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Legal & Compliance

VARA Licensed — Broker-Dealer (VASP) — Dubai, UAE

Terms & Conditions

VARA Broker-Dealer License (VASP)Last revised: May 2026
Please read these Terms carefully before using the Cirify platform or activating any AI trading bot. By accessing our services, you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree, you must refrain from using Cirify's services.

1Introduction

Cirify LLC is incorporated in Dubai, UAE, and licensed by VARA to provide Broker-Dealer Services under the VASP framework. Registered address: Al Wasl R260 Building, Office 01, Ground Floor, Baniyas Road, Deira, Al Rigga, Dubai, UAE.

These Terms govern your access to and use of the Cirify website, application, API, and all related services including the AI trading bot marketplace and wallet access.

2Definitions

  • "Platform" — The Cirify website, application, API, and all associated services.
  • "AI Bot" — An automated algorithmic trading program available through the Cirify marketplace.
  • "Runtime" — The fixed period during which a selected AI Bot actively executes trades.
  • "Private Wallet" — A non-custodial digital asset wallet controlled by the User.
  • "VARA" — Dubai Virtual Assets Regulatory Authority.
  • "VASP" — Virtual Asset Service Provider under applicable UAE regulations.

3Eligibility

  • You must be at least 18 years of age and legally capable of entering contracts.
  • You must not be resident in a jurisdiction where virtual asset services are prohibited.
  • You must not be subject to applicable sanctions.
  • You must have successfully completed Cirify's KYC verification.
Cirify reserves the right to refuse, suspend, or terminate any account at its sole discretion if any eligibility criterion is not met.

4Our Services

Bot Marketplace

Cirify operates an internal marketplace where Users may select from a curated range of AI trading bots designed to execute trades automatically on supported markets including cryptocurrency markets and prediction markets such as Polymarket. Cirify does not guarantee the performance or profitability of any specific bot.

Fixed Runtimes

Upon selecting a bot, Users choose a fixed Runtime. Once activated, Runtimes cannot be cancelled, modified, or paused unless expressly permitted in the Platform interface.

Private Wallet Access

Cirify operates on a non-custodial wallet model. Users retain full ownership of their digital assets at all times. Cirify does not hold, custody, or control User funds.

Market availability may differ by jurisdiction. Cirify reserves the right to restrict access to certain markets based on regulatory requirements.

5Risk Disclosure

Trading virtual assets and using automated trading systems involves substantial risk. You may lose some or all of your capital. See the full Risk Disclosure tab for complete details.

6User Accounts & Security

You are solely responsible for maintaining the confidentiality of your account credentials. Each User may hold one account. Cirify may suspend accounts at any time for violations of these Terms or applicable law.

7KYC & AML

As a VARA-licensed entity, Cirify is required to verify the identity of all Users prior to granting access to trading services. All transactions are subject to AML monitoring. Suspicious activity will be reported to the UAE FIU without prior notice to the User. See the full AML Policy tab for details.

8Wallet & Funds

Cirify does not hold or take custody of User funds. All assets remain within the User's private wallet throughout Bot activation. Users are solely responsible for wallet security. Loss of private keys is irreversible.

9Bot Selection & Runtime Terms

Bot selection does not constitute investment advice. All selections are made at the User's own risk. Activated Runtimes are non-cancellable and non-refundable unless a material technical error by Cirify caused incorrect activation. Cirify makes no guarantee of Bot performance or profitability.

10Fees

Fees are displayed before any transaction is confirmed. See the Fee Schedule tab for full details. Cirify reserves the right to modify fees with 30 days' notice.

11Prohibited Activities

  • Money laundering, terrorist financing, or sanctions evasion
  • Market manipulation, wash trading, or spoofing
  • Providing false information during KYC
  • Reverse engineering any Cirify Bot or Platform component
  • Using the Platform from prohibited jurisdictions

12Intellectual Property

All Platform content, algorithms, designs, and trademarks are the exclusive property of Cirify LLC. Bot algorithms are proprietary and confidential. Users have no right to copy, reverse-engineer, or redistribute any Platform component.

13Limitation of Liability

To the maximum extent permitted by law, Cirify shall not be liable for trading losses, technical failures, wallet security failures, or market volatility. Cirify's aggregate liability shall not exceed fees paid by the User in the 30 days preceding the claim.

14Governing Law

These Terms are governed by the laws of the Emirate of Dubai and the UAE. Disputes shall be resolved by arbitration under DIAC rules, conducted in English in Dubai.

15Contact

CompanyCirify LLC
AddressAl Wasl R260 Building, Office 01, Ground Floor, Baniyas Road, Deira, Al Rigga, Dubai, UAE
RegulatorVARA — Broker-Dealer Services, VASP License

Privacy Policy

UAE Federal Decree-Law No. (45) of 2021 on Personal Data ProtectionLast revised: May 2026
This Privacy Policy explains how Cirify LLC collects, uses, stores, and protects your personal data. By registering an account, you consent to these practices. If you do not agree, do not use our services.

1Overview

Cirify LLC is subject to the UAE Federal Data Protection Law and VARA's Technology and Information Rulebook. This Policy applies to all personal data collected through the Cirify website, web application, API, and communication channels.

2Data We Collect

Identity & KYC

Full legal name, date of birth, nationality, passport or ID number, residential address, and proof of address documentation.

Account Data

Email address, phone number, hashed login credentials, and account activity history.

Financial & Wallet Data

Wallet addresses, transaction history, Bot activation records, Runtime durations, and source of funds documentation.

Technical Data

IP addresses, browser type, device identifiers, session timestamps, and platform usage logs.

3How We Use Your Data

  • Contract performance: Account creation, Bot activation, and service delivery
  • Legal obligation: KYC/AML verification, VARA reporting, Travel Rule compliance
  • Legitimate interest: Fraud prevention, security, and system improvement
  • Consent: Marketing communications where you have opted in
Cirify does not sell, rent, or trade your personal data to third parties for commercial purposes.

4Data Sharing

We share data only with regulatory authorities (VARA, UAE FIU), KYC/AML service providers under binding agreements, technology infrastructure providers, legal advisors, and external auditors. All processors are bound by data protection obligations no less stringent than this Policy.

5Retention

  • KYC and identity documents: 8 years from account closure
  • Transaction records: 8 years from transaction date
  • AML monitoring records: 8 years
  • Complaint records: 5 years from resolution
  • Technical logs: 12 months rolling

6Your Rights

Under UAE data protection law you have the right to access, rectify, erase, port, and object to processing of your data, and to withdraw consent at any time. Rights may be limited where Cirify has a legal retention obligation. Submit requests to our Data Protection Officer at the address below.

Mandatory VARA 8-year retention requirements may limit certain erasure requests.

7Security

Cirify applies encryption in transit and at rest, role-based access controls, regular penetration testing (including VARA-mandated Thread Led Penetration Testing), and incident response procedures in line with the VARA Technology and Information Rulebook.

8Contact

Data ControllerCirify LLC
AddressAl Wasl R260 Building, Office 01, Ground Floor, Baniyas Road, Deira, Al Rigga, Dubai, UAE

Risk Disclosure Statement

Mandatory — VARA Market Conduct RulebookLast revised: May 2026
Important: Trading virtual assets and using automated trading systems involves substantial risk of financial loss. You may lose some or all of your capital. Do not invest funds you cannot afford to lose.

1Important Notice

This Risk Disclosure is provided pursuant to the VARA Market Conduct Rulebook and is a mandatory pre-condition to using the Cirify Platform. By proceeding, you confirm that you have read and accepted all risks described herein. If uncertain, seek independent financial, legal, and tax advice before proceeding.

Virtual assets are not legal tender, are not backed by any government or central bank, and are not covered by any deposit guarantee scheme.

2Market Risk

Virtual asset prices are highly volatile. Price movements of 20%, 50%, or more within a single day are not uncommon. You could lose a substantial portion or the entirety of your invested capital at any time. Factors influencing prices include macroeconomic developments, regulatory announcements, market sentiment, and geopolitical events — none of which are within Cirify's control.

Past performance, including data displayed on the Platform, is not indicative of future results.

3Algorithm & Bot Risk

  • Model risk: No algorithm can predict future market conditions. Past bot performance does not guarantee future results.
  • Execution risk: Bots may experience slippage — the price at order placement may differ from execution price.
  • Strategy obsolescence: Strategies effective today may become ineffective as markets evolve.
Backtested data is simulated. It does not account for real-world slippage, fees, or liquidity constraints. Backtested results are not a reliable indicator of live performance.

4Technology Risk

Automated trading depends on technology that may fail. Risks include software bugs, internet outages, exchange API failures, blockchain network congestion, and cyber attacks. These may result in missed trades, erroneous orders, or inability to exit positions.

5Liquidity Risk

Some virtual assets and prediction markets may experience periods of low liquidity. Bots may be unable to execute trades at desired prices or close positions at all during low-liquidity periods.

6Regulatory Risk

The regulatory environment for virtual assets continues to evolve globally. Changes in law may affect the legality of holding or trading certain assets, Cirify's ability to offer certain services, and tax treatment in your jurisdiction.

7Wallet & Security Risk

Loss of private keys or seed phrases is irreversible. Cirify cannot recover lost wallet access under any circumstances. Never share your private key or seed phrase with anyone.

8Prediction Market Risk

Bots on prediction markets such as Polymarket carry additional risks: binary outcome risk, liquidity risk in niche markets, oracle resolution disputes, and potential regulatory restriction without notice.

9No Investment Advice

Nothing on the Platform constitutes financial, investment, tax, or legal advice. All Bot selections and capital allocation decisions are made entirely at your own discretion and risk. Cirify strongly recommends seeking independent professional advice before using the Platform.

AML & Compliance Policy

Anti-Money Laundering, Counter-Terrorist Financing & Sanctions ComplianceLast revised: May 2026
Cirify has zero tolerance for money laundering, terrorist financing, and all financial crimes. This is a public summary of our AML/CTF policy as required by VARA's Compliance and Risk Management Rulebook.

1Regulatory Framework

Cirify's AML/CTF programme complies with: UAE Federal Decree-Law No. (20) of 2018 on AML/CFT; VARA Compliance and Risk Management Rulebook (Version 2.0, June 2025); FATF Recommendations on Virtual Assets; and UAE Cabinet Decision No. (134) of 2025 on the Virtual Asset Travel Rule.

2Risk-Based Approach

Cirify applies a risk-based approach to AML/CTF compliance, assessing money laundering risks for each customer, product, and transaction. Our Business Risk Assessment (BRA) is reviewed quarterly in line with VARA's 2026 mandatory quarterly review requirements. Higher-risk customers are subject to Enhanced Due Diligence and enhanced monitoring.

3Customer Due Diligence

Standard CDD

All customers complete full KYC before accessing services: full name, date of birth, nationality, government-issued ID, residential address, and source of funds declaration.

Enhanced Due Diligence

Applied to Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, and accounts with unusual activity. Requires senior management approval.

Ongoing Monitoring

Customer profiles and transaction activity are monitored continuously via automated systems and on-chain KYT analytics.

4Suspicious Activity Reporting

Cirify is a registered reporting entity to the UAE FIU. Where we have reasonable grounds to suspect money laundering or terrorist financing, we are legally obligated to file a Suspicious Transaction Report (STR) via the UAE FIU goAML portal.

Cirify is legally prohibited from notifying any customer that an STR has been filed concerning their account. This tipping-off prohibition is absolute.

5Sanctions Screening

All customers and transactions are screened against UAE, UN, EU, and OFAC sanctions lists at onboarding and on an ongoing basis. Any sanctions match results in immediate account suspension and regulatory referral.

6Travel Rule

Cirify complies with the UAE Virtual Asset Travel Rule (VARA Circular, February 2026). Originator and beneficiary information is collected, verified, and transmitted for qualifying virtual asset transfers. Users may be required to provide additional information to facilitate compliance.

7Record Keeping

All KYC, transaction, CDD, EDD, and STR records are retained for a minimum of 8 years from the relevant transaction date or end of customer relationship, whichever is later.

Complaints & Dispute Resolution

VARA Market Conduct Rulebook — Complaints Handling RequirementsLast revised: May 2026
Cirify is committed to resolving complaints promptly, fairly, and transparently. All complaints are investigated impartially. Please follow the process below.

1How to Submit a Complaint

In writingAl Wasl R260 Building, Office 01, Ground Floor, Baniyas Road, Deira, Al Rigga, Dubai, UAE
Subject lineFormal Complaint — [Your Account Reference]
Via PlatformContact / Support section in your account dashboard

Please include your full name, account reference, a clear description of the issue, relevant dates and amounts, the Bot or service involved, the outcome you are seeking, and any supporting documentation.

2Response Timeframes

  • Acknowledgement: Within 2 business days of receipt
  • Holding response: Within 15 business days if further investigation is required
  • Final response: Within 30 calendar days of receipt
  • Complex complaints: Up to 60 calendar days with written justification
Complaints resolved within 3 business days may receive an informal resolution confirmation in lieu of a full written response.

3Escalation Process

Internal Escalation

If unsatisfied with the initial response, request escalation to our Compliance Officer in writing. The Compliance Officer conducts an independent review and issues a final decision.

VARA Referral

If the internal process is exhausted and you remain dissatisfied, or if Cirify fails to respond within prescribed timeframes, you may refer your complaint to VARA at www.vara.ae. Cirify will cooperate fully with any VARA investigation.

4Record Keeping

Cirify maintains a formal complaints register in accordance with the VARA Market Conduct Rulebook. All complaints, investigations, and outcomes are retained for a minimum of 5 years. Aggregated data is reported to VARA as required.

Fee Schedule

VARA Market Transparency RequirementsEffective: September 2026 (Beta Launch)
This schedule becomes effective upon the Beta launch in September 2026. No fees apply during the PRE Phase (May–August 2026). All fees are subject to change with 30 days' notice.

1Overview

All Cirify fees are displayed on the Platform before any transaction is confirmed. All fees are denominated in USD or an approved stablecoin equivalent. Cirify charges no hidden fees.

  • Account registration: Free
  • KYC verification: Free
  • Marketplace browsing: Free
  • Bot activation fee: Per-bot, displayed at time of selection
Specific fee amounts per Bot and Runtime tier will be published in this schedule no later than 30 days before the Beta launch.

2Runtime Fees

Runtime fees are charged per activation period and are non-refundable once commenced. Three Runtime tiers are planned (Short, Standard, Extended) — exact durations and prices to be confirmed. A performance fee may apply to certain Bots as a percentage of realised net profits only. No performance fee is charged on losing Runtimes.

3Third-Party Fees

Outside Cirify's control: blockchain gas fees, exchange trading fees, prediction market spreads, and currency conversion fees. Estimated third-party fees will be displayed where calculable in advance.

4Refunds

Runtime fees are non-refundable except where a material technical error by Cirify caused incorrect activation, or where Cirify suspends a Bot during an active Runtime for reasons attributable solely to Cirify. Refund requests must be submitted in writing within 14 calendar days of the triggering event.

5Taxes

All Cirify fees are exclusive of applicable taxes including VAT. Where applicable, taxes will be itemised in transaction confirmations. You are solely responsible for your own tax obligations arising from Platform use.

Cookie Policy

UAE Cybersecurity Law & VARA Technology and Information RulebookLast revised: May 2026
This policy explains how Cirify uses cookies and similar tracking technologies. By continuing to use the Platform, you consent to our use of cookies as described below. You can manage preferences at any time as set out in Section 3.

1Cookie Types We Use

Strictly Necessary

Essential for Platform functionality. Cannot be disabled. Includes session cookies, security/CSRF tokens, and consent preference storage. No consent required.

Functional

Remember your preferences and settings (language, dashboard layout). Enhance usability but are not strictly necessary.

Analytics

Help us understand how Users interact with the Platform in aggregate, anonymised form — page views, session duration, navigation paths, and error tracking. Only placed with your consent.

Security & Compliance

Support fraud detection, AML monitoring, and regulatory compliance. May track device fingerprints and behavioural signals. Required for regulatory compliance and cannot be disabled.

2Third-Party Cookies

Identity verification providers, analytics tools (with consent), and security/DDoS protection services may set their own cookies. These are governed by each provider's own privacy and cookie policy.

3Managing Preferences

  • Consent banner: Shown on first visit — accept or decline non-essential cookies
  • Account settings: Update preferences at any time within your account
  • Browser settings: Block or delete cookies via browser privacy settings
Disabling strictly necessary or security cookies may prevent login and affect regulatory compliance capabilities.