Terms of Service

Last Updated: February 10, 2026

These Terms of Service (“Terms”) constitute a legally binding agreement between you and Anzo Labs, Inc. (“Avvio,” “we,” “us”) governing your access to and use of the Avvio application, wallet software, and any related websites, products, and services (collectively, the “Service”). By accessing or using Avvio, you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree, you must not use the Service.

1. Eligibility and Compliance

You represent that you are at least eighteen (18) years of age and have the legal capacity to enter into this agreement. You further represent that you are not located in, a resident of, or otherwise subject to any jurisdiction subject to comprehensive sanctions or similar restrictions imposed by the United States, the European Union, the United Kingdom, Canada, or other applicable authorities.

You are solely responsible for ensuring that your use of the Service complies with all applicable laws, rules, and regulations, including those relating to digital assets, anti–money laundering, counter‑terrorist financing, sanctions, tax, and consumer protection, as well as any requirements imposed by our third‑party service partners.

2. Nature of the Avvio Service (Non‑Custodial)

Avvio is non‑custodial wallet software. It enables you to:

  • Create and manage crypto wallets for supported networks (including Bitcoin, Ethereum/EVM, Solana, and other blockchains we may add).

  • Interact with on‑chain protocols, including token transfers, swaps, and cross‑chain bridges, via third‑party infrastructure providers such as OneBalance, LI.FI, Jupiter, Relay, and similar services we may support.

  • Access, now or in the future, fiat on‑/off‑ramp, virtual accounts, card, savings/yield with DeFi protocols, and tokenized‑asset functionality provided by independent third‑party partners (described below), which may not be available in all jurisdictions and may be limited or disabled in some regions.

Avvio does not custody user funds, take possession of your digital assets, or execute transactions on your behalf. You are solely responsible for controlling your private keys and Digital Assets. Avvio cannot access, freeze, or move your assets without your authorization.

Avvio is not a bank, trust company, exchange, broker, dealer, broker‑dealer, investment adviser, investment manager, money services business, money transmitter, or other regulated financial institution, and does not provide custodial, fiduciary, or portfolio‑management services. Any fiat services, card programs, exchange or routing functionality, yield products, or tokenized assets you may access through the Service are provided by independent third parties under their own terms, privacy policies, and regulatory approvals.

3. Wallet Creation and Keys

Wallets for BTC, ETH/EVM, Solana, and other supported networks are generated and managed using Turnkey’s non‑custodial key‑management infrastructure (including multi‑party computation and secure hardware). Signing credentials are protected through cryptographic key‑shares held by Turnkey and your device‑level authentication methods, such as passkeys, biometrics, PINs, or secure enclave mechanisms.

Recovery of wallet access is performed solely through the recovery mechanisms you configure (for example, device‑ or account‑based flows implemented by Turnkey). Avvio does not have the ability to access, reconstruct, or sign transactions on your behalf and cannot reset or bypass your authentication controls.

You are solely responsible for:

  • Safeguarding your devices, credentials, passkeys, and recovery methods.

  • Reviewing all transactions and messages before you approve and sign them.

  • All activity initiated from your wallet(s), whether authorized by you or by someone else using your credentials.

Loss, theft, or compromise of your credentials, devices, or recovery factors may result in irreversible loss of digital assets.

4. Transactions and Third‑Party Protocols

Transactions executed through the Service may be routed via third‑party protocols and infrastructure providers, including OneBalance, LI.FI, Jupiter, Relay, and other DEXs, bridges, and smart‑contract systems. Bitcoin transactions may utilize PSBT or similar signing mechanisms.

Once a transaction is signed and broadcast to a blockchain network, it is generally irreversible and cannot be cancelled or modified by Avvio. Execution depends on network conditions, protocol behavior, and third‑party liquidity and is outside our control.

We do not guarantee any particular:

  • Execution price, slippage, or spread.

  • Settlement time or confirmation speed.

  • Availability, security, or performance of any route, asset, network, or provider.

Your use of any third‑party protocol or service (including DEXs, bridges, on‑ramps, card issuers, and tokenized‑asset providers) is solely between you and that third party and is governed by their terms and policies. Avvio does not control, endorse, or assume responsibility for any third‑party service and is not a party to your relationship with those providers.

5. Bridge Virtual Accounts (If Enabled)

Fiat‑related services, including ACH, wires, and virtual accounts, may be provided by Bridge.xyz and its banking and payment partners. Such accounts are not bank deposits or accounts of Avvio and may not be insured or protected by any deposit‑insurance scheme in your jurisdiction.

Your use of these services is subject solely to the terms, disclosures, and policies of Bridge.xyz and the relevant financial institutions and payment networks. Avvio is not responsible for account opening decisions, transaction approvals, holds, chargebacks, or other actions taken by those third parties.

6. Avvio Card (If Enabled)

Any “Avvio Card” or similar payment card product surfaced in the Service is powered by Bridge.xyz and issued by the applicable licensed bank or card issuer (for example, Lead Bank, Member FDIC, pursuant to a license from Visa U.S.A. Inc., or another issuer as disclosed).

All card usage is governed by the applicable Cardholder Agreement, issuing bank terms, and card‑network rules. Avvio is not the issuer of the card and does not control authorizations, declines, chargebacks, refunds, or settlement decisions, and is not liable for losses arising from those processes.

7. Yield and DeFi Features (If Enabled)

Yield and savings opportunities are facilitated through third‑party protocols and smart contracts, including integrations provided by partners such as yo.xyz and other DeFi platforms. Returns, if any, are not guaranteed and may fluctuate significantly.

Participation exposes you to, among other things, smart‑contract risk, liquidation risk, market volatility, oracle failures, peg loss, governance risk, and potential total loss of principal. You are solely responsible for evaluating these risks.

Avvio does not provide investment, tax, accounting, or financial advice and only offers technical access to these protocols. Nothing in the Service constitutes a recommendation or endorsement of any asset, protocol, or strategy.

8. Tokenized Stocks and Real‑World Assets (If Enabled)

Access to tokenized securities, tokenized stocks, or other real‑world assets (“RWAs”) is provided by licensed partners in permitted jurisdictions, including partners such as XStocks or similar regulated entities. Avvio only provides technical connectivity and user‑interface functionality.

Avvio does not:

  • Advise on the suitability or investment merit of any token or asset.

  • Determine or warrant the legal or regulatory classification of any asset.

You are solely responsible for understanding the nature, legality, and risk profile of any tokenized asset before interacting with it.

9. Fees

Use of the Service may incur:

  • Blockchain network (“gas”) fees.

  • Fees charged by third‑party providers (liquidity providers, on‑ramps, card issuers, DeFi protocols, etc.).

  • Avvio service or routing fees.

Where reasonably possible, applicable fees are disclosed before you confirm a transaction. Avvio may modify its own fee structure at any time to the extent permitted by law. Third‑party providers may change their fees independently and without notice to us.

10. Prohibited Activities

You agree not to use the Service for any unlawful, abusive, or prohibited purpose, including but not limited to:

  • Money laundering, sanctions evasion, terrorist financing, fraud, or other financial crimes.

  • Market manipulation, wash trading, or deceptive practices.

  • Violating export controls, sanctions, or other regulatory restrictions.

  • Attempting to interfere with, disrupt, or compromise the security or integrity of the Service or any blockchain network.

We may, where permitted by law and at our discretion, restrict, suspend, or terminate your access to the Service if we suspect prohibited or high‑risk activity or if requested by a partner or competent authority.

10A. Acceptable Use and Enforcement
As a condition of accessing or using the Service, you agree that you will not:
Violate, misappropriate, or infringe the rights of Avvio, our users, our licensors, or any third party, including privacy, publicity, intellectual‑property, or other proprietary rights.
Use the Service for any illegal, obscene, defamatory, threatening, intimidating, harassing, hateful, or racially or ethnically offensive purpose, or to instigate or encourage conduct that would be illegal or otherwise inappropriate (including promoting violent or financial crimes).
Impersonate any person or entity, or otherwise provide false, inaccurate, or misleading information.
Send spam or otherwise engage in bulk messaging, auto‑messaging, auto‑dialing, or similar unsolicited communications.
Attempt to avoid, bypass, remove, deactivate, impair, or otherwise circumvent any security or access‑control measures used in connection with the Service or any third‑party service integrated into Avvio.
Disguise your location through IP proxying, VPNs, or other methods in order to circumvent geofencing, sanctions, or other restrictions applied by Avvio or its partners.
Interfere with or attempt to interfere with any user, host, or network, including by introducing malware, overloading, flooding, spamming, or mail‑bombing the Service.
Circumvent any content‑filtering techniques, rate limits, or access controls that we or our providers apply to the Service.
Use the Service in any manner that could damage, disable, overburden, or impair the functioning, security, or performance of Avvio, any blockchain network, or any third‑party service.
Use the Service in violation of any applicable law or regulation, including, without limitation, any applicable anti‑money‑laundering, counter‑terrorist‑financing, anti‑proliferation, and sanctions programs (including the U.S. Bank Secrecy Act and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and other relevant authorities).
Encourage, enable, or assist any other person to do any of the foregoing.
By using the Service, you further represent, warrant, and covenant that:
Any Digital Assets you use in connection with the Service have been legally obtained by you, belong to you (or you are duly authorized to use them), and do not infringe any third‑party rights.
You will not use the Service to transmit or exchange Digital Assets that are the direct or indirect proceeds of any criminal or fraudulent activity, including terrorism, sanctions evasion, or tax evasion.
You will pay all applicable network fees (“gas”) and any fees charged by Avvio or third‑party providers for your use of the Service, including where a transaction is presented as “gasless” but a fee is still required on the underlying blockchain.
We have no general obligation to monitor any content or activity on the Service. However, we reserve the right, in our sole discretion and where permitted by law, to (a) monitor use of the Service, and (b) restrict, suspend, or terminate access to the Service, or remove or disable access to any content, at any time and for any reason, including if we believe you have violated these Terms or are otherwise engaging in suspicious or high‑risk activity.

11. Account Deletion and Data

You may request deletion of your Avvio account as described in the app or on our website. Deletion will remove off‑chain profile data we maintain about you, subject to legal and regulatory retention requirements. Blockchain transactions and other on‑chain activity are public and permanent and cannot be erased or modified by Avvio.

Our collection and use of personal data is governed by our Privacy Policy, as amended from time to time.

12. Risks and No Advice

Digital assets and related technologies are experimental and highly volatile. By using the Service, you acknowledge and agree that:

  • You may lose some or all of the value of your digital assets.

  • Protocols, bridges, networks, or partners may fail, be paused, or be exploited.

  • Transactions may be delayed, replayed, front‑run, or otherwise affected by network or protocol behavior.

All information made available through the Service (including prices, quotes, analytics, and educational content) is for informational purposes only and does not constitute legal, financial, tax, or investment advice or a recommendation. You should consult your own professional advisers before making any decisions.

13. No Fiduciary Duty

Avvio provides technology services only and owes you no fiduciary duty. We do not act as your agent, custodian, trustee, broker, or adviser and do not manage assets on your behalf. Nothing in these Terms or your use of the Service creates any fiduciary or advisory relationship between you and Avvio.

14. Limitation of Liability

To the maximum extent permitted by law:

  • Avvio is not liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, data, or goodwill, arising out of or related to the Service.

  • Avvio is not liable for any loss or damage arising from blockchain transactions, market movements, third‑party services or protocols, smart‑contract vulnerabilities, Bridge.xyz services, card‑issuer actions, network congestion, security breaches, or your use or misuse of the Service.

In no event will Avvio’s aggregate liability to you exceed the greater of (a) the amount you paid directly to Avvio for use of the Service in the six (6) months preceding the event giving rise to the claim, or (b) one hundred U.S. dollars (USD 100).

Some jurisdictions do not allow certain limitations of liability, so some of the above limitations may not apply to you.

15. Dispute Resolution and Governing Law

Where permitted by applicable law, you and Avvio agree that:

  • Any dispute, claim, or controversy arising out of or relating to these Terms or the Service will be resolved by binding, individual arbitration, not by a class or representative action.

  • Arbitration will be conducted under the rules of a recognized arbitration provider.

  • These Terms are governed by the laws of the State of Delaware, without regard to its conflict‑of‑laws principles.

If mandatory local law in your jurisdiction prohibits arbitration or requires different consumer protections, those laws will apply to the extent they conflict with this Section.

16. Modifications

We may update these Terms at any time. If we make material changes, we will provide notice (for example, via the app or our website). Your continued use of the Service after changes become effective constitutes your acceptance of the revised Terms.

17. Contact; Regulatory Status

Anzo Labs, Inc.
Email: support@avvio.xyz
Website: https://avvio.xyz

Anzo Labs, Inc. is a self custodial wallet, not a bank, broker, exchange, or investment adviser. Any card products are issued by the relevant licensed card issuer or bank, not by Anzo Labs, Inc. or Avvio. Bridge.xyz and other partners act as program managers and/or regulated service providers for fiat, card, and related services where available.

© 2026 Anzo Labs, Inc. All rights reserved.

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