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Terms & Conditions

1. Introduction

1.1. What is Pasa?
Pasa is a United States–based platform operated by FINAX GLOBAL LLC, where you can access the following Services related to a variety of Digital Assets: earn, send, request payments, and convert currency. You can use Pasa’s Services through our mobile application (“App”), which is available for both iOS and Android devices.

1.2. Who are we?
The Pasa Platform is provided by FINAX GLOBAL LLC, a limited liability company incorporated under the laws of the State of Florida, United States, and registered in the State of Florida under Document Number L25000246231.

On the Pasa Platform, Services are offered exclusively by FINAX GLOBAL LLC.

1.3. We are not a bank
The Pasa Platform is not chartered as, nor licensed to operate as, a bank, credit union, or other depository institution under the laws of the United States or any state thereof, including the State of Florida. Consequently, the Federal Deposit Insurance Corporation (“FDIC”) deposit insurance and the Securities Investor Protection Corporation (“SIPC”) protection do not apply to any Services offered through the Pasa Platform.

We are also not a “money services business” or “crypto asset service provider” as defined under U.S. law unless otherwise expressly stated, and we are not registered as such with the Financial Crimes Enforcement Network (“FinCEN”) or any state financial regulator for the provision of the Services described herein.

2. Language in these General Terms and Conditions

2.1. General
We want our General Terms and Conditions to be clear. Therefore, we write them as simply as possible. However, these Terms and Conditions address legal topics, which sometimes require the use of legal terminology. If anything is unclear to you, you may call us, email us at support@getpasa.com, or contact us through the chat function in our App. Our contact details are available on our Website, in our App, and at the end of this document.

2.2. Definitions
Some words or abbreviations in these General Terms and Conditions are capitalized. We do this to indicate that such a word has a specific meaning in these General Terms and Conditions. Below is a list of the meanings of the capitalized words used herein.

We also explain in this list who we mean by “we” (or “us”/“our”) and who we mean by “you” (or “your”/“yourself”). However, in these General Terms and Conditions, we write these words in lower case for easier reading.

Account: the digital record that provides Users with one or more cryptographic private and public key pairs on the Stellar Network, together with a graphical interface allowing Users to view information about their Stellar Network account and to generate, sign, and submit transactions on the Stellar Network. After we have accepted a User as a customer, the User can access Services via the Account and make use of any other possibilities offered to Users by the Pasa Platform.

Anchor: a participant on the Stellar Network that issues Stablecoins or other Digital Assets on the Stellar Network and offers eligible persons the ability to exchange fiat currency or other real-life assets for Digital Assets, or to exchange Digital Assets for fiat currency or other real-life assets.

App: the mobile application (but not the Website), released by or with the permission of FINAX GLOBAL LLC, which allows the use of the Pasa Platform. There are two versions of the App: one for iOS and one for Android.

CFTC: the U.S. Commodity Futures Trading Commission, an independent agency of the United States Government that regulates derivatives markets, including futures, swaps, and certain kinds of Digital Asset-related products.

DEX: a decentralized exchange on the Stellar Network.

Digital Assets: virtual currency or other digital representations of value as defined under applicable U.S. federal law and the laws of the State of Florida.

FDIC: the Federal Deposit Insurance Corporation, an independent agency of the United States Government that insures deposits in U.S. banks and savings associations.

FINAX GLOBAL LLC: the limited liability company incorporated under the laws of the State of Florida, with its principal place of business at 12550 Biscayne Blvd., Suite 218, North Miami, FL 33181, United States, registered with the Florida Division of Corporations under Document Number L25000246231.

General Terms and Conditions: this document.

Key Recovery Services: a service that dispenses Digital Asset public and private keys to requesters for use as backup keys in MultiSig Wallets, as further described under Pasa Wallet credentials and Key Recovery Services.

KRSP: Key Recovery Service provider.

MultiSig Wallet: a digital wallet that operates with multisignature addresses. This means that it requires more than one private key to sign and authorize a transaction in Digital Assets, or, in some cases, that several different keys can be used to generate a signature.

OFAC: the Office of Foreign Assets Control of the United States Department of the Treasury, which administers and enforces economic and trade sanctions.

Pasa Platform: the platform, accessible through the Website or the App, through which Users can access Services.

Pasa Wallet: a graphical user interface allowing you to view information about your non-custodial wallet on the Stellar Network and generate, sign, and submit transactions to the Stellar Network.

Recovery Key A: a private key stored by FINAX GLOBAL LLC, with a weight of 10.

Recovery Key B: a private key stored by a KRSP, with a weight of 10.

Recovery Keys: Recovery Key A and Recovery Key B.

SEC: the U.S. Securities and Exchange Commission, an independent agency of the United States Government that enforces securities laws and regulates the securities industry.

Services: earn, send, request payments, and convert currency with respect to Digital Assets.

Stablecoin: a type of Digital Asset that purports to maintain a stable value by reference to the value of one or more fiat currencies that are legal tender, one or more commodities, or one or more other Digital Assets, or a combination of such assets.

Stellar Network: a distributed ledger network powered by an open-source protocol, the reference implementation for which is found here: https://github.com/stellar/stellar-core.

Third Party Service Provider(s): other websites, applications, content, or resources accessible through the World Wide Web.

User: a consumer or company who has been accepted by us as a client and is using an Account on the Pasa Platform.

User Agreement: the agreement concluded between a User and FINAX GLOBAL LLC, to which these General Terms and Conditions apply.

User Key: your private key, which is encrypted and stored locally on your phone, possessing a weight of 20.

we (and “us”/“our”): FINAX GLOBAL LLC.

Website: the website accessible via https://getpasa.com/.

XLM Reserve: the reserve held by each Pasa Wallet to cover Stellar Network transaction fees for transactions initiated via the Pasa Wallet, and the minimum reserves necessary for maintaining and adding trustlines or signers to the Stellar Network account tied to your Pasa Account.

XLM: the native Digital Asset of the Stellar Network (also known as Lumens).

you (and “your”/“yourself”): you as a User of the Pasa Platform.

3. When do these General Terms and Conditions apply?
These General Terms and Conditions always apply when you use the Pasa Platform. These General Terms and Conditions also apply if you only visit the Website or download the App. They further apply when you contact us about anything related to the use of the Website, the App, or the Pasa Platform.

3.1. Your User Agreement with us
You can only use the Pasa Platform with our permission. By registering an Account, you are requesting our permission to use the Pasa Platform. Our permission is granted when we accept you as a client. Accepting you as a client creates a User Agreement between you and us.

Our permission to use the Pasa Platform is subject to conditions. Those conditions are described in these General Terms and Conditions. We may also require certain actions to be taken, or specific information to be provided, on the Website or in the App in order to use the Pasa Platform. This is to ensure that the Pasa Platform continues to operate efficiently and securely.

3.2. Amendment of the General Terms and Conditions
We may amend the General Terms and Conditions and the operation of the Website and App from time to time. For example:

  • if applicable U.S. federal, state, or local law changes;

  • to adapt our Services to new technical developments;

  • to improve the organization of our business.

If we make changes, you may close your Account on the Pasa Platform at any time. If we wish to change the General Terms and Conditions, we will send you a notification at least two (2) weeks in advance. If you continue to use the Pasa Platform after that period, it means that you agree to the amended General Terms and Conditions, and they will apply to you.

3.3. All people involved and all Accounts
The General Terms and Conditions apply to all Services offered on the Pasa Platform. There may be other service providers offering Services on the Pasa Platform in the future. Or we may sell or transfer our business to another company in the future. In that event, the General Terms and Conditions will also apply to the Services of those other companies and your dealings with them.

You may not have more than one Account on the Pasa Platform. If you do, it constitutes a violation of the General Terms and Conditions. However, even if an Account is registered in violation of the General Terms and Conditions, we may still invoke these General Terms and Conditions against you.

4. Who is eligible to use the Pasa Platform?
The Pasa Platform is only for individuals who are legally permitted to use the Services offered by the Pasa Platform under the laws of the United States, the State of Florida, and their country of residence.

4.1. High-risk jurisdictions and jurisdictions under increased monitoring
In principle, we offer the Pasa Platform worldwide, except for countries that have been designated as high-risk jurisdictions or jurisdictions under increased monitoring by the Financial Action Task Force (FATF) and/or the United States of America.

At the time of these General Terms and Conditions (version 1.0), the most recent designations can be found here:

  • High-risk jurisdictions (March 2022): Democratic People’s Republic of Korea, Iran.
    Source: FATF, “High-Risk Jurisdictions subject to a Call for Action – March 2022”, fatf-gafi.org.

  • Jurisdictions under increased monitoring (March 2022): Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Mali, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, Uganda, United Arab Emirates, Yemen.
    Source: FATF, “Jurisdictions under Increased Monitoring – March 2022”, fatf-gafi.org.

4.2. Sanctions lists
In principle, we offer the Pasa Platform to any adult person with legal capacity, except for persons or entities subject to sanctions imposed by the United Nations, the United States, and/or any other applicable sanctions authority.

At the time of these General Terms and Conditions (version 1.0), the most recent sanctions designations can be found here:

  • United Nations Sanctions (last update 13 June 2022): United Nations Security Council Consolidated List.
    Source: United Nations Security Council, “United Nations Security Council Consolidated List”, un.org.

  • United States Sanctions (last update 6 June 2022): Office of Foreign Assets Control (OFAC) Sanctions List.
    Source: U.S. Department of the Treasury, “Specially Designated Nationals and Blocked Persons List (SDN)”, treasury.gov.

4.3. You must be an adult person and you must have legal capacity
You must be at least 18 years old to use the Pasa Platform. If the laws of your country of residence impose a higher minimum age to conduct transactions with Digital Assets or to access other Services on the Pasa Platform, you may not use the Pasa Platform until you have reached that minimum age.

You may only use the Pasa Platform if you have full legal capacity, meaning that you are legally permitted to manage your own Digital Assets. You may not use the Pasa Platform if:

  • you are a minor under the laws of your country of residence;

  • you are declared bankrupt;

  • you are subject to a formal debt restructuring proceeding;

  • you are under guardianship, conservatorship, or any similar legal arrangement.

You may not use the Pasa Platform if you are subject to any legal restriction under the laws of your country of residence that prevents you from making independent decisions regarding your assets.

4.4. You must comply with the law that applies to you
In some jurisdictions, trading or using Digital Assets is prohibited. If you reside in such a country, or if you hold citizenship in a country that by law prohibits its citizens from trading Digital Assets or using similar Services, you are not allowed to use the Pasa Platform.

At the time these General Terms and Conditions (version 1.0) take effect, use of the Pasa Platform is prohibited for individuals from countries designated as high-risk jurisdictions or jurisdictions under increased monitoring by the FATF or the United States of America (as set out above under “Who is eligible to use the Pasa Platform?”).

4.5. You are only allowed to use the Pasa Platform for yourself
Only the individual whose Account is registered may use the Pasa Platform. You may not use the Pasa Platform to trade Digital Assets or perform any other Service on behalf of another person or entity.

You may not voluntarily use the Pasa Platform for the benefit of anyone else.

5. This is what you promise to us if you use the Pasa Platform

5.1. Representations and warranties
If you register an Account on the Pasa Platform, you represent and warrant to us:

  • that you have read and agree to these General Terms and Conditions, as amended from time to time;

  • that you are at least 18 years old and meet the minimum legal age required in your country of residence to enter into a binding User Agreement with us;

  • that you understand and accept the risks associated with holding, transferring, or trading Digital Assets;

  • that you have full legal capacity to act independently and to manage, control, and dispose of your assets and entitlements;

  • that all information and documents you provide to us are true, accurate, and complete;

  • that all Digital Assets or funds you deposit or use on the Pasa Platform are your property and have been lawfully acquired by you;

  • that you will only create one Account;

  • that you will use the Services solely for yourself and not on behalf of any third party, unless you have obtained prior written approval from Pasa;

  • that you are responsible for all activities and transactions that occur under your Account, whether or not you are aware of them;

  • that you will not use the Pasa Platform for any unlawful, prohibited, or fraudulent activity under applicable U.S. federal law, State of Florida law, or the laws of your country of residence;

  • that you will comply with all terms and conditions of use of the Pasa Platform and only use it for its intended purposes;

  • that you will follow all lawful instructions given by our authorized staff;

  • that you meet all eligibility requirements set forth in these General Terms and Conditions.

5.2. Indemnity
You agree to indemnify and hold harmless FINAX GLOBAL LLC (operating as Pasa), its officers, directors, employees, and agents, from and against any and all claims, damages, liabilities, losses, costs, and expenses (including reasonable attorneys’ fees) arising out of or related to:

(i) your use of the Pasa Platform in violation of these General Terms and Conditions and/or in a manner inconsistent with its intended purpose;
(ii) any false, misleading, or inaccurate information or documents you provide to us for identity verification or any other reason; and/or
(iii) your breach of one or more of the representations and warranties listed above.

“Indemnification” means that you must compensate us for any losses or damages caused by the above events. It may also require you to take reasonable steps, at our request, to help prevent or mitigate potential damage.

6. How do I start on the Pasa Platform?

6.1. Registration of an Account
To use the Pasa Platform, you must first register for an Account in order to access the Services.

6.2. Private key as a password
When you register an Account, you will be provided with a cryptographic private key and a corresponding public key. Your private key functions as the secure credential to access your Account. Because our Services enable financial transactions, it is essential that you store and protect your private key securely and never share it with anyone. Loss or compromise of your private key may result in the permanent loss of access to your Digital Assets.

6.3. Client rejection
By applying to register an Account, you are requesting that we accept you as a client and grant you permission to use the Pasa Platform. We may, at our sole discretion, decline to accept you as a client if:

  • you fail to provide all information or documents we request, or take an unreasonably long time to provide them;

  • we detect indications that the information or documents you provided are false, misleading, or incomplete;

  • we determine that you do not meet the eligibility requirements for using the Pasa Platform;

  • our identity verification process determines that we are prohibited by applicable law or regulation from accepting you as a client.

If we choose not to accept you as a client, we are not obligated to disclose the specific reason for our decision.

7. What if my situation changes?

7.1. Relocating
If your country of residence changes, or if any other information you have provided to Pasa becomes outdated or inaccurate, you must update your Account information immediately.

7.2. Other changes
If there are any other changes to your personal, financial, or legal circumstances that may be relevant to us or affect your use of the Pasa Platform, you must notify us without delay.

7.3. Bankruptcy, debt restructuring and similar issues
You must inform us immediately if you lose power of disposition. This includes situations where:

  • you are declared bankrupt;

  • you are subject to statutory debt restructuring for natural persons;

  • you are placed under (protective) guardianship;

  • you are subject to an equivalent proceeding under the laws of your country of residence.

You must also notify us without delay if you have debts and intend to resolve them by proposing a settlement to your creditors.

You can notify us of such changes by sending an email to info@getpasa.com.

If we become aware that any of these circumstances apply to you, we may immediately block your Account, whether or not you have informed us. We are not required to give you advance notice of this action.

7.4. General
If any change in your situation causes you to no longer meet the eligibility requirements for using the Pasa Platform, we may terminate your User Agreement without prior notice.

8. Services

8.1. Pasa Wallet
The Pasa Platform provides you with an Account featuring one or more cryptographic private and public key pairs on the Stellar Network, along with a graphical user interface that allows you to view information about your Stellar Network wallet and to generate, sign, and submit transactions to the Stellar Network.

8.2. Use of the Stellar Network
The Stellar Network is not part of the Services as described in these General Terms and Conditions. However, the Pasa Wallet enables you to perform certain actions and activities on the Stellar Network. A Stellar Network account allows its holder to hold and transfer Digital Assets, conduct certain transactions, interact with smart contracts, and otherwise transact via the Stellar Network.

The Stellar Network operates through a network of independent servers and is not controlled by us or by any other single entity. We do not and cannot guarantee the successful operation, up-time, security, or proper functioning of the Stellar Network.

Because we do not control the Stellar Network, we cannot influence or prevent the activities of you or of third parties who may develop applications, validate transactions, or otherwise interact with the network. We cannot prevent, reverse, erase, hide, fix, or otherwise alter any transaction submitted to the Stellar Network. All activity and data on the Stellar Network are permanent and public.

Any access to or use of the Stellar Network by you is entirely at your own risk. We bear no responsibility or liability for your use of the Stellar Network, including (but not limited to) losses, damages, or harm arising from:

  • transactions sent to incorrect Stellar addresses,

  • incorrectly constructed transactions,

  • network or software failures,

  • unauthorized access to accounts,

  • legal or regulatory issues, or

  • fraud by third parties.

8.3. Digital Assets
The Pasa Wallet enables you to store, view, transfer, and otherwise interact with your Digital Assets on the Stellar Network. However, we do not guarantee that the Pasa Wallet or its related applications will display all Digital Assets capable of being held in a Stellar Network account. We reserve the sole discretion to determine which Digital Assets from the Stellar Network are displayed in the Pasa Wallet interface.

Neither XLM (the native asset of the Stellar Network) nor any other Digital Asset held in your Pasa Wallet is legal tender, backed by any government, or subject to deposit protection or insurance schemes. The fiat value of XLM or any other Digital Asset may be highly volatile and could lose all value, even if such Digital Assets are intended to track the value of real-world currency.

We do not control, and are not responsible for, the value of any Digital Asset in your Pasa Wallet. We make no representation, warranty, or recommendation, express or implied, regarding the value of any Digital Asset. You are solely responsible for conducting your own independent due diligence before acquiring, holding, or transferring any Digital Asset. Any acquisition of Digital Assets by you or on your behalf is made voluntarily, knowingly, and entirely at your own risk.

We may impose limits on the total value of Digital Assets you may hold in your Pasa Wallet at any time. When such limits are in effect, the quantity and value of Digital Assets shown in your Pasa Wallet interface may differ from the actual quantity and value in your Stellar Network account.

8.4. Pasa Wallet credentials and Key Recovery Services
When creating a Pasa Wallet, the Services generate cryptographic private and public key pairs which together comprise your account on the Stellar Network. When setting up your Pasa Account, you must also enroll in the Key Recovery Services.

Under the Key Recovery Services, each Pasa Wallet is provisioned with three associated private keys, each with the following weights:

  • Your private key, encrypted and stored locally on your phone, with a weight of 20 (User Key).

  • A private key stored by Pasa, with a weight of 10 (Recovery Key A).

  • A private key stored by a Key Recovery Service Provider (KRSP), with a weight of 10 (Recovery Key B).

By using the Pasa Wallet, you agree to create a separate account with the applicable KRSP and to be bound by its terms and conditions. Recovery Key A and Recovery Key B are used exclusively for the Key Recovery Services facilitated by a KRSP, as described here.

Pasa only controls one of the private keys associated with your account on the Stellar Network. We do not possess sufficient credentials to take unilateral action regarding your account or the balances in it. We will never take steps to recover your account unless we receive a request that we reasonably believe originates from you, and which has been confirmed through a phone number or email address you have previously linked to your account.

You must store, outside of the Services, a secure backup of your User Key and all related Pasa Wallet credentials, including (but not limited to) passphrases, mnemonic phrases, identifiers, backup phrases, private keys, and network addresses. If you do not maintain such a backup outside of the Services, you will be unable to access the Digital Assets in your Pasa Wallet on the Stellar Network if the Services or the Pasa Wallet are disrupted, discontinued, or no longer offered.

The Key Recovery Services are provided at our discretion and should not be relied upon as a guaranteed method for fund recovery. They may not function reliably, accurately, securely, or effectively. Pasa or a KRSP may lose, misplace, or otherwise be unable to provide or use Recovery Key A or Recovery Key B at any time, for any reason. We do not maintain, and are not responsible for maintaining, any data on your behalf.

You are solely responsible for the secure storage of any Digital Assets in your Pasa Wallet, your User Key, and any other related private keys in your possession. Under no circumstances will Pasa be liable for the security, control, or access to any Digital Assets, User Keys, recovery keys, or other credentials associated with the Pasa Wallet.

8.5. Pasa Wallet Transactions
The Pasa Wallet provides an interface that enables you to automatically generate, sign, and submit transactions to the Stellar Network simply by using the buttons, links, and other interactive features within the Pasa Wallet. The Pasa Wallet will use the private key information stored locally on your device to sign the transactions you initiate.

To conduct any transaction on the Stellar Network via the Pasa Wallet:
(i) the transaction must include sufficient network transaction fees – denominated in XLM – for the Stellar Network to process it; and
(ii) it must be signed by private key(s) with a total weight of 20.

This means you can conduct transactions solely using your User Key, since it possesses a weight of 20. Neither Pasa nor any KRSP can unilaterally conduct transactions on your behalf, as the Recovery Keys each have a weight of only 10.

Once a Pasa Wallet transaction has been signed with the required weight and submitted to the Stellar Network for confirmation, it cannot be cancelled, reversed, or altered. The Stellar Network itself may suspend, delay, redirect, reverse, or cancel a transaction at any time, for any reason or no reason. Pasa bears no responsibility or liability for any suspension, delay, redirect, reversal, or cancellation imposed by the Stellar Network.

8.6. Fees
The Pasa Platform may charge a small fee for certain Services. When Pasa outsources the investment of Digital Assets to a Third-Party Service Provider to generate yield, Pasa receives the yield and subsequently shares it with Users, retaining a small portion as a service fee. The current yield rates and any applicable fees are published on our Website and/or in the App.

The Pasa Wallet itself does not currently charge a fee for transactions you conduct through the Services. However, we reserve the right to introduce such fees in the future. If we do so, we will display applicable fees to you before you incur them.

Pasa currently provides each Pasa Wallet with a sufficient XLM Reserve to cover Stellar Network transaction fees for transactions initiated via the Pasa Wallet, as well as the minimum reserves necessary to maintain and add trustlines or signers to the Stellar Network account linked to your Pasa Account. In the future, we may discontinue providing such reserves, in which case you will be responsible for paying all Stellar Network transaction fees and maintaining any required reserves.

The XLM Reserve provided may only be used to maintain the existence and functionality of the Stellar Network account associated with your Pasa Account. It cannot be withdrawn, transferred, merged into another account, or used for any other purpose.

9. Third Party Services

9.1. Third Party Service Providers
The Pasa Platform may provide links or integrations to Third Party Service Providers. These are provided solely for your convenience. We do not control the content, availability, or legitimacy of these services and do not warrant, endorse, or take responsibility for any products, services, or resources accessed through them.

We make no express or implied warranties or representations regarding such Third Party Services, their owners or operators, the information they contain, or the suitability of their products or services. You acknowledge that you are solely responsible for — and assume all risks associated with — your use of any third party websites, applications, services, or resources.

9.2. Anchors
Among the Third Party Services, the Pasa Platform may allow you to interact with Anchors on the Stellar Network directly from the Pasa Website or App.

An Anchor is a participant on the Stellar Network that:

  • Issues Stablecoins or other Digital Assets on the Stellar Network; and

  • Offers eligible persons the ability to convert between fiat currency or other real-world assets and the corresponding Digital Assets.

9.2.1. Anchor services
Any services provided by an Anchor — such as converting between fiat currency and Stablecoins — are the sole responsibility of that Anchor, not Pasa. Your use of such services will be subject to the terms and conditions of the Anchor.

Pasa makes no representations, warranties, or endorsements regarding any Anchor’s services and expressly disclaims all responsibility for them. You acknowledge that using Anchor services involves certain risks, including, without limitation:

  • Loss of funds;

  • Loss of access to digital assets;

  • Unavailability of Stellar Network functionality;

  • Software bugs or errors in the Anchor’s systems;

  • Inability to purchase, redeem, or convert Digital Assets;

  • Risks related to the handling or storage of data you share with the Anchor.

Pasa is not responsible for any loss or delay in accessing your Digital Assets when such issues are related to an Anchor’s services. We (or the Anchor) may set limits on the maximum amount of fiat or Digital Assets that you can convert via an Anchor’s services, and such limits may be changed at our sole discretion without prior notice.

9.2.2. Exchange Anchor
Through the Pasa Platform, you may access the Third Party Services of an Exchange Anchor — an entity that allows eligible persons to convert between fiat currency and its corresponding Stablecoin or other Digital Asset. For such conversions, Pasa is not responsible for conducting Customer Due Diligence; this responsibility lies solely with the Exchange Anchor.

Currently, Pasa supports Anclap as an Exchange Anchor. More information about Anclap can be found at: https://home.anclap.com/.

Other Exchange Anchors may be added in the future, but you will not be automatically enrolled in their services without your prior consent.

9.2.3. Yield Providing Anchor
Through the Pasa Platform, you may access the Third Party Services of a Yield Providing Anchor. A Yield Providing Anchor issues Stablecoins on the Stellar Network — for example, a Yield Providing Anchor may issue yUSDC and hold 1 USDC for every 1 yUSDC on platforms that generate yield.

Pasa currently supports Ultra Capital as a Yield Providing Anchor. More information about Ultra Capital can be found at: https://ultracapital.xyz/.

Other Yield Providing Anchors may be added in the future, but you will not be automatically enrolled in the services of any such Anchor without your prior consent.

9.3. Stellar Network DEX
The Stellar Network includes a built-in Decentralized Exchange (DEX). In addition to tracking an account holder’s Digital Asset balances, a Stellar Network account also stores that account holder’s bids and asks across all Digital Asset pairs on the network. The DEX automatically matches bids and asks to enable peer-to-peer exchanges.

While the DEX may be accessible through the Pasa Wallet, Pasa acts solely as a graphical user interface for your convenience. Pasa is not affiliated with the DEX and is not responsible for its functionality, reliability, or security. All DEX transactions occur directly between Stellar Network account holders, without any intermediation by Pasa or other third parties for settlement, matching, exchange, or asset transfers.

Through the Pasa Wallet and related Services, we may offer features to help you trade more efficiently on the DEX. We reserve the right to choose which trading pairs are displayed within the Pasa Services, and we do not guarantee that any particular trading pair will be available or remain available. We may, at our sole discretion:
(i) Require you to provide certain information before granting or continuing access to DEX-related Services; and
(ii) Set limits on the amounts, sizes, or values of DEX transactions available to you through the Services.

10. Risks

10.1. General
When market conditions are favorable, Digital Assets can generate positive returns. However, there are inherent risks associated with Digital Assets, and we may not be able to protect you from those risks. Moreover, not all risks are known, and therefore we cannot warn you about all of them.

For example, the value of Digital Assets can fluctuate suddenly and significantly—such changes may be beneficial or harmful to you.

You may lose your entire deposit.

Another key risk is that Digital Assets, due to their cryptographic nature, are entirely and irrevocably controlled through possession of the private key. While this provides benefits such as privacy, speed, and convenience, it can also be a disadvantage. For example, if a private key is lost or if Digital Assets are accidentally sent to the wrong address or username, we cannot reverse the transaction.

Because these risks are always present when dealing with Digital Assets, you should educate yourself thoroughly before using the Pasa Platform—both on the technical and economic aspects of Digital Assets, and particularly on the risks involved.

You should only use the Pasa Platform for Digital Assets you can afford to lose.

10.2. No retrieval of private keys
The only existing backups of your credentials are held by you and the Key Recovery Service Provider (KRSP). Pasa does not store or have access to your passwords, recovery phrases, private keys, passphrases, transaction history, PIN, or other credentials related to your use of the Services.

We cannot assist you in recovering lost credentials. You are solely responsible for remembering, storing, and securing your credentials in a safe location, out of reach of unauthorized parties. If you lose your credentials, you will lose access to your Pasa Account, your Pasa Wallet, and consequently to your Digital Assets.

10.3. Failure of Third Party Services
You understand that transactions involving the Stellar Network DEX, Anchors, or any KRSP inherently carry risks associated with third parties over which Pasa has no control.

The ability to transact with the DEX, any Anchor, or any KRSP via the Pasa Services does not imply that Pasa endorses, supports, recommends, or makes any representation about such Anchor, the DEX, or the KRSP.

Unless explicitly stated otherwise in these General Terms and Conditions, Pasa disclaims any and all liability arising from:

  • Your use of Third Party Services,

  • Your interactions with third parties, or

  • Any transactions you may conduct with third parties, whether via the Pasa Website or App, the Services, or otherwise.

10.4. Technology risks
You understand that some of the technology supported or made available through the Services is new, untested, and outside of Pasa’s control. Advances in cryptography, or other technical developments—such as the creation of quantum computers—could pose risks to blockchain networks, potentially resulting in the theft or loss of Digital Assets.

Where possible, Pasa intends to update the Services to address advances in cryptography and to incorporate additional security measures. However, Pasa does not guarantee or represent that the system will be completely secure. By using the Services, you acknowledge these inherent risks.

10.5. Cybersecurity risks
Hackers, malicious groups, or organizations may attempt to compromise Pasa’s products and information systems through various means, including but not limited to denial-of-service attacks, side-channel attacks, spoofing, smurfing, malware attacks, or consensus-based attacks. Such risks could result in the complete loss of the Digital Assets held in your Pasa Wallet.

10.6. Application security
Applications on the Stellar Network are based on code, which can contain flaws. You are solely responsible for evaluating any code provided by the Services and for assessing the trustworthiness of any third-party websites, products, smart contracts, or content you access or use through the Services.

10.7. Network disruption
If there is a disruption to the Stellar Network or any other relevant network, Pasa or the Services may be unable to facilitate activity related to your account on the Stellar Network. In such cases, transactions may fail to complete, be partially completed, be executed incorrectly, or be significantly delayed. These risks may cause you to lose all Digital Assets held in your Pasa Wallet. Pasa is not responsible for any loss caused by network disruption.

10.8. Volatility of Digital Assets
Digital Assets are highly volatile due to factors such as adoption rates, speculation, technological changes, and security risks. You could lose the entire value of your Digital Assets. Additionally, the cost of conducting transactions on distributed ledgers can vary and may increase at any time, affecting any activity you carry out on the Stellar Network.

10.9. Regulatory changes
Distributed ledger technologies are subject to ongoing regulatory changes and scrutiny worldwide, including, but not limited to, anti-money laundering (AML) laws and financial regulations. You acknowledge that certain Services, including their availability, may be impacted in the future by one or more regulatory requirements.

11. We may change our activities
Pasa is a private, commercial company. We may decide at our sole discretion:

  • in which countries we do and do not offer the Pasa Platform;

  • which clients we accept as Users; and

  • what Services we offer on the Pasa Platform.

We may also decide to terminate or transfer all or part of our business, or to change, limit, or suspend our activities.

We will announce important changes via email, through the Website, and/or in the App. To stay informed of any changes, it is important that you log in to your Account regularly.

12. Termination of the User Agreement

12.1. Termination by you
You may terminate the User Agreement with us at any time, without the need to provide a reason. No notice period applies.

12.1.1. How does it work?
If you wish to terminate the User Agreement, you must:

  1. Check if there are any Digital Assets remaining in your Account.

  2. If there are still Digital Assets, transfer them to another wallet.

  3. Once your Digital Asset balance is zero, press the ‘Close Account’ button in your Account.

If you have any questions about closing your Account, you can contact us at support@getpasa.com.

12.1.2. Your data
We must retain certain data from your Account for a period after closure, as required by applicable laws. Please refer to our Privacy Statement for more details.

12.2. Termination by us
We may terminate the User Agreement with you without providing a reason. In such cases, we will apply a notice period of four (4) weeks.

12.2.1. Termination for compelling reasons
In certain circumstances, we may terminate the User Agreement immediately and without prior notice, including but not limited to:

  • if you fail to respond to our staff’s questions in a timely manner;

  • if we determine you should have informed us under these General Terms and Conditions but failed to do so;

  • if potential or future Customer Due Diligence reveals facts requiring us to end our relationship with you under applicable law, including anti-money laundering or sanctions regulations.

12.2.2. Disbursement of your Digital Assets
If we terminate the User Agreement, your Digital Assets held in your Pasa Wallet will be transferred to you. We will request the address of the wallet to which we can send your Digital Assets. You must provide this information within 14 days.

If you fail to respond within this period, you will no longer be able to access your Digital Assets through your Pasa Account, but you may still access them using a backup file from another service, as described on our Website.

In certain cases, we may be legally prohibited from transferring your Digital Assets—for example, if they are frozen by a creditor or public authority, or if you are bankrupt, subject to debt restructuring, placed under guardianship, or otherwise deprived of the power of disposition. In such cases, we will handle your Digital Assets in accordance with the law.

12.3. Suspension of our Services
If we have indications that something may be wrong with your Account, we may temporarily block it while we investigate. This may occur, for example, if:

  • you fail to respond to our staff’s questions in a timely manner;

  • we have indications that you may be the victim of fraud;

  • we have evidence that you have provided false or incomplete information;

  • we have evidence that you have used or may be using the Pasa Platform for illegal or unlawful activities;

  • we have indications that you have breached these General Terms and Conditions.

While your Account is blocked, you will not be able to access the Services or close your Account, and you will not be able to transfer any Digital Assets.

13. Limitation on liability
This section sets out our liability if something unexpectedly goes wrong with the Pasa Platform.

Pasa will not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages arising out of or in connection with these General Terms and Conditions, the Services, the Stellar Network, the Pasa Wallet, or any Digital Assets associated with the Services.

We are never liable for:

  • your use or inability to use the Services;

  • the secure storage of your private user keys or other relevant credentials;

  • any changes to, inaccessibility, or termination of the Services;

  • any delay, failure, unauthorized access to, or alteration of any transmission of data;

  • any transaction or agreement entered into through the Services;

  • any activities or communications of third parties;

  • any loss of value of any Digital Asset;

  • any data or material from a third person accessed through the Services;

  • any damages resulting from hacking, hardware failure, or connection failure on which our Services depend.

These limitations apply whether damages arise from use, misuse, or reliance on Pasa or the Services, regardless of any failure of essential purpose or limited remedy, and to the fullest extent permitted by law.

If you are dissatisfied with the Services, your sole and exclusive remedy is to discontinue their use.

Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitations may not apply to you.

14. Situations not provided for in these General Terms and Conditions
There may be situations not covered by these General Terms and Conditions. In such cases, we will carefully weigh your interests against ours and decide how to proceed, and you must comply with that decision—unless otherwise required by law.

We may deviate from these General Terms and Conditions where necessary to ensure the security of the Pasa Platform, to comply with applicable laws, or for any other compelling reason.

15. Choice of law and choice of forum

15.1. Choice of law
Because FINAX GLOBAL LLC is based in the State of Florida, USA, the User Agreement, these General Terms and Conditions, and all related offers, notices, and Services—as well as any dispute or claim arising out of or in connection with them, whether contractual or non-contractual—are solely subject to the laws of the State of Florida, without regard to its conflict of law principles.

We expressly exclude the application of the United Nations Convention on Contracts for the International Sale of Goods (CISG) and any other international treaties that would otherwise apply.

15.2. Choice of forum
We may choose to submit any dispute to the courts located in Miami-Dade County, Florida. If we intend to do so, we will notify you.

If you reside outside the jurisdiction of those courts and would prefer the dispute to be heard in the courts of your place of residence, you have one month from the time we inform you to notify us of your preference. If you do not object within that month, the dispute will proceed in Miami-Dade County, Florida.

16. Communication and complaints

16.1. Communication with you
When you register an Account, you authorize us to send official communications (including legal notices) to the email address you provide in your Account. We may also contact you using other information you have provided if we believe there is a reason to do so, but we are not required to.

We will only use your contact information to communicate with you about the Pasa Platform. For more details, please refer to our Privacy Policy.

An email is considered legally delivered to you once it has been delivered to your email server. It is your responsibility to read your emails regularly. Please note that important messages can sometimes be filtered into spam, junk, or promotions folders by your email provider—it is your responsibility to check these folders.

16.2. Complaints
We want you to be satisfied with our Services. However, if you are not satisfied, you may submit a complaint to us. You can find instructions on how to do this in the complaints procedure available on our Website.

17. Questions?
If you have any questions about these General Terms and Conditions, the Pasa Platform, or any other matters related to us, please contact us:

📧 info@getpasa.com