PUBLIC PRIVACY AND LEGAL NOTICE

 VEVRO Wallet is   designed as a global, non-custodial cryptocurrency and digital-asset wallet   using MPC/TSS or comparable distributed-key technology. VEVRO may provide   access to independent third-party services, including Transak for   cryptocurrency on-ramp and off-ramp functionality and THORChain-related   infrastructure for cryptocurrency swaps. Availability, eligibility, pricing,   fees, execution, liquidity, verification, payout, and other third-party   functions are subject to the applicable provider and protocol.

This Privacy Policy and associated Terms are intended for VEVRO Wallet users globally. VEVRO may collect and process information necessary to operate, secure, support, maintain, and improve its website, cryptocurrency wallet, digital-asset services, and related functionality. Applicable mandatory privacy and consumer laws may provide rights or protections that supplement or supersede portions of this document where required.

Depending on how a person interacts with VEVRO, information may include name and contact information; email address; phone number; account identifiers; device and browser information; IP address and technical data; application diagnostics; security information; public blockchain addresses; transaction identifiers; customer-support communications; and information associated with authorized integrations.

VEVRO Wallet is designed around distributed authorization rather than a conventional model in which a complete private key is centrally stored in one ordinary location. Depending on the production implementation, authorization may involve User/device cryptographic material and VEVRO/service cryptographic material participating in an MPC/TSS signing process.
 

VEVRO does not intend, in ordinary operation, to maintain a conventional complete private key or plaintext seed phrase for each User. Google Drive, Apple/iCloud, or another cloud provider may, where enabled, store encrypted, protected, incomplete, or otherwise non-independently-usable recovery information. Such storage does not make the cloud provider a custodian of the User's Digital Assets.

Where supported, VEVRO may use Google Drive, Apple/iCloud, email, SMS, or other services as components of recovery, verification, re-entry, notification, or security. VEVRO does not control the security, availability, retention, deletion, account recovery, or infrastructure of independent providers.
 

Users are responsible for protecting their devices, cloud accounts, email accounts, phone numbers, authentication methods, and recovery information.

VEVRO may make Transak available through an integration, widget, link, API, or embedded experience. Transak is an independent third-party provider.
 

Transak ON-RAMP functionality may enable eligible users to purchase cryptocurrency or other Digital Assets using fiat currency or supported payment methods. Transak OFF-RAMP functionality may enable eligible users to sell cryptocurrency or other Digital Assets for fiat currency or another supported payout method.
 

VEVRO is not Transak and does not control Transak's KYC/AML decisions, verification, supported jurisdictions, supported assets, pricing, fees, liquidity, payment methods, banking providers, transaction limits, order acceptance, holds, suspensions, refunds, reversals, chargebacks, payout timing, or availability.
 

To the maximum extent permitted by applicable law, VEVRO is not responsible for Transak's shortcomings, delays, rejected orders, verification decisions, KYC/AML determinations, payment failures, banking delays, liquidity limitations, quote changes, fees, refunds, reversals, chargebacks, payout failures, outages, restrictions, or other events within Transak's or another third party's control.

VEVRO may provide access to THORChain-related functionality for cryptocurrency swaps, including cross-chain swaps. THORChain is independent decentralized swap infrastructure. VEVRO does not control its protocol, nodes, liquidity, routing, supported networks, fees, slippage, execution, settlement, or availability.
 

Cryptocurrency swaps can involve network fees, slippage, liquidity conditions, confirmation delays, protocol conditions, failed transactions, and irreversible transactions. Users must verify the asset, network, destination address, amount, fees, and applicable swap conditions before approving a transaction.
 

To the maximum extent permitted by applicable law, VEVRO is not responsible for THORChain or related protocol failures, node failures, liquidity problems, routing issues, unsupported assets, blockchain congestion, incorrect transaction details, or other third-party events outside VEVRO's reasonable control.

VEVRO may support or provide access to Bitcoin, Ethereum, stablecoins, tokens, NFTs, and other Digital Assets depending on the production implementation. Digital Assets can be highly volatile and may lose some or all value. Blockchain transactions may be irreversible. Incorrect addresses, networks, token contracts, or transaction parameters may result in permanent loss.
 

Blockchain networks, validators, smart contracts, decentralized applications, bridges, exchanges, liquidity providers, payment providers, cloud providers, and other infrastructure may fail, be compromised, congested, modified, or discontinued.

VEVRO may use information to operate and maintain the website and Wallet; provide support; communicate with Users; authenticate and secure accounts; prevent fraud and abuse; troubleshoot and improve technical performance; investigate security incidents; comply with applicable law; and protect VEVRO, Users, and third parties.

Independent third parties—including Transak, cloud providers, payment providers, email providers, SMS providers, blockchain infrastructure providers, analytics providers, and other service providers—may independently collect and process information under their own policies and terms. If a User provides information directly to a third party, that third party's privacy policy and legal terms may govern that information.
 

Public blockchain records may remain publicly visible outside VEVRO's control.

The VEVRO website may use cookies and similar technologies for website operation, security, preferences, analytics, functionality, and performance. Third-party integrations may use their own technologies according to their respective policies.

VEVRO uses reasonable measures designed to protect information within its control. No website, cryptocurrency wallet, application, cloud system, communications channel, blockchain, or electronic transmission can be guaranteed to be completely secure. Users remain responsible for the security of credentials, devices, accounts, recovery methods, and authentication factors under their control.

VEVRO Wallet is not designed for persons who lack the legal capacity to enter into the applicable agreement. Because legal capacity, contractual capacity, and age-related requirements vary by jurisdiction, VEVRO does not rely solely on one universal numerical age standard. Persons should use VEVRO only where they are legally permitted and have the capacity to enter into and perform the applicable agreement under the law governing them.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VEVRO AND ITS OPERATORS SHALL NOT BE RESPONSIBLE FOR FAILURE, DELAY, INTERRUPTION, LOSS, CORRUPTION, OR INABILITY TO PROVIDE THE SERVICE TO THE EXTENT CAUSED BY EVENTS BEYOND REASONABLE CONTROL, INCLUDING ACTS OF GOD; NATURAL DISASTERS; EARTHQUAKES; FLOODS; FIRES; STORMS; HURRICANES; EXTREME WEATHER; EPIDEMICS OR PANDEMICS; WAR; TERRORISM; CIVIL UNREST; RIOTS; GOVERNMENT ACTION; SANCTIONS; EMBARGOES; POWER OUTAGES; GRID FAILURES; INTERNET OR TELECOMMUNICATIONS OUTAGES; CLOUD OR DATA-CENTER OUTAGES; CYBERATTACKS; DDoS EVENTS; BLOCKCHAIN OR VALIDATOR FAILURES; PROTOCOL CHANGES; TRANSAK OR PAYMENT-SERVICE FAILURES; THORCHAIN OR RELATED PROTOCOL FAILURES; HARDWARE OR SOFTWARE FAILURES; SUPPLY-CHAIN DISRUPTIONS; LABOR DISPUTES; STRIKES; LOCKOUTS; OR OTHER UNFORESEEABLE OR UNAVOIDABLE CIRCUMSTANCES BEYOND REASONABLE CONTROL.
 

This provision does not waive liability that applicable law makes non-waivable or excuse fraud or willful misconduct where prohibited by law.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VEVRO AND ITS OPERATORS, AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, CONTRACTORS, LICENSORS, SERVICE PROVIDERS, AND INFRASTRUCTURE PROVIDERS SHALL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, PUNITIVE, OR SIMILAR DAMAGES, OR LOSS OF PROFITS, REVENUE, DATA, DIGITAL ASSETS, DIGITAL-ASSET VALUE, ACCESS, OR USE ARISING FROM OR RELATED TO VEVRO, THE WALLET, ANY BLOCKCHAIN, TRANSAK, THORCHAIN, OR ANY THIRD-PARTY SERVICE.
 

Without limitation, VEVRO is not responsible for compromised devices, email or cloud accounts, SIM swaps, lost credentials, lost recovery components, incorrect transaction details, fraudulent recipients, unsupported assets or networks, phishing, malware, unauthorized access outside VEVRO's reasonable control, Transak decisions or failures, payment-provider failures, THORChain or protocol failures, liquidity or routing issues, or third-party outages.
 

To the maximum extent permitted by applicable law, VEVRO's aggregate liability shall not exceed the greater of amounts paid directly to VEVRO for the applicable service during the preceding twelve months or US $100, subject to mandatory law.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE USER AGREES TO DEFEND, INDEMNIFY, AND HOLD HARMLESS VEVRO, ITS OPERATORS, AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, LICENSORS, SERVICE PROVIDERS, AND INFRASTRUCTURE PROVIDERS FROM CLAIMS, DEMANDS, ACTIONS, LOSSES, LIABILITIES, DAMAGES, JUDGMENTS, PENALTIES, COSTS, AND REASONABLE ATTORNEYS' FEES ARISING FROM OR RELATED TO THE USER'S USE OR MISUSE OF VEVRO; VIOLATION OF THESE TERMS OR APPLICABLE LAW; TRANSACTIONS INITIATED OR AUTHORIZED BY THE USER; USER NEGLIGENCE, FRAUD, OR INTENTIONAL MISCONDUCT; COMPROMISE OF USER DEVICES, ACCOUNTS, CLOUD STORAGE, EMAIL, PHONE NUMBERS, OR RECOVERY METHODS; OR USE OF DIGITAL ASSETS, THORCHAIN, TRANSAK, DECENTRALIZED APPLICATIONS, OR OTHER THIRD-PARTY SERVICES.
 

This indemnification provision is not intended to require a User to indemnify VEVRO for VEVRO's own fraud, willful misconduct, or liability that applicable law prohibits VEVRO from shifting.

Depending on the User's location, applicable law may provide rights concerning access, correction, deletion, restriction, objection, portability, or other aspects of personal information. Requests concerning information collected directly by an independent provider, including Transak, may need to be directed to that provider.

VEVRO may update this Privacy Policy and Terms from time to time. Material changes will be handled in accordance with applicable law.
 

Official support contact: support@vevro.com. VEVRO support should never request a private key, seed phrase, complete recovery phrase, password, passkey, or one-time authentication code.