General Terms and Conditions

The following General Terms and Conditions are hereby established to regulate the use of the contents and services belonging to the Adblidai group of companies (Adblidai LLC, headquartered at 8 The Green, Ste A, Dover, Delaware, USA; Adblidai OU, headquartered at Harju County, Tallinn, Lasnamae Subdistrict, Vaike-Paala St 2, 11415, Estonia; and Adblidai OU Filialas, headquartered at Perkunkiemio St. 13-91, Vilnius, Lithuania), collectively forming the "Eluter" Platform/Application (hereinafter referred to as the "Site"), as well as other websites and/or internet platforms directly or indirectly owned by the aforementioned group (hereinafter referred to interchangeably as the "Holder" or the "Company"). These present Terms and Conditions (hereinafter the "Terms and Conditions" or "T&C") describe the general conditions applicable to any individual and/or legal entity that, for any reason, accesses the Site (hereinafter interchangeably referred to as "Users" or the "User"). By interacting with and/or using the Site, the User is understood to have fully and unreservedly accepted these Terms and Conditions. Therefore, the User undertakes to comply with all provisions contained in these Terms and Conditions, under applicable laws, statutes, regulations, and rules related to the use of the Site. The Site Holder reserves the right to revise these T&C at any time, by updating and/or modifying them. The User must review these Terms and Conditions each time they access the Site, as the clauses comprising them are mandatory and binding. Any modification to these T&C will be considered tacitly accepted whenever the User accesses the site without the need for express confirmation, unless required otherwise by the Holder. Furthermore, since certain services and content offered to Users through the Site may have specific rules that regulate, complement, and/or modify these T&C, Users are recommended to familiarize themselves with these specific rules before using the Site.


The Services provided by the Company through the Site are only available to individuals who have the legal capacity to contract and be contracted with or who are of legal age according to the applicable legislation of each country. Persons without such capacity or Users who have been temporarily suspended or permanently disabled are not allowed to use the services. If a User registers on the Site as a legal entity, they must have the capacity to contract on behalf of that entity and bind it in the terms of these T&C. The Holder is not obligated to verify whether Users have the right or capacity to use the Site. Additionally, the Services provided by the Company through the Site are available exclusively to qualified individuals who understand the risks and volatility of Digital Assets.

Restricted Jurisdictions

1.1 Currently, the following countries are admitted to use the Site: Spain, France, Italy, Poland, Portugal, Switzerland, Turkey, Israel, South Africa, Argentina, Brazil, Chile, Colombia, Mexico, Peru, Australia, and New Zealand.

1.2 Persons who are residents of any jurisdiction in which (i) the Holder is not authorized to provide the Services, or (ii) the use of the Services is illegal or violates any applicable law of that jurisdiction ("Restricted Jurisdiction") may not register as Users.

1.3 By accepting these Terms and Conditions, the User declares that they are not a resident of any Restricted Jurisdiction and will not register an account if they are. The Holder reserves the right to deactivate the account of any User that has been registered in violation of these provisions.


2.1 Every User who wishes to use the Site must register by completing the registration form, which is considered a sworn declaration, providing valid information and accurate, precise, and truthful personal information ("Personal Data" and/or "Information") in all fields. Additionally, the User must fulfill all requirements provided by Anti-Money Laundering and Counter-Terrorism Financing ("AML/CTF") regulations that may apply according to their country of birth, residence, and/or tax registration. Once registered, the User commits to updating the Personal Data as necessary. The Company is not responsible for the accuracy of the Personal Data provided by Users. Users guarantee and are responsible, in any case, for the truthfulness, accuracy, completeness, validity, and authenticity of the entered Information. The Holder reserves the right to request proof and/or additional information to verify the Personal Data provided by a User, as well as to temporarily or permanently suspend those Users whose data cannot be confirmed. The Holder also reserves the right to reject a registration request or to cancel or suspend an account, temporarily or permanently, without the need to provide any cause to the User. In case of inconsistencies or suspicious activities detected in the information provided by a User, the Holder will automatically reject, cancel, or suspend the account. In both cases, the Holder's decision will not entitle the User to any compensation or reimbursement. It is clarified that, in all cases, the Account, regardless of its type, is personal, unique, and non-transferable, and will be assigned to a single User. Its sale, assignment, or transfer (including reputation) under any title is prohibited. The User may not allow or authorize third parties to use their Account.

2.2. The User will access the personal account created through their registration on the Site (hereinafter the "Account") by entering their email address and password. Additionally, the Site also allows entry through biometric data, which must be authorized by the user. The User will be responsible for maintaining the confidentiality of their data and password. The User acknowledges and agrees that the Site may anonymously disclose certain data contained in their registration application to third parties. However, the Company will not disclose the User's name or email address to third parties without their prior consent, except to the extent necessary for compliance with existing laws or legal proceedings, or if a judicial and/or state administrative authority requests it through a legal order, where such information is relevant or strictly necessary for the provision of services through the Site. The User will be responsible for all operations carried out in their Account, as access to it is restricted to entering and using their Password, which will be exclusively known to them. The User undertakes to immediately notify the Company of any unauthorized use of their Account and the entry of unauthorized third parties to it, using appropriate means.

2.3. All the Information provided by the User upon registration on the Site and any other data and information will be used in accordance with what is mentioned in these Terms and Conditions, which the User acknowledges and accepts.

2.4. The Holder will use the Information for the following purposes: a) identification and authentication, b) business administration and management, c) service improvement, d) statistical purposes, e) sending notifications, promotions, or advertisements, among others.

2.5. The User expressly authorizes the Holder to share the Personal information provided at the time of registration and account verification (including email address) with financial and/or state institutions if required by anti-money laundering, counter-terrorism financing, and/or fraud prevention procedures, and with service providers or affiliated companies that contribute to providing service and/or improving or facilitating operations through Eluter in all jurisdictions where the service is available. This includes (but is not limited to) payment methods, payment collection methods, banking entities, insurance, or intermediaries in payment management, call centers, entities involved in dispute resolution such as (but not limited to) Insurance Companies, Friendly Compilers or Arbitration Courts or competent courts, among others. The Company will ensure that certain standards for transmitting information are met through the signing of agreements or conventions whose purpose is the privacy and confidentiality of our users' personal data.

Data Privacy

The data provided by the User is safeguarded ethically and responsibly according to our Privacy Policy (link).

Use of the Site

3.1. General considerations about the use of the Site. The User agrees to use the Site in accordance with the law, these Terms and Conditions, as well as generally accepted morals and good customs, and public order. The User undertakes to refrain from using the Site for illegal purposes or effects, contrary to what is established in these T&C, harmful to the rights and interests of third parties, or that could in any way damage, disable, overload, or deteriorate the Site or prevent its normal use by other Users.

3.2. Payment Methods for obtaining digital coins are those specified on the Holder's website, and the Holder does not operate with other payment methods not listed on the website. For the purposes hereof, payment will be considered made in the terms of the Civil and Commercial Code of the Nation - or the applicable legislation to the User - to those made through authorized payment methods. The Holder will not be liable for damages and/or inconveniences caused to the User due to misuse or conflicts between the user and the payment method, nor for the user's use of a payment method not included or informed on the Holder's website.

3.2.3 The User declares under oath that they are a knowledgeable individual with the necessary education, who expressly understands and accepts the fluctuations of Digital Assets. The final exchange rate for conversion between the legal currency of the country and the Digital Asset will be specified in the calculator available on the website at the time of funds crediting. Additionally, the User can view the conversion within the Site/App, as well as preview the quotation and commission that will be charged.

3.2.4 The User acknowledges that the Holder and the payment provider are two separate legal entities. Therefore, if there is a delay in crediting and/or reconciling the User's money, it cannot be attributed to the Holder, and the User must resolve it with the corresponding provider. Notwithstanding this, the user may notify the Holder in writing of this through a note or email for the purpose of allowing the Holder to consult the payment provider for the reasons for such a delay, without assuming any legal responsibility. Furthermore, when issuing an Instruction/Operation/Action, the User accepts that once executed through the Site, such transaction is irreversible and cannot be canceled.

3.2.5 The Holder is not responsible for the destination of the Digital Assets that the User acquires, nor for the origin of the same. In the event that information about an account's behavior is requested, it will be provided in accordance with what is specified in point 2.2 of these terms and conditions.

3.2.6 In the event of any breach by the User of these Terms and Conditions, Eluter is legally empowered to close the account of such User and/or return the funds stored in their account via a bank transfer, retaining the corresponding administrative expenses (e.g., load balance service commissions, commissions for said bank transfer, etc.).

3.2.7 Regarding Digital Asset protocols. The User acknowledges that neither the Holder nor Eluter has authority or control over the software protocols governing operations in digital currency on our platform(s). In general, these protocols are open-source, and anyone can use, copy, modify, and distribute them. By using Eluter's services, the user acknowledges and agrees that (i) Neither the Holder nor Eluter are responsible for the operation of the underlying protocols and do not guarantee their functionality, security, and/or availability, and (ii) the protocols are subject to sudden changes in their operational rules (as is the case with eventual forks). Such forks can materially affect the value, functionality, and/or denomination of the digital currency stored on the Eluter platform. In the event of a fork, the user agrees that the Holder may temporarily suspend their operations on the "Eluter" platform (with or without prior notice) and that the Holder may, if deemed necessary, (a) configure or reconfigure their systems or (b) decide not to support (or cease supporting) an alternative protocol, provided the user has the opportunity to withdraw their funds from the platform. The user acknowledges and agrees that the Holder assumes no responsibility for an unsupported branch of an alternative protocol.

3.2.8 The User consents to and accepts that the Holder, in no way, determines the prices of the Digital Assets offered on the Site. The quotation of these assets may vary according to market transaction volume, supply and demand, as well as any other exogenous factor that could affect prices. The User acknowledges that the displayed price may change and may differ from the moment they enter the Site to the moment the transaction is executed.

Services with Cryptoassets

3.2.9 Subject to compliance with the provisions in these General Terms, the User may, through instructions given to the Site, carry out the following operations: (a) buy and sell Cryptocurrencies; (b) hold balances in Cryptocurrencies; (c) make outgoing Cryptocurrency transfers; (d) receive Cryptocurrencies to their Account; (e) earn yields; (f) make donations to institutions, civil associations, NGOs, and/or organizations dedicated to social and environmental well-being (also called Re-Fi/Regenerative Finance); (g) create Cryptocurrency wallets; (h) integrate the API for processing payments.

3.2.10 By merely accepting these Terms and Conditions, Users acknowledge and accept that: (i) transactions with Cryptoassets are subject to various specific risks, including, but not limited to: (a) risks inherent to the jurisdiction in which the User resides, as well as those of the jurisdiction in which the buying, selling, or transferring of Cryptoassets occurs; (b) computer, technical, or technological risks arising from the functionality, features, use, and other technical properties of the Cryptoassets, as well as the underlying technology of these, and any other risks impacting the transaction; (c) risks due to implementation or changes in regulatory and/or legal matters affecting those who possess Cryptoassets, or inherent risks due to the lack of regulatory support or supervision by governmental bodies; (d) risks inherent to technology and the use of digital platforms, as despite the Holder's investment in computer security, there are risks such as phishing, identity theft, or cyberattacks (hacks) that could lead to losses, changes, or theft of Cryptoassets; (e) economic, financial, and volatility risks in the value of the cryptoasset, as they are not considered legal tender, and their value is not backed by any government or financial institution; (f) technological, cyber, and fraud risks inherent to the buying, selling, and exchanging of Cryptoassets.

The User accepts, acknowledges, and assumes that, in addition to those mentioned above, there may be additional risks not expressly foreseen in these Terms and Conditions, and releases the Holder, its shareholders, directors, employees, representatives, and/or agents from any responsibility for damages or losses suffered as a direct consequence of requests made on the Site.

3.2.11 User Declaration. As a condition for using cryptoasset services, the User declares, affirms, and warrants the following: (a) they have complete and thorough knowledge of the nature, legal framework (or lack thereof), and volatility of Cryptoassets' value and fully assume the risk of transacting in such assets; (b) they understand and accept that neither the Holder, the site, nor its providers offer financial advice and/or recommendations, regarding financial matters or the advisability or appropriateness of transacting through the Application with cryptoassets; (c) they are not prevented or restricted from conducting any operations with cryptoassets and such operations do not constitute a violation of the user's tax, regulatory, legal regime, or any restriction or regulation applicable to the User in the relevant jurisdiction; (d) the site may require additional information and/or documentation from the User, in which case they agree to provide it immediately and authorize sharing such information and/or documentation with external providers in order to process the requests made through the site; (e) the digital assets or funds used on the Site have been obtained lawfully and are intended for lawful acts; (f) the operations carried out through the Site may have purely electronic documentation, foregoing written records, so the User should consider this aspect when contracting third parties to carry out or formalize operations within the Site; (g) the User acknowledges that neither the Holder, external providers, nor third parties authorized to provide additional services listed on the site will be responsible for the time elapsed between sending the instruction to purchase or sell Cryptoassets and the effective transfer of these into the User's Account; (h) Users exclusively assume the risk of operating with Cryptocurrencies and release the Holder from any liability or loss derived from or related to such operations. Consequently, the User agrees and declares that: (a) they will refrain from claiming for any fluctuations in the Cryptoasset quotations; and (b) they exempt the Holder, external providers, and authorized third parties from any kind of liability for any damages, losses, or reductions in value, direct or indirect, current or future, related to Cryptoassets, regardless of the cause.

3.2.12 There may be a minimum or maximum balance loading on the Site; in such cases, Users will be duly informed.

3.2.13 Cryptocurrency Transactions. By using the "deposit," "send," and "buy/sell" buttons on the Site, the User is understood to be generating a Request, constituting an irrevocable mandate and instruction for the Holder, through its external providers, authorized third parties, and/or whoever the Holder designates, to buy or sell Cryptocurrency on the User's behalf. Each Request shall indicate, among other data, the quantity and type of Cryptocurrencies to be bought or sold (according to the options available on the Site), the amount, and the price to be paid or received by the User for such transaction (according to the quotations displayed on the Site).

The User declares that they are aware and accept that such buy/sell service is not performed directly by the Holder but rather outsourced through other entities separate from the aforementioned holding.

3.2.14 The Cryptocurrencies acquired through the corresponding operations will be displayed in the User's Account. In the event that the User wishes to sell the Cryptocurrencies through the Site, they must submit a Request to that effect, and once the sale is executed on their behalf, the proceeds will be integrated into the Account after deductions.

Such transfers are subject to: (a) the availability and existence of a Cryptocurrency balance in favor of the User in their Account; and (b) the issuance of the corresponding Request, which must contain the quantities of Cryptocurrency to be transferred and the required data. (c) the supply and demand in the corresponding cryptocurrency market. The User can check their Cryptocurrency balances, movements, and respective receipts through the site.

3.2.15 The Holder is not responsible for delays or inconveniences in the accreditation of the cryptocurrencies, as they can occur due to events beyond their control or as a result of the actions of external providers not associated with the Holder and/or the Site. Notwithstanding this, the Developer will make commercially reasonable efforts to ensure that Requests are executed as soon as possible.

The User understands and accepts that the Holder will not be responsible if the Requested operation cannot be processed or carried out due to reasons beyond the Holder's control.

3.2.16 The User will be solely responsible for the data provided in the Request, and the Holder is not liable for any damages this may cause, such as if the User provided an incorrect wallet address for fund withdrawal, resulting in the loss of cryptocurrencies.

3.2.17 The Holder is not responsible for the loss or theft of cryptocurrencies or compensatory payments for their loss.

3.2.18 The Holder reserves the right to not accept or reject Requests coming from illicit, fraudulent accounts, or those whose origin is associated with money laundering or terrorism financing. The Developer may proceed to close the Account in the event of detecting suspicious operations, even if the User claims that these were not carried out by them.

3.2.19 Charges and/or Commissions. The User acknowledges and agrees that the purchase and sale or exchange of cryptocurrencies on the Site may involve costs and commissions that arise from the services provided by third parties involved in the transfers. Deposit commissions are covered by the User who sends the cryptocurrencies.

3.2.20 Custody of Cryptocurrencies. The Holder, through External Providers and/or authorized third parties, provides the User with a custody and conservation service for the Cryptocurrencies available in the User's Account. The User understands and accepts that in the event of a judicial or administrative request, the Holder may immobilize and/or transfer the Cryptocurrencies in the User's Account that are subject to custody services. In such a case, the Holder will not accept any new Requests from the User and will dispose of the Cryptocurrencies in the manner determined by the corresponding judicial or administrative order.

3.2.21 The User must make Requests considering the compatible networks and the cryptocurrencies/tokens listed on the Site to ensure that the sent/received funds reach their destination correctly. The risk of not doing so implies that the sent funds may be lost, and recovery may not be possible. In the event of using an incompatible network, the User risks losing their cryptocurrencies, and additional fees resulting from the failed operation may be charged by the Network, not the Holder.

3.2.22 The User declares that they understand and accept that the Holder does not possess or control any of the underlying programs through which blockchain networks are formed, and cryptocurrencies are created and traded. In general, the underlying software for blockchain networks tends to be open-source, so anyone can use, copy, modify, and distribute it. By using the Site, the User understands and acknowledges that the Holder is not responsible for the operation of the software and underlying networks that support cryptocurrencies and that the Holder does not guarantee the functionality, security, or availability of said software and networks.

Security and Key Recovery

4.1 The user who registers on the site must create a password to access their profile. The user declares that this password is strictly personal and should not be shared or disclosed to third parties. In case the user forgets or loses their password, they must click on the "Forgot my password" link and follow the steps provided on the platform to generate a new one and regain access to the platform.

4.2 In case of any issues in this regard, the user can contact the company via email at the address and follow the steps indicated by the executive actively working on the case.

Modification of Terms and Conditions

5.1 The User agrees that they must carefully and comprehensively read these Terms and Conditions every time they access the Site, as they may undergo modifications.

5.2 The Holder may modify these Terms and Conditions at any time by publishing the modified terms on the Site. All modified terms will come into effect from the moment of their publication and will be deemed accepted by the User as long as they continue to use the Site.

5.3 The Holder reserves the right to make any modification or update to its contents and services in general, as well as to any elements that constitute the design and configuration of the Site, at any time and without prior notice.

5.4 The User declares that they fully understand these Terms and Conditions; otherwise, they will refrain from interacting or accessing the site.

Tax and Legal Obligations

6.1 Each User will be responsible for all tax obligations and burdens according to the laws of their country or the country where they are fiscally obligated for their operations on the Site. No responsibility for non-compliance by Users can be attributed to the Company. The Holder is not responsible for the effective compliance with tax or tax obligations established by current law and/or any other obligations arising from agreements between Users.

Intellectual Property

7.1 The contents of the screens related to the Site, as well as the programs, databases, networks, and files that allow the User to access and use their Account on the Site, are the exclusive property of the Holder and are protected by international copyright, trademark, patent, model, and industrial design laws and treaties. Improper use and total or partial reproduction of said contents are prohibited, except with the express authorization of the Holder.


8.1 The User acknowledges and agrees that they use the Site at their sole and exclusive responsibility. Each User acknowledges and agrees to be solely responsible for their actions within the Site. The User acknowledges and agrees that by conducting operations through the Site, they do so at their own risk. In no event shall the Company be responsible for any damage to the information network, failure of the information network, hardware or software failure, communication failures, or other system failures, power failure, strike, labor dispute, riots, uprising, productivity or lack of means of production, fire, flood, storm, explosion, war (declared or undeclared), governmental action, judicial administration orders, or omissions of a third party, loss of profit, or any other damage and/or loss that the User may have suffered due to operations conducted through the Site. The Company shall not be responsible for Users' interactions based on trust placed in the system or the Site. Likewise, the Company shall not be responsible for any damage and/or loss suffered by the User due to interactions and/or operations they conduct with other users and/or third parties on the platform.

8.2. By accepting these Terms and Conditions, the User releases the Company, its affiliates and associates, its directors, representatives, and/or employees from any liability arising from actions and/or claims and/or indemnities for damages of any kind and/or nature that may have originated or be connected to the use of the platform and/or operations between one or more Users. Furthermore, by accepting these Terms and Conditions, the User releases the Holder from any type of civil, criminal, commercial, administrative, or other liability, present or future, known or unknown, initiated against them and their respective shareholders, directors, officers, employees, agents, related companies, and External Providers, for any of the risks described in these Terms and Conditions, and as a result, irrevocably waives any action that may be taken to claim any liability arising from the use of the "Eluter" website and/or the sites promoted by the Holder.

8.3. The Holder does not guarantee the privacy and security of the use of the Site and, in particular, does not guarantee that unauthorized third parties may not become aware of the nature, conditions, characteristics, and circumstances of the use that Users make of the Site. Neither the Holder nor any of its controlled or affiliated companies guarantee that the Site will operate free of errors or that the Site and its server will be free of computer viruses or other harmful mechanisms. If the User has to resort to technical support or replace equipment or data due to the use of the Site, neither the Holder nor any of its related or controlled companies will be responsible for these expenses. The Site is provided as is currently available to the User, without any warranties of any kind. Neither the Holder nor any of its related or controlled companies assume any warranties regarding the accuracy, truthfulness, completeness, or currency of the content, services, software, texts, graphics, and links available on the Site. Nevertheless, the Company will make and has made all necessary efforts to mitigate the risk of any inconvenience in the security of the account and/or data leakage.

8.4. The Site may contain links to third-party websites, which does not indicate that they are owned or operated by the Holder, nor that they have any relationship with it. Since the Holder has no control over such sites, it will not be responsible for the content, and/or materials, and/or actions, and/or services provided by them, nor for damages and/or losses caused to Users by their use, whether directly or indirectly. The presence of links to other websites does not imply any partnership, relationship, approval, or endorsement by the Company or its related or controlled companies with the owners of such sites or contents.

8.5. By accepting these Terms and Conditions, the User accepts and acknowledges that trading real and/or virtual goods and products involves significant risk due to losses that may occur as a result of market fluctuations, such as (but not limited to) the foreign exchange market (FOREX), as well as cryptocurrencies and financial assets in general. The User accepts and acknowledges that the trading of Digital Assets is a volatile market primarily based on trust, which entails special risks not shared with the trading of commodities or goods in a traditional market. Considering these considerations, the user accepts, acknowledges, and assumes that there may be additional risks that have not been expressly foreseen in these Terms and Conditions and releases the Holder from any liability for damages or losses suffered as a direct consequence of the characteristics inherent in the markets offered on the "Eluter" web platform and/or other platforms belonging to the Holder.

Scope of Services

9.1. The User accepts and acknowledges that the acceptance of these Terms and Conditions does not create any kind of partnership, agency, franchise, and/or employment relationship between the Site and the User.

9.2. It is expressly established, and the user agrees that the Company, through the Site, does not provide any type of investment advice regarding the services provided. The Company may provide information about the price, range, and volatility of Digital Assets and events that have affected the price of Digital Assets, but this will never be considered financial or investment advice and should not be interpreted as such. Any decision to purchase or sell Digital Assets is the exclusive decision of the User, and the Company will not be responsible for any loss suffered as a result of that decision.


10.1. Through the Site, the User may issue Instructions to make withdrawals of their assets. The User accepts and declares that this operation is not the responsibility of the Holder but is carried out by the payment provider.

10.2 The User acknowledges and accepts that withdrawals made in Digital Assets will be sent to the Wallet specified in the withdrawal instruction, and some Wallets may require additional information to process the transaction. Therefore, in case this additional information is required, the User must provide it in the withdrawal request when applicable.

10.3 The User is solely responsible for ensuring the accuracy of the information included in the withdrawal instruction, including but not limited to account number, bank account number, Wallet address, destination tag, and any other confidential or non-confidential information requested, depending on the type of withdrawal requested by the User. The User accepts that they cannot cancel any withdrawal instruction once it has been initiated.

10.4 The User declares that they understand and accept that the Holder does not guarantee the timing of the withdrawal of assets, which may be delayed or not available due to reasons not attributable to the Company.

10.5 In the event that the User does not provide a valid or enabled bank account, or if the account is provided with an incorrect or incomplete account number, incorrect currency, or any other reason that would prevent the proper execution of the operation, the withdrawal cannot be carried out until the necessary requirements are fulfilled. Furthermore, the User acknowledges and accepts that if they provide an account of any kind belonging to one of the countries not within the ones specified in section 1.1 "Restricted Jurisdictions," the transfer will not be executed or received.

10.6 The Holder will not be liable in the event that the User is temporarily unable to withdraw their funds because the receiving bank and/or financial institution and/or exchange requests additional information, supplementary documentation, or for any other reason initiated by the receiving entity. The User is solely responsible in the contractual relationship they maintain with the banking entity or virtual wallet to which they send their funds for withdrawal.

10.7 The Company reserves the right to freeze account balances and prevent transfers to third parties by Users in the event that any type of judicial requirement or government agency request is received.

System Failures

11.1 The Company is not responsible for any damage, harm, or loss suffered by a User caused by system failures, server failures, or internet connection issues, nor will it be liable for any viruses, trojans, spyware, malware, and/or intrusive software that may infect the User's equipment as a result of accessing, using, or examining the Site, or due to any transfer of data, files, images, texts, or audio content contained therein. Users cannot attribute any responsibility or claim compensation due to damages resulting from technical difficulties or failures in the systems or internet connection. The Company does not guarantee continuous or uninterrupted access and use of its Site. The system may eventually be unavailable due to technical difficulties, network failures, or any other circumstance beyond the control of the Holder; in such cases, efforts will be made to restore it as quickly as possible, without this implying any kind of responsibility to the Holder or its related or controlled companies. The User accepts and acknowledges that emails sent are not secure and releases the Company from liability for any damage the User may suffer from sending or receiving emails from the Site over the Internet.

Site Employees

12.1 Employees in a dependent employment relationship with the Company may use the Site strictly in accordance with these Terms and Conditions. It will be understood that they use the Site for personal purposes and under no circumstances on behalf of the Holder or any of its related or controlled companies. For this reason, neither the Company nor any of its related or controlled companies are responsible for the contacts they make. Site employees are subject to these Terms and Conditions under the same conditions as any User of the Site. To use the Site, employees must provide their personal email address and personal address, not their work address at the Company.


13.1 For the provision of services through the platform, the Company will charge the User a commission depending on the payment method used in the transaction. The equivalent amount of the commission will be deducted by the Company from the account balance of each User simultaneously at the close of each transaction. It is expressly established that the Company may unilaterally modify the commissions that apply to different transactions at any time. Any changes in the commission structure can be viewed by the User on the "Eluter" site. The use and operation through the Site after the modifications have been notified will be understood as acceptance of the new commission structure.


14.1 The User agrees to defend, indemnify, and hold harmless the Holder of the Site, related companies, its directors, employees, and representatives from any charges, including but not limited to any legal and/or extrajudicial actions, resulting from the use that Users make of the Site, or from any infringement on their part of these Terms and Conditions. The User shall bear the legal expenses or any other nature in which the Holder of the Site, related companies, its directors, employees, and representatives may incur. To this end, the Holder of the Site will promptly notify the User of any demands, actions, or processes.

Duration and Termination

15.1 The provision of the Site service and other contents and/or services has, in principle, an indefinite duration. Nevertheless, the Holder is authorized to terminate and/or suspend the provision of services through the Site and/or any of the contents and services at any time, without the need to invoke any cause to the User. When reasonably possible, the Site will communicate the termination or suspension of the provision of services through the Site and/or through the sending of email, at the choice of the Holder. Such suspension and/or termination shall in no way give rise to the right of the User to claim damages and/or losses that the suspension and/or termination of the Site may cause them.

15.2 The User can request the closure of their account (account closure) via email to, solely from the email address with which they registered, or via valid certified mail to the legal address of the Company, detailed in these Terms and Conditions, and indicating the intention to close the account. The Company reserves the right to request evidence and/or additional information in order to verify the accuracy of the information provided and/or the request made by the User. Once such a request is considered valid, the Site will proceed to close the account and delete the access credentials, which means that the user will not be able to access again. The account status will be changed to Closed. The ID and email associated with that account will remain blocked, meaning they cannot create a new account for those parameters. Transaction information will be kept for the entire life of the Site, as it is structural information, and user-specific information will be kept as a report, as a backup, for a period of at least two consecutive years from the moment of closure, or for the time that the Company considers necessary or relevant for the purposes for which it has been collected.

Use of Cookies and Similar Technologies

16.1 Users and/or visitors of the website owned by the Holder and named "Eluter" acknowledge and accept that it may use tracking systems and/or similar technologies or those that serve a similar function, such as those listed below in a non-exhaustive manner:

Cookies: These are small files that are installed in the storage site of the computer or device used by the user and/or visitor of the site, with a limited duration in time that helps customize services. Additionally, the Holder through its website and/or "Eluter" app may offer certain functionalities that are only available through the use of cookies. Cookies are used to understand the interests, behavior, and demographics of those who visit or use the website and thus better understand their needs and interests and provide better service or provide related information. The User acknowledges, accepts, and gives their irrevocable consent for the Holder to also use the information obtained through cookies to analyze the pages browsed by the user and/or visitor of the site, as well as their searches conducted, to improve and/or personalize commercial and promotional initiatives, create news, advertising, or promotions, interest banners, and enhance their content offerings; cookies can also be used to track and verify registrations and validation levels, as well as to promote and enforce the rules and security of the "Eluter" web platform. The Holder may also include cookies in emails sent to registered users on the "Eluter" platform and/or app to measure the effectiveness of their promotions and advertising campaigns. It is established that the installation, permanence, and existence of cookies on the user and/or visitor's computer or device depend on their exclusive will and can be removed from their computer or device whenever they wish. To learn how to remove cookies from the system, it is necessary to review your browser's settings.

Internet Protocol Address Registration: The Holder uses an internet protocol address registration system that allows knowing the location of users and/or visitors to the site in order to provide better service and provide related information, as well as to improve and/or personalize commercial and promotional initiatives, create news, advertising, or promotions, interest banners, enhance their content and articles offerings, and, on the other hand, to promote and enforce the rules, regulations, provisions, and security established by the FATF and its member states. By accessing the "Eluter" web platform and/or app, the user and/or visitor of the site acknowledges and accepts that such a system will be used.

Single Pixel: It is an electronic image (also known as a transparent pixel) placed in the code of a web page for purposes similar to cookies. Additionally, a single pixel is used to measure traffic patterns from users and/or visitors of the site to another with the aim of maximizing the flow of traffic through the web. The user and/or visitor of "Eluter" acknowledges and accepts that the Holder may use a tracking system through the use of single pixels.

Pointer Tracking System: To analyze and improve the usability of the site, the Holder of the "Eluter" platform and/or app may also use systems or tracking services of mouse pointer movement as well as other user tracking systems on their site. The user and/or visitor of "Eluter" acknowledges and accepts that the Holder may use this mouse pointer tracking system as well as other similar tracking systems. All information requested and/or collected through these tracking methods will be treated with strict confidentiality and can only be disclosed upon an express request from a competent judicial entity.


17.1 The following documents are an integral part of these General Terms:

Specific Terms and Conditions for Argentine Residents

Privacy Policy

Jurisdiction and Domicile

18.1 These Terms and Conditions are governed and interpreted according to the laws of the State of Delaware, USA. Any dispute arising from these terms will be subject to the exclusive jurisdiction of the courts of that State. In the event that any clause of these Terms and Conditions is declared null and void, such nullity will not affect the validity of the remaining clauses, which will maintain their full validity and effect. For all purposes arising from these Terms, the Holder establishes their domicile at 8 The Green, Ste A, city of Dover, state of Delaware, USA.


These specific terms and conditions (hereinafter referred to as the "Specific Terms") are applicable to any person of Argentine nationality over 18 years of age ("Argentine User") who wishes to use the Services available on the "Eluter" site.

Payment Account

Once the User has successfully created an account according to the requirements established by the Site, the Argentine User will be assigned a payment account and a Uniform Virtual Key (CVU) included in their Account.

Payment service provider offering payment accounts

The Holder provides payment account (CVU) services through the company Propago SRL, which is limited to offering payment services and is not authorized to operate as a financial entity by the Central Bank of the Argentine Republic. Legal currency funds deposited in the account held by the User on "Eluter" do not constitute deposits in a financial entity, nor do they have any of the guarantees that such deposits may have under the applicable legislation and regulations on deposits in financial entities. The User acknowledges and accepts that Propago SRL will maintain the funds of the Unique Virtual Account in bank accounts of Argentine financial system banks of its choice.


Users can deposit Argentine pesos into their Account registered in "Eluter" as a result of: (i) collection operations, (ii) transfer operations, and (iii) through enabled cards and extrabanking collection networks. Funds will be credited to the Account according to the settlement deadlines and mechanisms and rules determined on the Site and in these Terms and Conditions and/or third-party providers and as established in the regulations on "National Payment System. Transfers" and "National Payment System - Transfers - Complementary Rules" of the Central Bank of the Argentine Republic (BCRA).


By using the "Deposit," "Send," and "Buy/Sell" buttons on the Site, it is understood that the User generates a Request, constituting this a mandate and irrevocable instruction for the purpose of the Holder and/or the providers that the Holder employs, to carry out operations on behalf and by the order of the User. Each Request must indicate, among other data, the amount of funds to be made available (according to the options available on the Site) and the necessary details based on the type of operation required.

The User may use the credited funds in their Account to carry out the operations described in accordance with the provisions of these Terms and the available Services.

The User agrees, accepts, and authorizes the receipt of funds sent by other Users (or non-Users from payment accounts or virtual accounts or external bank accounts, including, but not limited to, transfers made by providers or operators of other accounts) to their Account and to debit any applicable charges.


For security reasons and in compliance with anti-money laundering and counter-terrorism financing regulations ("AML/CFT"), the Holder may pause the status of any User's Account, causing the funds to remain on hold for a reasonable period until the conditions that gave rise to suspicions and/or alerts established by the FATF and/or any of its member states are evaluated.


Transfers to payment or bank accounts that are not owned by the User requesting the transfer may be subject to limits imposed by current regulations (especially the communications and texts ordered by the BCRA and anti-money laundering and counter-terrorism financing regulations, "AML/CFT"), either for security reasons or for any other reason.

Declaration of Argentine Users

By submitting any Request, the User declares that it does not infringe any applicable law, nor is it for a service, sale, or transmission that is prohibited by law or the Terms and Conditions, including but not limited to: (a) gambling or betting, which is prohibited by current regulations; (b) arms trafficking, human trafficking, animal trafficking, etc.; (c) money laundering or terrorism financing; (d) pornography, prostitution, or pedophilia; and/or (e) any activity that may be considered fraudulent, illegal, or suspicious of being so. The User will not use the Services to transmit material that constitutes a crime or that may give rise, directly or indirectly, to civil liabilities or that violate these Terms and Conditions.

The use of the Account to carry out any Requested operation on behalf and by the order of a User for their own benefit and/or between two or more Users that could be considered or understood as cash advance or loan is absolutely prohibited.

If the Holder believes that there is suspicion or indication of the use of the Account for any activity prohibited by law or the Terms and Conditions, it may reject, cancel, or suspend a Request and/or temporarily block access and use of an Account and/or the use or availability of functionalities and/or permanently cancel an Account. In such cases, the User will be liable for the damages that may have been caused to the Holder, its controlling entities, controlled entities, subsidiaries, officers, employees, directors, agents, and/or employees, for which purpose the Holder reserves the right to initiate any legal or extrajudicial actions it deems appropriate.

Absence of Interest. Fees. Charges.

Funds available or pending settlement in the Account owned by the User on the Site do not generate interest for the Users. The User may use the available funds at any time to carry out the Requested operations described in the Terms once they are credited to their Account according to the deadlines, mechanisms, and rules determined on the Site and in these Terms and Conditions.

By using the Services, the Developer may charge the User a fee (the "Fee") each time they receive funds in their Account and/or make requests for deposits or withdrawals from their Account, under certain conditions. The Fees will be duly informed to the User and will be aligned with the commercial rules established in the "NATIONAL PAYMENT SYSTEM - TRANSFERS - COMPLEMENTARY RULES" compendium of Communications, as well as with any other complementary regulations that may apply. Consequently, the User authorizes the Holder to deduct and retain the Fees or any other amounts due from the available funds in their Account. Likewise, the User authorizes the Holder to deduct and retain from the available funds in their Account any amounts owed to companies related to those with whom the Holder has a commercial agreement in this regard, as well as to any provider of products and services whose contracting was carried out as established in the heading. It is clarified that the Holder will inform the User of the companies that fall under this category.

Security and Confidentiality.

The User must keep their electronic device (notebook, PC, tablet, cellphone, and/or any other device that allows access to the Account) in a secure place and with mechanisms that restrict access to the applications and functionalities of the device. It is the User's obligation to prevent, at all times and with the utmost care, third parties from accessing their Account on Eluter. Users will be solely and exclusively responsible for all Requested operations carried out from their respective Account, email accounts, and/or phone numbers. Users undertake to immediately notify the Holder through the designated channels of any unauthorized use of their Account, as well as unauthorized access or attempted access by third parties.

The User releases the Holder from all liability related to (i) Requested operations that are not carried out due to suspicions of financial crimes, (ii) Requested operations carried out from their electronic device (notebook, PC, tablet, cellphone, and/or any other device that allows access to the Account), (iii) Requested operations carried out by unauthorized third parties unless the User has blocked the Account after a situation of theft, robbery, or loss of the device. In the event of theft, robbery, or loss of the device, the User must immediately report this event to the Holder through the designated channels of attention so that the Holder can carry out blocks and necessary actions to prevent access to the Account. If the User neglects this commitment, they may be held responsible for operations carried out by third parties.

The User must keep their email account updated at all times so that the Developer can carry out the necessary security procedures for the provision of the Services, and/or to be able to notify any communication and/or decision that is necessary.

The Holder has implemented technical and organizational measures specially designed to ensure the User's Personal Data in case of accidental loss and unauthorized access, use, alteration, or disclosure. However, the Holder cannot guarantee that unauthorized third parties will not be able to overcome these measures or use the User's Personal Data for improper, unlawful, and/or fraudulent purposes. The User acknowledges that they provide their Personal Data at their own risk.

Modifications of the Terms and Conditions

The Holder may modify the Terms at any time. It will notify the changes to the User by publishing an updated version of the Terms with the date of the last modification. All modified terms will come into effect upon their publication. The modified Terms will apply to all Requests made after the User's notification.

User Declarations

In compliance with the provisions of the United States Foreign Account Tax Compliance Act (FATCA), the User declares, under oath, that: (a) they are not a U.S. person (citizen and/or resident); nor (b) are acting on behalf and representation of a U.S. person; (c) in the event of being a person of U.S. nationality, they undertake to cooperate with the Holder and provide all required information to facilitate the Developer's provision of information about them and/or their Account to the United States Internal Revenue Service (IRS).

For the purposes of the exchange of financial account information of the Organisation for Economic Co-operation and Development (OECD), the User declares, under oath, to have a fiscal domicile in the Argentine Republic.

The User acknowledges and accepts that the Holder is committed to conducting its business ethically and avoiding any corrupt practices, aligning its actions at all times with the provisions of Law No. 27.401 on the Criminal Liability of Legal Entities.


The User expressly opts for the documentation and information related to these Terms provided by the Holder to have, unless expressly stated otherwise, electronic support. In any case, the User may make copies, even in physical format, of the documentation and information provided by the Holder regarding these Terms. The User irrevocably authorizes the Holder and/or their designees to record the User's Requested operations related to the Services and to use these recordings as evidence before administrative and/or judicial authorities. The issued records will be considered sufficient proof of compliance with the instructions and Requests and replace the need for any receipt, and are fully opposable to the User. For this purpose, the User and the Holder agree to give evidentiary value to the records issued as a result of approvals or instructions given by the User, to the extent established by current legislation.