Terms of Use

Last updated: December 4, 2025

(i) Without limiting any other obligations set forth in the agreements entered into between Lumx and its CLIENTS (the “MSA”), in order to use the Lumx Platform and/or any functionalities, products, and services made available through the Platform (collectively, the “Services”), End Users must read and agree to these Terms of Use (“Terms”), Annex I, and all applicable policies made available on the Lumx website and/or directly on the Platform.

(ii) To ensure greater clarity and understanding of this document, the definitions of the terms and expressions used herein are detailed in Annex I.

(iii) If the End User is located in a restricted jurisdiction or if the operation involves a country, region, or person subject to legal, regulatory, or compliance restrictions (“Restricted Locations”), LUMX may refuse to offer, limit, or deny the Services. The list and criteria of Restricted Locations may be updated at any time, with disclosure on the website and on the Platform, as applicable.

(iv) The End User is subject to verification and validation procedures, including KYC (“Know Your Customer”) and KYB (“Know Your Business”), document verification, and compliance checks conducted by Lumx and/or third-party partners, depending on the operational model of the Service and the jurisdiction involved.

(v) LUMX is governed by Brazilian law and reserves the right to refuse or cancel End User registrations, whether foreign or domestic, that do not meet eligibility criteria, including, but not limited to, failure in identity verification procedures, without any obligation to provide compensation or indemnification.

(vi) The End User acknowledges that, if classified as a “US Person” and/or if the operation involves a relevant connection to the United States, the execution of the Services may occur exclusively through licensed third-party partners contracted by LUMX. In such cases, Lumx acts solely as a technological integration bridge, without touching, holding, or moving funds, and without processing the settlement of the transaction.

1. ABOUT THE PLATFORM
   1.1. Ownership. LUMX S.A., a legal entity registered under CNPJ/MF No. 42.887.120/0001-00, headquartered at Rua Voluntários da Pátria, 89, Suite 804, Botafogo, Rio de Janeiro/RJ, Zip Code 22270-000, is a startup pecialized in providing technological infrastructure for payments integrated with stablecoins (“Platform”), through Application Programming Interfaces (“APIs”).
   
   1.2. Purpose. The LUMX Platform consists of an integrated and modular solution that enables international payments and settlements using stablecoins through user-friendly APIs and a dashboard for managing and monitoring operations.
   1.2.1. Documentation. The technical documentation is available at “https://docs.lumx.io/”, covering all functionalities, usage conditions, technical requirements, and other essential information for the proper operational functioning of each tool.
   
   1.2.2. Use of the Services. These Terms govern End User access to and use of the Services. For the avoidance of doubt, the End User does not receive any API or dashboard license from LUMX unless also acting as a Client under the MSA. In certain operations, the Client may also act as an End User, including as beneficiary, payer, recipient, and/or holder of a transaction. In such cases, the following documents apply concurrently: (i) the MSA, regarding the Client’s rights and obligations toward LUMX; and (ii) these Terms, regarding the rules applicable to the use of the Services in the capacity of End User, as applicable.

   1.2.3. Characteristics. The Platform is offered to End Users on an “as available” basis, without any express or implied warranty of continuous, uninterrupted, or error-free operation.
   
   1.2.4. Connectivity. The operation of the Services depends solely on internet access, with no need for the installation of additional software components or hardware.
   
   1.3. Partners. Lumx provides its Services through technological integrations with partner companies (“Partners”), whose solutions are connected to the LUMX infrastructure. These partnerships allow End Users to carry out digital asset transactions and use stablecoins, expanding the functionalities and accessibility of the services offered by LUMX. The list of partners may be updated at any time, with new partners being added or existing ones removed at LUMX’s sole discretion. A list of LUMX’s essential partners will be made available on the LUMX website.
   
   

2. APPLICATION OF TERMS OF USE
   2.1. Scope. These Terms of Use govern the activities carried out and the Services offered by LUMX.
   
   2.2. Binding Effect. These Terms of Use constitute a legally binding document that establishes the rights and obligations of LUMX and End Users, and form part of any other terms or agreements that may be executed between the contracting parties for all legal purposes.
   
   
   

3. ADHESION AND ACCEPTANCE
   3.1. Adhesion and Acceptance. The use of the Platform is conducted under the full and exclusive responsibility of the End User, and by clicking the acceptance checkbox with the statement “I HAVE READ AND AGREE TO THE TERMS AND CONDITIONS OF USE,” the CLIENT provides informed and unequivocal consent to
   all rules set forth in these Terms.
   
   

4. REGULATION
   4.1. Compliance. LUMX declares that it conducts its activities in accordance with the laws and regulations applicable in Brazil, including, without limitation, Law No. 12,965/2014 (“Brazilian Internet Civil Rights Framework”) and Law No. 13,709/2018 (“LGPD”), as well as all other rules and regulatory acts applicable to the provision of the Services. LUMX further declares that it observes the legal and regulatory framework applicable to virtual asset service providers, including Law No.14,478/2022, Decree No. 11,563/2023, and the resolutions issued by the Central Bank of Brazil that are in effect on the subject.
   
   

5. ACESS
   5.1. Dashboard Console. The CLIENT will have access to a dashboard designed to meet its operational needs and optimize the use of the functionalities made available.
   
   5.2. Login. The CLIENT’s login to the Dashboard Console shall be carried out through the link sent by LUMX to the registered email address or directly at (https://dashboard.lumx.io/login). After accessing the link, the CLIENT must provide the necessary information to configure its access and navigate within the environment.
   
   5.2.1. Access Requirements. To use the Services, the CLIENT must:
   (i) Have received a legally granted license from LUMX, which shall be limited, non-exclusive, personal, non-transferable, and revocable;
   
   (ii) Access the link sent by LUMX to the registered email address, through which the CLIENT may create its login and password to access the Dashboard Console. Access may be completed via Google, SMS, Magic Link, or another customized authentication method, technically known as Single Sign-On (“SSO”).

   5.2.2. Responsibility for Access. The CLIENT is responsible for securely storing its account access credentials, ensuring confidentiality and proper protection against unauthorized or improper use.
   
   5.2.2.1. After accessing the Dashboard Console, the CLIENT’s Account Administrator may add members of the CLIENT’s team (such as internal developers), enabling them to use the environment in a controlled and secure
   manner.
   
   5.2.2.2. LUMX must be notified in a timely manner of any unauthorized use of the CLIENT’s account, subject to the liability limitations set forth in these Terms of Use.
   5.2.3. Registration or Access Violations. Any CLIENT registration and/or Account Administrator access carried out in violation of the rules established in these Terms of Use may result in sanctions and/or termination of the contractual relationship, as provided in the applicable provisions of these Terms.
   
   5.2.4. End-User Management. The CLIENT is solely responsible for the registration, authorization of specific access, permission management, and sharing of data and information of End-Users, including the accuracy of the information provided and compliance with applicable laws and regulations.
   
   5.3. Integration with Blockchain Networks. Integration with and support for various Blockchain networks is determined exclusively by LUMX, at its sole discretion, taking into account technical, operational, and strategic factors to ensure interoperability and technical efficiency in the operations performed. The CLIENT may indicate a preferred Blockchain network, but the final decision shall rest with LUMX.
   
   5.3.1. LUMX reserves the right to modify the Blockchain network used at any time when necessary to ensure efficiency, security, and operational viability of the services provided. Such changes may be motivated by external factors, including technological updates, operational costs, or restrictions within the previously selected network. If a change occurs, LUMX shall notify the CLIENT with reasonable advance notice.
   
   

6. OBLIGATIONS AND LIMITATIONS OF LIABILITY
   6.1 LUMX Obligations. LUMX undertakes only to:
   (i) Provide the Services in a secure and stable manner;
   
   (ii) Maintain, according to our judgment and market possibilities, constant updates of the Platform aimed at its improvement and adaptation to available new technologies; and
   
   (iii) Protect the confidentiality of all information to which it has access, adopting appropriate security measures.
   
   6.1.1 Service Availability. LUMX will use its best efforts to ensure the proper functioning of the Platform, but cannot guarantee (i) its uninterrupted availability or freedom from any errors or failures, which may occur due to technical aspects, maintenance, or updates; (ii) that it will not be subject to attack, intrusion, and/or
   unauthorized modification by third parties; and (iii) the continuity of the service in cases of force majeure or unforeseen events, which may temporarily impact access to or functioning of the Services.
   
   6.2 End User Obligations. The End User declares that the information and documents provided, directly or indirectly, are true, complete, and current, committing to keep them updated and provide clarifications and/or additional documentation when necessary or requested. The End User acknowledges that LUMX may rely on this information and instructions as received, including for verification and execution of operations.
   
   6.3 Limitation of LUMX Liability and Disclaimer of Warranties. The End User acknowledges and agrees that LUMX and its third-party suppliers and Partners shall not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, including, but not limited to, damages for loss of profits, revenue, goodwill, use, data, or other intangible losses, even if LUMX has been advised of the possibility of such damages, resulting from: (1) the use or inability to use LUMX Services; (2) the cost of acquiring substitute goods or services; (3) access to or alteration of the User's account or data due to their conduct or negligence; or (4) any other matter related to the content or Services provided by LUMX.
   
   6.4 Financial Liability Limitation. liability of each Party towards the other for any event related to these Terms of Use shall be limited to the direct damages actually suffered by the aggrieved Party, excluding any lost profits, revenue loss, and/or indirect damages, as well as penalties of any kind imposed by public authorities or third parties on the aggrieved Party, and such liability shall always be limited to the total amount actually paid by the End User to LUMX.
   
   

7. PLATFORM ACCESS CANCELLATION RULES
   7.1 Access Limitation. LUMX reserves the right to limit, restrict, suspend, or terminate access to the Platform for End Users who: (a) Breach any rule or condition set forth in these Terms of Use; (b) Infringe copyright, applicable laws, or regulations; or (c) Compromise the security or integrity of the Platform.
   
   7.2 Access Cancellation. LUMX may cancel or refuse access to the Platform immediately and without prior notice in the following situations:
   (i) Total or partial breach of any rules, conditions, and obligations set forth in these Terms of Use, in contracts executed with LUMX, and/or applicable law, including non-payment as contracted;
   
   (ii) Platform deactivation, in which case LUMX undertakes to send an official email to the CLIENT notifying the decision, with no compensation owed; and
   
   (iii) Evidence of illicit or improper use of the infrastructure, including operating suspicious activities that violate applicable laws or regulations or contravene good faith.
   
   

8. INTELLECTUAL PROPERTY
   8.1 Intellectual Property Protection. All texts, photographs, images, videos, illustrations, icons, technologies, links, and other audiovisual or sound content, including software, graphic designs, source codes, APIs, and extensions, as well as any developments or improvements made by LUMX related to its Platform, are exclusive property of LUMX and are protected by national and international laws and treaties. Any copying, reproduction, or other use is prohibited, and violators are subject to civil and criminal sanctions in accordance with Laws No. 9,279/96, 9,609/98, and 9,610/98.
   
   8.2 Trademark Protection. Trademarks, trade names, distinctive signs, or logos of any kind displayed through any medium are also property of LUMX, and using the Platform does not constitute authorization for the End User to use or dispose of such elements without LUMX’s written consent.
   
   8.3 Prohibition of Use of IP and Trademarks. It is not permitted to reproduce, duplicate, copy, sell, resell, visit, or otherwise commercially exploit the content of the Platform tools without our prior written consent. Specifically, the use of data mining, bots, or other data collection and extraction tools to extract, individually or
   recurrently, any substantial part of the Platform for reuse is expressly prohibited. Violation of this provision will subject the End User to a non-compensatory fine equal to 20 (twenty) times the value of the contracted plan, without prejudice to the repair of direct, indirect, or lost profit damages.
   
   8.4 Limited Use.The End User acknowledges that they are not acquiring any intellectual property rights in the Platform covered by these Terms of Use. Furthermore, the End User understands that the use of the Platform is limited to accessing its content, functionalities, and modules, provided that all conditions set forth in these Terms of Use and, where applicable, specific conditions agreed with LUMX, are fully complied with.
   
   

9. PERSONAL DATA PROCESSING AND DATA STORAGEEERE
   9.1 Privacy Notice. The processing of End Users’ personal data, including the collection, use, storage, and protection of such information, shall be carried out in accordance with the provisions set forth in LUMX’s Privacy Notice, available on our website.
   
   9.2 Use of Cloud Computing Services. The End User acknowledges that LUMX will use third-party companies to provide its services, including Google Cloud Platform, whose terms and conditions are available at (https://cloud.google.com/terms). The End User recognizes that the services provided by such third parties are subject to the limitations and conditions described in that link, and that LUMX will use its best efforts to ensure
   adequate protection of the data transferred, in compliance with applicable law.
   
   9.3 International Data Transfer and Storage. LUMX undertakes to fully comply with the provisions of Article 33 of the Brazilian General Data Protection Law (LGPD) as well as the rules established by CD/ANPD Resolution No. 19, dated August 23, 2024, or any future replacement, ensuring that any transfer is conducted securely and in accordance with applicable principles and legal rights.
   
   

10. FINAL PROVISIONS
    10.1 Amendments. Laws and regulations regarding data processing, intellectual property, taxation, cryptocurrencies, tokens, crypto assets, and other blockchain technology applications vary significantly across jurisdictions and are subject to uncertainty. Therefore, the lack of regulatory or legal stability in Brazil may impact the use of the Services under these Terms of Use, which may be amended at LUMX’s sole discretion.
    
    10.2 Updates. These Terms of Use may be modified at any time without prior notice, provided there is no legal prohibition. Any new version of these Terms of Use will become effective once published. The End User will be notified in advance of the new version via notification and/or email, and continued use of the Services constitutes the End User’s acceptance of the updated provisions.
    10.3 Preservation of Terms. If any part of these Terms of Use is deemed invalid or unenforceable, such section shall be interpreted consistently with applicable law to reflect, as closely as possible, the original intention of the parties, and all other provisions shall remain in full force and effect.
    
    10.4 Preservation of Rights and Liability Exclusions. If LUMX fails to enforce any rights or provisions of these Terms of Use, such failure shall not constitute a waiver, and LUMX may exercise its rights within the applicable legaL deadlines. Acts of force majeure or circumstances beyond the parties’ control shall exclude liability in accordance with Brazilian law.
    
    

11. OUR OFFICIAL SUPPORT CHANNELS
    11.1 Questions. For any questions regarding the Terms of Use, the End User may request support via email: support@lumx.io
    
    11.2 Technical Support Conditions and SLA. Technical support will be provided remotely, exclusively for matters related to the use of the Services, as described in our documentation, available at: https://lumx.io/sla
    
    

12. APPLICABLE LAW AND JURISDICTION
    12.1 Applicable Law and Jurisdiction. These Terms of Use are governed by Brazilian law, with the courts of the District of Rio de Janeiro as the agreed competent jurisdiction for resolving any disputes arising herefrom, to the exclusion of any other forum, no matter how privileged. Priority shall always be given to attempts at resolution through conciliation or mediation.