Terms & Conditions

Cuandeoro Limited

1. Introduction

These Terms & Conditions (“Terms”) govern access to and use of the website, platforms, documentation and services provided by CUANDEORO LIMITED, a private company limited by shares incorporated in Ireland (“Cuandeoro”, “the Company”, “we”, “us”).

By accessing or using any part of the Company’s services or website, you agree to be bound by these Terms.

2. Nature of the Company and Services

2.1 Cuandeoro operates exclusively as a technology and infrastructure provider.

2.2 The Company provides:

blockchain-based technical infrastructure,
tokenisation frameworks for real-world assets (RWA),
analytical, reporting and settlement support systems,
non-custodial smart contract architecture.

2.3 Cuandeoro does not:

hold or custody client funds or assets,
hold private cryptographic keys on behalf of users,
operate as a bank, payment institution, electronic money institution or investment firm,
provide investment advice, portfolio management or financial recommendations.

3. Non-Custodial Framework

3.1 All digital assets, tokens or representations referenced through Cuandeoro’s systems remain under the sole control and responsibility of their respective owners.

3.2 Users are solely responsible for:

wallet security,
private key management,
transaction execution,
compliance with applicable laws in their jurisdiction.

3.3

3.4 Private Key Recovery: Cuandeoro declares it technically impossible to recover funds if you lose your private keys or seed phrase. You bear sole responsibility for safeguarding access credentials.

3A. Notary Independence and Escrow Architecture

CRITICAL NOTICE: This section defines the legal relationship between parties and notaries in the multisig escrow system. It is fundamental to Cuandeoro's non-custodial classification under MiCA.

3A.1 Direct Contracting: Cuandeoro does NOT select, contract, employ, or maintain any agency relationship with the Public Notaries participating in transactions. The Notary acting as the third party in the 2-of-3 multisig escrow is contracted DIRECTLY and JOINTLY by the Buyer and Seller, without any intervention from Cuandeoro in such selection or contracting.

3A.2 Cuandeoro's Limited Role: Cuandeoro provides exclusively:

An informational directory of technically verified notaries (non-exclusive, non-binding)
Technical tools for wallet integration (SDK/API)
Template legal documents as reference only (non-binding)
Technical support for platform usage

3A.3 Explicit Prohibitions: Cuandeoro CANNOT:

Remove or replace the Notary without consent of BOTH parties (Buyer and Seller)
Give instructions to the Notary regarding when to sign or not sign
Influence the Notary's decisions relating to the transaction
Access the Notary's private key under any circumstance
Receive, hold, or control any key in the multisig arrangement

3A.4 Notary's Mandate: The Notary acts under an irrevocable mandate from the parties, formalized through a "Cryptographic Key Deposit Deed" (Acta de Deposito de Clave Criptografica), and is accountable solely to the Buyer and Seller, never to Cuandeoro.

3A.5 Regulatory Classification: This structure ensures that Cuandeoro maintains its NON-CUSTODIAL nature under Regulation (EU) 2023/1114 (MiCA) and applicable Irish legislation. Cuandeoro does not exercise "effective control" over any keys in the multisig system.

3A.6 Notary Directory Disclaimer: The Notary Directory provided by Cuandeoro is purely informational. Inclusion in the directory indicates only that the notary has completed a basic technical verification. Cuandeoro does not recommend, guarantee, or endorse any listed notary. Parties are free to choose any notary of their trust, whether or not included in the directory. Cuandeoro is not a party to the contractual relationship between the parties and the notary.

4. Regulatory Positioning (MiCA)

4.1 Cuandeoro operates in alignment with Regulation (EU) 2023/1114 (MiCA) where applicable.

4.2 The Company does not provide regulated crypto-asset services unless duly authorised by the relevant competent authority.

4.3 Nothing on the website or in any documentation constitutes an offer of regulated financial services or a solicitation to invest.

5

5.1 All information provided by Cuandeoro is for technical, informational and educational purposes only.

5.2 Nothing provided by the Company constitutes:

investment advice,
legal advice,
tax advice,
financial recommendations.

5.3 Any investment decision made by users or third parties is taken solely at their own risk.

6. Limitation of Liability

6.1 To the maximum extent permitted by law, Cuandeoro shall not be liable for:

financial losses,
loss of profits,
loss of digital assets,
technical failures,
smart contract vulnerabilities,
blockchain network failures.

6.3 "As Is" Provision: The software, platform, and all services are provided "AS IS" and "AS AVAILABLE", without warranty of any kind, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, uninterrupted availability, or absence of errors or bugs.

6.4 You acknowledge that holding keys via our interface does not guarantee interface support for all derivative assets or network upgrades. Cuandeoro shall not be liable for any "lost opportunity" claims related to unsupported network events.

7. Intellectual Property

7.1 All content, software, documentation and branding are the exclusive property of Cuandeoro unless otherwise stated.

8. Compliance and User Obligations

8.1 Users must comply with all applicable laws, including anti-money laundering and sanctions regimes.

8.2 Cuandeoro reserves the right to restrict access where legally required.

8.3 User Warranties: By using the platform, you represent and warrant that:

You are not a resident of, or located in, any jurisdiction subject to comprehensive sanctions as listed by the U.S. Office of Foreign Assets Control (OFAC), EU restrictive measures, or A Security Council (including but not limited to Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions, and any other jurisdiction added to such lists);
You are not a Specially Designated National (SDN) or otherwise blocked under OFAC, EU, or A sanctions;
For real estate transactions in the United States, you comply with all applicable state laws including Florida SB 264 restrictions on foreign ownership;
You will provide accurate information and any required affidavits relating to your legal status and eligibility to transact.

8.4 VPN and Location Misrepresentation: You confirm you are not using a VPN, proxy, or similar technology to conceal your true location in order to circumvent geographic restrictions. Access from geo-blocked jurisdictions (including UAE/Dubai) through evasion technologies constitutes a material breach of these Terms and a fraudulent misrepresentation, releasing Cuandeoro from any liability.

9. Data Protection

9.1 Personal data is processed in accordance with applicable data protection law and the Company’s Privacy Policy.

10. Termination

10.1 Cuandeoro may suspend or terminate access to services where required by law or for security reasons.

11. Governing Law and Jurisdiction

These Terms shall be governed by the laws of Ireland.

The courts of Ireland shall have exclusive jurisdiction.