Bloquo Inc., a Montana corporation registered with the United States (“U.S.”) Financial Crimes Enforcement Network (“FinCEN”) as a Money Services Business (“MSB”), together with its affiliates, subsidiaries, parents, and related entities (“Bloquo”, “us”, “we”, “our”), is a technology provider that facilitates access to a platform, website, mobile applications, messaging channels, application programming interfaces (“APIs”), and other integrations with third-party platforms, websites, mobile applications, and services (collectively, the “Platform”). Through the Platform, Bloquo enables access to a digital and operational infrastructure that allows users to engage in certain transactions, including, as applicable, cross border payment processing services involving the coordination of the conversion between fiat currencies and digital assets such as stablecoins, in each case through one or more transactional third-party service providers (“TSPs” or “TSPs Partners”). All of the foregoing, together with any services described in the Order Form (as defined in Section 2) and any other related or ancillary products and services that Bloquo may offer from time to time in connection therewith, are collectively referred to herein as the “Services”.
These General Terms and Conditions of Use and Service (“Terms and Conditions”) govern your access to and use of our Services.
The Services are provided to anyone who accesses or uses the Services in accordance with these Terms and Conditions, including but not limited to any persons to which Bloquo may provide access to the Services from time to time (“User,” “Users,” “you,” “your”).
As set forth herein, the Services rely on TSPs (including, without limitation, virtual asset service providers, liquidity providers, custodians, banks, and network infrastructure, including, without limitation, blockchain networks) and their respective systems and networks. Bloquo does not own, operate, or control the systems or networks of such TSPs and, to the maximum extent permitted by applicable Laws (as defined in Section 3 below) and subject to the express limitations set forth in Sections 17 and 18 of these Terms and Conditions, Bloquo is not responsible for any operation, failure, delay, interruption, or other issue attributable to such TSPs and their systems or networks.
BY SIGNING THIS AGREEMENT (ELECTRONICALLY OR OTHERWISE), CLICKING “I AGREE” OR SIMILAR BUTTON OR CHECKBOX, CREATING AN ACCOUNT, OR OTHERWISE USING THE SERVICES, YOU CONFIRM THAT:
(I) YOU AND ANYONE ACCESSING OR USING THE SERVICES THROUGH YOU (INCLUDING, WITHOUT LIMITATION, YOUR AGENTS, CONTRACTORS, CONSULTANTS, OR EMPLOYEES): (A) ARE AT LEAST EIGHTEEN (18) YEARS OF AGE OR HAVE REACHED THE REQUIRED LEGAL AGE IN YOUR OR THEIR JURISDICTION OF RESIDENCE; OR (B) HAVE OBTAINED ALL NECESSARY CONSENTS REQUIRED UNDER APPLICABLE LAWS AND OUR PRIVACY POLICY (“PRIVACY POLICY”); TO ENTER INTO A LEGALLY BINDING CONTRACT WITH US;
(II) YOU AND ANYONE ACCESSING OR USING THE SERVICES THROUGH YOU ARE NOT: (A) LOCATED, ORGANIZED, OR RESIDENT IN ANY JURISDICTION SUBJECT TO COMPREHENSIVE SANCTIONS OR DESIGNATED BY THE FINANCIAL ACTION TASK FORCE (“FATF”) AS A “HIGH-RISK JURISDICTION SUBJECT TO A CALL FOR ACTION”; (B) LISTED ON, OR OWNED OR CONTROLLED (DIRECTLY OR INDIRECTLY) BY ANY PERSON OR ENTITY LISTED ON, ANY SANCTIONS LIST MAINTAINED BY THE US OFFICE OF FOREIGN ASSETS CONTROL’S (“OFAC”), THE UNITED NATIONS (UN”), CANADA, BRAZIL, OR ANY OTHER APPLICABLE SANCTIONS AUTHORITY; OR (C) OTHERWISE PROHIBITED FROM USING THE SERVICES UNDER APPLICABLE LAW;
(III) YOU AND ANYONE ACCESSING OR USING THE SERVICES THROUGH YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THESE TERMS AND CONDITIONS AND THE PRIVACY POLICY; AND
(IV) THESE TERMS AND CONDITIONS BECOME EFFECTIVE AND BINDING ON THE FIRST DATE ON WHICH YOU TAKE ANY OF THE ACTIONS STATED ABOVE.
IMPORTANT: THESE TERMS AND CONDITIONS CONTAIN BINDING ARBITRATION AND A CLASS ACTION WAIVER (SEE SECTION 24).
If you do not agree with these Terms and Conditions, we kindly request you not to access or use the Services.
Subject to these Terms and Conditions, you may register for, or be granted, access to, and use of the Services through an account (“Account”) secured by a username and password (“Account Credentials”).
To create an Account, and/or promptly after its creation, you will be required to complete and go through a due diligence process (“Due Diligence”), including, without limitation, Know Your Customer (“KYC”) or Know Your Business (“KYB”) verifications, as applicable, and any other approval processes that may be required by Bloquo from time to time at its sole discretion.
As part of the Due Diligence, and as applicable depending on whether you are an individual or an entity, you will be required to provide certain information and documentation to Bloquo or the respective third-party KYC/KYB services providers (“KYC/KYB Providers”), in addition to any information collected as indicated in our Privacy Policy. Such information and documentation may include, without limitation, the following:
(a) Entities: (i) articles of incorporation, formation, or other registration documents; (ii) a current certificate of good standing or equivalent document issued by the relevant governmental authority; (iii) a description of the primary business activity or activities and applicable industry classification(s); (iv) a recent bank statement and/or utility bill evidencing the business address (dated within the past sixty (60) days); (v) legal representative’s contact details (full legal name, email address, and mobile phone number); (vi) directors’ contact details (full legal names, email addresses, and mobile phone numbers); (vii) ultimate beneficial owners holding, directly or indirectly, the applicable ownership threshold (“UBOs”), including full legal names, contact details, and ownership information; (viii) any other individuals exercising control over, or delegated authority with respect to, the Account, as applicable; and (ix) any other business, corporate, operational, or organizational information reasonably requested by Bloquo for compliance, risk management, or regulatory purposes.
(b) Individuals (including individual Users, legal representatives, directors, UBOs, delegates, or any other persons exercising control over or authorized access to an Account): (i) full legal name (including all given name(s) and surname(s)); (ii) current residential address; (iii) date of birth; (iv) valid, unexpired government-issued photo identification (e.g., passport, national ID card, or driver’s license); (v) tax identification number or equivalent, where applicable; (vi) recent bank statement and/or utility bill evidencing residential address (dated within the past sixty (60) days); and (vii) any other personal, identification, or verification information reasonably requested by Bloquo or its KYC/KYB Providers for compliance, risk, or regulatory purposes.
Notwithstanding the foregoing, you hereby agree to provide any further supplemental documentation upon Bloquo’s request. You also hereby authorize Bloquo, directly and through third party service providers, to make inquiries and verify that the information provided is accurate, including to request a credit report to the applicable authorities containing your name and address.
Information and documentation provided pursuant to this Section 1 may be collected, used, processed, and retained by Bloquo as part of its Due Diligence, and may also be shared with third parties to the extent necessary for the performance of the Services or to comply with applicable law, including, without limitation, KYC/KYB Providers, TSPs, partners, regulators, governmental authorities, and other service providers or counterparties, in addition to any disclosures or sharing described in our Privacy Policy.
Initial access to and continued use of the Services are subject to eligibility criteria that may be updated from time to time in response to regulatory developments, risk assessments, or internal policies. Such criteria may take into account, without limitation: (i) the User’s jurisdiction of incorporation, residence, or principal place of business; (ii) the nature of the User’s business activities; (iii) the frequency, average value, and characteristics of the User’s intended transactions; (iv) the User’s exposure to sanctions, investigations, or adverse regulatory developments; and (v) the User’s compliance history, including any public records of regulatory violations, administrative proceedings, or imposed sanctions. Bloquo may, at its sole discretion, assign Users to different access tiers or service levels based on the foregoing criteria. Each tier may be subject to distinct limitations, thresholds, verification requirements, or feature availability. Bloquo further reserves the right to modify a User’s assigned tier, impose additional conditions, restrict certain functionalities, or suspend access where deemed necessary for regulatory, risk management, or compliance purposes.
Without limiting our rights under Section 15 (Term and Termination), we reserve the right, at any time and for any reason or no reason in our sole discretion, to deny access to or use of the Services, and to suspend, restrict, terminate, or close any User’s Account, including, without limitation, in the event that a User provides information that cannot be verified, is inaccurate, untrue, incomplete, fails to comply with a request for additional information, or otherwise fails to comply with the registration requirements.
You are fully responsible for maintaining the confidentiality of your Account Credentials, for adopting strong and unique passwords, and for implementing robust authentication measures, including but not limited to managing, requiring, and maintaining multi-factor authentication (“MFA”) as applicable. You agree not to disclose your Account Credentials to any third party. You may not use a third party’s Account or Account Credentials at any time. You may be held liable for any losses incurred by Bloquo, our affiliates, and respective officers, directors, employees, managers, members, shareholders, agents, successors, assigns, and representatives due to someone else’s use of your Account Credentials. You agree to accept responsibility for all activities that occur under your Account Credentials. You agree to notify Bloquo immediately upon becoming aware of any breach of security or unauthorized use of your Account. We further reserve the right to suspend access to the Services, or access to your Accounts, if we believe that Account Credentials may have been compromised or that failing to take such suspension measures may pose a risk to you, us, or any of our third-party providers.
Subject to your compliance with these Terms and Conditions, Bloquo grants you a limited, non-exclusive, non-transferable, non-sublicensable, and freely revocable right to access and use the Platform solely for your internal business purposes (if you are a business entity) or personal use (if you are an individual). Notwithstanding the foregoing, any further use of the Services may be subject to the execution of an order form between you and Bloquo (each, an “Order Form”) and shall be limited to the scope, purposes, and terms set forth therein.
Without limiting our rights under Section 15 (Term and Termination), this right ends immediately if: (i) you violate any provision of these Terms and Conditions, the Privacy Policy, other internal policies, or any applicable Laws (as defined below); (ii) Bloquo exercises its right to terminate these Terms and Conditions at its sole discretion; or (iii) you deactivate your Account and discontinue your use of the Services.
You may use the Services only as permitted by these Terms and Conditions and subject to Section 4 below (Prohibited or Restricted Activities, Persons, and Jurisdictions). You shall not, and shall not permit any other party, to:
(a) Interfere in any manner with the operation of the Services or any component related to the Services, or the hardware and network used to operate the Services;
(b) Rent, lease, lend, sell, sublicense, assign, distribute, publish, transfer, or otherwise make available the Services to any person, including on or in connection with the internet or any time-sharing, service bureau, software as a service, cloud, or other technology or service;
(c) Reverse engineer, disassemble, decompile, decode, adapt, or otherwise attempt to derive or gain access to the source code utilized to provide the Services, or any component related to the Services, in whole or in part;
(d) Bypass or breach any security device or protection used by the Services or access or use the Services except through your own valid access credentials as a User;
(e) Input, upload, transmit, or otherwise provide to or through the Services any information or materials that are unlawful or injurious, or contain, transmit, or activate any Harmful Code. For purposes of these Terms and Conditions, “Harmful Code” shall mean any software, hardware, or other technology, device, or means, including any virus, worm, malware, or other malicious computer code, the purpose or effect of which is to: (i) permit unauthorized access to, or to destroy, disrupt, disable, distort, or otherwise harm or impede in any manner any (x) computer, software, firmware, hardware, system, or network; or (y) any application or function of any of the foregoing or the security, integrity, confidentiality, or use of any data processed thereby; or (ii) prevent any User from accessing or using the Services as intended by these Terms and Conditions;
(f) Damage, destroy, disrupt, disable, impair, interfere with, or otherwise impede or harm in any manner the Services, in whole or in part;
(g) Remove, delete, alter, or obscure any trademarks, specifications, documentation, warranties, or disclaimers, or any copyright, trademark, patent, or other Intellectual Property Rights (as defined in Section 10) or proprietary rights notices from any Services, including any copy thereof;
(h) Access or use the Services in any manner or for any purpose that infringes, misappropriates, or otherwise violates any Intellectual Property Right or other right of any third party (including by any unauthorized access to, misappropriation, use, alteration, destruction, or disclosure of the data relating to any User or other individual), or that violates any applicable statute, law, ordinance, regulation, rule, code, order, constitution, treaty, common law, judgment, decree, or other requirement of any federal, state, local, or foreign government or political subdivision thereof, or any arbitrator, court, or tribunal of competent jurisdiction (“Laws”);
(i) Access or use the Services for purposes of competitive analysis of the Services, the development, provision, or use of a competing software service or product, or any other purpose that is to Bloquo’s detriment or commercial disadvantage;
(j) Modify, copy, create, or make derivative works or improvements of the Services, documentation provided by Bloquo, and any other Bloquo Technology (as defined in Section 10) in connection therewith;
(k) Engage in same-name “me-to-me” transfers intended to obfuscate fund provenance, or as otherwise restricted by Bloquo’s internal policies or applicable Laws; or
(l) Otherwise use the Services in any manner that exceeds the scope of authorized use permitted by these Terms and Conditions and the applicable Order Form.
The Services may only be used for legitimate purposes and may not be used for any unlawful or prohibited purpose, including violations of anti-money laundering (“AML”) and counter-terrorism financing (“CFT”), anti-bribery/anti-corruption, sanctions, or other applicable financial crime Laws. You are prohibited from using, exporting, or re-exporting (directly or indirectly) the Services for, to, or in connection with any person, entity, organization (formal or informal), or country that is blocked or sanctioned by the US or any other applicable jurisdictional law, including those identified on Brazil’s Lists of Non-Cooperative Jurisdictions, Canadian Sanctions, the UN Security Council Consolidated List, the OFAC’s various sanctions lists, and listed as High-Risk Jurisdictions subject to a Call for Action or blacklists as indicated by the FATF such as North Korea, Iran, and Myanmar, or, in the case of exporting or re-exporting, to any other relevant jurisdiction that requires any export license or other governmental approval at the time of export without first obtaining such license or approval. You acknowledge that lists and classifications issued by the UN, OFAC, and FATF, are dynamic and may change, update, or be revoked at any time without prior notice. Bloquo will continuously monitor these publications and may update this document as necessary to ensure compliance with applicable regulations.
You are also prohibited from allowing non-affiliated third parties to use or access the Services, which includes prohibiting you from using or accessing the Services on behalf of, or for the benefit of, anyone other than yourself (e.g., any non-affiliated third parties).
In addition to the prohibited jurisdictions and persons described above, express prior written authorization from Bloquo is required before using the Services in connection with: (ii) any person, entity, or transaction involving jurisdictions designated by the FATF as “Jurisdictions Under Increased Monitoring”; (ii) any Politically Exposed Person (“PEP”), including any current or former senior government official, senior executive of a state-owned enterprise, political party official, candidate for public office, or any immediate family member, close associate, or entity directly or indirectly owned or controlled by such person; or (iii) any other jurisdiction or person identified by Bloquo as presenting elevated compliance risk based on factors such as weak AML/CFT frameworks, ongoing FATF monitoring, heightened corruption indices, or other regulatory or reputational concerns (collectively, “Restricted Categories”). Bloquo reserves the right to determine and update the Restricted Categories from time to time in its sole discretion to reflect changes in FATF designations, regulatory developments, or internal risk assessments. Any authorization granted by Bloquo with respect to Restricted Categories may be subject to enhanced Due Diligence, additional documentation requirements, transaction limitations, or other conditions as Bloquo may determine in its sole discretion.
Furthermore, you acknowledge and agree that you, your representatives, or any legally authorized third parties, are expressly prohibited or restricted, as applicable, from using the Services in connection with any of the activities, items, or services identified in Exhibit A, attached hereto.
Bloquo may, from time to time, and in its sole discretion, designate, amend, or remove any other category as prohibited or restricted under this Section 4 and Exhibit A.
Without limiting our rights under Sections 1 (Service Access and Accounts) and 15 (Term and Termination), if Bloquo determines that User has used the Services in connection with any person, activity, item, or service prohibited or restricted under this Section 4, Bloquo may, at its sole discretion, decide the temporary or permanent suspension of Services, blocking of pending or processing transactions, fund retention for investigation and compliance analysis, Account Credential and Account deactivation, charging additional fees for investigation and remediation costs, inclusion in internal restriction lists and sharing with partners, giving notice to competent authorities about suspicious or illicit activities, cooperating with regulatory, police, or judicial investigations, initiate legal action for damage compensation and application of contractual penalties. Furthermore, if Bloquo suspects that the User’s Account has been used for an unauthorized, illegal, or criminal purpose, or any other activity otherwise prohibited under this Section 4, User expressly authorizes Bloquo to share information about User, User’s Account, access to the Services, and transactions with the applicable law enforcement and regulatory agencies.
In addition to providing access to the Platform, Bloquo may provide other Services as described in, and subject to, the applicable Order Form. To the extent required by applicable Laws, such Services are provided in accordance with Bloquo’s registration as an MSB with FinCEN, and applicable U.S. federal laws and regulations, including, the Bank Secrecy Act, anti-money laundering requirements, and OFAC administered sanctions programs.
Notwithstanding any other applicable exemption under U.S. federal or state law, in certain transactions facilitated through the Platform, Bloquo may act as the User's (i.e., the payee’s) agent for the purpose of collecting payments or funds from payors. Where Bloquo acts as the User's agent in this capacity, pursuant to these Terms and Conditions (which constitute a preexisting written agreement), delivery of funds to Bloquo will be deemed to satisfy the payor's obligation to the User in full, and Bloquo will promptly notify the User upon receipt of such funds. The User agrees to credit the payor’s account (or otherwise fulfill its obligations) immediately upon receiving such confirmation from Bloquo.
As contemplated by these Terms and Conditions, the Services rely on TSPs (including, without limitation, virtual asset service providers, liquidity providers, custodians, banks, and network infrastructure, including, without limitation, blockchain networks) and their respective systems and networks. Bloquo does not own, operate, or control the systems or networks of such TSPs and, to the maximum extent permitted by applicable Laws and in accordance with these Terms and Conditions, Bloquo is not responsible for any operation, failure, delay, interruption, or other issue attributable to such TSPs and their systems or networks. For clarity, Bloquo does not accept, hold, convert, transmit, or otherwise control funds or digital assets beyond its role as technology provider and registered MSB status. Provided that TSPs custody your funds or value, such TSPs are solely responsible for the same, and Bloquo shall not be liable for any fraud, misdelivery, error, omission, misdisbursement, non-receipt, or other improper or wrongful disposition of funds or value arising from or caused by the actions or omissions of such TSPs.
For purposes of the foregoing, Bloquo may enter into agreements with TSPs. User is not a third-party beneficiary of these agreements. However, some TSPs may require User to enter into a direct agreement with such TSP. If User is required to enter into such an agreement and declines to do so, Bloquo may, without limitation of its rights under Sections 1, 4, and 15, suspend, restrict, or terminate User’s Account or access to the Services.
Without limiting our rights under Sections 17 (Disclaimers) and 18 (Limitation of Liability), and to the maximum extent permitted by applicable Laws, Bloquo shall not be liable for any fraud, misdelivery, error, omission, misdisbursement, non-receipt, or other improper or wrongful disposition of funds or value arising from or caused by the actions or omissions of any User, sender, recipient, counterparty, or third party, including without limitation, TSPs. Bloquo will rely on transaction instructions provided by the User and will use commercially reasonable efforts and methods to facilitate the transactions with such instructions; provided, however, that Bloquo shall not be responsible for any loss, error, or delay resulting from inaccurate, incomplete, or incorrect instructions, or from the actions or omissions of any sender, recipient, counterparty, or third-party service provider, including without limitation, TSPs.
User has an independent obligation to comply with all applicable Laws related to the Services. User expressly acknowledges and agrees it is assuming the risk of its non-compliance with the rules governing the processing of transactions in connection with the Services.
Specifically, User acknowledges and agrees that the User is responsible for all reversed or failed transactions, and for any associated fees, claims, fines, penalties, losses, or other liabilities incurred by Bloquo, our TSPs Partners or other Bloquo Users arising from User’s use of User’s Account or the Services or any breach of these Terms and Conditions. Without limiting the foregoing, User agrees to reimburse Bloquo or our TSPs Partners for any liability relating to a transaction that: (i) is reversed in accordance with Bloquo or its TSPs Partners’ risk management policies; (ii) is reversed in accordance with applicable Laws, (iii) fails due to User’s error; (iv) fails due to the provision of inaccurate information; or (v) is cancelled or rejected by the User or the recipient or sender, or the respective system or network (each, a “Reversal”).
User will be able to access information regarding their transaction history and Account balances. Upon request, Bloquo shall make such information reasonably available to User, subject to any limitations of the Services in accordance with these Terms and Conditions.
Bloquo reserves the right to modify, update, and discontinue any features or functionalities of the Services at any time, at Bloquo’s sole discretion, and without prior notice to User (“Changes to the Services”). The Changes to the Services may include, but are not limited to, enhancements, adjustments, or the removal of specific features. Bloquo is committed to continually improving the Services and User acknowledges that Changes to the Services are necessary to maintain quality and innovation.
User irrevocably authorizes Bloquo to transmit User transaction instructions to the applicable TSPs and authorizes such TSPs to perform any cross-border, settlement, conversion, custody, transmission, or other actions necessary to execute the transaction, in each case in accordance with the applicable agreements between Bloquo and such TSP and applicable Laws. User’s authorization permits Bloquo and its TSPs to generate a paper draft or electronic transfer order to process each transaction that User authorizes. User acknowledges that transaction instructions, once transmitted, may be irreversible and cannot be cancelled or modified.
Specifically, User authorizes the applicable TSPs to initiate electronic entries to each account for which User inputs or enables the retrieval of the routing number and account number, card number or applicable information in order to complete a transaction using the Platform, including without limitation any software, website, mobile application, messaging channels, API integrations, and integrations with third-party websites and mobile applications, or any other ingress point, and to initiate adjustments for any transactions credited or debited in error.
User agrees that its use of the Platform constitutes User's authorization for Bloquo to retain and log its transaction authorization requests and that Bloquo’s online logs will be evidence of such transaction authorization.
User’s authorization will remain in full force and effect until User notifies Bloquo that User revokes such authorization by contacting Bloquo in accordance with instructions provided by Bloquo from time to time or by closing User’s Account. User understands that Bloquo requires a reasonable time to act on its revocation, not to exceed ten (10) business days.
Each transaction request must be supported by commercially reasonable and compliant documentation evidencing the lawful origin of the relevant funds or resources, which may include, without limitation, commercial contracts, invoices, payment receipts, tax filings, and other supporting records requested by Bloquo. Such documentation shall be provided promptly upon request and, in any event, within the timeframe specified by Bloquo. All documentation shall form part of the transaction record and may be retained, reviewed, and disclosed by Bloquo to competent authorities or third parties, as required or permitted by applicable Laws.
For purposes of these Terms and Conditions, “Fees” means the fees to be paid by User to Bloquo for use of the Services, as specified in the applicable Order Form or otherwise made available to User through the Platform, pricing schedules, quotes, dashboards, statements, confirmations, or other commercial communications. Unless expressly stated otherwise, Fees do not include fees, charges, or costs imposed directly by TSPs pursuant to a separate agreement between User and such TSP.
All Fees are non-refundable except to the extent required by applicable Laws. Your right to access or use the Services hereunder is subject to the payment of Fees.
In accordance with Section 8 (Deductions, Set-Off, and Collection Rights), Fees shall be collected directly by Bloquo, or its designated agents, in connection with the transaction, and may be deducted or withheld from the amounts associated with such transaction.
Unless otherwise stated, Fees do not include any direct or indirect local, state, provincial, federal, or foreign taxes, levies, duties, or similar governmental assessments of any nature, including, without limitation, value-added, goods and services, harmonized, use or withholding taxes (collectively, “Taxes”). You are solely responsible for determining, collecting, withholding, reporting and remitting Taxes. Bloquo will not determine whether Taxes apply, nor calculate, collect, report, or remit Taxes to any tax authority arising from your use of the Services. If Bloquo has the legal obligation to pay or collect Taxes for which you are responsible under this Section 7, the appropriate amount shall be invoiced to and paid by you, unless you provide Bloquo with a valid tax exemption certificate authorized by the appropriate taxing authority. Nothing in this Section 7 limits Bloquo’s right to collect or remit Taxes where required by Law.
Bloquo reserves the right to increase Fees in its sole discretion without notice (“Fee Increase”). By continuing to use the Services, User consents to the Fee Increase. To withdraw its consent, User must close its Account in accordance with these Terms and Conditions.
To the extent permitted by applicable Laws, Bloquo may deduct any Fees, Reversal-related costs or other charges you owe to Bloquo under these Terms and Conditions and the applicable Order Form directly from amounts associated with a transaction or otherwise available through the Platform, and may set off such amounts against any balance in your Account or against any amounts due to you. Unless expressly stated otherwise in the applicable Order Form, all charges are deducted first from the transaction funds and thereafter from your Account.
If the amounts available are insufficient to satisfy amounts owed to Bloquo, Bloquo may, directly or through its applicable TSPs, collect the outstanding balance from any funding source associated with User’s Account. Your failure to pay in full amounts that you owe Bloquo on demand will constitute a material breach of these Terms and Conditions.
User will be liable for Bloquo’s costs associated with collection in addition to the amount owed, including, without limitation, attorneys’ fees and expenses, collection agency fees, and interest at the lesser of 1.5% per month or the highest rate permitted by applicable Laws. In its discretion, Bloquo may make appropriate reports to credit reporting agencies and law enforcement authorities and cooperate with them in any resulting investigation or prosecution.
In addition to any other obligations set forth in these Terms and Conditions, User is solely responsible for ensuring that its activities and operations comply fully with all applicable Laws. This non-delegable responsibility includes, but is not limited to, the following aspects, as applicable:
(a) Maintaining the accuracy, quality, integrity, legality, reliability, and appropriateness of all User Data, including its content and use;
(b) Obtaining, maintaining, and timely renewing all licenses, registrations, authorizations, and approvals necessary for conducting its respective activities and for using the Services;
(c) Ensuring that all operations conducted through Bloquo and/or the Services, are in compliance with AML and CFT regulations; personal data protection norms; foreign exchange and capital control rules; specific financial sector regulations; economic sanctions and commercial embargoes;
(d) Monitoring suspicious activity, including but not limited to implementing and maintaining alert systems to promptly identify and respond to suspicious or anomalous activities, in addition to implementing and maintaining rigorous controls to preserve the confidentiality, integrity, and availability of sensitive information under its custody, including personal data of third parties, confidential commercial information, and Account Credentials;
(e) Maintaining organized and updated records of internal compliance policies, procedures, operational procedures, transaction records, due diligence evidence, and any other documents that prove compliance with its obligations, as applicable. These documents must be made available to Bloquo whenever requested, within a maximum period of five (5) business days;
(f) Immediately communicate to Bloquo any relevant security incidents, including but not limited to “phishing” attempts, and any breach of security or unauthorized use of your Account or Account Credentials, as well as suspicions of irregular activity, ongoing regulatory investigations, changes in User’s compliance status, or any event that may impact Services provision;
(g) Adopting and maintaining appropriate device and network protection measures, including ensuring that all operating systems, browsers, and software used in connection with the Services are always updated with the latest security patches, and acknowledging that you are fully responsible for maintaining the security of your equipment and systems; and
(h) Ensuring the legality and compliance of its international operations in all involved jurisdictions, as applicable, including, but not limited to conducting adequate classification of products, services, or flows according to required nomenclatures; preparing and presenting all fiscal, customs, and regulatory documents required for international operations; calculating, collecting, and paying all taxes, fees, and charges levied on its operations; and rigorously observing all applicable foreign exchange and capital control rules. Bloquo assumes no responsibility for violations committed by the User before any fiscal, regulatory, customs, or foreign exchange authorities.
For purposes of these Terms and Conditions, “Intellectual Property Rights” means any and all registered and unregistered rights granted, applied for, or otherwise now or hereafter in existence under or related to any patent, copyright, trademark, trade secret, database protection, or other intellectual property rights laws, and all similar or equivalent rights or forms of protection, in any part of the world.
Furthermore, “Bloquo Technology” means the software, algorithms, models, and other technologies used to provide the Services, including, without limitation, software, the Platform, a website, a mobile application, messaging channels, API integrations, and any modifications, enhancements, or derivative works thereof, whether now existing or hereafter developed, and all Bloquo proprietary information and technology, used by Bloquo or provided to you in connection with the Services.
(a) Intellectual Property Rights. Except as expressly provided in these Terms and Conditions, you are not granted any right, title, or interest in or to (including any license under) any Intellectual Property Rights in or relating to the Services, including, without limitation, Bloquo Technology, or any of the materials provided therein, whether expressly, by implication, estoppel, or otherwise. All right, title, and interest in and to the Services, including, without limitation, the Bloquo Technology, social media pages, documentation provided by Bloquo, and any other materials in connection therewith, are and will remain with Bloquo or Bloquo’s licensors or providers, as applicable. Bloquo’s intellectual property includes, but is not limited to, any and all patents, trademarks, copyrights, logos, images, illustrations, databases, graphics, sounds, and videos. You may not copy, distribute, broadcast, display, sell, license, or otherwise use Bloquo’s intellectual property, either in whole or in part, without written consent from Bloquo.
(b) Bloquo Technology. You acknowledge that Bloquo retains all rights, title, and interest in and to the Services, including, without limitation, Bloquo Technology, and any other materials in connection therewith, and that Bloquo Technology is protected by Intellectual Property Rights owned by or licensed to Bloquo.
(c) User Feedback. You hereby grant Bloquo a royalty-free, worldwide, transferable, sublicensable, irrevocable, perpetual license to use or incorporate into the Services and Bloquo Technology any suggestions, enhancement requests, recommendations, or other feedback provided by you relating to the Services and Bloquo Technology. Bloquo shall not identify you as the source of any such feedback.
(d) User Data. Subject to applicable Laws, the Privacy Policy, and the rights and permissions granted to Bloquo under these Terms and Conditions, Users retain all right, title, and interest in and to all information, data, and other content, in any form or medium, that is contributed by, or collected, downloaded, or otherwise received, directly or indirectly, from Users in their individual capacity or otherwise by or through the Services (“User Data”). Users hereby irrevocably grant to Bloquo, its personnel and subcontractors, including, without limitation, TSPs, a non-exclusive, worldwide, royalty-free, fully paid-up, transferable, and sublicensable license to: (i) access and use your User Data to enforce these Terms and Conditions and provide, improve, and expand the Services, subject to the Privacy Policy; and (ii) create, reproduce, and use aggregated, de-identified, or otherwise anonymous information derived from User Data for the purposes of operating, maintaining, improving, and expanding the Services, including, without limitation, to compile statistical information related to the provision and operation of the Services, as well as developing and offering new features, technologies, services, products, and lines of business. Bloquo will own all aggregated and de-identified data and will not attempt to re-identify it. Users represent and warrant that they have all necessary rights to grant Bloquo the foregoing licenses.
(e) Performance Data. Bloquo retains all right, title, and interest in and to system-generated technical information, such as server logs, usage metadata, and telemetry, captured automatically by the Services’ analytics tools to measure its access patterns, functionality, efficacy, reliability, and accuracy (“Performance Data”), excluding personally identifiable information, and may use the Performance Data for any lawful purpose.
User Data is hosted under industry-standard physical, technical, and logical security controls. If we become aware of any unauthorized access, disclosure, or use involving User Data or Account Credentials (“Security Breach”), we will promptly notify you and take appropriate actions.
Although Bloquo uses reasonable security measures, no system is perfectly secure. To the fullest extent permitted by Law, Bloquo shall not be liable for any Security Breaches.
We will not use or disclose User Data except as allowed in these Terms and Conditions, as described in the Privacy Policy, or as required by applicable Laws.
In providing the Services, Bloquo collects, analyzes, and relays information generated in connection with transactions to and from Users. User authorizes Bloquo to provide such information to the TSPs. TSPs may use this information to perform their obligations under applicable agreements with Bloquo, to operate and promote their respective systems or networks, to perform analytics and create reports, to prevent fraud, and for any other lawful purpose.
Personal data is handled under the Privacy Policy available at (“Privacy Policy”) and applicable Laws. You acknowledge that by using the Services, you have reviewed and agreed to the Privacy Policy. The Privacy Policy is part of these Terms and Conditions.
The Services, including but not limited to the Bloquo Technology and any other materials in connection therewith, or any other products or services that Bloquo makes available, may contain links to websites or applications controlled by parties other than Bloquo (“Third Party Content”). Bloquo is not responsible for and does not endorse or accept any responsibility for the availability, contents, products, services, or use of any Third Party Content, any website or application accessed from a Third Party Content, or any changes or updates to such websites or applications. Bloquo makes no guarantees about the content or quality of the products or services provided by such websites or applications. Links are for convenience only and the inclusion of any link does not imply endorsement by Bloquo of the Third Party Content.
Additionally, some features and functions may require connecting to third party platforms (“Connected Accounts”). By connecting a third party platform: (i) you represent and warrant that you are entitled to disclose any log-in information provided by you in connection therewith (if applicable) and/or to grant Bloquo access to such Connected Accounts; (ii) you represent and warrant that it is in good standing with respect to such Connected Accounts; and (iii) you acknowledge that Bloquo may access Connected Account data so that it may be used as allowed in these Terms and Conditions and the Privacy Policy. Availability and uptime of Connected Accounts are controlled by their providers. Bloquo will have no liability for any unavailability of any Connected Account, or any third party provider’s decision to discontinue, suspend, or terminate any Connected Account.
Bloquo may offer an API to retrieve information from or submit requests to Bloquo. If User uses such an API to develop applications and integrate the Services into its website or mobile application, User shall ensure its end users agree to terms no less protective than these Terms and Conditions.
These Terms and Conditions are effective as of the date you either sign this agreement (electronically or otherwise), click “I Agree” or similar button or checkbox, create an Account, or otherwise first access or use the Services, and will remain in effect until: (i) you violate any provision of these Terms and Conditions, the Privacy Policy, other internal policies, or applicable Laws, in which case your right to access and use the Services and these Terms and Conditions will automatically terminate, without any resulting obligation or liability of Bloquo; (ii) to the extent permitted by applicable Laws, Bloquo exercises its reserved right to terminate these Terms and Conditions, or to suspend or revoke your access to or use of the Services, for any other reason or no reason at all, in its sole discretion, at any time, temporarily or permanently, without prior notice, and without any resulting obligation or liability to Bloquo; (iii) you deactivate your Account and discontinue your use of the Services; or (iv) the expiration of your relationship with Bloquo.
In light of the foregoing and other sections of these Terms and Conditions, Bloquo reserves the right to modify or discontinue the Services at any time (including by limiting or discontinuing certain features of the Services), temporarily or permanently, without prior notice. Bloquo will have no liability for any change to the Services or any suspension or termination of your access to or use of the Services pursuant to these Terms and Conditions.
Any termination of these Terms and Conditions does not relieve User of any obligations to pay Fees and other charges accrued prior to the termination and any other amounts owed by User to Bloquo.
Upon termination of these Terms and Conditions: (i) your access and User rights of the Services will terminate and you must immediately cease all access and use of the Services; (ii) you will no longer be authorized to access your Account or the Services; (iii) any pending transactions will be canceled, and any available User funds at the time of termination will be paid out to User, less any applicable Fees and charges owed to Bloquo, according to a payout schedule to be set by Bloquo upon its reasonable discretion, assuming all payout-related authentication requirements have been fulfilled; and (iv) any provision that is reasonably necessary to accomplish or enforce the purpose of these Terms and Conditions shall survive and remain in effect in accordance with its terms, including, without limitation, Sections 7, 8, 10, 13, 16, 17, 18, 19, 23, 24, 25, 26, and 31.
Following termination, Bloquo may retain, delete, or otherwise process User Data in accordance with applicable Laws and the Privacy Policy. To the extent required or permitted by applicable Laws, Bloquo may retain User Data for legitimate business, compliance, or regulatory purposes. Notwithstanding the foregoing, upon User’s reasonable request, and subject to applicable law and technical, security, or contractual constraints, Bloquo may assist with the export or deletion of User Data.
(a) Bloquo represents and warrants that, as of the date hereof and to Bloquo’s actual knowledge: (i) it has the full right, power, legal capacity and authority to perform its obligations under these Terms and Conditions, and by entering into these Terms and Conditions, it will not conflict with, or breach the terms, conditions or provisions of, or default under any other agreement to which it is a party; (ii) there is no action, suit or proceeding at law or in equity now pending or, to its knowledge, threatened by or against or affecting it which would substantially impair its right to perform the Services as contemplated herein; (iii) in connection with the performance of its obligations under these Terms and Conditions, it conducts its business in material compliance with applicable Laws; and (vi) the Services will not infringe the intellectual property rights of any person in any jurisdiction in which the Services are offered.
(b) User represents, warrants and undertakes that: (i) it has the full right, power, legal capacity and authority to perform its obligations under these Terms and Conditions, and by entering into these Terms and Conditions, it will not conflict with, or breach the terms, conditions or provisions of, or default under any other agreement to which it is a party; (ii) it has reviewed and agree to the Privacy Policy; (iii) its registration information is accurate and complete, and it will update its Account information to ensure it remains current; (iv) it is not listed on, nor owned or controlled (directly or indirectly) by any person or entity listed on, any sanctions list administered or enforced by OFAC, the UN, Canada, Brazil, or any other applicable sanctions authority; (v) it is not located, organized, or resident in a jurisdiction subject to comprehensive sanctions or designated by the FATF as a “High-Risk Jurisdiction subject to a Call for Action” or a “Jurisdiction Under Increased Monitoring”; (vi) there is no action, suit or proceeding at law or in equity now pending or, to its knowledge, threatened by or against or affecting it which would substantially impair its right to carry on its activity or business as contemplated herein or adversely affect its financial condition or operations; (vii) it complies and shall continue to comply with all applicable Laws, regulations and any and all directives, standards and/or guidelines of any applicable regulatory, governmental or other authority, relating to its obligations pursuant to these Terms and Conditions, and it will not use the Services in violation of any applicable export control, sanctions, AML/CFT, anti-bribery or anti-corruption Laws; (viii) all funds or assets made available or otherwise used in connection with the Services have a lawful origin, are derived from legitimate activities, and are used in full compliance with applicable Laws; (ix) it verifies the identity of its transaction counterparties and that no counterparty to any transaction engages in any activity prohibited under Section 4 (Prohibited Activities) or otherwise uses the Services in violation of these Terms and Conditions or applicable Laws; (x) in undertaking its obligations pursuant to these Terms and Conditions, it will exercise at least the same degree of competence and professionalism which would reasonably and ordinarily be expected from a skilled and experienced operator engaged in the same type of activity or business as User under the same or similar circumstances, but in no event with less than reasonable care; and (xi) all transactions will be made only in Users’ name, from a financial account held in Users’ name, and under Users’ control.
(c) Bloquo’s warranties do not apply and will become null and void if User breaches these Terms and Conditions, if User uses unsupported environments, modifies or damages the Services, or misuses them, including any use of the Services other than as specified in these Terms and Conditions or otherwise expressly authorized by Bloquo in writing. User’s remedy for Bloquo’s uncured breach of its warranties is to terminate these Terms and Conditions.
THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE,” WITH ALL FAULTS AND DEFECTS, WITHOUT REPRESENTATION OR WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY. USE OF THE SERVICES IS AT YOUR OWN RISK. BLOQUO, OUR TSPs PARTNERS, AND OUR AND THEIR RESPECTIVE AFFILIATES, OFFICERS, DIRECTORS, AGENTS, EMPLOYEES, AND SUPPLIERS, SPECIFICALLY DISCLAIM ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. NEITHER BLOQUO NOR OUR TSPs PARTNERS REPRESENTS OR WARRANTS THAT THE SERVICES WILL MEET YOUR REQUIREMENTS, BE CONTINUOUS, UNINTERRUPTED, SECURE, TIMELY, OR ERROR-FREE, OR THAT DEFECTS WILL BE CORRECTED. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM BLOQUO WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED HEREIN. NEITHER BLOQUO NOR OUR TSPs PARTNERS SHALL BE RESPONSIBLE FOR ANY SERVICE INTERRUPTIONS OR SYSTEM FAILURES THAT MAY AFFECT THE PROCESSING, COMPLETION, OR SETTLEMENT OF TRANSACTIONS. THIS DISCLAIMER OF WARRANTY SECTION SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.
IN ADDITION TO THE LIMITATIONS OF LIABILITY SET FORTH IN SECTION 18, IN NO EVENT WILL BLOQUO AND OUR AFFILIATES, OFFICERS, DIRECTORS, AGENTS, EMPLOYEES, AND SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY, SPECIAL, OR PUNITIVE DAMAGES ARISING OUT OF, OR IN CONNECTION WITH, THE USE OF OR RELIANCE ON THE SERVICES. BY USING THE SERVICES, USER EXPRESSLY ACKNOWLEDGES AND ACCEPTS THESE RISKS AND LIMITATIONS.
BLOQUO MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD PARTY THROUGH THE SERVICES OR ANY HYPERLINKED WEBSITE OR SERVICE, OR FEATURED IN ANY BANNER OR OTHER ADVERTISING, AND BLOQUO WILL NOT BE A PARTY TO, OR INVOLVED IN, MONITORING ANY TRANSACTION BETWEEN USER AND THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES.
BLOQUO IS A TECHNOLOGY PROVIDER AND DOES NOT ITSELF ACCEPT, HOLD, CONVERT, TRANSMIT, OR OTHERWISE CONTROL FUNDS OR DIGITAL ASSETS FOR ITS OWN ACCOUNT OR ON BEHALF OF USERS IN A MANNER THAT CONSTITUTES MONEY TRANSMISSION UNDER APPLICABLE U.S. FEDERAL OR STATE LAWS BEYOND ITS REGISTERED MSB STATUS. WHERE APPLICABLE (AND SUBJECT TO THE SPECIFIC FACTS OF EACH TRANSACTION), BLOQUO MAY ACT IN A LIMITED FACILITATION, INTERMEDIARY, OR AGENT-OF-THE-PAYEE CAPACITY SOLELY TO ENABLE CONNECTIONS BETWEEN USERS AND TSPs, AS APPLICABLE. NOTHING IN THESE TERMS AND CONDITIONS SHALL BE CONSTRUED AS A REPRESENTATION, ADMISSION, OR ACKNOWLEDGMENT THAT BLOQUO ENGAGES IN MONEY TRANSMISSION OR ANY SIMILAR REGULATED ACTIVITY BEYOND ITS REGISTERED MSB STATUS AND AS EXPRESSLY DESCRIBED HEREIN.
TO THE FULLEST EXTENT PERMITTED UNDER APPLICABLE LAW: IN NO EVENT WILL BLOQUO OR ITS AFFILIATES, OR ANY OF ITS OR THEIR RESPECTIVE LICENSORS, SUBCONTRACTORS, OR SERVICE PROVIDERS, BE LIABLE TO YOU, ANY USER, OR ANY THIRD PARTY FOR ANY USE, INTERRUPTION, DELAY, OR INABILITY TO USE THE SERVICES; LOST REVENUES OR PROFITS; DELAYS, INTERRUPTION, OR LOSS OF SERVICES, BUSINESS, OR GOODWILL; LOSS OR CORRUPTION OF DATA; LOSS RESULTING FROM SYSTEM OR SYSTEM SERVICE FAILURE, MALFUNCTION, OR SHUTDOWN; FAILURE TO ACCURATELY TRANSFER, READ, OR TRANSMIT INFORMATION; FAILURE TO UPDATE OR PROVIDE CORRECT INFORMATION; SYSTEM INCOMPATIBILITY OR PROVISION OF INCORRECT COMPATIBILITY INFORMATION; OR BREACHES IN SYSTEM SECURITY; OR FOR ANY DECISION, ACTION, OR OMISSION BY ANY USER THAT IS BASED ON, ARISES OUT OR RELATES IN ANY WAY TO THE USE OR NON-USE OF THE SERVICES, BLOQUO TECHNOLOGY, AND ANY OTHER MATERIALS IN CONNECTION THEREWITH; OR FOR ANY DIRECT, INDIRECT, PUNITIVE, EXEMPLARY, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, (INCLUDING ATTORNEYS’ FEES AND ALL RELATED COSTS AND EXPENSES OF LITIGATION AND ARBITRATION, OR AT TRIAL OR ON APPEAL, IF ANY, WHETHER OR NOT LITIGATION OR ARBITRATION IS INSTITUTED), WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE, OR OTHER TORTIOUS ACTION, OR ARISING OUT OF OR IN CONNECTION WITH THESE TERMS AND CONDITIONS, INCLUDING WITHOUT LIMITATION ANY CLAIM FOR PERSONAL INJURY OR PROPERTY DAMAGE, ARISING FROM THESE TERMS AND CONDITIONS AND ANY VIOLATION BY YOU OF ANY FEDERAL, STATE, OR LOCAL LAWS, STATUTES, RULES, OR REGULATIONS, REGARDLESS OF WHETHER SUCH DAMAGES WERE FORESEEABLE AND WHETHER OR NOT BLOQUO WAS PREVIOUSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. WITHOUT LIMITING THE FOREGOING, WE ARE NOT LIABLE TO YOU FOR CONSEQUENTIAL, INDIRECT, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES, LOST PROFITS, OR LOST REVENUE ARISING FROM, OR RELATED TO, YOUR USE OF OR INABILITY TO USE ANY AND ALL BLOQUO SERVICES OR TECHNOLOGY, INCLUDING BUT NOT LIMITED TO THE PLATFORM, REPUTATIONAL HARM, PHYSICAL INJURY OR PROPERTY DAMAGE, OR ANY OTHER LOSSES OR HARM ARISING FROM OR RELATED TO YOUR RELATIONSHIP WITH BLOQUO, BLOQUO SERVICES OR TECHNOLOGY, OR THESE TERMS AND CONDITIONS, WHETHER OR NOT WE WERE ADVISED OF THEIR POSSIBILITY BY YOU OR ANY THIRD PARTY. EXCEPT AS PROHIBITED BY LAW, IF THERE IS LIABILITY FOUND ON THE PART OF BLOQUO, IT WILL BE LIMITED TO THE LESSER AMOUNT OF 5,000 U.S. DOLLARS, OR THE AMOUNT PAID FOR THE SERVICES (IF ANY) FOR THE USER IN THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO LIABILITY, AND UNDER NO CIRCUMSTANCES WILL THERE BE CONSEQUENTIAL OR PUNITIVE DAMAGES.
You hereby agree to defend, indemnify, and hold harmless Bloquo, its affiliates, and respective officers, directors, employees, managers, members, shareholders, agents, successors, and assigns from and against any and all claims, damages, obligations, losses, liabilities, deficiencies, actions, judgements, settlements, interest, awards, penalties, fines, costs, or expenses, of whatever kind, including attorney’s fees, arising from or relating to: (i) your violation of these Terms and Conditions or any other applicable terms or policies of Bloquo or our TSPs partners; (ii) your violation of the Privacy Policy; (iii) your use or misuse of the Services; (iv) your violation of any third party right, including but not limited to Intellectual Property Rights, or privacy rights; (v) your violation of any applicable Laws; and (vi) any claim that is made against you by a third party as a result of using or misusing the Services or violating any applicable Laws.
You acknowledge and agree that Bloquo reserves the right to refuse access to the Services to any individual or entity, and to suspend or terminate any User’s access at any time.
Bloquo reserves the right, in its sole discretion, to amend, change, modify, revise, or reissue these Terms and Conditions from time to time (each, an “Update”). Excluding Fee Increases which are subject to Section 7 of these Terms and Conditions, in the event that an Update materially affects your rights or obligations, or those of Bloquo under these Terms and Conditions, Bloquo will provide you with notice of such Update via email, through your Account, or by any other reasonable means of communication, using the email address or other contact information provided during registration or thereafter. You will be deemed to have accepted any Update by continuing to access or use the Services for fifteen (15) days following such notice, and the updated Terms and Conditions will thereafter govern the rights and obligations between you and Bloquo.
If applicable, User grants Bloquo the right to use its company name and logo as a reference for marketing or promotional purposes on Bloquo’s website and in other public or private communications or disclosures with its existing or potential customers and investors, subject to its standard trademark usage guidelines as provided to Bloquo from time to time.
If any provision of these Terms and Conditions, or the Privacy Policy, is found to be invalid, illegal, or unenforceable, it shall be modified to the minimum extent necessary to make it enforceable while preserving its original intent. If modification is not possible, the provision shall be severed, and the remainder of the agreement shall continue in full force. If a provision is unenforceable under mandatory local Law, that local law will apply only to that specific matter, without affecting the validity of the remaining provisions.
To expedite resolution and control the cost of any dispute, controversy, or claim related to these Terms and Conditions, the Privacy Policy or the Order Form (“Dispute”), the parties agree to first attempt to negotiate any Dispute informally for at least thirty (30) days before initiating the arbitration procedure provided in this Section 24. Such informal negotiations shall commence upon written notice from the party promoting the Dispute.
If the parties are unable to resolve the Dispute through informal negotiations, the Dispute will be solely and exclusively resolved through binding arbitration, except that each party retains the right to seek injunctive or other equitable relief in a court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of a party’s confidential information, copyrights, trademarks, trade secrets, patents, or other Intellectual Property Rights.
BOTH YOU AND BLOQUO UNDERSTAND AND AGREE TO SUBMIT TO ARBITRATION PROCEEDINGS TO SETTLE ANY DISPUTES HEREUNDER, THAT ARBITRATION WILL BE IN LIEU OF LITIGATION EXCEPT AS OTHERWISE EXPRESSLY PROVIDED HEREIN, AND EACH PARTY HEREBY WAIVES THE RIGHT TO SUE IN COURT IN FAVOR OF THE ARBITRATION PROCEEDING.
There is no judge or jury in arbitration, and court review of an arbitration award is limited. However, an arbitrator can award on an individual basis the same damages and relief as a court (including injunctive and declaratory relief or statutory damages) and must follow these Terms and Conditions as a court would.
The arbitration, once initiated, will be conducted by the American Arbitration Association (“AAA”) under its Commercial Arbitration Rules (or, if required by law to be treated as a consumer dispute, the AAA Consumer Arbitration Rules). The AAA’s rules are available from the AAA. The Federal Arbitration Act governs the interpretation and enforcement of this Section 24. Payment of all filing, administration, and arbitrator fees will be governed by the AAA’s rules. The parties may choose to have the arbitration conducted by telephone, based on written submissions, or in person in the state of Montana, or at another mutually agreed location. Any award of damages by an arbitrator must be consistent with Sections 17 and 18. The arbitrator may award declaratory or injunctive relief in favor of the claimant only to the extent necessary to provide relief warranted by the claimant’s individual claim.
Notwithstanding the foregoing, if for any reason a Dispute proceeds in court rather than in arbitration, such Dispute shall be instituted in the federal courts of the U.S. (or, if federal jurisdiction is lacking, the state courts) located in the state of Montana, and each party irrevocably submits to the exclusive jurisdiction of such courts in any such legal suit, action, or proceeding. Service of process, summons, notice, or other document by mail to such party’s address set forth herein shall be effective service of process for any suit, action, or other proceeding brought in any such court.
The parties agree that all arbitration proceedings shall be confidential. All evidence, testimony, and the arbitral award shall remain confidential and shall not be disclosed to any third party without the written consent of the other party, except as may be required by Law or for the purpose of enforcing an arbitral award.
Both you and Bloquo agree that any Dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action. THIS MEANS THAT YOU AND BLOQUO BOTH AGREE TO WAIVE THE RIGHT TO PARTICIPATE AS A PLAINTIFF AS A CLASS MEMBER IN ANY CLASS ACTION PROCEEDING. FURTHER, UNLESS YOU AND BLOQUO AGREE OTHERWISE IN WRITING, THE ARBITRATOR IN ANY DISPUTE MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS AND MAY NOT PRESIDE OVER ANY FORM OF CLASS ACTION PROCEEDING.
Unless otherwise required by Law, an action or proceeding by User relating to any disagreement pertaining to a payment transaction facilitated by Bloquo under these Terms and Conditions (“Payment Dispute”) must commence within six months of initiation of such payment/transaction. An action or proceeding by the parties relating to any other Dispute must commence in accordance with the applicable statute of limitations.
EACH PARTY WAIVES ANY RIGHT TO JURY TRIAL IN CONNECTION WITH ANY DISPUTE, ACTION, OR LITIGATION IN ANY WAY ARISING OUT OF OR RELATED TO THESE TERMS AND CONDITIONS AND THE PRIVACY POLICY.
These Terms and Conditions and the Privacy Policy shall be governed by and construed in accordance with the laws of the state of Montana, without giving effect to any choice-of-law or conflict-of-law provision or rule that would result in the application of the laws of any other jurisdiction.
You shall not assign or otherwise transfer any of your rights, or delegate or otherwise transfer any of your obligations or performance, under these Terms and Conditions, in each case whether voluntarily, involuntarily, by operation of Law, or otherwise, without Bloquo’s prior written consent, which consent Bloquo may give or withhold in its sole discretion. We may assign or transfer all or any of our rights or obligations without your consent. Any merger, purchase, sale, consolidation, reorganization, corporate divestiture, or any other type of acquisition or business combination of all or any portion of a party’s assets or equity interests, or transfer of all or a portion of a party’s business involving any party (regardless of whether such party is a surviving or disappearing entity) will be deemed to be a transfer of rights, obligations, or performance under these Terms and Conditions for which the other party’s written consent is not required. These Terms and Conditions bind and benefit permitted successors and assigns.
No agency, partnership, joint venture, employer-employee, or franchiser-franchisee relationship is intended or created by these Terms and Conditions between the parties.
These Terms and Conditions and the documents incorporated by reference (including the Privacy Policy and the Order Form, as applicable) are the entire agreement and replace all prior or contemporaneous agreements on this subject. In the event of any conflict or inconsistency, these Terms and Conditions shall control unless stated otherwise.
These Terms and Conditions are written in English, which shall control. Any translation is provided for convenience only and shall not modify or affect the interpretation of these Terms and Conditions. In the event of any inconsistency or conflict, the English version prevails.
By accepting these Terms and Conditions, you agree and consent to receive all communications, agreements, documents, notices, and disclosures (collectively, “Communications”) that Bloquo provides in connection with your Account and the Services, electronically. Communications may be delivered by email to the primary email address associated with your Account, by providing a link or instructions for accessing such Communications, and, by posting the Communications on the Platform.
Unless stated otherwise, written notices are effective when received if delivered personally or by certified or registered mail; when electronically confirmed if sent by facsimile or email; or the next day if sent by recognized overnight delivery.
You may withdraw your consent to receive Communications electronically from Bloquo by contacting Bloquo, which will be effective only after Bloquo has had a reasonable period of time to process your request. If you withdraw your consent, Bloquo may terminate the Services to you.
If you are a California resident, in accordance with Cal. Civ. Code § 1789.3, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by contacting them in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.
Bloquo will not be liable or responsible to you, nor be deemed to have defaulted under or breached these Terms and Conditions, for any failure or delay in fulfilling or performing any of its obligations under these Terms and Conditions or in providing the Services, when and to the extent such failure or delay is caused by or results from any events beyond Bloquo’s reasonable control, including, without limitation, acts of God; flood, fire, earthquake, epidemics, pandemics, tsunami, explosion; war, invasion, hostilities (whether war is declared or not), terrorist threats or acts, riot or other civil unrest; government order, law, or action; embargoes or blockades; strikes, labor stoppages or slowdowns, or other industrial disturbances; shortage of adequate or suitable internet connectivity, telecommunication breakdown, or shortage of adequate power or electricity; and other similar events beyond Bloquo’s control.
If you have any questions or concerns regarding these Terms and Conditions or the Privacy Policy, please feel free to contact us:
By email:
By mail: to Bloquo Inc., at 1001 S Main Street, Suite 500, Kalispell, MT 59901
You, your representatives, or any legally authorized third parties, are expressly prohibited from using the Services in connection with any of the following persons, activities, items, products, services, or clients:
The following activities, items, or services may only be served with Bloquo’s prior written approval following enhanced Due Diligence:
Privacy Policy — Version 1.0 — Effective March 2026 · Bloquo Inc. (Montana, USA), FinCEN-registered MSB
Bloquo Inc., a Montana corporation registered with the United States ("U.S.") Financial Crimes Enforcement Network ("FinCEN") as a Money Services Business ("MSB"), together with its affiliates, subsidiaries, parents, and related entities ("Bloquo", "us", "we", "our"), is a technology provider that facilitates access to a platform, website, mobile applications, messaging channels, application programming interfaces ("APIs"), and other integrations with third-party platforms, websites, mobile applications, and services (collectively, the "Platform"), through which it enables a series of content, functionalities, and services.
This Privacy Policy, together with any documents incorporated herein by reference, including the Website Terms of Use ("ToUs") and the General Terms and Conditions of Use and Service ("Terms and Conditions"), as applicable, describes and governs the collection and use of Personal Information (as defined below) by Bloquo.
It applies to Personal Information collected from individuals to whom Bloquo may provide access to the website, Platform, and related services, as well as from any other individual who interacts with Bloquo or its offerings ("User", "Users", "you", or "your"). This includes Personal Information collected in connection with your access to or use of the website, the Platform, and related services, Bloquo's social media, any other Bloquo Technology (as defined below) in connection therewith, or any other products, services, or documentation that Bloquo may offer or make available from time to time, whether online or offline (collectively, the "Services").
This Privacy Policy further explains how such Personal Information is used, the circumstances under which it may be shared, and the choices available to you regarding our use of such Personal Information. It does not apply or extend to organizations or individuals outside Bloquo's ownership, control, or management. Bloquo is not responsible for the data-handling practices, products, information, or services of any third party that may be linked to or accessible through the website, the Platform, and Services, including, without limitation, any Third Party Content (as defined in Section 4 below), nor does Bloquo endorse or make any representations regarding such third parties.
"Personal Information" means information that you or Users provide access to Bloquo, or information which Bloquo creates or obtains on behalf of you or the User, that: (a) directly or indirectly identifies an individual or (b) can be used to authenticate an individual. User's business contact information is not by itself Personal Information.
"Bloquo Technology" means the software, algorithms, models, and other technologies used to provide the Services, including, without limitation, software, the Platform, a website, a mobile application, messaging channels, API integrations, and any modifications, enhancements, or derivative works thereof, whether now existing or hereafter developed, and all Bloquo proprietary information and technology, used by Bloquo or provided to you in connection with the Services.
By accessing or using Bloquo's Services, you agree to our collection, use, and disclosure practices of your Personal Information, and other related activities, as described in this Privacy Policy.
If you do not agree with this Privacy Policy, we kindly request you not to access or use the Services.
If you have any questions or wish to exercise your rights and choices, please email us at the email address set out in Section 11 below. If you are a resident whose state or foreign jurisdiction may provide certain statutory privacy protections, please see the additional disclosures in Sections 12 to 16 of this Privacy Policy.
(a) Information You Provide. We may collect information about you when you access and use the Services or interact with us offline, including information you provide when you register an account, update your profile, access our content and functionalities, make a purchase, or contact customer support. The categories of information we collect, and may have collected in the past twelve (12) months, include:
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
(b) Information Collected Automatically. In addition, we automatically collect information when you access and use the Services. The categories of information we automatically collect, and may have collected in the past twelve (12) months, include:
For further information on your rights and choices, see Section 6 below.
(c) Information from Other Sources. We may also collect information from other sources. The categories of sources from which we collect information, and may have collected from in the past twelve (12) months, include:
(d) Technologies. The types of technologies we use to collect information include:
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see Sections 5 and 6 of this Privacy Policy.
We may collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business and commercial purposes for collecting and using information, and for which we may have collected and used information in the past twelve (12) months, include:
Notwithstanding the above, we may transform Personal Information, as well as data and information relating to you and to Users' use of the Services, into aggregated, de-identified, or otherwise anonymized information, including, without limitation, to compile statistical information related to the provision and operation of the Services and performance data (including, without limitation, system-generated technical information, such as server logs, usage metadata, and telemetry) ("Resultant Data") and, except where prohibited by applicable law, use or disclose such data for any lawful purpose, including evaluating and enhancing the performance, features, and effectiveness of the Services; analyzing usage patterns, user demographics, and general behavioral trends; conducting or supporting research with industry partners to advance the Services; and developing new insights, content, and products and services. For example, we may aggregate data to calculate average activity or related or derived metrics across all Users over a specified period.
For information on your rights and choices regarding how we use information about you, please see Section 6 below.
We may share information we collect in accordance with this Privacy Policy, the ToUs, and the Terms and Conditions, as applicable. The categories of parties with whom we share information, and may have shared information in the past twelve (12) months, include:
Notwithstanding the above, we may share Resultant Data, except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see Section 6 below.
The Services may contain links to websites or applications controlled by parties other than Bloquo ("Third Party Content"). In addition, we integrate technologies operated or controlled by other parties into parts of the Services, including, without limitation, third party LLMs.
Some examples include:
(a) Links. The Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. We may get a commission if you purchase a product after clicking on a link to an affiliate's website; and
(b) Brand pages and chatbots. We may offer our content through social media, such as Meta. Any information you provide to us when you engage with our content (such as through our brand page or chatbot) is treated in accordance with this Privacy Policy. Also, if you publicly reference the Services on social media (e.g., by using a hashtag associated with Bloquo in a post), we may use your reference on or in connection with the Services.
Please note that when you interact with other parties, including when you leave the Services, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
We may use analytics services, such as Google Analytics, to help us understand how Users access and use the Services. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products, devices, and Services on other websites and services. For example, we may place ads through Google and Meta that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Services (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you ("Interest-based Advertising").
As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
(a) Account Information. Please note that we will retain and use information about you as necessary for our records, to perform the Services, to fulfill our legal obligations, resolve disputes, and enforce our agreements. You may request access to or a full deletion of your Personal Information by emailing us at the email address set out in Section 11 below. To confirm that any access or deletion request is legitimate, we may ask you to complete a verification form demonstrating that you have the authority to act. Even after we honor a request to delete Personal Information, we may keep limited records as required or permitted by law, along with certain Resultant Data.
Users may access, update, edit, or delete certain information they have provided to us through their account settings, including first and last name, username and password, email address, mailing address, and other profile information.
If you are a resident whose state or foreign jurisdiction may provide certain statutory privacy protections, please see the additional disclosures in Sections 12 to 16 of this Privacy Policy.
(b) Tracking Technology Choices.
Please be aware that if you disable or remove certain technologies some parts of the Services may not function correctly.
(c) Analytics and Interest-Based Advertising. You may opt out of certain data collection and targeted advertising features provided by third parties. For example, Google and Microsoft provide tools that allow you to opt out of the use of certain information they collect.
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you.
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities' statements regarding their opt out options or programs.
(d) Communications.
Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
The Services are not directed at people under 18 years old. If you have not yet reached the age at which your jurisdiction permits you to consent to the processing of your data, do not register for the Services or provide us with Personal Information. Should Bloquo discover that it has inadvertently collected Personal Information from a minor who lacks the legal capacity to give such consent, we will delete that information as swiftly as possible. If you believe a minor in this situation has supplied us with Personal Information, please email us at the email address set out in Section 11 below.
We do not knowingly collect personal information (as defined by the U.S. Children's Privacy Protection Act, or "COPPA") from children.
We implement and maintain reasonable organizational, administrative, physical, and technical security safeguards and encryption during transmission and at rest to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction, in accordance with the ToUs and the Terms and Conditions, as applicable. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once it is received. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. By using the Services you acknowledge and agree that Bloquo makes no such guarantee, and that you use them at your own risk.
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Services from outside of the U.S., please be aware that information collected through them may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Services, or any other products or services that Bloquo makes available, or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. as set out in this Privacy Policy.
We use recognized transfer tools, for example, LGPD (as defined in Section 16 below) transfer mechanisms, and perform transfer risk assessments where required. We disclose key third-country recipients upon request where permitted.
We retain personal data only for as long as it is reasonably needed to fulfill the purposes described in this Privacy Policy, the ToUs, and the Terms and Conditions, as applicable, and to comply with applicable legal and regulatory requirements, including tax, accounting, audit, and anti-money laundering and counter terrorist financing obligations.
Bloquo reserves the right, in its sole discretion, to change, modify, revise, or reissue this Privacy Policy from time to time (each, an "Update"). Bloquo will make each Update available on Bloquo's website. In the event that an Update materially affects your rights or obligations, or those of Bloquo, under this Privacy Policy, Bloquo will provide you with notice of such Update via email, through your account, or by any other reasonable means of communication, using the email address or other contact information provided during registration or thereafter; except where an Update is immaterial to any of your legal rights or to the legal obligations of Bloquo and is made solely to correct a typographical, formatting, or grammatical inaccuracy, in which case such Update will be effective immediately upon posting on Bloquo's website. You will be deemed to have accepted any Update by continuing to access or use the Services for fifteen (15) days following such notice, and the updated Privacy Policy will thereafter govern the collection, use, and disclosure of your information by Bloquo.
If you have any questions or concerns regarding this Privacy Policy, our data practices, or our compliance with applicable law, please feel free to contact us:
Nevada law requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. We do not sell personal information of Nevada residents. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please email us at the email address set out in Section 11 above.
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 ("CCPA") provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
(a) Notice of Collection.
The categories of personal information, as described in the CCPA we collect, and have collected in the past twelve (12) months, include:
For further details on information we collect, including the sources from which we receive information, review Section 1 above. We collect and use these categories of personal information for the business purposes described in Section 2 above, including to manage the Services.
To the extent "sale" under the CCPA is interpreted to include the activities set out in this Privacy Policy, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review Section 3 above for further details about the categories of parties with whom we share information.
While the CCPA does not currently apply to Bloquo, if it becomes applicable in the future, you will have the rights listed below.
(b) Right to Know and Delete.
This is the right to know certain details about our data practices in the past twelve (12) months. In particular, you may request the following from us:
In addition, you have the right to delete the personal information we have collected from you.
To exercise any of these rights, please email us at the email address set out in Section 11 above. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. You may appoint an authorized agent to exercise your privacy rights on your behalf. Any request the agent submits must follow our usual process, and we may require a signed authorization proving the agent's authority. We may also ask you to verify your identity directly and confirm that you granted the agent permission to act for you. If we are unable to verify your identity, we may deny your requests to know or delete.
California's "Shine the Light" statute (CA Civil Code §1798.83) may allow you, as a California resident, to request once per calendar year a disclosure of any categories of personal information that Bloquo has shared with third parties for those parties' direct-marketing purposes, along with the names and addresses of the third parties involved. While currently, the California's "Shine the Light" law does not apply to Bloquo, if it becomes applicable in the future, and you would like to make this request, please email us at the email address set out in Section 11 above.
(c) Right to Opt Out.
Although Bloquo does not sell your personal information to third parties, to the extent that any sharing of your personal information constitutes a "sale" under the CCPA, you have the right to opt out of the sale of your personal information by us to third parties at any time. You may submit a request to opt out by emailing us at the email address set out in Section 11 above.
If you are a resident of a U.S. state such as, without limitation, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, your state's privacy statute may afford you certain rights. Specifically, you may:
Bloquo will honor these rights as required by the laws of your state.
If you are a resident of a country outside of the U.S., your country's privacy statute may afford you certain rights. These rights may vary depending on the jurisdiction and the nature of your relationship with Bloquo. If you are a foreign User and wish to submit a request or inquiry relating to our compliance with the data protection or privacy laws of your respective country, please email us at the email address set out in Section 11 above.
This Privacy Policy is written in English, which shall control. Any translation is provided solely for convenience and does not modify or affect the interpretation of this Privacy Policy. In the event of any inconsistency or conflict, the English version prevails.
This section applies exclusively to Users who are residents of Brazil. If any provision of this section conflicts with another part of this Privacy Policy, this section will prevail for Brazilian Users.
We process personal data in accordance with Federal Law No. 13,709/2018 (Lei Geral de Proteção de Dados – "LGPD") and other applicable Brazilian data protection laws. For purposes of this section, the term "personal data" has the meaning assigned to it under the LGPD.
If a Portuguese version of this Privacy Policy is not otherwise made available, such version may be provided upon request by emailing us at the email set out in Section 11 above.
This Privacy Policy is written in English, which shall control. Any translation is provided solely for convenience and does not modify or affect the interpretation of this Privacy Policy. In the event of any inconsistency or conflict, the English version prevails.
By accessing or using the Services, or otherwise interacting with us, you acknowledge that your personal data may be collected, used, and shared as described in this Privacy Policy, to the extent necessary to provide and operate the Services and as permitted under applicable law.
You acknowledge that we may process personal data for purposes related to credit score analysis, fraud prevention, security, risk management, and misuse prevention, including verifying the integrity of accounts and transactions and protecting the Services from unauthorized or unlawful activity. Such processing may involve information obtained from credit bureaus, agencies, and other third parties that provide security, risk, or verification services or that have the technical capacity for the assessment of risk or aggregation of your information and data, as permitted under the LGPD.
(a) Processing of Personal Data.
We process personal data only when supported by a lawful basis under the LGPD, which may include, as applicable:
(b) Your Rights Under Brazilian Law.
As a data subject under the LGPD, you may request, as applicable:
(c) Submitting a Request.
You may submit a request to exercise your rights free of charge and at any time by emailing us at the email address set out in Section 11 above.
We will acknowledge and respond to requests within the timeframe required by applicable law. If we are unable to comply with a request, in whole or in part, we will provide a clear explanation of the factual or legal reasons preventing compliance.
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