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Terms of Service

Atlas Foundry Limited • Luca Money Platform

IMPORTANT NOTICE — READ CAREFULLY

BY DOWNLOADING, INSTALLING, ACCESSING, OR USING THE LUCA MONEY APPLICATION OR PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS OF SERVICE. YOU ALSO ACKNOWLEDGE THAT YOU UNDERSTAND AND ACCEPT THE SUBSTANTIAL RISKS INVOLVED, INCLUDING THE POSSIBILITY OF PARTIAL OR TOTAL LOSS OF DIGITAL ASSETS. THE PLATFORM INTERACTS WITH BLOCKCHAIN NETWORKS AND DECENTRALIZED LENDING PROTOCOLS THAT CARRY INHERENT RISKS. ANNUAL PERCENTAGE YIELD ("APY") IS VARIABLE AND NOT GUARANTEED. WE ARE NOT A BANK, MONEY TRANSMITTER, OR REGULATED FINANCIAL INSTITUTION. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE PLATFORM.

1. DEFINITIONS AND INTERPRETATION

1.1 In these Terms:

  • "Company," "we," "us," or "our" means Atlas Foundry Limited, a company incorporated in the British Virgin Islands ("BVI"), Company No. 2170810, with registered address at Intershore Chambers, Road Town, Tortola, British Virgin Islands.
  • "Platform" means the Luca Money mobile application (iOS and Android), web application, and all related services, features, content, and functionality.
  • "User," "you," or "your" means any person who downloads, installs, accesses, or uses the Platform.
  • "Digital Assets" means cryptographic tokens, cryptocurrencies, stablecoins (including but not limited to USDC), and other blockchain-based digital assets supported by the Platform.
  • "Wallet" means the self-custodial blockchain wallet created through the Platform, including both the externally owned account (EOA) and any associated smart contract wallet (Account Abstraction wallet).
  • "Private Keys" means the cryptographic keys that control access to your Wallet and Digital Assets, which are generated on your device and remain solely in your custody.
  • "Recovery Materials" means the recovery phrase, backup file, passkey, PIN, or any other mechanism used to restore access to your Wallet.
  • "Allow-Listed Lending Protocols" means reputable, audited, over-collateralized decentralized lending protocols (such as Aave v3, Compound v3, and similar protocols) on supported blockchain networks that have been vetted and approved by the Company for integration with the Platform.
  • "Yield Services" means the functionality that allows Users to deposit Digital Assets into smart-contract vaults that allocate to Allow-Listed Lending Protocols to generate variable returns.
  • "Card Services" means the virtual and/or physical debit card services offered through the Platform via third-party card issuers and payment processors.
  • "Payment Services" means QR code payments, bank transfers, and other payment functionality facilitated through third-party payment providers.
  • "On-Ramp Services" means services that allow Users to purchase Digital Assets using fiat currency, provided by licensed third-party providers.
  • "Off-Ramp Services" means services that allow Users to convert Digital Assets to fiat currency, provided by licensed third-party providers.
  • "Rewards Program" means any points, bonuses, APY boosts, prizes, referral incentives, or other promotional benefits offered through the Platform.
  • "Third-Party Services" means any services, applications, protocols, or platforms not operated by the Company but accessible through or integrated with the Platform, including but not limited to card issuers, payment processors, on-ramp/off-ramp providers, and DeFi protocols.
  • "Account Abstraction" means the smart contract wallet technology (such as ERC-4337) that enables features like gasless transactions, where the Company may sponsor network fees on your behalf.
  • "Self-Custody" means the arrangement whereby Users generate, control, and are solely responsible for their Private Keys; the Company does not possess, have access to, or control User Private Keys or Digital Assets.

2. ELIGIBILITY AND JURISDICTION

2.1 Age and Capacity

You must be at least eighteen (18) years old, or the age of legal majority in your jurisdiction (whichever is higher), and have full legal capacity to enter into a binding agreement to use the Platform. By using the Platform, you represent and warrant that you meet these requirements.

2.2 Geographic Restrictions — Blocked Locations

The Platform is available only in jurisdictions where such services are lawful. You represent and warrant that you are not located in, under the control of, or a national or resident of any of the following blocked locations, and you agree not to access or use the Platform from or for the benefit of persons in these locations:

Afghanistan; Algeria; American Samoa; Bangladesh; Barbados; Belarus; Bolivia; Burkina Faso; China (including Hong Kong and Macao SAR); Côte d'Ivoire; Cuba; Democratic Republic of the Congo; Egypt; Eritrea; Faroe Islands; French Guiana; Guinea-Bissau; Haiti; Iran; Iraq; Jamaica; Japan; Kosovo; Lebanon; Liberia; Libya; Madagascar; Malaysia; Mayotte; Mongolia; Morocco; Myanmar; Nepal; Nicaragua; Nigeria; North Korea; Pakistan; Palestine; Panama; Qatar; Réunion; Russia; Saint Helena; Senegal; Somalia; South Sudan; Sudan; Syrian Arab Republic; Timor-Leste; Tunisia; Uganda; Ukraine; United States of America (including all U.S. territories); United States Virgin Islands; Venezuela; Western Sahara; Yemen; Zimbabwe.

We enforce geographic restrictions through IP geo-blocking, third-party KYC/identity verification controls, sanctions screening, device location services, and our contractual right to suspend or terminate service upon suspected evasion. The list of blocked locations may be updated at any time without prior notice.

2.3 United States Exclusion

THE PLATFORM IS NOT OFFERED TO, AND MAY NOT BE USED BY, PERSONS WHO ARE RESIDENTS OF, LOCATED IN, OR CITIZENS OF THE UNITED STATES OF AMERICA, INCLUDING ITS TERRITORIES AND POSSESSIONS. By using the Platform, you represent and warrant that you are not a U.S. Person as defined under applicable U.S. law.

2.4 Sanctions Compliance

You represent and warrant that you are not: (a) listed on any sanctions list maintained by the United Nations, European Union, United Kingdom, United States (including OFAC's SDN List), or any other applicable jurisdiction; (b) owned or controlled by, or acting on behalf of, any person or entity on such lists; or (c) located in, organized in, or a resident of any country or territory subject to comprehensive sanctions.

2.5 Your Compliance Responsibility

You are solely responsible for understanding and complying with all laws, rules, and regulations applicable to you in connection with your use of the Platform, including but not limited to tax laws, foreign exchange regulations, and cryptocurrency regulations. We make no representation that the Platform or any services thereon are appropriate, available, or lawful in any particular jurisdiction.

3. PLATFORM DESCRIPTION AND SERVICES

3.1 Overview

The Platform provides a self-custodial mobile and web interface that enables Users to: (a) create and manage a blockchain Wallet; (b) store and transfer Digital Assets; (c) access Yield Services through integration with Allow-Listed Lending Protocols; (d) access Card Services and Payment Services through third-party providers; (e) use On-Ramp and Off-Ramp Services through licensed third-party providers; and (f) participate in Rewards Programs. The Company acts as a software provider and interface facilitator; we do not custody, control, or have access to your Digital Assets.

3.2 Self-Custody Model

The Platform operates on a self-custody model. When you create a Wallet through the Platform: (a) your Private Keys are generated locally on your device using industry-standard cryptographic algorithms (AES-256 and related standards); (b) your Private Keys never leave your device in unencrypted form; (c) the Company does not have access to, store, or possess your Private Keys; (d) the Company cannot recover your Private Keys if lost; (e) the Company cannot freeze, seize, or transfer your Digital Assets; and (f) you are solely responsible for safeguarding your Private Keys and Recovery Materials.

3.3 Account Abstraction and Smart Wallets

The Platform uses Account Abstraction technology, whereby your Wallet is associated with a smart contract wallet on the blockchain. Only your locally-generated Private Keys can authorize transactions from this smart contract wallet. The Company may sponsor gas (network transaction fees) for certain transactions at our discretion, but this does not give the Company any control over your funds or the ability to execute unauthorized transactions.

3.4 Wallet Backup and Recovery

The Platform offers backup options including encrypted cloud backup (such as Google Drive or iCloud), passkey authentication, and manual recovery phrase backup. All backups are encrypted with a PIN or password that only you know. The Company cannot access your encrypted backups and cannot recover your Wallet if you lose both your device and your Recovery Materials.

3.5 Yield Services

Users may deposit supported Digital Assets (primarily USDC) into smart-contract vaults that allocate funds to Allow-Listed Lending Protocols to generate yield. Returns are variable, not guaranteed, and depend on market conditions and protocol performance. Yield displayed in the Platform is an estimate and may change at any time. Past performance is not indicative of future results.

3.6 Card Services

Card Services, including virtual and physical debit cards, are provided by third-party card issuers and payment networks (such as Visa or Mastercard) and are subject to their separate terms and conditions, fees, and geographic availability. The Company is not a card issuer. Card usage may require additional identity verification. Card Services may be modified, suspended, or discontinued at any time based on third-party provider availability or regulatory requirements.

3.7 Payment Services

Payment Services, including QR code payments and bank transfers, are provided through licensed third-party providers (such as Manteca in Argentina) and are subject to their separate terms, conditions, KYC requirements, and geographic availability. The Company does not process payments directly. Payment Services require identity verification through the third-party provider.

3.8 On-Ramp and Off-Ramp Services

On-Ramp Services (purchasing Digital Assets with fiat currency) and Off-Ramp Services (converting Digital Assets to fiat currency) are provided by licensed third-party providers (such as MoonPay and Manteca) operating under their own regulatory authorizations. These providers have their own terms of service, privacy policies, and KYC/AML requirements. By using these services, you agree to the terms of the applicable third-party provider. The Company is not responsible for the acts or omissions of these providers.

3.9 Admin and Guardian Functions

The Company maintains limited administrative functions over the Platform's smart contracts, specifically: (a) the ability to upgrade smart contracts (proxy upgrade), gated by a multi-signature wallet (Gnosis Safe, 2-of-3) with designated signers and a 24-hour timelock; (b) the ability to pause deposits or rebalancing in emergency situations; (c) the ability to add or remove Allow-Listed Lending Protocols. These administrative functions do not permit the Company to access, freeze, seize, or redirect User funds to Company-controlled addresses.

4. YIELD STRATEGY, REBALANCING, AND RISKS

4.1 Lending-Only Strategy

Yield Services are limited to allocation among Allow-Listed, over-collateralized lending protocols on supported blockchain networks. No AMM (Automated Market Maker), liquidity pool, or other higher-risk DeFi strategies are employed. Any future expansion to additional strategy types would require updated Terms and advance notice to Users.

4.2 Rebalancing

The Platform may automatically reallocate deposited Digital Assets among Allow-Listed Lending Protocols to optimize returns. Rebalancing occurs when: (a) another protocol offers a meaningfully better net rate after accounting for gas costs and fees; (b) liquidity and health checks pass internal thresholds; (c) risk parameters are within acceptable limits. Rebalancing is non-leveraged. The Company does not use leverage, rehypothecation, or stacking of risk. During rebalancing, new deposits may be briefly delayed for safety purposes.

4.3 Risk Acknowledgment — PLEASE READ CAREFULLY

By using the Platform, you acknowledge and accept the following risks:

  • (a) Smart Contract Risk: Smart contracts may contain bugs, vulnerabilities, or be subject to exploits. Such events can result in partial or total loss of your Digital Assets.
  • (b) Protocol Risk: Third-party DeFi protocols may fail, be hacked, change governance, become insolvent, or cease operations, resulting in loss of deposited assets.
  • (c) Market Risk: Interest rates are variable and determined by market conditions. APY can decrease significantly or become zero.
  • (d) Liquidity Risk: Liquidity shortages may prevent or delay withdrawals.
  • (e) Oracle Risk: Price oracles may fail or provide incorrect data, adversely affecting protocol operations.
  • (f) Stablecoin/Peg Risk: USDC and other stablecoins are designed to maintain a 1:1 peg with their reference currency but may trade above or below parity, temporarily or permanently. Issuers may freeze assets or become insolvent.
  • (g) Blockchain/Network Risk: Blockchain networks may experience congestion, forks, attacks, outages, or consensus failures that affect transactions and asset availability.
  • (h) Operational Risk: Outages, maintenance, upgrades, or infrastructure failures (including chain outages and third-party provider downtime) may delay deposits, withdrawals, or rebalancing.
  • (i) Regulatory Risk: Changes in laws or regulations may affect the legality, availability, or functionality of the Platform or Digital Assets in your jurisdiction.
  • (j) Self-Custody Risk: Loss of your Private Keys or Recovery Materials results in permanent, irreversible loss of your Digital Assets. The Company cannot recover lost keys.
  • (k) Third-Party Risk: Third-party service providers (card issuers, payment processors, on/off-ramp providers) may fail, become unavailable, or breach their obligations.

5. REWARDS PROGRAM

5.1 Program Description

The Platform may offer Rewards Programs including, but not limited to: points earned through platform activity (maintaining balances, card usage, referrals); prize wheels and games of chance; APY boosts; promotional bonuses; and referral incentives. Participation in Rewards Programs is optional and subject to additional terms that may be displayed within the Platform.

5.2 No Monetary Value

Points, rewards, and promotional benefits have no cash value and cannot be exchanged for cash, sold, or transferred outside the Platform, except where expressly converted to Digital Assets within the Platform's reward redemption mechanisms. Points and rewards may expire and are subject to forfeiture upon account termination.

5.3 Modification and Termination

The Company reserves the right to modify, suspend, or terminate any Rewards Program at any time, with or without notice, including changing point earning rates, redemption values, expiration periods, and available prizes. Abuse, fraud, or violation of these Terms may result in forfeiture of all accumulated rewards.

5.4 Prize Wheels and Games of Chance

Prize wheels and similar promotional games are for entertainment purposes and use pseudo-random number generation. The Company determines prize distribution, odds, and availability at its sole discretion. Prizes are not guaranteed. The Company makes no representation that such features constitute gambling under any jurisdiction's laws, and you are responsible for determining the legality of your participation.

6. USER RESPONSIBILITIES AND CONDUCT

6.1 Wallet Security and Backup

You are solely responsible for: (a) creating and maintaining secure backup of your Recovery Materials; (b) keeping your PIN, password, and passkeys confidential; (c) maintaining the security of your device and the Platform application; (d) enabling appropriate device security features (biometric authentication, device encryption, screen lock); (e) logging out of shared or compromised devices; and (f) notifying us immediately if you suspect unauthorized access. THE COMPANY CANNOT RECOVER LOST PRIVATE KEYS OR RECOVERY MATERIALS. Loss of your Recovery Materials results in permanent loss of your Digital Assets.

6.2 Accurate Information

You agree to provide accurate, current, and complete information when using the Platform or Third-Party Services, and to promptly update such information as necessary. You will not use false identities, VPNs, proxies, or other means to circumvent geographic restrictions or misrepresent your identity or location.

6.3 Lawful Use

You agree not to use the Platform for any purpose that is unlawful or prohibited by these Terms, including but not limited to:

  • Money laundering, terrorist financing, or other financial crimes
  • Sanctions evasion or transactions involving sanctioned parties or jurisdictions
  • Tax evasion or fraud
  • Transactions involving proceeds of illegal activity
  • Market manipulation or securities fraud
  • Circumventing geographic or eligibility restrictions
  • Interfering with, disrupting, or attacking the Platform or underlying protocols
  • Reverse engineering, decompiling, or extracting source code from the Platform
  • Using bots, scripts, or automated tools without authorization
  • Abuse of Rewards Programs through fraud, manipulation, or multiple accounts

6.4 Tax Responsibility

You are solely responsible for determining and fulfilling all tax obligations arising from your use of the Platform, including but not limited to reporting and paying any taxes on income, capital gains, or other tax consequences. The Company does not provide tax advice and does not report to tax authorities on your behalf.

6.5 Application Updates

You agree to keep the Platform application updated to the latest version available through official app stores. Outdated versions may have security vulnerabilities, reduced functionality, or may become incompatible with the Platform. The Company is not responsible for any issues arising from use of outdated application versions.

7. THIRD-PARTY SERVICES

7.1 Third-Party Providers

The Platform integrates with and provides access to Third-Party Services, which may include:

  • MoonPay: Licensed provider for fiat-to-crypto and crypto-to-fiat conversion services
  • Manteca: Licensed provider for fiat off-ramp, QR payments, and bank transfers (primarily Argentina)
  • Card Issuers: Licensed financial institutions that issue debit cards used with the Platform
  • Payment Networks: Visa, Mastercard, and similar payment networks
  • DeFi Protocols: Decentralized lending protocols (Aave, Compound, and similar)

7.2 Separate Terms and Conditions

Third-Party Services are governed by their own terms of service, privacy policies, and applicable laws. By using Third-Party Services through the Platform, you agree to be bound by their respective terms. The Company is not a party to your relationship with these providers and is not responsible for their acts, omissions, products, or services.

7.3 KYC/AML Requirements

Certain Third-Party Services, including On-Ramp Services, Off-Ramp Services, and Card Services, require identity verification (Know Your Customer / KYC) and compliance with anti-money laundering (AML) regulations. These requirements are imposed by the third-party providers under their regulatory obligations, not by the Company. Failure to complete required verification may result in inability to use certain features.

7.4 No Endorsement

Integration with or access to Third-Party Services does not constitute an endorsement, guarantee, or recommendation by the Company. We do not control, operate, or audit Third-Party Services and make no representations regarding their reliability, security, or suitability.

8. FEES

8.1 Platform Fees

The Company does not currently charge platform fees for core wallet and yield services. We reserve the right to introduce fees in the future with advance notice through these Terms, the Platform, or other appropriate means.

8.2 Network Fees

Blockchain transactions require network fees (gas fees) which may be sponsored by the Company at our discretion. When not sponsored, network fees are your responsibility and are paid directly to the blockchain network, not to the Company.

8.3 Third-Party Fees

Third-Party Services may charge their own fees including, but not limited to: on-ramp/off-ramp conversion fees; card issuance and transaction fees; ATM withdrawal fees; foreign exchange fees; payment processing fees; and slippage on conversions. These fees are charged by the respective third-party providers and are your responsibility. Fee information is typically displayed before you confirm a transaction.

9. DISCLAIMER OF WARRANTIES

9.1 As-Is Basis

THE PLATFORM AND ALL SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. TO THE FULLEST EXTENT PERMITTED BY LAW, THE COMPANY DISCLAIMS ALL WARRANTIES INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, AND THOSE ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

9.2 No Guarantee of Availability or Performance

We do not warrant that the Platform will be uninterrupted, error-free, secure, or available at any particular time or location; that defects will be corrected; that the Platform is free of viruses or other harmful components; or that any specific results will be achieved.

9.3 No Investment, Financial, Legal, or Tax Advice

Nothing on the Platform or in these Terms constitutes investment advice, financial advice, trading advice, legal advice, tax advice, or any other form of professional advice. You are solely responsible for evaluating the merits and risks of any transaction and for seeking independent professional advice as needed. The Company is not your investment advisor, broker, fiduciary, or financial planner.

9.4 No Fiduciary Duty

The Company is not your fiduciary and owes you no duties of care, loyalty, best execution, or other fiduciary duties. Our relationship is governed solely by these Terms.

10. LIMITATION OF LIABILITY

10.1 Exclusion of Consequential Damages

TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT SHALL THE COMPANY, ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF DIGITAL ASSETS, LOSS OF PROFITS, LOSS OF DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, OR ANY OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATED TO YOUR USE OF OR INABILITY TO USE THE PLATFORM, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE) AND EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

10.2 Liability Cap

IN NO EVENT SHALL THE COMPANY'S AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATED TO THE PLATFORM OR THESE TERMS EXCEED THE GREATER OF: (A) ONE HUNDRED U.S. DOLLARS (US$100); OR (B) THE AMOUNT OF PLATFORM FEES ACTUALLY PAID BY YOU TO THE COMPANY IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

10.3 Force Majeure

The Company shall not be liable for any failure or delay in performance due to events beyond our reasonable control, including but not limited to: acts of God; natural disasters; war, terrorism, or civil unrest; government actions or regulations; blockchain network failures, forks, or attacks; smart contract failures or exploits; third-party service failures; cyberattacks; pandemics; or utility failures.

10.4 Essential Purpose

THE LIMITATIONS IN THIS SECTION APPLY EVEN IF ANY LIMITED REMEDY FAILS OF ITS ESSENTIAL PURPOSE. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. IN SUCH CASES, OUR LIABILITY SHALL BE LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

11. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless the Company, its affiliates, and their respective directors, officers, employees, agents, and licensors from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to: (a) your use of or access to the Platform; (b) your violation of these Terms; (c) your violation of any applicable law or regulation; (d) your violation of any rights of a third party; (e) any transaction you conduct through the Platform; (f) your tax obligations; or (g) any dispute between you and a third party, including any Third-Party Service provider.

12. SUSPENSION AND TERMINATION

12.1 Company's Right to Suspend or Terminate

The Company may, in its sole discretion, suspend or terminate your access to the Platform, without prior notice or liability, for any reason, including but not limited to: (a) violation of these Terms; (b) suspected fraud, abuse, or illegal activity; (c) requests by law enforcement or government agencies; (d) discontinuation of the Platform or material modification of services; (e) technical or security issues; (f) failure to complete required identity verification; or (g) extended periods of inactivity.

12.2 Effect of Termination

Termination of your access to the Platform does not affect your ownership of your Private Keys or your ability to access your Wallet through other means (such as directly through blockchain interfaces). Your Digital Assets remain in your self-custody. However, you will lose access to Platform-specific features, interfaces, and any accumulated rewards that have not been redeemed.

12.3 Survival

The following sections survive termination: Definitions, Disclaimer of Warranties, Limitation of Liability, Indemnification, Dispute Resolution, Intellectual Property, and any other provisions that by their nature should survive.

13. INTELLECTUAL PROPERTY

13.1 Company Ownership

The Platform, including its software, design, text, graphics, logos, icons, images, audio, video, and other content, as well as the selection, arrangement, and compilation thereof, is owned by the Company or its licensors and is protected by copyright, trademark, and other intellectual property laws. "Luca," "Luca Money," and associated logos are trademarks of the Company.

13.2 Limited License

Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, revocable license to download, install, and use the Platform application on your personal device solely for your personal, non-commercial use. This license does not include the right to: (a) modify, copy, or create derivative works; (b) reverse engineer, decompile, or disassemble the Platform; (c) rent, lease, loan, sell, or sublicense the Platform; (d) remove or alter any proprietary notices; or (e) use the Platform for any commercial purpose without written consent.

13.3 Feedback

Any feedback, suggestions, or ideas you provide regarding the Platform may be used by the Company without any obligation to you.

14. PRIVACY AND DATA

14.1 Privacy Policy

Your use of the Platform is also governed by our Privacy Policy, which describes how we collect, use, and share your information. By using the Platform, you consent to our collection and use of information as described in the Privacy Policy.

14.2 Blockchain Transparency

You acknowledge that blockchain transactions are publicly visible and that your wallet addresses and transaction history are recorded on public blockchains. While the Company does not publicly link your identity to your wallet address, this information may be discoverable through blockchain analysis.

15. ELECTRONIC COMMUNICATIONS

By using the Platform, you consent to receiving electronic communications from us, including via email, push notifications, in-app messages, and notices posted on the Platform. You agree that all agreements, notices, disclosures, and other communications we provide electronically satisfy any legal requirement that such communications be in writing.

16. DISPUTE RESOLUTION

16.1 Governing Law

These Terms and any dispute arising out of or related to the Platform shall be governed by and construed in accordance with the laws of the British Virgin Islands, without regard to its conflict of law principles.

16.2 Binding Arbitration

Any dispute, controversy, or claim arising out of or relating to these Terms or the Platform, including the determination of the scope or applicability of this agreement to arbitrate, shall be determined by binding arbitration in the British Virgin Islands, in accordance with the BVI IAC Arbitration Rules then in effect. The arbitration shall be conducted by a single arbitrator. The arbitrator's decision shall be final and binding, and judgment on the award may be entered in any court of competent jurisdiction.

16.3 Class Action Waiver

YOU AGREE THAT ANY CLAIMS AGAINST THE COMPANY WILL BE BROUGHT SOLELY IN YOUR INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, REPRESENTATIVE, OR CONSOLIDATED ACTION. YOU WAIVE ANY RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION.

16.4 Time Limitation

Any claim or cause of action arising out of or related to these Terms or the Platform must be filed within one (1) year after such claim or cause of action arose; otherwise, such claim or cause of action is permanently barred.

17. CHANGES TO TERMS

The Company reserves the right to modify these Terms at any time. Updated Terms will be posted on the Platform with a revised "Last Updated" date and may be communicated via email, push notification, or in-app notice. For material changes, we will endeavor to provide advance notice. Your continued use of the Platform after any modification constitutes your acceptance of the modified Terms. If you do not agree to the modified Terms, you must stop using the Platform.

18. MISCELLANEOUS

18.1 Entire Agreement

These Terms, together with the Privacy Policy and any other agreements expressly incorporated by reference, constitute the entire agreement between you and the Company regarding the Platform and supersede all prior agreements and understandings.

18.2 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the parties' original intent.

18.3 Waiver

The failure of the Company to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. Any waiver must be in writing and signed by the Company.

18.4 Assignment

The Company may assign or transfer these Terms, in whole or in part, without restriction. You may not assign or transfer these Terms or any rights or obligations hereunder without our prior written consent.

18.5 Notices

We may provide notices to you via the Platform, email, push notifications, or other reasonable means. You may contact us at: main@lucamoney.com

18.6 No Third-Party Beneficiaries

These Terms do not create any third-party beneficiary rights in any person, except that the Company's affiliates, directors, officers, employees, agents, and licensors are express third-party beneficiaries of the indemnification, limitation of liability, and disclaimer provisions.

18.7 Headings

Section headings are for convenience only and shall not affect the interpretation of these Terms.

FINAL ACKNOWLEDGMENT

BY DOWNLOADING, INSTALLING, ACCESSING, OR USING THE PLATFORM, YOU CONFIRM THAT YOU:

  • Have read, understood, and agree to be bound by these Terms of Service
  • Are at least 18 years old (or the age of majority in your jurisdiction) and have legal capacity to enter into this agreement
  • Are not located in, a resident of, or accessing the Platform from any blocked location, including the United States
  • Are not subject to sanctions or listed on any sanctions list
  • Understand the risks of using blockchain networks, decentralized protocols, and self-custodial wallets
  • Accept that APY is variable and returns are not guaranteed
  • Accept that you alone control your Private Keys and may permanently lose access to your Digital Assets if you lose your Recovery Materials
  • Agree to use the Platform only where lawful and in compliance with all applicable laws
  • Acknowledge that the Company is not a bank, money transmitter, or regulated financial institution

Last Updated: 27 January 2026

Atlas Foundry Limited

Intershore Chambers, Road Town, Tortola, British Virgin Islands

Company No. 2170810

Contact: main@lucamoney.com