Termos de uso
Scope and acceptance of the terms
These Terms of Use («Terms») constitute a legal agreement between you («User») and the entity operating the DeFlow platform («Platform», «we», «DeFlow»), a company registered in the Commonwealth of the Bahamas. They fully govern access, registration and use of all features, products and services made available through the Platform, including, without limitation: account creation and management, deposits (conversion of fiat into digital assets), withdrawals (conversion of digital assets into fiat), payment links, charges and receiving QR codes, bill (boleto) payments, the affiliate programme and any current or future functionality. By creating an account, accessing, browsing or using the Platform in any way, you represent that you have read, understood and agreed to these Terms in full. If you do not agree with any provision herein, you must not create an account or use the Platform. Use of the Platform constitutes binding acceptance of these Terms. Formal acceptance of the Terms is made expressly when you scroll the document to the end, tick the corresponding option and confirm, after having had a real opportunity to read all topics. This procedure is required on first access after registration and whenever a new version of the Terms is published, in which case renewed acceptance is requested at login before you can continue using the account. Substantial changes to the Terms require explicit renewed acceptance; until such acceptance is made, access to features may be restricted. We recommend that you review this page periodically to stay informed of any updates.
Nature of the service
DeFlow is a technology platform, operated by an entity registered in the Commonwealth of the Bahamas, that facilitates the exchange between fiat currency (via instant payment methods such as PIX) and digital assets (stablecoins, in particular the one known as DePix), in a non-custodial manner. This means we do not custody, hold, control or possess users' digital assets; assets are credited directly to the wallet the user controls. The Platform acts solely as a technical bridge between the user and third-party payment and liquidity providers: we display a quote, and the operation (deposit or withdrawal) is executed against those providers, not between users. DeFlow does not offer trading, a marketplace or user-to-user (P2P) exchange; there are no offers from one user accepted by another. At no time does DeFlow act as custodian, financial institution or counterparty to settlement. The PIX payment provider is an independent third party; its actions, timelines and decisions are not acts of DeFlow. Services are provided «as is», to the extent permitted by applicable law. The Platform does not guarantee specific results, fixed processing times or uninterrupted availability. The user uses the Platform at their own risk, with full awareness of the non-custodial nature of the service and the responsibilities this implies.
No KYC (Know Your Customer)
The DeFlow Platform does not perform Know Your Customer (KYC) procedures or formal identification or verification of customers. We do not request identity documents, proof of address, proof of source of funds, selfie, video or any other requirement typical of KYC/AML compliance programmes for use of the Services. The decision to operate without KYC reflects our business and privacy model; however, this means that the user assumes full responsibility for compliance with the laws of their jurisdiction. You are solely responsible for complying with all legal obligations that apply to your use of the Platform, including but not limited to: tax obligations, reporting to the competent authority, anti-money laundering and counter-terrorism financing rules, exchange regulations and any identification or reporting requirements imposed by law or by financial institutions you deal with. The absence of KYC on the Platform does not exempt the user from any of these responsibilities. In jurisdictions where use of services like ours requires prior identification or reporting to authorities, it is your responsibility to ensure your activities comply. DeFlow is not responsible for user failure to comply with the laws of their country or region, and we reserve the right to restrict or terminate user access when there is evidence of violation of law or these Terms.
We are not a banking institution
DeFlow is not a bank, financial institution, currency issuer, payment account service provider or entity regulated as a credit institution in any jurisdiction. We do not issue currency, we do not accept demand deposits in the regulatory sense (as a financial institution), we do not offer regulated payment accounts, credit or debit cards, loans, insurance or any product or service typical of the banking sector. Fiat amounts used in operations are processed through agreements with third parties (payment providers, gateways, etc.), as available in your region. Custody of digital assets is always held by the user, through wallets they control. Nothing in these Terms or in the Platform's communications shall be construed as an offer of banking services, regulated payment account, regulated investment or financial product subject to specific supervision. The user must not rely on DeFlow for functions that are proper to regulated financial institutions (e.g. deposit guarantee, insurance, resolution of banking disputes). Any reference to «deposit» or «withdrawal» in the context of the Platform refers exclusively to the technical flow of conversion between fiat and digital assets in the interface, and not to deposits or withdrawals in the regulatory banking sense.
Definitions
Platform: the set of website(s), applications, interfaces, APIs, technological infrastructure and any other means by which DeFlow makes its Services available. User: the natural or legal person who accesses, uses or registers on the Platform, including visitors and account holders. Services: all functionalities offered by DeFlow, including, without limitation: account creation and management, deposit (conversion of fiat into digital assets in the user's wallet), withdrawal (conversion of digital assets into fiat sent to the designated account), non-custodial wallet management, creation and use of payment links, charges and receiving QR codes, bill (boleto) payments, affiliate programme and coupons, and any additional features made available in the future. The Platform does not offer user-to-user (P2P) trading. Digital assets / cryptoassets: digital representations of value recorded on a distributed network or equivalent system, including stablecoins and other tokens supported by the Platform. Fiat / fiat currency: legal tender issued by a government or monetary authority (e.g. the Brazilian real), as opposed to digital assets. Instant payment method: the fiat transfer channel(s) available for sending and receiving funds in the deposit and withdrawal flow (e.g. PIX), operated by third-party payment providers. Payment provider: an independent third party responsible for processing fiat (PIX) transfers and settlement with the financial system, for which DeFlow is only the technical bridge. Account: the user's registration on the Platform, linked to access credentials (email, password, two-factor authentication where applicable) and associated data and preferences. Coupon / affiliate: referral mechanism, affiliate code and affiliate programme when available, subject to the specific rules described in the corresponding section of these Terms.
Eligibility and capacity
Only persons with full legal capacity to enter into binding contracts in their jurisdiction and who are not prohibited by law, regulation or these Terms may use the Platform. Use of the Platform by persons under 18 years of age (or the minimum age of majority in your jurisdiction, if higher) is expressly prohibited. If you are using the Platform on behalf of a legal entity, you represent that you have authority to bind that entity to these Terms. Use is also prohibited by persons who have been previously banned, whose access has been revoked or who are on DeFlow's internal restriction list. Attempts to create a new account after a ban or revocation may result in permanent blocking and additional measures. The user represents and warrants that: (i) all information provided during registration and use of the Platform is true, accurate and up to date; (ii) their use of the Platform complies with all laws applicable to their situation (including laws of the country where you reside, where you are located when accessing the Platform and where you conduct operations); (iii) you are not in a country or territory subject to embargo or restrictions that prohibit use of the Services; (iv) you are not using the Platform for illegal purposes or in violation of third-party rights. False or inaccurate representations may result in account termination and liability.
Account and security
The user is solely responsible for maintaining the confidentiality of all credentials for access to their account, including password, two-factor authentication (2FA) codes, backup codes and any other verification mechanisms made available by the Platform. You must not share your credentials with third parties, store them in insecure locations or reuse passwords used on other services. We strongly recommend using two-factor authentication (2FA) when available, using a password manager and accessing the Platform only from trusted and up-to-date devices. All activity carried out using your credentials will be deemed to have been carried out by you, except where prior and proven notice of unauthorised use has been given. The Platform is not responsible for losses, misplacement or damage arising from unauthorised access to the account due to the user's failure to protect their credentials, maintain password confidentiality or adopt reasonable security measures. In the event of loss of the device used for 2FA, the user is responsible for using backup codes or the recovery procedures made available. The user must notify DeFlow immediately of any unauthorised use of the account, any suspected security breach (e.g. login from an unknown location or device, unsolicited change of data) or any other irregularity. Delay or failure to give such notice may increase risks and limit the Platform's ability to take corrective action. DeFlow reserves the right to request additional identity or security verification when there is evidence of account compromise or breach of these Terms.
Deposits and withdrawals
Deposits consist of the conversion of fiat amounts sent by the user via the instant payment channel available in their region (as indicated in the interface) into digital assets that are credited to the user's non-custodial wallet. Withdrawals consist of the conversion of digital assets from the user's wallet into fiat amounts that are sent to the account or destination indicated by the user, via the same or another available channel. Deposits and withdrawals are subject to minimum and maximum limits, processing times, operational and security rules and liquidity and partner availability. Limits and times may vary by region, volume, user history and internal policies. The user is responsible for providing correct data (including keys, accounts or destination identifiers) and for bearing any network fees, Platform fees or applicable processing costs, as disclosed at the time of the operation. Delays, failures or cancellations may occur for technical, security, regulatory or third-party reasons (payment providers, blockchain networks, etc.) or by Platform decision when there is evidence of fraud or breach. The Platform acts in good faith to meet the times indicated in the interface, but does not guarantee results within a set time nor assume responsibility for delays or failures due to external factors. In case of inconsistency (e.g. sent amount not identified, incorrect withdrawal data), the user must contact support; resolution is subject to case-by-case analysis and internal policies.
Quotes, orders and execution
Every operation on the Platform (deposit or withdrawal) starts from a quote displayed before confirmation, which already reflects the amount to be paid and the amount to be received, including the applicable effective fee. DeFlow does not operate user-to-user (P2P) trading: there are no offers from one user that are accepted by another. The order is executed by the Platform as a technical bridge against third-party payment and liquidity providers; the settlement counterparty is never another user. By confirming an operation, you accept the quote presented at that moment. Quotes have limited validity and may expire or vary according to market, network and provider liquidity conditions; if a quote expires, a new one is displayed before any execution. In withdrawals, the amount actually received corresponds to the confirmed amount, with no tolerance margin; amount discrepancies, incorrect destination data or payments originating from an account held by a different holder may result in non-processing or reversal, in accordance with the payment provider's rules. Execution depends on external factors (payment provider availability, blockchain network confirmation, liquidity). DeFlow acts in good faith to execute orders according to the accepted quote, but does not guarantee a determined timeframe nor is it responsible for delays, blocks or failures attributable to third-party providers, networks or incorrect data supplied by the user. In case of inconsistency, the user should contact support; resolution is subject to case-by-case analysis and the internal and provider policies.
Non-custody and "your keys, your assets"
DeFlow is a non-custodial platform. This means we do not hold, custody, control or possess users' private keys or digital assets. Assets remain under the exclusive control of the user, through cryptographic wallets linked to the account on the Platform or managed by you on devices and applications of your choice. The principle «your keys, your assets» applies in full: whoever controls the private keys controls the assets; the Platform has no ability to access, move or recover assets in wallets under user control. Loss of private keys, recovery codes, devices where wallets are installed or means of access to the wallet may result in irreversible loss of assets. There is no «account recovery» or «password reset» that would allow DeFlow or third parties to access or recover assets held in non-custodial wallets. It is solely the user's responsibility to ensure secure backup of keys and recovery means, protect their devices against malware and unauthorised access and adopt appropriate security practices. DeFlow is not responsible for losses arising from key loss, backup failure, device compromise or user error.
Fees and costs
Use of the Platform and certain features may be subject to fees, which will be disclosed at the time of the operation, in the settings area or in documentation available in the interface. Fees may vary by type of operation (deposit, withdrawal, link creation, etc.), volume, region, applicable affiliate or coupon rules and commercial policy changes. DeFlow reserves the right to modify fees at any time for new operations; significant changes will be communicated with reasonable notice where applicable. Continued use of the Platform after disclosure of new fees may be deemed acceptance for operations carried out thereafter. Network costs (e.g. blockchain fees, payment processing costs, spread or liquidity costs) may be passed on to the user, included in the amount displayed or charged separately, as described in the interface at the time of the operation. The amount displayed before confirmation already reflects the applicable effective fee; the user is responsible for checking the total cost before confirming any transaction. Nothing in these Terms guarantees that fees will remain fixed or that there will be no additional costs due to third-party factors (network fee variation, exchange rates, etc.).
Prohibited uses and rules so as not to compromise the platform
The user is expressly prohibited from using the Platform or Services in a manner that: (1) violates applicable laws, including anti-money laundering, counter-terrorism financing, tax evasion, international sanctions or exchange and securities regulations; (2) constitutes or facilitates fraud, scam, misappropriation, abusive chargeback, fraudulent transfers or any form of unlawful gain; (3) uses automation, bots, scripts, scrapers or unauthorised means to access, query or operate the Platform, or to circumvent limits, security controls or technical restrictions; (4) allows unauthorised third parties to use your account or credentials; (5) abuses support, customer service channels or Platform features (e.g. opening multiple tickets abusively, providing false information); (6) manipulates prices, offers, liquidity or system operation in an artificial or deceptive manner; (7) sends spam, malware, phishing or content harmful to other users or infrastructure; (8) violates third-party rights (intellectual property, privacy, honour) or (9) in any way compromises the integrity, security, availability or reputation of the Platform or other users. Failure to comply with these rules may result in warning, restriction of features, temporary or permanent account blocking, loss of balances or benefits, termination of the relationship and, where appropriate, reporting to authorities and legal action. DeFlow cooperates with competent authorities in investigations related to unlawful activities. By using the Platform, you undertake not to compromise the service for yourself or for other users.
Sanctions, blocking and termination
In the event of breach of these Terms, Platform policies or conduct that compromises the security, integrity or reputation of the service or other users, DeFlow may apply progressive or immediate sanctions, depending on the severity of the case. Sanctions include, without limitation: warning by email or in the interface; restriction of features (e.g. value limit, temporary suspension of deposits or withdrawals); temporary account blocking; permanent account blocking; termination of the relationship and prohibition on creating new accounts. Blocking or termination may be based on grounds such as: breach of terms of use; fraud, scam or attempt thereof; misuse of the platform; abusive chargeback; fraudulent transfers; money laundering or financing of unlawful activities; tax evasion; breach of applicable laws; abuse of support; system manipulation; conduct that exposes the Platform or other users to risk; or other grounds in accordance with internal policy and applicable law. In blocking situations, the user will be notified where appropriate and to the extent permitted by law; withdrawal of remaining assets may be subject to compliance review, legal deadlines or decision by the competent authority. DeFlow cooperates with authorities in investigations and may retain data or funds when required by law or court order.
Privacy and data
Processing of users' personal data is carried out in accordance with our Privacy Policy, which forms part of the context of these Terms and should be read together. We collect only the minimum necessary to operate the Platform, provide support, comply with legal obligations and ensure the security and integrity of the service. Data may include, as the case may be: account identification (email, name when provided), usage data (access logs, IP address, device type), transaction data (for support and compliance) and communications with support. The user is responsible for providing correct, complete and up-to-date data. Incorrect or outdated data may prevent access to certain features, processing of operations or contact when necessary. DeFlow does not sell personal data to third parties for marketing purposes; data may be shared with service providers (hosting, support, analytics tools) to the extent necessary and in compliance with the Privacy Policy and applicable law. If you have questions about the collection, use, storage, retention or your rights regarding your data, please refer to the Privacy Policy available on the website or contact us through the indicated channels.
Affiliate programme and coupon
The Platform may offer an affiliate programme and referral coupon mechanism, allowing users to share a code or link and, in accordance with the current rules, receive benefits (e.g. share of fees, credits or discounts) when new users register or carry out operations using that code. Use of a coupon on registration or in account settings is subject to the rules in force at the time: the coupon must be valid, active and not fraudulent, and used in good faith. Coupons obtained unlawfully, resold or used in breach of the rules may be voided and the user may be penalised. The affiliate (who shares the coupon) is responsible for promoting the programme in a lawful manner, without practising spam, deceptive inducement, false promises or violation of laws (e.g. advertising or consumer protection regulations in their jurisdiction). DeFlow reserves the right to change the programme rules, benefits, percentages and conditions at any time, as well as to terminate the programme or the participation of a specific affiliate. Benefits (discounts, credits, commissions, etc.) may be changed or discontinued in accordance with Platform policy; significant changes will be communicated where applicable. Any dispute between affiliate and referred user (e.g. regarding entitlement to commission, use of coupon) is the responsibility of the parties; the Platform acts only as provider of the programme infrastructure and rules, with no obligation to compensate or mediate conflicts between users. The affiliate has no employment, partnership or agency relationship with DeFlow; they act independently in promoting the coupon.
Availability and risks
The Services are offered «as is» and «as available», to the maximum extent permitted by applicable law. We do not guarantee uninterrupted availability, absence of errors, bugs or vulnerabilities, specific response time or determined result for any operation. The Platform may experience interruptions due to maintenance, updates, technical failures, attacks, third-party issues (hosting providers, networks, payment providers) or by DeFlow decision. The user should consider these risks before relying on the Platform for time-sensitive operations. Use of cryptoassets and payment methods for fiat conversion involves inherent risks, including but not limited to: price volatility; technical failures of network or software; regulatory changes affecting the legality or operation of the services; risk of loss of keys or assets in non-custodial wallets; delays, blocks or failures in processing by third-party payment providers; reversal of funds by the payment provider's own mechanism in cases of suspected fraud; and risk of third-party fraud. The user declares that they are aware of these risks and fully assumes responsibility for their decisions and for any resulting losses. DeFlow is not responsible for asset losses, delays, third-party failures or regulatory changes. Use of the Platform is at the user's own risk, and the user has had the opportunity to read and accept these Terms.
Indemnification
The user agrees to indemnify, defend and hold harmless DeFlow, its subsidiaries, affiliates, partners, service providers, directors, employees, agents and representatives («Indemnified Parties») from and against any and all claims, demands, actions, proceedings, losses, damages, costs and expenses (including reasonable legal and advisory fees) arising out of or related to: (i) the user's breach of these Terms or Platform policies; (ii) the user's misuse of the Platform or Services; (iii) the user's violation of laws, regulations or third-party rights; (iv) disputes between the user and other users or third parties (including claims by another user against DeFlow arising from the user's conduct); (v) claims that the user's data, content or conduct infringes third-party rights or applicable laws; (vi) unauthorised access to the user's account when resulting from the user's failure to protect credentials. This indemnification obligation survives termination of the relationship between the user and DeFlow. The Indemnified Parties reserve the right to assume the exclusive defence of any matter subject to indemnification by the user, without prejudice to the obligation to indemnify.
Limitation of liability
To the maximum extent permitted by applicable law, DeFlow, its subsidiaries, partners and representatives shall not be liable to the user or third parties for: (a) indirect, incidental, special, consequential or punitive damages; (b) loss of profits, revenue, data, use, opportunity or goodwill; (c) cost of procuring substitute goods or services; (d) any damage arising from interruption, failure, delay, error or vulnerability of the Services, even if DeFlow has been advised of the possibility of such damages. DeFlow's total aggregate liability to the user, for any cause (contract, warranty, tort, negligence, strict liability or otherwise), shall be limited to the lesser of: (i) the amount actually paid by the user to the Platform in the last twelve (12) months for use of fee-based Services; or (ii) the maximum amount that applicable law permits to be limited. In jurisdictions that do not allow the exclusion or limitation of certain types of damages, DeFlow's liability shall be limited to the maximum extent permitted in that jurisdiction. Nothing in these Terms excludes or limits liability that cannot be excluded or limited by law (e.g. in some jurisdictions, wilful misconduct or gross negligence).
Governing law, arbitration and jurisdiction
These Terms are governed by and construed in accordance with the laws of the Commonwealth of the Bahamas, the jurisdiction in which the DeFlow operating entity is registered, without regard to its conflict of law principles. The technical infrastructure of the Platform and its providers may be located in the United States of America and other jurisdictions, which does not change the law applicable to these Terms. Any dispute, controversy or claim arising out of or relating to these Terms, the Platform, the Services or the relationship between the user and DeFlow («Dispute») shall be resolved by final and binding arbitration, conducted on an individual and confidential basis, in accordance with recognized international arbitration rules, with the laws of the Bahamas as the applicable substantive law and English as the language of the proceedings, unless the parties agree otherwise. The user and DeFlow waive any right to a jury trial and the right to participate in class actions or representative litigation in relation to any Dispute; each party may only bring claims in its own individual capacity. Alternatively, where arbitration is not applicable or enforceable, the Dispute shall be submitted to the competent courts of the Commonwealth of the Bahamas, with express waiver of any other forum, however privileged. Nothing herein prevents DeFlow from seeking injunctive, enforcement or urgent measures in any jurisdiction where the user has assets or where violations may be occurring. If the user is located in a jurisdiction whose mandatory law requires consumer contracts to be governed by the law or forum of the consumer's domicile, such mandatory provisions may prevail strictly to the extent of the conflict.
Changes to the terms
DeFlow reserves the right to change these Terms at any time, to reflect changes in our Services, operational practices, legal requirements or other legitimate reasons. Substantive changes (e.g. changes that materially affect your rights or obligations) will be communicated through the Platform, for example: prominent notice in the interface when logging in, notification to the email associated with the account or publication on the Terms page with indication of the last update date. The date of the last update is in the versioned document (version and updatedAt) available in the interface. When required by our internal policy or applicable law, we will request explicit renewed acceptance of the Terms (e.g. by ticking a checkbox and confirming). Otherwise, continued use of the Platform after the new version of the Terms takes effect may be deemed tacit acceptance of the new version. If you do not agree with the changes, you must stop using the Platform immediately and may close your account in accordance with the termination policy and the procedures available in the interface. Maintaining an active account after changes, without renewed acceptance when requested, may result in access restriction until acceptance is completed. We recommend that you review this page periodically to stay informed of any updates.
General provisions
Entire agreement: These Terms, together with the Privacy Policy and any specific policies or rules referenced or made available on the Platform, constitute the entire agreement between the user and DeFlow regarding use of the Platform and Services, superseding all prior agreements, understandings and communications, written or oral, on the same subject. Waiver: DeFlow's failure to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. No waiver shall be effective unless made in writing and signed by a duly authorised representative of DeFlow. Severability: If any provision of these Terms is held to be invalid, illegal or unenforceable by a competent authority, such invalidity shall not affect the remaining provisions, which shall remain in full force and effect. The parties shall seek to replace the invalid provision with one that is valid and that most closely approximates the original intent. Assignment: The user may not assign, transfer or sublicense these Terms or any rights hereunder, in whole or in part, without the prior written consent of DeFlow. Any attempt to assign in violation of this provision shall be void. DeFlow may assign these Terms or its rights and obligations, in whole or in part, without restriction (e.g. in the event of restructuring, merger or sale of assets). Contact: For questions, complaints or notices relating to these Terms or use of the Platform, please contact us through the channels indicated on the website or in the application (e.g. support page, contact form or support email address). Notices to DeFlow must be sent to the officially indicated address or channel. DeFlow may send notices to the user by email associated with the account or by notice in the interface.