# Welcome to Qiro ## Overview Qiro is building a tokenized private credit marketplace connecting stablecoin investors with prime private credit opportunities, curated via enterprise grade underwriting infrastructure.\ \ Through its enterprise grade credit underwriting infrastructure, Qiro will empower RWA financing platforms with seamless access to off-chain credit data, comprehensive credit risk assessments, and real-time risk monitoring. \ \ We are launching our private credit marketplace as first use-case leveraging our underwriting infrastructure. # Thesis Disrupting the private credit market Private Credit is $1.7T market where non-banking lenders issue loans to asset originators and corporates. However, it has been plagued with rent seeking intermediaries and broken TradFi infrastructure rendering it expensive, inefficient for the participants. \ \ Tokenization of RWAs has been on the rise and Tokenized private credit has rapidly grown to become the largest Real-World Asset (RWA) category after stablecoins, boasting **$9.75 billion** in active loans and **$16.48 billion** in total loans issued to date. This impressive growth signals that the market is not just a trend—it’s here to stay. We believe that tokenization address a fundamental issue in private credit: illiquid assets and limited accessibility. By transitioning assets from off-chain ledgers to on-chain systems, they become modular "money legos," enabling the creation of diverse financial products. This innovation allows anyone holding stablecoins to invest in previously inaccessible private credit opportunities, thereby making the illiquid assets more liquid and accessible.
**But before that, why tokenize private credit ?** 1. Private credit provides attractive risk-adjusted yield opportunities for on-chain investors. 2. Tokenization simplifies access, allowing retail investors to tap into private credit markets that were once limited to institutional players. 3. Blockchain and smart contracts enhances transaction efficiency for the asset originators and investors by eliminating intermediaries. e.g [97% cost reduction for securitisation on centrifuge](https://centrifuge.mirror.xyz/TLXQmWd7d4QJtqXE9c_Y7TgGSvAG060S-YOBs_9TIP0)
# Vision & Mission internet capital markets ## Vision Our vision is to become a global tokenized debt protocol enabling global investors to seamlessly access private credit. We believe in internet capital market and aim to be the de-facto layer for private credit transactions on-chain. ## Mission Our mission is to improve global private credit markets by leveraging blockchain based credit infrastructure. This improvement will be in terms of the cost, speed and efficiency for the investors and originators alike. # DeFi has an underwriting problem Adverse Selection is a big problem in DeFi There have been few attempts in DeFi to solve for tokenized private credit. Incumbents have struggled with one issue across platforms hindering their growth: Adverse selection i.e low quality borrowers which further leads to defaults and losses.\ \ Common argument is the best borrowers go to TradFi lenders and the worst left come to DeFi because they can't get loans from TradFi lenders. While, that's the true for few cases. There are a lot of high quality institutional borrowers, willing to borrow from DeFi. It's already evident with significant active laons on tokenized private credit platforms. Lot of traditional borrowers in with TradFi lenders on their books, still they want capital from DeFi. Because, it enables access to new capital source and cheaper rates in some cases. \ \ **So, what's the real issue here? Adverse selection is an underwriting problem, which is two phased - data and incentives** 1\. **Lack of infra or willingness to capture complete info on borrowers financials and creditworthiness.** Moreover, most protocols only do due-diligence on asset originators and not the underlying financial risk, quality of the asset pool and risk correlation. Also, there isn’t active collateral/covenant monitoring post-loan. fintech lenders in Tradfi lend to same set of borrowers and have significantly low NPAs compared to DeFi cause they follow the best practices. 2\. **Underwriting is done by asset originators/pool delegates/credit committees with very little or no skin in the game,** having no incentive to select the best assets for lending pools. It's all crowdsourced capital that's being deployed in the lending pools. Also, the Underwriting process is highly centralised and opaque creating the environment for "trust me bro" and vibe based borrower/asset selection rather than having a transparent, data driven process. This has improved a bit post the defaults recently, but still not the ideal state for the market to grow.
1. Improved credit underwriting/monitoring infra to avoid adverse selection(low quality loans) and credit defaults/losses. 2. Standardised and transparent risk assessment to make the products easier to understand for the broader investor base. 3. Qiro's underwriting infrastructure leverages a data-driven approach and distributed risk evaluation, ensuring transparent on-chain risk management.
# Glossary **Stablecoin Investors :** Investors providing capital into lending pools via various tranches based on risk appetite. Mostly investing in the senior tranche & protected by junior buffer.\ \ **Asset Originators :** Fintech lenders, NBFCs looking to finance securitised fintech loan portfolio by launching lending pools on the Qiro marketplace.\ \ **Credit Underwriters :** Fintech credit underwriters responsible for evaluating credit risk in the lending pools on Qiro marketplace. Investors in the junior tranche as well.
# Qiro Marketplace High level overview of Qiro Finance
Qiro is developing a decentralised private credit protocol with the capability to facilitate a wide range of tokenised private credit . This is achieved by unifying asset originators, stablecoin investors, and credit underwriters under a single framework. Our protocol supports two primary types of credit products: #### 1. **Term Loan Pools** Designed for fixed-tenure lending, Term Loan Pools follow a predictable repayment structure. These pools typically involve regular principal and interest repayments over time and may optionally support tranching. They are well-suited for straightforward lending arrangements with predefined cashflows.\ \ These pools will be focused on funding non-lending fintechs which are in payments, invoicing, real estate domain.\ \ Read more here: [Term Loans](/products/qiro-marketplace/term-loans) #### 2. **Securitisation Pools** Built for more dynamic, cashflow-based repayment scenarios, Securitisation Pools allow investors to participate in structured finance deals with multiple tranches (e.g., Senior and Junior). Instead of scheduled repayments, these pools distribute actual cashflows from the underlying assets based on predefined waterfall mechanisms. \ \ These pools will be focused on funding lending fintechs which are in invoice financing/discounting, trade finance, gold loans, consumer loans. \ \ Read more here: [Securitisation](/products/qiro-marketplace/securitisation) # Term Loans First RWA lending application on Qiro Protocol **Term Loan Pools** represent a straightforward lending structure where the borrower agrees to repay the loan over a fixed term. This product mirrors traditional loan agreements where repayment obligations are clearly defined in advance. In these pools, the loan is issued for a specific duration, and the repayment schedule — including when and how much is to be paid — is set upfront. The investor's cashflows are based on this schedule, providing **predictable and time-bound returns**. These are best suited for lending use cases with a clear repayment horizon and minimal variability in cash inflows, such as corporate working capital loans, invoice financing, or inventory-backed lending. **Key Features:** * **Fixed Repayment Structure**\ Borrowers repay over a defined period, and repayments can be structured in two formats: * **Bullet Repayment**: The borrower repays the entire principal in one go at the end of the loan term. Interest may be paid periodically or also at maturity. * **Amortised Repayment**: The principal is repaid in parts over time. The frequency (e.g., monthly, quarterly) and the start date of principal repayments can be configured at the pool level. * **Investor Simplicity**\ These pools are typically **uni-tranched**, meaning all investors share the same risk and return. Tranching can be enabled if needed but is not the default setup. * **Support for Real-Life Scenarios**\ The system automatically handles a variety of real-world events that may affect repayment and investor returns: * **Late Payments**: Tracked and included in the repayment flow. * **Prepayments**: Allows early principal repayments by the borrower. * **Write-Offs**: Supports partial or full write-offs in case of default. * **Recoveries**: Captures funds recovered post-default and allocates them fairly. # How does it work? 1. **Proposal Submission**\ Asset Originators submit loan proposals, including terms (loan amount, tenure, interest rate, repayment structure) along with credit data and details of real-world assets to be used as collateral. 2. **Credit Assessment**\ Underwriters review the credit data, assess default risk, and publish credit reports with recommendations, including approval status and suggested interest rates. 3. **Asset Tokenization**\ Upon approval, Asset Originators tokenize the underlying assets using Qiro’s tokenization platform. 4. **Pool Creation**\ The Asset Originator is onboarded, a lending pool is created with a defined tranche structure and interest terms, and the pool is launched for capital formation. 5. **Capital Formation**\ Investors contribute capital during the formation period. The pool proceeds only if the target capital requirement is met. 6. **Capital Disbursement**\ Once the pool target is fulfilled, Asset Originators can withdraw the funds for use as per the loan agreement. 7. **Repayments**\ Asset Originators repay principal and interest as per the agreed repayment schedule. 8. **Investor Redemption**\ Investors redeem their investments based on available pool liquidity or at pool maturity. # Repayments When a borrower takes a loan through a pool, the repayment schedule defines how and when they repay the principal and interest. Our platform supports a **Fixed Repayment Structure**, where repayment terms are agreed upfront and remain consistent through the life of the loan. There are two common formats: *** #### **1. Bullet Repayment** In a bullet structure, the borrower repays the **entire principal at the end of the loan term**. Interest can be paid either: * **Periodically** (e.g., monthly or quarterly), or * **Along with the principal** at the end of the term **Best suited for:** Short-term loans or situations where the borrower expects a lump-sum inflow later (e.g., invoice or trade receivables financing). **Example:** * $100,000 loan for 12 months at 12% annual interest * Interest paid quarterly → $3,000 every 3 months * Principal repaid in full ($100,000) at the end of 12 months *** # Amortisation With amortised repayments, the borrower **repays the principal in parts over the loan period**. Each repayment typically includes both interest and a portion of the principal. Key parameters: * **Repayment Frequency**: Monthly, quarterly, or as set at the pool level * **Principal Start Month**: Option to begin principal repayment after an initial interest-only period **Best suited for:** Loans where steady, predictable repayment over time is preferred. This flexibility allows borrowers to align their loan obligations with their business cash flows while giving investors predictable repayment visibility. # Late Fees Late fees are charged when a borrower misses a scheduled repayment. These fees serve as a penalty for delayed payments and are distributed **pro-rata to all investors**, since the capital at risk belongs to them. #### ⏱ When Are Late Fees Charged? 1. **Annualized Penalty**: Late fees are calculated using a yearly interest rate applied to the **overdue amount** (unpaid principal + unpaid interest). 2. **Daily Basis**: Fees accrue based on the **number of days** a payment is delayed, not by seconds or time of day. 3. **Per EMI**: Each delayed EMI is assessed independently — a late fee is calculated for every missed installment. 4. **After Grace Period**: A grace period may be defined per loan. Late fees apply **only after this period ends**. 5. **Charged Upfront on Repayment**: The late fee amount is **collected along with the delayed payment**, at the time the borrower clears their dues. *** ### 📘 How Late Fees Are Calculated #### 🔢 Key Terms * **`late_fee_apr`** – The annualized late fee interest rate.\ *Example: 4% late fee per year → `0.04`* * **`unpaid_amount`** – The portion of the installment that was not paid on time (Principal + Interest). * **`days_late_by`** – Number of days past due, **excluding any grace period**. *** #### ✅ Formula ``` late_fee = unpaid_amount × (late_fee_apr / 365) × days_late_by ``` This gives the penalty amount in currency terms, based on how many days the borrower is overdue. # End to End Flow **End-to End Financing Flow** 1. Asset originators originates the borrower assets 2. Shares the credit data and asset information with Qiro underwriters network 3. Underwriters evaluate the risk and give the decision, rejected if not passing the evaluation. 4. Asset Originator sets up a legal entity - a special purpose vehicle - for each pool. 5. Assets are tokenized and lending pool with senior & junior tranche is created using Qiro smart contracts 6. Senior and Junior Investors(underwriters & AOs) invest their capital in the lending pool 7. Capital is deployed to finance assets by the Asset Originators 8. Asset Originator repays the financings (Principal + Interest) 9. Repayments proceeds (Principal plus interest) are distributed to the Investors * Senior investors receive the principal + fixed rate as per deal terms * Junior investors receives remaining returns and takes potential losses 10. Pool is closed # Investor Funds Flow Following diagrams depict the detailed funds flow from the investors to Qiro lending pools, considering the case for fiat investors as well. \ \ 1\. Investors on ramp to crypto using an exchange or on/off ramp providers\ 2\. Upon receiving stablecoins in their wallet, they can invest in different tranches on Qiro marketplace\ 3\. That capital is pooled into lending pool contract and passed as a debt to borrower digital wallet.
**Invest in Tranches**
**Redeem/Withdraw funds from Tranches**
# Borrower Funds Flow Following diagrams depict the detailed funds flow from the borrowers to Qiro lending pools.\ \ **1. Investors on ramp to crypto using an exchange or on/off ramp providers**\ **2. Upon receiving stablecoins in their wallet, they can invest in different tranches on Qiro marketplace**\ **3. That capital is pooled into lending pool contract and passed as a debt to borrower digital wallet.**
# Securitisation **Securitisation Pools** are designed for pooling together a group of underlying loans or receivables and distributing the incoming cashflows from those assets to investors based on a tiered structure. Unlike Term Loan Pools, these do not follow a fixed repayment schedule. Instead, repayments to investors depend entirely on **actual collections** from the asset pool — including principal repayments, interest payments, early repayments, or recoveries from defaults. \ **Key Features:** * **Cashflow-Driven Repayments**\ Instead of following a fixed repayment schedule, repayments in these pools are made as cash is received — whether from interest, principal repayments, prepayments, or recoveries. This makes them suitable for portfolios where cashflows are variable or seasonal. * **Tranche-Based Investment Structure**\ These pools are always **multi-tranched**, starting with: * **Senior Tranche**: Receives repayments first and is more protected from losses. * **Junior Tranche**: Paid after senior obligations are met and absorbs losses first, offering potentially higher returns. * **Flexible Waterfall Distribution**\ The distribution of cashflows between tranches follows a predefined **waterfall mechanism**, which governs who gets paid, when, and how much: * **Sequential Waterfall**: All interest and principal payments go to the Senior tranche until it’s fully paid; only then does the Junior tranche start receiving distributions. * **Pro-Rata Waterfall**: Interest is shared proportionally between tranches, while principal is still prioritized to Senior first. This structure offers investors the ability to choose between **lower-risk, stable** returns (Senior) or **higher-risk, higher-reward** positions (Junior), depending on their risk appetite. # How does it work? 1. **Proposal Submission**\ Asset Originators submit loan proposals, including terms (loan amount, tenure, interest rate, repayment structure) along with credit data and details of real-world assets to be used as collateral. 2. **Credit Assessment**\ Underwriters review the credit data, assess default risk, and publish credit reports with recommendations, including approval status and suggested interest rates. 3. **Asset Tokenization**\ Upon approval, Asset Originators tokenize the underlying assets using Qiro’s tokenization platform. 4. **Pool Creation**\ The Asset Originator is onboarded, a lending pool is created with a defined tranche structure and interest terms, and the pool is launched for capital formation. 5. **Capital Formation**\ Investors contribute capital during the formation period. The pool proceeds only if the target capital requirement is met. 6. **Capital Disbursement**\ Once the pool target is fulfilled, Asset Originators can withdraw the funds for use as per the loan agreement. 7. **Repayments**\ Asset Originators repay principal and interest as per the agreed repayment schedule. 8. **Investor Redemption**\ Investors redeem their investments based on available pool liquidity or at pool maturity. # Tranching Every lending pool on Qiro Marketplace can be split into three tranches representing different risk and reward profiles. the industry standard is three tranche setup(senior, mezzanine, junior) representing low, high, medium risk/reward respectively. \ \ **1. Senior Tranche :** It's the lowest risk profiles whenever a repayment is made senior tranche receives it first and it has the lowest & fixed interest rate option. if the loan defaults, it will take losses at last offering maximum protection. Liquidity pool investors will be generally investing in this tranche. \ \ **2. Junior Tranche :** It's the highest risk profile it will receive the repayments at last after senior and mezzanine are paid. if loan defaults, it will take the first hit/loss. the interest rate for this tranche is variable and depends on the success of the loan. underwriters will be investing in this tranche. \ \ **3. Mezzanine Tranche :** It's medium risk profile it will have medium risk and rewards. whenever a repayment is made it will receive the payment after senior tranche and before junior tranche.
**Minimum Tranche ratio :** The underwriters based on the assessment of default and loss likelihood will propose a tranche structure to make sure senior is always protected in case of default and junior absorbs maximum loss due to default. \ \ \ Detailed info with example : [Interest Rates Calculation](/products/qiro-marketplace/securitisation/interest-rates-calculation)\
# Cashflow Waterfall In a securitised lending pool, investors are divided into different **tranches**, each with its own level of risk and return. When the borrower repays interest and principal, these cashflows must be distributed to the tranches in a predefined order.\ This predefined order is called the **cashflow waterfall**. A waterfall determines **who gets paid first**, **how much they receive**, and **when junior investors start receiving their share**. Because each tranche carries a different level of protection and priority, the design of the waterfall directly affects: * Investor risk * Expected yield * Speed of principal repayment * Protection against defaults Qiro supports two common waterfall structures for distributing repayments: * **Sequential Waterfall** — cashflows flow top-down, prioritising Senior investors before paying Junior investors. * **Pro-Rata Waterfall** — cashflows are shared proportionally between tranches, while still preserving seniority on overdue amounts and interest. These waterfall patterns form the core of how tranching works and define the economic relationship between Senior and Junior investors in a pool. # Sequential Waterfall ### **1. Sequential Structure** In a **Sequential** (or “waterfall”) structure, Senior investors are paid first. Junior investors receive repayments only after all Senior obligations are fully cleared. #### **How It Works** When the pool receives a repayment: **Interest Distribution** 1. Outstanding **Senior overdue interest** is paid first. 2. Then **current Senior interest** is paid. 3. Any remaining interest goes to the **Excess Interest Spread (EIS)**. 4. Only after the Senior tranche is fully repaid (no outstanding principal) does interest start flowing to Junior: * Junior overdue interest * Junior current interest **Principal Distribution** 1. All principal first repays: * Senior overdue principal * Senior current principal 2. After the Senior tranche is fully repaid, principal flows to: * Junior overdue principal * Junior current principal #### **In Simple Terms** * Senior investors get repaid first—both interest and principal. * Junior begins receiving principal only after Senior is completely paid down. * This structure provides **maximum protection** to Senior investors. # Pro-rata Waterfall ### **Pro-Rata Structure** In a **Pro-Rata** structure, both tranches share repayments more evenly. Senior still has priority on interest, but principal is allocated proportionally based on each tranche’s outstanding amount. #### **How It Works** When the pool receives a repayment: **Interest Distribution** 1. Senior overdue interest 2. Senior current interest 3. Junior overdue interest 4. Junior current interest 5. Remaining interest flows to EIS **Principal Distribution** * As long as the Senior tranche has outstanding principal, principal is shared **pro-rata** between Senior and Junior based on their remaining balances. * Once Senior is fully repaid, all principal flows to Junior. #### **In Simple Terms** * Interest still prioritises Senior first. * Principal is shared proportionally until the Senior tranche is paid off. * Junior receives principal earlier compared to Sequential, reducing their risk relative to that structure. # Interest Rates Calculation Based on the pool interest rate, interest rates for specific tranches will be determined. junior generally having high, variable interest and senior having fixed stable interest rate. (see example below)\ \ The pool interest rates calculation is dependent on several factors such as asset valuation(NAV), underlying asset risk profile, asset originator's credit worthiness, market conditions(benchmark interest rate), default probability, loss given default etc.
# Pool Lifecycle 1. **CapitalFormation** * The pool begins in this state. * If enough capital is raised → transition to **Pending**. * If the goal is not met → transition to **Revoked** (pool fails). 2. **Pending** * Waits for the borrower to draw down the loan. * On loan drawdown → move to **Active**. 3. **Active** * Loan is now issued. * As borrower begins repayment: * If only a portion is repaid → transition to **PartialRedeem**. * If fully repaid at once → transition directly to **Redeem**. 4. **PartialRedeem** * A portion of the repayment has been made. * Investors can redeem partially. * When full repayment is completed → move to **Redeem**. 5. **Redeem** * Loan is fully repaid. * Full redemption is now available for investors. * Once redemptions are finalized → transition to **Ended**. 6. **Ended** * Pool has concluded operations. * No further transitions. 7. **Revoked** * Terminal state if capital formation fails. * No borrowing or investor actions proceed.\ \
# Investor Protection **Bankruptcy Remote SPV:** Every lending pool on Qiro Marketplace has a separate SPV setup which protects the investors from bankruptcy **Over-collateralisation:** Based on underwriting, the asset originator are required to pledge additional portfolio as collateral to the [SPV](https://docs.qiro.fi/qiro-marketplace-product-guide/legal-structure). Typically, the LTV would be 60-70% for these fintechs. e.g $6M loan would required borrower to pledge $10M worth off-chain assets. **Cash Reserves**: We will also require the asset originators to deposit cash into reserves which can be utilised in case of missed repayments or default scenarios to make the investors whole. **Excess Interest Spread (EIS):** The spread between asset originators interest rate and what they pay to stablecoin investors on Qiro is the first buffer to cover defaults. e.g if the asset originator earns 15% on the loans, they will typically pay 10-12% to stablecoin investors on Qiro. **Junior Tranche Protection:** Every lending pool on Qiro will be have junior tranche where the underwriters will have to put capital to support their decision. This can also be filled jointly by underwriters + asset originator. Typically it’s \~20% of the whole pool.\ \ On top of this, we perform rigorous credit underwriting before approving the loan and have integration into asset originator's platform to track different information covenants(bank balance, financials, NPAs, profits, losses etc) which can trigger event of default if the agreed covenants thresholds are breached.
# Use-cases What kind of use-cases can be built on Qiro Marketplace #### **1. Payment Financing** **Payment Financing** helps businesses manage upfront payments to vendors or suppliers while deferring actual cash outflows. This is especially useful in supply chains or marketplaces where buyers need working capital flexibility without disrupting trade. * **How it works**: The financier pays the supplier on behalf of the buyer, and the buyer repays the financier later under agreed terms. * **Use case examples**: B2B marketplaces, distributor-dealer models, embedded checkout credit. * **Structure**: Typically done via **Term Loan Pools** with a short-tenure bullet or amortised repayment. #### **2. Trade Receivables Financing** **Trade Receivables Financing** allows sellers to unlock the value of their unpaid invoices before the payment due date. It improves liquidity and working capital efficiency for businesses with long receivable cycles. * **How it works**: A lender advances capital to a business based on its outstanding invoices (receivables), which are repaid when the buyer settles the invoice. * **Use case examples**: FMCG distributors, export receivables, SaaS subscription invoices. * **Structure**: Can be structured as either **Term Loan** or **Securitisation Pools** depending on scale and recurrence. #### **3. DePIN Financing** *(Decentralised Physical Infrastructure Networks)* **DePIN Financing** supports the development of real-world infrastructure networks (such as mobility, telecom, energy) by financing hardware or asset deployment, often in community-led or decentralized frameworks. * **How it works**: Operators or users are financed for purchasing and deploying infrastructure, which then generates yield (e.g., fees or tokens), used to repay the loan. * **Use case examples**: EV charging stations, shared mobility assets, IoT networks. * **Structure**: Typically **Term Loan Pools** with structured repayments based on usage/revenue models. Can evolve into **Securitisation Pools** as portfolios scale. #### **4. Corporate Credit Financing** **Corporate Credit Financing** refers to direct loans to businesses for working capital, capex, or operational requirements. These loans are tailored to a company’s cashflow and risk profile. * **How it works**: Businesses borrow a fixed amount under predefined terms and repay over time through scheduled installments or bullet repayments. * **Use case examples**: SME loans, inventory financing, growth capital. * **Structure**: Primarily through **Term Loan Pools**, but can be tranched if risk segmentation is needed. #### **5. Cross-Border Payment Financing** **Cross-Border Payment Financing** helps exporters, freelancers, and global businesses bridge the time gap between service delivery and final settlement from international clients. * **How it works**: Financing is provided against verified export invoices, contracts, or remittance pipelines, allowing immediate access to funds before international payment clearance. * **Use case examples**: SaaS exporters, IT services, global freelancers, merchant settlements. * **Structure**: Often suited for **Securitisation Pools**, especially when financing is provided against a portfolio of cross-border flows. # Qiro Underwriting Engine Qiro is building a distributed credit underwriting network that gathers structured credit data from various off-chain sources and connects it with a network of underwriting nodes. These nodes, hosted by credit underwriting experts, operate independently, running credit models and policies. \ \ The underwriting is performed in a verifiable compute environment, and the aggregated results are subsequently posted on-chain along with computation proof.
**Credit Data Sources:** Aggregated sources of Credit data from different avenues like audited financials, third party APIs and alternate data sources.\ \ **Distributed Credit Underwriting Network:** Distributed network of professional credit underwriters running their credit policies in a verifiable risk compute network.\ \ **Credit Policies:** Standard risk frameworks deployed by underwriters consisting of qualitative and quantitative parameters to evaluate the credit worthiness of a Asset Originator.\ \ We will be publishing detailed docs on the underlying architecture of credit underwriting network. # Underwriting network features Asset Originators in RWA backed loans are off-chain entities, there doesn't exist any connection between lending smart contracts and off-chain ledgers. By creating native credit infrastructure Qiro enables transparent risk management at protocol level.\ \ **Features of underwriting network** 1. Unbiased: Multiple underwriter nodes independently run risk models on borrower data enabling unbiased risk assessment. 2. Verifiable: Qiro’s underwriting happens in verifiable, data driven risk compute network. Currently using external compute providers, we’ll be shifting to own compute infra in V2 later this year. 3. Skin in the game: Underwriter take the first loss position aligning their rewards with loan success(repayments) 4. Reputation based system :- Every time an underwriter evaluate the loans they earn reputation points based on the overall loan performance which increase their ability to underwrite bigger loans in future. 5. Scalable: By having multiple underwriters Qiro can scale seamlessly to multiple borrower use-cases spanning different asset classes and geographies.
# Data Sources Different data sources for capturing relevant credit data about Asset Originators required for underwriting the loans. This generally includes asset originator's documents, softwares, services used by Asset Originators to manage the finances such as banking, ERP tools, accounting tools, CRM solutions. * **Loan Application :** Asset originators uploads relevant information & documents about the financials, revenue, tax returns, business performance metrics etc. * **Third Party Sources :** These are public sources which aggregate and provide credit information on a particular borrower. for e.g credit/debt bureaus, rating agencies, open banking APIs, tax portals, alternate data providers. * **Fintech SaaS Platforms** : Fintech Asset Originators use SaaS solutions for managing transaction data(sales, revenue etc), financials and credit risk those can be plugged in for fetching latest data. # Who can become underwriter? 1. Individual underwriters working at lending organisations. 2. Institutional lending organisations. 3. Credit analysts Every underwriter will be selected based on the track record, experience and speciality. We are bootstrapping the network with few experienced underwriters in Qiro's network. # Underwriting Report All underwriting nodes will have authenticated access to all the asset originator's data and will produce multiple variable regarding risk of the asset passing it to lender contracts. \ \ 1\. Probability of Default :- Indication of probability that a loan will default, this will help the protocol to choose high quality loans. \ 2\. Maximum loss given default :- Amount of loss protocol will take if the loan defaults.\ 3\. Tranches structure :- Depending on the above two parameters model will suggest a tranches structure.\ 4\. Interest rate :- Provide interest rate for different tranches based on the risk factors. \ \ **Note: These parameters are initial set of info which is essential for loan decision, there could be some additional parameters based on the asset type and protocol requirements.** # Qiro Underwriting Explorer The **Qiro Underwriting Explorer** provides full transparency into how credit assets are evaluated on the Qiro Network. It allows investors, pool admins, underwriters, and partners to view underwriting activity that is cryptographically verified and anchored on-chain. Link to explorer: ; ### **Overview of Sections** The Explorer contains three primary sections: ### **1. Assets** This section lists all borrower assets submitted for underwriting. Each asset page includes: * Borrower and asset information (loan amount, tenure, purpose, etc.) * Current underwriting status (Pending, Underwritten, Approved, Rejected) * Linked on-chain asset ID (tokenized asset NFT) * All underwriting assessments submitted by underwriter nodes This provides a clear, transparent overview of the underlying loan quality for each lending pool. ### **2. Underwriter Nodes** This page displays all active underwriter nodes participating in the Qiro underwriting network. Each node profile includes: * Node identity and metadata * Number of assets underwritten * Total value underwritten * Historical inferences submitted * Performance and participation metrics Underwriter nodes operate independently, enabling decentralized and market-driven risk evaluation. ### **3. Inferences** An inference represents an underwriting assessment submitted by a node. Each inference includes: * The underwriting outcome (risk metrics, limit, rate, or score depending on the model used) * The underwriter node that submitted the inference * The asset evaluated * Timestamped on-chain reference * A cryptographic proof validating the correctness of the computation This creates an auditable and transparent record of all underwriting decisions. ### **Underwriting Proof Verification** Qiro uses Zero-Knowledge (ZK) attestations to ensure that every underwriting result is: * Correctly computed * Tamper-proof * Verifiable on-chain * Privacy-preserving (no raw borrower data is exposed) Each inference contains: * A proof stored on Arweave * A corresponding on-chain transaction hash * (Upcoming) In-browser proof verification for anyone to independently verify correctness This architecture guarantees integrity without compromising sensitive borrower information. # For Investors Invest in Qiro Lending Pools Qiro enables investors to deploy capital into on-chain private credit strategies backed by real-world cash flows. \ \ Through Qiro, investors can: #### Invest in Credit Pools Access curated credit pools that originate and manage exposure to private credit assets such as receivables, payment flows, and short-duration lending strategies. Each pool has defined terms, risk parameters, and return profiles. #### Review Deal & Pool Details Before investing, investors can review: * Pool strategy and asset type * Underlying borrower profiles * Target returns and fee structure * Pool lifecycle and liquidity terms * Risk and underwriting summaries All key information is presented in a standardized format. #### Track Performance & NAV Monitor investments through: * Pool-level NAV updates * Accrued interest and cash flow reporting * Portfolio allocation and exposure * Historical performance data #### Earn Yield from Real Cash Flows Returns are generated from repayments and collections on underlying assets, not token incentives or emissions. #### Redeem According to Pool Terms Capital can be redeemed based on the pool’s defined redemption mechanics and liquidity windows.
# How to Invest? Investing in lending pools on Qiro is simple and secure. Follow these steps to get started:
1. **Connect Your Wallet**\ Use your crypto wallet (e.g., MetaMask) to connect to the Qiro Lending Marketplace. 2. **Verify Identity & Investor Status**\ Complete a one-time identity check (KYC) and investor accreditation. This unlocks full access to all lending pools and is required before you can invest. 3. **Browse and Select a Lending Pool**\ Explore available lending opportunities and choose a pool that matches your investment goals. 4. **Choose a Tranche**\ Select a tranche (e.g., Senior or Junior) based on your preferred risk-return profile. 5. **Enter Investment Amount**\ Specify the amount you want to invest, denominated in **USDC**. 6. **Sign Tranche Token Subscription Documents**\ Review and digitally sign the subscription agreement for regulatory and contractual purposes. 7. **Click "Invest"**\ Confirm the transaction in your wallet to complete the investment. # Investor Onboarding To invest in lending pools on the Qiro Marketplace, investors must complete a simple but essential onboarding process. The steps vary slightly for individuals and entities (institutions), ensuring compliance and security for all users. For Institutions (Entity) Onboarding Details : [Institution](/qiro-marketplace-product-guide/for-investors/investor-onboarding/institution) For Individual Onboarding Details: [Individual](/qiro-marketplace-product-guide/for-investors/investor-onboarding/individual) # Institution ## **Entity Investor Onboarding** Entity investors (funds, institutions, DAOs, and corporate structures) must complete a KYB-compliant onboarding process to verify the organisation and its authorised representatives. *** ### **1. Basic Information** Begin by selecting your entity type and providing the required business details. #### **Type of Entity** Choose the category that best describes your organisation: * Credit Fund * Family Office * Liquid Fund * DAO Treasury\ (Additional types may be supported) #### **Entity Information** Provide details about the legal entity: * **Legal Entity Name** * **Structure Type**\ Examples: LLC, SPV, Holding Company, Subsidiary, Fund, Foundation #### **Qualification Status** Select the appropriate status: * Qualified * Accredited #### **Investment Interest** Select your expected investment size band from the four available options. *** ### **2. Business Verification (KYB)** Entity onboarding includes company verification, ownership checks, and compliance screening. #### **1. Business Information Verification** Upload company documents such as: * Certificate of incorporation or registration * Formation documents * Operating or partnership agreements (where applicable) #### **2. Ultimate Beneficial Owner (UBO) Verification** Identify and verify all individuals who hold significant ownership or control over the business. #### **3. Authorised Signer Verification** The individual who will operate the account on behalf of the entity must complete identity verification. #### **4. Tax Information** Provide required tax forms or declarations based on jurisdiction. #### **5. Accreditation Verification (US Entities Only)** US-based entities must provide: * Accreditation documents, or * Verification through an approved third party *** ### **3. Add Wallet** Finally, link a **valid Ethereum wallet** owned by the entity.\ This wallet will be used for: * Funding investments * Receiving cashflow distributions * Holding tokenised securities or pool tokens Once the wallet is added and all checks are completed, the entity is fully onboarded and ready to invest. #### 🇺🇸 **U.S. Investor Accreditation Requirements** U.S.-based investors (individuals or entities) must meet SEC guidelines for accredited investors. You may: * Upload financial documents (income or net worth evidence), **OR** * Use an integrated **third-party verification provider** for faster review. # Individual ## **Individual Investor Onboarding** Individual investors must complete a simple 3-step onboarding flow before they can invest in lending pools on the Qiro Marketplace. This process ensures regulatory compliance and helps us determine investor eligibility. *** ### **1. Basic Information** You will begin by submitting your personal and investment details: * **Legal First Name** * **Legal Last Name** * **Investment Interest** (choose from four investment size bands) * **Accreditation Status** (Yes/No) This information helps Qiro determine your investor profile and tailor eligibility requirements. *** ### **2. Identity Verification (KYC)** To comply with global KYC/AML regulations, individuals must complete a three-step identity verification process: #### **1. Identity Verification** Confirming your identity and personal details. #### **2. Document Verification** Upload one of the supported identity documents: * **Passport** * **National Identity Card** A **liveness check** is also required to ensure the document belongs to you. #### **3. Accreditation Verification (US Investors Only)** If you are a US-based investor: * Upload accreditation documents, or * Use approved third-party accreditation verification *** ### **3. Add Wallet** To complete onboarding, link a **valid Ethereum wallet**.\ This wallet will be used for: * Investing into lending pools * Receiving interest, principal repayments, and redemptions * Holding tokenised pool tokens Once your wallet is connected, onboarding is complete and you can start investing on the Qiro Marketplace. #### 🇺🇸 **U.S. Investor Accreditation Requirements** U.S.-based investors (individuals or entities) must meet SEC guidelines for accredited investors. You may: * Upload financial documents (income or net worth evidence), **OR** * Use an integrated **third-party verification provider** for faster review. # Pool Onboarding As part of joining a lending pool, investors are required to review and sign the **Tranche Token Subscription Documents**. These documents confirm your participation in a specific tranche and outline the key terms of your investment. #### **What’s Included** * **Your Tranche & Allocation** — The tranche you’re subscribing to (Senior/Junior) and your committed amount. * **Risks & Repayment Priority** — How cashflows are distributed across tranches and the level of protection your tranche receives. * **Tokenized Representation** — Confirmation that your investment will be issued as on-chain **Tranche Tokens** and held in your connected wallet. * **Compliance & Declarations** — Standard regulatory and eligibility confirmations required for participating in private credit products. #### **Why It’s Required** Signing the Subscription Documents finalizes your pool onboarding, ensures compliance, and allows the pool admin to mint the corresponding tranche tokens to your wallet. Without completing this step, you cannot invest in or receive distributions from the pool. # Investor Portfolio The **Investor Portfolio** provides a consolidated overview of an investor’s performance and activity across all lending pools on the Qiro Marketplace. It includes high-level KPIs, detailed allocations, portfolio insights, and a complete transaction history. *** ### **1. Key Portfolio Metrics (KPIs)** These indicators give investors a quick snapshot of their overall portfolio health. | **Metric** | **Description** | | ---------------------------- | -------------------------------------------------------------------------------------- | | **Total Portfolio Value** | The current value of all active investments across pools. | | **Available for Withdrawal** | The amount of repaid funds that can be withdrawn immediately. | | **Average APY** | The weighted average yield across all active tranches. | | **Expected Returns** | The projected returns from active investments based on tranche APY and remaining term. | *** ### **2. Allocations** Shows all positions held by the investor across different lending pools. | **Field** | **Description** | | ------------------- | ------------------------------------------------------------------ | | **Pool Name** | The lending pool the investor is invested in. | | **Tranche** | The selected tranche (e.g., Senior or Junior). | | **Interest Rate** | Fixed APY associated with the tranche. | | **Invested Amount** | Total capital invested in that tranche. | | **Status** | Current state of the investment (Active, Redeemed, Matured, etc.). | | **Network** | The blockchain network where the investment is recorded. | This section helps investors understand where their capital is allocated and its performance. *** ### **3. Charts & Insights** Interactive visuals provide a deeper understanding of portfolio performance. * **Portfolio Value Over Time**\ Track historical performance using daily, weekly, and yearly filters. * **Portfolio Distribution**\ Visual breakdown of allocations across pools and tranches. These charts help investors evaluate diversification and returns. *** ### **4. Transactions** A complete record of all investment-related activities. #### **Features** * **Search by Pool Name** — Quickly filter transactions. * **Pagination Controls** — Rows per page and next/previous navigation. * **Transaction Table** — Detailed list of deposits, redemptions, payouts, and other transfers with timestamps. This ensures full transparency across all fund movements. # Tranche Tokens Most of pools on Qiro marketplace will have tranching where it will split into senior/junior tranche. To keep track of the investors we use tranche tokens. Every time investors put capital in a particular tranche, they receive tranche tokens pro-rate to their investment. These tokens represent share of the investors in the pool and can be redeemed to receive the share from the pool. \ \ There will be two kind of tranche tokens on Qiro marketplace. \ \ **Senior Tranche Token:** These tokens holders will receive the pool cashflows in second priority after Senior tranche token holders. This token holders receive a fixed interest rate. **Junior Tranche Token:** These tokens holders are mostly underwriters, and will receive the pool cashflows in second priority after Senior tranche token holders. This token holders receive a variable interest rate. \ \ These tokens are non-transferable to maintain the KYC restrictions, we foresee secondary markets in coming time when we would allow transfers to other KYCed investors.
# Redemptions Investors can redeem their tranche tokens on the lending pools to received their prinicipal + interest back from the pool. This can be at the maturity of the lending pool or early redemptions can be allowed in between the tenure of the pool depending on the structure of the pool and available liquidity in the pool. \ \ Investors will receive the capital based on their redemption rate which is function of the pool performance and their redemption history. \ \ To learn more about redemption rate calculation: # Pricing Calculations When investors redeem their tranche tokens, the amount of currency they receive depends on how much of the pool’s repayments have been collected and the investor’s share of the tranche. Qiro uses a transparent, formula-based approach to ensure fair and pro-rata redemption for all investors. Below is an overview of the key variables used in the redemption price calculation. #### **Key Variables** | **Variable** | **Description** | | --------------------------- | -------------------------------------------------------------------------------- | | **TrancheValue** | Total expected value of the tranche (Principal + Expected Interest – Write-offs) | | **TotalRepaid** | Total repayments collected so far for the tranche (Principal + Interest) | | **TokenReceived\[User]** | Number of tranche tokens minted to the user | | **TokenRedeemed\[User]** | Tokens already redeemed by the user | | **CurrencyRedeemed\[User]** | Currency already paid out to the user | | **UserShare** | User’s share of the tranche = TokenReceived / TotalTokens | | **TokenAmount** | Tokens the user wants to redeem (input) | ## **How Redemption Price Is Calculated?** Before processing a redemption, the system determines two things: 1. **How many tokens the user is allowed to redeem**, based on their ownership and repayments collected. 2. **How much currency those tokens are worth**. The process follows three steps: #### **1. Maximum Tokens the User Can Redeem** This ensures users cannot redeem more than their share of the tranche’s repaid amount. ``` MaxRedeemToken = ((TotalRepaid / TrancheValue) * TokenReceived[User]) – TokenRedeemed[User] ``` #### **2. Maximum Currency the User Can Receive** This represents the user’s pro-rata share of all repayments collected so far. ``` MaxRedeemCurrency = (TotalRepaid * Share[User]) – CurrencyRedeemed[User] ``` #### **3. Token Price at Redemption** The redemption price floats based on how much has been repaid. ``` TokenPrice = MaxRedeemCurrency / MaxRedeemToken ``` *** ## **What This Means for Investors** * The token price **increases as more of the tranche is repaid**. * Redemptions are **fair and proportional**, based on actual repayments—not NAV estimates. * Investors receive exactly their share of the collected repayments, even if they redeem at different times. # Investor Protection Buffer Mechanisms for default protection **Bankruptcy Remote SPV:** Every lending pool on Qiro Marketplace has a separate SPV setup which protects the investors from bankruptcy **Over-collateralisation:** Based on underwriting, the asset originator are required to pledge additional portfolio as collateral to the [SPV](https://docs.qiro.fi/qiro-marketplace-product-guide/legal-structure). Typically, the LTV would be 60-70% for these fintechs. e.g $6M loan would required borrower to pledge $10M worth off-chain assets. **Cash Reserves**: We will also require the asset originators to deposit cash into reserves which can be utilised in case of missed repayments or default scenarios to make the investors whole. **Excess Interest Spread (EIS):** The spread between asset originators interest rate and what they pay to stablecoin investors on Qiro is the first buffer to cover defaults. e.g if the asset originator earns 15% on the loans, they will typically pay 10-12% to stablecoin investors on Qiro. **Junior Tranche Protection:** Every lending pool on Qiro will be have junior tranche where the underwriters will have to put capital to support their decision. This can also be filled jointly by underwriters + asset originator. Typically it’s \~20% of the whole pool.\ \ On top of this, we perform rigorous credit underwriting before approving the loan and have integration into asset originator's platform to track different information covenants(bank balance, financials, NPAs, profits, losses etc) which can trigger event of default if the agreed covenants thresholds are breached.
# In case of default What happens if the asset originator doesn't repay the loan? Whenever asset originator misses the repayment and even after the grace period (depending on the loans) there is no repayments it is detected as default. There would be on-chain and off-chain process to handle this default event.\ \ **On-chain process**\ \ Junior pool takes the loss :- while structuring the deal the junior tranche assumes the first loss. so based on the buffer if it's under the junior pool size, it would be taken completely by junior pool investors. \ \ As an effect, the size of junior pool buffer and interest rate will reduce depending on the size of default. Senior pool will stay unaffected until the buffer is in place. If the buffer is breached and junior pool goes to $0, then senior pool will start losing the rewards and principal depending on default amount. \ **Off-chain process** During the grace period as well as whenever a default is detected, investors communicate with the asset originator to identify the conditions leading to the default, remediate and agree to a repayment plan, and establish transparent solutions to move forward with future repayments. In case of unsuccessful remediation process, Lenders can pursue off-chain legal recourse via excess interest spread, over-collateralisation and assets custody provided by the Asset Originators to recoup losses. All pools on Qiro are fully over-collateralised with off-chain assets. \ \ After such actions or liquidations the proceeds will be paid to tranche token holders based on the tranche they are invested in. # For Borrowers Asset Originators can borrow capital from the lending pools on Qiro marketplace. AOs will pledge real world assets to avail on-chain financing. Based on the underwriting decision a lending pool would be created on the Qiro marketplace. \ \ **Interested to Borrow:** # Asset Tokenization Qiro's lending pools are backed by tokenised real world assets (RWAs). We are creating the platform for tokenization of assets based on different schemas. These assets are further used as collateral to draw capital from the lending pools on Qiro marketplace.\ \ Qiro's underwriting network is responsible for valuation, risk evaluation and credit scoring of these tokenized assets. Tokenization enables 100% transparency for investors in terms of the collateral backing the pool.\ \ Tokenized assets will have risk parameters attached to it, which will keep updating based on the monitoring of financial covenants. This enable proactive risk management on Qiro Marketplace. # Tokenized Asset Lifecycle ### Tokenized Asset Lifecycle Each asset on the platform goes through a set of stages. These help track where the asset is in its journey — from creation, to funding, to completion. Here's what each stage means: *** #### `Draft` The asset is being created. You can add or edit all the details here. It’s not yet submitted for approval. *** #### `MetadataValidated` All required financial details (like loan amount, tenure, and repayment terms) have been filled in correctly. The asset is now ready to be submitted for approval. *** #### `PendingApproval` The asset has been submitted and is waiting for approval from the relevant team. No changes can be made at this point. *** #### `Approved` The asset is approved and ready to be tokenized. It can now be added to a pool or prepared for funding. *** #### `Minted` An NFT (token) has been created to represent the asset on-chain. This makes it compatible with smart contracts and pools. *** #### `Underwritten` The asset has been underwritten — meaning a party (usually the originator) has committed to it or taken initial risk. This may be required before it joins a pool. *** #### `Locked` The asset is now locked into a pool. It starts generating repayments, and the capital is active. *** #### `Unlockable` The loan is fully repaid or has reached the end of its term. The asset is now eligible to be unlocked. *** #### `Unlocked` The asset is released from the pool. Any final actions (like fund returns or asset transfers) can be completed. # How to Borrow **Step 1:** Asset Originators need to propose the loan terms with the loan conditions (loan amount, repayments, term, interest rates etc) with credit data about the real world assets to be used as a collateral for the loan. \ **Step 2:** Underwriters network access the credit data and publish the reports indicating the credit default risks, approval, interest rates etc. If they are approved, following steps would happen\ **Step 3:** Asset Originators tokenize their assets on Qiro's [tokenization](/qiro-marketplace-product-guide/for-borrowers/asset-tokenization) platform. \ **Step 4:** Asset Originators would be onboarded and a lending pool would be created with tranching structure, interest rate decided and the pool will go live for capital infusion from investors.\ **Step 5:** Once the pool is fulfilled, Borrower can withdraw the capital from the pool. \ **Step 6:** Asset Originators will repay principal + interest amount as per the schedule. \
# Repayments After successful borrowing, Asset Originators are required to repay the loan based on the repayment frequency and interest rate. different repayment models(bullet, amortisation) and fee structures (grace period, late fee) are possible for every pool listed on Qiro marketplace. Repayments depend on the lending pool structure, we currently support 2 repayments patterns for Loan Product: Bullet and Amortisation. \ \ Once received in the lending pool, the repayments are distributed to investors in the lending pools.
# Investor Reporting Borrowers on Qiro can upload periodic reports directly into their lending pool. These reports provide full transparency into the performance of the underlying loan and help both pool admins and investors stay informed throughout the lifecycle of the asset. *** ### **What Borrowers Can Upload** Borrowers may upload a range of report types, including: * **Financial Reports**\ Monthly or quarterly financial statements, revenue breakdowns, P\&L, cash flow, balance sheets. * **Operational Updates**\ Business performance metrics, utilization of funds, borrower KPIs, collateral updates. * **Repayment & Covenant Updates**\ Repayment schedules, covenant compliance status, changes to business conditions. * **Supporting Documents**\ Audit reports, bank statements, certifications, or any required disclosures. *** ### **Who Can See These Reports** Once uploaded: * Reports become **instantly visible to all investors** in the pool * Reports are also visible to **pool admins** for monitoring and compliance * No additional approval is required for visibility (unless you want to add that flow) This ensures a transparent, consistent flow of information to everyone participating in the pool. # Who can borrow? 1. **Lending Fintechs:** Fintech platforms that **focus on offering credit products** directly or in partnership with financial institutions. These include solutions like **invoice financing, supply chain financing, SME lending, BNPL (Buy Now Pay Later), embedded lending, and working capital loans**. They often leverage data and technology to underwrite, disburse, and manage credit more efficiently.
2. **Non-Lending Fintechs:** Fintech platforms that offer financial services other than lending. These can include **payment processing, expense management, payroll solutions, neobanking, wealth tech, and financial infrastructure tools**. While they don’t directly extend credit, many work with financial institutions or lenders to enable embedded financial services within their platforms.
3. **Private Credit Funds:** Investment vehicles that specialize in providing **non-bank debt financing** to businesses. These funds invest in **private debt instruments** such as term loans, structured credit, or asset-backed financing. Unlike traditional lenders, private credit funds often target higher-yield opportunities and operate with more flexible terms, catering to mid-sized or underserved borrowers. # For Pool Admins Pool Admins are responsible for creating, operating, and maintaining lending pools on the Qiro Marketplace. During the initial phase, all pools will be administered by the Qiro team. Over time, the platform will open up to external pool admins who can launch and manage their own pools on Qiro. Each lending pool has dedicated Pool Admins who handle the full lifecycle of the pool, including: * **Creating and configuring new lending pools**\ Setting up pool parameters, borrower details, capital formation rules, and operational settings. * **Managing investor access controls**\ Whitelisting and blacklisting investors to ensure only eligible participants can interact with the pool. * **Approving tokenized assets from borrowers**\ Reviewing and authorizing the minting of borrower-issued tokenized assets tied to the pool. * **Approving underwriting for borrower assets**\ Verifying that the borrower’s assets meet Qiro’s underwriting and risk standards before activation. * **Uploading and publishing investor reports**\ Providing periodic performance updates, NAV summaries, and cashflow reports to pool investors. * **Reporting defaults and write-offs**\ Recording credit events such as missed payments, partial losses, or full write-offs that impact pool performance. This framework ensures a transparent, compliant, and well-governed environment for both borrowers and investors across the Qiro ecosystem. # Tokenization Approvals #### **Minting Approvals for Borrowers** Allows the Pool Admin to authorize a borrower to mint the tokenized asset (e.g., pool notes, tranche tokens, deal tokens).\ This approval is required before any minting transaction can occur and confirms that all compliance checks, documentation, and operational prerequisites have been satisfied.\ Once approved, the borrower can proceed to mint the asset that will be offered to investors. #### **Underwriting Approvals for Borrowers** Enables the Pool Admin to approve the borrower’s underwriting status based on credit evaluation, risk assessment, and internal scoring models.\ This action ensures the borrower’s deal structure meets the platform’s underwriting standards.\ Only after this approval can the deal move forward to the minting stage or investor onboarding. # Launch a Pool Pool Admins can create new lending pools on Qiro Marketplace with following steps 1. Enter Basic Information on the Borrower. 2. Enter Pool Information in terms of underlying asset, principal, interest rate and fees. 3. Enter Repayment Details 4. Enter Tranche Details including interest rate 5. Select Network and Borrower Address 6. Review Pool Details 7. Deploy lending pool on-chain. # Manage Pool #### **Whitelist / Blacklist Investors** Allows the admin to control which wallet addresses can participate in the pool. * **Whitelist:** Grants an investor permission to deposit, purchase pool tokens, or otherwise interact with the pool. * **Blacklist:** Revokes an investor’s access, preventing further deposits or interactions. Existing holdings remain but future transactions are blocked. #### **Activate Borrow** Enables the borrower to draw down funds from the pool once all capital-formation requirements (e.g., minimum raise, documentation, approvals) are met.\ This updates the pool status to *Active* and makes liquidity available for disbursement according to the loan agreement. #### **Report Write-off** Used to record a permanent loss on part or all of the outstanding principal.\ Once a write-off is reported, the corresponding amount is removed from expected receivables and reflected in the NAV, investor entitlements, and loss-allocation logic. #### **Repay from Reserve** Allows the admin to make a repayment to the pool using the reserve or coverage account instead of borrower cashflows.\ Typically used in cases of delayed payments, shortfalls, or structured protection mechanisms (e.g., junior tranche or FLDG-like reserves). #### **Update Pool State** Changes the operational state of the pool (e.g., Capital Formation → Active → Redeem → Closed/Revoked).\ This function is used to progress the pool through its lifecycle based on funding status, repayment completion, compliance events, or administrative actions. # Investor Reporting #### **Generate Investor Reports** Allows the Pool Admin to compile and publish the latest reporting data for all investors, including NAV updates, cashflows, allocations, and position summaries.\ This function triggers the creation of a new reporting cycle (e.g., monthly or quarterly) and makes the report available in the investor dashboard. #### **Update Reporting Data** Lets the Pool Admin update the underlying performance and financial data used for investor reporting — such as principal repayments, interest accruals, losses, reserves, and expenses.\ These updates ensure that the next reporting cycle reflects the correct and complete financial state of the pool. #### **Publish Reports** After generating and verifying the report, the Pool Admin can publish it, making it visible to all investors.\ This action locks the reporting data for that cycle, ensuring consistency and preventing retroactive changes. # Who can become Pool Admin? 1. Curators 2. Underwriters 3. Fintech Lenders\
Interested in becoming a pool admin, please fill this form: # Legal Structure **SPVs** - Borrowers are required to create a SPV to pledge the assets for availing the loan, the SPV holds the legal recourse in case of default. The SPV creates a legal agreement with Borrowers. \ \ Every lending pool on Qiro marketplace has a legal entity tied to it i.e SPV or Special purpose vehicle. \ \ **What is SPV ?**\ A Special Purpose Vehicle (SPV) is an independent legal entity. It has its own assets and liabilities, as well as its own legal status. Usually, SPVs are created for a specific objective, often to isolate financial risk. As an SPV is a separate legal entity, it carries even if its parent company goes bankrupt. # Underwriting Process Qiro underwriting is powered by a decentralised network of underwriters who independently run data driven models on borrower credit data to generate underwriting report. Every node operator will have a credit policy deployed to evaluate the borrower. This process enables transparent, strong and fair underwriting framework for Qiro protocol. \ \ Interested to become an underwriter: # Fees Fee component on Qiro Marketplace | Fees | Paid by | Percentage | Comments | | -------------------- | ------------ | ----------------------------------------------------------- | ------------------------------------------------------------------------------------------------- | | **Origination Fees** | **Borrower** | 1-1.5% of principal |

Can be taken from principal or borrower can pay

Should be paid before borrowing

| | **Performance Fees** | **Investor** | 10% of interest | (taken from interest repayments) | | **Servicer Fees** | Borrower | Fixed Amount determined at the time of creation of the pool |

Paid by Originator/Admin

Applicable to Securitisation only.

| | Late Fees | Borrower | Configurable | Paid by the borrower on the late repayments | # Public Testnet Guide (Plume) This is a guide for Qiro Marketplace Testnet To participate in the Qiro Marketplace Public Testnet, you have to visit our app at: [https://testnet.qiro.fi]() \ \ **Invest** 1. Connect wallet (any EVM wallet should work), if not installed get one [here](https://metamask.io/) 2. Select one of the lending pools 3. Click on Faucet to get test tokens and gas for transactions 4. Enter the amount and Click on "Invest" 5. You will receive the tranche tokens in your wallet on successful transaction. **Note: There will be a lockup period for your position based on the loan tenure, it can be only redeemed after that.** **Redeem** 1. Connect wallet (any EVM wallet should work), if not installed get one [here](https://metamask.io/) 2. Select your lending pool 3. Click on Redeem 4. Enter the Amount and Click on "Redeem" 5. You will receive your deposit + interest in your wallet # Public Testnet Guide (Aptos) This is a guide for Qiro Marketplace Testnet To participate in the Qiro Marketplace Public Testnet, you have to visit our app at: [https://testnet.qiro.fi]() \ \ **Invest** 1. Connect wallet (any Aptos wallet should work), if not installed get one [here](https://petra.app/) or [here](https://chromewebstore.google.com/detail/martian-aptos-sui-wallet/efbglgofoippbgcjepnhiblaibcnclgk) 2. Select one of the lending pools on Aptos Testnet 3. Click on Faucet to get test tokens and gas for transactions 4. Enter the amount and Click on "Invest" 5. You will receive the tranche tokens in your wallet on successful transaction. **Note: There will be a lockup period for your position based on the loan tenure, it can be only redeemed after that.** **Redeem** 1. Connect wallet (any Aptos wallet should work), if not installed get one [here](https://petra.app/) or [here](https://chromewebstore.google.com/detail/martian-aptos-sui-wallet/efbglgofoippbgcjepnhiblaibcnclgk) 2. Select your lending pool on Aptos Testnet 3. Click on Redeem 4. Enter the Amount and Click on "Redeem" 5. You will receive your deposit + interest in your wallet # Public Testnet Guide (Polygon) This is a guide for Qiro Marketplace Testnet To participate in the Qiro Marketplace Public Testnet, you have to visit our app at: [https://testnet.qiro.fi]() \ \ **Invest** 1. Connect wallet (any EVM wallet should work), not installed get one [here](https://metamask.io/) 2. Select Polygon Amoy Chain 3. Select one of the lending pools 4. Click on Faucet to get test tokens and gas for transactions 5. Enter the amount and Click on "Invest" 6. You will receive the tranche tokens in your wallet on successful transaction. **Note: There will be a lockup period for your position based on the loan tenure, it can be only redeemed after that.** **Redeem** 1. Connect wallet (any EVM wallet should work), if not installed get one [here](https://metamask.io/) 2. Select Polygon Amoy Chain 3. Select your lending pool 4. Click on Redeem 5. Enter the Amount and Click on "Redeem" 6. You will receive your deposit + interest in your wallet # FAQs Coming soon! # Privacy Policy Qiro ("we," "our," "us") is committed to protecting the privacy of our investors, borrowers, partners, and platform users. This Privacy Policy explains how we collect, use, store, and share information when you interact with our services, including the Qiro platform ([qiro.fi](https://qiro.fi/)), our smart contracts, wallets, and related financial services supporting tokenized credit investments. By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein. ### 1. Information We May Collect We may collect the following categories of information: #### 1.1 Personal Information Provided by Investors and Borrowers * Full name, date of birth, nationality, and identification documents (passport, ID card, driver's license) * Contact details (email address, phone number, residential address) * Financial and professional information required for KYC/AML checks * Accredited/qualified investor certifications (where applicable) #### 1.2 Wallet and Transaction Data * Blockchain wallet addresses used for investments and repayments * Details of subscriptions, token holdings, disbursements, and repayment transactions * Smart contract interactions (Investor contract, Borrower contract, Distributor contract, SPV wallets) #### 1.3 Institutional and Borrower Data * Legal entity details, incorporation certificates, beneficial ownership disclosures * Loan origination and asset performance data * Collateral and receivable information provided under Security Agreements #### 1.4 Platform and Technical Data * IP addresses, device identifiers, and browser information * Usage data from the Qiro platform and dashboards * Cookies and similar technologies (if applicable) ### 2. How We Use Information Qiro Platform uses the collected information for the following purposes: * Regulatory Compliance: To perform AML/KYC checks and comply with applicable laws * Fund Flow Execution: To process subscriptions, issue tokens, disburse loans, and route repayments * Risk Management: To verify borrower eligibility, enforce security pledges, and manage investor protections * Platform Operations: To provide dashboards, investor reporting, and marketplace services * Security: To prevent fraud, unauthorized transactions, and malicious activities * Communications: To provide investors and borrowers with reports, notices, and disclosures ### 3. Legal Basis for Processing We process personal data on the following bases: * Consent: Where you have given explicit consent * Contractual Necessity: To perform obligations under the Subscription Agreement, Loan Agreement, or related contracts * Legal Obligations: To comply with AML, KYC, tax, and regulatory requirements * Legitimate Interests: To safeguard platform integrity, investor protections, and operational efficiency ### 4. Cross-Border Data Transfers and Third Party Services We may share your personal information with carefully selected third-party service providers to help us operate, provide, and improve our services. These third parties may include: * Identity verification and compliance providers for Know-Your-Customer (KYC) and Anti-Money Laundering (AML) obligations * Cloud hosting, storage, and IT providers to securely manage data * Payment processors, custodians, and banking partners to facilitate transactions * Analytics, fraud prevention, and security services to maintain the integrity of our platform We require all third parties to process your information in accordance with applicable data protection laws and our instructions. They are prohibited from using your information for their own purposes. Because we operate internationally, your personal information may be transferred to and processed in jurisdictions outside of your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. Where such cross-border transfers occur, we implement appropriate safeguards to protect your personal information, including: * Standard Contractual Clauses (SCCs) approved under the General Data Protection Regulation (GDPR) * Binding contractual obligations requiring recipients to safeguard personal data * Technical and organizational measures such as encryption and restricted access For residents of the European Economic Area (EEA), United Kingdom, or Switzerland, we will only transfer your personal data to jurisdictions recognized as providing adequate protection or subject to legally valid transfer mechanisms. For residents of California, we comply with the California Consumer Privacy Act (CCPA), ensuring you have the right to know, access, delete, and opt out of the sale or sharing of your personal data. We do not sell your personal information. #### Cross-Border Processing by Issuers and SPVs Personal data may also be processed by Issuers or Special Purpose Vehicles (SPVs) incorporated in Panama or other jurisdictions where Qiro structures transactions. In such cases: * Contractual Safeguards: We require all Issuers and SPVs to adhere to binding contractual obligations, including Standard Contractual Clauses (SCCs) where applicable, ensuring that equivalent data protection standards are applied * Purpose Limitation: Data shared with Issuers or SPVs is limited to what is strictly necessary for executing contractual obligations * Access Controls: Only authorized personnel of the Issuer or SPV, subject to confidentiality undertakings, may access personal data * Further Sharing: These entities may in turn disclose data to trustees, security agents, escrow providers, auditors, or regulators solely for compliance with legal or contractual obligations * User Rights: You continue to retain all rights provided under applicable data protection laws regardless of where processing takes place * Legal Disclosure: Where required by applicable law or supervisory authority, we may share relevant data without additional notice, but will limit disclosure to the minimum necessary By using our services, you acknowledge and agree to such transfers and processing of your personal data in accordance with this Privacy Policy. ### 6. Data Retention We retain data for as long as necessary to: * Fulfill the purposes outlined in this policy * Comply with legal and regulatory obligations * Enforce contractual rights and resolve disputes Investor and borrower identity records are typically retained for 7 years post-termination of the business relationship, subject to jurisdictional requirements. ### 7. Data Security Qiro employs a comprehensive framework of technical, organizational, and administrative safeguards designed to protect personal data and other confidential information from unauthorized access, disclosure, alteration, or destruction. Our security program is aligned with industry standards and financial services best practices and includes, without limitation: * Encryption protocols for data in transit and at rest, where applicable * Strict access controls and multi-factor authentication to ensure that only authorized personnel may access sensitive information * Segregation of duties and role-based permissions to minimize risks of internal misuse * Regular monitoring, vulnerability assessments, and audits to identify and address emerging threats * Secure infrastructure and storage solutions, including third-party service providers that are contractually bound to adhere to equivalent security measures Further to demonstrate our commitment to the highest standards of security and regulatory compliance: * Independent Audits: We engage reputable third-party firms to perform annual smart-contract and system security audits * Responsible Disclosure: We maintain a responsible vulnerability disclosure program that allows security researchers to report issues in a safe, coordinated, and legally protected manner * Breach Notification: In the unlikely event of a personal data or system security breach, Qiro will notify affected individuals and competent supervisory authorities without undue delay, in accordance with applicable law * Continuous Monitoring: Our systems are subject to ongoing monitoring, penetration testing, and incident-response protocols to identify and address emerging threats in real time * Blockchain and Decentralized Network Considerations: Certain information, such as wallet addresses and on-chain transaction records, may be publicly recorded on decentralized networks Residual Risk and User Responsibility: While we strive to apply appropriate safeguards in accordance with applicable laws and regulatory obligations, no method of transmission or storage is entirely secure. Accordingly, we cannot guarantee absolute protection of personal data. Users are responsible for maintaining the confidentiality of their access credentials, private keys, and devices used to engage with our services. ### 8. Your Rights Depending on your jurisdiction (e.g., GDPR in the EU, PDPA in Singapore), you may have rights to: * Access, correct, or update your personal data * Request deletion, subject to legal retention obligations * Restrict or object to processing of personal data * Request a copy of your data in portable format Requests can be submitted to ### 9. Cookies and Web Tracking Qiro platform uses cookies, tracking technologies, and similar tools to enhance functionality, improve user experience, and collect information about how our services are used. These technologies allow us to: * Recognize and remember users' preferences and settings * Facilitate secure login and account management * Monitor website traffic, usage patterns, and performance * Conduct analytics and market research to improve our services * Comply with legal and regulatory obligations, including fraud detection and security monitoring #### Types of Cookies and Tracking Technologies * Strictly Necessary Cookies: Essential for the operation of our platforms * Functional Cookies: Enhance usability by remembering preferences or settings * Analytics and Performance Cookies: Collect aggregated information about user activity to help us improve services * Security Cookies: Assist in fraud prevention and authentication We do not use cookies for targeted advertising without obtaining appropriate user consent. Most web browsers allow you to control or disable cookies through settings. Please note that if you disable or reject certain cookies, some features of our services may not function as intended. ### 10. Updates to Privacy Policy We may update this Privacy Policy from time to time. Updates will be posted on [qiro.fi](https://qiro.fi/) and the "Last Updated" date will be revised accordingly. ### 11. Disclaimer Please note that blockchain data is public and immutable. Wallet addresses, balances, transaction hashes, and smart-contract events are recorded on decentralized ledgers that are publicly visible and cannot be altered or erased. As a result, certain data-subject rights do not apply to on-chain records. We will, however, respect your rights with respect to any off-chain personal data that we process. ### 12. Complaints We take very seriously any complaints we receive about our use of Personal Information. Questions, comments, requests, or complaints regarding this Privacy Notice, or wish to discuss your data protection rights with us, please contact using the information below. ### 13. Contact Us To exercise any of your rights or if you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us using the following information: Email: # Terms of Use Welcome to Qiro ([qiro.fi](https://qiro.fi/)) ("Qiro," "we," "our," "us"). Qiro provides blockchain-based technology services that enable investors and borrowers to interact through smart contracts and Special Purpose Vehicles ("SPVs") for tokenized loan transactions. Important: Qiro provides technology infrastructure and connectivity services only. Qiro does not itself issue, originate, hold custody of, or intermediate any loans, securities, or tokens. All token issuances are undertaken by independent SPVs or borrowers, and Qiro is not a counterparty. All contractual relationships in respect of investments or loans are directly between Investors, SPVs, and Borrowers. Qiro does not diligence, verify, or endorse any SPV, Borrower, investment, or related disclosures, and users must rely solely on their own due diligence. These Terms of Use ("Terms") govern your access to and use of the Qiro website, smart contracts, and related services (collectively, the "Services"). By accessing or using the Services, you acknowledge and agree to be bound by these Terms, and you confirm that you meet the applicable eligibility requirements. If you do not agree with these Terms, you may not access or use the Services. ### Eligibility Requirements To access and use the Qiro platform and Services, you must meet the following eligibility criteria. #### 1. General Requirements * You must be at least 18 years of age (or the legal age of majority in your jurisdiction) * You must have the legal capacity and authority to enter into binding contracts * You must not be a resident of or located in a jurisdiction that is sanctioned, restricted, or prohibited by applicable international laws #### 2. Investor Eligibility If you are accessing the platform as an Investor, you represent and warrant that: * You qualify as an accredited, professional, sophisticated, or otherwise qualified investor under the standards applicable in your jurisdiction * You have successfully completed the AML/KYC verification required by the relevant Issuer (SPV) or its appointed service providers * You shall provide accurate and complete tax residency self-certifications (including, where applicable, under FATCA and CRS regimes) * You represent and warrant that you are not a Sanctioned Person and are not owned or controlled by any Sanctioned Person * You understand and accept that investments involve risk of capital loss, and Qiro does not provide financial, legal, or tax advice * You agree to comply with the Subscription Agreement and any offering documents relating to tranche tokens issued by SPVs #### 3. Additional Acknowledgments In addition, you acknowledge and agree that: * Your participation does not require licensing, registration, or authorization under the laws applicable to you, or that you have obtained all such required approvals * You possess the knowledge, experience, and capacity to evaluate the merits and risks of participating in tokenized lending transactions * You have not relied on Qiro, its affiliates, or its personnel for any investment recommendation, suitability assessment, or fiduciary duty * All subscription funds or digital assets used are derived from legitimate, lawful sources * You acknowledge that tranche tokens may be illiquid, non-transferable, or subject to restrictions * You are solely responsible for all tax liabilities arising from your participation #### 4. Borrower (Asset Originator) Eligibility If you are accessing the platform as a Borrower, you represent and warrant that: * You are a duly incorporated legal entity in good standing under the laws of your jurisdiction * You have the authority to enter into a Web3 Loan Agreement with the Issuer (SPV) * You will provide all information and documentation required by the Issuer (SPV) or its service providers to satisfy AML/KYC and loan due diligence requirements * You agree to comply with the loan covenants and permitted use of proceeds under the Web3 Loan Agreement #### 5. Prohibited Users You may not use the Services if you: * Are under the age of 18 (or the age of majority in your jurisdiction) * Have been previously suspended or removed from the Qiro platform * Provide false, misleading, or incomplete information ### 6. Important Notices Applicable to Your Use of the Service Please read the following notices carefully. By accessing or using the Qiro platform and Services, you acknowledge and agree that: **Technology Service Provider Only** * Qiro acts solely as a blockchain platform service provider * Qiro does not act as a bank, lender, broker, custodian, financial advisor, or securities dealer * All contractual relationships exist directly between Investors, Issuers (SPVs), and Borrowers **No Advice** * Information provided is for informational purposes only * Qiro does not provide legal, accounting, tax, financial, or investment advice * You should obtain independent professional advice before making any decision **Risk of Loss** Participation in blockchain-based lending and investment structures involves significant risk, including the risk of partial or total loss of capital. Transactions on public blockchains are irreversible, and Qiro cannot reverse, cancel, or recover transfers. **User Responsibility** You are solely responsible for maintaining the security of your wallet, private keys, and access credentials. Qiro has no ability to access, recover, or replace lost or compromised keys or wallets. **No Guarantee** Qiro makes no representation, warranty, or guarantee regarding borrower repayment, performance of any investment, or enforceability of legal agreements. Past performance is not indicative of future results. ### 7. Token Transfer Controls **Transfer Restrictions** All digital tokens or other tokenized instruments ('Tokens') made available through or in connection with the Qiro Marketplace are subject to the Tokenisation Terms and related documentation. Users acknowledge and agree that: * Tokens may not be freely transferable and may be subject to contractual restrictions * Any attempted transfer in violation of such restrictions shall be null and void * Qiro Marketplace reserves the right to prevent, block, suspend, or reverse any Token transfer that is unauthorized, unlawful, or non-compliant **Technical Controls** Users acknowledge that Qiro Marketplace may implement smart contracts, whitelisting, lock-up mechanisms, or other technical restrictions to enforce Token transfer limitations. Users shall not circumvent or attempt to circumvent any such technical controls. **No Guarantee of Liquidity** Qiro Marketplace makes no representation or warranty that Tokens will be tradable, liquid, or capable of transfer at any particular time. Users bear sole responsibility for understanding and accepting the illiquid nature and restrictions attached to any Tokens they acquire. ### 8. Use Restrictions of Service and Content **a. Permitted Use** * You may use the Services solely for lawful purposes and in accordance with these Terms * You may access the platform only for your personal or internal business use as an eligible Investor or Borrower **b. Prohibited Use of Services** You shall not, and shall not attempt to: * Use the Services for any unlawful, fraudulent, or prohibited activity * Circumvent, disable, or tamper with any security features * Use automated systems (bots, scrapers, crawlers) except as expressly permitted * Interfere with or disrupt the normal operation of the platform * Misrepresent your identity, eligibility status, or provide false information * Attempt to gain unauthorized access to other users' wallets, accounts, or data **c. Restrictions on Content** All content made available through the Qiro platform is protected by intellectual property laws. You may not: * Copy, reproduce, distribute, or modify the Content without prior written consent * Use Qiro's Content for any commercial purpose other than your own permitted participation * Create derivative works, reverse engineer, or extract source code * Use Qiro's name, branding, or Content in a way that suggests sponsorship or endorsement ### 10. Dispute Resolution and Governing Law **Good Faith Resolution** The Parties shall first attempt in good faith to resolve any dispute through negotiations. If unable to resolve within thirty (30) days, the matter shall be referred to arbitration. **Arbitration** Any Dispute shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with the SIAC Rules. The seat of arbitration shall be Singapore, the language shall be English, and the tribunal shall consist of a sole arbitrator. **No Class or Representative Actions** The Parties agree that any Dispute shall be conducted solely on an individual basis. Neither Party shall bring or participate in any class, collective, or representative action. **Governing Law** These Terms of Use and any Dispute shall be governed by and construed in accordance with the laws of Singapore, without regard to its conflict of law principles. ### 11. Tax and Accounts Responsibility User Responsibility for Taxes: Each user is solely responsible for determining, reporting, withholding, collecting, filing, and remitting any and all taxes that may be imposed under Applicable Law in connection with their participation. No Responsibility for User Taxes: Qiro Marketplace shall have no obligation or liability for any taxes owed by any user, except where required by Applicable Law to withhold or deduct taxes at source. ### 12. Disclaimer of Representations and Warranties IMPORTANT DISCLAIMER The Services are provided strictly on an "as is," "where is," and "as available" basis. To the maximum extent permitted under Applicable Law, Qiro Marketplace expressly disclaims all representations, warranties, guarantees, covenants, conditions, and undertakings of any kind, whether express, implied, statutory, or otherwise. **No Representations Regarding Information** Qiro Marketplace makes no representation, warranty, or covenant that any content, data, documents, projections, forecasts, or information will be accurate, reliable, adequate, error-free, or suitable for any purpose, or that any investment opportunity has been approved, recommended, or endorsed. **No Advice or Fiduciary Duty** Qiro Marketplace does not provide, and nothing in the Services constitutes, investment advice, legal advice, tax advice, or any form of professional or fiduciary advice. Investors are solely responsible for conducting their own independent investigation and due diligence. **No Guarantee of Results** Qiro Marketplace makes no representation that any investment opportunity will be successful, profitable, or generate any particular result. All investments are subject to risk, volatility, illiquidity, and the potential loss of part or all of the invested capital. ### 13. Limitation of Liability Maximum Limitation: To the fullest extent permitted under Applicable Law, in no event shall the Qiro Parties be liable to any user for any losses, damages, liabilities, costs, or expenses in excess of the greater of: * The total fees actually paid by the user to Qiro Marketplace in the twelve (12) months immediately preceding the event giving rise to the claim; or * One hundred United States Dollars (USD $100) Exclusion of Certain Damages: The Qiro Parties shall not be liable for any indirect, consequential, incidental, exemplary, punitive, or special damages of any kind, including lost profits, loss of data, loss of goodwill, or business interruption. Exceptions: Nothing in these Terms shall exclude or limit liability for fraud, fraudulent misrepresentation, willful misconduct, gross negligence, or any liability that cannot be excluded under Applicable Law. ### 14. Jurisdictional Access & Reverse Solicitation **No Active Solicitation** Qiro Marketplace operates as a technology service provider. Qiro does not conduct marketing, solicitation, or active promotion of the Services in any jurisdiction where such activities would be unlawful or require licensing. Any access occurs solely on the basis of the user's independent initiative and reverse solicitation. **User Representation of Reverse Solicitation** By accessing or using the Services, each user expressly represents that they have independently sought out and accessed the Services at their own initiative, without any solicitation by Qiro, and that their access complies with all applicable laws in their jurisdiction. **Restricted Jurisdictions** The Services are not offered to residents or entities in jurisdictions subject to comprehensive international sanctions or embargoes. Qiro reserves the right to restrict, suspend, or terminate access for users in any such restricted jurisdiction. ### 15. No Custody; User Control of Assets User Control of Assets: All digital assets, stablecoins, or Tokens are at all times held in wallets controlled by the user or in segregated wallets operated by independent third-party service providers. Qiro does not accept deposits, take possession of, or exercise control over any user assets. No Custodial Function: Qiro does not provide custodial, safekeeping, trust, escrow, or deposit-taking services. No fiduciary, trustee, or agency relationship is created by virtue of using the Services. Risk of User Wallets: Each user is solely responsible for the custody, security, and management of their own private keys, wallets, and access credentials. Qiro has no ability to retrieve, replace, freeze, or reverse any transaction. No Deposit Protection: Assets used in connection with the Services are not protected by deposit insurance, investor compensation schemes, or any government guarantee. ### 16. Independent SPVs & Borrowers No Agency or Partnership: Each SPV, Borrower, and counterparty is an independent legal entity. Qiro does not act as agent, partner, joint venturer, employee, fiduciary, or representative of any SPV or Borrower. No Responsibility for Counterparties: Qiro does not perform due diligence, verification, or endorsement of any SPV or Borrower. All disclosures, representations, and warranties are made exclusively by the relevant SPV or Borrower. Users enter into transactions entirely at their own risk. ### 17. General Provisions Indemnity: The user agrees to indemnify, defend, and hold harmless Qiro Marketplace from and against any and all claims, actions, losses, liabilities, damages, and expenses arising out of the user's breach of these Terms, violation of any law, or misrepresentation of eligibility. Force Majeure: Qiro Marketplace shall not be liable for any failure or delay resulting from causes beyond its reasonable control, including acts of God, natural disasters, war, terrorism, governmental orders, or blockchain-specific events. Severability: If any provision is held invalid or unenforceable, it shall be enforced to the maximum extent permissible, and the remaining provisions shall continue in full force. Assignment: These Terms may be assigned by Qiro Marketplace without restriction. Users may not assign their rights or obligations without prior written consent. ### 18. Notices Any notice required under these Terms shall be in writing and shall be deemed duly given when delivered by electronic mail, posting on the platform, or courier/registered post. Contact Email: Company: Celestia Market Inc., a company incorporated in Panama, with registration number 155772823 # Smart Contract Audits We have completed the smart contracts audits with QuillAudits, report is attached below.\ \