3.1

Stablecoin means fiat-backed stablecoins, being digital assets designed to maintain a stable value by reference to a fiat currency. The Stablecoins currently supported under this Policy include, but are not limited to, USD Coin (USDC) and Tether (USDT);

3.2

Conversion means the exchange of stablecoins to USD;

3.3

User means any verified Cleva account holder using the Stablecoin Address feature;

3.4

Platform means the Cleva digital platform and associated service.

4.1

This Policy applies to all users of the Cleva platform who transact in, or otherwise interact with stablecoin-related services made available through the Cleva platform.

4.2

This feature is available only to verified Cleva account holders who have successfully completed the compulsory identity verification (KYC), and who maintain an active USD wallet or USD virtual account in good standing

4.3

By using this feature, you represent and warrant that you are at least 18 years of age, that you have the legal capacity to enter into binding agreements, and that you are in compliance with all applicable laws and regulations in your jurisdiction. You further warrant that you are not located in, or a resident of, any restricted or sanctioned jurisdiction, and that you are not on any sanctions lists including Office of Foreign Assets Control (OFAC), United Nations (UN), European Union (EU), or similar designations.

5.1

Cleva will accept only the stablecoin types and blockchain networks explicitly listed on its platform, which may include but are not limited to USDT, USDC, and other approved stablecoins on the ERC-20 and TRC-20 network.

5.2

Users bear sole responsibility for selecting the correct blockchain network when initiating a stablecoin deposit. The network selected in the sending wallet or exchange must exactly match the network displayed for the user's Stablecoin Address.

5.3

Cleva reserves the right to add or remove supported stablecoins and networks at its sole discretion with or without prior notice. Sending unsupported stablecoins or using unsupported networks may result in permanent and irretrievable loss of funds.

5.4

Removal of support for a stablecoin or network applies prospectively to new deposits. Existing balances that have already been converted to USD will not be affected by subsequent changes to stablecoin or network support.

6.1

All stablecoins received through your Stablecoin Wallet Address will be automatically and irrevocably converted to USD at an exchange rate determined by Cleva and disclosed to you at the time of conversion.

6.2

Once converted, the resulting USD funds will be credited to your USD wallet, subject to successful completion of all compliance checks.

6.3

Users acknowledge that conversion rates may differ from rates displayed on other platforms or exchanges.

7.1

Cleva may charge conversion fees, gas fees or any other relevant fee to facilitate blockchain transactions.

7.2

All applicable fees will be disclosed on the platform prior to transaction completion and are subject to change with reasonable notice.

7.3

Fees will be deducted from the converted USD amount before crediting to your USD Wallet.

8.1

Cleva has established a minimum stablecoin deposit threshold, which shall be determined by Cleva and disclosed to users from time to time. Deposits that fall below the applicable minimum threshold may not be processed, converted, or credited to the user's USD Wallet.

8.2

Cleva maintains sole discretion to reject, return, or hold sub-minimum deposits without crediting the corresponding USD value to the user's account.

8.3

Cleva may impose maximum deposit limits on a per-transaction, daily, weekly, or monthly basis to manage operational capacity, liquidity, compliance obligations, and risk exposure. Such limits may vary based on user account verification level, account history, jurisdiction, and the Company's ongoing risk assessment.

8.4

Users with higher verification tiers may be eligible for increased transaction limits. The specific limits applicable to each user's account are displayed within the Platform interface and may be reviewed in account settings or during the deposit initiation process.

8.5

These limits may be adjusted based on risk assessment and regulatory requirements. Conversion occurs upon confirmation on the blockchain network, and settlement time for USD crediting may vary, typically one to two business days.

8.6

Delays may occur due to network congestion, compliance reviews, partner systems, public holidays, or other factors beyond Cleva's control. Cleva will provide transaction status updates through the platform.

9.1

Cleva does not hold, store, or provide custody services for stablecoins on behalf of users. All stablecoins are held by a partner custodian appointed by Cleva.

9.2

All stablecoins received are immediately processed for conversion to USD. Users cannot withdraw received stablecoins in their original form, reverse or cancel automatic conversions, or maintain stablecoin balances within Cleva. All holdings within Cleva are denominated and held exclusively in USD.

10.1

All transactions are subject to applicable AML/CTF/CPF laws and regulations. Cleva implements risk-based monitoring and screening procedures, and transactions may be monitored for suspicious activity.

10.2

Cleva may require additional information, documentation, or verification at any time. Users must promptly respond to verification requests, and failure to provide requested information may result in account suspension.

10.3

Cleva reserves the right to reject, block, or reverse any transaction deemed suspicious or potentially fraudulent, non-compliant with applicable laws or regulations, in violation of these Terms, or connected to sanctioned individuals, entities, or jurisdictions.

10.4

Cleva may be required to report certain transactions to regulatory authorities, law enforcement, or financial intelligence units. Users acknowledge that such reporting may occur without prior notice.

10.5

Users are solely responsible for determining and fulfilling their tax obligations. Cleva may report transaction information to tax authorities as required by law. Users should consult qualified tax professionals regarding their specific circumstances.

11.1

Cleva shall not process, facilitate, or permit any transfer of stablecoins to or from;

11.1.2

wallet addresses associated with sanctioned individuals, entities, or prohibited activities; or

11.1.2

persons or entities located in, incorporated in, or ordinarily resident in jurisdictions subject to sanctions, embargoes, or other restrictions under applicable laws.

11.2

Where a wallet address or transaction is identified as prohibited or confirmed to be high-risk under applicable anti-money laundering, counter-terrorist financing, or sanctions laws, or the Cleva’s internal compliance frameworks, Cleva may reject, block, suspend, reverse, or report such transaction in accordance with applicable law and our internal procedures.

11.3

Cleva reserves the right, at its sole discretion, to place a hold on any incoming stablecoin transaction if it reasonably suspects the transaction may be fraudulent or the proceeds of fraud, connected to criminal activity, in violation of applicable laws, regulations, or sanctions, non-compliant with Cleva's policies or risk tolerance, or sent in error or disputed by a third party.

11.4

Stablecoins placed under hold will not be converted to USD or credited to your USD Wallet until cleared. Cleva may hold such funds for the period necessary to complete internal reviews, external investigations, regulatory inquiries, or law enforcement cooperation. Hold periods typically range from 5 to 90 working days but may be extended as circumstances require.

11.5

Cleva will use reasonable efforts to notify you promptly if your transaction is being held. You may be required to provide additional identification documents, source of funds documentation, transaction history and purpose, counterparty information, or any other information reasonably requested.

11.6

During hold of transactions, stablecoins may be held in a secure, segregated account separate from Cleva's operating funds. You will have no right to access, withdraw, convert, or otherwise transact with quarantined funds until resolution. Held funds do not accrue interest or other benefits.

11.7

Upon completion of Cleva's review, legitimate transactions will be converted to USD at the applicable rate at the time of release and credited to your USD Wallet. Suspicious or illegal transactions may be permanently blocked and returned to sender (if permitted); seized by legal authority; reported to appropriate authorities as required by law; or forfeited in accordance with applicable legal requirements.

11.8

Cleva shall not be liable for any losses, damages, or opportunity costs arising from held transactions in good faith. Exchange rate fluctuations during hold periods are at User's risk.

11.9

You agree to indemnify and hold harmless Cleva, its affiliates, officers, directors, employees, and agents from any losses, costs, liabilities, or expenses, arising from holding of suspected fraudulent or non-compliant inflows, except to the extent directly caused by Cleva's gross negligence or willful misconduct.

12.1

You acknowledge and accept that blockchain transactions are irreversible and that Cleva cannot recover funds sent to incorrect addresses or using incorrect networks. Sending unsupported stablecoins or tokens may result in permanent loss, and Cleva is not responsible for recovering unsupported assets.

12.2

You expressly acknowledge and agree that the Company maintains no technical ability, infrastructure, or obligation to recover, retrieve, or credit stablecoins or other digital assets sent via unsupported networks or in unsupported formats.

12.3

Cleva will not engage in manual recovery efforts, blockchain analysis, or technical intervention to attempt recovery of unsupported deposits, even if technically possible in specific circumstances. You assume all risks associated with deposit errors and network selection mistakes.

12.4

You further acknowledge that conversion rates are subject to market fluctuations and may vary significantly from other platforms, and that stablecoin values may deviate from their intended peg. Network congestion may cause delays, blockchain protocol changes may affect service availability, and smart contract vulnerabilities in stablecoin protocols pose inherent risks.

12.5

You understand that regulatory changes may affect service availability and that services may be suspended or terminated due to regulatory requirements. You also acknowledge that stablecoin issuers may experience insolvency or operational failures, that stablecoins may lose their peg to USD, and that Cleva does not guarantee the value or redeemability of any stablecoin.

12.6

Cleva is not affiliated with, endorsed by, or responsible for the policies, reserves, redemption mechanisms, or operational practices of any stablecoin issuer including but not limited to Tether Limited (USDT), Circle Internet Financial (USDC), or any other stablecoin provider. While Cleva may partner with or use services from stablecoin issuers, we do not control or influence their operations or decisions.

13.1

Users must ensure only supported stablecoins are sent to their Stablecoin Address and must verify address accuracy and network selection before initiating transfers. Users are responsible for maintaining the security and confidentiality of account credentials, promptly updating account information and responding to verification requests, maintaining compliance with all applicable laws in their jurisdiction, and reporting any unauthorized account access or suspicious activity immediately.

13.2

Users are prohibited from using the Stablecoin Address to engage in money laundering, terrorist financing, or other criminal activities; to violate any applicable laws, regulations, or sanctions; to send proceeds of illegal activity; to circumvent transaction limits or compliance measures; to create multiple accounts to evade restrictions; to engage in market manipulation or fraudulent schemes; to process payments for prohibited goods or services; or to violate any third party's rights.

14.1

Cleva collects, processes, and stores personal and transaction data in accordance with its Privacy Policy and applicable data protection laws. By using this feature, you consent to the collection, processing, and sharing of your data as necessary to provide services and comply with legal obligations.

14.2

Transaction data may be retained for a minimum of five (5) years or for such period as required by law.

15.1

Cleva strives to maintain continuous service availability but does not guarantee uninterrupted access.

15.2

Services may be temporarily suspended for scheduled maintenance, system upgrades, security incidents, regulatory compliance, or force majeure events. Cleva will provide reasonable notice of scheduled maintenance when practicable.

16.1

Cleva may amend these Terms at any time by posting updated Terms on the platform. Continued use of the platform constitutes acceptance of the updated Terms.

16.2

Material changes will be effective 30 days after notice, unless a shorter period is required by law or for security reasons.

16.3

Continued use of the Stablecoin Address feature after the effective date constitutes acceptance of the updated Terms. If you do not accept amended Terms, you must discontinue use of the feature.

17.1

To the maximum extent permitted by law, Cleva shall not be liable for any indirect, incidental, special, consequential, or punitive damages; loss of profits, revenue, data, or business opportunities; losses arising from incorrect or unsupported stablecoin transfers; exchange rate fluctuations or stablecoin depegging events; network delays, congestion, or failures; third-party service provider failures; unauthorized access to your account due to your failure to maintain security; or events beyond Cleva's reasonable control.

17.2

Cleva's total liability for any claims shall not exceed the fees paid by you in the 12 months preceding the claim.

18.1

Cleva reserves the right to suspend or terminate your access to the Stablecoin Address feature immediately, with or without notice, for any reason including suspected fraudulent activity, non-compliance with this Policy, failure to respond to verification requests, violation of applicable laws or regulations, regulatory directives or legal requirements, risk management purposes, or closure or restructuring of services.

18.2

Upon termination, access to the Stablecoin Address feature will be disabled, pending transactions may be cancelled or completed at Cleva's discretion, and existing USD balances remain accessible subject to compliance requirements. Certain Terms survive termination, including indemnification and liability provisions. Users may discontinue use of the feature at any time and should ensure no pending transactions before discontinuation.

19.1

Any dispute, controversy, or claim arising out of or relating to this Policy, including its interpretation, validity, performance, breach, or termination, shall be resolved in accordance with the procedure set out in this Clause:

19.2

Users agree to first attempt to resolve any disputes informally by contacting Cleva support.

19.3

Where the dispute is not resolved within fourteen (14) days of the written notice from the User or Cleva, the dispute shall be referred to and finally resolved by arbitration in accordance with the Arbitration and Mediation Act 2023

19.4

A dispute shall be deemed to have arisen when the User serves written notice on the other describing the nature of the dispute and requesting resolution.

20.1

This Policy and any non-contractual obligations arising out of or in connection with it shall be governed by and construed in accordance with the laws of the State of Delaware, United States of America.

20.2

The seat and venue of arbitration shall be Delaware, United States of America, and proceedings may be conducted virtually, in whole or in part.

20.3

The language of arbitration shall be English.

Cleva shall not be liable for any failure or delay in performance due to events beyond its reasonable control, including but not limited to natural disasters, pandemics, or public health emergencies; war, terrorism, civil unrest, or government actions; blockchain network failures or cyberattacks; internet or telecommunications failures; third-party service provider failures; or changes in law or regulatory requirements.

If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.

These Policy, together with Cleva's Privacy Policy and any other referenced policies, constitute the entire agreement between you and Cleva regarding the Stablecoin Address feature.

You may not assign or transfer your rights or obligations under these Terms without Cleva's prior written consent. Cleva may assign these Terms without restriction.

Cleva's failure to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision.

26.1

Cleva is not a bank, credit union, or depository institution, and is not a regulated securities or commodities exchange. USD balances are not insured by the Nigeria Deposit Insurance Company.

26.2

Cleva provides this service through its licensed partners. The Company does not directly provide custody, storage, or management of digital assets, and all services are facilitated by partners that are appropriately licensed and regulated.

26.3

All services are provided "AS IS" and "AS AVAILABLE," without any warranties, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, non-infringement, uninterrupted or error-free operation, or accuracy or reliability of information.

26.4

Nothing in this Policy or on the platform constitutes financial, investment, legal, or tax advice. Users should consult qualified professionals for advice specific to their circumstances.

27.1

For questions, concerns, or support regarding the Stablecoin Address feature or these Terms, please contact@getcleva.com..

27.2

By using the Cleva Stablecoin Address feature, you acknowledge that you have read, understood, and agree to be bound by this Stablecoin Policy.