General terms and conditions of use of the TurinPool platform


TURIN LABS, S.L. (hereinafter,”TURIN LABS”), with address for this purpose in Spain, Calle Don Ramón de la Cruz, 38, in Madrid, with CIF B88623616, registered in the Mercantile Registry of Madrid in Volume 40372, Folio 30, Sheet M-717137, is the owner of the website: through which you access the Platform based on Distributed Registry Technology called TurinPool (hereinafter, the”Platform” or”Turin Pool”).


Turin Pool: is a Platform based on Distributed Record Technology (hereinafter,”TRD”) developed and used by TURIN LABS, which allows the digitization of economic rights to shares in Mercantile Companies and their exchange and management by users and COMPANIES, as well as access to goods or services through utility Tokens.

Cryptoassets: are Tokens or digital representations of values or rights that can be transferred and stored electronically, through TRD.

Economic Rights Tokens or “DE Tokens”: are Cryptoassets generated through TRD that digitally represent Economic Rights of the shareholding shares of Mercantile Company Partners or”COMPANIES”, and that confer on the user or holder of the same the credit right to receive in cryptocurrency or current currency the dividends agreed by the COMPANIES or the liquidation fee equivalent to the increase in the value of the shares or shares in the event of the sale of the Company.

Cryptocurrencies or Virtual Coins: digital representation of value not issued or guaranteed by a central bank or public authority, not necessarily associated with a legally established currency and that does not have the legal status of currency or money, but which is accepted as a medium of exchange and can be transferred, stored or traded electronically.

Token Stable Coins or “SC Tokens”: are cryptocurrencies referenced to current currencies or”FIAT” generated through TRD or that allow the transfer of value and exchange for fiat currency on Exchanges or Cryptocurrency Exchange Service Providers.

User: people of legal age and with full capacity to hire, who access TurinPool for the management and exchange of cryptocurrencies and cryptoassets. In this sense, the User of the TurinPool Platform may be both a natural person and a legal entity.

Economic Rights Management Vault or “DE Vault”: are the technological systems or private asset digitization ecosystems generated by TURIN LABS for COMPANIES that allow the distribution, assignment, exchange and management of Tokens or Cryptoassets.

Liquidity pool: They are exchange funds that contain a specific pair of cryptoassets, the token to which it is intended to provide liquidity and an SC, and that are made available to Users of the DE Vaults to provide liquidity and to facilitate the sale of the corresponding cryptoasset without the need for sales orders. They involve a dynamic pricing mechanism based on the proportion at any given time of both cryptoassets in the Pool, calculated according to a formula called “Invariant”.

COMPANIES: are the Mercantile Companies that have contracted the services of TURIN LABS for the digitization of the economic rights of the shareholding of the partners through the DE Vaults.

Partners: they are the Partners of the COMPANIES who have agreed, at the Meeting of Partners, to issue and tokenize the economic rights to their shares, as well as their management and exchange in the private environment of a DE Vault through the Liquidity Pools created by the COMPANIES.

E-wallet or Wallet: a storage system for cryptoassets and cryptocurrencies that has a public key and a private key associated with it to allow the movement of the user's funds. The public and private keys of the Wallets that are provided by the TurinPool Platform to Users will be kept only by each User of the Platform, so that TURIN LABS is not constituted as a provider of custody services for the Wallets that operate in the DE Vault, and the User is the sole responsibility of managing the same.

Dividend distribution: are the dividend payment processes initiated by COMPANIES to users or holders of DE Tokens in their Vaults.

Liquidative events: are the payment processes initiated by COMPANIES to users or holders of DE Tokens in their Vaults, which are equivalent to the liquidation fee related to the increase in value of shares or shares in the event of the sale of the COMPANY. A liquidation event shall be understood as the transfer to one or more third parties of shares representing the share capital of the COMPANY, whether total (100.00%) or partial by more than fifty percent (50.00%), in one or more successive transfers within a maximum period of twelve (12) months, and such transfer involves a monetary collection in favor of the members of the COMPANY.

Membership Registration Book: it is the book that COMPANIES are obliged to have and to keep, in order to record in it who are the founding partners of the company and the subsequent transfers of shareholding, as well as the constitution of real rights and other encumbrances on them, such as the ownership of DE Tokens.


These General Terms and Conditions (hereinafter,”TCG”) regulate the use of the TurinPool Platform and the provision of services through it, which will allow the User to manage and exchange DE Tokens representing the economic rights of the shareholding of COMPANY Partners.

In particular, TURIN LABS, S.L. has created the TurinPool Platform to allow the issuance and provide liquidity to both DE Tokens of COMPANY Partners.

TurinPool allows the tokenization of economic rights to the social shares of COMPANY Partners, as well as the digitization of access rights to products or services, and their respective representation through cryptoassets or Tokens. To this end, private corporate ecosystems have been created for the exchange of cryptoassets through TRD within the TurinPool Platform, called Vaults, and which will be created by TurinPool for each of the COMPANIES on the Platform.

The Economic Rights Management Vaults or”Vaults DE” allow COMPANIES to manage the ownership of these DE Tokens, with the objective of fulfilling the social and economic obligations of distributing social dividends, liquidation events and annotation in the Members' Record Book. In addition, the Access Rights Management Vaults allow the management of ownership and establish information to the User about the products or services to which their owners are entitled.

In this regard, TurinPool allows the User, subject to acceptance of the Particular Terms and Conditions (hereinafter,”TCP”), access to the DE vaults of each COMPANY. These DE Vaults of each COMPANY will have a Liquidity Pool or token exchange fund, available to Users, to provide liquidity and facilitate the exchange of cryptoassets.

All the tools, services and aspects common to all the Vaults that make up TurinPool (among others: identification and knowledge of the Customer - KYC, assignment and management of Wallets, etc.) are made available to the user and regulated by TURIN LABS through these TCG. The specific characteristics of each of them and the aspects related to their operation in COMPANIES will be regulated in the TCP applicable to the specific case, which must be expressly accepted by the User.


TURIN LABS provides, through TurinPool, an environment in which, in a simple and simple way, the intervening Users can, through electronic wallets or wallets (hereinafter,”Wallets”) that provides the TurinPool user with access to the following services:

  • Electronic Wallets or Wallets:
  • Storage of cryptocurrencies and cryptoassets supported by TurinPool.
  • Exchange of cryptoassets between users with Wallets within TurinPool.
  • Vaults:
  • Access the Vaults created by COMPANIES.
  • Exchange the DE Tokens of the COMPANY Partners for SC Tokens through the Liquidity Pool of each DE Vault.
  • Remuneration rights management (liquidation events and dividend distribution) granted by COMPANIES to the holders of the DE Tokens in each Vault.


These TCG, the Legal Notice, the Privacy Policy, the Cookie Policy, as well as the TCP of the Vaults of the COMPANIES with which the User wishes to interact and any other specific conditions published on this website, are applicable to the services offered by TURIN LABS through the TurinPool Platform.

These TCG must be accepted by the User in order to use the TurinPool services, which require prior acceptance through the website. The non-acceptance of the TCG in the registration processes makes it impossible to use TurinPool services.

With the express acceptance of these TCG, it is understood that the User has fully accepted them and that, therefore, he has previously read and understood each and every one of the terms, being obliged to comply with all the specifications established therein, and may be stored and reproduced by the latter at any time.

TURIN LABS, in accordance with the provisions of article 27.1 of Law 34/2002, of July 11, on information society services and electronic commerce (hereinafter,”LSSI”), expressly states that it will archive the electronic document in which the contracting of the Services is recorded.


People of legal age and with full capacity to contract can acquire the status of User. Therefore, any request for admission as a TurinPool User by a minor under eighteen (18) will be denied.

The acquisition of the status of User of the TurinPool Platform implies the express and unreserved reading and acceptance of the terms included in these TCG, the Legal Notice and the Privacy Policy of TURIN LABS.

Registering as a TurinPool User is an essential prerequisite for contracting the services made available by TURIN LABS.

The User who accesses TurinPool in the name and on behalf of a Legal Entity, accepts and declares to have sufficient powers and representation to link the Legal Person, Company or Professional they represent to the contracting of services, and TURIN LABS will presume that it has been carried out by the latter.

TURIN LABS reserves the right to modify any legal texts of TurinPool and they will be considered fully accepted if, within one month of making them available, the User does not request to cancel or cancel the service.


The User may access the TurinPool services using the username and password that will be generated during the registration process at the time they sign up to these Terms and Conditions.

The username and password are strictly personal and confidential.

The User expressly accepts that TURIN LABS presumes that the uses of the service made using their identification keys are made by the registered User. In case of loss or theft, the user must immediately change it.

The password may be freely modified by the User, through the procedures established for this purpose. The replaced password will be canceled as soon as the new one is generated.


The User must provide in its entirety the information required by TurinPool and declares and guarantees it is accurate, updated and complete.

In compliance with the provisions of the Law 10/2010, of 28 April, on the prevention of money laundering and terrorist financing (hereinafter,”PBCyft Act”) and other applicable legislation, the type of User will determine the information to be requested depending on whether they are a natural or legal person, and on the interaction that the User wishes to make with the DE or UT Liquidity Pools in their corresponding Vaults.

Among other things, the requested information may consist of:

  • Identifying data such as: name, surname, date of birth, email address, mobile phone number, profession, etc.
  • Username and password.
  • Security code sent to the email or security code required for double authentication.
  • Other possible data or necessary information.

Depending on the service and the economic thresholds of the operations to be carried out by the User, different levels of information will be requested, in order to allow services with more functionality and higher quantitative thresholds in the operations that the User wishes to carry out.

TURIN LABS has the necessary tools to collect the documentation and initial information requested from the User at the time of registration. COMPANIES, in their capacity as subjects bound by the PBCyft Act, may at any time request additional information in order to learn more about the purpose and nature of the User's business relationship, and may even do so through a third party.

In this regard, for the provision of the services covered by these TCG, it will be necessary for TURIN LABS to make available to COMPANIES the necessary information on data protection and PBCyft for the proper protection of intervening Users who exchange cryptoassets in the different Liquidity Pools of the Vaults DE. Such communication or transfer of information It will only occur when the user accepts the TCPs from each DE Vault.

The lack of information or the existence of evidence of money laundering in the data provided will allow TURIN LABS to block the account and, where appropriate, the immediate unilateral termination of the contract for the provision of services that binds them.

In addition, TURIN LABS reserves the right to suspend the User's operations cautiously and block the use of the service, until it has been able to confirm and verify the legality and legitimacy of the operations.

  1. TurinPool SERVICES

In order to operate on the Platform, TURIN LABS will provide each User with personal and non-transferable Wallets on the TurinPool Platform. The Wallets will allow the User to carry out the following activities:

  1. Wallets

Wallets are configured as storage systems for cryptoassets and cryptocurrencies that have a public key and a private key associated with them to allow the movement of funds.

TURIN LABS will provide a Wallet to every registered user on the Platform. The public and private keys of the Wallets provided by the TurinPool Platform to Users will be guarded only by each User of the Platform, so that TURIN LABS It is not constituted as a provider of custody services for Wallets that operate in La Bóveda DE, being the User's sole responsibility for managing the same.

The transfer of Wallets, as well as the transfer of usage keys, is prohibited. Each user will be responsible for the breach of this obligation. In this regard, all operations carried out from the User's Wallet will be attributable to the User, and it will be presumed that they have been carried out by the User.

  1. Cryptoassets supported in the Platform's Wallet

TurinPool supports the following Cryptocurrencies or Cryptoassets:

  • Los “Economic Rights Tokens” or”Tokens DE”, issued and managed through the DE Vaults of the COMPANIES in TurinPool, and which represent the economic rights of the shareholding of the Partners of the COMPANIES.
  • Los “Stable Coin Tokens” or “SC Tokens”, which are blockchain-based cryptocurrencies or monetary units paired 1:1 to the value of a legal tender and recognized by TurinPool (e.g., USTD).
  1. Storage of funds in the Wallet

In order to operate in TurinPool, it is necessary for the User to have funds in their Wallet, for which they can only deposit through the cryptocurrencies supported by TurinPool. 

TURIN LABS is not responsible for any external account or wallet fees or commissions or for the administration and security of any external account. The User is solely responsible for the use of any external account, and agrees to comply with all terms and conditions applicable to any external account. The time associated with a charge transaction will depend in part on the performance of third parties responsible for maintaining the applicable external account, and TURIN LABS does not guarantee the time it can take to deposit funds into your Wallet.

  1. Check the Balance

The User will always have in their Wallet the balances of the cryptoassets and cryptocurrencies supported by TurinPool that they have deposited or purchased through the COMPANY's DE Vaults or by transfer from third parties.

The User must bear in mind that TURIN LABS does not pay interest on any balance they have in their account.

  1. Exchange Services

The TurinPool service allows exchanges of cryptoassets and cryptocurrencies in the Liquidity Pools and private transfers between the Vault Users of each TurinPool COMPANY. In this regard, the transfer of DE Tokens between Users will require that both Users are users of the specific DE Vault of the DE Token to be transferred and have passed the identification process for access to the Vaults, after accepting the TCP.

  1. Withdrawal Services

The TurinPool service allows the User, from their Wallet, to send cryptoassets and cryptocurrencies to external Wallets, except for the withdrawal of DE Tokens, since it is only allowed to operate with them in the environment of the COMPANY's Vault DE for the purpose of correctly tracing their ownership.

Withdrawal of SC Tokens, utility tokens or cryptocurrencies to an external Wallet: as long as the balance of funds in the User's Wallet is greater than any minimum balance requirement necessary to be able to operate, you can withdraw any amount of funds from your Wallet to an external account, up to the total amount of funds in your Wallet. In this regard, the User will be informed at all times before carrying out an operation in the Vault of the resulting balance.

To do this, the User must withdraw by entering the destination address of the desired cryptocurrency or by generating an invoice from their external Wallet in the case of withdrawal through the Polygon network. The User must send only cryptocurrencies of the type that the destination address and/or Wallet can receive.

The User accepts that TURIN LABS may charge certain costs for such withdrawals as strictly necessary, for example, network costs, protocol maintenance, fees associated with liquidity providers, etc.

TURIN LABS is not responsible if the destination address indicated by the User or the invoice provided in the withdrawal form is incorrect.

In some cases, the external Wallet may refuse your funds or may be unavailable or incompatible. The user accepts that TURIN LABS will not be held responsible for damages resulting from such rejected exchanges or sent to incompatible Wallets.

Cryptocurrency withdrawals from TurinPool can be verified in a compatible blockchain browser, for example, through a transaction identification code that TurinPool will make available to the User.

Withdrawal of DE Tokens: The DE Tokens they cannot be withdrawn from the User's Wallets to external accounts or Wallets, and the User may only operate with them within the DE Vault enabled for this purpose by the COMPANY.

  1. Access to the Vaults

To access the services of each Vault or exchange of Tokens for other Cryptoassets, the User must first accept the specific TCPs of each Vault, which, once accepted, can be downloaded or reproduced from

After prior acceptance of the TCP, the User may, through the Wallet provided by TURIN LABS, operate in the Liquidity Pool of the DE Vaults in accordance with the information provided by the COMPANIES.

  1. Exchanges in the Liquidity Pools

Users of the DE Vault will have a Liquidity Pool available to Users to provide liquidity and facilitate the exchange of cryptoassets.

The Liquidity Pool will be created by the COMPANY providing two pairs of cryptoassets or tokens of those supported by the Platform.

At the time the Liquidity Pool is created, the formula of the Pool's dynamic pricing mechanism, known as “Invariant”, will be generated, which will allow calculating the price of DE Tokens for transactions carried out in the DE Vault environment. According to this formula, the more demand there is for the DE Token, the more value it will have in the Liquidity Pool. Conversely, if there is a larger supply of DE Tokens in the Liquidity Pool, their value will be lower.

You can get more information about the “Invariant” formula and the dynamics of Liquidity Pools at the following link:

  1. Private exchanges between Users

Private exchanges may take place between the users of each Vault who have accepted the TCPs, and TurinPool is not responsible for the underlying legal business that enables such exchanges.

  1. Liquidity providers

Any User who is configured as a liquidity provider to the Pool by contributing the same amount of both pairs of Tokens traded in the DE Vault, will obtain a certain percentage for each transaction made in the Pool in terms of commissions or “fees”, as reported at

  1. Registration and ownership of Tokens

All the exchanges produced in the Liquidity Pools of the Vaults DE are registered in the Blockchain network of Polygon. This registration will allow COMPANIES to identify the exchanges produced and to comply with their social and economic obligations in relation to the identification of the ownership of economic rights to social shares, as well as to make appropriate annotations in the Shareholders' Record Book and to comply with liquidation events. This identification will in any case be made through the registration of TurinPool Users.

To guarantee the privacy of transactions made through TurinPool, the Platform will not publish any details of the User's identity or public key in its public transactions.

  1. Dividend distribution and liquidation events

COMPANIES will distribute dividends through the Wallet service for users of the TurinPool Platform based on the ownership of the DE Tokens in the DE Vault User Registry. These distributions will be made in accordance with those specified in the TCP, by entering them in the User's Wallet. Likewise, COMPANIES will distribute, in accordance with the TCP, the distribution of liquidative events to the user's wallets at the time they occur.

  1. Closing the Liquidity Pool

In the event of the closure of a Liquidity Pool by a COMPANY, TurinPool will inform Users at least 30 days in advance of the closing date of the Pool, and from then on the exchange of cryptoassets through the Liquidity Pool is not allowed.

In the event of the closure of Liquidity Pools on DE Tokens, the functions of distributing dividends and liquidative funds for COMPANIES and Users will remain operational, thus limiting the operation of exchanging Tokens through the Liquidity Pool. TURIN LABS is not responsible for any damages that may arise to Users as a result of the decision to close the Liquidity Pool.

  1. Conditions and restrictions

TURIN LABS you may at any time and at your sole discretion reject any exchange submitted through the Services, impose limits on the amounts of exchanges allowed through the Services, or impose any other conditions or restrictions on the use of the Services without prior notice.  

Once an order or exchange request on TurinPool has been executed, you cannot change, withdraw or cancel your request. All exchanges are irreversible once initiated. 

  1. Insufficient funding

In cases where there is not a sufficient amount of funds in the TurinPool user's Wallet to complete an exchange in a Liquidity Pool, such exchange order may be canceled by TurinPool.

  1. Limits on operations

TurinPool Users can find information regarding the limits of the services offered, as well as the price or commissions for using them by accessing the Limits and Pricing section of the website (


The service provided to the User through TurinPool will generate fees and/or commissions (they can be found in the commissions and limits section of the website:, which will be reported to the User on each exchange, and will be kept in the User's exchange history in accordance with the PBCyft Act for ten (10) years.

  1. TAXES

The User is responsible for determining what taxes, if any, apply to the transactions carried out through the Services, and it is their responsibility to report and submit the correct tax to the corresponding tax authority. The User accepts that TURIN LABS is not responsible for determining if taxes apply to their operations or for collecting, reporting, withholding or remitting taxes derived from any transaction.


This contract has a duration of one year from its acceptance and signature, and can be extended AUTOMATICALLY for periods of equal duration, indefinitely, unless either party communicates to the other of its intention not to extend. However, the User may at any time request the termination of the contract. In any case, the User cannot cancel the contract until they have fulfilled all their payment obligations to TURIN LABS.

In the event that, for reasons of force majeure, TURIN LABS interrupts its TurinPool services, or TURIN LABS enters into a liquidation or dissolution process, TURIN LABS would inform COMPANIES and Users with cryptoassets and cryptocurrencies managed in TurinPool of this fact.


TURIN LABS undertakes to:

  • Respond with the greatest possible diligence to all queries that the User may request arising from the use of the services included in TurinPool.
  • Provide the service to the User as established in these TCG.
  • Keep TurinPool operational 24 hours a day, except for temporary interruptions due to web maintenance services, technical or computer problems such as internet outages caused by any cause, computer attacks and similar situations that make it temporarily impossible to provide the service. This will be restored as soon as the incidents have been resolved.
  • Notify any movement that TURIN LABS may consider suspicious for the purpose of compromising the security of the User's account, for subsequent analysis of the same.
  • Request as much documentation and information as necessary to comply with your legal obligations.

The User undertakes to:

  • Provide the information required on the forms in the cases indicated in this document.
  • Confirm your acceptance of these GTC by clicking on the “I have read and accept the GENERAL CONDITIONS” button.
  • Communicate to TURIN LABS all the data necessary for access and use of services that require prior identification, which must be true, current and adjusted to reality.
  • Accept the TCP of the Vaults created by the COMPANIES in which you intend to operate.
  • Adopt the necessary security measures, both personal and material, to maintain the confidentiality of relevant data provided by TURIN LABS or its partners, and to immediately notify TURIN LABS of the loss, loss, theft or illegitimate access in your name and/or your knowledge by third parties. The User expressly accepts that any use of the service made with his access credentials has been made by himself. 
  • Make appropriate use of the Services included in TurinPool, always in accordance with the legal system.
  • Not to carry out any activity that hinders or interferes with the operation of the Services, included in TurinPool.
  • To be responsible for all operations carried out in your User account, as well as for safeguarding and preserving the confidentiality of your credentials, exonerating TURIN LABS from any responsibility.
  • Inform TURIN LABS immediately via of any security risk or error or defect in TurinPool that may result in its fraudulent use or that contravenes these Terms and Conditions.

TURIN LABS will do everything reasonably possible to ensure that the User can access the services in accordance with these Terms and Conditions. However, TURIN LABS may temporarily suspend services for reasons of maintenance or updates, and will do everything reasonably possible to inform you about such Scheduled Maintenance. The User recognizes that this may not be possible in cases of emergency and accepts the risks associated with the fact that the User will not always be able to access, or use or carry out exchanges, with the Wallet provided by TURIN LABS.

The TurinPool service, therefore, may be interrupted by TURIN LABS temporarily and without prior notice for those maintenance tasks that are necessary for the proper functioning of TurinPool.

Failure to comply with the obligations listed below by the TURIN LABS User will result in the temporary suspension of the service for the User in TurinPool:

  • The detection by TURIN LABS of fraudulent operations.
  • Lack of additional information necessary for compliance with legal obligations.
  • Do not accept possible updates to the GTC or the Privacy Policy.

The suspension of the service has the following consequences:

  • TURIN LABS will inform you of your decision to temporarily suspend your activity in TurinPool, stating the reason for the suspension, (except for a legal obligation not to do so), requiring the actions to be taken to regularize the situation.
  • The User will not have access to TurinPool during this period and therefore will not be able to carry out any operations there.
  • This temporary suspension becomes final THIRTY (30) days from the beginning of the temporary suspension, if your situation has not been regularized or updated with the necessary information to continue operating in TURINPOOL. After those THIRTY (30) days have elapsed without regularizing the situation and, if you have a balance in your Wallet, will be blocked, becoming considered an “account with an abandoned balance and/or deposit”, applying TURIN LABS to current legal regulations or, where appropriate, will act as ordered by the competent authorities.

These Terms and Conditions are terminated for the following reasons:

  • For non-acceptance of the Privacy Policy, the GTC or the price of the service: The contract will automatically terminate.
  • For breach by one of the parties of any essential obligation of the contract: the other party may unilaterally terminate this contract.
  • At the express wish of the User: The User may decide at any time to end the term of this contract, for which they must communicate their decision to the following email address:

When this contract is terminated for any reason, the User may not ask TURIN LABS to undo the operation or operations carried out throughout the duration of the contractual relationship.


The User ensures that they understand and have the necessary knowledge to use blockchain systems and services, and that they are fully aware of the risks associated with cryptoassets and the use of blockchain. TURIN LABS will not be responsible for any loss or gain of cryptocurrencies or cryptoassets or situations that make access to them impossible, which may result from any action or omission of the User.

TURIN LABS does not provide any type of advice to the User in any area, whether fiscal, financial, economic, accounting, commercial or any other. Therefore, the decisions taken by the User are made in a personal capacity.

Exchanges in cryptocurrencies and cryptoassets are irreversible, so the User must take maximum precautions when carrying out transactions or providing a correct public address for their wallet. The User will not claim from TURIN LABS any transaction that is sent from their User account.

The User declares to be aware of all the risks involved in the possession of cryptocurrencies and cryptoassets and therefore exempts TURIN LABS from any liability for their loss.

Notwithstanding the foregoing, in cases where an error may occur during transactions with cryptoassets or cryptocurrencies, the User may contact the TURIN LABS support service at


The Services offered through TurinPool comply with the provisions of the Spanish legal system. TURIN LABS is not responsible for those services that do not comply with the provisions of the legal system of other countries to which the services offered through TurinPool could be provided.

TURIN LABS is released from any liability in case of misuse or contrary to the legal system of TurinPool by the User.

TURIN LABS will not assume any responsibility for damages or losses that may be suffered as a result of events that could not have been foreseen, or that were foreseen to be inevitable, either due to fortuitous circumstances or force majeure.

TURIN LABS is not responsible for any failure, technical error, accident, breakdown, manipulation, interruption in TurinPool or any other incident that may arise in equipment or technical services other than TURIN LABS whose use is necessary for the provision of the Service.

TURIN LABS does not assume any responsibility for failures in the internet network, in cryptocurrency blockchains, external wallets, or for the attack on the software of any hacker that results in the loss or disappearance of the cryptocurrencies owned by the User.

TURIN LABS will not be responsible in the event of TurinPool's unavailability due to force majeure or temporary suspension for technical reasons.

TURIN LABS assumes no responsibility for misuse of the User's access credentials. The replaced password will be canceled as a means of identification, at the same time the new one is generated. The User expressly accepts that any use of the service made with his access credentials has been made by himself.

The User will be responsible for any damages that may have been caused to third parties, due to the data provided, on an enumerative and non-limiting basis as a result of the following actions:

  • Use of data that is not up to date, false or that does not correspond to reality.
  • Use by third parties of the User's personal keys and addresses.

TURIN LABS does not recommend the use of cryptoassets and cryptocurrencies to people who are not fully aware of the service they are hiring and correctly understand how it is being provided.

TURIN LABS is not responsible for the goods or services that allow UT Tokens outside the TurinPool environment, and it is the sole responsibility of the COMPANIES that issue such UT Tokens to guarantee access to such goods or services.


TURIN LABS, if you consider it necessary, you may assign or subcontract the contracts formalized with Users to other entities to carry out the object of the contract as established in these GENERAL CONDITIONS.


The TCG will come into force and, therefore, will apply to TURIN LABS and the User, as soon as the following conditions are met: The User has given consent to them by clicking the “I have read and accept the GENERAL CONDITIONS” enabled in TurinPool.

However, and in compliance with the provisions of article 28 of Law 34/2002 of July 11 on Information Society and Electronic Commerce Services (“LSSI”), within a maximum period of twenty-four hours from the entry into force of the TCG, TURIN LABS will confirm their acceptance by confirming the entry into force of the contract.


TURIN LABS is committed to protecting privacy and providing a secure User experience. By contracting the services provided at TurinPool, the User explicitly accepts the processing of their data as described in the Privacy Policy established by TURIN LABS, S.L. at

In particular, the user knows and accepts that the exchanges are registered in a pseudonymized form on the Polygon network and cannot be deleted or deleted. The pseudonymized registration will allow TURIN LABS and COMPANIES to trace the identity and transactions carried out exclusively by the User on the BlockChain, and therefore the possibility of linking them to the User who owns the Cryptoassets. Once the provision of the services has ended or the right of deletion has been exercised by the user, TurinPool and the COMPANIES will be obliged to delete the data, blocking the processing of the data, and judges and courts must be left at the disposal of the competent authority for the statute of limitations of the legal actions that correspond to the latter in defense. Once the indicated deadline has elapsed, TURIN LABS and the COMPANIES will eliminate the link to the pseudonymized record that allowed the records to be identified with the user's identity, thus guaranteeing the right to the deletion of personal data. TURIN LABS and the COMPANIES are not responsible for the disclosures of identity that occur by the user or by third parties.

Polygon uses cryptographic protocols implemented to improve levels of privacy so that, although they can be verified and validated within the network, they preserve the confidentiality of the exact amounts of the exchanges made and of the issuers or recipients of such exchanges.


The activity of COMPANIES whose Partners have tokenized the economic rights of their shares is subject to the PBCyft Act.

Therefore, registration on the Platform implies the request of the information indicated in clause 5.2 of these TCG by TURIN LABS, with the purpose of providing it to COMPANIES whose Vaults the User accesses and intends to operate. For this purpose, TURIN LABS informs you that these regulations require, among other obligations, that of documentally identifying its Users, gathering information about the nature of their professional or business activity and informing, either at the request of the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences, or ex officio, of any fact or transaction for which there is evidence or certainty that it is related to money laundering.


The TURIN LABS System, its source code and the contents it houses are protected by national and international intellectual and industrial property regulations. They may not be subject to exploitation, reproduction, distribution, modification, public communication, assignment or transformation, unless there is express written authorization from the rights holders.

The design, images, labels, distinctive signs, trade name, brands, logos, products and services contained in it are protected by Industrial Property law.

Access to this Platform does not grant Users any right or ownership over intellectual or industrial property rights or the content it contains. Users who access this Platform may not copy, modify, distribute, transmit, reproduce, publish, assign or sell the above-mentioned elements or create new products or services derived from the information obtained without express written authorization from TURIN LABS.

The alteration of the content or structure of this Platform by the User is strictly prohibited. TURIN LABS reserves the right to take appropriate legal action against Users who violate or infringe intellectual and industrial property rights.


In TURINPOOL you will find links to third-party websites, which are governed by their own conditions, and TURIN LABS is not responsible for the operations that the User may carry out through those entities outside TURIN LABS. Likewise, the Privacy Policy or TCG of these entities is not owned by TURIN LABS, so the User must take this into account to know that both the TCG and the Privacy Policy of these third parties are solely their responsibility and not of TURIN LABS.


This contract will be interpreted and governed in accordance with current Spanish legislation. Both parties, with the express waiver of any jurisdiction that may apply to them, submit any interpretation or controversy resulting from this contract to the Courts that, according to the legal system, are competent.

TURIN LABS S.L. 2024 - Spain.

All rights reserved.