Terms of Use
Version 1.0, effective as of September 15, 2026.
1. Parties, acceptance and definitions
1.1. These Terms govern the use of the KairosPay application and services (the "Service"), provided by Kairos Solutions Group LLC, a limited liability company organized under the laws of the State of Wyoming, United States of America, with its registered office at 30 N Gould St, Ste N, Sheridan, WY 82801, United States ("Kairos"), to the individual who creates an account in the Service (the "Customer").
1.2. By creating an account, the Customer represents that they have read and fully accepted these Terms, the Privacy Policy, the Card Terms of the Issuing Partner and, upon enrollment, the Referral Program Rules. The latter three are separate documents.
1.3. For the purposes of these Terms:
- Virtual Asset: the US dollar-referenced stablecoins supported by the Service, currently USDC and USDT.
- Supported Networks: Polygon, BNB Smart Chain, Arbitrum and Ethereum, and any others that Kairos may announce in the application.
- Deposit Address: an address on a Supported Network, generated and controlled by Kairos and assigned to the Customer's account for receiving Virtual Assets.
- Customer Assets Wallet: the operational wallet in which Kairos consolidates the Virtual Assets received from Customers.
- Balance: the amount, expressed in US dollars, recorded in the Customer's name in Kairos' internal ledger, pursuant to clause 6.
- Card: the payment card issued by the Issuing Partner, pursuant to clause 7.
- Card Account: a Safe-type smart contract account on the Gnosis Chain network, linked to the Customer's Card.
2. Eligibility and jurisdiction
2.1. The Customer must be at least 18 years old and have full legal capacity.
2.2. The Service is offered exclusively to residents of the jurisdictions listed in the application (the "Served Jurisdictions").
2.3. The Service is not offered to persons who are citizens or residents of, or physically located in, the United States of America or its territories, nor to persons subject to sanctions administered by OFAC, the European Union, the United Kingdom or the United Nations, nor to residents of jurisdictions subject to comprehensive sanctions. The Customer represents that none of these circumstances applies to them and agrees to the closure of their account should Kairos determine otherwise.
2.4. The Customer is responsible for verifying whether use of the Service is permitted in the jurisdiction where they are located.
3. Nature of the Service and of custody
3.1. Kairos provides a software service and operates Virtual Asset wallets in the Customer's name and on the Customer's behalf.
3.2. Kairos generates, maintains and controls the private key of each Deposit Address and of each wallet assigned to the Customer. The Customer does not generate, receive, hold or control private keys, and the Service has no key export function.
3.3. As a consequence of clause 3.2, Kairos is technically able to move, block and restrict the Virtual Assets held in the wallets assigned to the Customer.
3.4. The Customer expressly acknowledges that this arrangement constitutes, in its functional substance, a custody relationship over digital assets.
3.5. The Service exists because operating directly on multiple blockchain networks requires managing wallets, safekeeping recovery phrases, maintaining balances for network fees on each network and understanding smart contract approvals, activities subject to irreversible error. Kairos performs this operational layer in the Customer's name and for the Customer's benefit.
3.6. Kairos is not a bank, is not a financial institution and does not take deposits.
4. Account, identification and anti-money laundering
4.1. Account creation is subject to identity verification conducted by a specialized provider engaged by Kairos and to risk analysis by Kairos. Kairos may refuse, limit or close accounts based on its anti-money laundering and counter-terrorism financing program and on legal obligations.
4.2. The Customer undertakes to provide truthful information, keep it up to date, use the account exclusively for themselves and not use the Service for any unlawful activity.
4.3. Kairos monitors transactions, including source and destination addresses on blockchain, and may request additional information, hold operations and report to authorities when required by law, without prior notice to the Customer where the law so provides.
5. Customer instructions and operations without individual instruction
5.1. Kairos executes upon the Customer's instruction through the application: withdrawals, conversions and other available features.
5.2. Kairos executes, regardless of individual instruction and without the Customer's presence, the operations necessary for the functioning of the Service, including:
- (a) transfer of Virtual Assets received at Deposit Addresses to the Customer Assets Wallet;
- (b) conversion between Supported Networks and between Virtual Assets, to maintain the Balance and satisfy withdrawals and payments;
- (c) provision of balance to the Card Account prior to transaction authorization;
- (d) reprocessing of failed operations;
- (e) reallocation of liquidity between operational wallets and between networks.
5.3. By accepting these Terms, the Customer authorizes in advance the operations described in clause 5.2, which are executed exclusively to maintain the Service and do not change the value of the Balance, except for the fees provided in clause 8.
5.4. Operations sent to and confirmed on blockchain are irreversible by anyone, including Kairos. The Customer is responsible for verifying address, network and amount before instructing a withdrawal.
6. Multi-network wallet and Balance
6.1. Virtual Assets received at a Deposit Address, on a Supported Network and in a supported Virtual Asset, are credited to the Balance after the number of network confirmations defined by Kairos for each network.
6.2. Assets sent on an unsupported network, in an unsupported token or to an incorrect address may be unrecoverable. Kairos may, at its discretion and subject to a fee, attempt to recover them, without any guarantee of success.
6.3. The Balance is expressed in US dollars and recorded in Kairos' internal ledger.
6.4. Kairos bears the network fees of the operations provided in clause 5.2. Network fees for withdrawals follow clause 8.
6.5. Legal nature of the Balance. The Balance represents the amount that Kairos holds in the Customer's favor, backed by Virtual Assets held in the Customer Assets Wallet and attributed to the Customer through Kairos' internal ledger.
7. Card and Card Account
7.1. The Card is issued by a partner institution authorized in the jurisdiction of issuance (the "Issuing Partner"), under the Issuing Partner's own terms, which the Customer accepts separately. Kairos does not issue the Card.
7.2. The balance available for the Card is held in the Card Account. The Card Account has a single owner, and that owner is a wallet controlled by Kairos.
7.3. The Issuing Partner operates modules enabled on the Card Account, with authority limited to the settlement of Card transactions. The Issuing Partner is not the owner of the Card Account.
7.4. Both Kairos, as owner, and the Issuing Partner, through the settlement modules, are able to move funds in the Card Account, each within its own scope.
7.5. Kairos transfers amounts from the Balance to the Card Account pursuant to clause 5.2(c) and may return amounts from the Card Account to the Balance.
7.6. The Issuing Partner may block, suspend or cancel the Card independently of the Card Account balance. Blocking the Card does not, by itself, block the Balance.
7.7. Card transaction disputes follow the Issuing Partner's terms and the card scheme rules.
8. Fees
8.1. The fees in force are those published in the Fee Schedule in the application, which forms part of these Terms.
8.2. Network fees for withdrawals are passed on to the Customer at cost, as they are owed to the blockchain network and not to Kairos. The estimated amount is displayed before confirmation.
8.3. Fee changes are communicated at least 30 days in advance. Reductions may take effect immediately.
9. Withdrawal and account closure
9.1. The Customer may withdraw the entirety of the Balance to an external address on a Supported Network at any time, subject to the controls of clause 4 and the technical timeframes of each network.
9.2. The Customer may close the account at any time after withdrawing the Balance. Kairos may close the account upon 30 days' notice, or immediately in the cases of clause 4 or of breach of these Terms, preserving the right of withdrawal except where prohibited by law.
9.3. In the event of discontinuation of the Service, Kairos will give at least 60 days' notice and keep withdrawals available during that period.
10. Asset segregation and insolvency
10.1. Virtual Assets received from Customers are consolidated in the Customer Assets Wallet, intended exclusively for Customer assets. Kairos' own funds, including revenues, fees and working capital, are not held in that wallet.
10.2. The Customer Assets Wallet is controlled by Kairos, which holds its private key. There is no on-chain segregation between individual Customers within that wallet. Each Customer's entitlement is recorded in Kairos' internal ledger.
10.3. Kairos does not use Customer Virtual Assets in its own operations, to pay its own expenses or as collateral for its own obligations.
10.4. Kairos maintains an individualized internal ledger per Customer and checks it against the balances held on blockchain.
10.5. The Customer acknowledges that, in the event of Kairos' insolvency, bankruptcy or judicial reorganization, the treatment of the assets attributed to them will depend on the law applicable to the proceeding, and that there is, under the present structure, no guarantee that such assets will be returned in full or with priority over other creditors of Kairos.
10.6. If the available assets are insufficient relative to the total recorded, for any reason, the available assets will be attributed to Customers pro rata to their respective Balances.
11. Regulatory status
11.1. Kairos Solutions Group LLC is a company organized in the State of Wyoming, United States of America.
11.2. The Service is not covered by any deposit guarantee fund, deposit insurance or equivalent mechanism in any jurisdiction.
12. Kairos' intervention powers
12.1. As a result of the custodial model described in clause 3, Kairos is able to suspend the account, refuse or block an operation before it is sent to the network and restrict the Customer's access to features.
12.2. Kairos will exercise such powers when required by its anti-money laundering program, by legal or judicial order, upon well-founded suspicion of fraud or compromise of the Customer's account, or to preserve the integrity of the Service.
12.3. Whenever the law allows, Kairos will inform the Customer of the reason and the estimated duration of the restriction.
12.4. Kairos does not reverse operations confirmed on blockchain, pursuant to clause 5.4.
13. General risks
13.1. The Customer acknowledges the risks inherent to Virtual Assets and blockchains, including: volatility and loss of peg of stablecoins; network failures, congestion and reorganizations; smart contract failures; governance acts of protocols and of stablecoin issuers, including freezing of addresses by the issuer; regulatory changes that may restrict or terminate the Service in their jurisdiction; and information security risks, including key compromise.
13.2. Kairos adopts technical and organizational security measures in the safekeeping of private keys and in the operation of the Service. No system is immune to failure.
14. Personal data
14.1. The processing of personal data is governed by the Privacy Policy.
14.2. The Customer authorizes the sharing of data with the Issuing Partner, with the identity verification provider and with fiat conversion partners, to the extent necessary for the provision of the Service and compliance with legal obligations.
15. Liability
15.1. Kairos is liable for damages arising from failures in the provision of the Service, under applicable law.
15.2. To the maximum extent permitted by applicable law, Kairos is not liable for losses arising from failures of third-party networks, protocols or smart contracts; loss of peg of stablecoins; acts of stablecoin issuers; incorrect Customer instructions as to address, network or amount; unauthorized access to the account resulting from the Customer's negligence with their credentials; and loss of profits.
16. Governing law and dispute resolution
16.1. The Customer and Kairos will seek to resolve any dispute through the support channel, within 30 days, before any other measure.
16.2. These Terms are governed by the laws of the State of Wyoming, United States of America, without prejudice to rights guaranteed by mandatory consumer protection rules of the Customer's jurisdiction of residence.
17. Referral Program
17.1. The Referral Program, when available, is governed by separate Rules.
17.2. Participation is free of charge and does not require the purchase of any product. Compensation derives exclusively from the acquisition of a Card and the payment of monthly fees by verified Customers, never from the recruitment of new participants, or from any Customer's deposits, Balance or earnings.
18. Changes to these Terms
18.1. Kairos may amend these Terms. Material changes are communicated at least 30 days in advance, by email and in the application.
18.2. Continued use after the new version takes effect constitutes acceptance. A Customer who does not agree may withdraw the Balance and close the account before the effective date.
18.3. Changes required by law or by order of an authority may take effect immediately.
19. General provisions
19.1. Communications will be made to the registered email address and through the application.
19.2. Kairos may assign these Terms to a successor or affiliated company upon notice. The Customer may not assign their account.
19.3. The invalidity of any clause does not affect the remaining clauses.
19.4. In the event of any discrepancy between the Portuguese version and any translation, the Portuguese version prevails.
19.5. Contact: through the application's support channel or the email address published at kairospay.app.