1. Definitions
For purposes of these Terms of Use, the definitions below apply:
TroqPay: TROQ SOLUÇÕES DIGITAIS LTDA, a private legal entity, registered under CNPJ/MF No. 32.231.982/0001-19, responsible for the platform and services described in this document.
User: Individual or legal entity that uses the TroqPay platform services in the course of commercial or professional activity, in a relationship of a business nature.
End Customer: Person who makes payments to the User using the integrations provided by TroqPay.
DEV Mode: Initial phase of using the platform, exclusively for tests and simulations, without legal or financial value.
Production Mode: Phase subsequent to the submission and approval of the User's documentation, enabling real operations, Pix receipts and withdrawals through the rails available on the platform.
BaaS Partner: Financial and/or payment institution duly licensed or authorized by the Central Bank of Brazil, responsible for the processing, settlement and other regulated financial services made possible by the TroqPay platform.
VASP Partner: Virtual asset service provider duly authorized by the competent authorities, responsible for quotation, purchase, sale, settlement, applicable regulatory codes, custody and transfer of virtual assets, including supported stablecoins, when this service is enabled on the platform.
1.1 Nature of TroqPay's activity
TroqPay is not a bank, financial institution, payment institution, electronic money institution, foreign exchange broker, exchange, virtual asset service provider, virtual asset custodian or digital wallet.
TroqPay provides integration technology, checkout, webhooks, reconciliation, status visualization and operational support. Regulated financial services, where they exist, are provided by duly licensed or authorized partner institutions, as applicable.
Making functionalities available on the platform does not imply that TroqPay holds, has custody of, manages or moves its own funds or third-party funds outside the structure of its regulated partners.
TroqPay does not enter into foreign exchange contracts in its own name or on behalf of third parties, does not provide international payment or transfer services (eFX), does not send funds abroad, does not take on the position of financial counterparty and does not hold customer funds on its balance sheet.
2. Contractual structure
The User's journey on TroqPay is divided into two stages with distinct rules:
2.1 DEV Mode (Testing Environment)
In this phase, the User has access to the platform to test integrations with the Pix gateway, without the need to submit documents.
Nature of the Data: The transactions and data entered in this environment are exclusively fictitious and must not be used in a production environment.
Collected Data: During tests, TroqPay may collect technical data such as email, IP, API identifiers, platform usage and request logs for diagnostic and performance purposes.
Prohibitions on Production use: It is prohibited to use the testing environment for real financial transactions or to deceive third parties by simulating genuine operations.
Withdrawals and Fees: There is no availability of withdrawals or real financial movement in this mode. The amounts displayed are merely illustrative.
Privacy: The collected data follows the LGPD guidelines, even in a testing environment.
2.2 Production Mode (Real Environment)
After submitting the required documentation and approval in the KYC/KYB (Know Your Customer / Know Your Business) process, the User will be migrated to the production environment, enabled to use the platform with real transactions. Pix receipts and the associated financial operations are processed and settled by the responsible BaaS Partner.
The account review process generally takes 1 business day. However, there are cases where it may take up to a maximum of 3 business days to be approved. This process is extended when a document is submitted with an inconsistency, and the account may be rejected if data is missing or incorrect.
In case of rejection, a new review may be conditioned on the submission of additional documentation, the correction of identified inconsistencies or the lapse of a period defined by TroqPay or its partners. Recently opened accounts may be subject to additional checks.
2.3 Business relationship and responsibility toward the end customer
TroqPay provides infrastructure technology, API, checkout, webhooks, reconciliation and operational tracking for individuals or legal entities in the course of their commercial or professional activities. The relationship between TroqPay and the User is of a civil and business (B2B) nature and does not constitute a consumer relationship between these parties.
The User is solely responsible toward the End Customer for the offer, sale, delivery, quality, warranty, return, support, tax compliance and regularity of the products or services marketed in its own environment. The User is also responsible for fraud, unlawful acts, misleading advertising, delivery failures or breaches committed in its operation.
If TroqPay is sued or contacted by end consumers, consumer protection agencies, authorities, partners or third parties due to an act, omission, fraud, operational failure or breach by the User, TroqPay may exercise the right of recourse, apply proportional precautionary measures over access to the platform, request or reflect blocking, retention or refund measures executed by competent partners and seek the appropriate measures to recover losses, costs, fines, indemnities and expenses.
Documentation and verification
The User must submit valid documents, in accordance with the instructions provided by the TroqPay team. It cannot be a photo of a photo, a photo of a screen or a print of a photo. Also, the identification document submitted cannot be old. It must be submitted without erasures, cuts or reflections.
The selfie of the managing partner must be current, front-facing, without accessories or reflections, and only the responsible person must appear in the image. The verification process includes validating the identity, the CNPJ (when applicable) and the ownership of the destinations enabled for withdrawal, such as a Pix key and a wallet on a compatible network, when applicable.
It is the User's sole responsibility to ensure that the documents submitted are legible, up to date and of good quality. Failure to observe these requirements may result in delays or rejections in the verification process.
Pix Fees
Software license fee: For licensing the use of the platform, data processing, APIs, webhooks, checkout, reconciliation and operational tracking, TroqPay charges 1% on each approved Pix transaction, subject to a minimum amount of R$ 0.99 per transaction. For example, on a charge of R$ 50.00, the fee will be R$ 0.99. On a charge of R$ 100.00, the fee will be R$ 1.00.
Nature of the remuneration: TroqPay's remuneration is exclusively in the nature of a software license, data processing and provision of an application programming interface (API). TroqPay does not earn brokerage commission, premium, foreign exchange spread, banking fee, eFX fee, international transfer fee or any financial remuneration on the quotation, conversion or settlement of virtual assets.
Withdrawal processing fee: For processing the withdrawal request in BRL via a Pix key of the same ownership on the TroqPay platform, a fee of 0.05% on the requested amount will be charged, subject to a minimum amount of R$ 2.99 per request for up to 20 requests in the month. From the 21st request in the same month, the minimum amount per request will become R$ 3.50. Other enabled rails may have their own fee, informed before confirmation. Any fees charged by the BaaS Partner for the financial operation itself will be informed separately when applicable.
Ownership of the BRL destination: BRL withdrawal instructions will only be processed for a Pix key of the same ownership as the registration approved at TroqPay, in accordance with the BaaS Partner's rules.
Fee changes: Any change in fees will be communicated in advance by email or through the platform dashboard.
Initial withdrawal limit: All accounts start with a limit of R$ 5,000.00 and a nighttime limit of R$ 1,000.00. This limit may be increased upon express request to TroqPay support.
Retention and blocks
The amounts displayed on the platform may become temporarily unavailable in the event of:
- Disputes, MED, chargebacks or other refund procedures.
- Internal review procedures by TroqPay's partner financial institution.
- Judicial measures or orders from competent authorities.
Disclaimer of liability
TroqPay acts as a technological and operational layer for the integration, recording, communication and tracking of transactions, without directly providing regulated financial services. Payment, settlement, maintenance of subaccounts, blocks and retentions are operated by the BaaS Partner, in accordance with its own terms, policies and operating rules. TroqPay has no control over retentions or blocks promoted by the BaaS Partner and cannot be held liable for retentions, blocks or delays arising from internal procedures, compliance, audits, reviews or any decision of the responsible partner institution.
Judicial blocks
In the event of attachment, block, seizure or any other measure determined by a competent authority, TroqPay may comply with the order within the technological scope under its control, forward it to the competent partners responsible for the account, subaccount, operational arrangement or settlement, or reflect on the platform the measures executed by such partners, without this constituting a contractual default.
Precautionary suspension, preventive retention and account closure
In compliance with the guidelines for preventing money laundering and terrorist financing (AML/CFT), fraud monitoring, platform security and the rules of regulated partners, TroqPay may apply a precautionary and temporary suspension of the registration, operational blocking of functionalities and restrictions on use of the platform. When the measure involves amounts, accounts, subaccounts, settlement, refund or financial retention, execution will fall to the responsible BaaS Partner, VASP or competent partner, and TroqPay may reflect the measure on the platform and cooperate with evidence and information.
Except for judicial or regulatory determinations, mandatory communications to authorities, confirmed fraud, risk of dissipation of funds or immediate requirement from a regulated partner, TroqPay will notify the User and grant a period of 72 (seventy-two) hours to submit documents, invoices, contracts, delivery confirmations, evidence of service provision or other information capable of demonstrating the regularity of the operation.
After technical analysis of the evidence by TroqPay, its partners or competent authorities, or in the event of the User's silence after the indicated period, the registration and use of the platform may be permanently terminated. Amounts, when held within a competent partner's structure, may be released, kept blocked, returned to origin, debited or retained by the responsible partner, in accordance with applicable law, authority orders, BaaS Partner or VASP rules or dispute/MED procedures.
The above measures may occur in the following situations:
- Suspicion of fraud, irregularity, misuse or illegality.
- Operations outside the usual behavior pattern.
- Failure to submit supplementary documentation, if requested.
- Excess of chargebacks, disputes, MED or refunds in a significant proportion relative to the monthly volume.
- Receipt of funds of doubtful origin.
- Judicial determination or by a regulatory authority.
- Identification of an operational failure or need for system maintenance.
- At any time by the partner financial institution, without any liability for TroqPay.
3. User responsibilities and prohibitions
Truthfulness of information: The User is responsible for providing correct and up-to-date data. Providing false or misleading information may result in civil and criminal sanctions, as provided in Art. 299 of the Brazilian Penal Code (Ideological Falsehood), with penalties that may reach up to 5 years of imprisonment.
Misuse: If a user uses the TroqPay platform to carry out scams, they may be held civilly and criminally liable. Among the applicable crimes are fraud (Art. 171, Penal Code), ideological falsehood (Art. 299, Penal Code), money laundering (Law 9.613/98) and criminal association (Art. 288, Penal Code). TroqPay reserves the right to take legal action against the User for damage to the company's image, in addition to reporting any suspicious activity to the Public Prosecutor's Office and other competent authorities.
Credential security: The User must keep their access credentials confidential. Liability for improper access due to the User's negligence is solely theirs.
3.1 Prohibited activities and activities subject to prior approval
The following activities are expressly prohibited on the TroqPay platform, regardless of prior approval:
- Betting, gambling, games of chance and lotteries without a license duly issued by the competent body.
- Pyramid schemes, irregular multilevel marketing and promises of guaranteed returns.
- Sale of cryptoassets, foreign exchange, remittance, credit or financial services without regulatory authorization from the competent authorities.
- Pornography, adult content or any form of sexual exploitation.
- Weapons, ammunition, controlled substances, prescription medicines and pharmaceutical products without authorization from the competent bodies.
- Counterfeit, pirated products or products in violation of intellectual property rights.
- Sale of personal data, documents, third-party accounts, bots or abusive automation services.
- Marketplaces, sub-acquiring, payment splitting or processing charges on behalf of third parties without prior written approval from TroqPay.
- Political donations, entities sanctioned by national or international lists and sectors expressly prohibited by the BaaS Partner.
- Any activity prohibited by applicable law, by orders of competent authorities or by the operating rules of TroqPay's partners.
4. Updates and changes
These Terms may be changed at any time. We recommend that the User consult this page periodically. In the event of substantial changes, we will notify active Users by email.
5. Contact and support
Our only official email: help@troqpay.com
6. Jurisdiction
The courts of the District (Comarca) of Campinas/SP are elected, to the exclusion of any other, however privileged, to settle any matters arising from these Terms of Use and Privacy Policy.
7.1 Tax responsibility
TroqPay does not act as a tax substitute for the User and does not operationally condition the issuance of tax documents on the use of the platform's functionalities. The absence of a requirement for an invoice as an operational prerequisite does not exempt the User from complying with the tax, accounting and fiscal obligations arising from its activity, under the terms of the applicable legislation.
TroqPay and its partners may request, at any time, tax documents, contracts, receipts or additional information for purposes of compliance, prevention of money laundering and terrorist financing (AML/CFT), risk analysis or response to competent authorities.
By opting for receipt, settlement or withdrawal in virtual assets, including supported stablecoins, the User declares to be aware that it is their responsibility, and/or the VASP Partner's responsibility when legally applicable, to comply with the tax, declaratory and ancillary obligations related to virtual assets, including declarations to Brazil's Federal Revenue Service, the Decrypto system, RFB Normative Instruction No. 1.888/2019 and its amendments, Law No. 14.754/2023, RFB Normative Instruction No. 2.180/2024, as well as any assessment, payment or withholding of taxes, including withholding income tax (IRRF) when applicable to their operation.
TroqPay does not file tax declarations on behalf of the User, does not provide tax advice and does not withhold tax on the volume transacted by the User. TroqPay's direct tax obligation is limited to issuing tax documents and paying the taxes levied on its own revenue from technology, software licensing, data processing and API.
7.2 Subaccounts at partner institutions
Use of TroqPay may involve the opening, maintenance or linking of accounts, subaccounts, virtual accounts or operational arrangements with the BaaS Partner, to enable the processing, settlement, segregation, blocking, refund or availability of the transacted amounts.
Such structures are maintained and operated by the responsible BaaS Partner and do not constitute a payment account, bank account, digital wallet or freely movable account maintained directly by TroqPay.
By registering on the platform, submitting their data and documents and using TroqPay's services, the User declares to be aware of and agree with the opening, maintenance and eventual closure of these structures, as well as with the sharing of information with the partner institutions, to the extent necessary for the provision of services. The User may be subject to the partners' policies, operating rules and terms, which will be communicated to the User when applicable.
7.3 Virtual asset operations (stablecoins)
When enabled, the User may request settlement or withdrawal in supported stablecoins through TroqPay's VASP Partner, responsible for quotation, conversion, execution, settlement, completion of applicable regulatory codes, KYC/AML, AML/CFT controls and sending of the virtual assets.
Functionalities involving pay-in, payout, receipt in the customer's local currency, settlement in a foreign fiat currency or settlement in a currency different from the sale currency will depend on the availability, approval and execution by competent partners, including the VASP Partner, financial institutions, payment institutions, foreign exchange, eFX, remittance, settlement or financial infrastructure partners, according to the nature and jurisdiction of each step.
TroqPay does not, on its own account, carry out the purchase, sale, exchange, intermediation, custody or transfer of virtual assets, foreign exchange operations or international payment/transfer services (eFX). TroqPay provides exclusively a technological interface for routing electronic orders, requesting, tracking and operationally recording transactions executed by the VASP Partner.
The reais and the virtual assets related to the User's operations do not enter TroqPay's balance sheet nor pass through a centralized proprietary wallet of TroqPay. The BaaS Partner and the VASP Partner assume, according to their regulatory roles, the position of providers of the financial, payment, conversion, settlement, custody or transfer services eventually involved.
Conditions informed before the operation: Before each stablecoin operation, the User will receive information about the selected asset, applicable quotation, applicable costs and fees, selected blockchain network, responsible provider and estimated settlement time. Confirmation of the operation implies awareness and acceptance of the conditions presented, as required by applicable regulation.
Travel Rule and mandatory data: To enable the VASP Partner to fulfill its regulatory obligations, the User authorizes the collection, validation and transmission of KYC/KYB data, civil identification, CNPJ, articles of association, identification of controllers, the destination wallet's electronic address, ownership information and documentary proof of the lawful origin of the reais received via Pix. The platform does not allow anonymization, masking of the parties' identity or concealment of the wallets involved.
Safety lock and slippage: The virtual asset market may present volatility, network congestion, gas fees and quotation slippage. To reduce the risk of abnormal variations between the request and execution by the VASP Partner, the platform may set systemic quotation tolerance limits. If the variation exceeds the applicable safety limit, the operation may be refused, canceled or submitted for new confirmation.
User responsibility: The User is responsible for providing a wallet address compatible with the selected asset and network, maintaining ownership and security of their keys, proving the lawful origin of funds when requested and complying with their tax and regulatory obligations. TroqPay and the VASP Partner are not liable for address errors, the selected asset, an incompatible network, loss of private key, variations within the informed tolerance limit, network congestion, gas fees or temporary unavailability of third-party infrastructure.
Wallet ownership: It is recommended that the wallet address provided be owned by the User themselves. TroqPay may request confirmation of ownership at any time for compliance and AML/CFT purposes.
8. Dispute module (MED)
The Dispute Module, also called MED (Special Refund Mechanism), organizes in the TroqPay dashboard the cases of dispute, refund or block related to Pix transactions. TroqPay acts as an operational layer for recording, collecting evidence and tracking the case with the applicable partners and procedures.
Opening of the dispute: A dispute may be received by TroqPay through an operational channel, partner financial institution, MED procedure, End Customer dispute, competent body or internal procedure applicable to the case. After registration, the disputed User is notified and the related amount may be frozen or temporarily blocked in the subaccount or in the available amounts until the final decision.
Deadline for defense: The disputed User must respond within the deadline informed in the case, attaching evidence proving the delivery of the product, the provision of the service, tax regularity, ownership and the lawful origin of the operation. This evidence may include, but is not limited to: invoices, contracts, delivery confirmations, tracking codes, system records, images, screenshots, conversations and additional requested documents.
Analysis and decision: The analysis follows the procedure applicable to the case and may involve partner financial institutions, operational channels, competent authorities and TroqPay's own operations team. If the defense is accepted, the block is removed and the amounts remain with the disputed User. If the defense is not submitted or is considered insufficient, the case may result in a refund, debit, chargeback, precautionary retention or block of the disputed amount.
Estimated total time for analysis: Up to 7 days after the dispute is opened.
Absence of defense: If the defense is not submitted within the deadline or is considered unfounded in the applicable procedure, the amounts may remain blocked until the conclusion of the case and, when applicable, be returned or debited from the disputed user's available amounts, in accordance with the BaaS Partner's procedure.
Notification on the platform: The cases recorded by TroqPay are available in a dedicated dispute area within the platform, with the status, deadline and evidence of the case.
Associated costs and risks: TroqPay does not charge fees for opening or losing MED disputes. However, the accumulation of disputes, fraud, refunds, absence of defense or chargebacks in a significant proportion relative to the total volume of transactions may lead to precautionary suspension, operational limitation or account closure after risk analysis, in accordance with the rules of TroqPay, the BaaS Partner, the MED procedure and applicable law.
