Terms of Service for Dena

Effective Date: July 27, 2026 Last Updated: July 27, 2026

These Terms of Service (“Terms”) govern your access to and use of the Dena mobile application (the “App” or “Service”), provided by Dena Pay (“Dena,” “we,” “us,” or “our”). By downloading, accessing, or using the App, you agree to be bound by these Terms. If you do not agree, do not use the App.

Please also review our Privacy Policy, which describes how we handle information.

0. Current Scope of the Service

As of the Effective Date above, the Service consists solely of self-custodial wallet functionality — holding, sending, and receiving USDC on the Solana blockchain, together with the Relay and account-recovery features described below.

Certain features may be displayed in the App as “Coming Soon” (including, without limitation, fiat deposit/withdrawal via PIX, debit card issuance, or similar integrations). These features are not currently available, are not offered by us, and are not covered by these Terms. Nothing in the App’s description or marketing of a “Coming Soon” feature constitutes an offer, guarantee, or commitment that the feature will launch on any particular timeline, or at all. Before any such feature becomes available, we will publish updated Terms (and, where applicable, an updated Privacy Policy) governing that feature, which you must accept before using it.

1. Eligibility

You must be at least 18 years old and legally capable of entering into a binding contract to use Dena. By using the App, you represent that you meet these requirements and that your use of the App does not violate any law applicable to you, including sanctions, export control, or anti-money-laundering laws in your jurisdiction.

You may not use Dena if you are located in, or a resident of, a country or region subject to comprehensive sanctions, or if you are listed on any restricted-party or denied-persons list.

2. Nature of the Service — Self-Custodial Wallet

Dena is a self-custodial (non-custodial) digital wallet. This is the most important thing to understand before using the App:

• Your private keys are generated and stored on your own device (in secure hardware such as Secure Enclave or Android Keystore) and, where applicable, split across a threshold key scheme you control.
• We never have custody, control, or possession of your digital assets, at any time. We cannot access, freeze, transfer, or recover your funds on your behalf, except through the specific, user-initiated recovery process described in Section 6.
• You are solely responsible for safeguarding your device, your recovery credentials, and any backup materials (such as a written recovery phrase). If you lose access to your keys and cannot complete the recovery process, your funds may be permanently and irrecoverably lost. We have no ability to reverse this.
• Dena is not a bank, broker-dealer, money transmitter, or custodian, and your use of the App does not create a deposit, custodial, or fiduciary relationship between you and us.

3. Blockchain Transactions Are Irreversible and Public

• Transactions you initiate through Dena are broadcast to the Solana blockchain, a public, decentralized, and immutable ledger. Once confirmed, transactions generally cannot be reversed, cancelled, or refunded — by you or by us.
• Your wallet address and transaction history are publicly visible to anyone on the blockchain. We do not control, and cannot remove, publicly recorded on-chain data.
• You are solely responsible for verifying recipient addresses, transaction amounts, and network details before confirming any transaction. Sending assets to an incorrect address, or to an address on an unsupported network, may result in permanent loss.

4. Relay and Gas Sponsorship

Dena operates backend infrastructure (“Relay”) that facilitates the signing and broadcasting of your transactions and may sponsor network (“gas”) fees on your behalf, subject to the fee terms in Section 5.

• The Relay is a facilitator only. It does not hold your assets and cannot independently move your funds — transactions require your own key authorization to execute.
• We may modify, limit, throttle, or discontinue Relay services (including gas sponsorship) at any time, including for security, cost, or regulatory reasons, with or without notice.
• We do not guarantee transaction speed, network confirmation times, or availability of any blockchain network, which depend on factors outside our control (e.g., network congestion, validator behavior, RPC provider uptime).

5. Fees

We may charge fees for certain actions within the App (for example, a one-time activation fee or fees related to network cost recovery). Any applicable fees will be clearly disclosed to you at the time of the relevant transaction, before you confirm it. Fees are non-refundable once a transaction has been confirmed on-chain, except where required by law.

We may change our fee structure at any time; changes will apply prospectively and will be disclosed in-app before you’re charged.

6. Account Recovery

Dena offers an optional recovery mechanism to help you regain access to your wallet if you lose your device, subject to the following:

• Recovery requires verification via your registered recovery email and a mandatory waiting/timelock period, designed to protect you against unauthorized recovery attempts (e.g., if your email is compromised).
• You are responsible for keeping your recovery email account secure and up to date. We cannot complete recovery without your registered email, and we cannot bypass the security timelock, even at your request, except as described in our recovery process documentation.
• The recovery service is provided on a best-efforts basis. We do not guarantee that recovery will always be successful, timely, or available (e.g., in the event of an infrastructure outage affecting our recovery service, or if you no longer control your recovery email).

7. Your Responsibilities

You agree that you will:

• Use the App only for lawful purposes and in compliance with applicable law, including tax, foreign exchange, and anti-money-laundering regulations in your jurisdiction.
• Not use the App to transmit funds derived from, or intended for, illegal activity, including fraud, sanctions evasion, or the financing of terrorism.
• Not attempt to reverse-engineer, decompile, tamper with, or interfere with the App’s security features, including the threshold key or recovery-timelock mechanisms.
• Not use the App in a manner that could disable, overburden, or impair our infrastructure (e.g., abusive automated transaction submission).
• Maintain the confidentiality of any device credentials, recovery materials, or backup phrases, and accept full responsibility for transactions authorized from your device or key set.

We reserve the right to suspend or restrict App functionality (such as Relay access) for accounts we reasonably believe are associated with prohibited activity, though — consistent with our self-custodial design — we cannot seize or freeze your on-chain assets.

8. No Financial, Investment, or Tax Advice

Nothing in the App or communicated by us constitutes financial, investment, legal, or tax advice. Digital assets are volatile and carry significant risk, including the risk of total loss. You should consult independent professional advisors before making financial decisions. Any market data, pricing, or asset information displayed in the App is provided for informational purposes only and may be delayed, inaccurate, or sourced from third parties we do not control.

9. Third-Party Services

The App may rely on or integrate with third-party infrastructure providers (such as blockchain RPC/node providers, email delivery services, or — where applicable — fiat/PIX or card-issuance partners). We are not responsible for the acts, omissions, availability, or terms of third-party services, and your use of any third-party integration may be subject to that provider’s own terms and privacy practices.

10. Intellectual Property

The App, including its design, software, logos, and content (excluding open-source components governed by their own licenses), is owned by Dena Pay or its licensors and is protected by intellectual property laws. We grant you a limited, non-exclusive, non-transferable, revocable license to use the App for your personal, non-commercial use, subject to these Terms. You may not copy, modify, distribute, sell, or lease any part of the App except as permitted by applicable open-source licenses or with our written consent.

11. Disclaimers

THE APP IS PROVIDED “AS IS” AND “AS AVAILABLE,” WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR THAT THE APP WILL BE UNINTERRUPTED, SECURE, OR ERROR-FREE.

WE DO NOT WARRANT THE SECURITY OF ANY BLOCKCHAIN NETWORK, THIRD-PARTY INFRASTRUCTURE, OR THE VALUE OF ANY DIGITAL ASSET. YOU ACKNOWLEDGE THAT DIGITAL ASSET TRANSACTIONS ARE INHERENTLY RISKY AND THAT YOU ASSUME ALL RISK OF LOSS ARISING FROM YOUR USE OF THE APP.

12. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, DENA PAY AND ITS OFFICERS, EMPLOYEES, AND AGENTS WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF FUNDS, DATA, OR DIGITAL ASSETS, ARISING FROM OR RELATED TO YOUR USE OF THE APP — INCLUDING LOSSES RESULTING FROM LOST OR COMPROMISED KEYS, FAILED RECOVERY, INCORRECT TRANSACTIONS, OR THIRD-PARTY INFRASTRUCTURE FAILURES — EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

TO THE EXTENT ANY LIABILITY IS NOT EXCLUDABLE, OUR TOTAL AGGREGATE LIABILITY TO YOU FOR ANY CLAIM ARISING OUT OF THESE TERMS OR YOUR USE OF THE APP WILL NOT EXCEED THE TOTAL FEES YOU PAID US IN THE 12 MONTHS PRECEDING THE CLAIM. IF YOU HAVE NOT PAID US ANY FEES, OUR LIABILITY IS LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

Some jurisdictions do not allow certain liability exclusions or limitations; in those jurisdictions, the above limitations apply only to the extent permitted by law.

13. Indemnification

You agree to indemnify and hold harmless Dena Pay and its officers, employees, and agents from any claims, damages, liabilities, and expenses (including reasonable legal fees) arising from your use of the App, your violation of these Terms, or your violation of any applicable law or third-party rights.

14. Suspension and Termination

We may suspend or terminate your access to the App (including Relay services) at any time, with or without cause or notice, including for suspected violation of these Terms, security concerns, or legal/regulatory requirements. Because Dena is self-custodial, termination of App access does not affect your ownership or control of your on-chain assets or your ability to use your own keys with compatible third-party tools.

You may stop using the App at any time. Sections of these Terms that by their nature should survive termination (including Sections 8, 11, 12, 13, and 16) will survive.

15. Changes to the App and These Terms

We may update the App and these Terms from time to time. If we make material changes, we will notify you through the App or other reasonable means. Your continued use of the App after changes take effect constitutes your acceptance of the revised Terms. If you do not agree to updated Terms, you should stop using the App.

16. Governing Law and Dispute Resolution

These Terms are governed by the laws of the Federative Republic of Brazil, without regard to conflict-of-law principles. Any dispute arising out of or relating to these Terms or the App will be subject to the exclusive jurisdiction of the courts of Brazil, without prejudice to any mandatory consumer-protection venue rules under the Código de Defesa do Consumidor (CDC) that cannot be waived.

17. Export Control and Sanctions Compliance

You may not use the App if you are located in a country subject to a U.S., EU, or UN embargo, or if you are listed on any restricted-party list (e.g., the U.S. Treasury OFAC Specially Designated Nationals list). Certain cryptographic components of the App may be subject to export control laws; you agree to comply with all applicable export and re-export restrictions.

18. Miscellaneous

• Entire Agreement: These Terms, together with our Privacy Policy, constitute the entire agreement between you and Dena Pay regarding the App.
• Severability: If any provision of these Terms is found unenforceable, the remaining provisions will remain in full force.
• No Waiver: Our failure to enforce any right or provision will not be a waiver of that right.
• Assignment: You may not assign these Terms without our written consent; we may assign these Terms in connection with a merger, acquisition, or sale of assets.

19. Contact Us

If you have questions about these Terms, contact us at:

Dena Pay Email: paul@dena-pay.com