Legal

RIVOOL TERMS OF USE

Last updated: September 30, 2026

On this page
  1. 1. ELIGIBILITY AND JURISDICTIONAL SCOPE
  2. 2. SERVICES
  3. 3. ACCOUNT SETUP AND IDENTITY
  4. 4. TRANSACTIONS AND INTERACTION WITH THE BLOCKCHAIN
  5. 5. OPERATIONAL LIMITS OF THE SOFTWARE
  6. 6. SUSPENSION AND TERMINATION OF ACCESS
  7. 7. LIABILITY AND LIMITATIONS
  8. 8. AVAILABILITY AND ACCURACY OF THE TECHNOLOGY SERVICES
  9. 9. PROMOTIONAL CAMPAIGNS, BONUSES, REWARDS, AND DISTRIBUTION PARTNERSHIPS
  10. 10. CUSTOMER SERVICE, FEEDBACK, AND DISPUTE RESOLUTION
  11. 11. DATA PROTECTION AND PRIVACY
  12. 12. USER SECURITY AND PROTECTION
  13. 13. INTEGRATION WITH Avenia AND Unblockpay SERVICES
  14. 14. PASSKEYS
  15. 15. WALLET AND SELF-CUSTODY
  16. 16. GENERAL PROVISIONS

Express acceptance: access to and use of the Platform are conditional upon express acceptance of these Terms at the time of registration (onboarding), through an affirmative act by the User, such as ticking an acceptance box. By giving such acceptance, the User represents that they have read, understood and agreed to these Terms, including the Privacy Policy, which forms an integral part hereof.

These Terms of Use constitute a binding agreement between you (the "User") and RVL Global, the company that owns the Rivool brand.

For the purposes of this agreement, "Rivool" refers to the rivool.finance website, the set of software protocols, the technology interfaces that make up the Rivool Platform, and the associated mobile applications.

By using our technology, the user acknowledges that Rivool is technology aggregator software of a self-custodial and distributed nature. Unlike traditional financial institutions, Rivool's software is not located or headquartered in a single physical jurisdiction. It operates through decentralized cloud infrastructure, running locally on the user's device and directly on public blockchain networks. The software works as an interface for the user to interact directly with the blockchain. Rivool has no access to, control over or custody of the user's private keys, recovery phrases (seeds) or digital assets.

READ CAREFULLY BEFORE PROCEEDING: RIVOOL IS NOT A BANK, IS NOT A FINANCIAL INSTITUTION, IS NOT A CUSTODIAL EXCHANGE AND DOES NOT INTERMEDIATE ANY TRANSACTION. RIVOOL IS SOLELY AN INTERFACE SOFTWARE PROVIDER. BY USING THIS PLATFORM, YOU ACKNOWLEDGE THAT THE OPERATING MODEL IS ONE OF SELF-CUSTODY. THIS MEANS THAT:

THE POSSESSION, SECURITY AND CONTROL OF YOUR PRIVATE KEY, YOUR DEVICE, YOUR PASSKEY AND YOUR RECOVERY PHRASE (SEED PHRASE) ARE YOUR SOLE AND ENTIRE RESPONSIBILITY.

WE DO NOT STORE, DO NOT HOLD A COPY OF AND DO NOT HAVE ACCESS TO YOUR PRIVATE KEYS, YOUR DEVICES OR YOUR ASSETS ON THE BLOCKCHAIN.

IMPOSSIBILITY OF RECOVERY: IF YOU LOSE ACCESS TO YOUR PRIVATE KEY OR YOUR RECOVERY PHRASE, Rivool TECHNICAL SUPPORT HAS NO TECHNICAL ABILITY TO RECOVER WALLET PASSWORDS, REVERSE TRANSACTIONS OR REFUND LOST AMOUNTS, AS WE DO NOT HOLD CUSTODY OF THE FUNDS.

BY USING A SERVICE THAT OPERATES ON A BLOCKCHAIN, YOU AGREE AND ARE AWARE THAT YOUR TRANSACTIONS ARE IRREVERSIBLE AND THAT SMART CONTRACTS, BLOCKCHAIN NETWORKS AND THIRD-PARTY PROVIDERS INVOLVE RISKS, AND Rivool CANNOT RECOVER YOUR KEYS OR REVERSE YOUR TRANSACTIONS.

USER RISK: BY ACCEPTING THESE TERMS, YOU FULLY ASSUME THE TECHNOLOGICAL RISK OF SELF-CUSTODY AND RELEASE Rivool FROM ANY LIABILITY FOR THE LOSS OF ACCESS TO YOUR DIGITAL WALLET. By registering or connecting your wallet to use the RIVOOL graphical interface (the "Website" or "App"), you agree that you have read, understood and accept all the terms and conditions contained in this Agreement, including our Privacy Policy, which forms an integral part of these Terms of Use.

INFRASTRUCTURE PARTNERS AND THIRD-PARTY SERVICES: By accepting these Terms of Use and using the products and features made available through Rivool's software, you acknowledge and agree that certain operations are enabled by external infrastructure partners.

Accordingly, when using specific services, you represent that you are aware of and fully agree to the terms of use of our partners, including, but not limited to:

Asset Conversion: Operations converting crypto-assets into fiat currency (fiat) and vice versa;

Rivool Card: The use of the physical or virtual card;

Custody and Settlement: Other payment processing and network infrastructure services.

Continued use of these features implies automatic acceptance of the conditions set by such partners, over which Rivool has no direct control.

The operation of the on-ramps and off-ramps is the sole responsibility of the respective third-party companies, and Rivool is exempt from any liability in this regard.

1. ELIGIBILITY AND JURISDICTIONAL SCOPE

1.1. Nature of the Software and Location. The User acknowledges that RIVOOL is technology software of a self-custodial and distributed nature. Unlike traditional institutions, RIVOOL's software is not "located" or headquartered in a single physical jurisdiction, but operates through decentralized cloud infrastructure and runs locally on the User's device and on the public blockchain network.

1.2. Due to its global nature, RIVOOL is not necessarily subject to the governing laws of a specific country, except with respect to the direct obligations of its developers. (A) Local Compliance: This does not imply legal immunity. Rivool complies with all rules applicable to its operating model in the countries in which it operates. The User is responsible for ensuring that access to and use of the Platform are permitted by the laws of the jurisdiction in which the User resides, is domiciled or from which the User accesses the services. (B) Unlawful Use: It is strictly prohibited to use RIVOOL's software for purposes deemed unlawful in the User's jurisdiction or under international rules, including, but not limited to: money laundering, currency evasion, terrorist financing, fraud or the purchase of illegal goods.

1.3. Anti-Money Laundering (AML) and Controls. Although RIVOOL is a technology provider and not a financial custodian, monitoring and control policies and tools are adopted to prevent the use of the tool for unlawful purposes (Anti-Money Laundering, AML, and Combating the Financing of Terrorism, CFT), as detailed in these Terms. Identity verification (KYC) and anti-money laundering and counter-terrorist financing screening are performed by a specialized third-party provider, Sumsub (Sum and Substance Ltd.), whose tools are integrated into the Platform for this purpose. Shared Responsibility: The existence of these control tools does not transfer legal liability to RIVOOL, nor does it release the User from their civil and criminal obligations. The User must contribute to the proper use of the Platform, providing truthful information when requested and AGREEING NEVER TO USE THE PLATFORM FOR ANY UNLAWFUL ACTIVITY.

1.4. The legal relationship established between the user and Rivool is one of software use licensing, in which the technology tool allows the user to exercise their financial sovereignty, maintaining exclusive control over their private keys and the final execution of any transaction. Technologically, RIVOOL operates under a non-custodial software architecture. This means that our platform acts strictly as a graphical interface for interacting with the Blockchain, never intermediating or holding possession of the assets.

1.5. The product marketed by RIVOOL is the license to use the interface and the aggregated technology services, and not the purchase and sale of financial assets, which takes place directly between the User and the blockchain network.

1.6. Legal capacity and prohibition of use by minors. The User represents that they are at least 18 (eighteen) years old and fully legally capable of performing the acts of civil life. RIVOOL's Platform and Technology Services are not intended for minors under 18, and their use, registration or access by legally incapable persons is prohibited. (A) The User is responsible for ensuring that they will not allow minors to access their credentials, their device or the features linked to their Account. (B) Once use by a minor or by a person lacking legal capacity is identified, Rivool may suspend access to the interface, subject to the technical impossibility of accessing self-custodied assets without the Private Key or Recovery Phrase. (C) Any processing of data associated with minors shall comply with the data protection and child and adolescent protection laws applicable in the User's place of domicile.

2. SERVICES

2.1. Nature of the Services: Technology Provider. RIVOOL acts exclusively as a provider of Technology Services, making available to users a software use license (the "Platform") intended to facilitate the user's direct interaction with decentralized blockchain networks.

By using RIVOOL, the user expressly acknowledges and agrees that: (A) RIVOOL makes available solely the software infrastructure and digital tools that allow viewing, reading and transmitting instructions directly to the blockchain; (B) RIVOOL does not hold, store, keep, process or control the user's Virtual Assets at any time; and (C) All transactions are executed directly by the user on the respective blockchain network, without any intervention, approval or financial settlement by RIVOOL.

2.2. No Financial Management or Brokerage. Unlike centralized exchanges, RIVOOL does NOT buy, sell or transfer virtual assets on behalf of third parties. For the avoidance of doubt, it is established that: (i) Strictly Technological Role: RIVOOL does not acquire or sell assets in its own name on the user's account; (ii) No Powers: RIVOOL has no power to represent the user or to make decisions about their assets; (iii) Direct Relationship: The user transacts directly with the decentralized protocol or with other users of the network (P2P/DeFi), and RIVOOL is responsible only for providing the connection software; (iv) Self-Custody: RIVOOL does not hold the user's private keys or funds. Responsibility for safekeeping the access credentials and private keys lies solely with the user.

2.3. RIVOOL's Platform works as an access portal ("Gateway") that translates the user's commands into language compatible with the blockchain. Accordingly: (i) The user connects their own wallet or generates new access credentials through the technology made available; (ii) The user signs transactions with their own private key; (iii) RIVOOL merely transmits that signed transaction to the public blockchain network for processing by the network's validators.

Furthermore, the User understands that the "RIVOOL Interface" (the web/app software) is distinct from the underlying "Decentralized Protocols" (the Smart Contracts that run on the Blockchain). (A) RIVOOL provides the Interface, which is merely a visual tool. (B) RIVOOL does not control, does not operate and cannot halt the Decentralized Protocols with which the Interface interacts. If there is a failure in the Protocol (e.g., a calculation error in the Pool's Smart Contract), RIVOOL bears no liability, as it is not the owner of the decentralized network.

2.4. Since RIVOOL provides only the Technology Services and not financial settlement: (A) Rivool does not guarantee the execution, settlement or immutability of transactions, which depend exclusively on the functioning of the underlying blockchain network; (B) RIVOOL has no technical ability to reverse, cancel or modify transactions once they have been transmitted by the user to the blockchain network; (C) Network fees ("Gas Fees") are paid directly by the user to the network's validators and do not constitute RIVOOL revenue.

2.5. Integrations, Web3 Browser and Third-Party Services. The Rivool interface may include virtual asset browser features ("Web3 Browser") or direct links that allow the user to access Decentralized Applications ("dApps") and Decentralized Exchanges ("DEXs") operated by third parties.

(A) Browser Nature: When using the Web3 Browser, the user understands that they are navigating outside the environment controlled by Rivool. The software acts only as a connecting bridge. Rivool does not control, endorse, audit or guarantee the security, legitimacy or functionality of any dApp or DEX accessed. (B) If the user interacts with a malicious dApp, falls for phishing scams or suffers losses due to failures in third-party smart contracts accessed via the Rivool interface, the responsibility lies solely with the user. Rivool has no power to reverse such interactions.

2.6. Additional Services. In addition to the main Technology Services, Rivool may develop and make available additional features or integrations with third-party systems (the "Additional Services"), with a view to expanding the usefulness of the Platform.

2.6.1. The Rivool Card and Partnerships. If the user chooses to use features such as the prepaid card integrated into the Platform (the "Rivool Card"): (A) Issuance by Third Parties: The user acknowledges that the card is issued and administered by a duly regulated partner financial or payment institution, and not by Rivool. (B) Technological Connection: Rivool's role is limited to providing the technology that allows the user to connect their self-custodial wallet to the issuing partner's system. (C) Subjection to Third-Party Terms: The use of Additional Services requires the user to accept the terms and conditions of the issuing partners. (D) Nature of the Card: The Rivool Card is a prepaid payment instrument backed by USDC. It does not constitute a debit or credit card in the traditional regulatory sense, nor does it grant the User the protections typical of banking products, such as deposit guarantees. Conversion fees, network fees and spread may apply.

2.6.2. Card partner infrastructure and policies. The functionality of the Rivool Card depends on the infrastructure and services provided by RAIN and its issuing network. Use of the Rivool Card is subject to these partners' own policies, and they may, according to their own risk and compliance criteria and procedures, approve, decline, limit, suspend or cancel the card and access to the respective feature. As the Rivool Card uses these partners' infrastructure, such decisions are made by them, and not by Rivool, which has no say over their merits, even if they affect the use of the card within the Platform.

2.7. Fees and Remuneration. For the use of the Platform and the Additional Services, Rivool may charge software licensing or service fees, which will always be presented transparently on the Platform. (A) Distinction of Fees: The user represents that they are aware that the fees charged by Rivool (for the use of the Technology Services) are distinct from network fees (Gas Fees) and distinct from any financial fees charged by third-party partners. (B) Responsibility: The user agrees to be responsible for paying all applicable fees presented on the Platform at the time of the transaction.

2.8. No Fiduciary Duty. This Agreement is not intended to create, and does not create, any fiduciary duties on the part of Rivool toward the User. To the maximum extent permitted by law, the User acknowledges and agrees that Rivool owes the User no duty of loyalty, financial duty of care or wealth management. Our only obligations are the strictly technical ones described in these Terms (provision of software).

2.9. Routing and Price Execution. Rivool's smart routing technology seeks to find efficient routes for the User's swaps. However: (A) Due to the volatility and speed of the Blockchain, Rivool does not guarantee that the price displayed in the simulation will be exactly the executed price, nor that it will be the best price available across the entire global market at that millisecond. (B) The User acknowledges that the final price may vary between the time of signing and the time of the transaction.

3. ACCOUNT SETUP AND IDENTITY

3.1. Registration of the Access Account. To use Rivool's Technology Services, it may be necessary to register a user profile on the Platform (a "Rivool Account"). Registration involves providing data such as name and e-mail address and creating credentials to access the software.

3.1.1. Nature of the Account. The Rivool Account is intended exclusively to: (i) manage the software settings; (ii) enable technological access to the Additional Services; and (iii) store activity history. The Rivool Account is not a bank, payment or deposit account. The creation of the Rivool Account does not, under any circumstances, imply the transfer of possession of the user's assets to Rivool.

3.2. Identity Verification (KYC) for Software Security. Although Rivool acts strictly as a Technology Provider, the security of the digital environment and compliance with global rules require the identification of users, especially to enable integrations with regulated partners (e.g., card issuers, cross border payments). Accordingly, the user agrees to provide the information requested for the purposes of identity verification, risk analysis and anti-money laundering policies (KYC / AML).

3.2.1. Use of Information. The user authorizes Rivool to use their data to validate their identity and, when the user chooses to use the Rivool Card, to share such data with the partner financial institutions, strictly to enable the partner to provide the service.

3.3. Account Password vs. Private Key. It is essential that the user understands the difference between the Rivool Account credentials and the credentials of their Wallet: (A) Rivool Account Credentials: (Login/Password). These allow access to the software/application. (B) Private Key or Recovery Phrase (Seed Phrase): These are the mathematical codes that control the Virtual Assets on the blockchain. Rivool DOES NOT HAVE ACCESS TO, DOES NOT STORE AND CANNOT RECOVER YOUR PRIVATE KEY. Rivool's operating model is one of self-custody. If the user loses their Private Key, they will lose access to their assets, and Rivool will be unable to intervene. Use of the platform and of the technology services made available implies full and unrestricted awareness of this aspect of the technology provided.

4. TRANSACTIONS AND INTERACTION WITH THE BLOCKCHAIN

4.1. The technology made available by Rivool allows the user to manage their own funds and interact directly with public blockchain networks. When initiating a transaction through the Platform (whether sending, receiving or interacting with smart contracts), the user acknowledges that: (A) The transaction is signed exclusively by the user's Private Key, stored locally on the user's device (or in an encrypted personal cloud solution), without Rivool having access to that signature; (B) Rivool does not act as a counterparty to the transaction. The purchase and sale takes place between the user and decentralized protocols (Smart Contracts) or other users of the network (P2P); (C) Rivool's software acts only as a transmitter of the message signed by the user to the nodes of the blockchain network.

4.2. Fiat Currency Integration (Fiat On-Ramp/Off-Ramp). Rivool does not receive, hold in custody or process fiat currency (Reais, Dollars, etc.). To facilitate conversion between fiat currency and Virtual Assets, the Platform may technologically integrate services provided by third parties ("Liquidity Partners"). (A) By choosing to buy or sell crypto-assets using Reais (BRL), the user establishes a direct contractual relationship with the Liquidity Partner. (B) Rivool provides only the viewing window (widget) for access to the Partner's service. The financial settlement, foreign exchange and regulatory compliance of that operation are the sole responsibility of the Liquidity Partner. (C) The User understands that the digital assets resulting from the conversion are delivered to their self-custodial wallet address at the end of the flow. The intermediate conversion steps, including any issuance, settlement or conversion of assets, are performed by the regulated Liquidity Partner, on its own infrastructure and under its own custody, according to the technical design of each operation. At no time does Rivool receive, hold or control the User's fiat currency or intermediate assets.

4.2.1. Failures in fiat rails (PIX, card and other fiat means). The User acknowledges that operations that depend on fiat rails, such as PIX settlement in the conversion between fiat currency and digital assets, or transactions carried out with the Rivool Card, are operated and settled by the regulated Partners, and not by Rivool. (A) Distinction from on-chain irreversibility: the impossibility of reversal provided for in these Terms applies exclusively to transactions already transmitted to the blockchain network, and is not to be confused with any operational failures in the fiat rails, which follow the procedure of the responsible Partner. (B) Handling of failures: in the event of a transient failure in the settlement of a fiat operation, the operation may be automatically resubmitted once; if a failure of a permanent nature persists, the corresponding amounts will be returned to the User, preferably by crediting the corresponding digital asset to their self-custodial wallet address, according to the Partner's technical design. (C) Handling channel: without prejudice to the operational responsibility of the regulated Partner, the User may report failures through the support channels indicated in Clause 10, which will forward the matter to the competent Partner. (D) This Clause does not extend Rivool's obligations beyond the provision of the technology interface, nor does it transfer to Rivool responsibility for financial settlement, which remains exclusively with the regulated Partner.

4.2.2. Autonomy of fiat conversion Partners. Conversion operations between fiat currency and digital assets (on-ramp and off-ramp) are performed by regulated Partners, subject to their own rules, licenses and regulatory and compliance obligations. The User acknowledges and agrees that: (A) Rivool selects its Partners through prior due diligence, prioritizing providers that demonstrate anti-money laundering, counter-terrorist financing and anti-fraud controls aligned with applicable global rules; (B) the Platform reflects, in real time, the policies, limits and restrictions imposed by these Partners, so that their decisions, including temporary or permanent blocks, changes to limits, refusals of operations, additional verification requirements or suspension of access, may affect the availability and use of features within Rivool; (C) such decisions fall within the exclusive competence of the regulated Partners, made according to their own criteria and procedures, and Rivool has no say over their merits, even if they affect the use of the Services; (D) the User is prohibited from employing means to circumvent such restrictions, such as the use of VPNs to mask their jurisdiction, under penalty of breaching these Terms.

4.2.3. Unavailability of withdrawal via fiat rail. If a withdrawal via a fiat rail, for example via PIX, remains blocked or unfeasible and it is not possible to obtain an alternative from the responsible Partner, the User may move the corresponding digital asset, held in their self-custodial wallet, to another wallet they own and make the withdrawal by another available means. Rivool does not replace the regulated Partner in financial settlement nor does it guarantee the existence of an alternative means of withdrawal, and the User retains full control of the digital asset in self-custody.

4.3. Unlike traditional banking systems or centralized exchanges, blockchain transactions are, by nature, irreversible. (A) Once the user signs and transmits a transaction to the network through Rivool's technology, it cannot be cancelled, reversed or modified. Rivool has no technical ability to reverse transactions, even in cases of error, theft or fraud. (B) It is the sole responsibility of the user to verify the destination address, the selected network and the amounts before signing the transaction.

4.4. Network Fees (Gas Fees) and Service Fees. (A) Network Fees (Miners/Validators): Every transaction on the blockchain incurs a processing fee (Gas Fee) paid to the network's validators. The User acknowledges that Rivool may, at its sole discretion and for greater convenience, facilitate payment of this fee through fee abstraction mechanisms. In such cases, Rivool may advance payment of the network fee on behalf of the User, being fully reimbursed by withholding the corresponding amount in the token used in the transaction itself. (B) Independence of the Fee: In cases where the facilitation mentioned in item (A) does not apply, the fee fluctuates according to network demand and is not set or controlled by Rivool. (C) Technology Fees: For the use of the technology solution that facilitates interaction (such as smart routing of swaps or convenience in fee payment), Rivool may charge a service fee, which will be added to the transaction and clearly displayed to the User before signing.

4.5. As a non-custodial wallet, the user's address on the blockchain can technically receive any asset compatible with that network. However, Rivool's Platform filters and displays only a selected list of Virtual Assets ("Viewable Assets") to ensure a better user experience and security. (A) Sending Unlisted Assets: If the user sends to their address an asset that is not visually supported by Rivool's software, the asset has not been lost (as it is on the blockchain), but it may not appear in the graphical interface. The user may need to import their Recovery Phrase into other compatible software to view/move that asset. (B) Termination of Support: Rivool may stop displaying certain assets in the interface at any time. This does not affect the user's ownership of the asset, only its viewing through Rivool's tool.

4.6. Specific Risks of DeFi Protocols and DEXs. Rivool's technology allows access to Decentralized Finance (DeFi) protocols and DEXs for swapping assets or providing liquidity. Unlike centralized exchanges that curate the listed assets, DEXs are open environments. (A) High-Risk Assets: The user acknowledges that DEXs and dApps may list assets without any prior verification. This includes assets with a high risk of illiquidity, extreme volatility, risk of being locked, or fraudulent tokens (scam tokens/rug pulls). It is the sole responsibility of the user to verify the asset's contract address before trading. (B) Third-Party Prices and Fees: The user may be charged fees imposed by the dApps or DEXs themselves (in addition to network fees). Rivool neither receives nor controls these third-party fees.

4.7. Blockchain networks may undergo protocol changes ("Forks"). Rivool does not control these changes. (A) Discretion: Rivool reserves the right to decide whether it will update its software to support a specific Fork. (B) No Obligation: Rivool has no obligation to support new chains resulting from forks, nor to ensure that the user receives tokens generated in forks (fork Airdrops).

4.8. (A) All Virtual Assets associated with the user's wallet address are the exclusive property and in the direct possession of the user. (B) Rivool does NOT hold, does not keep title to, does not have custody of and does not manage the user's assets. The assets are not on Rivool's balance sheet. (C) Only the holder of the Private Key (the user) can move the assets. Rivool has no technical means to freeze, confiscate or move the user's funds, not even upon court request (as the technology does not allow such access).

4.9. As Rivool has no access to private keys, Rivool cannot recover wallets whose passwords or Recovery Phrases have been lost by the user. Backup management is the full responsibility of the user.

4.10. It is strictly prohibited to use the Rivool interface to carry out or attempt to carry out: (A) Market Manipulation: Practices that violate market integrity, including, but not limited to, tactics known as Rug Pulls, Pump and Dump and Wash Trading; (B) Cyberattacks: Any activity that seeks to interfere with, intercept or compromise the integrity of Smart Contracts, including reentrancy attacks, malicious front-running or exploitation of protocol bugs.

4.11. Assumption of Technological Risk. Blockchain technology presents inherent risks. The User acknowledges and accepts that smart contracts, blockchain networks and the protocols accessed through the Rivool interface may contain bugs or be subject to exploits, hacker attacks or other failures or vulnerabilities, which may result in the partial or total loss of the assets involved. Because it provides only an interface and does not control this underlying technology, Rivool does not guarantee, and has no way of guaranteeing, that operations will be free of such risks. The User knowingly and voluntarily assumes these technological risks, without prejudice to the limitations of liability set forth in Clause 7.

5. OPERATIONAL LIMITS OF THE SOFTWARE

5.1. The use of Rivool's Technology Services and, in particular, of the Additional Services (such as fiat currency conversion or use of the Rivool Card) is subject to operational limits. Such limits may restrict the financial volume, the frequency of transactions, or access to certain features of the Platform within a given period.

5.2. The limits are set based on security, fraud prevention, and regulatory compliance (Compliance) criteria, and may vary according to: (i) The level of Identity Verification (KYC) completed by the user; (ii) The requirements imposed by operational Partners and card issuers; (iii) The history of use of the software and risk assessment.

6. SUSPENSION AND TERMINATION OF ACCESS

6.1. Without prejudice to other rights provided for in these Terms, Rivool, in its capacity as provider of the software license, may: (A) Refuse to process or transmit any technical instruction from the user to the blockchain network (for example, if the transaction is identified as malicious, such as fraud, or as directed to internationally sanctioned addresses); (B) Temporarily or permanently block the user's login to the Rivool Platform; (C) Restrict access to specific Additional Services (such as suspending the use of the Rivool Card) without necessarily blocking view access to the wallet.

6.1.1. Blocking by order of an authority or compliance requirement. In compliance with a court order, a determination by a competent authority, a requirement of a regulated Partner, or a compliance obligation, including international sanctions, Rivool may refuse to transmit instructions to the network, block access to the interface, or restrict Additional Services. Given the non-custodial nature of the technology, such measures do not grant Rivool possession, control, or ownership of the User's assets and do not constitute appropriation, and the User remains able to access their assets directly on the blockchain.

6.1.2. Emergency protective measures. In situations of force majeure, a security incident or breach, a cyberattack (including hacking and the exploitation of vulnerabilities), a loss of peg (de-peg) of stablecoins, material technical instability, or another proven need, Rivool may adopt, within the scope of the interface and the software under its control, the measures it deems necessary to protect Users, preserve the integrity of the Platform, and safeguard Users' funds, including suspending the interface in whole or in part, pausing or disabling specific features, interrupting the routing or transmission of instructions to the network, and restricting access. (A) Such measures apply exclusively to the software resources under Rivool's control and, given the non-custodial nature of the technology, do not grant Rivool possession, control, or ownership of the User's assets, and do not constitute custody or appropriation. (B) The User remains able, at any time, to access and move their assets directly on the blockchain by means of their Private Key or Recovery Phrase, regardless of the measures adopted on the interface. (C) Rivool will use reasonable efforts to limit such measures to what is strictly necessary and for the time necessary, restoring regular operation as soon as the cause has ceased.

6.2. Grounds for Suspension or Termination. Such measures may be taken, including with immediate effect, if: (i) The user violates any provision of these Terms; (ii) There is reasonable suspicion that the Rivool Account is being used for unlawful activities, money laundering, fraud, or currency evasion; (iii) There is a court order or a determination by a competent authority requiring that access to the software be blocked; (iv) The user's use of the technology puts the technical stability of the Platform at risk. Any suspension or termination of the user's account on the Rivool platform does not give Rivool the ability to access or transfer the user's funds. The user's wallet remains accessible on the blockchain through other platforms.

6.3. Consequences of Termination/Suspension: As Rivool does not hold custody of the assets, termination of access to the Platform does not entail the confiscation of the assets on the blockchain, provided the user has their self-custody credentials.

(A) If Rivool terminates the user's access to the software, the user may access and move their Virtual Assets using their Private Key or Recovery Phrase (Seed Phrase) in any other compatible wallet software available on the market (e.g., hardware wallets or other open-source applications). (B) Termination of the Rivool Account will result in the loss of access to the transaction history, custom settings, and data stored on Rivool's servers, but will not affect the immutable record of transactions on the blockchain. (C) If the user has outstanding financial obligations related to the Additional Services (e.g., outstanding amounts related to the Rivool Card or unpaid service fees), the user remains legally obligated to settle them, even after the suspension of access.

6.4. Irreversibility. The user acknowledges that, due to the immutable nature of the blockchain, Rivool has no technical ability to reverse, cancel, or refund transactions that have already been transmitted to the network, even in cases of account suspension. Suspension of the service only prevents the initiation of new transactions through the Rivool interface.

6.5. Whenever possible, and provided it does not violate applicable laws or compromise security investigations, Rivool will notify the user of the suspension or termination of access, stating the general reasons for the decision.

6.6. Rivool may, at its sole discretion, discontinue, modify, or change the architecture of the Platform or of any Technology Service at any time. In the event of a total discontinuation of Rivool's operations, the user will continue to have full control over their assets through their Recovery Phrase, regardless of the existence of the Rivool platform, reinforcing the censorship-resistant nature of self-custody.

6.6.1. Wind-down of operations and exit window. In the event of a planned discontinuation of the Platform or of Additional Services, Rivool will use reasonable efforts to notify the User with adequate advance notice, so as to allow the use of the fiat features, such as conversion and withdrawal through the Partners, before the shutdown. Once operations have ended, access to the fiat rails intermediated by Partners may cease, and the User will retain full control of their assets on the blockchain by means of their Recovery Phrase, regardless of the existence of the Platform.

7. LIABILITY AND LIMITATIONS

Prominent notice (read carefully). This Section 7, as well as Clauses 10.3, 10.4, and 16.8, contains provisions that limit rights and liabilities. Such clauses must be read carefully before acceptance.

7.1. If the user has a dispute with third parties, including, but not limited to: (i) other users; (ii) developers of smart contracts (Smart Contracts); (iii) token issuers; (iv) liquidity partners or card issuers; (v) blockchain network validators, (vi) hackers, the user expressly agrees to release Rivool, its directors, and its employees from any claims, demands, and damages of any nature arising out of or related to such disputes. Rivool provides only the access tool (interface); it is not a party to the transactions carried out on the blockchain.

7.2. The user agrees to indemnify and hold harmless Rivool and its technology partners against any costs, losses, liabilities, and expenses (including reasonable attorneys' fees) arising from: (A) Misuse of the Technology Services or violation of these Terms by the user; (B) Violation of any applicable law or regulation by the user.

7.3. Limitation of Financial Liability (Indemnity Cap). CONSIDERING THAT Rivool IS A SOFTWARE PROVIDER AND NOT A CUSTODIAN OF ASSETS: Except in cases of proven willful misconduct or gross negligence, Rivool's total and aggregate liability for any damages or losses suffered by the user will be strictly limited to the total amount of the service fees paid by the user to Rivool (excluding gas fees and partner fees) in the 12 (twelve) months preceding the event giving rise to the claim. Under no circumstances will Rivool's liability be calculated based on the value of the Virtual Assets held by the user on the blockchain, since Rivool has neither possession nor control of such assets.

7.4. Specific Exclusion of Damages (Technology Risks). In addition to the limitations above, Rivool will NOT be liable for losses arising from: (A) Loss of Keys: Loss, theft, forgetting, or compromise of the user's Recovery Phrase (Seed Phrase), Private Key, or passwords. Rivool does not hold a copy of this data and cannot recover it; (B) Blockchain Failures: Network congestion, high transaction fees, consensus failures, 51% attacks, or bugs in the protocol of the underlying blockchain; (C) User Errors: Sending assets to incorrect addresses or incompatible networks, or interacting with malicious contracts (Honeypots, Phishing); (D) Third-Party Risks: Bankruptcy, insolvency, or technical failures of Liquidity Partners, hacks or exploits in third-party products, protocols, or services made available or accessible through the platform, card issuers, or DeFi protocols accessed through the interface; (E) Lost Profits: Loss of profit opportunity, loss of expected revenue, or losses arising from market volatility; (F) Smart Contract Exploits: Bugs, vulnerabilities, exploits, or attacks affecting smart contracts accessed through the interface or developed or deployed by Rivool, except in cases of proven willful misconduct or gross negligence by Rivool (Clause 7.3).

7.5. Rivool's Technology Services are provided "as is" and "as available". (A) Rivool does not guarantee that transactions transmitted to the blockchain will be mined/validated in time or at a specific cost. (B) No information displayed on the Platform constitutes an investment recommendation or legal or tax advice. The user operates at their own account and risk. (C) Like all software, the Rivool Platform may contain errors (bugs) or experience instability. Rivool does not guarantee that the service will be uninterrupted or error-free, although it uses its best efforts to fix failures promptly.

7.6. No Guarantee of Profit. The User acknowledges and accepts that any yield feature available on the Platform is based on interactions with third-party decentralized protocols and variable digital assets. Rivool does not guarantee, under any circumstances, any profit, fixed return, or specific financial return.

7.7. Any rates of return displayed on the interface are mere estimates based on historical or real-time data from the underlying protocols, and may undergo drastic and immediate variations due to market volatility, changes to the rules of DeFi protocols, or blockchain network conditions. The final return may be significantly lower than estimated, and may even be zero or negative.

7.8. By using any yield strategy, the User declares that they are fully aware of, and releases Rivool from, any material loss they may incur arising from:

  • (A) Autonomous Decision: The choice of asset and strategy is the sole responsibility of the User;
  • (B) Market Risks: The value of the underlying assets may fall drastically, impacting the total amount invested, regardless of the yield generated;
  • (C) Technological Risks: The User accepts the risks of failures ("bugs"), cyberattacks, hackers, or loss of peg (de-peg) of stablecoins in the protocols where the assets are allocated.

7.9. Rivool, in its capacity as software provider, does not act as an investment advisor or wealth manager. The User releases Rivool from any liability for financial losses or direct or indirect damages arising from price variations or the performance of the assets chosen within the platform.

7.9.1. Non-financial nature of the yield features. The yield features available on the Platform are technological tools that allow the User to interact, autonomously and on a self-custodial basis, with third-party decentralized protocols. They do not constitute, and must not be construed as: (A) an offer of an investment product, financial investment, interest-bearing deposit, or solicitation of public savings; (B) a public offering of securities, a collective investment contract, or a collective investment scheme; (C) an activity of administration or management of third-party funds. Rivool is not a financial institution, a virtual asset service provider (PSAV), or a fund administrator or manager, and does not promise, guarantee, or ensure any return. Any rates of return displayed are variable and may even be zero or negative, as already provided in Clauses 7.6 to 7.9.

7.9.2. Prohibition of looped leveraged operations (leverage loop). The User is expressly prohibited from using credit, loans, or any funds obtained through credit protocols accessed through the Rivool interface to acquire, directly or indirectly, new digital assets through the Platform itself for the purpose of building looped leveraged positions (leverage loop). Rivool reserves the right to restrict, suspend, or prevent, technically or contractually, features that enable such practice, without this constituting a duty to continuously monitor the User's autonomous operations.

7.10. Force Majeure and Network Events. Rivool will not be liable for delays or failures in the performance of its obligations arising from events beyond its reasonable control, including, but not limited to: government acts, wars, terrorism, pandemics, failures in the global internet infrastructure, or critical blockchain network events (such as hacker attacks, bugs in smart contracts, contentious forks, network halts, loss of peg (de-peg) of stablecoins, censorship of transactions by validators, block reorganizations (chain reorg), or price oracle failures).

8. AVAILABILITY AND ACCURACY OF THE TECHNOLOGY SERVICES

8.1. Access to and Availability of the Software. Access to Rivool's Technology Services may suffer degradation, slowness, or temporary unavailability due to technical maintenance, failures in third-party servers, or periods of high congestion on the supported blockchain networks.

(A) Although Rivool is dedicated to maintaining the stability of the Platform, we do not guarantee that the technology solution will be available on an uninterrupted or error-free basis. (B) The user acknowledges that delays in the confirmation of transactions or failures in the transmission of orders may occur due to instability in the blockchain network itself (miners/validators), factors that are entirely beyond Rivool's technical control. (C) Rivool emphasizes that, due to the non-custodial nature of the services, any unavailability of the Rivool Platform does NOT prevent the user from accessing their Virtual Assets. If Rivool's software is unavailable, the user may, at any time, use their Recovery Phrase or Private Key to access and move their funds through other compatible software or wallets available on the market.

For this reason, Rivool will not be liable for any damages, lost opportunities, or depreciation of assets arising from the temporary inability to use the Platform, since access to the assets on the blockchain does not depend on the availability of Rivool's software.

8.2. Accuracy of Information and Network Data. The Rivool Platform acts as a viewer of public data recorded on the blockchain and in third-party price sources (Oracles or market APIs).

(A) Although Rivool seeks to present information (such as balances, history, and quotes) accurately and up to date, there may be latency (delay) between the recording of data on the blockchain and its display on the Platform. (B) The user acknowledges that the "source of truth" for their balances and transactions is the immutable record on the blockchain network, and not the cached view presented by Rivool's software. In the event of a discrepancy, the blockchain network data prevails. (C) The price quotes for Virtual Assets displayed are estimates based on third-party data. Rivool does not guarantee the accuracy of these quotes and is not responsible for purchase or sale decisions made by the user based on this visual information.

8.3. Third-Party Content and Links. The Platform may display links, news, or integrations with third-party services (including block explorers, DeFi protocols, and liquidity partners). The user acknowledges and agrees that Rivool does not control, does not endorse, and assumes no responsibility for the content, accuracy, policies, or practices of these third-party services. Access to such external resources is at the user's sole responsibility and risk.

9. PROMOTIONAL CAMPAIGNS, BONUSES, REWARDS, AND DISTRIBUTION PARTNERSHIPS

9.1. Rivool may, at its sole discretion, offer promotions, referral programs, sign-up bonuses, or other rewards ("Promotions"). The User's participation in any Promotions is conditional on acceptance of and compliance with the specific terms of each campaign, as well as the eligibility rules, regional restrictions, and account verification in effect at the time of participation.

9.2. Rivool reserves the right, at any time and without prior notice, to modify, suspend, or end any Promotion, as well as to change the eligibility criteria or the value of the rewards, without giving the User any vested right to future bonuses or discontinued campaigns.

9.3. Rivool reserves the right to disqualify the User, block the account, and revoke, reverse, or cancel any rewards (even if already credited) if it identifies, at its sole discretion, among other things: a) The creation of multiple accounts or the use of false data; b) The use of robotic means, emulators, VPNs to circumvent geographic restrictions, or automation scripts; c) Self-referral or collusion between accounts to manipulate the rewards system; d) Any violation of the acceptable use policy or suspicion of fraud.

9.4. The User acknowledges that rewards paid in crypto-assets are subject to market volatility. Rivool is not responsible for fluctuations in value, technical failures that prevent immediate participation, or manifest material errors in the configuration of bonuses, and reserves the right to correct such failures and adjust balances as necessary.

9.5. Validity, expiration, and anti-fraud measures. Rivool may set validity periods and expiration conditions for points, bonuses, or rewards, as well as adopt proportionate anti-fraud measures. The expiration of points or rewards not used within the stated period does not give rise to any right to indemnification or compensation, subject to any mandatory rules that may apply in the User's place of domicile.

9.6. Referral Program. RIVOOL may, at its sole discretion, make available a referral program ("Referral Program"), through which Users may receive benefits, incentives, or special conditions for referring third parties.

9.7. RIVOOL may change, suspend, or end the Referral Program, as well as the participation of any User, at any time and for any reason, without any obligation of compensation, indemnification, or prior notice, except for rights already vested where applicable and in accordance with the specific rules of the Program.

9.8. The rules, eligibility criteria, and conditions of the Referral Program, when it exists, will be described in a separate document or on a specific page.

9.9. Access through Distribution Partners. The User may access the Platform by referral from or through a partner that distributes it ("Distribution Partner"), which acts independently. (A) The Distribution Partner is not an employee, representative, or agent of RIVOOL, and RIVOOL is not liable for guidance, recommendations, or services provided by the Distribution Partner to the User. (B) The Distribution Partner has no access to, possession of, or control over the User's keys, credentials, or assets, which remain in self-custody. (C) RIVOOL and the Distribution Partner may adopt a model for sharing the Platform's service fees (fee split), at no additional cost to the User beyond the fees disclosed on the Platform. (D) The relationship between RIVOOL and the Distribution Partner is governed by a separate agreement, to which the User is not a party.

10. CUSTOMER SERVICE, FEEDBACK, AND DISPUTE RESOLUTION

10.1. If the user has questions, suggestions, or feedback, or encounters technical difficulties in using the Platform, they must contact Rivool's Technical Support team by e-mail at contact@rivool.finance or through the official channels indicated on the rivool.finance page. For the purpose of receiving service of process or formal extrajudicial notices, Rivool designates the following physical/electronic address: contact@rivool.finance

10.2. Scope of Support and Limitations. The user acknowledges that the support offered by Rivool is strictly limited to the operation of the technology and of the software interface. (A) What we handle: Login problems with the Rivool Account, display errors in the application, difficulties in the integration with partner services (Card), and bugs in the interface. (B) What we CANNOT handle: Rivool's support has no technical means to recover funds sent to wrong addresses, reverse transactions on the blockchain, recover Private Keys lost by the user, or speed up pending transactions on the network. Complaints of this nature will be technically impossible for Rivool to resolve.

10.3. Amicable Dispute Resolution. Except where prohibited by applicable law, before initiating any judicial or administrative proceeding against Rivool, the user agrees to first contact our support team to attempt to resolve the matter amicably. The user agrees to grant Rivool a period of up to 30 (thirty) days, counted from the formal receipt of the complaint with all the necessary information, to review the case and propose a technical solution or clarification. If the user initiates a dispute without first exhausting this attempt at amicable resolution, Rivool reserves the right to request the stay of the proceeding until the support procedure has been completed.

10.4. These Terms are governed by the laws of the British Virgin Islands.

11. DATA PROTECTION AND PRIVACY

11.1. Processing of Personal Data. By using Rivool's Technology Services, the user acknowledges that Rivool may collect and process personal data in accordance with Rivool's Privacy Policy, which is an integral part of these Terms. Data is processed for the purposes of: (i) Providing the software license and personalizing the user's experience; (ii) Complying with legal and regulatory obligations (including the prevention of fraud and money laundering); (iii) Enabling integration with the Additional Services (such as fiat currency conversion or the issuance of the Rivool Card with the banking partners).

11.2. Data on the Blockchain (Public Data). The user understands and accepts a fundamental characteristic of blockchain technology: Transparency and Immutability. When carrying out a transaction through the Rivool interface, the user's public wallet address and the transaction details are permanently recorded on the blockchain. (A) Public Data: This data is public and decentralized, and is not controlled or stored on Rivool's servers. (B) Impossibility of Deletion: The user acknowledges that Rivool has no technical ability to change, anonymize, or delete data that has already been written to the blockchain. Therefore, the rights to deletion or to be forgotten provided for in data protection legislation do not apply to the immutable records of the blockchain, but only to the data held in Rivool's internal databases (such as registered e-mail and name).

11.3. Sharing with Partners. For the provision of the Additional Services (especially connected financial services, such as the Rivool Card), the user authorizes Rivool to share their registration and identification data with the partner institutions (card issuers, banks, or liquidity partners), strictly for the performance of the contract and compliance with the regulatory rules (Compliance) of those institutions.

11.3.1. Disclosure to authorities and legal requests. Rivool may disclose the User's data to competent public authorities upon a valid legal request or to comply with a legal or regulatory obligation. Such disclosure will observe the principles of necessity and proportionality, being limited to the data strictly necessary to meet the request, with the suppression (redaction) of data of third parties not covered by the order whenever technically and legally possible. Where permitted, Rivool may inform the User of the request.

11.3.2. Identity verification (KYC/AML) by a third-party provider. For identity verification and anti-money laundering and counter-terrorist financing screening, RIVOOL uses Sumsub (Sum and Substance Ltd.) as a data processor. In this process, the User may be asked to provide identification documents and biometric data (for example, a facial image for liveness detection), processed by Sumsub for these purposes. Sumsub's processing of data is governed by its own Privacy Policy (Privacy Notice), available at https://sumsub.com/privacy-notice/. (A) Sensitive data: the User is aware that biometric data is sensitive personal data, processed exclusively for identity verification and compliance with anti-money laundering duties. (B) International transfer: the User is aware that this processing may involve an international transfer of data, carried out under the safeguards required by the applicable data protection legislation.

11.4. User Representations. The user represents that all information provided to Rivool is true and current. The user undertakes to keep their data up to date on the Platform and acknowledges that reading and accepting the Privacy Policy is an indispensable condition for using the services.

12. USER SECURITY AND PROTECTION

12.1. Responsibility for Credentials and Devices. To use Rivool's software, the user must create access credentials for the Platform (Login and Password). The user is solely and fully responsible for the security of their electronic device and for maintaining adequate control of their security data.

12.2. Critical Security Distinction (App vs. Blockchain). The user must understand the difference between two levels of security: (A) Rivool Account Security: This refers to access to the application interface. Rivool may assist in recovering the application password (password reset via e-mail) if the user forgets it. (B) Wallet Security (Self-Custody): This refers to the Private Key or Recovery Phrase (Seed Phrase) that controls the funds on the Blockchain. Rivool NEVER requests, stores, or has access to your Private Key. WARNING: If the user loses, forgets, or has their Private Key/Seed Phrase stolen, Rivool WILL NOT BE ABLE to recover access to the funds or reverse transactions. The security of the Private Key is the sole responsibility of the user.

12.3. Prevention of Phishing and Scams. Rivool is not responsible for damages arising from access to external links, third-party advertisements (on search engines or social networks), or fraudulent websites that imitate the official interface of the service. It is the User's duty to verify the authenticity of the URL and make sure they are in an official environment before entering any data or carrying out transactions.

12.3.1. Inducement and social engineering. The User acknowledges that, if they are induced, through social engineering, phishing, or third-party fraud, to sign a transaction, reveal credentials, install applications, or grant access to their device, Rivool has no technical means to reverse the signed transaction or to recover the transferred assets. Verifying the legitimacy of any request is the sole responsibility of the User.

12.4. Security Breach. If the user suspects that their Rivool Account (app access) has been compromised: (A) The user must IMMEDIATELY notify Rivool Support so that access to the interface can be temporarily blocked; (B) The user must IMMEDIATELY use their Recovery Phrase (Seed Phrase) in another secure interface to transfer their funds to a new secure wallet, since Rivool does not have the power to "freeze" funds on the blockchain.

12.5. Rivool declares that it adopts technical, organizational, and administrative information security measures strictly aligned with the standards required by the Lei Geral de Proteção de Dados (Brazilian General Data Protection Law, Law No. 13,709/2018 - LGPD) and by the applicable regulatory rules. Such measures are intended to protect personal data against unauthorized access and against accidental or unlawful destruction, loss, or alteration.

13. INTEGRATION WITH Avenia AND Unblockpay SERVICES

13.1. By using the conversion features between fiat currency and crypto-assets available on the platform, the User acknowledges and agrees that these services are provided directly by Avenia and Unblockpay ("Avenia and Unblockpay") and their banking partners, and not by Rivool. Accordingly:

13.2. Acceptance of Third-Party Terms: To use these services, the User automatically adheres to, and must observe, the Terms of Service and the Privacy Policy of Avenia and Unblockpay.

13.3. Data Sharing: The User authorizes Rivool to share their registration data, KYC (Know Your Customer) information, and wallet (Wallet) details with Avenia and Unblockpay for the purposes of identity validation and the prevention of money laundering, as required by applicable regulation.

13.4. Geographic Restrictions and Sanctions: The service is not available to Users who are residents or citizens of, or who attempt to access the platform from, jurisdictions classified as "Prohibited Countries" by Avenia and Unblockpay. The User declares that they have no connection with the following locations:

Afghanistan, Albania, Algeria, Bangladesh, Belarus, Qatar, China, Congo (Democratic Republic of the), North Korea, Cuba, Eritrea, Ethiopia, Gaza Strip, Yemen, Iran, Iraq, Kosovo, Lebanon, Libya, North Macedonia, Mali, Morocco, Myanmar, Nepal, Nicaragua, Niger, Central African Republic, Russia, Syria, Somalia, Sudan, South Sudan, Ukraine, Venezuela, West Bank, and Zimbabwe.

13.5. Limitation of Liability: Rivool acts only as a technology integrator. Any failure, delay, custody of funds, or dispute related to currency conversion or financial settlement is the sole responsibility of Avenia and Unblockpay, and Rivool is exempt from liability for losses arising from these specific services.

13.6. Nature of the foreign currency conversion and withdrawal feature. The feature for conversion and any withdrawal in foreign currency through Avenia is an additional, optional tool intended to allow the User to manage and convert assets they own. The User acknowledges and agrees that: (A) Rivool is a non-custodial technical interface and is not a virtual asset service provider (PSAV) subject to Brazilian regulation, and does not carry out the triggering event provided for in art. 76-A of Central Bank of Brazil Resolution BCB No. 521/2025; (B) each step involving fiat currency is operated by a provider regulated in the respective jurisdiction: the step in Brazilian reais, where applicable, by a partner regulated by the Central Bank of Brazil, and the step in foreign currency, where applicable, by a partner regulated in the respective jurisdiction. The characterizations in this Clause reflect Rivool's understanding based on the current technical architecture and do not constitute legal or tax advice to the User, who remains responsible for assessing the classification of their own transactions.

14. PASSKEYS

14.1. The use of passkeys is mandatory for all accounts created with email on Rivool.

14.2. The Passkey is generated and stored exclusively in the secure hardware of the User's device. Rivool does not have access to the User's Private Key under any circumstances and cannot request it. Rivool stores only the Public Key, which is necessary to verify the authenticity of signatures.

14.3. Rivool uses the browser's WebAuthn API to request the user's confirmation on the device itself (biometrics, PIN or security key) before operations with the wallet. This verification takes place locally on the user's device, and no biometric data is transmitted to Rivool or to third parties.

14.4. Each transaction requires individual and direct biometric approval by the User on their device. There is no persistent session. Each action requires confirmation at the moment it is performed.

14.5. By design of the WebAuthn standard, the User's Passkey is bound to the rivool.finance origin. The Passkey will not work on any other domain or application, even if visually identical to Rivool. Rivool will never ask the User to disclose, export or share their Passkey or any biometric data.

Notice: Biometric authentication (Face ID, Touch ID, fingerprint) takes place locally on your device. Your biometric data is never sent to Rivool, to the blockchain or to any third party. What the network receives is only the cryptographic signature produced by your device.

14.6. USER RESPONSIBILITIES:

14.6.1. The User is solely responsible for the safekeeping, security and control of the device on which the Passkey is stored. Rivool has no liability whatsoever for losses arising from theft, loss, unauthorized access or compromise of the User's device.

14.6.2. The User is responsible for controlling who has access to the biometrics registered on their device. Any person whose face or fingerprint is registered on the User's device will be able to authenticate transactions on Rivool. Rivool has no means of distinguishing between the User and third parties authorized on the device.

14.6.3. The User is responsible for managing their account in the Passkey Manager of the platform they use (Apple ID, Google account, or a compatible manager). Syncing the Passkey across devices is a third-party feature over which Rivool has no control.

14.6.4. The User is strongly encouraged to set up their Passkey. The assets remain secure on the blockchain regardless, but access to the Rivool interface will require an active Passkey.

14.6.5. The User is responsible for monitoring the notifications sent by Rivool during the Protection Period of a recovery. Rivool will send daily notifications during the 7 days of the Protection Period. The User must immediately cancel any recovery they did not initiate.

14.6.6. The User acknowledges and accepts that the Passkey is the only mechanism for authorizing transactions in their Smart Wallet. The definitive loss of access to the Passkey, with no possibility of recovery through the Recovery Guardian, results in the permanent loss of access to the assets. Rivool cannot intervene in this situation.

USER RESPONSIBILITY: You are the sole guardian of your Passkey. Rivool has no way to recover your access outside the process described in Clause 14.8. If you lose your device and your Recovery Guardian at the same time, without access to the Passkey Manager, access to your assets may be permanently lost.

14.7. TECHNICAL LIMITATIONS AND EXCLUSION OF LIABILITY OF Rivool.

14.7.1. Rivool does not have access to, does not store and cannot recover the User's Private Key under any circumstances. This is a structural technical component, not an operational policy.

14.7.2. Rivool has no control over third-party Passkey Managers (Apple, Google, 1Password, Bitwarden, or others). Rivool is not liable for failures, unavailability, policy changes or discontinuation of these services that affect the User's access to their Passkey.

14.7.3. Rivool is not liable for failures of secure hardware (Secure Enclave or equivalent), operating system updates that affect the operation of passkeys, or any other technical limitations of the User's devices.

14.7.4. Rivool is not liable for transactions carried out by third parties who have obtained access to the User's device, to the biometrics registered on the device, or to the User's Passkey Manager, except in the event of a proven failure attributable exclusively to Rivool.

14.8. ACCOUNT RECOVERY

14.8.1. The only account recovery mechanism available on Rivool is the process described in this Clause 14.8. Rivool offers no other recovery channel, whether through human support, administrative reset or any other means.

14.8.2. The Recovery Guardian is the Privy wallet previously linked to the User's email. After the adoption of passkeys, the Recovery Guardian has no signing powers in the main transaction flow; it acts exclusively as a recovery mechanism in the social recovery module of the Smart Wallet.

14.8.3. To initiate a recovery, the User must:

  • (i) Access Rivool on a new device;
  • (ii) Authenticate with the email associated with the Account, activating the Recovery Guardian;
  • (iii) Register a new Passkey on the new device;
  • (iv) Wait for the Protection Period of 7 (seven) calendar days;
  • (v) Confirm the activation of the new Passkey at the end of the Protection Period.

14.8.4. The 7-day Protection Period is a security protection and not an operational limitation. It exists to ensure that any unauthorized recovery attempt, such as an attempt by someone who has access to the User's email, can be detected and canceled by the legitimate User before it takes effect.

14.8.5. During the 7 days of the Protection Period, Rivool will send the User:

  • (a) An immediate notification at the start of the recovery;
  • (b) Daily reminder notifications while the process is active;
  • (c) A final notification when the new Passkey is ready to be activated.

14.8.6. If the User receives notification of a recovery they did not initiate, they must cancel it immediately through the channel indicated in the notification. Rivool is not liable for recoveries completed during the Protection Period in which the User received the notifications and did not take steps to cancel.

14.8.7. If the User simultaneously loses: (a) access to the Passkey; (b) access to the Passkey Manager; and (c) access to the email associated with the Recovery Guardian, access to the account may be permanently unrecoverable. The assets will remain on the blockchain, but there will be no technical mechanism available to authorize transactions. Rivool has no ability to intervene in this situation.

CRITICAL WARNING: The email associated with your account is your safety net. Keep access to it. If you lose your Passkey and access to your email at the same time, with no possibility of recovery via the Passkey Manager, your assets may become permanently inaccessible.

14.9. SYNCING ACROSS DEVICES.

14.9.1. Syncing Passkeys across devices is performed exclusively by the Passkey Manager chosen by the User, and not by Rivool. Rivool does not control the syncing process, its availability or its technical requirements.

14.9.2. The Rivool Passkey may be stored:

  • (a) in the Passkey Manager of a phone or tablet, such as iCloud Keychain on Apple devices or Google Password Manager on Android devices. In this case, the Passkey can be used on a computer via QR Code and Bluetooth proximity, and its syncing follows the rules of the respective manager;
  • (b) in a physical security key compatible with the FIDO2 standard. In this case, the Passkey is stored only on the key and is not synced with other devices.

Rivool does not guarantee compatibility with third-party password managers, such as 1Password, Bitwarden or Dashlane, nor future compatibility with any Passkey Manager.

14.9.3. In the event of a change of ecosystem (for example, from Android to iPhone), the Passkey may not be transferred automatically. In such cases, the User must register a new Passkey through the recovery process described in Clause 14.8.

14.9.4. The User is responsible for keeping the syncing of their Passkey correctly configured on their devices. Rivool is not liable for access failures arising from the User's configuration of the Passkey Manager. The Passkey is bound to the internet domain of the Rivool platform, and access failures arising from a change of that domain by Rivool are not the User's responsibility.

14.10. TECHNOLOGY UPDATES AND CHANGES TO THE PASSKEY SYSTEM.

14.10.1. Rivool reserves the right to update, modify or replace the passkey system described in this Clause 14 in response to technological developments, security requirements or regulatory changes, provided that adequate prior notice is given to the User.

14.10.2. Material changes to the authentication and signing system will be communicated to the User at least 30 (thirty) days in advance, except in cases of security urgency requiring an immediate response.

14.11. The User's use of the passkey feature constitutes express acceptance of all the terms of this Clause 14, including the responsibilities assigned to the User and the limitations of Rivool's liability.

14.12. This Clause 14 must be read together with the other clauses of these Terms of Use, especially the clauses concerning the nature of Rivool as a software interface, the self-custody of assets, and the general limitations of liability.

15. WALLET AND SELF-CUSTODY

15.1. Self-custodial nature. The Wallet accessed through the Rivool interface is self-custodial (non-custodial). Control of the credentials that move the Virtual Assets belongs exclusively to the User. Rivool is not a custodian, does not hold possession of the Virtual Assets and has no technical means of moving them on the User's behalf.

15.2. Generation and control of credentials. When the Wallet is created, a set of cryptographic credentials under the User's exclusive control is generated (the "Credential", which, depending on the architecture, may comprise the private key, the recovery material ("Secret" or Recovery Phrase) and the Passkey described in Clause 14). Rivool does not generate, store, copy or have access to the Credential at any time.

15.3. Wallet technology provider (Privy). The embedded wallet infrastructure made available through the Rivool interface is provided by a technology partner, Privy (Horkos, Inc., D/B/A Privy). By creating or using the Wallet, the User acknowledges and agrees that: (A) Privy operates on a self-custodial basis and states that it does not store or have access to the User's private key, recovery material ("Secret") or other credentials, nor does it have the power to transact on the User's behalf; (B) use of the Wallet entails adherence to Privy's Terms of Use, available at https://www.privy.io/user-terms-of-service, which apply to the wallet technology layer and whose conditions, including Privy's limitations of liability, the User declares that they know and accept; (C) Rivool integrates Privy's technology solely as an interface and is not responsible for the availability, operation or any failures of the services provided directly by Privy, without prejudice to the limitations of liability set forth in Clause 7.

15.4. Safekeeping as the User's exclusive responsibility. The safekeeping, confidentiality and backup of the Credential are the sole and entire responsibility of the User. Neither Rivool nor its wallet technology partners have the technical ability to recover a lost Credential by administrative means, reset access outside the mechanisms provided for in these Terms, or reverse transactions.

15.5. Impossibility of recovery. Loss of the Credential, without the applicable recovery mechanism (Clause 14.8), results in the permanent loss of access to the Virtual Assets. Rivool has no copy of the Credential and cannot recover it. Transactions signed and broadcast to the network are irreversible, under the terms of Clause 4.3.

15.6. Independence from the platform. The Virtual Assets remain recorded on the blockchain and are owned and directly possessed by the User, regardless of the availability of the Rivool interface. In the event of unavailability or discontinuation of the platform, the User may access and move their Virtual Assets using their Credential in any compatible wallet software.

16. GENERAL PROVISIONS

16.1. The user agrees to use Rivool's Technology Services in strict compliance with applicable laws, including anti-money laundering regulations. The user declares that the funds moved through the interface are of lawful origin. The User further declares that they are not included on international sanctions or trade restriction lists and that they will not use the Platform to conceal assets, evade currency controls or finance illicit activities.

16.2. All content, design, source code, logos, graphics and interfaces made available by Rivool ("Content") are the exclusive property of Rivool or its licensors. Use of the Platform grants the user only a limited, revocable, non-exclusive and non-transferable license for personal use of the software. Copying, reverse engineering or redistribution of the Content without express authorization is prohibited.

16.3. These Terms do not create any partnership, joint venture, agency, franchise or employment relationship between the user and Rivool.

16.4. Tax Matters. Due to its non-custodial nature, Rivool does not withhold taxes at source on crypto-asset transactions. The user is solely responsible for calculating, reporting and paying any taxes levied on their capital gains arising from transactions facilitated by the Platform. Rivool does not provide tax advice.

16.4.1. Scope of tax liability. The User's tax liability covers the calculation and payment of taxes levied not only on capital gains, but also on any yield, rewards or other results obtained through the Platform's features. The User acknowledges that, as this is decentralized and self-custodial technology, any ancillary obligations to report or declare to the tax authorities of their place of domicile fall on the User. Rivool does not withhold, report or pay taxes on the User's behalf, nor does it provide tax advice.

16.5. Non-applicability of "Unclaimed Property". Unlike banks or custodial exchanges, Rivool does not hold possession of the assets. Therefore, there is no such thing as a "dormant account" or "unclaimed property" subject to appropriation or transfer to the State by Rivool. If the user stops using the Platform for years, their assets will remain secure on the blockchain, accessible only to whoever holds the Private Key.

16.6. Succession, Death and Incapacity. Rivool warns that, due to blockchain cryptography, it is not possible to transfer a deceased user's funds to their heirs if the heirs do not have the Recovery Phrase (Seed Phrase). (A) Access to the Account: Upon presentation of a valid probate inventory (Inventário) or court authorization (Alvará Judicial), Rivool may transfer ownership of the Rivool Account (login/access to the interface) to the estate administrator or heir. (B) Access to Funds: Transfer of the login does NOT guarantee access to the funds if the deceased did not leave the Private Key/Password accessible to the heirs. Rivool has no technical means to "break" the wallet's cryptography to deliver amounts to the estate. It is the user's exclusive responsibility to carry out their digital estate planning.

16.6.1. Supervening incapacity. The technical limitations described in this Clause apply equally to cases of the User's supervening incapacity. Upon presentation of a valid court document, such as a certificate of guardianship (termo de curatela), Rivool may transfer ownership of the Rivool Account to the legal representative, subject to the technical impossibility of accessing self-custodied assets without the Private Key or Recovery Phrase.

16.7. Entire Agreement and Assignment. These Terms constitute the entire agreement between the parties. Rivool may assign or transfer its rights and obligations under this agreement (in the event of a merger, acquisition or sale of assets) without the need for the user's prior consent, provided that notice is given.

16.8. Changes to the Terms. Rivool may change these Terms at any time. Changes will take effect on the date of their publication on the Platform. Continued use of the services after the change constitutes tacit acceptance. If the user does not agree, they must stop using the interface immediately.

16.9. Electronic Communications. The User expressly agrees to receive all communications, contracts, documents, legal notices, disclosures and updates to these Terms and the Privacy Policy by electronic means (including email, in-app notifications and notices on the Platform), which will have the same validity and effect as written communications. It is the User's responsibility to keep their contact details up to date.