Terms of Use

1. Identification and scope

This document sets out the terms of use of this website and the general terms for contracting with Swapo Finance Sociedade Prestadora de Serviços de Ativos Virtuais Ltda, CNPJ 52.854.278/0001-20, headquartered at Rua Fidêncio Ramos, 100, Vila Olímpia, São Paulo/SP, CEP 04551-010, referred to as Swapo.

Contracting each service depends on its availability, the client’s eligibility, the specific conditions and the corresponding acceptance. These terms do not expand the scope that the law or the conditions of the authorization process permit Swapo.

Publication of this version does not automatically transfer another legal entity’s contracts, balances or data to Swapo. Prior relationships require identification of the contracting party, individual notice and the applicable legal procedure, including new acceptance where necessary. Rights already acquired remain preserved.

Merely visiting the website does not constitute contracting a financial transaction, acceptance of a specific risk or consent to advertising.

2. Definitions

• Virtual asset: digital representation of value, as defined in Law No. 14,478/2022. It is not legal tender or a bank deposit.
• Stablecoin: a virtual asset that seeks to maintain a reference to another asset, such as the dollar. The peg may be lost.
• Intermediation: a service related to trading or transferring virtual assets, within the scope allowed to the category.
• Custody: safekeeping or control, by a provider, of the instruments that allow assets to be moved. Swapo does not provide custody.
• Liquidity provider: institution that supplies the quote, executes the purchase and settles the virtual asset in transactions intermediated by Swapo.
• Self-custody: the user controls their own keys. Losing the key may permanently prevent access to the assets.
• Intermediation fee (spread): percentage applied to the liquidity provider’s quote to remunerate the intermediation. It is not the price of the asset, the network fee or a tax.
• Platform profile: registration and electronic access. It does not imply the opening of a bank, deposit or payment account.

3. Registration and risk profile

The service is intended for persons aged 18 or older with legal capacity and for legal entities represented by persons with sufficient authority. Registration requires truthful, up-to-date information consistent with the transaction, including identification of the ultimate beneficial owner where applicable.

Eligibility depends on identity verification, source of funds, eligibility checks and risk assessment. Additional documents may be requested. Registration does not guarantee approval, a limit or a review deadline. Swapo may restrict profiles, products or jurisdictions for reasons of risk, sanctions or legal requirement.

The suitability assessment must consider objectives, financial situation, and knowledge of and experience with virtual assets. A transaction that does not match the profile requires the applicable warning procedure and a specific risk acknowledgment statement, documented before execution. The generic statement on this website does not replace that assessment.

Users must protect their credentials, use the available authentication features and report suspected unauthorized access. Swapo does not request passwords, authentication codes or private keys through its support channels.

4. Scope of services

Swapo intermediates, on behalf and at the order of the client, the purchase of USDT on the TRON network (TRC-20) with reais received via Pix and the sending of the asset to the wallet indicated. The asset is described in the asset sheet, and the service in the Service description.

The category requested is intermediary. Swapo does not provide custody, credit, financing, discretionary management, staking, issuance of assets, intermediation of securities or any product with a promise or expectation of returns. The providers involved are identified in the Transparency Center.

The request includes activity subject to the rules of the foreign exchange market. This is not a statement that authorization has been granted, nor an unrestricted offer of foreign exchange services. Transactions covered by BCB Resolution No. 277, as amended by BCB Resolution No. 521, depend on the applicable legal classification and conditions.

This website does not offer cards, card machines, BaaS, White-Label, API, global account, payments in other countries through off-ramp, or receipt and delivery of cash.

The content is for information only and is not a personalized investment recommendation, foreign exchange strategy or promise of returns.

5. Orders, execution and cancellation

Before confirmation, the offer must identify the asset, quantity, network, price, spread and other costs, applicable taxes, net amount, quote validity, estimated time and settlement conditions. Swapo does not act as counterparty: the quote comes from the liquidity provider, and the order is executed on behalf and at the order of the client. Swapo does not guarantee liquidity or full execution if the provider does not honor the quote.

An educational simulation is not an executable order. The demonstration on the home page uses a fixed hypothetical quote, not linked to the market, and an illustrative fee, and does not represent a current quote. Browsing the website authorizes no automatic conversion; any automation requires specific instruction from the client.

Check the destination and the network before confirming. Whether cancellation is possible depends on the stage of the transaction. A transfer confirmed on the blockchain may be irreversible. This does not preclude review of error, fraud or defects in the provision of the service, or rights guaranteed by law.

If execution is not possible under the accepted conditions, no authorization is presumed for a different price, quantity or destination. The client must receive information about the situation and the available alternatives, including new confirmation when necessary.

6. Deposits, withdrawals, safekeeping and statements

Do not send funds or assets without instructions for an eligible transaction. Check ownership, receiving institution, network, address, minimum amount, limits, costs and estimated time. Do not make payments to an account provided by an unverified contact.

Pix is a payment method in reais in Brazil. Using it does not turn a virtual asset into fiat currency, a bank account or an instant international transfer. Cash transactions are not accepted within the disclosed scope.

Swapo does not hold client assets. The USDT may pass, automatically and for less than 24 hours, through a Swapo transactional wallet and then proceeds to the wallet indicated. In self-custody, the client controls their keys. If the client chooses a custodian, the client depends on that custodian’s instruments, access rules and procedures, under a separate contract.

Withdrawal requests may require verification of ownership and of the origin/destination of the assets, in addition to a security review. Blocks must observe a legal or contractual basis, proportionality and the duties of disclosure, except where confidentiality is mandatory.

The client may request from support receipts and statements of their transactions, showing identification, asset, quantity, price, costs, date, time and status. The service contract must indicate the means of access, the frequency of statements and the deadlines for obtaining them, without replacing these details with a generic promise of availability.

7. Costs and taxes

The public cost breakdown table lists the applicable categories. The amount or percentage for the transaction must be presented before confirmation and recorded on the receipt. Asset price, intermediation fee, network fee and tax are distinct components and must not be charged twice. The fee may be shared with the OTC desk that supplies the liquidity; the conflict and its mitigation are described in the Transparency Center.

There is no guarantee of the lowest price, of savings compared to banks or of IOF exemption. Tax incidence depends on the transaction and on the law. The client retains their tax obligations; the provider’s legal duties of withholding, payment and reporting also remain.

These terms do not authorize maintenance or inactivity charges or automatic deductions for mere lack of use. A new fee will depend on valid provision, disclosure and contracting as applicable, with no retroactive charge by reason of this publication.

8. Identification and AML/CFT/CPF

Transactions are subject to the rules on preventing money laundering, terrorist financing and the proliferation of weapons of mass destruction (AML/CFT/CPF). Data on the sender, beneficiary, wallet holder, ultimate beneficial owner, and the source and purpose of funds may be required.

Information may be shared with authorities and providers where there is a legal basis, including in the exchange of data on virtual asset transfers, subject to the applicable regime and deadlines. Legally confidential communications will not be disclosed to the user.

Identification is not waived because of foreign nationality. The document accepted depends on the registration and the applicable rule. Using third parties to conceal true ownership is not permitted.

9. Risks and absence of guarantees

• Price and exchange rate variation, loss of peg and unavailability of buyers.
• Insolvency, blocks, failures or restrictions of issuers, providers and counterparties.
• Network or smart contract failures, attacks, forks and incompatibility between networks.
• Loss of key, fraud, address errors and irreversibility of transfers.
• Legal, tax and regulatory changes, suspension of assets and redemption restrictions.

Reserves declared by the stablecoin issuer are not equivalent to insurance or an unrestricted right of the client to redeem them. Access to direct redemption depends on the issuer’s terms, eligibility and jurisdiction. Swapo does not guarantee that the issuer will meet its obligations.

This document does not offer insurance coverage for losses. Insurance may be considered only when the insurer, beneficiaries, risks covered, limits, exclusions and claims procedure are identified. See the public risk information.

10. Liability and consumer protection

Swapo is liable for its services under applicable law, including the Consumer Defense Code. Contracting third parties does not remove the provider’s legal responsibilities. These terms do not generically exclude liability for fraud, security failures or defects in the service.

The user must provide truthful information, follow the transaction instructions and act lawfully. The assessment of losses must consider the facts, the participation of those involved and the legal liability regime, without presuming sole fault of the client.

There is no general cap on compensation, advance waiver of rights, contractual reversal of the burden of proof against the consumer or mandatory arbitration imposed by these terms.

11. Personal data

The Privacy Policy explains the purposes, legal bases, sharing, retention and rights. Awareness of the policy does not amount to generic consent. Advertising and optional cookies depend on separate choices, which can be reviewed.

12. Intellectual property

The brand, texts and software are subject to the rights of their respective owners. Consulting the website does not transfer intellectual property. References to Tether identify the issuer of the asset and do not declare a partnership, representation or endorsement.

13. Prohibited conduct

Using the service for fraud, money laundering, financing of illicit activities, concealment of ownership, violation of applicable sanctions, market manipulation or improper exploitation of the systems is prohibited. Forged documents and mechanisms intended to unlawfully hinder identification of the origin or destination of funds are also prohibited.

14. Suspension and termination

Access or a transaction may be suspended because of a legal duty, an order from an authority, well-founded indication of fraud, inconsistent registration data or significant risk. The client must receive information and guidance on regularization when there is no legal impediment to communication.

Termination may be requested from support. The treatment of pending orders, amounts owed, conditions for withdrawing assets and data whose retention is legally required must be clarified. Termination does not authorize confiscation, automatic loss of balance or extinction of liability.

In a liquidity contingency or significant interruption, Swapo may temporarily suspend or restrict the services, with notice to clients through the official channels (Liquidity management policy and Business continuity plan).

Technical unavailability or suspension of an asset requires guidance on alternatives and consequences, respecting the client’s rights and any legal restrictions. There is no promise of recovery of assets sent over an incompatible network.

15. Versions, communication and acceptance

This version was published on November 1, 2026. Material changes must be communicated clearly, before they apply when required, with new acceptance where relevant. Continued browsing is not presumed to authorize new services.

Contractual acceptance must identify the version, date and contracting party, in a form that allows it to be proven. This institutional website does not record acceptance of the app contract or the individual risk acknowledgment statement. Previous versions may be requested from support.

16. Complaints, ombudsman and jurisdiction

The client may file complaints through the support channels. Ask for a protocol number and keep the receipts. Unresolved claims may be taken to the Ombudsman ([email protected]), which responds within ten business days, extendable once with justification.

Access to Procon, the competent authority and the Judiciary is guaranteed, with no obligation to exhaust internal support. In consumer relationships, the jurisdiction of the consumer’s domicile and any other legally competent jurisdiction are preserved.

17. Final provisions

Brazilian laws apply, including Law No. 14,478/2022, the CDC and the LGPD (Brazil’s General Data Protection Law), and BCB regulations according to the service and the stage of the authorization process. The invalidity of one provision does not affect the others or remove legal rights.

Institutional information and regulatory sources are in the Transparency Center, and the policies are under Institutional policies. Consulting this document does not replace the specific information that must accompany each contracting.

18. Contact

Swapo Finance Sociedade Prestadora de Serviços de Ativos Virtuais Ltda
CNPJ 52.854.278/0001-20

[email protected]
+55 (11) 91004-2300 · Official WhatsApp