TERMS AND CONDITIONS OF USE
Welcome to UnblockPay!
This document establishes the general terms and conditions for the use of the services and products (“Services”) offered by UnblockPay (“UnblockPay” or “Platform”), through its technological infrastructure and digital interfaces, including its institutional website, proprietary API, operational dashboards, and other integrated tools.
The Terms of Use ("Terms") describe the general conditions applicable to any partner legal entity and, in certain cases, to end users who access the Services through these integrations. These Terms bind all activities developed and services offered by UnblockPay, made available through the website (https://www.unblockpay.io/) and its subdomains, integration API, programs, extensions, and other technological interfaces.
To use the Services, the Customer or End User must expressly and unreservedly accept these Terms. By accepting, you declare that you have read, understood, and agree to fully comply with the provisions contained herein, in accordance with applicable law, including Law No. 14,478/2022 (Legal Framework for Virtual Assets), rules of the Central Bank of Brazil, and other relevant regulations. If you do not agree with any provision, you should not continue to use the Platform or proceed with the technical integration process.
The Terms of Use are, therefore, a legally binding document that establishes rights and obligations between UnblockPay, its Customers, and, when applicable, End Users served indirectly through integrations. These Terms also incorporate, where applicable, other agreements entered into between the parties, such as commercial partnership agreements, API integration agreements, or complementary instruments.
UnblockPay reserves the right to review and modify these Terms at any time, and may update or change its provisions to reflect operational, technological, regulatory, or security changes. Substantial changes will be communicated to Customers in advance, and continued use of the Platform will be considered tacit acceptance of the new Terms.
BY USING UNBLOCKPAY'S SERVICES, THE USER ACKNOWLEDGES THAT THEY HAVE READ, UNDERSTOOD, AND AGREE TO ALL THE PROVISIONS SET FORTH HEREIN. IF YOU DO NOT AGREE WITH THE TERMS, UNFORTUNATELY YOU WILL NOT BE ABLE TO USE OR ACCESS UNBLOCKPAY SERVICES. PLEASE READ THEM CAREFULLY 😊
UnblockPay services are available exclusively to persons who have the legal capacity to contract and who are over 18 (eighteen) years of age, in accordance with applicable law. Those who do not have such capacity or who have been temporarily or permanently suspended or disabled from the platform may not use the Services. In the case of a legal entity, the Customer must have the necessary powers to represent it and bind it to comply with these Terms. UnblockPay may request, at any time, supporting documentation to verify the Customer's capacity or powers to use the Services.
Key Definitions:
For a better understanding of these Terms, it is important to understand some essential definitions. When reading the terms described below, whether in uppercase or lowercase, plural or singular, bold or not, they should be interpreted as follows:
API (Application Programming Interface): UnblockPay's technological interface that allows Customers to integrate their systems with the Platform to issue payment orders, perform on-ramp and off-ramp operations, and track transactions automatically.
Digital Assets: Digital representations of values, rights, or assets that can be created, stored, transferred, and traded electronically, including cryptocurrencies, tokens (such as Stablecoins), and other assets registered on blockchain or similar digital systems.
Blockchain: Distributed and immutable digital record technology that stores transactions in connected blocks, ensuring transparency and security without intermediaries.
Digital Wallet: Application or device that allows the Client or End User to store, send, and receive digital assets in a decentralized manner and managed autonomously by the Client or custodied by the Platform itself when used.
Client: Legal entity that directly contracts UnblockPay's services, integrating the Platform's technological infrastructure, to provide functionalities to its own customers (End Users), whether individuals or legal entities.
Cryptocurrencies: Decentralized digital currencies that use cryptography to secure transaction records, operating on Blockchain networks, are used as a medium of exchange, store of value, or as a utility medium for interacting with smart contracts, such as Stablecoins.
Smart Contract: Self-executing programs stored on the blockchain that automatically execute predefined terms and conditions between the parties.
Dashboard: Digital panel provided by UnblockPay that allows the Customer to view and track, in real time, information about On-ramp, Off-ramp, payments, stablecoin balances, and order status in a centralized and intuitive way.
On-ramp: Process of converting fiat currency (e.g., BRL, USD) into Stablecoins with settlement in a digital wallet indicated by the Customer or End User, through the UnblockPay infrastructure in a Digital Wallet indicated by the Customer or End User.
Off-ramp: Process of converting stablecoins (e.g., USDT, USDC) into fiat currency, with settlement in a bank account indicated by the Customer or End User.
Partner: Legal entity contracted by UnblockPay to provide support or complementary services that are not essential to the Platform's main operation, such as technological support and consulting, specialized consulting, or other ancillary activities. Although not subject to specific licensing or regulation, these services play an important role in supporting UnblockPay's operations.
UnblockPay Platform or “Platform”: Digital environment provided by UnblockPay, which brings together the technological infrastructure necessary for the execution of payment services with crypto assets. Through the Platform, each Customer accesses a personalized dashboard with a unique login, which allows them to issue payment orders, convert between fiat currencies and stablecoins, monitor transactions in real time, and use and configure integration features via API. The Platform also incorporates authentication, security, and monitoring mechanisms, ensuring efficiency and regulatory compliance.
Service Provider: Legal entity contracted by UnblockPay to provide essential services to its operation, including, but not limited to, custody of digital assets, technological infrastructure, payment services, settlement, or transmission of funds. These providers may be regulated or unregulated, and it is up to UnblockPay to adopt due diligence criteria to ensure compliance, operational security, and mitigation of associated risks.
Services: The services offered by our Platform, as described in these Terms of Use.
Stablecoin: A digital asset backed by fiat currency, used by UnblockPay as a means of settlement in its payment and conversion flows.
Terms of Use: This document establishing the rights and obligations related to the use of the Platform.
Token: Digital unit issued on a blockchain that represents a specific asset, right, or utility within a digital ecosystem. Tokens can be used for transactions, access to services or resources, or to represent digital or physical assets in a tokenized form.
Onchain Transaction: Transaction recorded and validated directly on the blockchain, becoming a permanent part of the distributed public record.
UnblockPay or “We”: Legal entity indicated in item 1.1 of this Term.
End User: Individual or legal entity, customer of the Client, who accesses and uses the services enabled by the UnblockPay infrastructure through the Client's application, platform, or system.
1. PLATFORM OWNERSHIP
1.1. Platform Ownership. The Platform belongs to UNBLOCK SERVICOS DIGITAIS LTDA., registered with CNPJ No. 58.444.469/0001-08, headquartered in the city of Rio de Janeiro, state of Rio de Janeiro, at Av. das Américas, No. 700, Block 6, Room No. 236, Barra da Tijuca, ZIP code 22640-100.
2. APPLICATION OF THE TERMS OF USE
2.1. Scope. These Terms of Use bind all activities developed and services offered by UnblockPay, which include the institutional website (https://www.unblockpay.com/) and its subdomains, the proprietary API, the operational dashboard, as well as any other programs, modules, applications, or extensions made available by the Platform.
2.2. Legal Nature. The Terms of Use constitute a binding legal document that establishes rights and obligations between UnblockPay, its Customers, and, when applicable, End Users who access the services through these integrations. These Terms integrate and complement other contracts or instruments that may be signed between the parties, producing effects for all legal purposes.
2.3. Contract. Depending on the level of customization of the contracted services or integration via API, a specific contractual instrument may be signed between UnblockPay and the Customer, with its own provisions. In such cases, these Terms of Use shall apply in a supplementary and complementary manner, with the specific contract prevailing only in points of possible conflict, without prejudice to the mandatory compliance with these Terms in matters not expressly regulated.
3. SCOPE AND OPERATION OF THE PLATFORM
3.1. Dynamics and Nature of Services. UnblockPay, as a Virtual Asset Service Provider under Law No. 14,478/2022, provides technological infrastructure for the execution of flows with virtual assets, notably stablecoins, including on-ramp and off-ramp, crypto liquidity management, provisioning and administration of digital wallets through specialized providers, integration via proprietary API, and provision of an operational dashboard for issuing orders, monitoring, reconciliation, and reporting. The operations made available involve exclusively virtual assets and do not constitute regulated foreign exchange operations, do not imply the purchase and sale of foreign currency on the foreign exchange market, nor do they characterize the typical activity of a financial or payment institution. The operation is primarily focused on institutional clients, and may indirectly reach End Users through these integrations.
3.2. Compliance. UnblockPay operates in compliance with Brazilian law, observing, in particular: (i) Law No. 12,965/2014 (Civil Rights Framework for the Internet); (ii) Law No. 13,709/2018 (General Data Protection Law – LGPD); (iii) Law No. 14,478/2022 (Legal Framework for Cryptoassets); and (iv) the regulations and standards issued or to be issued by the Central Bank of Brazil (BACEN), including the guidelines of Public Consultation No. 109/2024 (prudential regulation of PSAVs) and Public Consultation No. 111/2024 (inclusion of virtual assets in the foreign exchange market).
3.2.1. Compliance with Regulatory Requirements. UnblockPay declares that it will maintain a compatible capital structure and will seek to meet minimum capital requirements or financial guarantees that may be required by the Central Bank of Brazil as a result of Public Consultations No. 109/2024, No. 110/2024, and No. 111/2024.
3.3. Service Limitations. UnblockPay does not provide banking, financial advisory, investment consulting, or any other services regulated by government financial entities. UnblockPay does not conduct foreign exchange transactions, does not broker the purchase and sale of foreign currency on the official market, and does not perform services typical of financial or payment institutions. The platform does not offer investment recommendations and does not offer returns on digital assets. Conversion operations between fiat currency and stablecoins made available on the Platform are not characterized as regulated foreign exchange operations, but rather as transactions with virtual assets. Stablecoins are not legal tender, and such operations are subject only to the specific rules applicable to crypto assets.
3.3.1. Stablecoin Parity Risks. The Customer and End User acknowledge that stablecoins, although backed by fiat currency, may lose parity (depeg) or suffer market variations as a result of external events beyond UnblockPay's control.
3.3.2. No Guarantee of Profitability. UnblockPay does not guarantee the appreciation of digital assets, profitability, financial return, or market price stability, and it is solely up to the Customer and the End User to assess the risks before conducting transactions.
3.4. Operation. UnblockPay may interrupt the Services for technical reasons, preventive or corrective maintenance, or due to events beyond its control, including those resulting from the unavailability of services provided by third parties such as liquidity providers, payment institutions, and partner exchanges. The Platform does not guarantee uninterrupted availability and is not responsible for transactions that are not processed during such periods.
3.5. Features. UnblockPay reserves the right to update, change, or modify Platform features at any time, including adding, restricting, or discontinuing features as necessary for technical, regulatory, or security reasons.
3.6. Granting of License of Use to Users. Access to the Platform, dashboard, and API is granted to the Customer under a limited, personal, non-exclusive, non-transferable, and revocable license of use, subject to full compliance with these Terms and applicable rules.
4. REGISTRATION AND ACCESS
4.1. Registration. To use UnblockPay's Services, the Customer must complete institutional registration through the Platform by filling out the registration form or other officially available channel. The Customer undertakes to provide true, complete, valid, and up-to-date data, as requested, and is responsible for its accuracy. Where applicable, End Users who access the Services via Customer integration may also be subject to the collection of registration information, as defined in UnblockPay's Privacy Policy.
4.2. Mandatory Registration Data. The registration process will be subject to Know Your Customer (KYC) and Know Your Business (KYB) rules, which may include, at a minimum, but are not limited to:
For legal entities (Customers): company name, valid CNPJ (Corporate Taxpayer ID), address, industry, as well as data on legal representatives, including CPF (Individual Taxpayer ID), identification documents, and proof of representation powers;
For individuals (End Users, when applicable via integration): Full Name, valid CPF, date of birth, address, country, phone number, email, PEP self-declaration.
4.2.1. Restrictions for Politically Exposed Persons (PEPs). The registration and use of UnblockPay Services by Individuals classified as Politically Exposed Persons ("PEPs"), under applicable law, are prohibited, unless there is enhanced risk analysis, adoption of additional due diligence measures, and express approval by UnblockPay, in accordance with its internal Compliance and Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) policies.
4.2.2. Authorizations for External Database Queries. The Customer and End User expressly and irrevocably authorize UnblockPay to perform queries, verifications, and registration validations with external public and private databases, including, but not limited to, the Brazilian Federal Revenue Service (RFB), the National Financial System Customer Registry (CCS), credit protection services (SPC/SERASA), and other legally available databases for the purposes of complying with "Know Your Customer" (KYC) and "Know Your Business" (KYB) policies, as well as Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) regulations.
4.3. Access. Access to the Platform and API and dashboard features will be granted through individual credentials (login/password or API keys), and the use of multi-factor authentication (MFA/2FA) is recommended to enhance security. The Customer and its authorized representatives are responsible for maintaining the confidentiality of their access credentials.
4.4. Restricted jurisdictions. UnblockPay will not accept registrations from restricted jurisdictions that prevent or limit the provision of its services, including, but not limited to, the United States of America ("US Persons"), as defined by applicable law. The list of restricted jurisdictions, which includes the countries listed below, may be updated at any time:
4.4.1. List of restricted jurisdictions. North Korea, Iran, Syria, Cuba, Russia, Belarus, Crimea, Venezuela, Sudan, South Sudan, Myanmar, Burkina Faso, Cameroon, Haiti, Mali, Mozambique, Nigeria, Philippines, Senegal, South Sudan, Syria, Tanzania, Turkey, Uganda, Vanuatu, Afghanistan, Libya, Somalia, Yemen, Zimbabwe.
4.5. Registration Update. The Customer and/or End User must keep their data up to date at all times. UnblockPay may request, at any time, the updating or resubmission of information and documents as a condition for continued access to the Services, in compliance with regulatory, PLD/CFT, and security requirements.
4.6. Verification. UnblockPay may request additional documents and perform compliance checks, including consultations with public, private, and regulatory authority databases, in order to mitigate the risks of fraud, money laundering, and terrorist financing (AML/CFT). Failure to comply with requests may result in account suspension or disqualification.
4.7. Restrictions and Account Cancellation. UnblockPay reserves the right to refuse, suspend, or cancel registrations of Customers or End Users, at its sole discretion, when there is evidence of data inconsistency, suspicious activity, or violation of these Terms or applicable rules. The Customer is responsible for ensuring that only authorized persons use their credentials.
4.8. Registration or Access Violation. Registrations and credentials are individual and non-transferable. The Customer and/or End User must immediately notify UnblockPay in case of unauthorized use or security breach. UnblockPay is not responsible for damages resulting from the misuse of credentials, with or without the consent of the holder, when there is no fault on the part of UnblockPay.
4.9. Duty of Care. The Customer and/or End User must: (i) adopt measures to protect against online and offline fraud; (ii) be diligent in using the Platform; and (iii) fully comply with these Terms, as well as applicable regulatory and security standards.
4.10. Awareness of risks. Upon registration, the Customer and End User declare their awareness of the risks inherent in the use of virtual assets, including volatility, the possibility of total loss of value, technical network failures, variable blockchain fees, and custody risks, as well as risks of a regulatory nature, including any blocks, restrictions, or impositions determined by competent authorities, such as the Central Bank of Brazil.
5. OPERATION AND FUNCTIONING OF SERVICES
5.1. Purpose. UnblockPay offers technological infrastructure to facilitate on-ramp (conversion of fiat currency into stablecoins) and off-ramp (conversion of stablecoins into fiat currency) operations, as well as technological integration that enables settlement in local payment systems through authorized Service Providers. Such operations result from flows with virtual assets and do not constitute contracted exchange. The main objective is to provide a secure, scalable, and efficient experience for Customers through integration via API or Dashboard.
5.2. User Profile. The Platform is intended for Customers who use UnblockPay's infrastructure to offer payment and settlement solutions to their own end customers.
5.3. Services. The main features provided by UnblockPay include:
On-ramp: Conversion of fiat currency into stablecoins, with settlement via authorized Service Providers and credit to designated wallets.
Off-ramp: Conversion of stablecoins into fiat currency, with settlement into a bank account indicated by the Client or End User.
Integration via API and Dashboard: Tools that allow the Client to issue payment orders, perform conversions between stablecoins and fiat currencies, and track the status and history of transactions in real time.
Creation, Management, and Custody of Wallets (via Third Parties): UnblockPay offers its customers the ability to create and manage digital wallets, used to support payment flows. UnblockPay does not hold digital assets in custody itself; the wallets linked to the platform are provided by a third-party provider specializing in custody. Crypto assets remain the responsibility of the third-party provider, whose infrastructure even allows the export of generated private keys, although by default, these keys remain securely stored in its cloud.
5.3.1. Irreversibility of Blockchain Transactions. Transactions carried out on blockchain networks are irreversible. Once confirmed on the network, there is no possibility of reversal, cancellation, or refund, and the Customer and End User are fully responsible for verifying the data before sending any order, including addresses and amounts.
5.4. Supported Networks for On-ramp and Off-ramp. UnblockPay only provides support for blockchains previously listed on its Platform and documented in its API, , and it is the Customer's responsibility to select the appropriate network for making deposits (on-ramp) and withdrawals (off-ramp) of crypto assets. Sending assets to addresses on unsupported networks or requesting withdrawals to incompatible networks may result in the permanent and irreversible loss of funds, and UnblockPay is not responsible for recovering these amounts.
5.4.1. Blockchain Network Updates and Replacements. UnblockPay may, at its sole discretion, change or replace the supported blockchain networks, considering technical, security, or operational efficiency factors. Changes may result from technological updates, operating costs, or network restrictions. The Customer and End User acknowledge that blockchains may undergo protocol changes, forks, or multiple versions, and that UnblockPay is not liable for losses resulting from these events.
5.4.2. Recovery of Assets on Unsupported Networks. If the User sends digital assets to addresses linked to networks not supported by UnblockPay, the recovery of these assets may not be possible. In cases where, exceptionally, UnblockPay enables such recovery, it will be subject to technical feasibility analysis, as well as the application of specific conditions and additional fees, which will be previously communicated to the User. UnblockPay assumes no obligation to perform such recoveries, and the User is solely responsible for verifying the supported networks before making transactions.
5.5. Delays and Variations in Order Processing. The User acknowledges and agrees that orders to buy, sell, or transfer crypto assets may be subject to delays, technical failures, or unavailability due to network limitations, technological infrastructure, payment intermediaries, or external factors beyond UnblockPay's control. Such situations may cause mismatches between execution and cancellation, as well as market price variations. UnblockPay shall not be liable for any financial, material, or immaterial losses, whether direct or indirect, including loss of opportunity or damages resulting from such occurrences, except in cases of proven intent or fault on the part of UnblockPay itself.
5.6. Storage and Processing of Crypto Assets. Customer funds are segregated from UnblockPay's own funds, in accordance with internal compliance and audit controls. Transactions may be subject to technical and operational settlement deadlines, in accordance with the policies of UnblockPay and its authorized Service Providers. The virtual assets and resources of Customers and End Users remain fully segregated from UnblockPay's own assets and are not used for its own purposes, investments, or guarantees unrelated to the contracted services.
5.6.1. Custody by Specialized Service Providers. Digital assets that may be held in custody by authorized, specialized Service Providers may be stored in cold storage or equivalent environments, following international security standards. UnblockPay exercises due diligence in selecting and supervising these providers, but is not responsible for failures beyond its direct control.
5.6.2. Responsibility for Private Key Management. UnblockPay does not manage or store private keys of Customers or End Users, except when expressly contracted with authorized Service Providers specializing in custody. The management and secure storage of private keys for self-custody wallets or web platform credentials are the sole responsibility of the Customer or End User. The loss or exposure of private keys may result in the permanent and irreversible loss of digital assets.
5.7. Transaction Limits. UnblockPay may establish minimum and maximum limits per transaction for Customers and End Users, considering factors such as: (i) Customer profile and transaction history; (ii) registration verification stage (KYC/KYB); (iii) internal compliance and risk management policies; and (iv) legal or regulatory requirements and geographical limits established in these Terms. These limits may be changed unilaterally, with the Customer being informed in advance in the event of significant changes.
5.7.1. Confidentiality of Limit Setting Criteria. UnblockPay is not obligated to disclose the specific criteria used to set operational limits and may keep its internal compliance procedures confidential. By accepting these Terms of Use, the User declares to be aware of the applicable limits and acknowledges that such limits may be revised periodically.
5.7.2. Communication of Changes to Limits. Whenever there are significant changes to operational limits, UnblockPay undertakes to inform Customers in advance, ensuring that such information is accessible on the platform.
5.7.3. Additional Operational Limits. UnblockPay may apply additional limits per day, month, or Customer/User profile, defined based on compliance criteria, usage history, and regulatory requirements. These limits may be adjusted periodically.
5.8. Fees. The Customer acknowledges and agrees to pay the fees applicable to the use of UnblockPay Services, including, but not limited to (i) transaction fees charged per transaction; (ii) on-ramp, off-ramp, API integration, and settlement fees; and (iii) take rate (spread) fees charged on transactions.
5.8.1. Authorization for Fee Discounts. The Customer expressly authorizes UnblockPay to automatically debit the amounts due as fees directly from the total transaction amount of the balance available in their Account. In the event of insufficient funds, UnblockPay may restrict or suspend access to certain services until the amounts are settled.
5.8.2. Consultation and Update of Fees. The amounts and conditions of the fees will always be available on the Platform and may be changed by UnblockPay at any time. Relevant changes will be communicated in advance through official channels.
5.9. Use of Third-Party Services. For efficient order execution and liquidity, UnblockPay may integrate third-party services, such as exchanges, payment institutions, liquidity providers, blockchain services, or custody providers. Although it is not responsible for failures or unavailability of these Service Providers, UnblockPay undertakes to adopt mitigation measures and reasonable diligence in the selection and supervision of the services provided. UnblockPay adopts a process of due diligence and continuous monitoring of its Partners and Service Providers, ensuring that they comply with regulatory, information security, and AML/CFT standards, in line with Central Bank guidelines and best market practices.
5.10. Listing and Delisting of Tokens. UnblockPay may list or delist tokens/crypto assets on the Platform based on technical, market, legal, and security criteria, including analysis of regulatory compliance, liquidity, and associated risks. The list of crypto assets will be reviewed periodically, which may result in inclusion or exclusion as decided by the responsible internal committee. UnblockPay will give preference to listing consolidated Stablecoins with a proven track record of liquidity, security, and adoption in the market, in accordance with applicable regulatory guidelines. In the event of delisting, Customers will be notified in advance, with a reasonable period to make withdrawals or conversions.
6. OBLIGATIONS AND RESPONSIBILITIES
6.1. Customer Responsibilities. Customers are responsible for ensuring that their activities on the Platform comply with all applicable laws, regulations, and rules in their respective jurisdictions. This commitment includes, but is not limited to, regulatory and tax, labor, personal data protection (in accordance with the LGPD), and other regulations governing their operations. In addition, the Customer agrees that:
Registration and Accuracy of Information
The Customer assumes civil and criminal liability for any and all information provided to UnblockPay, including the content of the data entered on the Platform;
They declare that they have full civil capacity and the necessary powers to adhere to these Terms and assume the obligations set forth herein;
They will correctly and accurately provide all their data for registration and contractual purposes, undertaking to keep it up to date at all times;
They will present valid and authentic documents for verification and compliance processes, as requested;
Will observe and require that its customers and End Users strictly comply with UnblockPay's regulatory and commercial guidelines, including KYC/KYB rules, as applicable, applicable fees, and other internal policies.
Not assign, sell, rent, sublicense, or transfer, in any way, their registration and/or access to the Platform.
Use of the Platform and Behavior
You agree to use the Platform exclusively for lawful purposes, in strict compliance with these Terms and applicable law;
You will behave in an ethical, honest, respectful, and good faith manner when using the services provided;
You will be diligent in using the Platform's features, fulfilling your operational and financial responsibilities;
You will carry out your activities in accordance with applicable standards and the terms of this instrument.
Access Security
You agree to access your Account only through secure devices and networks, adopting best practices in digital security;
Keep your login information, private keys, and authentication devices secure, refraining from sharing them with unauthorized third parties;
Acknowledges that your Account and electronic password constitute your digital signature, which is confidential, personal, and non-transferable, exempting UnblockPay from any liability for misuse;
You must immediately notify UnblockPay, through official channels, in case of loss, theft, or suspected unauthorized access to your account.
Responsibility for Transactions
You are solely responsible for the financial transactions carried out through your Account and must ensure that they are not used for illegal purposes;
You will assume full responsibility for the correct technical integration of the API, the functioning of your application with the Platform, and the experience of your Integrated Users, exempting UnblockPay from any failure in its own systems;
You will be responsible for the correct collection of taxes, fees, and contributions levied on the services provided under the partnership.
Compliance and Cooperation
You agree to cooperate fully with anti-money laundering (AML) and counter-terrorist financing (CFT) procedures, immediately reporting any suspicious or atypical activities;
Fully comply with the terms and conditions established by UnblockPay, including operational limits and rules relating to financial transactions;
You will be responsible for the correct declaration and collection of taxes arising from cryptoasset transactions, in accordance with applicable law;
Ensure that all of their transactions comply with local and international laws and regulations;
Notify UnblockPay immediately of any relevant changes to their registration information, tax status, or any suspicious activities identified in their account;
You will promptly cooperate with internal procedures or regulatory investigations involving your activities on the Platform.
You will accept and, where applicable, implement technical or operational changes communicated by UnblockPay in a timely manner, provided that such changes are necessary for regulatory compliance or service evolution;
Use the UnblockPay brand and name only within the limits authorized by contract, upon prior notification and authorization from UnblockPay, safeguarding its reputation.
6.2. Prevention of Money Laundering and Terrorist Financing. UnblockPay maintains internal policies for the Prevention of Money Laundering and Terrorist Financing (PLD/FT), in line with the FATF and the rules of the Central Bank of Brazil. The Customer and/or End User may be asked to provide additional information and documents, and UnblockPay is responsible for reporting activities considered suspicious to the competent authorities.
6.2.1. Blocking and Access Restriction Measures. Without prejudice to the foregoing provisions, UnblockPay may, at its sole discretion and without prior notice, block, freeze, or temporarily restrict access to the Account, as well as the balances or tokens held therein, whenever:
i. it identifies evidence of fraud or irregular use of the Platform;
ii. there is suspicion of activities related to money laundering, terrorist financing, or other illegal practices;
iii. there is a breach of these Terms or contractual obligations; or
iv. in compliance with a court order or determination by a competent authority.
6.3. Restrictions on Use. The Customer may not carry out Transactions for the following purposes:
i. That are illegal under Brazilian law or applicable regulations;
ii. Involve financial crimes, including money laundering, terrorist financing, corruption, or any activity that violates the rules of the National Financial System, the Central Bank of Brazil, or other regulators;
iii. Are fraudulent or do not represent a regular legal transaction, aiming at manipulation, market abuse, or obtaining undue advantage;
iv. May cause damage to UnblockPay, other Users, or third parties, whether through abusive conduct, atypical operations, or practices that compromise the integrity of the platform.
6.3.1. Prohibited Conduct. It is prohibited to use the Platform for irregular currency arbitrage, unauthorized data mining, sending spam, distributing malicious software, or any other conduct that compromises the integrity of the Platform.
6.4. Responsibility for Account Use. The Customer is solely and fully responsible for any Transactions made on their Account, undertaking to inform UnblockPay immediately of any unauthorized use of their Account, as well as any illegitimate access by third parties.
6.5. Registration Updates. If the Customer or End Users fail to update or validate their registration information, use of the Services may be suspended until the information is properly regularized, in accordance with KYC/KYB policies and other applicable regulatory requirements.
6.6. Breach of Obligations. In the event that the Customer fails to comply with any of the conditions set forth herein, We reserve the right to terminate the contractual relationship for non-compliance, in whole or in part, at Our sole discretion, including by blocking the respective account(s) and suspending or canceling access to the Platform, as the case may be, without prior notice.
6.7. Our Responsibilities. They are:
Providing Settlement Services for Transactions involving Virtual Assets to Clients and End Users, within the scope of the Services and in accordance with applicable Regulations;
Verify the Client's Know Your Business ("KYB") information and ensure compliance with the Know Your Customer ("KYC") policies applicable to End Users;
Collect and transmit Data to the Client, provided that the End Users have given their consent, solely and exclusively for the performance of the contracted Services.
Enable, as applicable, the availability of settlement features for transactions involving virtual assets to Clients and End Users;
Provide and maintain the necessary technology and/or systems to enable the Services under UnblockPay's responsibility that are necessary for the Solution, in accordance with the Regulations;
Be responsible for all taxes, fees, and contributions, whether fiscal, social security, or labor-related, that are or may be levied on the Services provided by UnblockPay under this Agreement;
Comply with applicable regulatory duties, including (i) reporting transactions to the Brazilian Federal Revenue Service, pursuant to RFB Normative Instruction No. 1,888/2019; and (ii) reporting suspicious transactions to COAF, pursuant to Law No. 9,613/1998, as required for virtual asset service providers.
6.7.1. Limits on Liability. We are not responsible for:
Temporary interruptions in services caused by external factors, such as network failures, problems with third-party providers, or force majeure events;
Occasional technical failures, software errors, or temporary instabilities that do not result from gross negligence or bad faith on the part of UnblockPay;
For any losses or damages suffered, including moral damages, resulting from: (a) any incorrect or incomplete information provided by a User; (b) any fraud, fraudulent misrepresentation, or breach of duty, or violation of any of the conditions by a User; (c) connection failures; (d) data processing problems due to the fault of third parties; (e) third-party products or services, even if connected to the Platform;
To any User in relation to any violation of third-party rights;
For indirect, incidental, special, exemplary, punitive, or consequential damages, including personal injury or property damage, related to or otherwise resulting from any use of the Platform that the User may suffer due to actions taken or not taken through it, even if arising from the conduct of third parties;
For losses arising from actions or omissions by the Clients or End Users themselves, such as lack of security in credentials (e.g., loss of password, improper sharing of information, use of insecure devices or networks) and for making incorrect or incomplete transfers (invalid addresses or addresses incompatible with the crypto assets sent);
For losses resulting from decisions or transactions executed by the Customer or End User, such as errors in the choice of assets or quantities traded, as well as losses associated with market volatility, losses of parity of a given stablecoin (depeg), or misguided strategic decisions.
Due to unavailability, failures, delays, network congestion, increased transaction fees (fees/gas), protocol failures, forks, or discontinuity of blockchains used. Likewise, it is not responsible for smart contract failures, insufficient liquidity, or decisions made by third-party issuers of digital assets.
6.7.2. Mitigation Commitment. UnblockPay undertakes to act promptly to correct any technical failures identified on the Platform, mitigating losses and clearly communicating to Customers any incidents that may impact the provision of services.
6.7.3. Third-party links. The Platform may provide links to other websites or systems, which does not mean that these sites or systems are owned or operated by Us. As We have no control over these sites or systems, we shall not be responsible for the content, practices, and services offered by them. The presence of links to other websites or systems does not imply any partnership, supervision, complicity, or solidarity on our part with these websites or systems and their content.
6.8. Responsibility for Financial Decisions. Any use of UnblockPay's services for financial purposes, including the creation, management, or transaction of digital assets, is the sole responsibility of the Customer and End Users, and UnblockPay is not responsible for investment decisions, financial losses, crypto asset market volatility, or any other impact resulting from the use of the platform.
6.9. Indemnification. The Customer shall indemnify us, as well as our directors, administrators, collaborators, representatives, and employees for any claim brought by third parties arising from their activities on the Platform and for non-compliance with these Terms, as well as for the violation of any law or third-party rights, including attorneys' fees.
7. PLATFORM ENGINEERING
7.1. Availability. The Platform is available and offered "as is" and "as available." That is, we are not responsible for any implied warranties of merchantability, fitness for a particular purpose, or financial return. In addition, we do not guarantee that the Platform's services will be provided without interruptions or errors.
7.1.1. Inherent Risks. By agreeing to the Terms of Use, you accept that any risks arising from the use of the Platform are your sole and exclusive responsibility, to the extent permitted by law.
7.1.2. Interruptions. The Customer and End User acknowledge that access to the Platform may be temporarily interrupted without prior notice due to: (a) scheduled and/or emergency maintenance; (b) technical issues; (c) unforeseeable circumstances or force majeure.
8. SECURITY
8.1. Creation and Management of Access Credentials. The Customer undertakes to establish robust passwords containing uppercase letters, lowercase letters, numbers, and special characters, refraining from using passwords previously used in other services. It is expressly prohibited to register or share access credentials with third parties, except when using password management tools that guarantee proper encryption and security.
8.2. Authentication and Secure Environment. To reinforce the protection of access to the Platform, it is recommended that the Customer enable the two-factor authentication (2FA) mechanism. Access to the Platform should preferably occur through secure devices and networks, with the Customer being responsible for keeping their operating systems, antivirus software, and browsers up to date in order to reduce any vulnerabilities.
8.3. Access and Credential Recovery. UnblockPay provides specific procedures for recovering access in cases of password loss or compromised credentials, ensuring the Customer's security. These procedures include:
A. Password Recovery:
i. The Customer may initiate the password reset process directly through the website or application by requesting a secure link to be sent to the registered email address;
ii. After receiving the link, the Customer must reset their password, and it is mandatory to reconfigure two-factor authentication (2FA) to reinforce access security.
B. Authenticator Recovery (2FA):
i. In case of loss or compromise of the authenticator, the Customer must contact UnblockPay technical support via the official email address;
ii. Support will perform a rigorous validation procedure, which may include verification of personal documents (ID and proof of residence), submission of a selfie with identification document, and, if necessary, a video call to confirm identity;
iii. After validation, support will remove the compromised 2FA method and assist the Customer in setting up a new authentication mechanism.
8.4. Measures in Case of Unauthorized Access. To reinforce the protection of access to the Platform, it is recommended that the Customer enable the two-factor authentication (2FA) mechanism. Access to the Platform should preferably occur through secure devices and networks, with the Customer responsible for keeping their operating systems, antivirus software, and browsers up to date in order to reduce any vulnerabilities.
8.5. Preventive Account Suspension. UnblockPay may preventively suspend the Customer's access to their Account, without prior notice, when:
i. Transactions outside the Customer's standard usage pattern are identified;
ii. There is suspicion of illegal transactions, including money laundering, terrorist financing, or financial fraud;
iii. The Customer misuses the Account, violating any provision of these Terms of Use or applicable law;
iv. The Customer fails to provide requested documentation for identity verification and regulatory compliance purposes;
v. There is a legal requirement, determination by the Central Bank of Brazil, the Securities and Exchange Commission (CVM), or any other competent public authority.
8.6. Fraud Monitoring and Blocking. UnblockPay uses continuous monitoring systems to detect possible fraud and suspicious behavior in Transactions carried out through the Platform. If any evidence of irregularity, fraud, or suspicious transaction is identified, UnblockPay may, without prior notice, block, suspend, or cancel the Customer's Account as a preventive measure, as well as make the balance unavailable until the necessary analyses are completed.
8.7. Access Security. In addition to the cases provided for in clause 8.5, UnblockPay may temporarily suspend or block access to the Customer's Account, regardless of prior notice, if the following are identified:
i. Attempts to access the account using an unrecognized device or one that is different from the one registered;
ii. Consecutive errors in entering the access password, which may result in blocking after three unsuccessful attempts.
8.8. Unblocking Procedures. To request the unblocking of the Account, the Customer must contact UnblockPay through the official communication channels. Additional documentation may be required for the purpose of validating the Customer's identity and reinforcing the Platform's security measures.
8.9. Account Closure. The Customer may request the closure of their account on the Platform by contacting UnblockPay's official support directly. For the closure to take effect, the Customer must first transfer all remaining assets on th —whether crypto assets or account balances—to an external wallet owned by them. After confirmation of the transfer and closure, the account will be deactivated, with no refund or automatic transfer of remaining assets, exempting UnblockPay from any liability for any losses resulting from non-compliance with this procedure.
8.10. Continuity. UnblockPay maintains a business continuity and disaster recovery plan, including periodic backups, system redundancy, and service restoration protocols, in order to reduce impacts in cases of serious failures or force majeure events.
8.11. Auditing. UnblockPay may undergo periodic independent audits of information security, compliance, and financial matters as a way to prove its adherence to regulatory standards and reinforce transparency with Customers and Users.
8.12. Blockchains and decentralized technologies. The Customer and End User acknowledge that blockchains are decentralized technologies and may experience failures, delays, unavailability, bugs, or protocol vulnerabilities. They also acknowledge that technological advances, such as quantum computing, may compromise cryptographic security mechanisms. UnblockPay will make reasonable efforts to mitigate risks, but does not guarantee uninterrupted or absolute operation of the networks used.
9. PRIVACY AND DATA PROTECTION
9.1. Compliance with Personal Data Protection. UnblockPay fully complies with the legislation and standards related to personal data protection, in particular Law No. 13,709/2018 (LGPD) and Law No. 14,478/2022 (Legal Framework for Virtual Assets). The processing of personal data carried out within the scope of the Platform is intended exclusively for the performance of the contracted services, in strict compliance with the purposes informed to the data subject.
9.2. Data Governance. UnblockPay maintains a data governance structure based on internal policies and technical and organizational controls designed to ensure the proper processing of information. This includes procedures for the collection, classification, storage, access, monitoring, retention, and secure disposal of personal data, as well as periodic reviews to ensure regulatory compliance and risk mitigation.
9.3. Information Security. UnblockPay maintains internal information security policies that establish guidelines for the protection of data and systems, covering access controls, proper use of technological resources, vulnerability management, backup and disaster recovery, auditing and monitoring of activities, as well as periodic awareness training for employees. These policies aim to ensure the confidentiality, integrity, and availability of information, as well as compliance with regulatory requirements and good market practices.
9.4. Rights, Sharing, and Confidentiality of Personal Data. UnblockPay ensures that data subjects can exercise their rights under the LGPD, including confirmation, access, correction, deletion, portability, and review of automated decisions, upon request through the official channels indicated in its Privacy Policy. Personal data may be shared with third-party service providers, such as cloud providers and crypto asset custodians, always restricted to contractual purposes and in accordance with applicable law. All employees, Partners, Service Providers, and third parties who have access to personal data on behalf of UnblockPay will be bound by confidentiality obligations and will be responsible for the proper use of the information.
10. INTELLECTUAL PROPERTY
10.1. Intellectual Property Rights. The commercial use of the expression "UnblockPay" as a trademark, business name, domain name, logo, as well as the copyright and industrial property rights related to the Platform, API, software, databases, design, content, and other associated elements, belong exclusively to UNBLOCK SERVIÇOS DIGITAIS LTDA., or are duly licensed in its favor. Similarly, copyrights and other rights subject to industrial property protection, such as structure, screen content related to the Platform, as well as related programs, software, website, databases, networks, and files are our exclusive property. All rights mentioned in this clause are protected by Brazilian law and international treaties relating to copyright, trademarks, patents, models, and industrial designs.
10.2. License of Use. The Customer and End User are granted only a limited, non-exclusive, non-transferable, non-sublicensable, and revocable license to access and use the Platform, API, and features, exclusively for contractual purposes and in accordance with these Terms of Use. This license does not imply transfer of ownership of intellectual property rights.
10.3. Integration API. The use of the Integration API provided by UnblockPay does not grant the Customer any ownership rights over its technology. The Customer or End User is expressly prohibited from copying, altering, adapting, manipulating, decompiling, decomposing, reverse engineering, or exploiting the API or any other UnblockPay Intellectual Property assets for purposes other than those provided for in these Terms.
10.4. Third-Party Applications. Where applicable, UnblockPay acknowledges that applications developed by Customers remain the exclusive property of the Customers or their licensors, and UnblockPay is also prohibited from assigning, copying, modifying, manipulating, or exploiting such assets in any way other than as necessary for the performance of the contract.
10.5. Limited Use and Prohibition. It is prohibited to reproduce, duplicate, copy, sell, resell, visit, commercially exploit, or extract data from the Platform or API without the prior express consent of UnblockPay. In particular, the use of data mining, robots, spiders, or any automatic collection tools for the purpose of extracting substantial portions of the content or functionality is prohibited.
11. FINAL PROVISIONS
11.1. Improvement. The Customer and the End User agree that any and all systems, Platforms, or services, regardless of their producer or characteristics, are a type of product that is constantly being updated and improved.
11.2. Malfunctions. Any malfunctions in the Platform will be corrected as soon as possible, during the period necessary for maintenance. We do not intend for the Platform's server, system, database, software, and website to be free of errors, failures, or interruptions.
11.3. Warnings and suspension. Without prejudice to other applicable measures, we may warn, suspend, temporarily or permanently, the Customer's access at any time if he/she:
fails to comply with any provision of the Terms of Use;
uses, without authorization, our name and/or brand, especially the UnblockPay brand, in part or in its entirety, and/or violates our intellectual property rights in any other way;
fails to pay the agreed amount for licensing the Platform.
11.4. Nullities. If any provision of these Terms of Use is deemed illegal, invalid, or unenforceable, in whole or in part, that provision shall be deemed not to be part of these Terms of Use, and the legality, validity, and enforceability of the remaining provisions shall remain unaffected.
11.5. Term. The Terms of Use shall apply to each Customer and/or End User from their first access to the Platform and shall cease when the respective registration is deactivated, with responsibilities remaining for the period of use.
11.6. Future regulatory compliance. UnblockPay will continuously monitor regulatory developments relating to virtual asset service providers. If specific authorization is required for the operation of PSAVs or other regulatory adjustments, UnblockPay will take all necessary measures to obtain such authorizations and comply with legal requirements within the established deadline, ensuring full compliance of its services.
12. OUR OFFICIAL CUSTOMER SERVICE CHANNEL
12.1. Questions. In case of questions or suggestions about the Terms of Use or any other information related to the provision of the Service, the Customer and/or End User may request support by emailing hello@unblockpay.com.
12.2. Hours of operation. Support hours are from 9:00 a.m. to 6:00 p.m., Brasília time (GMT-3). Our support aims not only to resolve potential problems quickly and efficiently, but also to seek an amicable solution. Our initial response will occur within 24 hours (twenty-four hours) of receiving your email. The time frame for resolution may vary depending on the case reported. For Customers, the specific deadlines in the signed SLA will be observed.
13. APPLICABLE LAW AND JURISDICTION
13.1. Applicable law and jurisdiction. These Terms of Use are governed by Brazilian law, with the jurisdiction of the District of Rio de Janeiro being defined as competent to settle any disputes arising from them, to the detriment of any other, however privileged it may be or become, with priority always being given to attempts at resolution through conciliation or mediation.
Revision control:
- Date: 09/29/2025
- Activity: Issuance of the document
- Version: 1.0.