Effective Date: April 1, 2025
Last Updated: March 14, 2026
Section 1: Purpose and Scope
1.1. Introduction
This Custodial Wallet and Financial Services Disclosure (hereinafter referred to as "this Disclosure") is a legally binding document that forms part of the Zelencio Terms of Service and User Agreement and must be read in conjunction with the Zelencio Privacy Policy, AML and CTF Compliance Policy, Risk Disclosure Statement, and Restricted Jurisdictions Declaration. This Disclosure is published in fulfilment of Zelencio's commitment to full transparency regarding the nature of its custody model, the classification of its services, and the rights and responsibilities of users in connection with digital assets held on the platform.
The purpose of this Disclosure is to ensure that every user of the Zelencio platform fully understands the nature of the custodial relationship between themselves and Zelencio, what it means for their digital assets, what protections exist, and what limitations apply.
1.2. Scope of Application
This Disclosure applies to all users of the Zelencio platform, including all registered account holders across all account tiers and verification levels. It applies to all digital assets deposited into, held within, transferred through, or withdrawn from the Zelencio platform, regardless of the method of deposit or the feature through which the asset is accessed or managed.
Section 2: Nature of Zelencio's Custody Model
2.1. Definition of a Custodial Wallet
A custodial wallet is a digital asset wallet in which the private keys that control access to the on-chain blockchain address are held and managed by the platform operator, not by the individual user. In a custodial model, the platform operator acts as a trusted intermediary responsible for the safekeeping, management, and execution of transactions on behalf of the user.
Zelencio operates a custodial wallet model. This means that when you deposit digital assets into your Zelencio wallet, those assets are held under the custody of Zelencio on your behalf. Zelencio manages the underlying private keys associated with the blockchain addresses assigned to your account. You do not have direct access to the private keys of your Zelencio wallet addresses.
2.2. What Custodial Control Means for Your Assets
Because Zelencio holds the private keys to your wallet addresses, the following conditions apply to your digital assets while they are held on the platform. You access and manage your assets exclusively through the Zelencio platform interface and application. All on-chain transactions, including deposits received and withdrawals executed, are processed by Zelencio's infrastructure on your behalf. Your assets are credited and debited within Zelencio's internal ledger system, which reflects your real-time balance and transaction history. You are not able to independently interact with the blockchain using your Zelencio wallet address outside of the Zelencio platform. Internal transfers, swaps, P2P trades, and code-based transactions are settled within Zelencio's internal ledger and do not necessarily result in an immediate on-chain transaction for every individual movement.
2.3. Distinction Between Custodial and Non-Custodial Wallets
It is important that users understand the distinction between Zelencio's custodial model and a non-custodial wallet, such as MetaMask, Trust Wallet, or a hardware wallet. In a non-custodial wallet, the user holds their own private keys and is solely responsible for the security and management of their assets. In a custodial wallet such as Zelencio, the platform holds the private keys and provides a managed, secured environment for asset storage, trading, and transfer. Custodial wallets offer greater convenience, user experience, and access to integrated platform features such as P2P trading, escrow, automation, and internal transfers. However, they also mean that the user is relying on Zelencio's security infrastructure, operational integrity, and continued availability to access their assets. Users who prefer to maintain sole control over their private keys are advised to use a non-custodial wallet for long-term storage of large asset holdings.
2.4. User's Beneficial Ownership of Assets
Notwithstanding Zelencio's custodial control of the private keys, users retain full beneficial ownership of all digital assets credited to their Zelencio account. Zelencio does not claim ownership of user assets. User assets are not Zelencio's assets, are not available for use by Zelencio for its own operational purposes, and are not subject to claims by Zelencio's creditors in the ordinary course of business, except where a legal hold, court order, regulatory freeze, or confirmed fraudulent transaction investigation requires otherwise. Zelencio maintains detailed internal records of all user asset balances and transaction histories to support the accurate attribution of beneficial ownership at all times.
Section 3: Classification of Zelencio's Services
3.1. Zelencio as a Virtual Asset Service Provider
Zelencio is classified as a Virtual Asset Service Provider (VASP) under the framework established by the Financial Action Task Force (FATF) Recommendations for Virtual Asset Service Providers. As a VASP, Zelencio provides services that include the exchange of virtual assets for fiat currencies or other virtual assets, the transfer of virtual assets on behalf of users, the safekeeping and administration of virtual assets and related instruments, and the participation in and provision of financial services related to an issuer's offer or sale of virtual assets.
3.2. Technology-First Operational Framework
Zelencio operates under a technology-first framework, meaning that the platform's primary function is to provide a secure and efficient technological infrastructure for digital asset management. Zelencio is not a licensed bank, a licensed securities dealer, a licensed investment advisor, or a licensed money services business in any jurisdiction where such a license is required and has not been obtained. Zelencio does not offer fiat banking services, interest-bearing deposit accounts, or investment products. Zelencio does not provide financial advice, investment recommendations, or portfolio management services. Users are responsible for making their own independent financial and investment decisions.
3.3. Services Provided by Zelencio
The following services are provided by Zelencio within its custodial and VASP framework. Custodial digital asset storage, providing users with secured wallet addresses for the receipt and holding of supported cryptocurrencies. On-chain deposit processing, facilitating the receipt of digital assets sent to user wallet addresses from external blockchain sources. On-chain withdrawal execution, processing user-initiated transfers of digital assets from Zelencio wallets to external blockchain addresses. Internal asset transfers, enabling off-chain movements of digital assets between verified Zelencio users via the internal ledger. Asset swap and conversion services, providing algorithmic and market-based exchange of one supported digital asset for another. P2P and U2U marketplace services, operating a monitored peer-to-peer trading environment with integrated fund locking and escrow support. Zelencio Code and Crypto Gift distribution, enabling encrypted internal voucher creation and asset gifting between users. Referral and rewards management, tracking and distributing referral bonuses and platform rewards in accordance with the Referral and Rewards Ecosystem policy. Automated trading tools, including the Swap on Market Drop (SOMD) feature, executing pre-authorized user instructions based on configured market conditions. Escrow Hub services, providing a human-moderated escrow environment for the trade of digital products between users.
3.4. Services Not Provided by Zelencio
Zelencio does not provide the following services, and users should not interpret any platform feature as constituting any of the following. Zelencio does not provide fiat currency deposit accounts or fiat banking services. Zelencio does not provide interest on user balances or yield-bearing products of any kind. Zelencio does not provide investment advice, financial planning, or portfolio management. Zelencio does not provide insurance or deposit protection schemes for user assets. Zelencio does not guarantee profits, returns, or the preservation of asset value. Zelencio does not provide legal, tax, or accounting services or advice.
Section 4: Asset Security and Segregation
4.1. Security Infrastructure
Zelencio employs institutional-grade security infrastructure to protect user assets held under its custody. This infrastructure includes AES-256 military-grade encryption for all sensitive identity and financial data stored within the platform. Multi-factor authentication requirements, including sequential PIN and Google Authenticator two-factor authentication, for all outbound asset movements. AI-driven fraud detection systems that monitor platform activity continuously for suspicious behavior, unauthorized access attempts, and transaction anomalies. Cold and warm wallet architecture for the management of on-chain asset holdings, designed to limit exposure of the majority of user assets to online attack vectors. A tiered KYC and AML verification framework that ensures all users are verified in accordance with FATF standards before accessing higher-value transaction features.
4.2. Asset Segregation
Zelencio maintains a strict operational policy of segregating user assets from the company's own operational funds. User digital assets credited to Zelencio accounts are tracked, recorded, and managed separately from Zelencio's corporate treasury. Zelencio does not commingle user assets with its own operational funds for the purpose of business expenses, corporate investments, or any other internal use. This segregation is maintained at the internal ledger level and is reflected in Zelencio's asset management records.
4.3. Limitations of Security Guarantees
While Zelencio employs industry-leading security practices, users must understand that no digital security system is entirely immune to risk. Zelencio does not guarantee the absolute security of digital assets held on the platform. In the event of an unforeseen security incident, Zelencio will take all reasonably practicable steps to contain the incident, notify affected users, and work to recover or restore affected balances where technically and legally possible. Users are encouraged to review the Zelencio Risk Disclosure Statement for a full account of the risks associated with using a custodial digital asset platform.
Section 5: User Rights in Relation to Custodied Assets
5.1. Right to Withdraw Assets
All verified Zelencio users have the right to withdraw their digital assets from the platform to an external wallet address of their choosing at any time, subject to the completion of applicable identity verification requirements, the absence of any account restriction, suspension, legal hold, or active investigation, the availability of sufficient balance to cover applicable withdrawal Service Fees, and network availability and processing conditions on the relevant blockchain.
5.2. Right to Transaction History and Balance Information
All users have the right to access a complete record of their transaction history and current asset balances within the Zelencio platform at any time through the account dashboard and transaction history interface. Zelencio maintains accurate and up-to-date records of all user account activity and makes these records available to users on demand through the platform interface.
5.3. Right to Account Closure
Users have the right to close their Zelencio account at any time. To close an account, the user must first withdraw all remaining digital asset balances to an external wallet address. Account closure requests must be submitted through official support channels at help@zelencio.com. Accounts with pending transactions, open escrow positions, active P2P trades, or outstanding disputes may not be immediately closeable and will remain active until all pending matters are resolved. Accounts subject to investigation, legal hold, or regulatory freeze may not be closed until the relevant matter is concluded.
5.4. Right to Data Access and Deletion
In connection with Zelencio's custodial operations, users retain the rights to their personal data as described in the Zelencio Privacy Policy, including the right to request access to their personal data, the right to request correction of inaccurate data, and the right to request deletion of their data, subject to applicable legal and regulatory data retention requirements which may require Zelencio to retain certain records for a mandatory period notwithstanding a deletion request.
Section 6: Platform Risk and Operational Continuity
6.1. Counterparty Risk
By using a custodial platform, users are exposed to counterparty risk, meaning the risk that Zelencio as an entity could face operational difficulties, technical failures, or regulatory action that affects the accessibility of user assets. Users should be aware that digital assets held on a custodial platform are subject to the operational health and regulatory standing of the platform operator. Users with significant long-term holdings are encouraged to consider maintaining a portion of their assets in a non-custodial wallet as a risk management measure.
6.2. Platform Availability
Zelencio will make all commercially reasonable efforts to maintain continuous availability of the platform and its services. However, scheduled maintenance, unscheduled technical incidents, network outages, blockchain congestion, and third-party service disruptions may result in temporary unavailability of certain features. Zelencio will communicate planned downtime through the platform and its official communication channels wherever possible. Zelencio shall not be liable for losses arising from temporary platform unavailability except in cases of gross negligence or willful misconduct by Zelencio.
6.3. Regulatory Risk
The regulatory environment governing virtual asset service providers, custodial wallets, and cryptocurrency exchanges is subject to rapid and material change in many jurisdictions. Changes in applicable laws, regulatory guidance, or licensing requirements may require Zelencio to restrict, modify, or discontinue certain services in specific jurisdictions without prior notice. Zelencio will make reasonable efforts to communicate material regulatory-driven changes to affected users in advance wherever legally permissible.
Section 7: Financial Services Declaration for App Distribution
7.1. Statement for App Store and Regulatory Review
This section constitutes Zelencio's formal financial services declaration for the purpose of app store submission, regulatory review, and public transparency. Zelencio is a custodial digital asset management platform and virtual asset service provider developed and operated by DMG Dynasty. The Zelencio platform provides cryptocurrency wallet, exchange, transfer, and related digital asset management services. Zelencio does not hold a banking license, securities dealer license, or regulated financial services license in any jurisdiction. Zelencio's services are made available in jurisdictions where the provision of virtual asset services at the technology layer does not require a specific regulatory license at this stage of the platform's development. Zelencio restricts access to its platform from jurisdictions where a financial services or virtual asset service provider license is required and not currently held, as detailed in the Zelencio Restricted Jurisdictions and Geo-Restriction Declaration. Zelencio's primary target markets are in sub-Saharan Africa and other emerging markets where digital asset services are accessible without a platform-level financial services license requirement. Zelencio complies with applicable AML, CTF, and KYC requirements in its operating markets in accordance with FATF Recommendations for Virtual Asset Service Providers.
7.2. Confirmation of Non-Banking Status
Zelencio is not a bank. Zelencio is not a deposit-taking institution. User balances held on the Zelencio platform are digital asset balances, not fiat currency bank deposits. These balances are not covered by any government-backed deposit insurance scheme, including but not limited to the Nigerian Deposit Insurance Corporation (NDIC), the Federal Deposit Insurance Corporation (FDIC), the Financial Services Compensation Scheme (FSCS), or any equivalent scheme in any other jurisdiction. Users are advised to consider this when determining the amount of digital assets they choose to hold on the platform.
Section 8: Contact and Disclosure Inquiries
8.1. Official Contact for Custodial and Financial Services Inquiries
For all inquiries relating to the nature of Zelencio's custody model, asset security, financial services classification, or the contents of this Disclosure, users may contact Zelencio through the following official channels.
Support Email: help@zelencio.com
Official Help Center: help.zelencio.com
Legal and Compliance Portal: zelencio.com/help
Zelencio will make reasonable efforts to respond to all inquiries relating to this Disclosure within 5 business days. Nothing communicated by Zelencio in response to such inquiries constitutes legal, financial, or investment advice.