{"terms_version":"2026-07-12","terms_hash":"0xbd7ded4fe2aa4c21b764c97e98853d3358234182c62a9f08e619aacdfa9406ef","eip712_domain":{"name":"Opcode Terms Acceptance","version":"1","chain_id":1},"representation_text":"Each person who acquires Tokens on any secondary market will be deemed, by such acquisition, to have represented that: (a) they have received and acknowledged the disclaimers and warnings set out herein; (b) they understand the risks associated with each such disclaimer and warning; (c) that they are not then prohibited from acquiring Tokens, as described from time to time at docs.ondo.finance/ondo-global-markets/eligibility (such prohibited persons, \"Prohibited Persons\"); (d) that the Tokens are suitable for them; and (e) that they wish to acquire Tokens issued by the Issuer.","terms_of_use":"# Opcode Terms of Use\n\nLast updated: July 14, 2026\n\nThese Terms of Use (the \"Terms\") are a binding agreement between you (\"you\", \"your\", or the \"User\") and Polymancer Ltd. (\"Opcode\", the \"Company\", \"we\", \"us\", or \"our\"). They govern your access to and use of the Opcode website, web application, application programming interfaces, front ends, and related software (together, the \"Interface\"), and of the swap functionality made available through it (the \"Service\").\n\nBy accessing or using the Interface or the Service, and by signing the acceptance message presented to you through the Interface, you confirm that you have read, understood, and agreed to these Terms and to every document incorporated in them by reference. Acceptance by use and acceptance by signature are each independently sufficient to bind you. Your signed acceptance is produced by your self-custodial wallet and binds the version identifier of these Terms, a content hash of the Terms and of the documents published with them, any attestation you are asked to make, and the time of acceptance. You represent that every value you sign is true. If you do not agree to these Terms in their entirety, you have no right to use the Interface and you must stop immediately.\n\nRead these Terms carefully. Section 1 restricts who may use the Service. Section 2 provides the Interface without warranty, allocates every risk to you, and irrevocably waives any fiduciary duty. Section 5 permits us to refuse, restrict, or terminate your access at our discretion. Section 7 releases us from claims and Section 8 requires you to indemnify us. Section 9 caps our aggregate liability at $100.00. Section 10 requires binding individual arbitration and waives your right to a class action and to a jury trial. The Company would not make the Interface available on any other basis.\n\n## 1. THE INTERFACE\n\nThe Interface is software. It lets you sign an order to exchange a token you already hold for a tokenized stock issued by Ondo (the \"Issuer\"; those tokens, the \"Tokens\"), and it presents that order to independent third parties (solvers) that route and settle the exchange on a public blockchain. Settlement occurs on-chain, from your own wallet, on the authority of your own signature. The Service is gasless from your perspective: network fees are paid or abstracted at the settlement layer.\n\nYour acquisition of a Token through the Interface is a secondary-market acquisition made outside the United States. The Tokens are made available to non-U.S. persons in offshore transactions in reliance on Regulation S under the United States Securities Act of 1933, as amended (\"Regulation S\"). The Company is not the issuer, offeror, seller, underwriter, or distributor of the Tokens, and the Interface is not a primary offering and is not an offer or solicitation where one would be unlawful.\n\nThe Service is non-custodial. Your assets remain in your own self-custodial wallet at all times, whether you reach that wallet through passkey login or by connecting a wallet you control. The Company does not take custody, possession, or control of your funds, your Tokens, or your keys, does not hold client money, is not the counterparty to your transactions, and cannot move, spend, transfer, freeze, or recover your assets. The Company cannot reverse a settled on-chain transaction.\n\nThe Company provides software and nothing more. It is not your broker, dealer, investment adviser, exchange, trading venue, clearing house, custodian, bank, trustee, agent, or fiduciary, it does not solicit transactions, and it exercises no discretion over your assets. Neither these Terms nor your use of the Service creates any such relationship. Any counterparty to a swap is a solver, a market, or the Issuer, never the Company.\n\nThe Interface has not been approved, reviewed, endorsed, registered, licensed, or authorized by any securities regulator, financial services authority, or other governmental body in any jurisdiction, and no such body has passed upon the merits of the Tokens or the accuracy of any information made available through the Interface.\n\n**Eligibility and restricted persons.** Access is limited to eligible persons, and the representations below are conditions of your access. You make each of them when you accept these Terms and again every time you access the Interface or place an order. If any ceases to be true, you must stop using the Interface immediately and any further access is unauthorized.\n\n**You are not a U.S. Person.** You are not a \"U.S. person\" within the meaning of Rule 902 of Regulation S, and you are not acting for the account or benefit of any U.S. person. You are not located in, and will not access the Interface or place an order from within, the United States or any of its states, territories, or possessions. You acknowledge that (a) where persons prohibited from acquiring the Tokens hold, directly or indirectly, in the aggregate 50% or more of the beneficial ownership of, or control over, an entity, that entity may itself be prohibited from acquiring, holding, or redeeming the Tokens, and (b) the Issuer may, in its sole discretion, prohibit any person from acquiring, holding, or redeeming the Tokens where it determines that the activity may violate any applicable law, rule, or regulation (including sanctions restrictions), the governing documents of the Tokens, or the Issuer's own governing documents and policies.\n\n**You are not located in or a resident of a Prohibited Jurisdiction.** You are not a citizen or resident of, are not located in, are not organized under the laws of, and do not have your principal place of business in, any jurisdiction that the Issuer or the Company identifies as prohibited or restricted for the Tokens (each a \"Prohibited Jurisdiction\"). That list is maintained by the Issuer at [docs.ondo.finance/ondo-global-markets/eligibility](https://docs.ondo.finance/ondo-global-markets/eligibility), it may change at any time without notice to you, and it is enforced through the Interface, including by geographic blocking. Determining your own eligibility remains your responsibility.\n\n**You satisfy any investor qualification that applies to you.** Where the jurisdiction in which you are located or resident permits the Tokens to be held only by professional, accredited, qualified, sophisticated, or institutional investors, or applies any equivalent classification, you represent that you satisfy that requirement, that you meet each condition the Issuer specifies for that jurisdiction, and that you can produce evidence of that status on request. Where the Interface asks you to attest to that status, your attestation is signed with your acceptance and forms part of these Terms.\n\n**You are not a sanctioned or blocked person.** You are not, and you are not owned or controlled by or acting on behalf of, any person that is the subject or target of sanctions administered or enforced by any competent authority, including the United States Office of Foreign Assets Control, the United Nations Security Council, the European Union or any of its member states, or His Majesty's Treasury of the United Kingdom. You are not listed on any sanctions or restricted-party list.\n\n**You have full legal capacity.** You are at least the age of majority in your jurisdiction and have the full legal capacity and authority to enter into and perform these Terms. If you use the Interface on behalf of an entity, you represent that you are authorized to bind it, and \"you\" refers to that entity as well as to you personally.\n\nThe access controls applied through the Interface are operational measures taken for the Company's benefit. They are not advice, are not a determination that you are eligible, and their failure or circumvention does not make you eligible.\n\n## 2. NO WARRANTIES\n\nThe Interface and the Service are provided \"as is\" and \"as available\", with all faults and without warranty of any kind. To the fullest extent permitted by applicable law, the Company and its affiliates, and their respective officers, directors, employees, contractors, agents, service providers, and licensors (together with the Company, the \"Company Parties\"), disclaim all warranties, express, implied, or statutory, including any implied warranty of merchantability, fitness for a particular purpose, title, accuracy, or non-infringement.\n\nThe Company Parties do not warrant that the Interface will be available, uninterrupted, secure, or error-free, that any order will be quoted, routed, filled, or settled, that any quote is an executable or fair price, or that any price, valuation, or net asset value shown is accurate, current, or free from delay or error. They make no warranty regarding the Tokens, the Issuer, any solver, oracle, network, or wallet provider, and are not responsible for their acts or omissions.\n\n**You assume all risk.** You use the Interface at your own risk and on your own account, and you accept every risk of the Service and of the Tokens, including total loss. Those risks include the following, which are not exhaustive:\n\n- **Tokenized-securities risk.** The Tokens are a novel instrument whose legal characterization is uncertain and differs across jurisdictions. Your rights are defined by the Issuer's governing documents, not by these Terms, and any redemption is subject to the Issuer's own requirements and discretion.\n- **Smart-contract risk.** The Service relies on smart contracts and other software that may contain bugs or vulnerabilities, and an exploit or failure can cause partial or total loss of the assets involved in a transaction.\n- **Oracle and pricing risk.** Quotes and valuations depend on price oracles and net-asset-value feeds supplied by the Issuer and other third parties, and that data may be delayed, stale, incorrect, or manipulated. A price shown through the Interface guarantees neither execution nor price.\n- **Volatility risk.** The value of a Token can move sharply and without warning, and you may lose some or all of the value of your holding.\n- **Liquidity risk.** No secondary market for any Token is guaranteed to exist or to continue, and you may be unable to sell, exchange, or redeem a Token at an acceptable price, or at all.\n- **Issuer dependency.** The Tokens depend entirely on the Issuer and its continued solvency and operation. The Issuer may change its criteria, refuse issuance or redemption, or impose conditions at its discretion, and any failure by the Issuer can result in loss to you.\n- **Regulatory risk.** The laws that apply to the Tokens, the Issuer, and the Service are unsettled and may change, and any change may restrict, suspend, or end the Service or affect your holdings.\n- **No protection scheme.** The Tokens are not bank deposits and are not money, and they are not insured by any government, deposit-insurance program, or investor-compensation scheme.\n\nYou should commit only assets that you can afford to lose in their entirety.\n\n**No recourse.** You have no recourse against the Company Parties for any loss arising out of or relating to the Interface, the Service, or the Tokens. The Company Parties have no obligation to compensate you, to refund or unwind any transaction, or to remedy any loss, however caused, and no such obligation may be implied.\n\n**No fiduciary duty; irrevocable disclaimer and waiver.** To the fullest extent permitted by applicable law, the Company Parties do not owe you, and expressly and irrevocably disclaim, any fiduciary duty and any duty of care, loyalty, good faith, disclosure, best execution, or suitability, whether arising at law, in equity, by statute, or by course of dealing. You irrevocably waive and release any such duty that might otherwise be found to exist or be imposed. The obligations of the Company Parties are solely contractual and limited to the express provisions of these Terms, and the Company Parties may act in their own interest at all times. Where such a duty may not lawfully be waived in full, it is limited to the greatest extent permitted by law.\n\n**Your keys and your assets are your responsibility.** You are solely responsible for the security of your wallet, keys, passkeys, recovery methods, and devices, and for every transaction signed with them. A transaction signed by your wallet is deemed authorized by you. The Company Parties cannot recover a lost or compromised key or assets sent to a wrong address or approved to a malicious contract, and have no liability for any loss arising out of the compromise of your keys or devices, out of phishing or malware, or out of any transaction you sign.\n\n## 3. PROHIBITED ACTIVITIES\n\nYou must not, must not attempt to, and must not assist any other person to, do any of the following:\n\n- Access or use the Interface if you do not satisfy every eligibility requirement in Section 1, if any representation you make in Section 1 is untrue, or if your access would cause the Company to violate any law.\n- Circumvent or interfere with the geographic blocking or any other access control applied through the Interface, including by using a virtual private network, a proxy, or any other means to disguise your true location or internet protocol address, or by claiming a residence or nationality that is not your own.\n- Provide false or misleading information, or misrepresent your identity, location, residence, nationality, beneficial ownership, eligibility, or investor qualification, including in any acceptance or attestation you sign.\n- Engage in market abuse or in manipulative, deceptive, or fraudulent conduct, including wash trading, spoofing, layering, front-running, insider dealing, or any conduct intended to manipulate a price, a quote, an oracle, a net-asset-value feed, or the settlement of an order.\n- Use the Interface in connection with money laundering, terrorist financing, sanctions evasion, tax evasion, fraud, or any other unlawful activity, or transact with assets that are the proceeds of crime.\n- Exploit or attempt to exploit any bug, vulnerability, or unintended behavior in the Interface, in any smart contract, in the quoting engine, in solver routing, or in the settlement path, including by extracting value from a mispriced quote or an oracle failure, by gaining unauthorized access to any system, by introducing malware, or by probing security without our prior written authorization.\n- Use any bot, scraper, or other automated means to access the Interface, to place a disproportionate load on it, to circumvent a rate limit, or to harvest data from it, except as we expressly permit in writing.\n- Infringe the intellectual-property or other rights of the Company or of any third party, including by copying, modifying, distributing, creating derivative works from, reverse engineering (except where applicable law prohibits that restriction), or decompiling any part of the Interface, or by impersonating any person.\n- Engage in any other activity that violates any law, rule, regulation, or sanctions program, that is intended to defraud, deceive, or harm any person, or that would cause the Company to violate any law or to become subject to any licensing requirement.\n\nWe may investigate any actual or suspected breach and may report conduct to competent authorities. A breach is a material breach of these Terms, it entitles us to terminate your access under Section 5 immediately, and it triggers your indemnity under Section 8. You have no entitlement to any gain obtained through prohibited activity.\n\n## 4. NO PROFESSIONAL ADVICE\n\nNothing made available through the Interface is, or may be relied on as, investment, financial, legal, tax, accounting, or other professional advice, and nothing is a recommendation or an inducement to enter into any transaction or to acquire, hold, or dispose of any asset. Quotes, prices, valuations, net asset values, and market data are provided for general information only, may be inaccurate or out of date, and must not be relied on.\n\nThe Company does not assess whether any Token or transaction is suitable or appropriate for you. It does not know and does not ask about your objectives, circumstances, experience, or financial position, and it performs no suitability, appropriateness, or best-execution assessment. No fiduciary, advisory, brokerage, agency, client, or trust relationship arises between you and the Company by reason of these Terms, your use of the Service, or any communication from us.\n\nYou are solely responsible for determining and paying any tax that applies to you as a result of acquiring, holding, exchanging, or disposing of any Token, and for any related filing obligation. The Company does not withhold, collect, report, or remit tax on your behalf except where required by law. The tax treatment of the Tokens is uncertain and depends on your own circumstances and jurisdiction. You are solely responsible for your own decisions, and you should obtain independent advice from your own qualified advisers before using the Service.\n\n## 5. LIMITATIONS, RESTRICTIONS, AND OTHER TERMS\n\n**Our eligibility determinations are final.** We determine, in our sole and absolute discretion, whether you are eligible to access the Interface and the Service. Our determinations are final, binding, and non-appealable. We are not required to give reasons or to provide any review or appeal, and no determination gives rise to any claim by you.\n\n**Access is a revocable permission, not a right.** We may, at any time, for any reason or for no reason, without notice and without liability to you: suspend, restrict, condition, or terminate your access in whole or in part; impose limits on the transactions, amounts, or features available to you; withdraw the Service in any jurisdiction or for any category of person; and modify, suspend, or discontinue the Interface entirely. Your right to use the Interface terminates automatically on any breach of these Terms.\n\n**We may decline any order.** We may decline to quote, route, or settle any order, and may reject or cancel any order that has not settled, at our discretion, including for legal, regulatory, sanctions, or compliance reasons, and including where we believe that a representation you have made is untrue, that your conduct breaches Section 3, or that a quote, an oracle, or a settlement path is unreliable. We are under no obligation to quote, route, or settle any order, and nothing in these Terms obliges us to monitor, screen, or review any transaction or any user. Exercising, or declining to exercise, any right in this paragraph gives the Company no custody or control of your assets and creates no duty to you.\n\n**Fees.** Your use of the Service may be subject to fees, which may include a protocol fee, solver or settlement costs, a price spread, and, where applicable, blockchain network fees. Applicable fees are shown in the quote presented to you before you sign an order, and they may be taken from the token you provide as the input to the swap. By signing an order you agree to the fees shown for it, and fees paid are non-refundable except where a refund is required by law. We may change fees at any time on a prospective basis. Third parties, including the Issuer and any on-ramp you use, charge their own fees under their own terms, and fees shown exclude any tax that applies to you.\n\n**On-chain transactions are irreversible.** Once a transaction has been included in a block, it is final and irreversible, and neither the Company nor any other person can cancel, reverse, refund, or recover it. You are solely responsible for checking every order before you sign it, including the assets, the amounts, the price, any slippage tolerance, any approval you grant, and the destination address. An error, including a mistyped amount, an approval granted to a malicious contract, or a signature obtained from you by deception, is irreversible and is your loss.\n\n**You represent that you are sophisticated.** You represent and warrant that you have the knowledge, experience, and sophistication to evaluate the technical, market, legal, and tax risks of the Interface, the Service, and the Tokens; that you have conducted your own investigation and taken any advice you consider necessary; that you are not relying on any statement or omission of the Company Parties; and that you can bear the entire loss of everything you commit.\n\n**Technical malfunction and conditions outside our control.** We do not guarantee that the Interface or the Service will be available at any time or for any period. To the fullest extent permitted by applicable law, the Company Parties have no liability for any delay, failure, interruption, error, or loss arising out of: a bug, outage, or latency affecting the Interface; congestion, a reorganization, a fork, a halt, or an upgrade of a blockchain network, a failed, stuck, or reordered transaction, or the extraction of value by validators; a failure or error of a solver, an oracle, a net-asset-value feed, a node or hosting provider, a wallet provider, or the Issuer; a stale, withdrawn, or unfilled quote; or any event beyond our reasonable control, including an act of God, natural disaster, war, terrorism, civil unrest, epidemic, power or internet failure, cyber-attack, change in law, and any governmental action.\n\n## 6. MODIFICATIONS\n\nWe may modify, suspend, or discontinue the Interface, the Service, or any feature at any time, in our sole discretion, without notice and without liability to you.\n\nWe may amend these Terms at any time in our sole discretion. Amended Terms take effect when posted through the Interface with an updated \"Last updated\" date and version identifier, and it is your responsibility to review each version presented to you.\n\nYour acceptance is cryptographically bound to a version identifier and to a content hash of these Terms, of the Privacy Policy, and of the Issuer Representation published with them. Any change to that content produces a new hash, and your prior acceptance does not extend to the amended Terms. You will be asked to sign a fresh acceptance of the current version, and your continued use of the Service is conditioned on that renewed acceptance. If you do not accept the amended Terms, your sole and exclusive remedy is to stop using the Interface.\n\n## 7. RELEASE OF CLAIMS\n\nYou expressly and irrevocably release, waive, and forever discharge the Company Parties from all claims, demands, causes of action, proceedings, damages, losses, liabilities, costs, and expenses of every kind, whether known or unknown, suspected or unsuspected, and whether arising at law, in equity, or under any statute, that arise out of or relate in any way to the Interface, the Service, the Tokens, any quote, order, or settlement, any failure to quote, route, or settle, any decision you make to acquire, hold, or dispose of a Token, any change in the value of any asset, any act or omission of the Issuer or of any solver, oracle, network, or wallet provider, and any technical failure.\n\nThis release restates and does not limit your assumption of risk and your acknowledgement under Section 2 that you have no recourse against the Company Parties. If you have a dispute with the Issuer, with any solver, or with any other user, you release the Company Parties from all claims related to that dispute and will pursue it against that person.\n\nTo the fullest extent permitted by applicable law, you waive the benefit of any statute or doctrine that limits the effect of a general release as to claims the releasing party does not know or suspect to exist in its favor at the time of the release, and you intend this release to extend to all claims, whether or not you know of them today.\n\n## 8. INDEMNITY\n\nTo the fullest extent permitted by applicable law, you will indemnify, defend, and hold harmless the Company Parties, in that capacity the \"Indemnified Parties\", being the Company, its affiliates, and their respective officers, directors, employees, contractors, agents, and service providers, from and against all claims, demands, investigations, proceedings, losses, liabilities, damages, judgments, fines, penalties, settlements, costs, and expenses, including reasonable legal fees, arising out of or relating to:\n\n- your access to or use of the Interface or the Service, and any transaction you sign or attempt;\n- your breach or alleged breach of these Terms, including of any representation, warranty, or attestation you make under Section 1;\n- any activity prohibited under Section 3;\n- your violation or alleged violation of any law, rule, regulation, or sanctions program, or of the rights of any third party;\n- any tax obligation of yours arising out of your use of the Service;\n- your negligence, fraud, or willful misconduct; and\n- any dispute between you and the Issuer, any solver, any other user, or any other third party.\n\nYou will cooperate fully with the Indemnified Parties in the defense of any matter subject to this indemnity, at your expense. We may assume the exclusive defense and control of any such matter, at your expense, in which case you will not settle it or make any admission without our prior written consent. This indemnity survives any termination of these Terms.\n\n## 9. LIMITATION OF LIABILITY\n\nTo the fullest extent permitted by applicable law, the Company Parties will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, business, goodwill, or data, or for any loss of tokens or value, any trading loss, or any loss caused by a movement in price, arising out of or relating to these Terms, the Interface, the Service, or the Tokens, whether the claim is based in contract, tort (including negligence), strict liability, statute, equity, or any other theory, and whether or not the Company Parties were advised of the possibility of such damages.\n\nTo the fullest extent permitted by applicable law, the total aggregate liability of the Company Parties for all claims arising out of or relating to these Terms, the Interface, the Service, or the Tokens will not exceed $100.00. That cap is an aggregate cap across all claims and all claimants, and it applies regardless of the theory of liability, regardless of the number of claims, and whether or not you have paid any fee. Without limiting it, the Company Parties have no liability for any loss arising out of an act or omission of the Issuer or of any solver, oracle, network, or wallet provider, a bug in any smart contract, the compromise of your keys, a movement in the price of any asset, an order that is declined or unfilled, any eligibility determination we make, or any event described in Section 5.\n\nSome jurisdictions do not allow the exclusion or limitation of certain warranties or damages, so some of these exclusions and limitations may not apply to you. In those jurisdictions, the liability of the Company Parties is limited to the smallest amount permitted by applicable law, and nothing in these Terms excludes any liability that cannot lawfully be excluded, including liability for fraud. The exclusions and limitations in this Section are an essential basis of the agreement between you and the Company.\n\n## 10. ARBITRATION AND CLASS ACTION WAIVER\n\n**Read this Section carefully. It requires you to resolve disputes with the Company by binding individual arbitration, and it waives your right to a trial by jury and your right to take part in a class or representative action.**\n\nThese Terms, and any dispute, claim, or controversy arising out of or in connection with them, the Interface, the Service, or the relationship between you and the Company, including any question about their validity or termination and any non-contractual claim (each a \"Dispute\"), are governed by and construed in accordance with England and Wales, without regard to its conflict-of-laws rules.\n\n**Mandatory informal resolution.** Before commencing arbitration, you must send a written notice of Dispute to us at info@opcode.fi describing the Dispute and the relief you seek, and you must then allow a period of 30 days from that notice for the parties to attempt to resolve it informally. Completing this process is a condition precedent to arbitration, and either party may seek an order staying an arbitration commenced before it is satisfied.\n\n**Binding arbitration.** Any Dispute that is not resolved informally will be referred to and finally resolved by binding arbitration administered by London Court of International Arbitration (LCIA) in accordance with LCIA Rules. The number of arbitrators is one. The seat and venue of the arbitration is London, United Kingdom, and the language of the arbitration is English. The award is final and binding, and judgment on it may be entered in any court of competent jurisdiction. The arbitrator decides all questions of arbitrability, including the scope, validity, and enforceability of this Section, except that the enforceability of the waiver below is for a court. Each party bears its own costs except as the applicable rules provide, and the parties will keep the arbitration confidential except as required by law.\n\n**Waiver of court proceedings and jury trial.** You and the Company each waive any right to have a Dispute resolved in court and any right to a trial by jury, except as stated in this Section. Nothing here prevents the Company from seeking injunctive relief in any court of competent jurisdiction to protect its intellectual property, systems, or data, or to restrain a breach of Section 3.\n\n**Class action and representative action waiver.** You and the Company each agree to bring a Dispute against the other only in an individual capacity, and not as a plaintiff or a class member in any purported class, collective, consolidated, mass, or representative proceeding, and not as a private attorney general. The arbitrator may not consolidate the claims of more than one person, may not preside over any class or representative proceeding, and may award relief only in favor of the individual party seeking relief. If this waiver is held unenforceable as to a claim, that claim must be severed from the arbitration and brought in a court of competent jurisdiction, and it will be stayed until every arbitrable claim has been resolved.\n\n**Non-arbitrable claims and disputes with the Issuer.** To the extent a Dispute is found not subject to arbitration, it will be brought exclusively in the courts of London, United Kingdom, and you submit to their personal jurisdiction. A dispute between you and the Issuer concerning the Tokens is governed by the Issuer's own documents, and this Section does not extend to it.\n\n## 11. ISSUER REPRESENTATION\n\nBy using the Service to acquire a Token on a secondary basis, you make the deemed representation that the Issuer requires of secondary-market acquirers of the Tokens. That representation is reproduced in full in the Issuer Representation section published with these Terms (the application appends the Issuer's text, as synced from the Issuer's published documentation, at runtime), and it is incorporated into these Terms and bound into the content hash you sign on acceptance. Its clauses are not restated in this Section. The controlling version is the version published by the Issuer, the Issuer may change it at any time, and the Company makes no representation as to its accuracy and assumes no liability for it.\n\n## 12. MISCELLANEOUS\n\n**Entire agreement and non-reliance.** These Terms, together with the Privacy Policy and the Issuer Representation published with them, are the entire agreement between you and the Company regarding the Interface and the Service, and they supersede every prior agreement, understanding, and representation on that subject. You confirm that you have not relied on any statement, assurance, or warranty that is not set out in these Terms. The Privacy Policy is incorporated by reference, and your acceptance of these Terms is also your acceptance of it.\n\n**Assignment.** We may assign, transfer, or novate these Terms or any of our rights or obligations, in whole or in part, at any time, without notice and without your consent, including to an affiliate or in connection with a merger or a sale of assets. You may not assign or transfer these Terms or any right under them without our prior written consent, and any purported assignment by you is void.\n\n**Severability and waiver.** If any provision of these Terms is held invalid or unenforceable, it will be reformed to the minimum extent necessary to make it enforceable or, if it cannot be reformed, severed, and the remaining provisions continue in full force and effect. No failure or delay by us in exercising any right operates as a waiver, and a waiver is effective only if we give it in writing.\n\n**Notices.** We may give you any notice under these Terms by posting it in the Interface, by a signature request to your wallet, or by sending it to an email address you have provided, and it is deemed given when posted or sent. You must give any notice to us in writing to info@opcode.fi, and it is effective only on actual receipt. All communications between you and the Company are in English.\n\n**Third parties and survival.** The Company Parties and the Indemnified Parties may enforce the provisions expressed to benefit them, and no other person may enforce any provision of these Terms. You and the Company are independent parties. Sections 2, 3, 4, 5, 7, 8, 9, 10, 11, and 12 survive any termination. No rule of construction requiring an agreement to be construed against its drafter applies, and if these Terms are translated, the English version controls.","privacy_policy":"# Opcode Privacy Policy\n\nEffective date: July 14, 2026\n\nPolymancer Ltd. (\"Opcode\", \"we\", \"us\", or \"our\") operates the Opcode application and the related interfaces through which it is made available (the \"Service\"). The Service lets eligible users swap tokens into tokenized equity instruments issued by Ondo, without paying gas. Those instruments are offered and traded outside the United States on a Regulation S basis, and US persons may not use the Service.\n\nThis Privacy Policy explains what personal data we collect through the Service, why we process it, who we share it with, and what rights you have over it. For the purposes of the EU General Data Protection Regulation (the \"GDPR\") and the UK General Data Protection Regulation (the \"UK GDPR\"), Polymancer Ltd. is the controller of the personal data described in this Policy.\n\nThis Policy covers only the personal data we process. It does not cover third parties we do not control, including wallet providers, blockchain networks, token issuers, and any site you reach from a link on the Service. Public blockchains are open networks operated by no single party, and anything recorded on them is public and permanent.\n\nIf you do not agree with this Policy, do not use the Service.\n\n## 1. PERSONAL DATA WE COLLECT, WHY WE PROCESS IT, AND THE LEGAL BASIS\n\nWe collect personal data that you give us, personal data we collect automatically when you use the Service, and personal data our service providers collect on our behalf.\n\n### Information you provide to us\n\n**Login and contact details.** You sign in with a passkey and an email address. Our login provider registers and verifies the passkey credential on our behalf and gives us the email address associated with it. Passkey authentication uses public-key cryptography, so there is no reusable password for us to hold. The private key behind your passkey, and any biometric or screen-lock check used to authorize its use, stay on your device and are not sent to us.\n\n**Acceptance of our terms.** Before you can trade, you must accept our Terms of Service and the eligibility representations they contain. When you do, we store a signed acceptance record. That record contains the wallet address you signed with, the version of the terms you accepted, a cryptographic hash of that version, whether you attested to professional client or qualified investor status (an attestation we require only where the rules of a jurisdiction call for it), the country derived from your IP address at the time of acceptance, the user agent reported by your browser or device, the timestamp of acceptance, and your signature. We do not ask you to declare your country or jurisdiction and we do not store a self-declared one. The country in the record is the country we derived from the IP address you were using at the moment you signed.\n\n**Support messages.** If you contact us for support or otherwise write to us, we process the content of your message, the address you send it from, and anything else you choose to include in it.\n\nWe do not want, and do not ask you for, special categories of personal data (such as data about your health, political opinions, or religious beliefs), identity documents, or your wallet private key or recovery phrase. Please do not send them to us.\n\n### Information we collect automatically\n\nWhen you access the Service, we and our service providers collect:\n\n- your IP address, and the country we derive from it using an IP-geolocation provider;\n- your user agent, including browser type and version, operating system, and device characteristics;\n- usage and interaction data, such as the pages and features you use, the actions you take, session identifiers, referring pages, language settings, and timestamps;\n- server logs, diagnostic data, and error reports generated by our infrastructure; and\n- on-chain activity associated with the wallet address you connect, including the quotes you request, the orders you sign, and the settlement transactions that result.\n\nWe use this data to run, secure, and improve the Service; to work out whether the Service is available where you are and whether you are a Restricted Person under our Terms of Service; to detect, investigate, and prevent fraud, abuse, and security incidents; and to meet our legal and regulatory obligations. Access to the Service may be refused automatically based on the country derived from your IP address and on the outcome of screening checks.\n\n### Wallet connections\n\nThe Service is used with self-custodial wallets. When you connect a wallet, we receive its public address and the signatures you choose to produce. We never receive your private key or recovery phrase, we cannot sign on your behalf, and we cannot move your assets.\n\nYour wallet is supplied by a third party, not by us. Your use of it is governed by that third party's own terms and privacy policy, and that third party decides for itself what personal data it collects from you and what it does with it. We do not control the data practices or the conduct of any wallet provider, we are not responsible for them, and we disclaim all liability arising out of them. Read the provider's privacy policy before you connect a wallet.\n\n### Legal basis for processing\n\nWhere the GDPR or the UK GDPR applies, we rely on the following legal bases.\n\n**Performance of a contract.** We process your login, wallet, order, and acceptance data because it is necessary to provide the Service you have asked for and to take steps at your request before entering into a contract with you. This includes determining whether you are a Restricted Person under our Terms of Service and therefore not permitted to use the Service.\n\n**Consent.** Where we ask you to consent to a specific use of your personal data, we process that data on the basis of your consent. You can withdraw your consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before you withdrew it.\n\n**Legitimate interests.** We process device, usage, log, and IP data because we have a legitimate interest in operating and securing the Service, preventing fraud and abuse, enforcing our terms, understanding how the Service is used, and establishing, exercising, or defending legal claims. We rely on this basis only where our interests are not overridden by your interests, rights, and freedoms.\n\n**Legal obligation.** We process personal data where we have to in order to comply with a legal or regulatory obligation that applies to us, including sanctions screening, anti-money-laundering requirements, and record-keeping duties.\n\n### Cookies\n\nWe use cookies and similar technologies (including browser storage and session tokens) only where they are strictly necessary to deliver the Service you have asked for: to keep you signed in for the length of a session, to protect the security and integrity of that session, to hold essential settings, and to route traffic so that the Service works.\n\nWe do not use cookies for marketing, advertising, or cross-site tracking, and we do not sell data collected through cookies. You can block or delete cookies through your browser settings, but the Service will not work properly without the strictly necessary ones.\n\n## 2. YOUR RIGHTS\n\nIf you are in the European Economic Area (the \"EEA\") or the United Kingdom, you have the following rights over your personal data under the GDPR and the UK GDPR.\n\n- **Access.** You can ask us to confirm whether we process personal data about you and, if we do, to give you a copy of it together with information about how we use it.\n- **Rectification.** You can ask us to correct personal data about you that is inaccurate, and to complete personal data that is incomplete.\n- **Erasure.** You can ask us to delete personal data about you where we no longer have a good reason to keep processing it.\n- **Restriction.** You can ask us to suspend the processing of your personal data in certain cases, for example while we check the accuracy of data you have told us is wrong.\n- **Portability.** You can ask us to give you, or a controller you name, the personal data you provided to us in a structured, commonly used, machine-readable format, where we process it by automated means on the basis of your consent or of a contract with you.\n- **Objection.** You can object, on grounds relating to your particular situation, to processing we carry out on the basis of our legitimate interests.\n- **Withdrawal of consent.** Where we process personal data on the basis of your consent, you can withdraw that consent at any time, without affecting the lawfulness of the processing carried out before you withdrew it.\n\nTo exercise any of these rights, write to us at info@opcode.fi. We will respond within one month of receiving your request. Where a request is complex, or where you have made a number of requests, we may extend that period by up to two further months, and we will tell you within the first month if we do and why.\n\nWe may need to verify who you are before we act on a request. That can include asking you to sign a message from the wallet address the request relates to.\n\nThese rights are not absolute. We cannot change or erase anything recorded on a public blockchain, and we may have to keep certain records, including the signed acceptance record described in Section 4, in order to meet a legal obligation or to establish, exercise, or defend a legal claim. If we cannot act on a request, we will tell you why.\n\nYou also have the right to lodge a complaint with a data protection supervisory authority, as set out in Section 9.\n\n## 3. SHARING OF PERSONAL DATA\n\nWe do not sell your personal data. We share it in the following cases.\n\n**Service providers and vendors.** We share personal data with companies that process it for us, under contract and on our instructions, so that we can run the Service. They include our passkey and email login provider; Ondo, as the issuer of the tokenized instruments available through the Service; our hosting and infrastructure providers; our IP-geolocation provider; our analytics providers; and the blockchain-analysis and screening providers we use for sanctions and risk checks.\n\n**Professional advisors.** We share personal data with our lawyers, auditors, accountants, insurers, and other professional advisors where they need it to advise us, and with counterparties and their advisors in connection with a merger, acquisition, financing, or sale of assets, in which case the data stays subject to this Policy or to a successor policy.\n\n**Legal and security reasons.** We may disclose personal data where we believe in good faith that it is necessary to comply with applicable law, regulation, or legal process; to respond to a request from a court, regulator, or law enforcement authority; to enforce our terms; to detect, prevent, or investigate fraud, security incidents, or unlawful activity; or to protect the rights, property, or safety of Opcode, our users, or others.\n\n**Public blockchains.** The transactions you sign are broadcast to and recorded on public blockchains, where anyone can read them. That is how the technology works. It is not a disclosure we control, and it is not one we can reverse.\n\n## 4. RETENTION\n\nWe keep personal data only for as long as we need it for the purposes set out in this Policy, which means for as long as necessary to provide the Service, to comply with our legal, regulatory, tax, and record-keeping obligations, to resolve disputes, and to establish, exercise, or defend legal claims. How long that is depends on the type of data and on why we hold it. When we no longer need personal data, we delete it or irreversibly anonymize it. Where we cannot delete it immediately, for example because it sits in a secure backup, we isolate it and protect it from further processing until deletion is possible.\n\nThe signed acceptance record described in Section 1 is treated differently. It exists to evidence that a particular wallet accepted a particular version of our terms, with the eligibility representations that version contained, at a particular time. Its value as evidence depends on it not changing. We therefore keep it as an immutable, tamper-evident audit trail for as long as we may need to rely on it. We do not alter entries in that audit trail and we do not selectively delete entries from it.\n\nData recorded on a public blockchain is permanent. We cannot change it or remove it, and it may stay publicly available indefinitely, whatever we do with our own records.\n\n## 5. CHILDREN'S PRIVACY\n\nThe Service is for adults. It is not directed to anyone under the age of 18, and we do not knowingly collect personal data from anyone under 18. If you are under 18, do not use the Service and do not give us any personal data. If we learn that we hold personal data collected from a person under 18, we will delete it. If you believe that a person under 18 has given us personal data, write to us at info@opcode.fi.\n\n## 6. SECURITY\n\nWe take reasonable technical and organizational measures designed to protect personal data against loss, misuse, and unauthorized access, disclosure, alteration, and destruction. These include encrypting data in transit, controlling access on a least-privilege basis, logging and monitoring, and limiting access to personal data to the personnel and processors who need it.\n\nNo method of transmitting or storing data is completely secure, and we cannot guarantee the security of personal data. Any transmission of personal data to us is at your own risk. You are responsible for keeping your device, your passkey, and your wallet keys secure. We will never ask you for your wallet private key or your recovery phrase.\n\n## 7. INTERNATIONAL TRANSFERS\n\nWe and our service providers process personal data in a number of countries. Personal data collected from you in the EEA or the UK may therefore be transferred to, stored in, and processed in a country outside the EEA or the UK whose data protection laws are different from those of your own country.\n\nWhere we transfer personal data out of the EEA or the UK, we do so on one of the following bases. Either the recipient is in a country that the European Commission or, for transfers subject to the UK GDPR, the UK government has decided offers an adequate level of protection. Or we put appropriate safeguards in place, which for us means the Standard Contractual Clauses approved by the European Commission and, for transfers subject to the UK GDPR, the UK International Data Transfer Addendum to those clauses (or the UK International Data Transfer Agreement), together with any additional technical and organizational measures the transfer calls for.\n\nYou can ask us for a copy of the safeguards that apply to a particular transfer by writing to info@opcode.fi.\n\n## 8. THIRD-PARTY WEBSITES AND LINKS\n\nThe Service may contain links to sites, applications, and resources operated by third parties, including wallet providers, block explorers, and token issuers. We provide those links for convenience and they are not an endorsement. We do not control those third parties, we are not responsible for their content or for their privacy practices, and this Policy does not apply to them. Any personal data you give to a third party is governed by that party's own privacy policy, which you should read before you give it.\n\n## 9. PERIODIC REVIEWS AND UPDATES TO THIS POLICY\n\nWe review this Policy periodically and update it to reflect changes in the Service, in our data practices, or in the law. We keep our processing under review against the EU GDPR and the UK GDPR.\n\nIf you are in the EEA or the UK and you think we have processed your personal data unlawfully, you have the right to lodge a complaint with a data protection supervisory authority. In the EEA, that is the supervisory authority of the member state where you habitually reside, where you work, or where the alleged infringement took place. In the UK, that is the Information Commissioner's Office. We would rather have the chance to resolve your concern first, so please consider contacting us before you do.\n\nWhen we update this Policy, we will post the updated version on the Service and change the effective date at the top of it. Where the changes are material, we will give additional notice through the Service where that is required or appropriate. If you continue to use the Service after an updated Policy takes effect, you accept it. We encourage you to read this Policy from time to time.\n\n## 10. CONTACT\n\nIf you have questions about this Policy, or if you want to exercise any of the rights described in Section 2, write to us at info@opcode.fi."}