Terms and Conditions

Effective Date: May 20, 2025

Cacao Financial Holdings Limited (Cayman Islands), operating through its subsidiary Ruvo Financial Inc. (Delaware, USA)

1. Nature and Limitations of the Service

Ruvo is a global technology platform that enables users to interact with regulated financial infrastructure through a transparent digital experience. Ruvo is not a financial institution and does not hold any fiduciary or crypto funds. All financial operations (card issuance, identity verification, Pix and ACH payments, crypto transactions) are performed by licensed third-party providers. Users interact with these services via the Ruvo platform, which orchestrates the user experience, identity flow, and transaction initiation. Ruvo does not guarantee continuous availability or performance of any third-party infrastructure service.

2. Infrastructure Providers and Their Responsibilities

Ruvo relies on specific providers, each operating under its own licenses and compliance obligations:

  • • a. Crossmint Provider of non-custodial crypto wallets. Wallets are created on-chain under the user's exclusive control via smart contract infrastructure. Ruvo does not hold or access private keys.
  • • b. BlindPay Enables fiat payments (e.g. Pix, ACH) through virtual accounts and payout rails. Ruvo users consent to the creation of a virtual account for fiat settlement. BlindPay is responsible for monitoring transactions for AML/CFT compliance. Ruvo does not use or provide BlindPay custodial wallets.
  • • c. Rain Cards Issuer of virtual Visa cards and enabler of Apple Pay and Google Pay services. All card-related features are subject to Rain's own Cardholder Terms and Privacy Policy. Ruvo only initiates provisioning and usage via API.
  • • d. Persona Performs identity verification and document analysis in accordance with KYC, OFAC, and LGPD requirements. Biometric and document data is shared securely with Persona and may be reused across partners.

Each provider is solely responsible for its regulated operation; Ruvo is not responsible for errors, interruptions, or changes in their services.

3. User Eligibility and Responsibilities

To use the Ruvo platform, users must:

  • • Be over 18 years of age and legally competent
  • • Provide accurate personal information during onboarding
  • • Not reside in restricted or sanctioned jurisdictions
  • • Use the platform solely for legal and personal financial activities
  • • Not use the platform for any prohibited business activities, including but not limited to:
    • • Adult entertainment
    • • Unlicensed pharmaceuticals
    • • Gambling or casinos
    • • Weapons or ammunition sales
    • • Politically Exposed Persons (PEPs)

Violations may result in immediate suspension or referral to competent authorities.

4. Data Sharing and Compliance

By using the Ruvo platform, the user consents to the sharing of personal and transactional data with regulated providers for:

  • • Identity verification
  • • Virtual account creation
  • • Card issuance and fraud prevention
  • • Legal and regulatory compliance (e.g. AML, LGPD, CFT)
  • • Law enforcement requests

Data may be processed by infrastructure partners in the USA, Brazil, EU, and other compliant jurisdictions. Ruvo ensures that its providers maintain appropriate safeguards and contractual obligations (SCCs, encryption, access control) in compliance with LGPD Article 37.

5. Fiat Transaction Infrastructure via BlindPay

Users who request payouts via Pix or ACH authorize Ruvo and BlindPay to create a virtual fiat account for payment settlement. This account is not a wallet and does not store user funds. BlindPay may monitor transactions for fraud, identity mismatch, suspicious behavior, or AML risk. If violations are detected:

  • • Payouts may be frozen
  • • The user's payout access may be suspended or terminated
  • • BlindPay may notify regulators or law enforcement as required

Use of fiat rails is governed by BlindPay's Terms of Service and the applicable laws of Delaware, USA.

6. Use in the Brazilian Market

Ruvo does not operate as a legal entity in Brazil and does not offer regulated services directly in Brazilian territory. Services are offered to Brazilian users as international technology with localized interfaces. Users interact with the platform voluntarily and agree that:

  • • All services are executed by international providers
  • • No services are rendered locally by Ruvo
  • • Ruvo complies with BCB Resolution 175/2024 by relying exclusively on licensed Brazilian or foreign intermediaries for any activity involving Pix or Brazilian financial institutions

7. Legal Jurisdiction and Dispute Resolution

These Terms are governed by the laws of the Cayman Islands for general platform use. Any dispute will be resolved in the courts of George Town, Cayman Islands or Wilmington, Delaware, as applicable.

For disputes related specifically to services provided via BlindPay, the laws of Delaware, USA apply, and users agree to submit to binding arbitration under the rules of the American Arbitration Association (AAA), waiving class actions and jury trials for such disputes.

8. Platform Conduct and Suspension

Users agree not to:

  • • Engage in fraud, money laundering, or illegal remittances
  • • Share access credentials or impersonate other individuals
  • • Circumvent Ruvo's verification or compliance flows
  • • Attempt unauthorized use of the platform or any third-party service

Ruvo may immediately suspend access if it suspects any breach of these terms, including fraudulent onboarding, abuse of services, or if required by infrastructure partners.

9. Risk and Limitation of Liability

Ruvo is a coordination layer between users and regulated providers. The platform does not:

  • • Guarantee availability or performance of financial services
  • • Custody, control, or hold user funds
  • • Set fees, limits, or transaction speeds for partner services
  • • Take responsibility for delays, failures, or losses due to:
    • • Blockchain errors or forks
    • • Volatility in digital asset prices
    • • Network outages or API failures from infrastructure providers

The use of the platform is at the user's own risk, and Ruvo shall not be liable for any direct, indirect, or consequential damages related to third-party infrastructure.

10. Modifications to Terms

Ruvo reserves the right to modify these Terms and Conditions at any time. Changes will be published at www.ruvo.com with notice via email or in-app messages. Continued use of the platform after such notice constitutes acceptance of the updated terms.

11. Contact

For questions, users can contact:

Email: ajuda@ruvo.com

Website: www.ruvo.com