Contents
01 - Adoption of Self-Governing Digital Asset Compliance Laws Based on Global Standards.
02 - Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy for LXX DAO.
03 - Know Your Customer (KYC) and Investor Verification Policy.
04 - General Data Protection Regulation (GDPR) Compliance Policy.
05 - Privacy Policy.
06 - Digital Asset Custody Framework & Disclaimer.
07 - Third-Party Services, Integrations, and Dependency Disclaimer.
08 - Terms of Use - Crypto-Linked Card Services.
09 - Terms of Use - Decentralized Wallet Services.
02 - Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy for LXX DAO.
03 - Know Your Customer (KYC) and Investor Verification Policy.
04 - General Data Protection Regulation (GDPR) Compliance Policy.
05 - Privacy Policy.
06 - Digital Asset Custody Framework & Disclaimer.
07 - Third-Party Services, Integrations, and Dependency Disclaimer.
08 - Terms of Use - Crypto-Linked Card Services.
09 - Terms of Use - Decentralized Wallet Services.
10 - White Paper download
01
Adoption of Self-Governing Digital Asset Compliance Laws Based on Global Standards.
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Introduction & Commitment to Responsible Innovation
LXX DAO (“the DAO”) is a decentralized autonomous organization built on the principles of transparency, security, and equitable governance. While operating at the frontier of digital finance and organizational structure, the DAO recognizes the paramount importance of legal and regulatory compliance. This document outlines our proactive framework for adopting and integrating global regulatory standards for digital assets, with a primary focus on aligning with the spirit and requirements of the European Union’s Markets in Crypto-Assets Regulation (MiCA) and other emerging global benchmarks. Our operational model, as detailed in our whitepaper, is inherently designed to meet core regulatory objectives: mitigating systemic risk, ensuring transparency, protecting members and counterparties, and preventing market abuse. We view compliance not as a constraint, but as a foundation for sustainable growth and mainstream adoption.
2. Core Principles of Our Compliance Alignment
Our approach is built on the following foundational principles:
● Proactive Alignment: We commit to monitoring, understanding, and adapting our operations and governance to meet the requirements of key regulatory frameworks like MiCA, even in advance of formal, direct applicability to our specific decentralized structure.
● Substance Over Form: We will assess the economic substance of our activities (e.g., capital pooling, asset management, governance rights) and seek to comply with the relevant regulatory objectives, even where existing legal categories do not perfectly map to a DAO.
● Transparency & Disclosure: We uphold the highest standards of transparency through on-chain verifiability of transactions and governance actions, coupled with clear public communication, mirroring the disclosure ethos of traditional and digital asset markets.
● Member & Investor Protection: The mechanisms embedded in our design—such as the bonding curve for entry/exit, the multi-signature Chancellor structure for capital deployment, and the clear mandate system—are engineered to protect participants, a core goal of MiCA and similar regulations.
● Collaboration with Authorities: We are committed to constructive dialogue with regulatory bodies. As envisioned in our structure, a dedicated Compliance Governance Unit (GU) will be tasked with interpreting regulatory developments and implementing necessary controls.
3. Alignment with Key MiCA and Global Standard Provisions
While MiCA primarily regulates legal entities acting as issuers or service providers, LXX DAO’s architecture is designed to fulfill analogous functions in a decentralized manner. Our alignment focuses on the following areas:
a) Governance & Management Accountability:
● MiCA requires clear identification of management and their fitness. In our structure, the Queen DAO (tokenholder collective) holds ultimate oversight, with clearly defined, time-limited Mandates granted to operational GUs (Venture, Treasury, Compliance).
● The Compliance GU is explicitly responsible for ensuring operations adhere to the DAO’s principles and, by extension, to the compliance framework we adopt. This creates a clear line of accountability.
b) Token Classification & Disclosure:
● We acknowledge the importance of proper asset classification. Our DAO Governance Token is designed as a representation of a proportional claim on a diversified, transparently held pool of underlying capital (including stablecoins and other high-quality crypto-assets).
● We will provide clear, ongoing information analogous to a whitepaper or crypto-asset white paper required under MiCA, detailing the rights of token holders, the risks, and the functioning of the DAO.
● MiCA imposes strict custody and safeguarding rules. Our model uses a bonding curve and a transparent, multi-signature (Chancellor) mechanism for all capital movements, involving separate GUs (Treasury, Venture, Compliance) to prevent misuse.
● The portfolio composition and value are intended to be verifiable, aligning with the need for secure and transparent asset management.
d) Market Integrity & Transparency:
● All significant transactions, mandate approvals, and governance votes are recorded on-chain, providing an immutable and publicly auditable ledger. This exceeds traditional transparency requirements and directly supports market integrity goals. e) Cross-Border Operation & Regulatory Cooperation:
● As a global, internet-native entity, we recognize the challenge of multiple jurisdictions. Our commitment to standards like MiCA provides a robust EU-aligned baseline. We will structure our operations and access provisions to respect jurisdictional boundaries and cooperate with regulatory processes where formally required and feasible within our decentralized structure.
4. Implementation and Ongoing Adaptation
1. Designated Function: The Compliance GU will serve as the central point for monitoring regulatory evolution, conducting internal assessments, and proposing protocol upgrades to maintain alignment.
2. Community Education: We will educate our community on the importance of this framework and how their governance decisions impact the DAO’s compliance posture.
3. Iterative Protocol Upgrades: The DAO’s governance allows for the proposal and adoption of technical and procedural updates to meet evolving standards. This may include enhanced KYC/AML procedures for certain interactive functions, reporting modules, or adjustments to GU mandates.
4. Legal Opinion & Engagement: We will seek ongoing specialist legal counsel in key jurisdictions, including the EU, to inform our adaptations and engage in industry dialogues on DAO regulation.
5. Disclaimer & Forward-Looking Statement
This document represents LXX DAO’s current intent and framework for aligning with global digital asset compliance standards. It is not exhaustive legal advice, nor does it constitute a binding guarantee of specific regulatory outcomes. The regulatory landscape for decentralized autonomous organizations is nascent and rapidly evolving. While MiCA provides a significant reference point, its direct application to DAOs remains subject to interpretation by regulators and courts. LXX DAO operates in a decentralized manner, and its compliance efforts are implemented through community-driven governance and technical design. We undertake this proactive alignment in good faith to promote a secure, transparent, and sustainable ecosystem. However, participants should be aware that regulatory risks remain, and the ultimate responsibility for understanding the applicable laws in their jurisdiction lies with each individual member or counterparty. This framework will be reviewed and updated periodically by the Compliance GU in response to new legal developments and community governance decisions.
For further information or regulatory inquiries, please contact: [Designated Point of Contact - To be established by the Compliance GU]
1. Introduction & Commitment to Responsible Innovation
LXX DAO (“the DAO”) is a decentralized autonomous organization built on the principles of transparency, security, and equitable governance. While operating at the frontier of digital finance and organizational structure, the DAO recognizes the paramount importance of legal and regulatory compliance. This document outlines our proactive framework for adopting and integrating global regulatory standards for digital assets, with a primary focus on aligning with the spirit and requirements of the European Union’s Markets in Crypto-Assets Regulation (MiCA) and other emerging global benchmarks. Our operational model, as detailed in our whitepaper, is inherently designed to meet core regulatory objectives: mitigating systemic risk, ensuring transparency, protecting members and counterparties, and preventing market abuse. We view compliance not as a constraint, but as a foundation for sustainable growth and mainstream adoption.
2. Core Principles of Our Compliance Alignment
Our approach is built on the following foundational principles:
● Proactive Alignment: We commit to monitoring, understanding, and adapting our operations and governance to meet the requirements of key regulatory frameworks like MiCA, even in advance of formal, direct applicability to our specific decentralized structure.
● Substance Over Form: We will assess the economic substance of our activities (e.g., capital pooling, asset management, governance rights) and seek to comply with the relevant regulatory objectives, even where existing legal categories do not perfectly map to a DAO.
● Transparency & Disclosure: We uphold the highest standards of transparency through on-chain verifiability of transactions and governance actions, coupled with clear public communication, mirroring the disclosure ethos of traditional and digital asset markets.
● Member & Investor Protection: The mechanisms embedded in our design—such as the bonding curve for entry/exit, the multi-signature Chancellor structure for capital deployment, and the clear mandate system—are engineered to protect participants, a core goal of MiCA and similar regulations.
● Collaboration with Authorities: We are committed to constructive dialogue with regulatory bodies. As envisioned in our structure, a dedicated Compliance Governance Unit (GU) will be tasked with interpreting regulatory developments and implementing necessary controls.
3. Alignment with Key MiCA and Global Standard Provisions
While MiCA primarily regulates legal entities acting as issuers or service providers, LXX DAO’s architecture is designed to fulfill analogous functions in a decentralized manner. Our alignment focuses on the following areas:
a) Governance & Management Accountability:
● MiCA requires clear identification of management and their fitness. In our structure, the Queen DAO (tokenholder collective) holds ultimate oversight, with clearly defined, time-limited Mandates granted to operational GUs (Venture, Treasury, Compliance).
● The Compliance GU is explicitly responsible for ensuring operations adhere to the DAO’s principles and, by extension, to the compliance framework we adopt. This creates a clear line of accountability.
b) Token Classification & Disclosure:
● We acknowledge the importance of proper asset classification. Our DAO Governance Token is designed as a representation of a proportional claim on a diversified, transparently held pool of underlying capital (including stablecoins and other high-quality crypto-assets).
● We will provide clear, ongoing information analogous to a whitepaper or crypto-asset white paper required under MiCA, detailing the rights of token holders, the risks, and the functioning of the DAO.
● MiCA imposes strict custody and safeguarding rules. Our model uses a bonding curve and a transparent, multi-signature (Chancellor) mechanism for all capital movements, involving separate GUs (Treasury, Venture, Compliance) to prevent misuse.
● The portfolio composition and value are intended to be verifiable, aligning with the need for secure and transparent asset management.
d) Market Integrity & Transparency:
● All significant transactions, mandate approvals, and governance votes are recorded on-chain, providing an immutable and publicly auditable ledger. This exceeds traditional transparency requirements and directly supports market integrity goals. e) Cross-Border Operation & Regulatory Cooperation:
● As a global, internet-native entity, we recognize the challenge of multiple jurisdictions. Our commitment to standards like MiCA provides a robust EU-aligned baseline. We will structure our operations and access provisions to respect jurisdictional boundaries and cooperate with regulatory processes where formally required and feasible within our decentralized structure.
4. Implementation and Ongoing Adaptation
1. Designated Function: The Compliance GU will serve as the central point for monitoring regulatory evolution, conducting internal assessments, and proposing protocol upgrades to maintain alignment.
2. Community Education: We will educate our community on the importance of this framework and how their governance decisions impact the DAO’s compliance posture.
3. Iterative Protocol Upgrades: The DAO’s governance allows for the proposal and adoption of technical and procedural updates to meet evolving standards. This may include enhanced KYC/AML procedures for certain interactive functions, reporting modules, or adjustments to GU mandates.
4. Legal Opinion & Engagement: We will seek ongoing specialist legal counsel in key jurisdictions, including the EU, to inform our adaptations and engage in industry dialogues on DAO regulation.
5. Disclaimer & Forward-Looking Statement
This document represents LXX DAO’s current intent and framework for aligning with global digital asset compliance standards. It is not exhaustive legal advice, nor does it constitute a binding guarantee of specific regulatory outcomes. The regulatory landscape for decentralized autonomous organizations is nascent and rapidly evolving. While MiCA provides a significant reference point, its direct application to DAOs remains subject to interpretation by regulators and courts. LXX DAO operates in a decentralized manner, and its compliance efforts are implemented through community-driven governance and technical design. We undertake this proactive alignment in good faith to promote a secure, transparent, and sustainable ecosystem. However, participants should be aware that regulatory risks remain, and the ultimate responsibility for understanding the applicable laws in their jurisdiction lies with each individual member or counterparty. This framework will be reviewed and updated periodically by the Compliance GU in response to new legal developments and community governance decisions.
For further information or regulatory inquiries, please contact: [Designated Point of Contact - To be established by the Compliance GU]
02
Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy for LXX DAO
In Accordance with the Fifth EU Anti-Money Laundering Directive (AMLD5) and German AML Law (GwG)
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Preamble & Commitment
LXX DAO (“the DAO”) is committed to operating with the highest standards of integrity and compliance. As a decentralized autonomous organization utilizing blockchain technology, we recognize the importance of contributing to the global fight against money laundering (ML) and terrorist financing (TF). This policy outlines the principles and procedures adopted by the DAO to mitigate ML/TF risks in alignment with the requirements of the Fifth EU Anti-Money Laundering Directive (AMLD5) and the German Anti-Money Laundering Act (Geldwäschegesetz – GwG).
This policy is based on a risk-based approach, tailored to the unique characteristics of our decentralized structure, our governance token, and the operational model described in our whitepaper.
2. Risk-Based Approach & Scope
The DAO acknowledges that its activities, particularly involving the pooling and deployment of capital through a governance token (LXX), may present certain ML/TF risks. Key risk factors include the pseudonymous nature of blockchain interactions, the global reach of participants, and the potential for asset transfers. Our AML/CTF measures are applied proportionately to these identified risks. The policy applies to all activities governed by the DAO’s smart contracts and to the core operational functions carried out by its Governance Units (GUs), particularly the Treasury GU and Compliance GU.
3. Core AML/CTF Principles
To fulfill our commitment, the DAO adheres to the following principles derived from AMLD5/GwG:
1. Customer Due Diligence (CDD): Identifying and verifying the identity of our members (token holders) to the extent legally required and technologically feasible within a decentralized framework.
2. Risk Assessment: Conducting ongoing assessment of ML/TF risks associated with our activities, member base, and technological tools.
3. Transaction Monitoring: Implementing measures to monitor transactions for suspicious activity.
4. Reporting Obligations: Establishing procedures to report suspicious activities to the competent Financial Intelligence Unit (FIU).
5. Record Keeping: Maintaining records of CDD information and transaction data for the statutory period.
6. Prohibition of Transactions: Refusing to execute, and freezing, transactions where ML/TF is suspected or where CDD cannot be adequately performed.
4. Implementation Measures within the DAO Structure
Given our decentralized nature, compliance is achieved through a combination of technological design, governance rules, and dedicated human oversight.
a) Graduated Customer Due Diligence (CDD):
● Basic Level (For all): Interaction with the DAO’s public smart contracts is permissionless. However, the bonding curve mechanism provides a transparent, on-chain audit trail for all entries (minting) and exits (burning) of LXX tokens, recording wallet addresses and amounts.
● Enhanced Due Diligence (EDD): Enhanced measures will be triggered for:
○ Transactions or interactions exceeding a predefined risk-sensitive threshold.
○ Members seeking to participate directly in Governance Units (GUs) or other privileged roles (e.g., multi-signature signers in the Chancellor structure).
○ Any activity flagged by ongoing monitoring. EDD will require the collection of additional information, which may be facilitated through secure, privacy-preserving off-chain verification processes managed by the Compliance GU.
b) Ongoing Transaction Monitoring & Suspicious Activity Reporting (SAR):
● The Compliance GU is mandated to monitor on-chain activity related to the DAO’s core treasury and mandate executions.
● Automated tools and manual reviews will be used to identify patterns indicative of ML/TF (e.g., layering, rapid circular transactions, links to sanctioned addresses).
● A clear internal procedure will be established for the Compliance GU to assess and, if warranted, escalate potential suspicious activity. The Compliance GU will be empowered to initiate a “Benny Switch” emergency procedure or interact with the Treasury GU to freeze transactions pending investigation, if a severe threat is identified.
● Where there are grounds for suspicion, the Compliance GU is authorized to file a report with the relevant national FIU.
c) Sanctions Compliance:
● The DAO will not engage with, and will block transactions from, wallet addresses listed on relevant sanctions lists (e.g., EU consolidated lists, UN lists).
● The Compliance GU will implement tools to screen interactions against updated sanctions lists.
d) Record Keeping:
● All on-chain transactions are immutably recorded on the Polygon blockchain, satisfying the requirement for a durable, timestamped audit trail. ● Any off-chain CDD information collected for EDD purposes will be stored securely, confidentially, and in compliance with GDPR, for a minimum period of five years (as per GwG §8) after the relationship ends.
e) Internal Organization & Training:
● The Compliance GU will include members with relevant expertise in AML/CTF regulations and blockchain analytics. ● All members of operational GUs (Venture, Treasury, Compliance, Development) will receive training on this AML/CTF policy and their responsibilities.
5. Governance & Policy Enforcement
● This AML/CTF policy is ratified and can be amended by a vote of the Queen DAO (LXX majority token holders).
● The Compliance GU is responsible for the day-to-day implementation, monitoring, and periodic review of this policy.
● The DAO will conduct a regular ML/TF risk assessment, at least annually, to update and refine its measures.
6. Disclaimer & Limitations
LXX DAO is a decentralized, borderless, and pseudonymous network. Full implementation of traditional AML measures designed for centralized financial institutions is technologically and structurally challenging. This policy represents our good-faith effort to integrate the objectives and principles of AMLD5/GwG into our operations to the maximum extent possible within our framework. The regulatory treatment of DAOs is evolving. Each participant (token holder) is ultimately responsible for ensuring their own compliance with all applicable laws and regulations in their jurisdiction, including those related to AML/CTF. By interacting with LXX DAO’s smart contracts or participating in its governance, users acknowledge this policy and the inherent compliance limitations of a decentralized system.
Designated Responsible Person/Unit: Compliance Governance Unit (GU)
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Preamble & Commitment
LXX DAO (“the DAO”) is committed to operating with the highest standards of integrity and compliance. As a decentralized autonomous organization utilizing blockchain technology, we recognize the importance of contributing to the global fight against money laundering (ML) and terrorist financing (TF). This policy outlines the principles and procedures adopted by the DAO to mitigate ML/TF risks in alignment with the requirements of the Fifth EU Anti-Money Laundering Directive (AMLD5) and the German Anti-Money Laundering Act (Geldwäschegesetz – GwG).
This policy is based on a risk-based approach, tailored to the unique characteristics of our decentralized structure, our governance token, and the operational model described in our whitepaper.
2. Risk-Based Approach & Scope
The DAO acknowledges that its activities, particularly involving the pooling and deployment of capital through a governance token (LXX), may present certain ML/TF risks. Key risk factors include the pseudonymous nature of blockchain interactions, the global reach of participants, and the potential for asset transfers. Our AML/CTF measures are applied proportionately to these identified risks. The policy applies to all activities governed by the DAO’s smart contracts and to the core operational functions carried out by its Governance Units (GUs), particularly the Treasury GU and Compliance GU.
3. Core AML/CTF Principles
To fulfill our commitment, the DAO adheres to the following principles derived from AMLD5/GwG:
1. Customer Due Diligence (CDD): Identifying and verifying the identity of our members (token holders) to the extent legally required and technologically feasible within a decentralized framework.
2. Risk Assessment: Conducting ongoing assessment of ML/TF risks associated with our activities, member base, and technological tools.
3. Transaction Monitoring: Implementing measures to monitor transactions for suspicious activity.
4. Reporting Obligations: Establishing procedures to report suspicious activities to the competent Financial Intelligence Unit (FIU).
5. Record Keeping: Maintaining records of CDD information and transaction data for the statutory period.
6. Prohibition of Transactions: Refusing to execute, and freezing, transactions where ML/TF is suspected or where CDD cannot be adequately performed.
4. Implementation Measures within the DAO Structure
Given our decentralized nature, compliance is achieved through a combination of technological design, governance rules, and dedicated human oversight.
a) Graduated Customer Due Diligence (CDD):
● Basic Level (For all): Interaction with the DAO’s public smart contracts is permissionless. However, the bonding curve mechanism provides a transparent, on-chain audit trail for all entries (minting) and exits (burning) of LXX tokens, recording wallet addresses and amounts.
● Enhanced Due Diligence (EDD): Enhanced measures will be triggered for:
○ Transactions or interactions exceeding a predefined risk-sensitive threshold.
○ Members seeking to participate directly in Governance Units (GUs) or other privileged roles (e.g., multi-signature signers in the Chancellor structure).
○ Any activity flagged by ongoing monitoring. EDD will require the collection of additional information, which may be facilitated through secure, privacy-preserving off-chain verification processes managed by the Compliance GU.
b) Ongoing Transaction Monitoring & Suspicious Activity Reporting (SAR):
● The Compliance GU is mandated to monitor on-chain activity related to the DAO’s core treasury and mandate executions.
● Automated tools and manual reviews will be used to identify patterns indicative of ML/TF (e.g., layering, rapid circular transactions, links to sanctioned addresses).
● A clear internal procedure will be established for the Compliance GU to assess and, if warranted, escalate potential suspicious activity. The Compliance GU will be empowered to initiate a “Benny Switch” emergency procedure or interact with the Treasury GU to freeze transactions pending investigation, if a severe threat is identified.
● Where there are grounds for suspicion, the Compliance GU is authorized to file a report with the relevant national FIU.
c) Sanctions Compliance:
● The DAO will not engage with, and will block transactions from, wallet addresses listed on relevant sanctions lists (e.g., EU consolidated lists, UN lists).
● The Compliance GU will implement tools to screen interactions against updated sanctions lists.
d) Record Keeping:
● All on-chain transactions are immutably recorded on the Polygon blockchain, satisfying the requirement for a durable, timestamped audit trail. ● Any off-chain CDD information collected for EDD purposes will be stored securely, confidentially, and in compliance with GDPR, for a minimum period of five years (as per GwG §8) after the relationship ends.
e) Internal Organization & Training:
● The Compliance GU will include members with relevant expertise in AML/CTF regulations and blockchain analytics. ● All members of operational GUs (Venture, Treasury, Compliance, Development) will receive training on this AML/CTF policy and their responsibilities.
5. Governance & Policy Enforcement
● This AML/CTF policy is ratified and can be amended by a vote of the Queen DAO (LXX majority token holders).
● The Compliance GU is responsible for the day-to-day implementation, monitoring, and periodic review of this policy.
● The DAO will conduct a regular ML/TF risk assessment, at least annually, to update and refine its measures.
6. Disclaimer & Limitations
LXX DAO is a decentralized, borderless, and pseudonymous network. Full implementation of traditional AML measures designed for centralized financial institutions is technologically and structurally challenging. This policy represents our good-faith effort to integrate the objectives and principles of AMLD5/GwG into our operations to the maximum extent possible within our framework. The regulatory treatment of DAOs is evolving. Each participant (token holder) is ultimately responsible for ensuring their own compliance with all applicable laws and regulations in their jurisdiction, including those related to AML/CTF. By interacting with LXX DAO’s smart contracts or participating in its governance, users acknowledge this policy and the inherent compliance limitations of a decentralized system.
Designated Responsible Person/Unit: Compliance Governance Unit (GU)
03
Know Your Customer (KYC) and Investor Verification Policy
Aligned with U.S. Securities and Exchange Commission (SEC) Compliance Standards and Framework
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Purpose & Regulatory Alignment
This Know Your Customer (KYC) Policy establishes the principles and procedures for LXX DAO (“the DAO”) to verify the identity of its participants, assess associated risks, and ensure compliance with standards relevant to offerings of digital assets, as informed by the regulatory framework and enforcement priorities of the U.S. Securities and Exchange Commission (SEC). The policy is designed to:
● Mitigate risks of fraud, money laundering, and terrorist financing.
● Prevent unauthorized or fraudulent participation.
● Support a responsible and compliant ecosystem in line with U.S. regulatory expectations for investor protection and market integrity.
● Facilitate the DAO's commitment to operating with transparency and accountability, even within a decentralized structure.
2. Scope & Application: A Risk-Based Tiered Approach
Recognizing the spectrum of involvement within the DAO, this policy applies a risk-based, tiered KYC framework. The depth of verification is proportionate to the level of access, rights, and potential regulatory implications associated with different roles.
a) Tier 1: Basic Token Holder / Passive Participant
● Scope: Any individual or entity acquiring LXX governance tokens via the public bonding curve or secondary markets for the purpose of general holding and/or participation in overarching Queen DAO mandate votes. ● Standard: Given the pseudonymous and permissionless nature of the base-layer blockchain interaction, traditional KYC at this tier is inherently limited. The primary controls are the transparent, on-chain audit trail provided by the bonding curve mechanism and transaction monitoring for suspicious activity (as per the AML Policy).
b) Tier 2: Active Governance Unit (GU) Participant / Service Provider
● Scope: Individuals or entities seeking to contribute work, provide services, or hold a defined operational role within a GU (e.g., Venture GU analyst, Development GU contributor, Treasury GU operator).
● Standard: Mandatory Full KYC Verification. Participation at this level grants influence over capital deployment, operational execution, and potential access to non-public information. This aligns with SEC expectations for individuals involved in the management or essential operations of an asset pool.
● Procedure: Administered by the Compliance GU. Requires submission of:
○ For Individuals: Government-issued photo ID (passport, driver’s license), proof of address, and potentially a source of funds/wealth declaration.
○ For Entities: Certificate of incorporation, articles of association, identification of ultimate beneficial owners (UBOs) holding >25% ownership or control, and identification of authorized representatives.
○ Verification will be conducted using reliable, independent documentation, data, or through a qualified third-party KYC provider.
c) Tier 3: U.S. Person Participation & "Accredited Investor" Verification
● Scope: Any participant who is a "U.S. Person" (as defined in SEC Regulation S) or who seeks to engage in a manner that could be construed as participating in a U.S.-directed offering.
● Standard: Strict Prohibition or Enhanced Verification.
● Procedure:
1. General Prohibition: The DAO does not actively solicit participation from U.S. Persons. The bonding curve interface and official communications will contain clear, affirmative warnings restricting access by U.S. Persons.
2. Accredited Investor Verification (If Applicable): Should the DAO’s activities or the nature of the LXX token evolve, or if a specific mechanism for U.S. participation is established, the Compliance GU will implement a rigorous process to verify "Accredited Investor" status as defined in Rule 501 of Regulation D under the Securities Act of 1933. This involves reviewing:
■ Income or net worth documentation (e.g., tax returns, bank/brokerage statements, credit reports).
■ Written confirmation from a registered broker-dealer, investment adviser, or licensed attorney.
■ Verification via a qualified third-party service.
3. Core KYC Principles Aligned with SEC Expectations
● Investor Protection: The tiered system prioritizes verification for those with operational control, directly addressing SEC concerns about the management of asset pools and protection of investors from fraud.
● Transparency of Control: By identifying GU participants, the DAO aims to provide transparency regarding the parties responsible for key functions, analogous to disclosures about a fund’s management team.
● Prevention of Unregistered Public Offerings: The restrictions on U.S. Persons are a critical component of the DAO’s efforts to avoid conducting an unregistered public offering of securities in the United States, a primary focus of SEC enforcement.
● Ongoing Due Diligence: KYC is not a one-time event. The Compliance GU will periodically re-screen GU participants and monitor for changes in status or red flags.
4. Data Handling, Privacy, and Security
● All collected KYC information will be handled with the utmost confidentiality and security.
● Data will be stored securely off-chain, with access strictly limited to authorized members of the Compliance GU and any necessary, vetted third-party service providers.
● Data collection and processing will comply with applicable data protection regulations, including the GDPR.
● Data retention periods will adhere to statutory requirements (typically 5+ years after the relationship ends).
5. Governance and Implementation
● The Compliance GU is responsible for developing, implementing, overseeing, and auditing this KYC policy.
● The policy is subject to amendment by a vote of the Queen DAO based on recommendations from the Compliance GU, particularly in response to new SEC guidance, enforcement actions, or legal precedent.
● The Compliance GU will maintain a record of all verification actions and will be the point of contact for any regulatory inquiries related to participant identity.
6. Disclaimer and Critical Legal Notice
THIS POLICY IS A STATEMENT OF CURRENT INTERNAL PROCEDURES AND DOES NOT CONSTITUTE LEGAL ADVICE NOR DOES IT GUARANTEE COMPLIANCE WITH U.S. FEDERAL OR STATE SECURITIES LAWS.
The application of U.S. securities laws (including the Howey Test) to decentralized autonomous organizations and their tokens remains an area of significant legal uncertainty and active regulatory scrutiny. The SEC has taken enforcement actions against certain token projects and DAO-like structures it deemed to be offering unregistered securities.
LXX DAO HAS NOT SOUGHT NOR OBTAINED A REGULATORY DETERMINATION FROM THE SEC OR ANY OTHER AUTHORITY REGARDING THE STATUS OF THE LXX TOKEN. PARTICIPATION BY U.S. PERSONS IS STRONGLY DISCOURAGED AND MAY BE TECHNICALLY RESTRICTED.
This KYC policy represents a good-faith effort to implement reasonable investor protection measures informed by the SEC’s regulatory framework. However, all participants must conduct their own independent legal and financial due diligence and understand that engaging with the DAO carries potential legal and regulatory risks.
Designated Responsible Unit: Compliance Governance Unit (GU)
Policy Subject to: Queen DAO Governance Vote & Regulatory Evolution
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Purpose & Regulatory Alignment
This Know Your Customer (KYC) Policy establishes the principles and procedures for LXX DAO (“the DAO”) to verify the identity of its participants, assess associated risks, and ensure compliance with standards relevant to offerings of digital assets, as informed by the regulatory framework and enforcement priorities of the U.S. Securities and Exchange Commission (SEC). The policy is designed to:
● Mitigate risks of fraud, money laundering, and terrorist financing.
● Prevent unauthorized or fraudulent participation.
● Support a responsible and compliant ecosystem in line with U.S. regulatory expectations for investor protection and market integrity.
● Facilitate the DAO's commitment to operating with transparency and accountability, even within a decentralized structure.
2. Scope & Application: A Risk-Based Tiered Approach
Recognizing the spectrum of involvement within the DAO, this policy applies a risk-based, tiered KYC framework. The depth of verification is proportionate to the level of access, rights, and potential regulatory implications associated with different roles.
a) Tier 1: Basic Token Holder / Passive Participant
● Scope: Any individual or entity acquiring LXX governance tokens via the public bonding curve or secondary markets for the purpose of general holding and/or participation in overarching Queen DAO mandate votes. ● Standard: Given the pseudonymous and permissionless nature of the base-layer blockchain interaction, traditional KYC at this tier is inherently limited. The primary controls are the transparent, on-chain audit trail provided by the bonding curve mechanism and transaction monitoring for suspicious activity (as per the AML Policy).
b) Tier 2: Active Governance Unit (GU) Participant / Service Provider
● Scope: Individuals or entities seeking to contribute work, provide services, or hold a defined operational role within a GU (e.g., Venture GU analyst, Development GU contributor, Treasury GU operator).
● Standard: Mandatory Full KYC Verification. Participation at this level grants influence over capital deployment, operational execution, and potential access to non-public information. This aligns with SEC expectations for individuals involved in the management or essential operations of an asset pool.
● Procedure: Administered by the Compliance GU. Requires submission of:
○ For Individuals: Government-issued photo ID (passport, driver’s license), proof of address, and potentially a source of funds/wealth declaration.
○ For Entities: Certificate of incorporation, articles of association, identification of ultimate beneficial owners (UBOs) holding >25% ownership or control, and identification of authorized representatives.
○ Verification will be conducted using reliable, independent documentation, data, or through a qualified third-party KYC provider.
c) Tier 3: U.S. Person Participation & "Accredited Investor" Verification
● Scope: Any participant who is a "U.S. Person" (as defined in SEC Regulation S) or who seeks to engage in a manner that could be construed as participating in a U.S.-directed offering.
● Standard: Strict Prohibition or Enhanced Verification.
● Procedure:
1. General Prohibition: The DAO does not actively solicit participation from U.S. Persons. The bonding curve interface and official communications will contain clear, affirmative warnings restricting access by U.S. Persons.
2. Accredited Investor Verification (If Applicable): Should the DAO’s activities or the nature of the LXX token evolve, or if a specific mechanism for U.S. participation is established, the Compliance GU will implement a rigorous process to verify "Accredited Investor" status as defined in Rule 501 of Regulation D under the Securities Act of 1933. This involves reviewing:
■ Income or net worth documentation (e.g., tax returns, bank/brokerage statements, credit reports).
■ Written confirmation from a registered broker-dealer, investment adviser, or licensed attorney.
■ Verification via a qualified third-party service.
3. Core KYC Principles Aligned with SEC Expectations
● Investor Protection: The tiered system prioritizes verification for those with operational control, directly addressing SEC concerns about the management of asset pools and protection of investors from fraud.
● Transparency of Control: By identifying GU participants, the DAO aims to provide transparency regarding the parties responsible for key functions, analogous to disclosures about a fund’s management team.
● Prevention of Unregistered Public Offerings: The restrictions on U.S. Persons are a critical component of the DAO’s efforts to avoid conducting an unregistered public offering of securities in the United States, a primary focus of SEC enforcement.
● Ongoing Due Diligence: KYC is not a one-time event. The Compliance GU will periodically re-screen GU participants and monitor for changes in status or red flags.
4. Data Handling, Privacy, and Security
● All collected KYC information will be handled with the utmost confidentiality and security.
● Data will be stored securely off-chain, with access strictly limited to authorized members of the Compliance GU and any necessary, vetted third-party service providers.
● Data collection and processing will comply with applicable data protection regulations, including the GDPR.
● Data retention periods will adhere to statutory requirements (typically 5+ years after the relationship ends).
5. Governance and Implementation
● The Compliance GU is responsible for developing, implementing, overseeing, and auditing this KYC policy.
● The policy is subject to amendment by a vote of the Queen DAO based on recommendations from the Compliance GU, particularly in response to new SEC guidance, enforcement actions, or legal precedent.
● The Compliance GU will maintain a record of all verification actions and will be the point of contact for any regulatory inquiries related to participant identity.
6. Disclaimer and Critical Legal Notice
THIS POLICY IS A STATEMENT OF CURRENT INTERNAL PROCEDURES AND DOES NOT CONSTITUTE LEGAL ADVICE NOR DOES IT GUARANTEE COMPLIANCE WITH U.S. FEDERAL OR STATE SECURITIES LAWS.
The application of U.S. securities laws (including the Howey Test) to decentralized autonomous organizations and their tokens remains an area of significant legal uncertainty and active regulatory scrutiny. The SEC has taken enforcement actions against certain token projects and DAO-like structures it deemed to be offering unregistered securities.
LXX DAO HAS NOT SOUGHT NOR OBTAINED A REGULATORY DETERMINATION FROM THE SEC OR ANY OTHER AUTHORITY REGARDING THE STATUS OF THE LXX TOKEN. PARTICIPATION BY U.S. PERSONS IS STRONGLY DISCOURAGED AND MAY BE TECHNICALLY RESTRICTED.
This KYC policy represents a good-faith effort to implement reasonable investor protection measures informed by the SEC’s regulatory framework. However, all participants must conduct their own independent legal and financial due diligence and understand that engaging with the DAO carries potential legal and regulatory risks.
Designated Responsible Unit: Compliance Governance Unit (GU)
Policy Subject to: Queen DAO Governance Vote & Regulatory Evolution
04
General Data Protection Regulation (GDPR) Compliance Policy
For LXX DAO and Its Governance Structure
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Introduction & Commitment
LXX DAO ("the DAO") is a decentralized autonomous organization. While operating on public, pseudonymous blockchain infrastructure, the DAO recognizes that certain activities may involve the processing of personal data as defined by the European Union General Data Protection Regulation (EU) 2016/679 ("GDPR") and related data protection laws. This policy outlines our commitment to data protection principles and establishes a framework for handling personal data responsibly, lawfully, and transparently when such processing occurs within our operations. This applies primarily to identifiable information collected off-chain (e.g., through KYC processes, GU contributor onboarding, or community interactions) and to the pseudonymous on-chain data that could become identifiable.
2. Definitions & Roles within the DAO Structure
● Personal Data: Any information relating to an identified or identifiable natural person ("Data Subject").
● Processing: Any operation performed on personal data (e.g., collection, storage, use, erasure).
● Data Controller: The entity that determines the purposes and means of processing personal data. Given the DAO's decentralized nature, LXX DAO, acting through its collective governance, is considered the joint data controller for processing activities undertaken to fulfill its operational objectives. The Compliance Governance Unit (GU) is designated to oversee and coordinate GDPR compliance on behalf of the DAO.
● Data Processor: An entity that processes personal data on behalf of the controller. This may include third-party service providers (e.g., KYC vendors, cloud hosting providers, communication platform providers) engaged by any GU.
3. Core Data Protection Principles
The DAO is committed to processing data in accordance with the following GDPR principles:
1. Lawfulness, Fairness, and Transparency: Processing will have a valid legal basis (e.g., consent, contractual necessity, legitimate interest, legal obligation). Data subjects will be informed via clear privacy notices.
2. Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
3. Data Minimization: Only data that is adequate, relevant, and limited to what is necessary for the purposes will be processed.
4. Accuracy: Personal data will be kept accurate and, where necessary, kept up to date.
5. Storage Limitation: Personal data will be kept in a form which permits identification of data subjects for no longer than is necessary.
6. Integrity and Confidentiality: Processing will ensure appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
7. Accountability: The DAO, via the Compliance GU, will demonstrate compliance with all these principles.
4. Legal Bases for Processing
The DAO will rely on the following legal bases for processing personal data:
● Contractual Necessity: To onboard and manage contributors to Governance Units (GUs), execute agreements, and process payments.
● Legal Obligation: To comply with AML/CFT (AMLD5) and KYC obligations as outlined in our separate policies.
● Legitimate Interests: For the purposes of network security, fraud prevention, governance administration, and furthering the DAO's objectives, provided such interests are not overridden by the data subject's fundamental rights. A Legitimate Interest Assessment (LIA) will be conducted for such processing.
● Consent: Where no other basis applies, explicit, informed, and freely given consent will be obtained and can be withdrawn at any time.
5. Data Subject Rights
The DAO commits to facilitating the following rights of Data Subjects, which will be managed primarily by the Compliance GU:
1. Right of Access: The right to confirm whether their data is being processed and to access that data.
2. Right to Rectification: The right to have inaccurate personal data corrected.
3. Right to Erasure ("Right to be Forgotten"): The right to have personal data deleted under certain circumstances. Note: This right may be limited in relation to immutable on-chain data and data we are legally obliged to retain (e.g., for AML purposes).
4. Right to Restriction of Processing: The right to restrict processing under certain conditions.
5. Right to Data Portability: The right to receive their personal data in a structured, commonly used, and machine-readable format.
6. Right to Object: The right to object to processing based on legitimate interests or for direct marketing.
7. Rights related to Automated Decision-Making: The DAO does not engage in solely automated decision-making with legal or similarly significant effects.
Procedure for Exercising Rights: Data Subjects can submit requests to the designated contact point. The Compliance GU will verify the identity of the requester and respond within one month.
6. Data Security & Breach Response
● Security Measures: The DAO mandates that all GUs implement appropriate technical and organizational measures (e.g., encryption, access controls, secure storage solutions) to protect personal data. This is particularly critical for off-chain data stores managed by the Treasury, Compliance, and Venture GUs.
● Data Breach Protocol: The Compliance GU will establish an internal procedure for detecting, reporting, and investigating personal data breaches. In the event of a breach likely to result in a risk to individuals' rights and freedoms, the Compliance GU will notify the relevant supervisory authority (e.g., the Irish Data Protection Commission, if designated) within 72 hours and, if the risk is high, communicate the breach to affected Data Subjects without undue delay.
7. Data Transfers Outside the EU/EEA
If personal data is transferred to third countries (e.g., to a KYC provider based in the USA), the DAO will ensure such transfers are governed by appropriate safeguards as required by the GDPR, such as:
● Adequacy Decisions by the European Commission.
● Standard Contractual Clauses (SCCs).
● Binding Corporate Rules (BCRs).
8. Record of Processing Activities (RoPA)
The Compliance GU will maintain a Record of Processing Activities as required by Article 30 GDPR, documenting processing purposes, data categories, recipients, transfers, and retention periods.
9. Privacy by Design & by Default
All GUs, when proposing new processes, tools, or smart contracts that may involve personal data, must consider data protection from the initial design stage and throughout the lifecycle (Privacy by Design). Default settings should always be the most privacy-friendly (Privacy by Default).
10. Contact & Supervisory Authority
● Designated Contact for Data Subjects & Authorities: Compliance Governance Unit (GU) - via a dedicated, secure communication channel published on the DAO's website.
● Lead Supervisory Authority: Given the DAO's pan-European nature and lack of a central establishment, the Irish Data Protection Commission is preliminarily identified as the lead supervisory authority for cross-border processing, in line with the GDPR's one-stop-shop mechanism. This designation is subject to review based on the DAO's evolving structure and main point of administrative decision-making.
11. Policy Governance & Review
This policy is ratified by the Queen DAO. The Compliance GU is responsible for its implementation, monitoring, and periodic review (at least annually). The policy will be updated in response to changes in law, regulatory guidance, or the DAO's own processing activities.
Disclaimer
This GDPR Policy represents LXX DAO's commitment to data protection principles within a novel decentralized structure. The application of GDPR to decentralized autonomous organizations involves complex legal questions. This document is a framework for good practice and is not exhaustive legal advice. Data Subjects with specific concerns are advised to seek independent legal counsel.
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Introduction & Commitment
LXX DAO ("the DAO") is a decentralized autonomous organization. While operating on public, pseudonymous blockchain infrastructure, the DAO recognizes that certain activities may involve the processing of personal data as defined by the European Union General Data Protection Regulation (EU) 2016/679 ("GDPR") and related data protection laws. This policy outlines our commitment to data protection principles and establishes a framework for handling personal data responsibly, lawfully, and transparently when such processing occurs within our operations. This applies primarily to identifiable information collected off-chain (e.g., through KYC processes, GU contributor onboarding, or community interactions) and to the pseudonymous on-chain data that could become identifiable.
2. Definitions & Roles within the DAO Structure
● Personal Data: Any information relating to an identified or identifiable natural person ("Data Subject").
● Processing: Any operation performed on personal data (e.g., collection, storage, use, erasure).
● Data Controller: The entity that determines the purposes and means of processing personal data. Given the DAO's decentralized nature, LXX DAO, acting through its collective governance, is considered the joint data controller for processing activities undertaken to fulfill its operational objectives. The Compliance Governance Unit (GU) is designated to oversee and coordinate GDPR compliance on behalf of the DAO.
● Data Processor: An entity that processes personal data on behalf of the controller. This may include third-party service providers (e.g., KYC vendors, cloud hosting providers, communication platform providers) engaged by any GU.
3. Core Data Protection Principles
The DAO is committed to processing data in accordance with the following GDPR principles:
1. Lawfulness, Fairness, and Transparency: Processing will have a valid legal basis (e.g., consent, contractual necessity, legitimate interest, legal obligation). Data subjects will be informed via clear privacy notices.
2. Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
3. Data Minimization: Only data that is adequate, relevant, and limited to what is necessary for the purposes will be processed.
4. Accuracy: Personal data will be kept accurate and, where necessary, kept up to date.
5. Storage Limitation: Personal data will be kept in a form which permits identification of data subjects for no longer than is necessary.
6. Integrity and Confidentiality: Processing will ensure appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
7. Accountability: The DAO, via the Compliance GU, will demonstrate compliance with all these principles.
4. Legal Bases for Processing
The DAO will rely on the following legal bases for processing personal data:
● Contractual Necessity: To onboard and manage contributors to Governance Units (GUs), execute agreements, and process payments.
● Legal Obligation: To comply with AML/CFT (AMLD5) and KYC obligations as outlined in our separate policies.
● Legitimate Interests: For the purposes of network security, fraud prevention, governance administration, and furthering the DAO's objectives, provided such interests are not overridden by the data subject's fundamental rights. A Legitimate Interest Assessment (LIA) will be conducted for such processing.
● Consent: Where no other basis applies, explicit, informed, and freely given consent will be obtained and can be withdrawn at any time.
5. Data Subject Rights
The DAO commits to facilitating the following rights of Data Subjects, which will be managed primarily by the Compliance GU:
1. Right of Access: The right to confirm whether their data is being processed and to access that data.
2. Right to Rectification: The right to have inaccurate personal data corrected.
3. Right to Erasure ("Right to be Forgotten"): The right to have personal data deleted under certain circumstances. Note: This right may be limited in relation to immutable on-chain data and data we are legally obliged to retain (e.g., for AML purposes).
4. Right to Restriction of Processing: The right to restrict processing under certain conditions.
5. Right to Data Portability: The right to receive their personal data in a structured, commonly used, and machine-readable format.
6. Right to Object: The right to object to processing based on legitimate interests or for direct marketing.
7. Rights related to Automated Decision-Making: The DAO does not engage in solely automated decision-making with legal or similarly significant effects.
Procedure for Exercising Rights: Data Subjects can submit requests to the designated contact point. The Compliance GU will verify the identity of the requester and respond within one month.
6. Data Security & Breach Response
● Security Measures: The DAO mandates that all GUs implement appropriate technical and organizational measures (e.g., encryption, access controls, secure storage solutions) to protect personal data. This is particularly critical for off-chain data stores managed by the Treasury, Compliance, and Venture GUs.
● Data Breach Protocol: The Compliance GU will establish an internal procedure for detecting, reporting, and investigating personal data breaches. In the event of a breach likely to result in a risk to individuals' rights and freedoms, the Compliance GU will notify the relevant supervisory authority (e.g., the Irish Data Protection Commission, if designated) within 72 hours and, if the risk is high, communicate the breach to affected Data Subjects without undue delay.
7. Data Transfers Outside the EU/EEA
If personal data is transferred to third countries (e.g., to a KYC provider based in the USA), the DAO will ensure such transfers are governed by appropriate safeguards as required by the GDPR, such as:
● Adequacy Decisions by the European Commission.
● Standard Contractual Clauses (SCCs).
● Binding Corporate Rules (BCRs).
8. Record of Processing Activities (RoPA)
The Compliance GU will maintain a Record of Processing Activities as required by Article 30 GDPR, documenting processing purposes, data categories, recipients, transfers, and retention periods.
9. Privacy by Design & by Default
All GUs, when proposing new processes, tools, or smart contracts that may involve personal data, must consider data protection from the initial design stage and throughout the lifecycle (Privacy by Design). Default settings should always be the most privacy-friendly (Privacy by Default).
10. Contact & Supervisory Authority
● Designated Contact for Data Subjects & Authorities: Compliance Governance Unit (GU) - via a dedicated, secure communication channel published on the DAO's website.
● Lead Supervisory Authority: Given the DAO's pan-European nature and lack of a central establishment, the Irish Data Protection Commission is preliminarily identified as the lead supervisory authority for cross-border processing, in line with the GDPR's one-stop-shop mechanism. This designation is subject to review based on the DAO's evolving structure and main point of administrative decision-making.
11. Policy Governance & Review
This policy is ratified by the Queen DAO. The Compliance GU is responsible for its implementation, monitoring, and periodic review (at least annually). The policy will be updated in response to changes in law, regulatory guidance, or the DAO's own processing activities.
Disclaimer
This GDPR Policy represents LXX DAO's commitment to data protection principles within a novel decentralized structure. The application of GDPR to decentralized autonomous organizations involves complex legal questions. This document is a framework for good practice and is not exhaustive legal advice. Data Subjects with specific concerns are advised to seek independent legal counsel.
05
Privacy Policy
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Introduction
Welcome to LXX DAO. This Privacy Policy explains how we, as a decentralized autonomous organization ("DAO," "we," "our"), approach information in the context of our operations, which are primarily built on public blockchain technology. It outlines the limited circumstances under which we may process personal data, your rights regarding that data, and the inherent transparency of blockchain-based systems. By interacting with our website (https://www.lxx-dao.com/), our smart contracts, or participating in our governance, you acknowledge the terms described in this policy.
2. Key Principles & the Nature of a DAO
Transparency & Immutability: Core to our operation is the use of public, permissionless blockchains (like Polygon). Transactions, governance votes, and smart contract interactions are recorded on-chain. This data is public, permanent, and immutable.
Pseudonymity: Interactions are typically conducted via blockchain addresses (public keys), which are pseudonymous identifiers not directly linked to your real-world identity unless you choose to reveal that linkage. Limited Off-Chain Data Collection: Our primary interface is the blockchain. We aim to minimize the collection of personal data off-chain. Where collection occurs, it is done with purpose, transparency, and in accordance with applicable law.
3. Information We May Process
A. Information from Blockchain Interactions (On-Chain Data):
● Public Wallet Addresses: The blockchain address you use to interact with LXX DAO smart contracts (e.g., to acquire LXX tokens via the bonding curve, to vote, to delegate).
● Transaction Data: Details of your interactions, including amounts, timestamps, and the functions called within our smart contracts. This is publicly visible on blockchain explorers.
● Voting History: Your governance participation, including votes cast on mandates and proposals, is recorded on-chain. B. Information You Provide Directly (Off-Chain Data):
● Communication Data: If you contact us via email, social media, or community channels (e.g., Discord, Telegram), we process the contents of your messages and your contact details.
● Contributor/KYC Data: If you apply to contribute to a Governance Unit (GU) in a capacity that requires identification (as per our KYC Policy), the Compliance GU may collect necessary personal information such as name, government ID, proof of address, and professional details. This is processed under strict controls.
● Website Usage Data: Our website may collect standard log data (IP address, browser type, pages visited) and use cookies for essential functionality and analytics. We aim to use privacy-preserving tools where possible.
4. Purposes and Legal Bases for Processing
We process information for the following purposes and under the corresponding legal bases:
1. Introduction
Welcome to LXX DAO. This Privacy Policy explains how we, as a decentralized autonomous organization ("DAO," "we," "our"), approach information in the context of our operations, which are primarily built on public blockchain technology. It outlines the limited circumstances under which we may process personal data, your rights regarding that data, and the inherent transparency of blockchain-based systems. By interacting with our website (https://www.lxx-dao.com/), our smart contracts, or participating in our governance, you acknowledge the terms described in this policy.
2. Key Principles & the Nature of a DAO
Transparency & Immutability: Core to our operation is the use of public, permissionless blockchains (like Polygon). Transactions, governance votes, and smart contract interactions are recorded on-chain. This data is public, permanent, and immutable.
Pseudonymity: Interactions are typically conducted via blockchain addresses (public keys), which are pseudonymous identifiers not directly linked to your real-world identity unless you choose to reveal that linkage. Limited Off-Chain Data Collection: Our primary interface is the blockchain. We aim to minimize the collection of personal data off-chain. Where collection occurs, it is done with purpose, transparency, and in accordance with applicable law.
3. Information We May Process
A. Information from Blockchain Interactions (On-Chain Data):
● Public Wallet Addresses: The blockchain address you use to interact with LXX DAO smart contracts (e.g., to acquire LXX tokens via the bonding curve, to vote, to delegate).
● Transaction Data: Details of your interactions, including amounts, timestamps, and the functions called within our smart contracts. This is publicly visible on blockchain explorers.
● Voting History: Your governance participation, including votes cast on mandates and proposals, is recorded on-chain. B. Information You Provide Directly (Off-Chain Data):
● Communication Data: If you contact us via email, social media, or community channels (e.g., Discord, Telegram), we process the contents of your messages and your contact details.
● Contributor/KYC Data: If you apply to contribute to a Governance Unit (GU) in a capacity that requires identification (as per our KYC Policy), the Compliance GU may collect necessary personal information such as name, government ID, proof of address, and professional details. This is processed under strict controls.
● Website Usage Data: Our website may collect standard log data (IP address, browser type, pages visited) and use cookies for essential functionality and analytics. We aim to use privacy-preserving tools where possible.
4. Purposes and Legal Bases for Processing
We process information for the following purposes and under the corresponding legal bases:
Purpose
Legal Basis (Where GDPR applies)
To execute blockchain transactions and smart contract operations (e.g., token minting/burning, governance execution).
Contractual Necessity: To perform the services inherent to the DAO’s protocol.
To facilitate on-chain governance and voting.
Legitimate Interest: To enable the decentralized governance model fundamental to the DAO’s operation.
To ensure security, integrity, and prevent abuse (e.g., monitoring for Sybil attacks, fraud).
Legitimate Interest: To protect the DAO and its members.
To comply with legal obligations (e.g., AML/CFT checks for GU contributors).
Legal Obligation.
To respond to your inquiries and provide support.
Legitimate Interest or your Consent.
To analyze and improve our website and community tools.
Legitimate Interest or your Consent (for non-essential cookies/analytics).
5. How We Share Information
● Publicly, via the Blockchain: As stated, all on-chain data is inherently shared with the global network of blockchain participants and is publicly accessible.
● With Service Providers: We may use trusted third-party providers for specific functions (e.g., hosting, communication platforms, KYC verification for contributors). These providers are bound by contractual obligations to protect your data.
● To Comply with Law: We may disclose information if required by law, regulation, legal process, or governmental request.
● Within the DAO Structure: Information may be shared between Governance Units (GUs) on a need-to-know basis to fulfill the DAO's operational mandates (e.g., the Compliance GU may verify a contributor's status for the Venture GU).
We do not sell your personal data.
6. International Data Transfers
As a global, internet-native entity, data may be processed in countries outside your home jurisdiction. When transferring personal data from the European Economic Area (EEA) to countries not deemed to have adequate data protection, we will implement appropriate safeguards (such as Standard Contractual Clauses) as required by law.
7. Data Retention
● On-Chain Data: Cannot be altered or deleted due to the immutable nature of the blockchain. Consider this before transacting.
● Off-Chain Data: We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. Specific retention periods are defined in our internal records.
8. Your Rights (Particularly for EEA/UK Individuals)
Under regulations like the GDPR, you may have rights regarding your personal data, including:
● Right of Access & Portability
● Right to Rectification
● Right to Erasure (Note: This is limited for on-chain data and data we must retain for legal reasons).
● Right to Restrict Processing
● Right to Object
● Right to Withdraw Consent
To exercise these rights, please contact the Compliance GU using the details below. We will respond within one month and may need to verify your identity. You also have the right to lodge a complaint with your local data protection authority.
9. Security
We implement appropriate technical and organizational measures to protect the off-chain personal data we process. However, no system is 100% secure. You are solely responsible for the security of your private keys and wallet credentials.
10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children.
11. Changes to This Policy
We may update this Privacy Policy. The "Last Updated" date at the top will indicate when changes were made. Material changes will be communicated through our official channels (website, governance forum). Your continued participation after changes constitutes acceptance.
12. Contact Us
For questions about this Privacy Policy or to exercise your data rights, please contact the designated team:
LXX DAO Compliance Governance Unit (GU)
Email/Contact Form:
Governance Forum:
This role is responsible for overseeing data protection matters on behalf of the LXX DAO collective.
Disclaimer: This Privacy Policy applies to the processing of personal data for which LXX DAO, in its capacity as a jointly-controlled entity, determines the purposes and means. It does not cover the practices of third-party websites, wallets, or exchanges you may use to interact with the blockchain. You should review their privacy policies separately.
● Publicly, via the Blockchain: As stated, all on-chain data is inherently shared with the global network of blockchain participants and is publicly accessible.
● With Service Providers: We may use trusted third-party providers for specific functions (e.g., hosting, communication platforms, KYC verification for contributors). These providers are bound by contractual obligations to protect your data.
● To Comply with Law: We may disclose information if required by law, regulation, legal process, or governmental request.
● Within the DAO Structure: Information may be shared between Governance Units (GUs) on a need-to-know basis to fulfill the DAO's operational mandates (e.g., the Compliance GU may verify a contributor's status for the Venture GU).
We do not sell your personal data.
6. International Data Transfers
As a global, internet-native entity, data may be processed in countries outside your home jurisdiction. When transferring personal data from the European Economic Area (EEA) to countries not deemed to have adequate data protection, we will implement appropriate safeguards (such as Standard Contractual Clauses) as required by law.
7. Data Retention
● On-Chain Data: Cannot be altered or deleted due to the immutable nature of the blockchain. Consider this before transacting.
● Off-Chain Data: We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. Specific retention periods are defined in our internal records.
8. Your Rights (Particularly for EEA/UK Individuals)
Under regulations like the GDPR, you may have rights regarding your personal data, including:
● Right of Access & Portability
● Right to Rectification
● Right to Erasure (Note: This is limited for on-chain data and data we must retain for legal reasons).
● Right to Restrict Processing
● Right to Object
● Right to Withdraw Consent
To exercise these rights, please contact the Compliance GU using the details below. We will respond within one month and may need to verify your identity. You also have the right to lodge a complaint with your local data protection authority.
9. Security
We implement appropriate technical and organizational measures to protect the off-chain personal data we process. However, no system is 100% secure. You are solely responsible for the security of your private keys and wallet credentials.
10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children.
11. Changes to This Policy
We may update this Privacy Policy. The "Last Updated" date at the top will indicate when changes were made. Material changes will be communicated through our official channels (website, governance forum). Your continued participation after changes constitutes acceptance.
12. Contact Us
For questions about this Privacy Policy or to exercise your data rights, please contact the designated team:
LXX DAO Compliance Governance Unit (GU)
Email/Contact Form:
Governance Forum:
This role is responsible for overseeing data protection matters on behalf of the LXX DAO collective.
Disclaimer: This Privacy Policy applies to the processing of personal data for which LXX DAO, in its capacity as a jointly-controlled entity, determines the purposes and means. It does not cover the practices of third-party websites, wallets, or exchanges you may use to interact with the blockchain. You should review their privacy policies separately.
06
Digital Asset Custody Framework & Disclaimer
LXX DAO – Notice on Non-Custodial Nature of Services
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Preamble: The Principle of Self-Custody
LXX DAO (“the DAO,” “we,” “our”) is a decentralized autonomous organization comprised of open-source smart contracts and a community of token holders. A foundational and non-negotiable principle of our operation is that LXX DAO does not, under any circumstances, take custody of users’ digital assets. All participants in the LXX ecosystem retain sole and absolute control over their private keys and the digital assets associated with their blockchain addresses.
This Framework Note serves as a definitive statement on this principle, detailing the technical and operational realities of interaction with the DAO, and outlining the critical responsibilities borne solely by the user.
2. Definition of Custody in the Digital Asset Context
For the purposes of this document, “custody” refers to the holding, storing, or possessing of digital assets on behalf of another party, coupled with the ability to unilaterally control, transfer, or dispose of those assets without the ongoing and specific authorization of the owner. This typically involves control over private keys. LXX DAO explicitly disclaims and does not engage in any such activity. The architecture of the DAO is purposefully designed to eliminate any central point of control over user assets.
3. Technical Architecture: How Interactions Are Non-Custodial
The user experience is one of direct, permissionless interaction with autonomous software:
● Interaction via User-Controlled Wallets: All actions—whether acquiring LXX tokens, voting, or redeeming tokens—are initiated by the user signing a transaction with their private key from a self-custodied wallet (e.g., MetaMask, Ledger). The DAO’s interface never requests or has access to private keys.
● The Bonding Curve Smart Contract: The mechanism for minting (buying) and burning (selling) LXX tokens is an autonomous smart contract. When you mint tokens, you send stablecoins (e.g., USDC, DAI) directly to this contract and it programmatically sends LXX tokens to your address. At no point do any individuals or entities within the DAO control these inbound stablecoins; they are pooled within the publicly verifiable smart contract logic.
● The Treasury Multi-Signature (“Chancellor”): The underlying capital pool of the DAO is governed by a decentralized multi-signature wallet requiring consensus from separate, independent Governance Units (Treasury GU, Venture GU, Compliance GU). This structure secures the DAO’s treasury, not user assets. Users do not deposit assets into this multi-sig; they interact with the public bonding curve contract.
4. User Responsibilities & Self-Custody Imperatives
By choosing to interact with LXX DAO, you affirmatively accept the following responsibilities:
1. Private Key Security: You are solely responsible for the generation, security, confidentiality, and backup of your private keys, seed phrases, and wallet passwords. Loss of this information will result in the permanent, irreversible loss of associated digital assets. LXX DAO has no means to recover or reset lost credentials.
2. Transaction Accuracy: You are responsible for verifying the accuracy of all transaction details (e.g., contract addresses, token types, amounts) before signing and broadcasting. Transactions on the blockchain are irreversible.
3. Wallet & Device Security: You are responsible for implementing appropriate security measures for your wallet software and the devices you use to access it, including protection against malware, phishing attacks, and unauthorized access.
4. Understanding of Protocol Risks: You are responsible for understanding the specific risks associated with interacting with decentralized finance (DeFi) smart contracts, including but not limited to: smart contract bugs or exploits, governance attacks, economic design failures, and impermanent loss.
5. Explicit Disclaimers of Custody & Liability
● No Custodial Relationship: No action taken by you in relation to LXX DAO’s smart contracts creates a custodial relationship, bailment, trustee-beneficiary relationship, or any other fiduciary relationship between you and LXX DAO, its community members, or its Governance Units.
● No Asset Recovery: The DAO cannot and will not attempt to recover, return, or restore any digital assets sent to incorrect addresses, lost due to user error, or stolen due to compromised user security.
● No Control Over External Protocols: The DAO may interact with or invest in other DeFi protocols via its mandate. The security and custodial models of those third-party protocols are entirely separate and are not governed by this framework. Users of LXX tokens are not directly exposed to the custodial risks of underlying portfolio protocols.
● Regulatory Status: This non-custodial model is a critical factor in the DAO’s operational and regulatory posture. It distinguishes the activity from that of regulated custodians, money transmitters, or e-money institutions.
6. Recommendations for Safe Participation
1. Use a hardware wallet for significant holdings.
2. Double-check all contract addresses against official sources published on our website and block explorer.
3. Never share your private keys, seed phrases, or passwords with anyone.
4. Stay informed about DAO governance proposals that could alter protocol parameters or risk profiles.
5. Seek independent legal and financial advice to understand the full implications of participation.
7. No Legal or Financial Advice
This Framework Note is for informational purposes only. It does not constitute legal, financial, tax, or investment advice. You should consult with your own professional advisors concerning your specific situation.
ACKNOWLEDGEMENT
BY INTERACTING WITH LXX DAO’S SMART CONTRACTS OR PROTOCOL, YOU EXPLICITLY ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND UNCONDITIONALLY ACCEPT THE NON-CUSTODIAL NATURE OF THE SERVICES AS DESCRIBED IN THIS FRAMEWORK NOTE. YOU ASSUME FULL AND SOLE RESPONSIBILITY FOR THE SECURITY AND CONTROL OF YOUR DIGITAL ASSETS.
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Preamble: The Principle of Self-Custody
LXX DAO (“the DAO,” “we,” “our”) is a decentralized autonomous organization comprised of open-source smart contracts and a community of token holders. A foundational and non-negotiable principle of our operation is that LXX DAO does not, under any circumstances, take custody of users’ digital assets. All participants in the LXX ecosystem retain sole and absolute control over their private keys and the digital assets associated with their blockchain addresses.
This Framework Note serves as a definitive statement on this principle, detailing the technical and operational realities of interaction with the DAO, and outlining the critical responsibilities borne solely by the user.
2. Definition of Custody in the Digital Asset Context
For the purposes of this document, “custody” refers to the holding, storing, or possessing of digital assets on behalf of another party, coupled with the ability to unilaterally control, transfer, or dispose of those assets without the ongoing and specific authorization of the owner. This typically involves control over private keys. LXX DAO explicitly disclaims and does not engage in any such activity. The architecture of the DAO is purposefully designed to eliminate any central point of control over user assets.
3. Technical Architecture: How Interactions Are Non-Custodial
The user experience is one of direct, permissionless interaction with autonomous software:
● Interaction via User-Controlled Wallets: All actions—whether acquiring LXX tokens, voting, or redeeming tokens—are initiated by the user signing a transaction with their private key from a self-custodied wallet (e.g., MetaMask, Ledger). The DAO’s interface never requests or has access to private keys.
● The Bonding Curve Smart Contract: The mechanism for minting (buying) and burning (selling) LXX tokens is an autonomous smart contract. When you mint tokens, you send stablecoins (e.g., USDC, DAI) directly to this contract and it programmatically sends LXX tokens to your address. At no point do any individuals or entities within the DAO control these inbound stablecoins; they are pooled within the publicly verifiable smart contract logic.
● The Treasury Multi-Signature (“Chancellor”): The underlying capital pool of the DAO is governed by a decentralized multi-signature wallet requiring consensus from separate, independent Governance Units (Treasury GU, Venture GU, Compliance GU). This structure secures the DAO’s treasury, not user assets. Users do not deposit assets into this multi-sig; they interact with the public bonding curve contract.
4. User Responsibilities & Self-Custody Imperatives
By choosing to interact with LXX DAO, you affirmatively accept the following responsibilities:
1. Private Key Security: You are solely responsible for the generation, security, confidentiality, and backup of your private keys, seed phrases, and wallet passwords. Loss of this information will result in the permanent, irreversible loss of associated digital assets. LXX DAO has no means to recover or reset lost credentials.
2. Transaction Accuracy: You are responsible for verifying the accuracy of all transaction details (e.g., contract addresses, token types, amounts) before signing and broadcasting. Transactions on the blockchain are irreversible.
3. Wallet & Device Security: You are responsible for implementing appropriate security measures for your wallet software and the devices you use to access it, including protection against malware, phishing attacks, and unauthorized access.
4. Understanding of Protocol Risks: You are responsible for understanding the specific risks associated with interacting with decentralized finance (DeFi) smart contracts, including but not limited to: smart contract bugs or exploits, governance attacks, economic design failures, and impermanent loss.
5. Explicit Disclaimers of Custody & Liability
● No Custodial Relationship: No action taken by you in relation to LXX DAO’s smart contracts creates a custodial relationship, bailment, trustee-beneficiary relationship, or any other fiduciary relationship between you and LXX DAO, its community members, or its Governance Units.
● No Asset Recovery: The DAO cannot and will not attempt to recover, return, or restore any digital assets sent to incorrect addresses, lost due to user error, or stolen due to compromised user security.
● No Control Over External Protocols: The DAO may interact with or invest in other DeFi protocols via its mandate. The security and custodial models of those third-party protocols are entirely separate and are not governed by this framework. Users of LXX tokens are not directly exposed to the custodial risks of underlying portfolio protocols.
● Regulatory Status: This non-custodial model is a critical factor in the DAO’s operational and regulatory posture. It distinguishes the activity from that of regulated custodians, money transmitters, or e-money institutions.
6. Recommendations for Safe Participation
1. Use a hardware wallet for significant holdings.
2. Double-check all contract addresses against official sources published on our website and block explorer.
3. Never share your private keys, seed phrases, or passwords with anyone.
4. Stay informed about DAO governance proposals that could alter protocol parameters or risk profiles.
5. Seek independent legal and financial advice to understand the full implications of participation.
7. No Legal or Financial Advice
This Framework Note is for informational purposes only. It does not constitute legal, financial, tax, or investment advice. You should consult with your own professional advisors concerning your specific situation.
ACKNOWLEDGEMENT
BY INTERACTING WITH LXX DAO’S SMART CONTRACTS OR PROTOCOL, YOU EXPLICITLY ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND UNCONDITIONALLY ACCEPT THE NON-CUSTODIAL NATURE OF THE SERVICES AS DESCRIBED IN THIS FRAMEWORK NOTE. YOU ASSUME FULL AND SOLE RESPONSIBILITY FOR THE SECURITY AND CONTROL OF YOUR DIGITAL ASSETS.
07
Third-Party Services, Integrations, and Dependency Disclaimer
LXX DAO – Notice Regarding External Protocols, Providers, and Infrastructure
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Introduction & Purpose
LXX DAO (“the DAO,” “we,” “our”) operates within a broad and interconnected digital ecosystem. Our protocol utilizes public blockchain infrastructure and may interact with, reference, or depend upon various external third-party services, smart contracts, software, and information providers ("Third-Party Services").
This Disclaimer is a critical notice that LXX DAO does not own, control, endorse, audit, or guarantee the security, functionality, accuracy, or legality of any Third-Party Service. All interactions with such services by users or by the DAO itself carry inherent and independent risks. By engaging with LXX DAO, you explicitly acknowledge and accept these risks.
2. Categories of Third-Party Services & Associated Disclaimers
A. Underlying Blockchain Networks & Infrastructure
● Services: The Polygon network, Ethereum, and other blockchains upon which LXX DAO contracts are deployed or may interact.
● Disclaimer: The DAO is dependent on the continued, secure, and uncensored operation of these public networks. We disclaim all liability for:
○ Network outages, congestion, or forks.
○ Changes in consensus rules or operational policies.
○ Security failures of the underlying blockchain.
○ Transaction fees ("gas") and their volatility.
B. User Wallet & Key Management Services
● Services: Browser extension wallets (e.g., MetaMask), hardware wallets (e.g., Ledger, Trezor), mobile wallets, and other software used by participants to manage private keys and sign transactions.
● Disclaimer: LXX DAO does not develop, audit, or support any wallet software. We are not responsible for:
○ Security flaws, bugs, or phishing attacks targeting wallet interfaces.
○ User error in managing private keys or seed phrases.
○ The design, functionality, or discontinuation of any wallet service.
○ Users are solely responsible for selecting and securing their chosen wallet.
C. Oracle Services & External Data Providers
● Services: Decentralized oracle networks (e.g., Chainlink) or other data feeds that may be used to provide price information (e.g., for Net Asset Value calculations) or other off-chain data to DAO smart contracts.
● Disclaimer: The accuracy and secure delivery of this data are vital. The DAO disclaims liability for:
○ Oracle failure, manipulation, or provision of incorrect data.
○ The economic or operational failure of the oracle network itself.
○ Any losses incurred due to reliance on such external data.
D. KYC/AML & Identity Verification Providers
● Services: Third-party platforms potentially used by the Compliance GU to perform identity verification for Governance Unit contributors, as outlined in our KYC Policy.
● Disclaimer: The use of such a provider does not constitute an endorsement. We are not responsible for:
○ The provider's data handling, security practices, or compliance with laws.
○ Errors in verification processes.
○ Any breach of data occurring at the provider.
○ Users must review the provider's own terms and privacy policy.
E. Other DeFi Protocols & Smart Contracts
● Services: External decentralized finance protocols, lending platforms, decentralized exchanges (DEXs), or asset management contracts with which the DAO’s treasury may interact under a specific investment mandate.
● Disclaimer: These interactions carry extreme risk. The DAO explicitly disclaims liability for:
○ Smart contract vulnerabilities, exploits, or hacks in these external protocols.
○ The economic design, failure, or "rug pulls" associated with other projects.
○ Impermanent loss or other financial risks specific to those protocols.
○ The performance and security of any third-party protocol are solely the responsibility of its developers and governance. LXX DAO’s due diligence is not a guarantee.
F. Communication & Collaboration Platforms
● Services: Websites, forums (e.g., Discourse), governance portals (e.g., Snapshot, Tally), and real-time chat applications (e.g., Discord, Telegram) used for community discussion and governance.
● Disclaimer: These are independent platforms. We disclaim liability for:
○ Platform outages, data loss, or changes in terms of service.
○ The content posted by other users, including fraudulent links or misinformation.
○ Security breaches of the platform that may expose user data.
○ Official governance actions occur on-chain; community platforms are for discussion only.
G. Fiat On-Ramps / Off-Ramps & Centralized Exchanges (CEXs)
● Services: Any service used to convert fiat currency to/from the digital assets used to interact with the DAO.
● Disclaimer: LXX DAO is in no way affiliated with these services. We are not responsible for:
○ Their regulatory compliance, solvency, or operational integrity.
○ User disputes regarding transactions, fees, or account access.
○ The listing, delisting, or trading parameters of the LXX token on any exchange.
3. General Disclaimers & User Responsibilities
1. No Endorsement: Reference to any Third-Party Service does not constitute an endorsement, recommendation, or approval by LXX DAO.
2. Due Diligence is Your Responsibility: You are solely responsible for conducting your own independent research (DYOR—Do Your Own Research) into the security, reputation, and risks associated with any Third-Party Service you choose to use in connection with LXX DAO.
3. No Warranty: All Third-Party Services are provided on an "as is" and "as available" basis, without warranties of any kind, either express or implied.
4. Assumption of Risk: You assume all risks arising from your use of any Third-Party Service, including the risk of financial loss. The DAO’s treasury may also be exposed to these risks through its mandated activities.
4. Protocol Dependency and Governance
The DAO’s governance may propose and ratify mandates that involve integration with or dependency on specific Third-Party Services. Such governance decisions:
● Are made collectively by token holders based on available information.
● Do not negate the inherent risks of the Third-Party Service.
● Should be evaluated critically by each participant.
ACKNOWLEDGEMENT
YOUR USE OF LXX DAO’S PROTOCOL IMPLIES YOUR EXPRESS UNDERSTANDING AND UNCONDITIONAL ACCEPTANCE THAT THE DAO OPERATES WITHIN A BROAD ECOSYSTEM OF INDEPENDENT, UNCONTROLLED THIRD-PARTY SERVICES. YOU BEAR SOLE RESPONSIBILITY FOR ASSESSING AND ACCEPTING THE RISKS ASSOCIATED WITH THESE DEPENDENCIES.
This document is an integral part of the LXX DAO risk disclosure framework and should be read in conjunction with all other published policies and disclaimers.
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Introduction & Purpose
LXX DAO (“the DAO,” “we,” “our”) operates within a broad and interconnected digital ecosystem. Our protocol utilizes public blockchain infrastructure and may interact with, reference, or depend upon various external third-party services, smart contracts, software, and information providers ("Third-Party Services").
This Disclaimer is a critical notice that LXX DAO does not own, control, endorse, audit, or guarantee the security, functionality, accuracy, or legality of any Third-Party Service. All interactions with such services by users or by the DAO itself carry inherent and independent risks. By engaging with LXX DAO, you explicitly acknowledge and accept these risks.
2. Categories of Third-Party Services & Associated Disclaimers
A. Underlying Blockchain Networks & Infrastructure
● Services: The Polygon network, Ethereum, and other blockchains upon which LXX DAO contracts are deployed or may interact.
● Disclaimer: The DAO is dependent on the continued, secure, and uncensored operation of these public networks. We disclaim all liability for:
○ Network outages, congestion, or forks.
○ Changes in consensus rules or operational policies.
○ Security failures of the underlying blockchain.
○ Transaction fees ("gas") and their volatility.
B. User Wallet & Key Management Services
● Services: Browser extension wallets (e.g., MetaMask), hardware wallets (e.g., Ledger, Trezor), mobile wallets, and other software used by participants to manage private keys and sign transactions.
● Disclaimer: LXX DAO does not develop, audit, or support any wallet software. We are not responsible for:
○ Security flaws, bugs, or phishing attacks targeting wallet interfaces.
○ User error in managing private keys or seed phrases.
○ The design, functionality, or discontinuation of any wallet service.
○ Users are solely responsible for selecting and securing their chosen wallet.
C. Oracle Services & External Data Providers
● Services: Decentralized oracle networks (e.g., Chainlink) or other data feeds that may be used to provide price information (e.g., for Net Asset Value calculations) or other off-chain data to DAO smart contracts.
● Disclaimer: The accuracy and secure delivery of this data are vital. The DAO disclaims liability for:
○ Oracle failure, manipulation, or provision of incorrect data.
○ The economic or operational failure of the oracle network itself.
○ Any losses incurred due to reliance on such external data.
D. KYC/AML & Identity Verification Providers
● Services: Third-party platforms potentially used by the Compliance GU to perform identity verification for Governance Unit contributors, as outlined in our KYC Policy.
● Disclaimer: The use of such a provider does not constitute an endorsement. We are not responsible for:
○ The provider's data handling, security practices, or compliance with laws.
○ Errors in verification processes.
○ Any breach of data occurring at the provider.
○ Users must review the provider's own terms and privacy policy.
E. Other DeFi Protocols & Smart Contracts
● Services: External decentralized finance protocols, lending platforms, decentralized exchanges (DEXs), or asset management contracts with which the DAO’s treasury may interact under a specific investment mandate.
● Disclaimer: These interactions carry extreme risk. The DAO explicitly disclaims liability for:
○ Smart contract vulnerabilities, exploits, or hacks in these external protocols.
○ The economic design, failure, or "rug pulls" associated with other projects.
○ Impermanent loss or other financial risks specific to those protocols.
○ The performance and security of any third-party protocol are solely the responsibility of its developers and governance. LXX DAO’s due diligence is not a guarantee.
F. Communication & Collaboration Platforms
● Services: Websites, forums (e.g., Discourse), governance portals (e.g., Snapshot, Tally), and real-time chat applications (e.g., Discord, Telegram) used for community discussion and governance.
● Disclaimer: These are independent platforms. We disclaim liability for:
○ Platform outages, data loss, or changes in terms of service.
○ The content posted by other users, including fraudulent links or misinformation.
○ Security breaches of the platform that may expose user data.
○ Official governance actions occur on-chain; community platforms are for discussion only.
G. Fiat On-Ramps / Off-Ramps & Centralized Exchanges (CEXs)
● Services: Any service used to convert fiat currency to/from the digital assets used to interact with the DAO.
● Disclaimer: LXX DAO is in no way affiliated with these services. We are not responsible for:
○ Their regulatory compliance, solvency, or operational integrity.
○ User disputes regarding transactions, fees, or account access.
○ The listing, delisting, or trading parameters of the LXX token on any exchange.
3. General Disclaimers & User Responsibilities
1. No Endorsement: Reference to any Third-Party Service does not constitute an endorsement, recommendation, or approval by LXX DAO.
2. Due Diligence is Your Responsibility: You are solely responsible for conducting your own independent research (DYOR—Do Your Own Research) into the security, reputation, and risks associated with any Third-Party Service you choose to use in connection with LXX DAO.
3. No Warranty: All Third-Party Services are provided on an "as is" and "as available" basis, without warranties of any kind, either express or implied.
4. Assumption of Risk: You assume all risks arising from your use of any Third-Party Service, including the risk of financial loss. The DAO’s treasury may also be exposed to these risks through its mandated activities.
4. Protocol Dependency and Governance
The DAO’s governance may propose and ratify mandates that involve integration with or dependency on specific Third-Party Services. Such governance decisions:
● Are made collectively by token holders based on available information.
● Do not negate the inherent risks of the Third-Party Service.
● Should be evaluated critically by each participant.
ACKNOWLEDGEMENT
YOUR USE OF LXX DAO’S PROTOCOL IMPLIES YOUR EXPRESS UNDERSTANDING AND UNCONDITIONAL ACCEPTANCE THAT THE DAO OPERATES WITHIN A BROAD ECOSYSTEM OF INDEPENDENT, UNCONTROLLED THIRD-PARTY SERVICES. YOU BEAR SOLE RESPONSIBILITY FOR ASSESSING AND ACCEPTING THE RISKS ASSOCIATED WITH THESE DEPENDENCIES.
This document is an integral part of the LXX DAO risk disclosure framework and should be read in conjunction with all other published policies and disclaimers.
08
Terms of Use – Crypto-Linked Card Services
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
IMPORTANT NOTICE:
THESE TERMS GOVERN THE USE OF A THIRD-PARTY CARD LINKED TO YOUR SELF-CUSTODIED DIGITAL ASSETS. LXX DAO IS NOT A BANK, MONEY TRANSMITTER, OR CARD ISSUER. READ THESE TERMS CAREFULLY BEFORE USING THE SERVICE.
1. Acceptance of Terms
These Terms of Use ("Card Terms") constitute a legally binding agreement between you ("Cardholder," "you," "your") and the LXX DAO community regarding your use of any crypto-linked card services ("Card Services") facilitated through or promoted by LXX DAO's ecosystem. These Card Terms incorporate by reference our Privacy Policy, AML Policy, and KYC Policy. By applying for, activating, or using the Card Services, you acknowledge that you have read, understood, and agree to be bound by these Card Terms. If you do not agree, you must not apply for or use the Card Services.
2. Nature of Service & Critical Third-Party Partnership
2.1 Non-Custodial Bridge Service: The Card Service is designed to function as a non-custodial bridge between your self-custodied digital assets and traditional payment networks. The core mechanism involves a qualified, licensed third-party card issuer and program manager ("Card Issuer").
2.2 Role of LXX DAO: LXX DAO does not issue the card, is not a party to the cardholder agreement with the Card Issuer, does not hold funds, and is not a regulated financial institution. LXX DAO's role may be limited to:
● Providing a technical interface or referral to the Card Issuer's services.
● Facilitating community governance over any partnership parameters.
● LXX DAO BEARS NO LIABILITY FOR THE ACTIONS, OMISSIONS, OR FINANCIAL CONDITION OF THE CARD ISSUER.
2.3 Primary Agreement with Card Issuer: Your use of the physical or virtual card is governed primarily by a separate Cardholder Agreement issued by the licensed Card Issuer. You must agree to those terms directly with the Card Issuer. These Card Terms supplement but do not replace that agreement. In the event of a conflict, the Card Issuer's Cardholder Agreement controls matters pertaining to card issuance, transaction processing, fees, and liability.
3. Card Functionality & Your Authorizations
3.1 Asset Conversion (On-Ramp/Off-Ramp): To fund a transaction, you authorize a process whereby:
● You initiate a swap of your self-custodied digital assets (e.g., LXX tokens, stablecoins) for fiat currency (e.g., EUR, USD) via a decentralized or licensed exchange partner.
● The resulting fiat proceeds are settled to an account controlled by the Card Issuer and loaded onto your card.
● You understand this conversion is a distinct taxable event in many jurisdictions and are solely responsible for any tax consequences.
3.2 No Credit or Overdraft: The card is prepaid only. Transactions cannot exceed the available fiat balance loaded on the card. There is no credit line, overdraft facility, or deposit insurance (e.g., FDIC, EU DGS) on the crypto assets or card balance.
3.3 Prohibited Transactions: You agree not to use the Card Services for:
● Illegal activities or purchases in prohibited categories (e.g., adult content, gambling, illicit substances) as defined by the Card Issuer.
● Circumventing financial sanctions or AML controls.
● Arbitrage or speculative trading via merchant refunds.
● Any activity that violates the terms of the Card Issuer.
4. User Eligibility, KYC & Representations
4.1 Eligibility: You must:
● Be of legal age in your country of residence.
● Pass the Card Issuer's and any required partner's KYC/AML verification procedures, which are mandatory and more stringent than basic protocol interaction.
● Reside in a jurisdiction where the Card Services are legally available.
● The service is NOT available to residents of prohibited jurisdictions, including but not limited to the United States.
4.2 Ongoing Compliance: You represent and warrant that all information provided for KYC is accurate and will be updated promptly upon any change. You will comply with all applicable laws related to the use of the Card Services, including anti-money laundering, counter-terrorist financing, and tax reporting laws.
5. Fees, Exchange Rates & Economic Terms
5.1 Disclosure of Costs: Using the Card Services incurs various fees, including but not limited to:
● Card Issuance/Maintenance Fees: Charged by the Card Issuer.
● Asset Conversion Fees (Spread): Applied during the swap from crypto to fiat.
● Transaction Fees: For ATM withdrawals, foreign transactions, etc.
● Network Fees: Blockchain gas fees for the initial transfer of your crypto assets. All fees will be clearly disclosed by the Card Issuer and/or the conversion service provider prior to your confirmation.
5.2 Foreign Exchange (FX): For transactions in a currency other than your card's base currency, the conversion will use an exchange rate set by the Card Issuer or the card network (e.g., Visa), which may include a markup. You bear all FX risk.
6. Risk Disclosures & Limitation of Liability
6.1 Specific Card Risks: You acknowledge and accept the following inherent risks:
● Third-Party Insolvency Risk: The Card Issuer is a separate legal entity. Its failure could result in loss of funds held as card balances.
● Transaction Finality & Reversals: Card transactions, especially with merchants, may be subject to holds, reversals (chargebacks), and disputes governed by card network rules, not blockchain finality.
● Technical & Fraud Risks: Card details can be stolen, skimmed, or compromised. Unauthorized transactions may occur. The liability framework is governed by the Card Issuer's agreement and applicable law (e.g., EU PSD2 limits).
● Regulatory Risk: The regulatory status of crypto-linked cards is evolving. Services may be suspended or terminated in your jurisdiction with little notice.
6.2 Limitation of LXX DAO's Liability:
TO THE MAXIMUM EXTENT PERMITTED BY LAW, LXX DAO, ITS CONTRIBUTORS, AND TOKEN HOLDERS SHALL HAVE NO LIABILITY FOR:
● ANY LOSSES ARISING FROM THE ACTS, OMISSIONS, OR INSOLVENCY OF THE CARD ISSUER OR ANY THIRD-PARTY SERVICE PROVIDER.
● ANY UNAUTHORIZED TRANSACTIONS ON YOUR CARD.
● DISPUTES BETWEEN YOU AND MERCHANTS OR THE CARD ISSUER.
● LOSSES DUE TO FRAUD, MARKET VOLATILITY DURING CONVERSION, OR CHANGES IN REGULATORY ENVIRONMENTS.
● CONSEQUENTIAL, INCIDENTAL, OR PUNITIVE DAMAGES.
7. Termination & Suspension
The Card Issuer reserves the right to suspend or terminate your card at any time in accordance with its agreement. LXX DAO or the Card Issuer may suspend access to the facilitation interface immediately if you breach these Card Terms, violate the law, or if required by a regulator.
8. Governing Law & Dispute Resolution
8.1 Primary Dispute Resolution: Disputes related to card transactions, fees, or unauthorized use must be resolved directly with the Card Issuer as per their Cardholder Agreement.
8.2 Disputes with LXX DAO: Any dispute arising specifically from LXX DAO's role in facilitating access to the Card Services shall be governed by the laws of Nevis and finally settled by arbitration under the Nevis Rules of International Arbitration, as outlined in the main LXX DAO Terms of Use.
9. Amendments
LXX DAO may amend these Card Terms at any time. Material changes will be communicated via our official channels. Continued use of the Card Services after amendments constitutes acceptance.
10. Contact
For card-specific support, disputes, or account inquiries, you must contact the Card Issuer directly using the details provided in your Cardholder Agreement. For questions regarding LXX DAO's role, use the official governance forums.
YOUR ACKNOWLEDGEMENT BY PROCEEDING WITH THE CARD APPLICATION OR USE, YOU CONFIRM THAT:
1. YOU HAVE READ AND UNDERSTAND THESE TERMS.
2. YOU UNDERSTAND LXX DAO IS NOT THE CARD ISSUER AND BEARS NO LIABILITY FOR THE CARD SERVICE'S OPERATION.
3. YOU ACCEPT ALL RISKS, INCLUDING THIRD-PARTY INSOLVENCY RISK AND REGULATORY RISK.
4. YOU AGREE TO BE BOUND BY THE CARD ISSUER'S SEPARATE CARDHOLDER AGREEMENT.
IMPORTANT NOTICE:
THESE TERMS GOVERN THE USE OF A THIRD-PARTY CARD LINKED TO YOUR SELF-CUSTODIED DIGITAL ASSETS. LXX DAO IS NOT A BANK, MONEY TRANSMITTER, OR CARD ISSUER. READ THESE TERMS CAREFULLY BEFORE USING THE SERVICE.
1. Acceptance of Terms
These Terms of Use ("Card Terms") constitute a legally binding agreement between you ("Cardholder," "you," "your") and the LXX DAO community regarding your use of any crypto-linked card services ("Card Services") facilitated through or promoted by LXX DAO's ecosystem. These Card Terms incorporate by reference our Privacy Policy, AML Policy, and KYC Policy. By applying for, activating, or using the Card Services, you acknowledge that you have read, understood, and agree to be bound by these Card Terms. If you do not agree, you must not apply for or use the Card Services.
2. Nature of Service & Critical Third-Party Partnership
2.1 Non-Custodial Bridge Service: The Card Service is designed to function as a non-custodial bridge between your self-custodied digital assets and traditional payment networks. The core mechanism involves a qualified, licensed third-party card issuer and program manager ("Card Issuer").
2.2 Role of LXX DAO: LXX DAO does not issue the card, is not a party to the cardholder agreement with the Card Issuer, does not hold funds, and is not a regulated financial institution. LXX DAO's role may be limited to:
● Providing a technical interface or referral to the Card Issuer's services.
● Facilitating community governance over any partnership parameters.
● LXX DAO BEARS NO LIABILITY FOR THE ACTIONS, OMISSIONS, OR FINANCIAL CONDITION OF THE CARD ISSUER.
2.3 Primary Agreement with Card Issuer: Your use of the physical or virtual card is governed primarily by a separate Cardholder Agreement issued by the licensed Card Issuer. You must agree to those terms directly with the Card Issuer. These Card Terms supplement but do not replace that agreement. In the event of a conflict, the Card Issuer's Cardholder Agreement controls matters pertaining to card issuance, transaction processing, fees, and liability.
3. Card Functionality & Your Authorizations
3.1 Asset Conversion (On-Ramp/Off-Ramp): To fund a transaction, you authorize a process whereby:
● You initiate a swap of your self-custodied digital assets (e.g., LXX tokens, stablecoins) for fiat currency (e.g., EUR, USD) via a decentralized or licensed exchange partner.
● The resulting fiat proceeds are settled to an account controlled by the Card Issuer and loaded onto your card.
● You understand this conversion is a distinct taxable event in many jurisdictions and are solely responsible for any tax consequences.
3.2 No Credit or Overdraft: The card is prepaid only. Transactions cannot exceed the available fiat balance loaded on the card. There is no credit line, overdraft facility, or deposit insurance (e.g., FDIC, EU DGS) on the crypto assets or card balance.
3.3 Prohibited Transactions: You agree not to use the Card Services for:
● Illegal activities or purchases in prohibited categories (e.g., adult content, gambling, illicit substances) as defined by the Card Issuer.
● Circumventing financial sanctions or AML controls.
● Arbitrage or speculative trading via merchant refunds.
● Any activity that violates the terms of the Card Issuer.
4. User Eligibility, KYC & Representations
4.1 Eligibility: You must:
● Be of legal age in your country of residence.
● Pass the Card Issuer's and any required partner's KYC/AML verification procedures, which are mandatory and more stringent than basic protocol interaction.
● Reside in a jurisdiction where the Card Services are legally available.
● The service is NOT available to residents of prohibited jurisdictions, including but not limited to the United States.
4.2 Ongoing Compliance: You represent and warrant that all information provided for KYC is accurate and will be updated promptly upon any change. You will comply with all applicable laws related to the use of the Card Services, including anti-money laundering, counter-terrorist financing, and tax reporting laws.
5. Fees, Exchange Rates & Economic Terms
5.1 Disclosure of Costs: Using the Card Services incurs various fees, including but not limited to:
● Card Issuance/Maintenance Fees: Charged by the Card Issuer.
● Asset Conversion Fees (Spread): Applied during the swap from crypto to fiat.
● Transaction Fees: For ATM withdrawals, foreign transactions, etc.
● Network Fees: Blockchain gas fees for the initial transfer of your crypto assets. All fees will be clearly disclosed by the Card Issuer and/or the conversion service provider prior to your confirmation.
5.2 Foreign Exchange (FX): For transactions in a currency other than your card's base currency, the conversion will use an exchange rate set by the Card Issuer or the card network (e.g., Visa), which may include a markup. You bear all FX risk.
6. Risk Disclosures & Limitation of Liability
6.1 Specific Card Risks: You acknowledge and accept the following inherent risks:
● Third-Party Insolvency Risk: The Card Issuer is a separate legal entity. Its failure could result in loss of funds held as card balances.
● Transaction Finality & Reversals: Card transactions, especially with merchants, may be subject to holds, reversals (chargebacks), and disputes governed by card network rules, not blockchain finality.
● Technical & Fraud Risks: Card details can be stolen, skimmed, or compromised. Unauthorized transactions may occur. The liability framework is governed by the Card Issuer's agreement and applicable law (e.g., EU PSD2 limits).
● Regulatory Risk: The regulatory status of crypto-linked cards is evolving. Services may be suspended or terminated in your jurisdiction with little notice.
6.2 Limitation of LXX DAO's Liability:
TO THE MAXIMUM EXTENT PERMITTED BY LAW, LXX DAO, ITS CONTRIBUTORS, AND TOKEN HOLDERS SHALL HAVE NO LIABILITY FOR:
● ANY LOSSES ARISING FROM THE ACTS, OMISSIONS, OR INSOLVENCY OF THE CARD ISSUER OR ANY THIRD-PARTY SERVICE PROVIDER.
● ANY UNAUTHORIZED TRANSACTIONS ON YOUR CARD.
● DISPUTES BETWEEN YOU AND MERCHANTS OR THE CARD ISSUER.
● LOSSES DUE TO FRAUD, MARKET VOLATILITY DURING CONVERSION, OR CHANGES IN REGULATORY ENVIRONMENTS.
● CONSEQUENTIAL, INCIDENTAL, OR PUNITIVE DAMAGES.
7. Termination & Suspension
The Card Issuer reserves the right to suspend or terminate your card at any time in accordance with its agreement. LXX DAO or the Card Issuer may suspend access to the facilitation interface immediately if you breach these Card Terms, violate the law, or if required by a regulator.
8. Governing Law & Dispute Resolution
8.1 Primary Dispute Resolution: Disputes related to card transactions, fees, or unauthorized use must be resolved directly with the Card Issuer as per their Cardholder Agreement.
8.2 Disputes with LXX DAO: Any dispute arising specifically from LXX DAO's role in facilitating access to the Card Services shall be governed by the laws of Nevis and finally settled by arbitration under the Nevis Rules of International Arbitration, as outlined in the main LXX DAO Terms of Use.
9. Amendments
LXX DAO may amend these Card Terms at any time. Material changes will be communicated via our official channels. Continued use of the Card Services after amendments constitutes acceptance.
10. Contact
For card-specific support, disputes, or account inquiries, you must contact the Card Issuer directly using the details provided in your Cardholder Agreement. For questions regarding LXX DAO's role, use the official governance forums.
YOUR ACKNOWLEDGEMENT BY PROCEEDING WITH THE CARD APPLICATION OR USE, YOU CONFIRM THAT:
1. YOU HAVE READ AND UNDERSTAND THESE TERMS.
2. YOU UNDERSTAND LXX DAO IS NOT THE CARD ISSUER AND BEARS NO LIABILITY FOR THE CARD SERVICE'S OPERATION.
3. YOU ACCEPT ALL RISKS, INCLUDING THIRD-PARTY INSOLVENCY RISK AND REGULATORY RISK.
4. YOU AGREE TO BE BOUND BY THE CARD ISSUER'S SEPARATE CARDHOLDER AGREEMENT.
09
Terms of Use – Decentralized Wallet Services
LXX DAO – Conditions for Access and Use via Self-Custodied Wallets
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Acceptance of Terms; Binding Agreement
These Terms of Use ("Terms") govern your access to and use of the decentralized software applications, smart contracts, and related interfaces (collectively, the "Protocol") provided by the LXX DAO community. By connecting your digital wallet ("Wallet") to our website or interface, you signify that you have read, understand, and irrevocably agree to be bound by these Terms and all applicable laws and regulations.
If you do not agree to these Terms, you must not access or use the Protocol. These Terms constitute a legally binding agreement between you and the LXX DAO collective.
2. Defined Terms
● "Protocol" refers to the suite of autonomous, open-source smart contracts deployed by LXX DAO, including but not limited to the bonding curve contract, governance contracts, and associated front-end software that facilitates interaction.
● "Wallet" refers to a software application (e.g., browser extension, mobile app) or hardware device that (a) interacts with blockchain networks, (b) stores your cryptographic private keys, and (c) allows you to manage digital assets and sign transactions. LXX DAO does not provide, develop, or maintain any Wallet software.
● "You," "your," or "user" refers to the individual or legal entity accessing the Protocol via a connected Wallet.
3. Essential Nature of the Protocol & Non-Custody
The Protocol is a non-custodial, decentralized suite of smart contracts. You affirm and understand that:
1. No Account Creation: You do not create an "account" with LXX DAO. Access is achieved solely by connecting a compatible, self-custodied Wallet.
2. Non-Custodial: LXX DAO does not hold, store, or have any ability to access, control, or recover the digital assets held in your Wallet. You retain sole and absolute control at all times.
3. Irreversible Actions: Transactions signed by your Wallet and broadcast to the blockchain (e.g., purchasing LXX tokens, voting, redeeming) are irreversible and final. LXX DAO cannot cancel, reverse, or modify any on-chain transaction.
4. Protocol Rules: Your interaction is governed exclusively by the immutable code of the relevant smart contracts, subject to on-chain governance by LXX token holders.
4. User Representations, Warranties, and Responsibilities
By using the Protocol, you represent, warrant, and covenant that you:
1. Legal Capacity & Compliance: Are of legal age in your jurisdiction, have full legal capacity, and are using the Protocol in compliance with all applicable laws in your jurisdiction.
2. Wallet Security: Are solely and exclusively responsible for:
○ The setup, administration, operation, maintenance, and security of your Wallet.
○ Securing your private keys, seed phrases, passwords, and any other access credentials. Loss of these credentials will result in the permanent, irrecoverable loss of associated assets.
○ All activity that occurs through your connected Wallet, whether authorized by you or not.
3. Risk Acknowledgement: Understand and accept the inherent risks of blockchain technology, decentralized finance, and digital assets, including but not limited to:
○ Price volatility leading to total loss of value.
○ Smart contract vulnerabilities, bugs, or exploits.
○ Network congestion and fluctuating transaction fees.
○ Regulatory uncertainty and changes.
4. Source of Funds: Warrant that any digital assets you use to interact with the Protocol are derived from legal sources and were lawfully obtained.
5. Prohibited Use: Will not use the Protocol to engage in or facilitate any illegal activity, including but not limited to money laundering, terrorist financing, tax evasion, fraud, or market manipulation.
5. Protocol Access; Disclaimers; Limitation of Liability
1. As-Is Basis: The Protocol is provided on an "AS IS" and "AS AVAILABLE" basis. LXX DAO, its contributors, and token holders expressly disclaim all warranties of any kind, whether express or implied, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.
2. No Liability for Asset Loss: LXX DAO shall bear no liability whatsoever for any direct, indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, digital assets, or other intangible property, arising from:
○ Your use or inability to use the Protocol.
○ Any unauthorized access to or use of your Wallet.
○ Any errors, inaccuracies, or omissions in the Protocol's interface or data.
○ Any interruption or cessation of transmission to or from the Protocol.
○ Any bugs, viruses, or malicious code that may be transmitted through the Protocol interface.
3. Third-Party Dependencies: Your access is dependent on third-party services, including your Wallet provider, internet service, and the underlying blockchain network. LXX DAO disclaims all liability for issues arising from these dependencies. You are subject to the terms of any such third-party services.
6. Indemnification
You agree to indemnify, defend, and hold harmless LXX DAO, its contributors, token holders, and their respective affiliates, officers, agents, and employees from and against any and all claims, damages, obligations, losses, liabilities, costs, or debt, and expenses (including but not limited to reasonable attorney's fees) arising from: (i) your use of and access to the Protocol; (ii) your violation of any term of these Terms; or (iii) your violation of any law or the rights of a third party.
7. Intellectual Property
The Protocol’s open-source software code is made available under applicable licenses. The "LXX DAO" name, logos, and visual interface elements are proprietary. You are granted a limited, non-exclusive, non-transferable license to access and use the Protocol for its intended purpose. You may not copy, modify, or create derivative works without explicit permission.
8. Governing Law, Dispute Resolution, and Venue
These Terms shall be governed by and construed in accordance with the substantive laws of Nevis, without regard to its conflict of law principles. Any dispute, controversy, or claim arising out of or in connection with these Terms shall be finally settled by arbitration in accordance with the Nevis Rules of International Arbitration of the Nevis Arbitration Centre in force on the date when the Notice of Arbitration is submitted. The seat of arbitration shall be Nevis. The arbitral proceedings shall be conducted in the English language.
Class Action and Jury Trial Waiver: You waive any right to participate in a class action lawsuit or class-wide arbitration against LXX DAO. You waive any right to a trial by jury.
9. Modifications; Termination
LXX DAO may modify these Terms at any time in its sole discretion. The updated version will be posted with a new "Effective Date." Your continued use constitutes acceptance.
LXX DAO reserves the right to terminate or restrict your access to its front-end interface at any time, for any reason, without notice or liability. These Terms survive any termination of access.
10. General Provisions
These Terms constitute the entire agreement between you and LXX DAO regarding the Protocol. If any provision is deemed invalid, the remaining provisions remain in full force. No waiver of any term shall be deemed a further waiver.
11. Contact
For questions about these Terms, please direct inquiries through the official governance forums of LXX DAO.
YOUR EXPRESS ACKNOWLEDGEMENT AND AGREEMENT
BY CONNECTING YOUR WALLET AND USING THE PROTOCOL, YOU CONFIRM THAT YOU HAVE READ, UNDERSTAND, AND UNCONDITIONALLY AGREE TO BE BOUND BY THESE TERMS OF USE. YOU FURTHER ACKNOWLEDGE THAT YOU ARE SOLELY RESPONSIBLE FOR THE SECURITY OF YOUR WALLET AND ASSETS, AND THAT LXX DAO BEARS NO LIABILITY FOR ANY RESULTING LOSSES.
Published by LXX DAO | Effective Date: 2026.03 | Version: 1.0
1. Acceptance of Terms; Binding Agreement
These Terms of Use ("Terms") govern your access to and use of the decentralized software applications, smart contracts, and related interfaces (collectively, the "Protocol") provided by the LXX DAO community. By connecting your digital wallet ("Wallet") to our website or interface, you signify that you have read, understand, and irrevocably agree to be bound by these Terms and all applicable laws and regulations.
If you do not agree to these Terms, you must not access or use the Protocol. These Terms constitute a legally binding agreement between you and the LXX DAO collective.
2. Defined Terms
● "Protocol" refers to the suite of autonomous, open-source smart contracts deployed by LXX DAO, including but not limited to the bonding curve contract, governance contracts, and associated front-end software that facilitates interaction.
● "Wallet" refers to a software application (e.g., browser extension, mobile app) or hardware device that (a) interacts with blockchain networks, (b) stores your cryptographic private keys, and (c) allows you to manage digital assets and sign transactions. LXX DAO does not provide, develop, or maintain any Wallet software.
● "You," "your," or "user" refers to the individual or legal entity accessing the Protocol via a connected Wallet.
3. Essential Nature of the Protocol & Non-Custody
The Protocol is a non-custodial, decentralized suite of smart contracts. You affirm and understand that:
1. No Account Creation: You do not create an "account" with LXX DAO. Access is achieved solely by connecting a compatible, self-custodied Wallet.
2. Non-Custodial: LXX DAO does not hold, store, or have any ability to access, control, or recover the digital assets held in your Wallet. You retain sole and absolute control at all times.
3. Irreversible Actions: Transactions signed by your Wallet and broadcast to the blockchain (e.g., purchasing LXX tokens, voting, redeeming) are irreversible and final. LXX DAO cannot cancel, reverse, or modify any on-chain transaction.
4. Protocol Rules: Your interaction is governed exclusively by the immutable code of the relevant smart contracts, subject to on-chain governance by LXX token holders.
4. User Representations, Warranties, and Responsibilities
By using the Protocol, you represent, warrant, and covenant that you:
1. Legal Capacity & Compliance: Are of legal age in your jurisdiction, have full legal capacity, and are using the Protocol in compliance with all applicable laws in your jurisdiction.
2. Wallet Security: Are solely and exclusively responsible for:
○ The setup, administration, operation, maintenance, and security of your Wallet.
○ Securing your private keys, seed phrases, passwords, and any other access credentials. Loss of these credentials will result in the permanent, irrecoverable loss of associated assets.
○ All activity that occurs through your connected Wallet, whether authorized by you or not.
3. Risk Acknowledgement: Understand and accept the inherent risks of blockchain technology, decentralized finance, and digital assets, including but not limited to:
○ Price volatility leading to total loss of value.
○ Smart contract vulnerabilities, bugs, or exploits.
○ Network congestion and fluctuating transaction fees.
○ Regulatory uncertainty and changes.
4. Source of Funds: Warrant that any digital assets you use to interact with the Protocol are derived from legal sources and were lawfully obtained.
5. Prohibited Use: Will not use the Protocol to engage in or facilitate any illegal activity, including but not limited to money laundering, terrorist financing, tax evasion, fraud, or market manipulation.
5. Protocol Access; Disclaimers; Limitation of Liability
1. As-Is Basis: The Protocol is provided on an "AS IS" and "AS AVAILABLE" basis. LXX DAO, its contributors, and token holders expressly disclaim all warranties of any kind, whether express or implied, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.
2. No Liability for Asset Loss: LXX DAO shall bear no liability whatsoever for any direct, indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, digital assets, or other intangible property, arising from:
○ Your use or inability to use the Protocol.
○ Any unauthorized access to or use of your Wallet.
○ Any errors, inaccuracies, or omissions in the Protocol's interface or data.
○ Any interruption or cessation of transmission to or from the Protocol.
○ Any bugs, viruses, or malicious code that may be transmitted through the Protocol interface.
3. Third-Party Dependencies: Your access is dependent on third-party services, including your Wallet provider, internet service, and the underlying blockchain network. LXX DAO disclaims all liability for issues arising from these dependencies. You are subject to the terms of any such third-party services.
6. Indemnification
You agree to indemnify, defend, and hold harmless LXX DAO, its contributors, token holders, and their respective affiliates, officers, agents, and employees from and against any and all claims, damages, obligations, losses, liabilities, costs, or debt, and expenses (including but not limited to reasonable attorney's fees) arising from: (i) your use of and access to the Protocol; (ii) your violation of any term of these Terms; or (iii) your violation of any law or the rights of a third party.
7. Intellectual Property
The Protocol’s open-source software code is made available under applicable licenses. The "LXX DAO" name, logos, and visual interface elements are proprietary. You are granted a limited, non-exclusive, non-transferable license to access and use the Protocol for its intended purpose. You may not copy, modify, or create derivative works without explicit permission.
8. Governing Law, Dispute Resolution, and Venue
These Terms shall be governed by and construed in accordance with the substantive laws of Nevis, without regard to its conflict of law principles. Any dispute, controversy, or claim arising out of or in connection with these Terms shall be finally settled by arbitration in accordance with the Nevis Rules of International Arbitration of the Nevis Arbitration Centre in force on the date when the Notice of Arbitration is submitted. The seat of arbitration shall be Nevis. The arbitral proceedings shall be conducted in the English language.
Class Action and Jury Trial Waiver: You waive any right to participate in a class action lawsuit or class-wide arbitration against LXX DAO. You waive any right to a trial by jury.
9. Modifications; Termination
LXX DAO may modify these Terms at any time in its sole discretion. The updated version will be posted with a new "Effective Date." Your continued use constitutes acceptance.
LXX DAO reserves the right to terminate or restrict your access to its front-end interface at any time, for any reason, without notice or liability. These Terms survive any termination of access.
10. General Provisions
These Terms constitute the entire agreement between you and LXX DAO regarding the Protocol. If any provision is deemed invalid, the remaining provisions remain in full force. No waiver of any term shall be deemed a further waiver.
11. Contact
For questions about these Terms, please direct inquiries through the official governance forums of LXX DAO.
YOUR EXPRESS ACKNOWLEDGEMENT AND AGREEMENT
BY CONNECTING YOUR WALLET AND USING THE PROTOCOL, YOU CONFIRM THAT YOU HAVE READ, UNDERSTAND, AND UNCONDITIONALLY AGREE TO BE BOUND BY THESE TERMS OF USE. YOU FURTHER ACKNOWLEDGE THAT YOU ARE SOLELY RESPONSIBLE FOR THE SECURITY OF YOUR WALLET AND ASSETS, AND THAT LXX DAO BEARS NO LIABILITY FOR ANY RESULTING LOSSES.