reasons. In such cases, El Dorado shall have a maximum period of up to fifteen (15) business days, counted from the identification of the rejection, to send the corresponding Crypto Assets to an External Wallet provided by the User.
6.2 In the event that the External Wallet provided by the User for a Withdrawal/Transfer likewise triggers compliance or risk alerts, or is rejected for any reason, El Dorado will review and determine the process to be followed in that particular case, which may include, among other measures, the retention and freezing of the corresponding funds. The User understands and agrees that the application of such measures shall not give rise to any liability on the part of El Dorado.
The User is solely responsible for ensuring that any deposit made into their wallet on the Platform is carried out exclusively in the Crypto Assets and Networks expressly supported by El Dorado, as indicated on the application's interface or through official communication channels.
Any deposit involving unsupported Crypto Assets or the use of Networks not enabled by the Platform shall 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 funds, nor for errors resulting from the incorrect use of incompatible assets or networks.
This includes, by way of example and not limitation:
El Dorado does not assume any obligation of recovery or compensation in these cases. Nevertheless, it may, at its sole discretion and on an exceptional basis, attempt to recover the funds involved, provided that the value of the erroneous deposit is equal to or greater than ten United States dollars (USD 10, or its equivalent in USDT) and that the User has formally reported the incident.
This process is conditioned upon:
If El Dorado decides to attempt recovery, a fee equivalent to three percent (3%) of the value of the erroneous deposit shall apply, which in no case shall be less than five United States dollars (USD 5, or its equivalent in USDT), plus the applicable network fee. The total amount will be deducted from the recovered value prior to its return to the User.
El Dorado shall 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 the User whether or not it will proceed with the recovery attempt.
Accordingly, the User is advised to carefully verify, before making any deposit:
The User represents that decisions related to the use of the Self-Custodial Wallet are made autonomously and at their sole discretion, without any financial or investment advice being provided by El Dorado, and states that they are aware of and fully accept the content of Annex D.
El Dorado acts solely as a technological facilitator enabling the User to access this self-custodied wallet service. The User's Crypto Assets are NOT held in custody by El Dorado; El Dorado does not intervene in, execute, or control any transaction carried out by the User, the User being solely responsible for the transactions they carry out.
Accordingly, except as expressly provided in these T&C, El Dorado shall not be liable for:
The User agrees to:
The Self-Custodial Wallet will be available only in the countries determined by El Dorado, which will be communicated through the Platform. El Dorado may expand or restrict the geographic areas of availability based on technical, operational, or regulatory criteria.
These T&C shall be governed by and construed in accordance with the laws of the Republic of Panama.
Where a dispute arises between El Dorado and the User in connection with these T&C, the parties shall seek to resolve it through a direct settlement phase, for a period of thirty (30) calendar days counted from the date on which one party notifies the other of the existence of the dispute.
Once that period has elapsed without the parties having reached an agreement, the dispute shall be submitted to the ordinary courts of the Republic of Panama.
The User may submit petitions, complaints, claims, or suggestions related to the Self-Custodial Wallet through the service channels made available by El Dorado. Requests must be submitted with sufficient information to allow for their proper review. El Dorado will respond within fifteen (15) business days following receipt.
For questions or support, please contact:
Any amendment, update, or adjustment to the conditions of this service 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 be informed of such changes. Continued use of the Platform, or express acceptance within it, shall be deemed full and binding acceptance of the new service conditions.
These Terms and Conditions, together with any of their annexes, shall prevail over any prior agreement, whether verbal or written, entered into with respect to the subject matter of the Agreement.
El Dorado reserves the right to expand or reduce the catalog of supported Crypto Assets and Networks without prior notice, it being the User's responsibility to verify such availability on the Platform before carrying out any transaction.
Last updated: August 4, 2026.
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