Services

Rozero Digital, MB provides a narrow, clearly defined service: custody of one encrypted cryptographic key share in the Everfair recovery system. The full list of services is below. Rozero Digital does not perform any other activity, including KYC, KYB or AML.

1. Encrypted key share custody

• Custody of a single encrypted block (an encrypted share) produced by the Shamir Secret Sharing algorithm and assigned to Rozero Digital's position in the Everfair 2-of-7 recovery scheme.
• The stored binary object cannot be decrypted with this single share alone — by design the algorithm requires at least two independent shares out of seven.
• Storage is segregated from Everfair's main infrastructure, from other share custodians and from any KYC/KYB processor.

2. Recovery quorum participation

• Upon receipt of a valid recovery request from the Everfair recovery orchestrator, we provide our encrypted share according to the protocol.
• Request authenticity is verified cryptographically. All requests and responses are recorded in the audit log.
• Neither the decision on user identity nor the final key reconstruction depends on Rozero Digital alone.

3. Audit logging

• Immutable operation logs: when a request was received, of what type, whether a response was provided, what authorisations were presented.
• Logs are made available to competent authorities as required by law; to Everfair network participants — only to the extent required by contractual or legal obligations.

4. Lawful disclosure to authorities

• Rozero Digital, MB is the Lithuanian-registered legal point of contact for law-enforcement and judicial requests concerning Everfair wallets.
• For this purpose Rozero stores the absolute minimum: wallet address → country code (ISO 3166-1) + national personal or company identification code. The personal code is encrypted with AES-256-GCM, with the key split using a Shamir 2/3 scheme.
• Upon a valid Lithuanian court order, prosecutor's decision or decision of a competent authority, Rozero unlocks the record and provides the authority with only the country code and the national code — nothing more, because nothing more is held.
• Rozero cannot provide the user's name, surname, address or document images. The authority itself establishes identity through state registers: in Lithuania — the Population Register and the Register of Legal Entities; abroad — the relevant register of that country (via Interpol, Europol, MLAT).
• Each disclosure is logged: request date, authority, legal basis, scope, data disclosed.
• This obligation does not weaken the cryptographic scheme: even when serving an authority's request, Rozero Digital cannot unilaterally move user funds.
• The KYC/KYB provider (currently — Sumsub) may be replaced with another accredited partner without affecting this function, since the record stored by Rozero does not depend on the KYC/KYB provider.

5. International legal cooperation

Rozero Digital does not act on direct requests from foreign law-enforcement agencies. Foreign authorities use established international cooperation channels, which always conclude with a Lithuanian national act issued by a court or prosecutor:

• EU Member States — European Investigation Order (EIO) under Directive 2014/41/EU. Submitted to the competent Lithuanian authority (typically the Prosecutor General's Office), which forwards it to Rozero Digital for execution.
• Third countries (e.g. US, UK, Switzerland) — via a Mutual Legal Assistance Treaty (MLAT) or diplomatic channel. The foreign agency contacts its own central authority, which contacts the Lithuanian Prosecutor General's Office or Ministry of Justice; these initiate a national procedure and issue a Lithuanian order.
• Emergency cases (imminent threat to life, child exploitation) — expedited disclosure is possible under the Lithuanian Code of Criminal Procedure and the AML Law, with mandatory retrospective judicial review.

A direct request from a foreign authority without a Lithuanian legal act is not a sufficient basis on its own to disclose personal data.

6. Independent operation

• Rozero Digital, MB is legally, financially and operationally separated from Everfair, from the other six share custodians and from the KYC/KYB provider (Sumsub or another accredited partner).
• This separation is an essential property of the banking-grade 2-of-7 model — it ensures that no single party can unilaterally reach user assets or data.

What Rozero Digital, MB does not provide

• Customer identity verification (KYC) and business entity verification (KYB) — performed by an accredited KYC/KYB provider of the Everfair network (currently — Sumsub).
• Anti-money-laundering (AML), PEP and sanctions screening — performed by the KYC/KYB provider and the Everfair compliance chain, not Rozero.
• Payment or wallet operation, transaction approval, customer fund custody.
• Processing of identity documents, biometric data or personal codes.