Terms of Service

1. Acceptance of Terms

By accessing or using Xochi ("Service," "Platform," or "we"), you agree to be bound by these Terms and Conditions. If you do not agree, do not use the Service.

You must be at least 18 years of age and legally capable of entering into binding contracts in your jurisdiction.

2. Description of Services

Xochi provides a private decentralized exchange (dark pool) frontend for cross-chain token swaps. You sign an intent, competing solvers bid to fill it, and settlement happens on-chain.

Public and stealth settlement (Ethereum or Base) are available today. The Private level is designed to settle to an Aztec account you own; it is not yet available, and Sovereign is not part of the first release.

The protocol's compliance layer is designed around ERC-8262, a submitted Ethereum standard for zero-knowledge compliance oracles designed to let users prove specific compliance statements without revealing trade data. It is not live yet: the Oracle is qualified on the Base Sepolia testnet first, and no compliance verification or sanctions screening runs in production.

Descriptions of planned features, including Aztec private settlement, the ERC-8262 Oracle and trust scoring, state our current intent. They are not commitments, and these features may change or may not launch.

3. No Custody

Xochi does not take custody of your assets at any time. All trades are executed through non-custodial smart contracts and third-party solvers. You retain full control of your assets until a transaction is signed and broadcast.

You are solely responsible for maintaining the security of your wallet private keys and seed phrases, and for all activity conducted through your connected wallet.

4. Trust Score

The Service is designed to offer optional identity verification through third-party providers to establish a Trust Score, giving verified users reduced trading fees (0.10% - 0.40% based on tier and asset) and access to enhanced privacy features. At launch, self-serve verification reaches the Premium tier at most; the Institutional tier is awarded only through institutional partnerships. This is not yet available: while trust scoring is off, attestations (which may be recorded) do not affect fees or privacy access, and every user trades at the Standard trust tier. A promotional discount, where offered, is separate from the trust tier.

We store only credential hashes, not personally identifying information. Raw identity data may be processed by the provider you select, but it is not sent to Xochi, to the solver, or to any blockchain.

5. Trading and Execution

Trades are executed through an intent-based system: you submit a signed intent, competing solvers bid to fill your order, and the best-priced solver executes your trade.

Price quotes are indicative and subject to change. Final execution prices may differ due to market movement, slippage, or solver availability. Transactions may fail due to insufficient balance, price movement, or network issues.

6. Fees

Trading fees are designed to range from 0.10% to 0.40% based on your Trust Tier and asset. Trust Score is not live yet, so every user pays the Standard tier rate (0.22% - 0.40%). There is no additive privacy premium: privacy is never separately priced. FX trading fees are 0.02% to 0.08% based on size.

You are responsible for all blockchain network fees (gas). We reserve the right to modify fee structures with 30 days' advance notice.

7. Privacy Levels

Public and stealth routes expose amounts; solvers receive exact amounts and destinations.

The Private level is designed to settle to an Aztec account you own. It is recipient-private, not amount-private: your source-chain deposit, its amount and token, stays public, and Xochi and the solver that fills your order see the destination and amount. If your payout uses zk.money's DAI on Aztec, the zk.money signing service that must co-sign every such payment also sees the recipient and the amount, and we cannot verify how it handles them. You hold your own keys and their backup; we never hold them, and losing them may make funds unrecoverable. A shielded payout is complete only when it is final on Aztec and your own wallet has confirmed it is spendable. Sovereign is not part of the first release. Shielded settlement is not available yet. We do not guarantee absolute privacy.

Stealth payout links are cleared once a trade has been completed, failed or refunded with no further update for 7 days; an expired trade keeps them until its trade record is deleted. Trade records are deleted 90 days after the trade's last update in a final state (completed, failed, refunded or expired), and swap failure reports 30 days after they are received. A retention hold delays these deletions, and the solver keeps its own record (see the Privacy Policy). Where a payout's outcome is unclear, we hold it for reconciliation and never automatically send or refund it again.

Notwithstanding your selected privacy level, we may be required to disclose information to regulators or law enforcement pursuant to valid legal process.

8. Prohibited Activities

You agree not to use the Service for money laundering, terrorist financing, sanctions evasion, market manipulation, wash trading, structuring to evade reporting thresholds, or any other unlawful purpose.

9. Restricted Jurisdictions

The Service is not available to residents of Cuba, Iran, North Korea, Syria, Crimea, Donetsk, Luhansk, or any jurisdiction subject to comprehensive US, EU, or UN sanctions. Use of VPNs to circumvent restrictions is prohibited.

10. Risk Disclosures

Cryptocurrency markets are highly volatile. The Service relies on smart contracts that may contain bugs, vulnerabilities, or be subject to exploits. Third-party protocols may experience failures or discontinuation.

Nothing in the Service constitutes investment, legal, tax, or financial advice. Consult qualified professionals before making financial decisions.

11. Limitation of Liability

THE SERVICE IS PROVIDED "AS IS" WITHOUT WARRANTIES OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES.

Our total liability shall not exceed the greater of fees paid by you in the twelve months preceding a claim, or one hundred US dollars ($100).

12. Dispute Resolution

Disputes shall be resolved by binding arbitration under ICC Rules, seated in Geneva, Switzerland, conducted in English. You waive any right to participate in a class action.

These Terms are governed by the laws of the State of Wyoming, United States.

13. Contact

For questions about these Terms, contact us at [email protected]