TERMS OF USE

THE BITCOIN CREDIT STACK — SITE, API AND MCP SERVER

Version: 0.2 · Effective date: 21 October 2026

These terms of use (the "Terms") govern access to and use of The Bitcoin Credit Stack through the website www.bitcoincreditstack.com, the API at api.bitcoincreditstack.com and the MCP server at mcp.bitcoincreditstack.com/mcp. The Bitcoin Credit Stack is published by ALETHEIA ANALYTICS, a French simplified joint-stock company with a sole shareholder (société par actions simplifiée à associé unique), with share capital of EUR 1,000, registered with the Paris Trade and Companies Register under number 107 152 662 R.C.S. Paris, whose registered office is at 173 rue de Courcelles, 75017 Paris, France ("Aletheia").

Contact: contact@aletheia-analytics.io.

The Bitcoin Credit Stack is a data publication. It is distinct from the open-source software known as The Gavel Protocol, from the thegavel.io interface and from Gavel's own data products, which are governed by separate documents (Article 6).

1. Purpose and scope

1.1. These Terms form the contract between Aletheia and each person who accesses or uses any of the Surfaces, directly or through a Machine Client (the "User").

1.2. These Terms govern only Aletheia's provision of the Surfaces. They do not govern the use of the credit venues, protocols, networks, tokens or third-party services described by the Data, nor the use of the Gavel Protocol or the thegavel.io interface.

1.3. The following documents supplement these Terms:

• the Data Licence, which governs the User's rights in the Data;
• the Terms of Sale, which govern the purchase of priced answers, prices, payment methods, VAT, receipts and the right of withdrawal;
• the Privacy Policy, which describes the processing of personal data;
• the Notices on the Data, which describe what the Data is and is not;
• the Credits and Sources page, which names each provider the Data rests on and its terms;
• the Legal Notice.

These documents are published at www.bitcoincreditstack.com/legal, each at its own address (for example www.bitcoincreditstack.com/legal/terms).

1.4. In the event of inconsistency, the Data Licence prevails for rights in the Data, the Terms of Sale prevail for sale and payment, and these Terms prevail for access to and use of the Surfaces.

2. Definitions

2.1. "Aletheia" means ALETHEIA ANALYTICS, the publisher of The Bitcoin Credit Stack.

2.2. "Stack" means The Bitcoin Credit Stack, the data publication published by Aletheia.

2.3. "Site" means the website www.bitcoincreditstack.com.

2.4. "API" means the programming interface at api.bitcoincreditstack.com.

2.5. "MCP Server" means the server at mcp.bitcoincreditstack.com/mcp under the Model Context Protocol, which makes reading tools available to AI assistants and agents.

2.6. "Surfaces" means the Site, the API and the MCP Server together.

2.7. "Data" means the values, series, measures, registries, criteria, charts, texts and reasoned absences served by the Surfaces, with their source, date and licence metadata.

2.8. "Machine Client" means any software that queries the API or the MCP Server, including an AI agent or assistant, a script or an application.

2.9. "User" has the meaning given in Article 1.1. Where a Machine Client acts on behalf of a person, the User is the person who deploys it or on whose behalf it acts.

2.10. "Gavel Protocol" means the open-source software known as The Gavel Protocol, deployed on Arbitrum One.

2.11. "Priced Answer" means an answer from the API or the MCP Server for which a price is due under the Terms of Sale.

3. Acceptance and evidence of agreement

3.1. By use. Accessing or using any Surface constitutes acceptance of these Terms in the version in force on the date of that access. No account, login or acceptance module is required. A User who does not accept these Terms must not use the Surfaces.

3.2. By a Machine Client. A request sent to the API or the MCP Server by a Machine Client constitutes acceptance of these Terms by the User who deploys that Machine Client or on whose behalf it acts. The User is answerable for the requests sent by its Machine Clients as for its own, including where an agent chooses the requests it sends by itself. The User ensures that any Machine Client it deploys can read these Terms.

3.3. How the Terms are referenced to machines. These Terms, the Data Licence and the Terms of Sale are referenced for Machine Clients: the address of these Terms is given in the MCP Server's instructions and in every HTTP 402 answer. An HTTP 402 answer also states the price of the call in machine-readable form, together with the elements the Terms of Sale provide for. The same texts appear on the pages written for people (/methodology and /legal); both forms are kept.

3.4. Evidence. Using the Surfaces creates no account and no named record of acceptance. The following may be used as evidence, to the extent permitted by applicable law and on the conditions of the Privacy Policy: the dated version of these Terms published on the date of access; the daily metering records of the API and the MCP Server; for a Priced Answer, the payment receipt (payer address, transaction reference); technical logs. None of these constitutes identity verification.

3.5. The User may download or print the version of these Terms in force. Each published version is dated and kept.

4. Professional users

4.1. The API, the MCP Server and Priced Answers are intended for persons acting for professional purposes. The Site may be read by anyone.

4.2. Where a User is nevertheless a consumer, the User retains all rights conferred by mandatory applicable law. The right of withdrawal and its waiver for digital content supplied at once are dealt with in the Terms of Sale.

5. Description of the Surfaces

5.1. The Stack publishes measurements of the bitcoin-collateralised credit markets: rates and curves, a registry of credit venues assessed against published, versioned criteria, chain series, indicators, a layer on listed issuers, and charts. The same measurements are published separately for credit secured by ether; the two are never added together.

5.2. The Stack is reached through three Surfaces:

• the Site, read in a browser. Most pages are pre-rendered; some query the API from the User's browser;
• the API, which answers read requests;
• the MCP Server, whose tools return observed Data.

5.3. All three Surfaces are read-only. No Surface prepares, signs or broadcasts a transaction; the MCP Server has no transaction tool. Aletheia holds no asset on behalf of any User and receives no mandate. No Surface creates a user account.

5.4. The Data is descriptive. No answer carries a composite score, a ranking, a default sort by rate, a safety verdict or a forecast. A value that cannot be established is served as an absence with its reason, never as a zero. The Notices on the Data describe these features in detail.

5.5. Aletheia may modify, add, remove, suspend or discontinue Data, routes, tools or functions at any time for legal, security, technical, operational or commercial reasons.

6. The Stack, the Gavel Protocol and Aletheia

6.1. The Stack is presented and listed as a data publication published by Aletheia. It is not the interface of any protocol.

6.2. The Gavel Protocol is open-source, permissionless software written by Jamie Frame in his personal capacity and released under the MIT licence. It has no operating entity.

6.3. Aletheia operates the thegavel.io interface and Gavel's own data products, which are governed by their own terms. These Terms do not govern them.

6.4. In the Stack, the Gavel Protocol appears as one credit venue among others, described against the same criteria, and its row is priced like any other venue's.

7. The publisher's commercial interest in Gavel

7.1. Aletheia has a commercial interest in Gavel: it participates in the Gavel Protocol for its own account and holds positions there, and it operates the thegavel.io interface and Gavel's own data products. Jamie Frame, the Stack's publication director, is the author of the Gavel Protocol.

7.2. This interest is stated on Gavel's row wherever venues are presented, in that row's disclosure field, whether the answer is free or priced, and in these Terms.

7.3. Aletheia's interest creates no mandate, fiduciary duty, liquidity or rate commitment or guarantee in favour of the User.

8. Free and paid use

8.1. Reading the Site is free. On the API and the MCP Server, each call belongs to a cost class. The catalogue and readings are free; snapshots and histories are priced beyond a free daily allowance. The classes, prices, allowance and billing unit are set by the price list and described in the Terms of Sale. A call costs the same through the API and through the MCP Server.

8.2. Beyond the allowance, a priced call receives an HTTP 402 answer stating its price. Payment is then made under x402, in USDC on the Base network. Other payment methods (Lightning, credits and a plan by card) may be offered; they are offered only once announced on the Site and in the Terms of Sale.

8.3. A Priced Answer has exactly the content of the corresponding free answer: the same values, words, absences and sources. Payment buys no priority, exclusivity or service level.

8.4. A failed call (a 4xx or 5xx answer) is not charged and does not use the allowance. The following are neither charged nor refused for payment: the Site's own pages, the calls the MCP Server makes to the API on the same server, and calls presented with an API key issued by Aletheia.

8.5. The Terms of Sale govern the sale, when it is complete, VAT, receipts and the right of withdrawal. The Data Licence governs what the User may do with the Data, paid for or not.

9. Rate limits

9.1. The API and the MCP Server apply rate limits to protect the service. They are computed per network address (the /64 prefix for IPv6, the address for IPv4), held in memory for the length of the limiting window only.

9.2. Rate limits are an infrastructure measure, not a billing one: they do not determine what is owed, and the metering of calls is a separate record. No unlimited use is offered. Aletheia may change the limits without notice.

10. Information only: no advice, mandate, execution or regulated service

10.1. The Stack is an information product, free or paid. Through its Surfaces, Aletheia does not receive or transmit orders, execute transactions for anyone's account, provide custody, manage portfolios, receive a mandate or provide any regulated service. Payment for a Priced Answer pays for the supply of Data; it does not change that qualification.

10.2. Aletheia does not act as a lender, borrower, credit intermediary, broker, agent or representative for a User. Nothing in the Surfaces or these Terms constitutes an offer of credit or lending.

10.3. The Data is general in nature. It does not constitute financial, investment, legal, tax, accounting, credit or other personalised advice, nor a recommendation to borrow, lend, buy, sell, hold or transfer any asset, or to use any venue.

10.4. Nothing in the Surfaces assesses a person. The Data concerns venues, contracts, markets and issuers; no Surface assesses the creditworthiness of a natural person or establishes a credit score. Where a page shows the public positions of an address entered by the User, it shows them as they stand on chain, without assessing them. Point 5(b) of Annex III to Regulation (EU) 2024/1689 on artificial intelligence is therefore not engaged.

10.5. The User obtains independent professional advice where appropriate and remains solely responsible for its decisions, and for those its Machine Clients take, on the basis of the Data.

11. User obligations

11.1. The User agrees to:

• use the Surfaces only for lawful purposes and in accordance with these Terms, the Data Licence and, for Priced Answers, the Terms of Sale;
• keep with the Data its sources, dates and the attribution notices that the Data Licence and the Credits and Sources page require;
• independently verify any Data before using it for a decision;
• pay the prices, taxes and costs arising from its use;
• comply with applicable sanctions, anti-money laundering, tax and market conduct rules; and
• stop using the Surfaces if that use becomes unlawful.

11.2. No Surface asks for a private key, recovery phrase or secret. The User must never disclose one to Aletheia.

12. Prohibited conduct

12.1. The User must not, directly or through a Machine Client:

• circumvent the rate limits, the free allowance or payment, including by rotating network addresses or spreading calls across several addresses to multiply the allowance, by forging or altering headers (origin, user agent, payment headers), by replaying a proof of payment, or by presenting itself as the Site itself or as an internal caller;
• extract Data from the Site or the API systematically beyond the limits, or by any means other than the documented routes and tools;
• interfere with, overload, compromise or disrupt the Surfaces or their infrastructure, or introduce malicious code into them;
• misrepresent the Data, including by presenting an absence as a zero, removing its sources, dates or attribution notices, presenting as licensed any value the Data Licence does not license, or presenting the Data as a score, ranking, recommendation or assessment made by Aletheia;
• use the Data as a benchmark, in the sense provided for and within the limits set by the Data Licence;
• misrepresent an affiliation with Aletheia, the Stack, the Gavel Protocol or any venue described;
• use the Surfaces for fraud, money laundering, sanctions evasion, terrorist financing or market manipulation, or to create a misleading appearance of activity, liquidity, price or demand; or
• use the Surfaces on behalf of a person subject to sanctions applicable to the User or to Aletheia.

12.2. Automated access to the Surfaces is made through the API and the MCP Server, according to their public documentation.

13. Availability, maintenance and suspension

13.1. The Surfaces are provided on an "as available" basis, whether used free of charge or for payment. Aletheia does not guarantee continuous, uninterrupted, error-free or secure availability, or compatibility with every browser, Machine Client or network condition. No service level is agreed.

13.2. Aletheia may suspend or restrict all or part of the Surfaces for maintenance, security, legal or regulatory reasons, infrastructure or data-provider failure, or suspected abuse.

13.3. The Data depends on third-party sources and chain reads; it may be delayed, incomplete or revised. A published value may be corrected; the Data Licence describes how to dispute a published value.

14. Intellectual property and the licence of the Data

14.1. The Surfaces, their proprietary code, layout, texts, graphics, databases, data products, documentation, trademarks and domain names are protected by intellectual property and other applicable rights belonging to Aletheia or its licensors.

14.2. The User's rights in the Data are governed exclusively by the Data Licence. The rights in a value follow its providers: Aletheia's own values fall under the Data Licence; third-party values fall under their provider's terms, named for each value.

14.3. Subject to compliance with these Terms, Aletheia grants the User a non-exclusive, non-transferable and revocable right to access the Surfaces for their intended purpose. No right is granted other than those provided by the Data Licence.

14.4. The MIT licence of the Gavel Protocol's code grants no right in Aletheia's trademarks, domain names, Surfaces or Data.

15. Personal data

15.1. Aletheia processes the technical and personal data needed to operate and secure the Surfaces, meter calls, collect payments and comply with its legal obligations. That processing, its legal bases and its retention periods are described in the Privacy Policy.

16. Disclaimers

16.1. To the maximum extent permitted by law, the Surfaces and the Data are provided "as is" and "as available", without any express or implied warranty, including of accuracy, completeness, timeliness, availability, quality, fitness for a particular purpose or non-infringement.

16.2. Aletheia does not warrant the liquidity, rate, solvency or safety of any venue, contract, token or issuer described by the Data.

16.3. No Data constitutes a guarantee, certification, credit assessment, investment recommendation or assurance of regulatory treatment.

16.4. Nothing in these Terms excludes any warranty or right that cannot lawfully be excluded, particularly where the User is a consumer.

17. Liability

17.1. Except to the extent that a loss is directly and foreseeably caused by Aletheia's proven breach of these Terms or proven fault, Aletheia is not liable for losses resulting from decisions taken by the User or its Machine Clients on the basis of the Data, from the use of any venue, protocol or service described (including the Gavel Protocol), from market movements, from a liquidation, from an error or interruption of a third-party source, or from unavailability of the Surfaces.

17.2. To the maximum extent permitted by law, Aletheia is liable only for direct and foreseeable loss caused by Aletheia's proven breach of an obligation arising under these Terms. Aletheia is not liable for indirect, consequential, special or punitive loss, loss of profit, revenue, opportunity, data, reputation or anticipated savings.

17.3. For Users acting for professional purposes, and except where limitation is prohibited by law, Aletheia's aggregate liability arising from or relating to the Surfaces, the Data or these Terms is limited to 10,000 euros.

17.4. The limitations in this Article do not apply to fraud, wilful misconduct, gross negligence where it cannot lawfully be limited, death or personal injury caused by negligence, breach of an essential obligation where limitation would deprive it of substance, or any other liability that cannot be limited under applicable law.

17.5. Where the User is a consumer, the User retains all mandatory statutory rights. Any limitation or exclusion in these Terms applies only to the extent permitted by the law applicable to that consumer.

18. Suspension and end of access

18.1. The User may stop using the Surfaces at any time.

18.2. Aletheia may suspend or end the access of a User or a Machine Client to the Surfaces, including by blocking network addresses, in the event of breach of these Terms, circumvention of the limits or of payment, suspected fraud, sanctions risk, security threat, unlawful use, legal requirement or discontinuation of the Stack.

18.3. The end of access gives no right to a refund of a Priced Answer already supplied, subject to the Terms of Sale and to the mandatory rights of consumers.

18.4. Articles intended by their nature to survive the end of access, including those on intellectual property, the Data Licence, liability, governing law and dispute resolution, remain in force.

19. Changes to these Terms

19.1. Aletheia may amend these Terms to reflect changes in law, regulation, functionality, security, business model or operations. Each version is published on the Site with its effective date.

19.2. A call is governed by the version in force on its date. An amendment does not apply retroactively to a Priced Answer already supplied. A User who does not accept an amendment must stop using the Surfaces.

20. Complaints and consumer mediation

20.1. Questions or complaints concerning the Stack should first be sent to contact@aletheia-analytics.io or by post to ALETHEIA ANALYTICS, 173 rue de Courcelles, 75017 Paris, France.

20.2. Where the User is a consumer and mandatory consumer mediation rules apply, the User may refer an unresolved dispute to the competent consumer mediator after first submitting a written complaint to Aletheia.

As of the effective date, Aletheia has not yet adhered to a consumer mediation scheme. The name and contact details of the competent consumer mediator will be published in these Terms and on the Site once Aletheia's adhesion to such a scheme is effective.

20.3. The availability of consumer mediation does not deprive the User of the right to bring proceedings before a competent court.

21. Governing law and jurisdiction

21.1. These Terms are governed by French law.

21.2. If the User is a consumer, the choice of French law does not deprive the User of mandatory protections granted by the law of the User's habitual residence where those protections apply. Consumer disputes are heard by the courts having jurisdiction under mandatory applicable rules.

21.3. If the User acts for professional or business purposes, any dispute arising from or relating to the Surfaces, the Data or these Terms falls within the exclusive jurisdiction of the competent courts of Paris, France, including in the event of multiple defendants or third-party proceedings, subject to any mandatory rule to the contrary.

21.4. Before commencing proceedings, the parties attempt in good faith to resolve the dispute through written discussions, except where urgent relief or a limitation period requires immediate action.

22. Miscellaneous

22.1. Entire agreement. These Terms and the documents listed in Article 1.3 constitute the agreement governing use of the Surfaces.

22.2. Severability. If any provision is held invalid or unenforceable, it is interpreted or limited to the minimum extent necessary, and the remaining provisions remain in force.

22.3. No waiver. A failure or delay in exercising a right does not constitute a waiver.

22.4. No partnership or agency. These Terms do not create a partnership, joint venture, employment, agency, fiduciary or representation relationship between Aletheia and the User.

22.5. Language. These Terms are drafted in French. An English translation is made available; in the event of inconsistency, the French version prevails.