User Agreement

Welcome to Bumba, a virtual asset trading and custody platform operated by Rules Holdings BVI Ltd., a company incorporated in the British Virgin Islands with registered number 1970684, having its registered office at Craigmuir Chambers, Road Town, Tortola, VG1110.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Agreement. If you do not agree to these terms, you must not access or use our Services.

Bumba is authorized and regulated by the Financial Services Commission ("FSC") of the British Virgin Islands as a Virtual Asset Service Provider (VASP) under license number VASP/24/007, permitted to provide virtual asset exchange and custody services.

To use our Services, you must:

• Be at least 18 years of age (or the age of majority in your jurisdiction)
• Have the legal capacity to enter into a binding agreement
• Not be a resident of any Restricted Location as defined by our policies
• Not be a Restricted Person under applicable sanctions laws
• Complete our identity verification (KYC) process
• Provide accurate and complete registration information

Restricted Locations: Our Services are not available to residents of certain jurisdictions including, but not limited to: United States, Cuba, Iran, North Korea, Syria, Crimea region, and other jurisdictions where virtual asset services are prohibited or require licenses we do not hold.

3.1 Account Creation: You must create an account to access our trading services. You agree to provide accurate, current, and complete information during registration and to update such information to keep it accurate.

3.2 Account Security: You are responsible for maintaining the confidentiality of your account credentials, including your password and any two-factor authentication methods. You must immediately notify us of any unauthorized access or use of your account.

3.3 Account Classification: Users may be classified as either Retail Clients or Professional Clients based on their experience, knowledge, and financial situation. Different protections and services may apply to each classification.

4.1 Service Description: Bumba provides an electronic trading platform for buying and selling virtual assets against fiat currency (BRL) or other digital assets. Our services are execution-only; we do not provide investment advice.

4.2 Trading Hours: Trading is available 24 hours a day, 7 days a week, except during scheduled maintenance periods or emergency suspensions.

4.3 Order Execution: Orders are executed on a best-efforts basis. Prices displayed on the order-entry screen or streamed through the API are indicative only. Actual execution prices may differ due to market movements.

4.4 Market Rules: All trading activities are subject to our Market Trading Rules, which govern order types, minimum order sizes, price limits, and other trading parameters.

5.1 Segregation: Your virtual assets are segregated from Bumba's own assets but may be pooled with other users' holdings in omnibus accounts.

5.2 Third-Party Custody: We utilize Fireblocks, a regulated third-party custodian, to store virtual assets. Assets are held in a combination of "hot wallet" (for operational liquidity) and "cold wallet" (for secure storage) configurations with multi-signature protections.

5.3 Fiat Custody: Fiat currency deposits and withdrawals are processed through our Brazil-based affiliate, Kinetic, which is authorized to handle fiat asset management in accordance with applicable Brazilian regulations.

You agree to pay all applicable fees as set forth in our Fee Schedule, which is available on our website. Fees may include, but are not limited to:

• Trading fees (maker and taker fees)
• Withdrawal fees
• Network/blockchain fees
• Currency conversion fees

We reserve the right to modify our fees at any time with reasonable notice. Continued use of our Services after fee changes constitutes acceptance of the new fees.

8.1 KYC Requirements: You must complete our Know Your Customer (KYC) verification process, which may include providing government-issued identification, proof of address, and source of funds documentation.

8.2 AML Compliance: We are committed to preventing money laundering and terrorist financing. We may monitor your transactions and report suspicious activities to relevant authorities as required by law.

8.3 Account Suspension: We reserve the right to suspend or terminate your account if we suspect any illegal activity, breach of this Agreement, or as required by regulatory authorities.

To the maximum extent permitted by applicable law:

• Our total liability for any claims arising from this Agreement shall not exceed the greater of USD 5,000 or the total fees paid by you in the 12 months preceding the claim
• We shall not be liable for any indirect, incidental, special, consequential, or punitive damages
• We shall not be liable for losses arising from market movements, technical failures beyond our control, or force majeure events

All content on the Bumba platform, including but not limited to text, graphics, logos, icons, images, software, and data compilations, is the property of Rules Holdings BVI Ltd. or its licensors and is protected by intellectual property laws.

You may not copy, modify, distribute, sell, or lease any part of our Services or included software, nor may you reverse engineer or attempt to extract the source code of that software.

11.1 Governing Law: This Agreement shall be governed by and construed in accordance with the laws of the British Virgin Islands.

11.2 Dispute Resolution: Any disputes arising from this Agreement shall be resolved through binding arbitration in accordance with the rules of the BVI International Arbitration Centre, unless otherwise required by applicable consumer protection laws.

11.3 Complaints: If you have a complaint, please contact us through our designated complaints procedure. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 business days.

12.1 Amendments: We may amend this Agreement at any time by posting the revised terms on our website. Material changes will be notified to you at least 30 days in advance. Your continued use of our Services after such changes constitutes acceptance of the amended Agreement.

12.2 Termination: Either party may terminate this Agreement at any time by providing written notice. Upon termination, you must withdraw your assets within the specified period. We may immediately terminate or suspend your account for breach of this Agreement or as required by law.