DePix App Terms of Use

Last updated: June 7, 2026

1. Acceptance of these Terms

These Terms of Use ("Terms") govern access to and use of DePix App — the website depixapp.com, the progressive web app (PWA), the integrated wallet and all related features (together, the "Platform").

By creating an account, accessing or using the Platform in any way, you ("User", "you") represent that you have read, understood and fully agree to these Terms and to the Privacy Policy, which forms an integral part of this document. If you do not agree with any provision, do not use the Platform.

These Terms may be updated, as set out in Section 21 — which ensures advance notice of material changes and the possibility of closing your account at no cost.

2. Definitions

For the purposes of these Terms:

• DePix App or Platform: the software, website, PWA and wallet made available under the DePix App brand ("DePix App", "Platform" or "we").
• DePix: a third-party digital asset (stablecoin) referenced to the Brazilian Real at a ratio of 1 DePix = 1 BRL, recorded on the Liquid Network. DePix App is not the issuer of DePix.
• Eulen: the issuer and administrator of DePix, responsible for its issuance, redemption and backing, under its own terms available at depix.info.
• Banking Partners: authorized payment institutions and service providers that process Pix operations and perform customer identification (KYC), anti-money-laundering and counter-terrorism-financing (AML/CFT) and regulatory compliance, including Plebit — Plebit.com.br Soluções em Tecnologia Ltda. (CNPJ No. 43.375.652/0001-13) (plebit.com.br) and Plebz — Plebz Intermediação de Pagamentos Ltda. (CNPJ No. 45.808.899/0001-01) (plebz.com.br).
• Partners: together, Eulen, the Banking Partners and other infrastructure and third-party service providers integrated into the Platform.
• Wallet: the optional non-custodial cryptoasset wallet that runs on the User's device, described in Section 13.
• Liquid Network: a Bitcoin sidechain operated by a federation, on which DePix circulates.
• Pix: the instant-payment system established and regulated by the Central Bank of Brazil.
• MED: Pix's Special Return Mechanism (*Mecanismo Especial de Devolução*), described in Section 8.
• Self-custody: a model in which the User holds exclusive control over their private keys and digital assets, bearing full responsibility for their safekeeping.

3. Nature of DePix App

3.1. What DePix App is

DePix App is free, non-custodial interface software, provided "as is". It merely connects the User to third-party infrastructure in order to (a) present Pix charges whose payment results in the acquisition of DePix; (b) generate the interface for the User to request the redemption of DePix, whose value in Reais is settled via Pix by the Partners; and (c) optionally, make available a self-custody wallet software that the User generates and fully controls on their own device. DePix App does not provide the underlying financial service, does not charge the User and receives no funds from the User; the service is provided and charged by the Partners (Section 7).

The Platform provides only the software, integration and user-experience layer. Financial operations, the custody of fiat funds, the issuance and redemption of DePix, and identification and compliance procedures are carried out by the Partners, each under its own terms and authorizations.

3.2. What DePix App is not

DePix App expressly and unequivocally:

• is not a bank, financial institution, payment institution, securities brokerage or distributor, cryptoasset exchange or brokerage, currency-exchange house, cryptoasset portfolio manager, or virtual-asset service provider (VASP), and does not hold any such authorizations or registrations;
• does not take custody of, hold or have access to fiat currency or cryptoassets of Users — no amount in Reais or in DePix is held by the Platform on the User's behalf;
• does not charge or receive any amount from the User — DePix App's only remuneration is a commission paid by Eulen for the technological integration (Section 7);
• does not perform Pix processing, bank settlement, or the issuance or redemption of DePix;
• does not directly carry out customer identification (KYC), AML/CFT or regulatory compliance, which are the exclusive responsibility of the Partners that hold the necessary authorizations;
• does not provide any financial, investment, accounting, tax or legal advice.

3.3. Operating structure and roles of the Partners

DePix App integrates independent third-party services, each with its own responsibilities:

• Eulen is solely responsible for the issuance, administration, backing and redemption of DePix, and for maintaining the asset's peg;
• the Banking Partners (Plebit, Plebz and other authorized providers) are solely responsible for processing Pix orders, bank settlement, customer identification (KYC), AML/CFT, compliance and the applicable reporting and ancillary obligations, including before the competent authorities;
• infrastructure providers (hosting, database, blockchain indexing, pricing and communications) provide technical services to the Platform.

Use of the Platform also subjects the User to the terms and policies of the relevant Partners. DePix App has no control over such services and is not responsible for the Partners' acts, omissions, failures, unavailability or decisions.

3.4. Non-custodial model

The Platform operates on a non-custodial basis: DePix App does not hold the private keys or any instrument that allows control over the User's cryptoassets and has no technical ability to access, move, block or recover them. DePix acquired is sent directly to the Liquid Network address indicated by the User, and transactions are executed on the blockchain by the User or by their Wallet (Section 13). Any blocking, retention or return measures take place at the Pix and issuance stage, within the Partners' sphere (Sections 8 and 11), and not over funds under DePix App's control.

4. Eligibility

To use the Platform, the User represents and warrants that they:

• are at least 18 years old and have full legal capacity;
• act in their own name and for their own benefit, and not as a straw person, nominee or on behalf of an undisclosed third party;
• are not subject to national or international economic sanctions (including UN, OFAC and EU lists), nor acting on behalf of a sanctioned person;
• will provide true, accurate and up-to-date information;
• will use the Platform in compliance with applicable law.

5. Registration and identification

5.1. DePix App account

Registration requires only basic data (such as name, e-mail, WhatsApp contact, username and password). The User is responsible for keeping their credentials confidential and for all activity carried out on their account.

5.2. Identification and KYC at the Partners

Identification of the User and verification of account ownership take place at the Banking Partners, notably by linking the CPF or CNPJ (Brazilian taxpayer ID) that owns the bank account used in Pix operations. The User acknowledges that the Partners may require, at any time at their discretion or as required by law, additional identity-verification, enhanced due-diligence and source-of-funds procedures, and that refusal or inability to satisfy them may result in blocking, suspension or termination of operations.

5.3. Merchant account

Access to merchant features (charges, sales, products and API) may require additional information, such as the establishment's CNPJ and website, and is subject to verification.

6. Description of the Services

The Platform may make available, among others, the following features:

• Deposit (Pix → DePix): generation and presentation of the Pix charge (QR code); payment, processed by the Banking Partner, results in DePix — issued by Eulen — being sent to the Liquid address indicated by the User;
• Withdrawal (DePix → Pix): an interface for the User to request from the Partners the redemption of DePix, whose settlement in Reais via Pix is carried out by the Banking Partner;
• Self-custody wallet: non-custodial wallet software executed and controlled by the User on their own device (Section 13);
• Merchant area: software tools for creating on-demand charges, sales reports, product catalog, payment links and API integration;
• Affiliate program: commissions on referrals, governed by Section 14.

The availability and features of each function may vary and change at any time, without prejudice to operations already confirmed.

7. Timeframes, limits, fees and remuneration

• Processing time: deposits may be processed within up to 24 hours (D+1), a timeframe that constitutes a security measure applied by the Partners, described in Section 8.
• Limits: operations are subject to minimum and maximum limits set and enforced by the Partners (currently, for example, a minimum of R$ 5.00 and a cap of R$ 6,000.00 per CPF every 24 hours), reflected in the interface and subject to change at any time, without prejudice to operations already confirmed.
• Who charges: DePix App does not charge the User. The banking partner processes the Pix and charges its processing fee (currently, for example, R$ 0.99 per operation); Eulen issues the DePix, applies its spread and remunerates DePix App through a commission (currently, for example, 2% on deposits and 1% on withdrawals) for the technological integration. No commission is due on reversed or returned operations (including via MED). Blockchain network costs and third-party fees may also apply.

The current amounts and limits are set by the Partners and displayed on the Platform itself, prevailing over any examples mentioned in these Terms.

8. Security window and Special Return Mechanism (MED)

The User acknowledges and agrees that:

• the processing time of up to 24 hours (D+1) is a fraud-prevention measure applied within the issuance and settlement carried out by the Partners, intended to allow disputed operations to be identified before cryptoassets are released;
• during and after that period, operations that are subject to a dispute through the MED — Pix's Special Return Mechanism, or to an order from a competent authority, may be subject, by the Partners, to a precautionary block, return of funds to the originating account (including in favor of a proven fraud victim), retention or disposal by order of a competent authority, as applicable;
• such measures are taken by the Partners, within the Pix and issuance spheres, with or without prior notice, where urgency or the law so requires; DePix App neither executes nor controls them and they do not reach funds under DePix App's control;
• the irreversibility characteristic of blockchain transactions does not prevent the application of return and blocking mechanisms at the Pix stage, which occurs within the sphere of the Banking Partners.

8.1. Complaints, defects and right of withdrawal

• Complaints and defects: for problems with operations (for example, an amount paid and DePix not received), the User should contact support (suporte@depixapp.com). DePix App will forward the communication to the Partner responsible for the relevant stage (Pix processing, issuance or settlement), to whom the analysis and any refund belong. Remedying defects follows the Partners' terms and consumer rights (Consumer Protection Code, Arts. 18 to 20).
• Right of withdrawal: you may cancel an operation that has not yet been executed, by not paying or by canceling the Pix charge before confirmation. After confirmation and delivery of DePix — immediate and irreversible —, the right of withdrawal (Art. 49 of the Consumer Protection Code) is rendered moot by the material impossibility of return, as provided by law.

9. User obligations and representations

The User undertakes to, and represents that they:

• keep their credentials, private keys, seed and PIN secure, and are solely responsible for their safekeeping;
• check the accuracy of all data before confirming any operation, especially destination addresses and Pix keys;
• understand that blockchain transactions are irreversible and that addressing errors may result in total and permanent loss of assets;
• carry out their own analysis and due diligence before transacting;
• have sufficient knowledge of digital assets and blockchain to understand the risks involved;
• have the financial capacity to absorb the total loss of the amounts used;
• are solely responsible for their tax and ancillary obligations arising from use of the Platform.

10. Prohibited conduct

It is forbidden to use the Platform for any unlawful purpose or for the purposes below, without prejudice to other conduct prohibited by law:

• money laundering or concealment of assets, rights and values (Art. 1 of Law No. 9,613/1998);
• terrorism financing (Law No. 13,260/2016);
• fraud, scams or swindles, including fake listings, fake call-center scams and Pix-based fraud (Art. 171 of the Criminal Code);
• foreign-exchange evasion and unauthorized currency-exchange operations;
• tax evasion and tax fraud (Law No. 8,137/1990);
• use of third-party accounts, straw persons or nominees;
• circumvention of national or international economic sanctions;
• unauthorized gambling, pyramid or Ponzi schemes;
• trafficking in drugs, weapons, ammunition, persons, organs or wildlife;
• production, distribution or facilitation of child sexual abuse material;
• dealing in stolen, counterfeit, smuggled or illicit goods;
• providing false information, omitting relevant information or document forgery;
• maintaining multiple accounts to circumvent limits or verifications;
• interference, reverse engineering, use of bots, or attempts to compromise the Platform or the Partners.

10.1. Merchant transparency obligation

A merchant who uses the Platform to receive payments undertakes to clearly and beforehand inform their customers that, by paying via Pix, they are acquiring the digital asset DePix (referenced to the Real at a 1:1 ratio). Failure to disclose this may lead to account suspension.

11. Crime prevention, reporting and cooperation with authorities

The User acknowledges and authorizes that:

• customer identification (KYC), the prevention of money laundering and terrorism financing (AML/CFT), and the reporting of suspicious operations to the competent authorities, including Brazil's Financial Activities Control Council (COAF), are carried out by the authorized Partners, which hold the regulatory authorizations, without notice to the User, in compliance with confidentiality duties;
• DePix App may adopt fraud-detection and security measures for the service (for example, identifying risk signals) and escalate to the Partners any indications requiring action, without replacing them in the formal AML/CFT obligations;
• cryptoasset operations may be reported to Brazil's Federal Revenue Service (Receita Federal), under the applicable tax legislation, by the responsible Partners, linking the holding CPF or CNPJ to the relevant operation;
• the Platform and the Partners may cooperate with police, administrative and judicial authorities, providing the information required by law or by a competent order;
• in the face of indications of illegality, a dispute (MED) or an order from an authority, the Partners may apply a precautionary block and retain or return funds within the Pix and issuance spheres, and DePix App may suspend or terminate access to the account and the software — measures that do not reach funds.

12. Taxes

The User is solely and fully responsible for assessing and paying all taxes due on their operations, as well as for complying with the related ancillary obligations, including declaring cryptoassets where applicable. DePix App does not provide tax advice and is not responsible for the User's tax obligations. Any reporting of operations by the Partners does not relieve the User of their own obligations.

13. Integrated Wallet Terms (self-custody)

This Section governs use of the optional non-custodial Wallet of DePix App and prevails, in what is specific to it, over the other provisions of these Terms.

13.1. Sole responsibility for keys

The Wallet is self-custody software executed by the User on their own device. The seed (recovery phrase), the PIN and the private keys are generated and remain exclusively on the User's device and are never transmitted to, known by, or stored by DePix App. The Partners do not take part in the self-custody Wallet.

As a result, only the User has control over and access to the Wallet's assets. DePix App does not hold the keys or any instrument that allows control and has no technical ability whatsoever to access, move, freeze, recover or restore the User's funds, seed or PIN. Anyone who holds the User's seed or PIN may access and dispose of their assets.

The User is solely responsible for: (a) securely and confidentially safeguarding their seed, PIN and other credentials; (b) keeping backups of their recovery phrase; and (c) checking all data before signing and broadcasting any transaction. Loss of the seed or PIN results in the permanent and irreversible loss of the assets, with no possibility of recovery by DePix App.

13.2. Assumption of risk for the Wallet

The Wallet and the software are provided "as is" and "as available", without warranties of any kind, express or implied, including warranties of fitness for a particular purpose, absence of defects, or uninterrupted operation.

To the fullest extent permitted by applicable law, and without prejudice to consumer-protection rules, which prevail over this clause, the User assumes the risks inherent in self-custody, acknowledging that DePix App cannot prevent or reverse losses arising from, among others:

• errors, failures, defects, bugs or unexpected behavior of the software;
• security vulnerabilities, intrusions, cyberattacks, hacks or exploits;
• leakage, compromise, loss, forgetting or disclosure of the seed, PIN or private keys, for any reason;
• compromise of the User's device by malware, viruses, unauthorized physical access or otherwise;
• phishing, social engineering, fraud or scams by third parties;
• sending assets to the wrong address, on the wrong network or in the wrong amount;
• failures, congestion, unavailability, forks or protocol changes of the Liquid Network, Bitcoin or any blockchain;
• failures, defects or interruptions in third-party software dependencies used by the Wallet (including open-source libraries and signing components), including supply-chain compromise;
• changes in value, loss of the asset's peg, lack of liquidity, or the User's own use and investment decisions.

13.3. Security recommendations

The User must keep the device secure and up to date, protect their seed and PIN, be wary of requests for credentials, and move high balances to dedicated storage solutions (hardware wallets). No browser-based defense is perfect against compromised devices.

13.4. Acknowledgment of third-party software risk

The Wallet relies on open-source libraries and third-party components. The User acknowledges that no software protection is absolute and that vulnerability and supply-chain risks, while mitigated, cannot be entirely eliminated.

14. Affiliate Program

This Section governs the Platform's affiliate (referral) program. By taking part, the User ("Affiliate") agrees to the rules below, which supplement the rest of these Terms.

14.1. Enrollment and referral link

The program is open to any registered User — individual, self-employed or merchant. Each User receives a unique referral link tied to their username. Referrals are attributed when a new person registers through that link.

14.2. Commission

The Affiliate is entitled to part of the commission that Eulen pays DePix App in respect of the actually confirmed deposits (Pix → DePix) made by their referred users, on a recurring basis for as long as the program is in force. The current value is equivalent to 1% of the referred deposit volume, and may vary by individual agreement; the prevailing value is the one shown on the Platform. No commission is due on operations that are not completed, are cancelled, reversed or subject to return (including via MED).

14.3. Calculation and dashboard

Commissions are calculated on an ongoing basis and displayed in the app's affiliate dashboard. Amounts shown before actual payment are estimates and may be adjusted due to reversals, returns, cancellations or fraud findings.

14.4. Commission payout

Payout of the commission is subject to the following conditions:

• it is paid in DePix, to the Liquid Network address provided by the Affiliate at the time of the request;
• it requires a minimum accrued balance of R$ 100.00 (one hundred Brazilian reais) for a request to be opened;
• it allows one request per calendar month;
• it is processed within up to 30 (thirty) days of the request, and may be conditioned on anti-fraud verification;
• it presupposes the definitive confirmation of the referred users' operations and the actual receipt, by DePix App, of the corresponding remuneration from the Partners; operations reversed, returned or not passed on by the Partners do not generate any payable commission;
• the accuracy of the address provided is the Affiliate's sole responsibility, and the transfer is irreversible (Section 9).

14.5. Prohibited conduct

The Affiliate must not, among other things:

• refer themselves (self-referral), directly or indirectly, including through third parties;
• create false, duplicate, fictitious or third-party accounts without authorization;
• use disposable e-mails, false data or any device to simulate referrals;
• engage in spam, misleading promotion, promises of earnings, or any practice that violates the law, including advertising and consumer-protection rules;
• impersonate the Platform, Eulen or the Partners, or use their trademarks without authorization;
• manipulate, defraud or attempt to circumvent the calculation of commissions in any way.

14.6. Consequences

Invalid, suspicious or fraudulent referrals give no right to a commission. In the event of a well-founded indication of fraud, irregularity or dispute, the Platform may withhold, cancel or reverse unconfirmed commissions, refuse payouts, and suspend or terminate the Affiliate's participation and account, without prejudice to other applicable measures.

14.7. Taxes

The Affiliate is solely responsible for assessing and paying the taxes due on the commissions received, as set out in Section 12.

14.8. Changes and termination of the program

The Platform may, at any time, change percentages, limits or rules, or terminate the affiliate program, by publishing the change on the Platform. Legitimate commissions already confirmed and not disputed will be paid according to the rules in force at the time of calculation.

14.9. No relationship

Participation in the program does not create any employment, corporate, mandate, agency or representation relationship between the Affiliate and DePix App.

15. Risks

The User represents that they are aware of the risks inherent in using the Platform, including:

• Peg and backing risk: DePix is issued by a third party (Eulen); maintaining the peg to the Real and the backing is the issuer's responsibility, not DePix App's;
• Irreversibility: blockchain transactions are, as a rule, final and irreversible;
• Technology risk: software failures, defects, attacks and network interruptions;
• Regulatory risk: regulatory changes may affect the availability or operation of the services;
• Third-party risk: acts, omissions, unavailability or insolvency of Partners;
• Loss of access: loss of credentials, seed or PIN may result in permanent loss of assets;
• Volatility and illiquidity: even though referenced to the Real, the asset may suffer market, liquidity or de-peg events.

16. Assumption of risk, disclaimer of warranties and limitation of liability

DePix App is free software, provided "as is" and "as available", without warranties of continuity, accuracy, uninterrupted availability or freedom from error. The User acknowledges and assumes, freely and on an informed basis, the risks inherent in using the Platform and the third-party services, including those described in Section 15.

To the fullest extent permitted by applicable law, DePix App is not liable for damages arising from: (a) acts, omissions, failures, unavailability, insolvency or decisions of the Partners and third parties; (b) the exclusive fault of the User or of a third party; (c) force majeure.

For a User that is a legal entity using the Platform outside the scope of the Consumer Protection Code, the total liability of DePix App, where any exists, is limited to the amount of commissions actually received by DePix App in respect of that User's operations in the 3 (three) months preceding the event.

Nothing in this Section waives or reduces rights that cannot be limited or excluded under mandatory law, including consumer-protection rules, nor does it release DePix App in cases of willful misconduct or gross negligence.

17. Indemnification

To the extent permitted by applicable law, the User is liable for the direct damages they cause, provably and through their own fault, by breach of these Terms, misuse of the Platform, violation of third-party rights or non-compliance with applicable laws, and undertakes to reimburse DePix App in such cases. This clause does not apply to the extent prohibited by mandatory consumer-protection rules.

18. Intellectual property

The Platform, its trademarks, distinctive signs, content and code are protected by intellectual-property rights. It is forbidden to copy, reproduce, modify, distribute, sublicense, reverse-engineer or create derivative works, except as expressly authorized or as permitted by applicable open-source licenses. The name "DePix" identifies the asset issued by Eulen and its use must respect the rights of the relevant holder.

19. Suspension, blocking and termination

Within the Pix and issuance spheres, the Partners may, at their discretion and without prior notice where urgency or the law requires, limit, suspend, block or reverse operations in the event of indications of illegality or fraud, a dispute via MED, or an order from a competent authority. DePix App, in turn, may suspend or terminate the User's access to the account and the software in the event of breach of these Terms, abuse of the Platform or the affiliate program, or risk to third parties — measures that do not reach funds, which are not under its control. The User may close their account at any time, subject to pending obligations and statutory data-retention periods.

20. Availability and force majeure

The Platform does not guarantee continuous or uninterrupted availability. DePix App is not liable for delays or failures arising from causes beyond its reasonable control, including natural disasters, power, telecommunications or internet failures, cyberattacks, pandemics, acts of authority, strikes, war or terrorism, as well as changes or failures in blockchain networks and in Partners' services.

21. Changes to these Terms

These Terms may be changed at any time, with the current version published on the Platform and the date of update indicated. Material changes will be communicated with reasonable advance notice through available channels, and a User who does not agree may close their account at no cost before the change takes effect. Continued use after the change takes effect constitutes acceptance of the new version.

22. Communications and notices

Communications from the Platform to the User may be made by e-mail, through the application's channels, or by notices published on the Platform, and are deemed valid when so made available.

23. General provisions

• Independence of the parties: these Terms do not create any corporate, employment, mandate, agency or partnership relationship between the User and DePix App.
• Assignment: the User may not assign their rights and obligations without consent; DePix App may assign them in the event of reorganization or transfer of operations.
• Severability: the invalidity of any clause does not affect the others.
• No waiver: failure to enforce any provision does not constitute a waiver.
• Entire agreement: these Terms and the Privacy Policy constitute the entire agreement between the parties regarding their subject matter, prevailing over prior understandings.

24. Contact

Questions about these Terms may be sent through the support channels available in the application or by e-mail at suporte@depixapp.com.