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disclosures

Disclosures

Last Updated: May 15, 2026 (draft - pending counsel review)

00. Draft status

Last reviewed by counsel: NOT YET.

These Disclosures are a working draft published in advance of formal legal review. They reflect Blockchain0x's intended regulatory posture but have not been signed off by external counsel. Per-jurisdiction language is provided in good faith and is not legal advice.

01. Purpose of this page

This page collects the risk disclosures, non-custody and non-advice statements, and per-jurisdiction regulatory notices for the Blockchain0x service. It is referenced from our Terms & Conditions and is binding on every user of the Service. Read it before you build on Blockchain0x.

The disclosures here are summaries. They do not replace the operative language in the Terms & Conditions, the Privacy Policy, the Refund Policy, or the Acceptable Use Policy - where any provision in those documents differs from a summary here, those documents control.

02. Non-custody disclosure

Blockchain0x is not a custodian. We do not hold customer funds at the platform layer. We do not control private keys. We cannot move funds on a customer's behalf.

Wallets used through the Service are held by:

  • The agent owner directly (in the case of self-custody integrations).
  • A regulated custody provider the customer has connected, such as Circle Programmable Wallets or Coinbase. Each provider is independently regulated under its own jurisdiction's laws.

The Blockchain0x service is a payment-orchestration layer: we provide APIs, identity primitives, spend policies, audit logs, and a dashboard over those wallets. We are not a money-services business, money transmitter, broker-dealer, custodian, bank, or trust company in any jurisdiction.

03. No investment, financial, tax, or legal advice

Nothing on the Service, in our documentation, in marketing materials, in our blog, in our learn pages, in newsletter emails, or in any communication from us constitutes:

  • Investment advice or a recommendation to buy, sell, or hold any crypto-asset.
  • Financial advice or a solicitation to engage in any financial transaction.
  • Tax advice with respect to any jurisdiction.
  • Legal advice with respect to any jurisdiction.
  • An offer or solicitation to provide regulated financial services.

Examples of price, fees, transaction volume, or revenue mentioned in our materials are illustrative. They are not promises, forecasts, or representations about what you will earn. Past behaviour of any crypto-asset or rail is not predictive of future behaviour. You are solely responsible for evaluating whether a payment, an integration, or a counterparty is appropriate for your circumstances and for obtaining your own professional advice.

04. Crypto-asset and payment risks

You acknowledge the following risks materially affect the use of Blockchain0x and the underlying rails it interoperates with:

  • Blockchain finality. On-chain transactions confirmed at finality are generally irreversible. A wallet that sends USDC to the wrong address has no automatic recourse. Misdirected payments may be permanently lost.
  • Reorg risk. Until a transaction reaches finality on the underlying chain, it can be reversed by a chain reorg. Our APIs surface confirmation counts and finality status; do not act on a `payment.received` event as if it were final.
  • Stablecoin issuer risk. USDC value depends on Circle's ability and willingness to redeem at par. Other stablecoins (USDT, PYUSD, EUROe) have their own issuer-specific risk. Issuer insolvency, regulatory action, or reserve impairment can cause loss of value at the dollar layer.
  • Smart-contract risk. Third-party smart contracts (wallet contracts, paymaster contracts, paid MCP tools your agent calls) may contain bugs or vulnerabilities outside our control.
  • Network operational risk. Base, Ethereum, Solana, Polygon, Arbitrum, and other supported networks may suffer downtime, gas spikes, sequencer issues, or network upgrades that affect availability or cost.
  • Custodial-provider risk. If you use a third-party custody provider (Circle Programmable Wallets, Coinbase Smart Wallet, etc), that provider has its own operational, regulatory, and solvency risk.
  • Volatility and liquidity. Even dollar-pegged stablecoins can de-peg under stress. Exchanges and on/off-ramps may have liquidity constraints during volatility events.
  • Regulatory risk. Crypto-asset and stablecoin regulation is evolving rapidly. Future legislative or enforcement actions in any jurisdiction may make some or all of the Service unavailable to users in that jurisdiction.

05. AI agent-specific risks

AI agents introduce risks beyond the rail-level concerns above. By giving an AI agent payment authority, you accept:

  • Prompt-injection risk. An agent's planner can be manipulated by adversarial inputs in tools it calls, documents it reads, or messages it processes. Blockchain0x's spend-policy controls bound this risk but do not eliminate it.
  • Misalignment risk. An agent may pursue intermediate objectives that produce outcomes the operator did not intend.
  • Pricing and rate-limit risk. An agent may call a paid tool in a loop or accept a quoted price you would not. Spend caps mitigate this; eliminate this entirely by tuning policy aggressively.
  • Counterparty risk. An agent may pay a counterparty that does not deliver the promised work. Blockchain0x's identity layer is a trust signal, not a guarantee.

It is your responsibility to configure spend policies, counterparty allowlists, identity verification, and operational monitoring at the level of caution appropriate to the value at stake.

06. United States

Blockchain0x is not a registered money-services business, a registered broker-dealer, or a registered investment adviser with the U.S. Securities and Exchange Commission, the Financial Crimes Enforcement Network, the Office of the Comptroller of the Currency, or any state-level regulator. We do not provide regulated services that require such registration.

The Service is not available to residents of states or sanctioned jurisdictions in which its use would violate applicable law. You are responsible for compliance with all federal and state laws applicable to your use, including but not limited to securities laws, money-transmission laws, and consumer-protection laws.

No information on the Service constitutes the offer or sale of a security as defined under the Securities Act of 1933 or the Securities Exchange Act of 1934. USDC and similar fiat-pegged stablecoins are not registered securities; we make no representation about whether any other crypto-asset accessed through the Service is or is not a security.

07. European Union and United Kingdom

Blockchain0x is not authorised as a credit institution, electronic-money institution, payment institution, or crypto-asset service provider under EU law (including MiCA) or UK law (FSMA). We do not offer regulated services that require such authorisation.

Stablecoins accessed via the Service (USDC on Base, etc) are issued by their respective issuers under their respective regulatory regimes. Blockchain0x is not the issuer of any crypto-asset.

For users in the EEA / UK: nothing on the Service is a "financial promotion" within the meaning of FSMA section 21 or analogous EU rules. We do not make such promotions in those jurisdictions. If you believe content on the Service constitutes a financial promotion under your applicable law, notify us at [email protected] and we will review.

08. India

Tosh Labs Private Limited, the operator of Blockchain0x, is incorporated under the laws of India. We comply with applicable Indian laws including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, the Foreign Exchange Management Act, 1999 (as applicable), and applicable provisions of the Prevention of Money-Laundering Act, 2002.

The Indian regulatory framework for crypto-assets continues to evolve. Indian users acknowledge that crypto-asset transactions may be subject to taxation under the Income Tax Act, 1961, including the 30% tax on income from virtual digital assets and the 1% TDS under Section 194S where applicable, and are responsible for their own tax filings.

The Service does not constitute "Banking Business" as defined under the Banking Regulation Act, 1949, "Pre-paid Payment Instruments" under the Payment and Settlement Systems Act, 2007, or services regulated under any Reserve Bank of India framework.

09. Sanctions and prohibited jurisdictions

The Service is not available to persons in, organized under the laws of, or resident of jurisdictions subject to comprehensive sanctions imposed by the United Nations, the United States (OFAC), the European Union, the United Kingdom, India, or any other jurisdiction whose sanctions apply to Blockchain0x. This includes (currently) Cuba, Iran, North Korea, Syria, the Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine. The list is illustrative, not exhaustive; the operative list is whatever is in force on the date of your access.

The Service is also unavailable to natural persons or entities listed on the OFAC Specially Designated Nationals and Blocked Persons (SDN) list, the EU Consolidated List, the UK Sanctions List, India's lists maintained under UAPA or by the Ministry of External Affairs, or any equivalent list maintained by another competent authority.

You represent and warrant that neither you nor any of your end users falls into any of the above categories. If your status changes during use, you must immediately cease use and notify us at [email protected].

10. Third-party services

The Service interoperates with third-party providers including Circle, Coinbase, Stripe, our cloud-infrastructure providers, and the underlying blockchain networks. Each third-party service is governed by its own terms and privacy practices. We are not responsible for the availability, accuracy, security, regulatory status, or behaviour of third-party services.

If a third-party service is unavailable, suspended, or terminated, the Blockchain0x features that depend on it may also be unavailable for the duration. We will use reasonable efforts to communicate such outages.

11. No fiduciary relationship

Nothing in the Service or these Disclosures creates a fiduciary, agency, partnership, joint-venture, or trust relationship between you and Blockchain0x or Tosh Labs Private Limited. We provide infrastructure under the Terms & Conditions; that is the entirety of the legal relationship.

12. Changes to these Disclosures

We may update these Disclosures from time to time. Material changes will be notified at least 30 days in advance by email or via the dashboard. The Disclosures in force on the date of your use of the Service govern that use.

13. Contact

For regulatory questions, jurisdiction-specific guidance, or to flag content that may be a regulated activity in your jurisdiction:

Legal - Tosh Labs Private Limited

Email: [email protected]

Postal: Tosh Labs Private Limited, Gurugram, Haryana, India.

Need legal clarification?

Our legal team is dedicated to ensuring your family's data remains protected. If you have any specific questions about our disclosures, we're here to help.