Terms of Service

Effective Date: 1 September 2026 Last Updated: 1 September 2026 Version: 1.0

1. Who We Are

Sentinel is operated by Custody Agents S.L., a company incorporated in Spain, CIF B24890931, with registered office at Avenida Diagonal, 449, 4a planta, 08036, Barcelona, Spain ("Custody Agents", "we", "us").

These Terms of Service ("Terms") govern your access to and use of the Sentinel Platform at sentinel.custodyagents.com and any associated services (the "Platform"), across all tiers: Sentinel Agents (free), Sentinel Pro, Sentinel Advisor, Sentinel Principal, and Sentinel Enterprise.

By creating an account or using the Platform, you agree to these Terms. If you do not agree, do not use the Platform.

Language: These Terms are provided in English. In the event of conflict with any future translation, the English version prevails, without prejudice to any mandatory consumer-protection provisions of your home jurisdiction.

2. What Sentinel Is, and What It Is Not

Sentinel is software. It provides governance, security, and compliance workflow tooling: policy configuration, validation, orchestration, risk assessment, and audit support for professionals advising on digital asset custody arrangements.

Sentinel is non-custodial. Custody Agents S.L. does not at any time hold, control, transmit, or have access to your funds, private keys, seed phrases, wallets, or any credential capable of moving assets. This is a structural property of the architecture, not a policy commitment.

Custody Agents S.L. does not provide digital-asset custody, brokerage, exchange, or value-transmission services. It is not a regulated financial institution, payment service provider, money transmitter, or custodian in any jurisdiction. It is not regulated by the Banco Central do Brasil under Lei 14.478/2022.

Nothing on the Platform constitutes financial, investment, legal, or tax advice. Sentinel produces analysis and recommendations as software output. All decisions regarding custody structures, key management, asset allocation, or governance policy remain the sole responsibility of you and any licensed professionals you engage. You are responsible for independently verifying any output before acting on it.

3. Eligibility

You must be 18 years of age or older, or the age of majority in your jurisdiction if higher. The Platform is intended for professional use by advisors, fiduciary consultants, firms, and institutional users. By using the Platform you confirm that you are acting in a professional capacity and, where you represent a firm, that you have authority to bind that firm to these Terms.

4. Accounts and Authentication

Accounts are authenticated via Microsoft Entra External ID. You are responsible for maintaining the security of your account credentials and for all activity under your account. We strongly recommend enabling multi-factor authentication. Notify us immediately at compliance@custodyagents.com if you suspect unauthorised access.

5. Subscriptions, Billing, and Trials

5.1 Tiers and Pricing

Current pricing is published at sentinel.custodyagents.com/pricing. We may change pricing prospectively; existing subscribers will be notified at least 30 days before a change takes effect at their next renewal.

5.2 Sentinel Pro

Pro subscriptions are sold and processed by Paddle.com Market Ltd., acting as Merchant of Record. Paddle handles payment processing, invoicing, and tax collection and remittance for these transactions. Your purchase is subject to Paddle's terms in addition to these Terms. Custody Agents S.L. remains the provider of the Platform itself.

Pro includes a one-month free trial. You will not be charged during the trial. Unless cancelled before the trial ends, the subscription converts automatically to a paid monthly subscription at the applicable rate for your currency.

5.3 Sentinel Advisor, Principal, and Enterprise

These tiers are not currently offered through public self-service checkout. Pricing, seat counts, payment terms, and any retainer or commission structure are set out in an individual engagement letter or order form, which forms part of these Terms for those tiers.

Where Advisor is subsequently made available through self-service checkout, the terms of section 5.2 will apply to it and this section will be updated accordingly.

5.4 Taxes

Prices are exclusive of VAT and other applicable taxes unless stated otherwise. For Pro subscriptions, Paddle calculates and collects applicable tax at checkout based on your location. Prices shown in Brazilian reais include IOF at the applicable rate.

5.5 Renewal and Cancellation

Subscriptions renew automatically for successive periods until cancelled. You may cancel at any time; cancellation takes effect at the end of the current billing period. See the Refund Policy at sentinel.custodyagents.com/refunds.

6. Acceptable Use

You agree not to:

• use the Platform in violation of any applicable law or regulation;
• reverse-engineer, decompile, or attempt to extract the source, structure, or underlying mechanics of the Platform, including the Arbiter policy-validation engine and the coordination transport layer;
• circumvent access controls, rate limits, or tier restrictions;
• resell, sublicense, or provide access to the Platform to third parties outside the seat allocations of your tier;
• misrepresent to any client or third party that Custody Agents S.L. holds, controls, or has access to their assets or keys, or that Sentinel output constitutes regulated financial advice;
• use the Platform to build a competing product or service;
• upload private keys, seed phrases, or credentials capable of moving assets. The Platform is not designed to receive such material and you must not submit it.

We may suspend or terminate access for breach of this section.

7. Your Content and Data

You retain ownership of the assessment inputs, configurations, and other material you submit ("Your Content"). You grant us a limited licence to process Your Content solely to operate and provide the Platform, as described in the Privacy Policy.

Processing of personal data is governed by our Privacy Policy at sentinel.custodyagents.com/privacy, which forms part of these Terms.

8. Our Intellectual Property

The Platform, including all software, the Arbiter policy-validation engine, the coordination transport layer, the agent orchestration system, documentation, and the Sentinel and Custody Agents marks, are and remain the exclusive property of Custody Agents S.L. and its licensors. These Terms grant you a limited, non-exclusive, non-transferable, revocable right to access and use the Platform in accordance with your tier, and no other rights.

9. Third-Party Services

The Platform integrates third-party services including Microsoft Azure, Microsoft Entra External ID, Azure OpenAI Service, and Paddle. We are not responsible for the availability, performance, or acts of third-party providers. Where you connect the Platform to a third-party vault, wallet, or hardware device, your use of that product is governed by its own terms and we make no representation about it.

10. Availability and Changes

We aim to keep the Platform available but do not guarantee uninterrupted access. We may modify, suspend, or discontinue features. For material adverse changes to paid tiers, we will give at least 30 days' notice.

Where a tier-specific service level is agreed in an order form for Advisor, Principal, or Enterprise, that service level applies to that tier.

11. Disclaimers

To the maximum extent permitted by applicable law, the Platform is provided "as is" and "as available". We disclaim all warranties not expressly stated, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

We do not warrant that Platform output is complete, accurate, or suitable for any particular custody arrangement, regulatory regime, or jurisdiction. Custody governance is fact-specific and jurisdiction-specific. You are responsible for professional judgement and for independent verification.

Nothing in this section limits liability that cannot be limited under applicable mandatory law.

12. Limitation of Liability

To the maximum extent permitted by applicable law:

• We are not liable for indirect, incidental, special, consequential, or punitive damages, or for loss of profits, revenue, data, business, or digital assets, arising out of or relating to the Platform.
• We are not liable for loss of, or inability to access, any digital asset. We never hold or control your assets or keys; asset custody, key management, and recovery remain entirely under your control and that of your chosen providers.
• Our aggregate liability arising out of or relating to these Terms is limited to the amounts you paid us for the Platform in the twelve months preceding the event giving rise to the claim.

Nothing here excludes liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be excluded.

13. Indemnity

You will indemnify and hold harmless Custody Agents S.L. against third-party claims arising from your breach of these Terms, your misuse of the Platform, or your professional advice to clients where that advice relies on Platform output.

14. Suspension and Termination

You may terminate at any time by cancelling your subscription and closing your account. We may suspend or terminate your access for material breach of these Terms, non-payment, or where required by law, with notice where practicable.

On termination, your right to access the Platform ends. Provisions that by their nature should survive (Sections 7, 8, 11, 12, 13, 16) survive termination.

15. Changes to These Terms

We may update these Terms. For material changes we will provide notice by email and by a banner on the Platform at least 30 days before the changes take effect. Continued use after the effective date constitutes acceptance. If you do not accept, you may cancel before the effective date.

16. Governing Law and Disputes

These Terms are governed by the laws of Spain. The courts of Barcelona, Spain have exclusive jurisdiction, except that:

• if you are a consumer resident in the EU, you retain the protection of mandatory provisions of your country of residence and may bring proceedings there;
• consumers in the EU may also use the European Commission Online Dispute Resolution platform.

17. Contact

Custody Agents S.L. CIF B24890931 Avenida Diagonal, 449, 4a planta, 08036, Barcelona, Spain

General enquiries, subscriptions, and data protection: privacy@custodyagents.com Legal, compliance, and security matters: compliance@custodyagents.com

END OF TERMS OF SERVICE