Terms and conditions

Terms and Conditions of Use and Privacy Policy

CryptoRevolution LLC – BETA Phase (Testing) Version: 1.0 — Effective Date: November 3, 2025.

INTRODUCTION

1. This User Agreement (the “Agreement”) shall govern the access, registration, and utilization of the platforms, API interfaces, mobile applications, and brokerage, exchange, limited custody, and other digital services operated by CryptoRevolution LLC (the “Company”) during its BETA-testing Phase.
2. Term and Effectiveness.The Agreement shall become effective on November 3, 2025, and shall remain in effect for an estimated duration of one (1) month, renewable for the same period, which renewal shall be dependent on the time required for the Platform to become optimal for production deployment. This Agreement governs the relationship between the Company and each User upon the User’s electronic acceptance hereof.
3. Access to the Platform during the BETA-testing Phase shall be exclusively by express invitation issued by CryptoRevolution LLC or by approval activation granted by the Company. The Invitation shall include registration instructions, required verification levels, and links to this Agreement and its appendices. The receipt of an Invitation does not obligate the Company to maintain its validity; the Company reserves the right to revoke, suspend, or modify Invitations in accordance with its risk and compliance policies.
4. DEFINITIONS

• User:Means any Natural Person or Legal Entity that registers for and utilizes the Services.
• Account:Means a verified profile that enables access to commercial services.
• Crypto-Asset:Means any token, virtual currency, or digital representation of value.
• Broker / Liquidity Provider:Means a third party that provides liquidity or executes trades/transactions.
• KYC / KYB:Means Know-Your-Customer and Know-Your-Business procedures.
• AML / CTF:Means Anti-Money Laundering and Counter-Terrorist Financing.
• API:Means Application Programming Interfaces that expose technical functionalities.
• Appendices:Means the documents integrated into this Agreement: Appendix A (Fees), Appendix B (Privacy Policy), Appendix C (Disclaimers), Appendix D (SLA and Procedures), Appendix E (Forms), Appendix F (API Terms), Appendix G (Audit and Compliance), Appendix H (Glossary and Contacts).

III. CONDITIONS OF USE

1. Eligibility Requirements

• Must be of legal age (or a Major) and possess the legal capacity to contract under the laws of the State of Florida.
• Must not be a national or fiscal resident of the United States; the Company does not provide services to US nationals or US fiscal residents. The User hereby warrants and represents the veracity of this condition under penalty of liability.
• Must not be listed on any Sanctions Lists or on any internal risk lists.

1. Invitation, Registration, and Verification

• Access by Invitation: The User may only register using an active Invitation. The Invitation shall contain a direct link to the registration process and the full text of this Agreement.
• Tiered Onboarding: Verification levels ranging from “Basic” to “Institutional” based on KYC/KYB compliance. The Company reserves the right to request additional documentation (identity, proof of address, source of funds verification, UBO documentation).
• Continuous Screening: The Company shall conduct periodic screenings against Sanctions Lists, PEPs (Politically Exposed Persons), and open-source data.
• Any lack of documentary veracity shall entitle the Company to suspend, limit, or terminate the Account and report to regulatory or other authorities.

1. Prohibited Activities

• Unlawful Use:Use for illicit purposes, including but not limited to, money laundering, fraud, terrorist financing (CTF), tax evasion, market manipulation, Ponzi schemes, or pump-and-dump schemes.
• Use of unauthorized automated tools or bots, except where expressly authorized via API subject to specific quotas and conditions.
• Opening or maintaining Accounts through fraudulent anonymity, impersonation, or unauthorized representation.

1. User Responsibilities

• To safeguard credentials and activate Multi-Factor Authentication (MFA); and immediately report any unauthorized access.
• To comply with all tax and reporting obligations in the User’s jurisdiction.
• Not to reproduce or exploit the Platform, APIs, or documentation without prior written authorization.
• To be responsible and liable for the acts of any persons authorized to operate the Account.

1. PRODUCTS, SERVICES, AND SCOPE

• Services Offered:Spot market trading, limit/market orders, Over-the-Counter (OTC) services via separate agreements, brokerage, limited custody services (hot/cold wallets), access to liquidity pools, and APIs for institutional integration.
• The Company may list, delist, suspend pairs, or modify limits and products in accordance with internal policies and regulatory requirements.
• Technical descriptions, limits, and specific conditions shall be set forth in Appendix F and the product interfaces.

 

1. FEES, BILLING, AND PAYMENTS

• Applicable fees are detailed in Appendix A and on the Platform: maker/taker commissions, onchain/offchain withdrawal charges, fiat conversion fees, inactivity fees, and premium services charges.
• The Company reserves the right to modify fees subject to prior notification in accordance with the modifications clause.
• The User shall be responsible for all applicable taxes; the Company may withhold amounts if required by applicable law or regulation.

 

 

1. PRIVACY AND DATA PROCESSING

• Scope and Framework. The Company adopts commercially reasonable technical and organizational measures for the protection of Personal Data. The complete Privacy Policy is set forth in Appendix B.
• Data Collected: Identification data, financial data, associated wallets, technical data (IP, logs, geolocation), and other data required for KYC/KYB and AML/CTF compliance.
• Purposes: Identity verification, AML/CTF compliance, fraud prevention, risk management, service execution, product analytics and improvement, and communications.
• Retention: Data shall be retained for no less than five (5) years or the period required by a competent authority.
• User Rights: The rights of access, rectification, erasure (deletion), data portability, and objection shall be available to the User, in accordance with the procedures set forth in Appendix B.
• International Transfers: Data may be hosted outside the User’s jurisdiction, provided that appropriate contractual and technical safeguards are implemented.

VII. INFORMATION SECURITY

• Measures Implemented: Encryption in transit and at rest, key management, Hardware Security Modules (HSM), access control, logging, penetration testing, and periodic external audits.
• Shared Responsibility: The Company shall apply reasonable controls; the User must adopt proper security practices (MFA, backups, secure storage of private keys).
• Incidents: The Company shall notify relevant breaches and coordinate remediation in accordance with legal obligations and best practices.

VIII. COMPLIANCE, AML/CTF, AND RISK MANAGEMENT

• Compliance Program: Transaction monitoring, screening of counterparties, PEPs, and sanctioned entities; reporting of suspicious activity to competent authorities.
• Retention and Freezing: The Company shall be entitled to retain, freeze, or dispose of funds when required by a court in order or when there is a substantiated suspicion of illicit activity.
• Institutional Clients: Subject to additional documentation requirements, controls, and specific agreements.

1. RISKS AND LIMITATION OF LIABILITY

• Market Risk: The User acknowledges the volatile nature of Crypto-Assets and the possibility of total loss of capital.
• Exclusions: Except for proven willful misconduct (dolo) or gross negligence, the Company shall not be liable for lost profits (lucro cesante), indirect losses, losses arising from third parties, or blockchain failures.
• Technology: Uninterrupted availability is not guaranteed; faults, outages, or hacks may occur.
• Limitation of Liability: The Company’s total liability for any claim shall be limited to the aggregate amount of commissions paid by the User in the six (6) months preceding the event giving rise to the claim, save for proven willful misconduct or liability for personal data as per applicable law.

1. INTELLECTUAL PROPERTY

• The Company shall retain all intellectual property rights over the platform, software, APIs, documentation, and trademarks.
• The User is granted a limited, revocable, non-transferable, and non-exclusive license to use the platform in accordance with this Agreement.
• Reverse engineering, decompilation, or unauthorized copying is prohibited.

1. CONFIDENTIALITY

Information classified as confidential shall be maintained by the Parties; this obligation shall survive for five (5) years following the termination of this Agreement, except for information that must be preserved for a longer period by law.

XII. TERMINATION AND EFFECTS

• Grounds for Termination: Material breach, fraud, User request, court order, detection of User’s US nationality/residency, or failure to comply with KYC/KYB requirements.
• Effects: Account closure, liquidation of positions, temporary retention of funds for legal compliance, and withdrawal procedures in accordance with Appendix D.
• Survival: Provisions regarding outstanding payments, limitation of liability, confidentiality, intellectual property, and data processing shall survive termination.

 

XIII. GOVERNING LAW, ARBITRATION, AND WAIVER OF COURTS

• Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the State of Florida, United States, without regard to its conflict of laws principles.
• Mandatory Arbitration. Any dispute, controversy, or claim arising out of or relating to this Agreement shall be settled by final and binding arbitration administered by the American Arbitration Association (AAA) under its then-current Commercial Rules.
• The seat of the arbitration shall be Miami, Florida; in-person hearings shall be conducted in Miami unless otherwise agreed.
• Waiver of Class Actions. The Parties waive the right to class actions or collective lawsuits; claims shall be resolved on an individual basis.

XIV. MODIFICATIONS TO THE AGREEMENT

The Company reserves the right to modify this Agreement upon notification to the User via email and publication on the platform. Non-objection or continued use shall constitute acceptance.

1. NOTIFICATIONS

Official communications shall be sent to the User’s registered email address and/or via notifications on the platform. For legal purposes, the Company designates its domicile in Miami, Florida, as indicated in appedix H.

APPENDIX A — Fees and Billing (Full Text)

1. General Structure

• Maker / Taker Commissions: Published on the Platform; may vary based on trading volume and Account type.
• On-chain Withdrawal Fees: Users shall be charged dynamic network fees (gas fees) plus a fixed administrative commission as published on the Platform.
• Fiat Deposit Fees: Subject to the method used and commercial agreements; the Company may impose administrative charges.
• Fees for Institutional Services, High-Frequency API Connection, and Premium Services: Subject to separate contractual agreements.

 

2. Billing and Adjustments

Electronic Invoices and summaries shall appear in the User’s dashboard; the Company may issue formal invoices for services rendered.

Adjustments for technical or billing errors may be corrected and, where applicable, reimbursed according to the current policy.

3. Withholdings and Taxes

The User shall be responsible for the payment of local taxes; the Company may withhold amounts if required by applicable legislation.

4. Fee Changes

The Company shall notify changes with at least the notice period published in its notification policy; continued use shall constitute acceptance.

APPENDIX B — Privacy Policy (Full Text)

1. Data Controller

CryptoRevolution LLC shall act as the Data Controller for the personal data collected within the scope of this Agreement.

2. Data Categories

 

• Identification:Name, identification document, date of birth.
• Contact:Email, phone number, address.
• Financial:Transaction history, balances, linked bank accounts.
• Technical:IP address, access logs, geolocation, device information.
• KYC/KYB:Supporting documentation, UBO (Ultimate Beneficial Owner) details, proof of source of funds.

 

3. Purposes

Identity verification, fraud prevention, AML/CTF compliance, contractual performance, operational analysis, and commercial communication with consent where applicable.

4. Legal Basis

Contractual performance, compliance with legal obligations, and the Company’s legitimate interest for fraud prevention and operational security.

5. Retention

Minimum Retention Periods: 5 years unless otherwise legally required.

6. Data Subject Rights

The rights of access, rectification, erasure, restriction (limitation), objection, and data portability shall be available in the terms provided by applicable law; procedures and timelines are detailed on the Platform.

7. Transfers and Subprocessors

Transfers to third parties and Subprocessors are permitted with contractual safeguards; a list of Subprocessors is available upon request (or on the Platform).

8. Security

Technical and organizational measures shall be implemented to ensure the confidentiality, integrity, and availability of the data.

9. Contact

Data Protection Officer or Privacy Officer contact details are published in Appendix H.

APPENDIX C — Legal and Commercial Disclaimers (BETA)

The following limitations and disclaimers are hereby provided to the User:

1. Jurisdictional Risk:The use of the Services may be prohibited in certain jurisdictions; the User is responsible for verifying local legality.
2. Asset Legality:The Company does not warrant the legality of Crypto-Assets across all jurisdictions.
3. Invitation Revocability:The receipt of an invitation does not obligate the Company to maintain the invitation or to open an Account.
4. Access Revocation:The Company reserves the right to revoke invitations, access, or services for compliance, risk, or security reasons.
5. Investment Warning:Investments in Crypto-Assets are highly volatile and may result in the total loss of capital.
6. Past Performance:Past performance does not guarantee future results.
7. Liquidity:Sufficient liquidity for the execution of orders at all times is not guaranteed.
8. Slippage/Partial Execution:During periods of high volatility, orders may be partially executed, subject to slippage, or may not be executed at all.
9. Blockchain Failures:The Company shall not be liable for losses caused by failures in blockchain networks, network congestion, or forks.
10. Third-Party Software:Third-party software may contain vulnerabilities outside the Company’s control.
11. Leverage Risk:The use of leverage carries a high risk; losses may exceed the capital invested.
12. No Advice:CryptoRevolution LLC does not offer financial, legal, or tax advice.
13. No Endorsement:The presence of a token on the Platform does not imply endorsement or recommendation.
14. Asset Management:The Company may suspend, limit, or delist assets for technical, regulatory, or risk reasons.
15. Fee Changes:Applicable fees may vary; changes will be notified in accordance with the modifications clause.
16. Data Sharing:The Company may share data with authorities under legal request or to fulfill AML/CTF obligations.
17. Data Sale:The Company does not sell personal data to commercial third parties.
18. Anonymity:Total anonymity is not guaranteed in operations subject to AML/KYC processes.
19. User Custody:The User is responsible for the secure custody of their credentials and private keys.
20. Unauthorized Access:CryptoRevolution LLC shall not be liable for unauthorized access where the User fails to comply with their custody obligations.
21. Service Continuity:The Company does not guarantee uninterrupted service continuity; outages, maintenance, or updates may occur.
22. Data Storage:Data may be stored on servers outside the User’s jurisdiction.
23. API Usage:API interfaces are subject to usage limits and quotas; non-compliance may lead to access revocation.
24. Unauthorized Automation:The use of unauthorized bots or automation is prohibited.
25. Administrative Charges:The Company may impose administrative charges for investigations, claims, or extraordinary management procedures.
26. Conflict of Terms:In the event of a conflict between this Agreement and specific policies published on the Platform, this Agreement shall prevail unless expressly stated otherwise.
27. Controlling Language:Translations of this Agreement are for informational purposes only; the English text shall prevail in the event of any discrepancy.
28. Third-Party Solvency:The Company assumes no responsibility for the conduct or solvency of third-party Brokers or Liquidity Providers.
29. Non-Bank Status:CryptoRevolution LLC is not a bank or regulated depository institution unless established in specific agreements.
30. Order Routing:Orders may be routed to third parties and are subject to their practices and execution times.
31. Third-Party Integration:The Company does not guarantee that third-party technical integrations will function without interruption.
32. Promotions:Promotions and incentive programs are subject to additional terms and may be canceled.
33. Trading Limits:The Company may impose limits per User, asset, or trading pair in accordance with its risk policy.
34. Fund Investigation:The Company may investigate and suspend funds upon reasonable suspicion of illicit activity.
35. Fund Retention:The Company may retain funds if required by a court order or competent authority.
36. Compliance Decisions:Decisions based on the Company’s risk and compliance model shall be final absent proof to the contrary.
37. Warranties:No warranties are offered regarding performance, absolute security, or total absence of faults.
38. Withdrawal Timing:On-chain withdrawal processing times depend on network congestion; the Company does not guarantee specific timelines.
39. Additional Verification:The Company may require additional verification periods before allowing significant withdrawals.
40. International Operations:International operations may incur additional costs and delays.
41. User Errors:The Company assumes no liability for User errors resulting in losses (sending to erroneous addresses, wrong network).
42. User Responsibility:The User is solely responsible for reviewing network fees and confirming transactions.
43. Atypical Activity:The Company may impose additional KYC/KYB requirements on Users with atypical activity.
44. Account Suspension:The Company may suspend accounts that breach policies or present unusual risk.
45. Compatibility:The Company does not guarantee compatibility with all third-party wallets or solutions.
46. No Fiduciary Relationship:Acceptance of this Agreement does not create a fiduciary relationship unless formalized by a separate written agreement.
47. Market Structure:The Company may change the structure of supported pairs and markets without prior notice, unless legally restricted.
48. Regulatory Cooperation:The Company shall cooperate with authority investigations and disclose pertinent information.
49. Force Majeure:The Company shall not be liable for losses arising from force majeure, wars, governmental actions, or infrastructure failures.
50. Limitation of Liability:The established limitations of liability are applicable and reasonable under the circumstances.
51. Technical Disputes:In technical disputes, the Platform’s logs shall constitute presumptive evidence.
52. Policy Updates:The Company may update security and operational policies; acceptance of such updates is a condition of continued use.
53. Beta Features:Beta or experimental features may be deactivated or modified without any obligation of reinstatement.
54. Data Misuse:The Company shall adopt reasonable measures to prevent misuse of data by third parties with access; it does not warrant total absence of misuse.
55. High-Risk Clients:The Company may impose additional conditions on institutional and high-risk Users.
56. Regulatory Risk:The Company reserves the right to deny services to jurisdictions presenting regulatory risk.
57. Communications:Communications sent by the Company may include notices and risks; the User is responsible for reviewing their email and notifications.
58. Discretionary Decisions:Discretionary decisions regarding risk, compliance, and security, if adopted in good faith, shall not generate liability.
59. Supplementation:Appendix C may be supplemented with additional disclaimers without affecting the validity of the other clauses.
60. Price Fluctuations:The Company assumes no liability for price fluctuations between different markets (spread between exchanges).
61. Conditional Orders:Conditional orders (stop, stop-limit) may not be executed at the expected price during high volatility.
62. Market Depth:The Company does not guarantee the availability of pairs with sufficient market depth for large volumes.
63. API Risk:The use of services via APIs implies technical risk; the Company shall not be liable for the misuse of APIs by third parties.
64. API Keys Security:User API keys must be protected; their exposure may result in losses that the Company will not cover unless the Company’s willful misconduct (deceit) is proven.
65. Simulations:Testing or simulation environments (sandbox) do not reflect real market conditions.
66. Alpha/Beta Risk:Alpha/beta testing may contain errors; its use is at the User’s own risk.
67. Support Response Times:The Company does not guarantee fixed response times for support on non-institutional accounts.
68. Security Limitations:The Company may limit access or services for security reasons without prior notice.
69. Suspicious Operations:The Company may demand additional documentation for suspicious operations and shall not be liable for any resulting delays.
70. Withdrawal Suspension:The Company may suspend withdrawals due to liquidity reasons or compliance requirements.
71. No Compensation:The Company shall not compensate for losses resulting from faults or adverse market conditions unless there is a legal obligation to do so.
72. Electronic Communications:The User agrees to receive electronic communications; notifications by other means shall be governed by the notification policy.
73. Scheduled Interruptions:Internal and external security testing may involve scheduled interruptions.
74. Temporary Limits:The Company may introduce temporary withdrawal limits for risk management purposes.
75. Protocol Interoperability:The Company does not guarantee interoperability between different blockchain protocols.
76. Address Blocking:The Company may block addresses identified for risk or sanctions.
77. Account Balances:Balances shown may reflect custodial balances, not necessarily the User’s absolute ownership until complete settlement.
78. Retroactive Claims:The Company may retroactively claim commissions for proven billing errors.
79. Standards & Certifications:Standards and certifications (ISO, SOC) apply according to the communicated scope; they do not imply unlimited coverage.
80. Minor Claims:The Company may require individual arbitration for minor claims.
81. Aggregated Statistics:The Company may publish aggregated usage statistics without identifying Users.
82. API Functionality:The Company may impose limits on API functionality to mitigate risks.
83. Off-Market Orders:Orders executed outside market hours may be settled according to applicable execution rules.
84. Right to Refuse Service:The Company reserves the right to deny service to any User for legitimate risk reasons.
85. Account Recovery:Account recovery procedures may require additional verification and variable timeframes.
86. Custody Services:The Company may offer custody services with specific agreements and risks; applicable terms must be reviewed.
87. Transaction Reversibility:Reversible transactions shall depend on the technical capacity of the blockchain; reversibility is not guaranteed.
88. Insolvency:In the event of the Company’s insolvency, the User’s rights shall be governed by applicable law and insolvency regulations.
89. External Audits:External audits are conducted in accordance with the published scope; they do not imply a total guarantee.
90. New Token Rules:The Company may establish special rules for new token launches (airdrops, listings).
91. Social Engineering:The Company shall not be liable for losses resulting from phishing or other social engineering attacks.
92. Tax Records:The Company recommends that the User retain transaction records for tax purposes.
93. Third-Party Products:Balances involved in staking, lending, or other third-party products are subject to the terms of the third-party provider.
94. Exceptional Market Conditions:The Company may suspend or limit operations during exceptional market conditions.
95. Additional Agreements:The Company may require additional agreements for OTC or institutional services.
96. Delegation:The Company may delegate functions to affiliates or third parties with appropriate notifications and safeguards.
97. Investigations:The Company may initiate investigations and preserve evidence upon suspicion of illicit activity.
98. Exit Controls:The Company may implement exit controls for large withdrawals or transfers.
99. No Loss Reimbursement:The Company does not promise reimbursement for losses resulting from the User’s market decisions.
100. Mandatory Security Reviews:The Company may impose mandatory security reviews on accounts exhibiting atypical activity.
101. Account Reactivation:The Company may condition the reactivation of closed accounts on additional verifications.
102. Asset Listings:The Company may publish lists of priority and high-risk assets; the absence of inclusion does not imply a recommendation.
103. Advanced Features:The Company may deny access to advanced features based on risk criteria.
104. Regulatory Collaboration:The Company may retain information and cooperate with authorities pursuant to legal obligations.
105. Market Data Disclaimer:Indicators, graphs, and market data on the Platform are informative and do not constitute advice.
106. Promotional Benefits:The Company may withdraw or modify promotional benefits at any time.
107. User Responsibility:The Company is not liable for the User’s legal, or tax decisions based on information from the Platform.
108. International Court Orders:The Company may suspend accounts based on international court orders in accordance with cooperation agreements.
109. Enhanced Due Diligence:The Company may require enhanced due diligence procedures for counterparties with reputational risk.
110. Dispute Resolution:The Company may delegate the resolution of technical disputes to independent experts.
111. Amendment:The Company may update this Appendix C with new disclaimers and notices to be published on the Platform.
112. User Communication Failures:The Company is not responsible for failures in the User’s messaging or email services.
113. Complementary Agreements:The Company may condition services on the signing of complementary agreements.
114. Institutional Confidentiality:The Company may require additional confidentiality clauses in institutional relationships.
115. API Deactivation:The Company may deactivate API functionalities upon detected threats.
116. Claim Waiver:The Company may waive claims in exceptional cases based on documented managerial discretion.
117. Geo-IP Limits:The Company may impose limits based on IP or geolocation in accordance with its security policies.
118. Third-Party Documentation:The Company does not warrant that all documentation provided by third parties is correct or complete.
119. Referral Abuse:The Company may suspend incentives in referral programs upon detected abuse.

APPENDIX D — SLA and Operational Procedures (Full Text)

1. On-chain Deposits: Timings are network-dependent; the Platform shall validate the required number of confirmations per asset as published.
2. On-chain Withdrawals: Processed in accordance with internal policies; may require additional verification.
3. Institutional Support: SLA levels, response times, and channels are defined in the Platform’s support section.
4. Incidents: Escalation procedure, logging (bitácoras), and communication to affected Users.
5. Discrepancies and Reconciliation: Steps and timelines for claims related to movements and transactions.

APPENDIX E — Forms and Templates

Individual and Institutional KYC form; UBO (Ultimate Beneficial Owner) form; Authorization templates; Data Portability request form; Notice assignment; Electronic Consent templates.

APPENDIX F — API and Developer Terms

1. API Keys: Issuance, rotation, and revocation; the User must protect keys and secrets.
2. Usage Limits: Published quotas; exceeding quotas may result in throttling or revocation.
3. Versioning: The Company shall announce deprecations with reasonable advance notice.
4. Responsibilities: The Company assumes no liability for the User’s defective integrations.

APPENDIX G — Audit, Compliance, and Reporting

Annual external audit plan; scope; publication of reports; subprocessors and remediation programs.

APPENDIX H — Glossary, Contacts, and Domicile

Expanded technical glossary; legal and fiscal addresses in Miami; contacts for support, compliance, and legal matters.

ACCEPTANCE

By accepting this Agreement through the electronic consent procedure provided on the Platform or by electronic signature, the User hereby declares that they have read, understood, and accepted all the terms, conditions, disclaimers, and Appendices incorporated herein, agrees to receive an invitation for access in accordance with the Company’s policies, and acknowledges the limitations and risks detailed.