1. Key Definitions
For these Terms, the definitions below apply.
- Technology platform for the integration of financial and payment services: digital environment that allows the User to access, manage, and move financial resources, as well as interact with services and digital assets supported by third parties, with no custody or direct intermediation by the Provider.
- User: individual or legal entity who creates an account, accesses, or uses the App.
- Payment Account: account used to execute financial transactions, held at an institution authorized by the Central Bank of Brazil.
- Transaction: any financial operation performed by the User.
- Provider: company responsible for the App, including parents, subsidiaries, employees, representatives, and authorized partners.
- Assets: financial resources held in a payment account, which may include integrations with digital assets supported by third parties, with no custody or direct intermediation by the Provider.
- Pix: instant payments arrangement instituted by the Central Bank of Brazil.
- MED: Special Refund Mechanism applicable to Pix.
- Regulators: government bodies, agencies, and supervisory authorities with jurisdiction over the services.
2. Acceptance of Terms
Using the App implies full acceptance of these Terms and complementary documents such as the Privacy Policy and Security Policy.
If the User disagrees with any condition, they must immediately stop accessing and close their account.
The Provider may change these Terms at any time, notifying through the App or official channels; continued use implies agreement with the current version.
3. Eligibility and Registration
Only individuals 18 or older with full legal capacity, or duly appointed legal representatives, may use the App.
Registration requires providing truthful, updated, and complete data, including information for identity verification (KYC) and anti–money laundering (AML).
The Provider may refuse, suspend, or close accounts in case of irregularities, regulatory noncompliance, or identified risk.
The Provider undertakes to notify the User, through the App or official channels, in case of suspension or closure of the account, informing the reason for the measure.
4. App Services
The App offers the following capabilities, which may vary based on updates and applicable regulations.
The Provider operates in accordance with the regulations of the Central Bank of Brazil, and may offer payment services and execute financial transactions, including Pix operations, in accordance with the rules in force.
- Viewing balances, statements, transaction history, and reports.
- Execution of transfers and financial movements of supported Assets.
- Tools for analysis, projection, financial education, and portfolio management.
- Integration with third-party APIs, financial institutions, data providers, and payment systems.
- Additional services made available under specific terms and any applicable fees.
5. User Responsibilities
By using the App, the User agrees to:
The User must keep their credentials (login, password, multi-factor authentication) and access devices confidential. Improper use resulting from negligence or voluntary sharing of credentials shall be the User's responsibility. If there are signs of unauthorized access or fraud by third parties, the User must immediately notify the Provider, which will adopt blocking and investigation measures to mitigate risks. The Provider and the User shall cooperate to reduce impacts and hold any offenders accountable.
- Keep credentials (login, password, multi-factor authentication) and access devices confidential, acknowledging that all actions under their credentials are their sole responsibility.
- Update registration data whenever a relevant change occurs.
- Comply with applicable laws, including tax, foreign exchange, regulatory, and anti–money laundering requirements.
- Evaluate transaction risks, recognizing that the Provider does not guarantee profitability, appreciation, or absence of losses.
- Use the App ethically, without fraudulent, illegal, or rights-infringing practices.
6. Provider Responsibilities
The Provider commits to:
The Provider shall not be liable for failures, delays, or unavailability arising from services performed by institutions responsible for settling or processing transactions.
The Provider does not guarantee immediate settlement of transactions in all cases; delays may occur for technical, operational, regulatory, or risk-analysis reasons.
- Offer technology infrastructure aligned with information security best practices.
- Maintain reasonable App availability, performing scheduled or emergency maintenance as needed.
- Fulfill legal and regulatory obligations, including reports to competent authorities.
- Provide technical support through indicated channels, within disclosed timelines and hours.
7. Special Refund Mechanism (MED)
In cases of suspected fraud, error, or regulatory determination, the Provider may block amounts and initiate refund procedures via MED, in accordance with applicable regulations. The User will be informed of the opening and progress of the refund procedure through the App or official channels. The Provider is not responsible for refunds outside the scope of MED or in disagreement with the regulations in force. The deadlines and conditions for completing the refund will follow the rules established by the Central Bank and other competent authorities.
Funds may remain blocked for the time necessary for analysis, in accordance with regulatory and security criteria.
8. Fees, Costs, and Taxes
Fees may be charged for specific services, such as operations, withdrawals, custody, or subscriptions. Values and criteria will be informed in advance in the App.
Taxes on operations or earnings are the User's responsibility, who must follow relevant tax obligations.
The Provider may withhold or deduct amounts required by law, court order, or competent authority.
The Provider may change fees with prior notice to the User.
9. Compliance, KYC, and AML
The User authorizes the Provider to collect, verify, and share information with credit bureaus, public and private databases for identification, fraud prevention, and legal compliance.
Suspicious activities may be reported to authorities without prior notice to the User.
The Provider may request additional documents, impose limits, or suspend operations until required checks are completed.
Transaction monitoring will be continuous, and the Provider may reassess the User's profile at any time, under the applicable regulations, including Circular No. 3.978 of the Central Bank of Brazil. The processing of the information collected will observe the data protection legislation in force.
10. Data Protection and Privacy
Personal data are processed according to the Privacy Policy and applicable law, including the Brazilian LGPD.
Processing of data may occur on the basis of legal and regulatory obligations and legitimate interest, under applicable law.
The User consents to processing, storage, and international transfer of data when necessary to deliver the service.
The Provider applies technical and organizational controls to mitigate unauthorized access risks, though no system is fully infallible.
Data may be shared with financial institutions, Pix participants, and competent authorities, exclusively to comply with legal, regulatory, or operational obligations necessary for the provision of services.
11. Security and Authentication
Multi-factor authentication is mandatory whenever available.
The Provider may block suspicious access, require credential resets, or update security protocols without prior notice.
Incidents or suspected compromise must be immediately reported by the User to support channels.
The Provider may log and audit access attempts for investigation and compliance purposes.
The Provider observes information security best practices and complies with applicable law. Although it is not possible to guarantee absolute protection against external attacks, it maintains monitoring and response processes designed to reduce impacts and preserve the integrity of the services.
12. Transactional Monitoring and Security
The Provider continuously monitors transactions to prevent fraud, and may block, limit, or suspend operations at any time. The User will be informed, whenever possible, of the measures applied. Monitoring observes the applicable regulations, including Circular No. 3.978 of the Central Bank of Brazil, and transactions may be logged and audited for investigation and compliance purposes.
The Provider may refuse or fail to process transactions that show signs of irregularity, data inconsistency, suspicion of fraud, or noncompliance with regulatory requirements.
13. Liability Limitations
The App is provided 'as is,' without guarantees of error-free operation, uninterrupted availability, or fitness for a particular purpose.
The Provider is not liable for indirect losses, lost profits, moral damages, or consequential damages from using the App.
The Provider shall not be liable for losses arising from fraud, misuse, or failure attributable to the User.
Events beyond reasonable control—force majeure, government actions, or third-party failures—exclude the Provider's liability.
Interruptions caused by preventive or corrective maintenance or system updates do not give rise to liability for the Provider.
In any case, the Provider's total liability is limited to the fees paid by the User in the 12 months preceding the event.
The Provider shall not be liable for failures arising from incorrect data provided by the User.
The provisions of this clause shall be interpreted in accordance with applicable law and do not imply waiver of the User's non-waivable rights or exclusion of liabilities that cannot be limited by law.
14. Financial Risk Disclaimer
Operations with financial assets and digital assets supported by third parties, with no custody or direct intermediation by the Provider, involve volatility and risks of market, liquidity, credit, counterparty, technology, and regulation.
The User affirms understanding these risks and acting on their own account, acknowledging the Provider does not offer financial, legal, tax, or investment advice.
There is no guarantee of profitability or absence of losses, and investment decisions are the sole responsibility of the User. Operations will observe the applicable regulations, without prejudice to the risks inherent to the market.
15. Communications and Notices
Official communications will be sent through the App, registered email, SMS, or push notifications.
Judicial or legal notices may be made through proper means, in accordance with applicable law.
The User must keep contact channels up to date; communications are deemed received on the send date.
16. Suspension and Termination
The User may close the account upon request, subject to pending obligations and operational timelines.
The Provider may suspend or terminate accounts in the following cases: suspected fraud, registration inconsistency, regulatory noncompliance, determination by a competent authority, or operational risk. Whenever possible, the User will be informed in advance of the measure adopted. In cases where immediate communication may compromise the investigation, the security of the system, or compliance with regulatory requirements, the Provider may suspend or terminate without prior notice, informing the User as soon as feasible.
Termination does not waive prior obligations, including financial settlement and record retention as required by law.
17. Intellectual Property
All App content, including code, trademarks, layout, and algorithms, is owned by the Provider or licensors and is protected by intellectual property and copyright legislation. Reproduction, reverse engineering, or misuse without express authorization is prohibited. Use of the App is limited to the purposes set out in these Terms, and any violation may result in account suspension and civil and criminal liability.
18. Assignment and Subcontracting
The Provider may assign rights and obligations to group companies or authorized third parties, remaining responsible to the User.
The User may not assign or transfer their account without the Provider's prior express consent.
Any assignment or subcontracting will observe applicable law and will not affect the User's rights under these Terms, which will remain intact and assured.
The User will be informed of relevant assignments that directly impact the provision of services.
19. Governing Law and Venue
These Terms shall be governed by Brazilian law, including, but not limited to, the rules issued by the Central Bank of Brazil, the Securities and Exchange Commission (CVM), and other competent authorities.
The courts of São Paulo, SP are chosen to settle disputes, unless specific jurisdiction or a different agreement applies.
20. General Provisions
Any tolerance of noncompliance does not imply waiver or novation of rights.
If any clause is deemed invalid, the remaining provisions stay effective.
These Terms replace previous versions and take effect from the latest recorded update in the App.
These Terms constitute the entire agreement between the parties, prevailing over any prior understandings.
Future changes will be communicated to the User and will take effect upon publication in the App.