# Legal Disclaimer Non-Custodial virtual asset Wallet*Version 1.0 | Last Updated: March 2026* **PLEASE READ THIS DISCLAIMER CAREFULLY AND IN ITS ENTIRETY BEFORE ACCESSING OR USING THIS WALLET. BY ACCESSING OR USING THE WALLET IN ANY MANNER, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREED TO BE BOUND BY ALL TERMS SET OUT HEREIN. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE USE OF THE WALLET.** ## Nature of Software and Non-VASP Status This application ('Wallet') is a client-side, non-custodial software interface that enables users to generate cryptographic key pairs, sign transactions, and interact directly and independently with public blockchain networks. The Operator provides technical infrastructure only. 1. **Self-Custody and Absence of Operator Control** * At no time does the Operator take possession, custody, access, or control of any virtual asset, private key, seed phrase, or other cryptographic material held or generated by the User. * The User bears sole and exclusive responsibility for the safekeeping of their private keys and seed phrases. Loss of these materials results in permanent, irrecoverable loss of access to associated virtual assets. The Operator has no technical or legal ability to assist with recovery under any circumstances. * All blockchain transactions initiated through the Wallet are executed directly by the User's device against the relevant public network. The Operator is not a party to, and does not intermediate, any such transaction. 2. **Non-VASP Declaration under Nigerian Law**The Operator does not constitute a Virtual Asset Service Provider ('VASP') within the meaning of the *Securities and Exchange Commission (SEC) Nigeria Rules on virtual assets Issuance, Offering Platforms, Exchange and Custody 2022*, or any other rule, circular, or guideline issued by SEC Nigeria or the Central Bank of Nigeria ('CBN'). This determination is based on the following objective characteristics of the Wallet: * The Operator does not conduct or facilitate the exchange of virtual assets for fiat currency, or vice versa, for or on behalf of any User; * The Operator does not transfer, transmit, or arrange for the transfer of virtual assets between users or to third parties; * The Operator does not safeguard, administer, or manage virtual assets or instruments enabling control over virtual assets on behalf of any User; * The Operator does not participate in, or provide financial services related to, an issuer's offer or sale of a virtual asset. Accordingly, the Operator is not required to be registered or licensed by SEC Nigeria as a virtual asset exchange, virtual asset custodian, or any other category of virtual asset service provider. Users are advised that SEC Nigeria's regulatory framework is subject to ongoing development and users should independently monitor applicable regulatory updates at *[www.sec.gov.ng](http://www.sec.gov.ng)*. ## No Investment Advice or Financial Services The Wallet does not provide, and no content, data, information, or functionality made accessible through the Wallet constitutes or should be construed as: * Investment advice, portfolio management advice, financial advice, or any recommendation to acquire, hold, dispose of, or otherwise deal with any virtual asset or other financial instrument; * Legal advice, tax advice, accounting advice, or any professional advisory service of any nature; * An offer, solicitation, or invitation to acquire or dispose of any virtual asset or security in any jurisdiction; * A research report or investment analysis of any kind. The Operator is not registered with, and has not been granted any licence by, SEC Nigeria as an investment adviser, portfolio manager, capital market operator, or any other category of service provider under the *Investments and Securities Act 2007 (ISA 2007)* or any rules made thereunder. Any market data, price information, asset information, or third-party analytics displayed through the Wallet are provided solely for informational convenience and do not constitute a recommendation of any kind.virtual assets are highly speculative, volatile, and illiquid instruments. Their value may increase or decrease significantly and without notice, up to and including total loss of value. Past performance is not indicative of future results. Users should seek independent professional advice from qualified legal, financial, and tax advisers before making any decision involving virtual assets. ## No Broker-Dealer or Intermediary Activity; Technological Neutrality The Operator does not act as, and expressly disclaims the status of, any of the following in connection with any transaction involving the User's virtual assets: * A broker, dealer, or broker-dealer within the meaning of applicable Nigerian securities laws; * A market maker, liquidity provider, or trading counterparty; * An exchange operator, alternative trading system, or multilateral trading facility; * An over-the-counter trading intermediary or any comparable financial intermediary; * A payment system provider, remittance service provider, or money services operator as defined under CBN regulations. The Operator does not receive, hold, or transmit any virtual asset on the User's behalf. The Operator does not match buy and sell orders, execute transactions, or receive any commission, spread, mark-up, or other economic benefit derived from the outcome of any User transaction.The Wallet functions as a technologically neutral software tool only. Where the Wallet offers connectivity to third-party decentralised protocols, decentralised exchanges ('DEXs'), cross-chain bridges, staking protocols, or other external services, such connectivity is provided as a technical convenience and shall not be construed as an endorsement, recommendation, or financial service of any kind. The Operator exercises no operational control over, and assumes no responsibility whatsoever for, the security, liquidity, regulatory compliance, continued availability, or conduct of any such third-party protocol or service. ## Compliance with Nigerian Anti-Money Laundering and Counter-Terrorism Financing Law This section is provided in alignment with Nigeria's anti-money laundering ('AML') and counter-terrorism financing ('CTF') framework, principally the *Money Laundering (Prevention and Prohibition) Act, 2022 ('MLPPA 2022')*, the *Terrorism (Prevention and Prohibition) Act, 2022 ('TPPA 2022')*, and the directives of the Financial Intelligence Unit of Nigeria ('NFIU') and the Special Control Unit Against Money Laundering ('SCUML'). 1. **Non-Designated Status of the Operator** The Operator is not a 'Financial Institution' or a 'Designated Non-Financial Business and Profession' ('DNFBP') under the MLPPA 2022, as it does not provide custody, exchange, or transfer services for virtual assets and does not otherwise fall within any designated category. Accordingly, statutory AML/CFT obligations that are attached to designated financial institutions and DNFBPs under the MLPPA 2022 — including customer due diligence, transaction reporting, and record-keeping obligations — do not apply to the Operator in connection with the Wallet. This position is predicated on the non-custodial, non-intermediary nature of the Wallet and is subject to change if applicable law is amended or if the Operator's activities materially change. 1. **User Representations and Warranties** By using the Wallet, the User expressly and irrevocably represents and warrants to the Operator that: * All virtual assets accessed, held, or transacted through the Wallet are lawfully owned by the User or are under the User's lawful control, and are not derived from, nor intended for use in, any criminal activity, including money laundering, terrorism financing, fraud, or kidnapping-for-ransom; * The User's use of the Wallet does not and will not violate any applicable law, including the MLPPA 2022, the TPPA 2022, or the regulations of the EFCC, NFIU, or SCUML; * The User is and will remain solely responsible for any individual reporting obligations that may arise under applicable Nigerian law in connection with their use of virtual assets. ## Foreign Exchange and Capital Controls The Wallet does not provide, and shall not be construed as providing, any Naira-to-virtual asset conversion, on-ramp, or off-ramp service. The Operator does not facilitate, intermediate, or process any foreign exchange transaction. Users agree not to use the Wallet for any purpose that would violate or circumvent the *Foreign Exchange (Monitoring and Miscellaneous Provisions) Act (Cap. F34, LFN 2004)*, any CBN directive or circular relating to foreign exchange, capital controls, or virtual assets, or any other applicable Nigerian law governing cross-border capital flows. Users are solely responsible for ensuring that their use of virtual assets complies with all applicable foreign exchange and capital control regulations. ## Data Privacy — Nigeria Data Protection Act 2023 In alignment with the *Nigeria Data Protection Act 2023 ('NDPA 2023')* and the regulations of the Nigeria Data Protection Commission ('NDPC'): * The Operator does not act as a Data Controller with respect to the User's blockchain transactions. Blockchain transactions are executed and recorded on public, decentralised networks beyond the Operator's control. * The Wallet operates on a privacy-by-design basis. The Operator does not collect, process, or store any Personal Data (as defined under the NDPA 2023) necessary for the mere execution of blockchain transactions. * Where the Operator does collect limited Personal Data for operational purposes (e.g., analytics, support), such collection shall be governed by the Operator's separate Privacy Policy, which is incorporated herein by reference. * Users are advised that blockchain transactions are inherently public and immutable on the relevant public ledger. The Operator cannot delete, anonymise, or alter any on-chain data. ## Third-Party Protocols and External Services The Wallet may provide technical interfaces enabling Users to interact with third-party decentralized protocols, DEXs, bridges, staking contracts, or other external services. With respect to all such third-party services: * Independent Operation: All third-party protocols and services operate independently of the Operator. The Operator exercises no control over their code, governance, liquidity, solvency, or regulatory status. * No Endorsement or Recommendation: The availability of a connection to any third-party service through the Wallet does not constitute a recommendation, endorsement, or financial advice in respect of that service, nor does it constitute any representation as to that service's quality, security, or legal compliance. * User Assumption of Risk: The User interacts with all third-party services entirely at their own risk. The User is solely responsible for conducting their own due diligence on any protocol, asset, or service before committing funds. * No Warranty on Third-Party Code: The Operator makes no representation as to the security or integrity of any smart contract or protocol accessible through the Wallet. Smart contract vulnerabilities, exploits, fraudulent acts by third-party developers, or the insolvency of any third-party protocol are risks entirely outside the Operator's control and responsibility. ## Taxes and Reporting Obligations Users are solely responsible for determining and discharging all tax obligations arising from their use of virtual assets, including obligations under the Companies Income Tax Act (Cap. C21, LFN 2004), the Personal Income Tax Act (Cap. P8, LFN 2004), and any directives of the Federal Inland Revenue Service ('FIRS') relating to virtual assets. The Operator does not provide tax advice, does not withhold any taxes on behalf of Users, and does not report User transaction data to the FIRS or any other tax authority unless required to do so by law. ## Absolute Limitation of Liability To the fullest extent permitted by applicable Nigerian law: * No Fiduciary Duty: The Operator owes no fiduciary duty, duty of care, or any other implied duty to the User in connection with the User's use of the Wallet or any associated virtual assets. * As-Is Basis: The Wallet is provided on an 'as is' and 'as available' basis, without any warranty of any kind, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, security, accuracy, or non-infringement. The Operator shall not be liable, whether in contract, tort, statute, equity, or otherwise, for any loss, damage, cost, or expense, whether direct, indirect, incidental, special, consequential, or punitive, arising out of or in connection with: * Loss of, or failure to safeguard, the User's private keys, seed phrases, or passwords; * Any unauthorised access to the User's Wallet or virtual assets; * Bugs, vulnerabilities, or exploits in any smart contract, protocol, or third-party service; * Fraudulent or deceptive conduct by any third-party protocol developer or project; * Network congestion, high transaction fees ('gas fees'), or failed transactions; * Regulatory actions, asset freezes, or enforcement measures taken by SEC Nigeria, the CBN, the EFCC, SCUML, or any other governmental authority; * Any force majeure event, including cyberattacks, natural disasters, or changes in applicable law; * The volatility, depreciation, or total loss of value of any virtual asset. ## Governing Law, Severability, and Dispute Resolution **Governing Law** This Disclaimer shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without reference to its conflict of laws principles. **Dispute Resolution** Any dispute, controversy, or claim arising out of or in connection with this Disclaimer, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by arbitration administered by the *Hong Kong International Arbitration Centre ('HKIAC')* in accordance with the HKIAC Administered Arbitration Rules in force at the time of commencement of the arbitration (the ‘HKIAC Rules’), which Rules are deemed to be incorporated by reference into this clause. The seat of arbitration shall be Hong Kong. The arbitral tribunal shall consist of one (1) arbitrator, to be appointed in accordance with the HKIAC Rules. The language of arbitration shall be English. The award shall be final and binding upon the parties and may be enforced in any court of competent jurisdiction. Nothing in this clause shall prevent either party from seeking urgent interim or injunctive relief from a court of competent jurisdiction pending the constitution of the arbitral tribunal. **Severability** If any provision of this Disclaimer is found to be invalid, illegal, or unenforceable by a court or arbitral tribunal of competent jurisdiction, such provision shall be severed and the remainder of this Disclaimer shall continue in full force and effect as if such invalid provision had never formed part hereof. **Entire Agreement and Amendment** This Disclaimer, together with any Privacy Policy or Terms of Use published by the Operator, constitutes the entire agreement between the Operator and the User with respect to the subject matter hereof and supersedes all prior representations, understandings, or agreements. The Operator reserves the right to amend this Disclaimer at any time. Continued use of the Wallet following publication of an updated version shall constitute acceptance of the amended terms. --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://pulse-network.gitbook.io/pulse-whitepaper/concepts/legal-disclaimer.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.