GENERAL TERMS AND CONDITIONS

Last updated: 30 June 2026.

1. GENERAL PROVISIONS AND ACCEPTANCE OF THE TERMS

1.1. These General Terms and Conditions (the "Terms") govern the use of all products and services available on the Whitely platform (hereinafter referred to as the "Platform") at https://whitely.hr/ (the "Website"), operated by White Tech d.o.o., OIB (personal identification number) 22301840862, MBS (company's registration number) 060486036, EUID HRSR.060486036, incorporated and operating in accordance with the laws of the Republic of Croatia (the "Company", "we", "us" or "our").

1.2. Retail Customers who qualify as consumers shall also be subject to the provisions set out in the section entitled "Special Terms for Consumers" at the end of these General Terms and Conditions.

1.3. By registering a Whitely account (the "Account") or using any service, software, product or tool made available through the Website (collectively, the "Services"), you ("Authorised User", "Retail Customer", "Business User", as applicable, "you" or "your") acknowledge that you have read, understood and fully accepted these Terms, as well as all policies, schedules and appendices incorporated herein by reference, including, without limitation, the Privacy Policy, Fee Schedule, Risk Disclosure Statement and the summary of the Company's Custody and Administration Policy.

1.4. By using the Services, you represent and warrant that you are at least 18 years of age (or the age of legal majority under the laws of your jurisdiction, whichever is higher), that you have full legal capacity to enter into legally binding agreements, and that you are not a citizen or resident of a jurisdiction in which crypto-asset services or payment processing services are restricted or prohibited by law. You are solely responsible for ensuring that your access to and use of the Services complies with all applicable laws and regulations.

1.5. If you act on behalf of a legal entity, you represent and warrant that you are duly authorised to bind such legal entity and that all obligations arising under these Terms shall be binding upon that legal entity. References to "you" or "your" shall include the legal entity you represent.

1.6. Acceptance of these Terms is evidenced by: (i) ticking the "Confirm" box during registration; or (ii) continuing to use the Services after any amendments or modifications to these Terms become effective. If you do not agree to these Terms, in whole or in part, you must not continue to use any of the Services.

1.7. Acceptance of these Terms, including any amendments thereto, is a mandatory condition for registration and continued use of the Services.

1.8. The processing of personal data is governed by the Privacy Policy available on our Website.

1.9. The use of the Website is governed by the Website Terms of Use available on the Website.

2. DEFINITIONS

2.1. In addition to the terms defined elsewhere in these Terms, the following definitions shall apply throughout this document. Unless the context requires otherwise, words in the singular shall include the plural and words in the plural shall include the singular. References to one gender shall include all genders. The words include, including, and in particular shall be deemed to be followed by the words without limitation.

2.2. "Account" (or "Whitely Account") means a virtual interface within the Platform made available to a Website User following successful registration and verification, through which the Website User, as defined in the Website Terms of Use, accesses the Services, views balances, initiates or monitors Transactions, and manages operational settings.

2.3. "Applicable Law" or "Applicable Regulations" means the applicable laws of the Republic of Croatia and applicable European Union legislation, including, without limitation: Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 ("MiCA"); the Act on the Implementation of Regulation (EU) 2023/1114 on Markets in Crypto-Assets (Official Gazette No. 85/24); the Anti-money laundering and counter terrorism financing Act (Official Gazette Nos. 108/17, 39/19 and 151/22); the Ordinance on the protection of assets of crypto-asset service providers' clients (Official Gazette No. 157/2025); Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market ("PSD2"); and all applicable European Union restrictive measures regulations, including any amendments thereto.

2.4. "Balance" means the amount of crypto-assets or their fiat equivalent credited to the Account or wallet of a Business User or Retail Customer and available for withdrawal or settlement.

2.5. "Business Day" means any day on which banking institutions in the Republic of Croatia are open for business, excluding Saturdays, Sundays, and public holidays prescribed by law.

2.6. "Company", "we", "us" or "our" means WHITE TECH d.o.o., a company incorporated in the Republic of Croatia, OIB 22301840862, MBS 060486036, EUID HRSR.060486036, which operates the Website/Platform and provides regulated crypto-asset exchange, custody and transfer services in accordance with MiCA and Applicable Law.

2.7. "Fee Schedule" means the document setting out all prices, fees, and charges applicable to the Company's Services, available on the Company's Website at [INSERT LINK].

2.8. "Access Credentials" means the login credentials of a Business User or Retail Customer, including the email address, password, two-factor authentication codes, and any other information required to access or verify the Account of a Business User or Retail Customer.

2.9. "Fees" means all service fees, commissions, and charges applicable to the provision or use of the Services, as described in these Terms or within the Account interface.

2.10. "KYC/KYB Verification" means the Know Your Customer (KYC) or Know Your Business (KYB) due diligence process conducted by the Company to verify the identity, ownership structure, and eligibility of a User of the Services before granting access to, or permitting continued use of, the Services.

2.11. "Materials" means the Website, Software, Products, Services, underlying technology, source code, content, graphics, images, user interfaces, and all related intellectual property components owned by or licensed to the Company.

2.12. "Privacy Policy" means the Company's policy governing the collection, use, and protection of personal data, available on the Website and forming an integral part of these Terms.

2.13. "Products" means hardware or software solutions provided by the Company, including, without limitation, Whitely PoS devices, APIs, reporting modules, and related merchant tools.

2.14. "Services" means the services provided by the Company as described in Article 5.

2.15. "Sanctioned Person" means any natural or legal person, entity, or body that:

• (a) is listed on any Sanctions List issued or maintained by a Sanctions Authority;

• (b) is organised, incorporated, registered, resident, or established in a Sanctioned Country;

• (c) is otherwise subject to Sanctions; or

• (d) is owned or controlled, directly or indirectly, by, or acts on behalf of or for the benefit of, any of the foregoing persons or entities.

  2.16. "Sanctions" means any economic or financial sanctions, restrictive measures or trade embargoes imposed, administered or enforced by a Sanctions Authority, including, as applicable, the Act on Restrictive Measures (Official Gazette Nos. 133/2023 and 151/2025), the Anti-Money Laundering and Counter-Terrorism Financing Act (Official Gazette Nos. 108/2017, 39/2019 and 151/2022, as amended, the "AML/CFT Act"), other related legislation of the Republic of Croatia, applicable European Union regulations concerning restrictive measures, and any other applicable international sanctions laws and regulations.

  2.17. "Sanctioned Country" means any country or territory that is subject to comprehensive territorial Sanctions.

  2.18. "Sanctions Authority" means:

• (a) the United Nations;

• (b) the European Union;

• (c) the United States of America;

• (d) the Republic of Croatia and its competent governmental authorities responsible for the implementation or enforcement of Sanctions;

• (e) the competent governmental institutions and agencies of any of the foregoing; and

• (f) any other governmental or regulatory authority that imposes, administers, or enforces Sanctions.

  2.19. "Transaction" means any transfer, conversion, or settlement of crypto-assets or fiat currency carried out through the Services, including deposits, withdrawals, exchanges, and payments.

  2.20. "Unsupported Payments" means any payments made in crypto-assets, tokens, or through blockchain networks that are not supported by the Company.

  2.21. "User of the Services" means a Retail Customer and/or a Business User.

  2.22. "Retail Customer" means a natural person who uses the Services for personal purposes. "Business User" means a natural or legal person who uses any of the Services in the course of carrying out a business or economic activity and is NOT a consumer.

  2.23. "Authorised User" means an individual who has been granted access to an Account and who is not a customer, but a user acting on behalf of a Business User.

  2.24. "Crypto-Asset" means a digital representation of value that can be digitally traded, transferred, or used for payment or investment purposes and that is based on distributed ledger technology or similar technology; it does not include digital representations of fiat currencies, securities, or other financial assets.

  2.25. "Wallet" means a software- or hardware-based mechanism for storing and managing private and public keys associated with crypto-assets, used for sending, receiving, and monitoring ownership of crypto-assets within or outside the Whitely system.

  2.26. "Website" means the Company's website, available at https://whitely.hr/, through which the Services are made available.

3. CONTACT AND COMPLAINT HANDLING

3.1. Complaints and enquiries relating to these General Terms and Conditions and the Services may be submitted through the following channels:

• 3.1.1. Email: support@whitely.hr

• 3.1.2. Postal address: Petrinjska ulica 6, 10000 Zagreb, Republic of Croatia.

  3.2. Users of the Services have the right to submit a complaint regarding the Company's provision of crypto-asset services. The submission and handling of complaints is free of charge.

  3.3. Complaints must be submitted in writing, either electronically to support@whitely.hr or by post to Petrinjska ulica 6, 10000 Zagreb, Republic of Croatia. A complaint must be signed or otherwise authenticated by the User of the Services or its authorised representative.

  3.4. A complaint should contain the full name and contact details of the complainant, a description of the subject matter of the complaint, and the preferred resolution. Users of the Services may use the standard complaint form available on the Company's Website at the following link: [INSERT LINK]. Use of the form is not mandatory.

  3.5. The Company shall acknowledge receipt of the complaint without undue delay. A final decision shall be provided without undue delay and no later than two months following receipt of the complaint. In exceptional circumstances where a decision cannot be issued within that period, the User of the Services shall be informed of the reasons for the delay and the revised expected timeframe.

  3.6. If the decision does not satisfy the Client's claim, or satisfies it only in part, the Company shall clearly state the reasons for its decision and provide information on the available remedies.

4. SCOPE OF SERVICES

4.1. The Company acts solely as a crypto-asset service provider and does not act as a bank, credit institution, investment firm, payment institution, electronic money institution, or your fiduciary. The Company provides its crypto-asset services in accordance with Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA). Nothing in these Terms or in connection with the Services shall be construed as the provision of investment advice, investment recommendations, portfolio management, or any other form of regulated investment service.

4.2. The Company does not provide payment services within the meaning of PSD2 and does not issue payment instruments. To the extent that fiat currency transfers, card processing services, or payment account services are required for the execution of Transactions, such services are provided by licensed payment institutions or credit institutions operating in accordance with PSD2 or equivalent regulatory frameworks. The Company acts solely as a technical service provider and a commercial interface in relation to such fiat services. Fiat payment services may be subject to separate terms and conditions of the relevant licensed payment service provider. The Company remains responsible for its regulatory obligations under MiCA and applicable crypto-asset legislation, but does not assume the regulatory obligations of licensed payment institutions providing fiat services.

5. SERVICES

5.1. The Company provides the following crypto-asset services in accordance with the authorisation granted under MiCA:

5.1.1. Custody and administration of crypto-assets on behalf of clients:

• 5.1.1.1. Implementation of multi-layered security protocols, including cold storage solutions, multi-factor authentication (MFA), and systems tested through penetration testing.
• 5.1.1.2. Business Wallets: a sub-category of Top-up Accounts that may be used for the most popular currencies for the convenience of Business Users.

5.1.2. Exchange of crypto-assets for funds (crypto-to-fiat) and exchange of crypto-assets for other crypto-assets (crypto-to-crypto):

• 5.1.2.1. Exchange Services: secure and efficient spot trading, crypto-to-crypto exchange, crypto-to-fiat (and vice versa) conversion, and advanced trading tools tailored to different Business User and Retail Customer profiles.
• 5.1.2.2. Fiat On-Ramp and Off-Ramp Solutions: integration with payment gateway systems and financial institutions to facilitate seamless transactions between fiat currencies and crypto-assets.

5.1.3. Conversion and Withdrawal Services: enables the holding of balances in more than one crypto-asset within an Account; the selected currency will not be converted after being deposited into a specific crypto-asset balance. It also enables the conversion of crypto-asset balances into other crypto-assets within the CRM system or via API. Exchange rate risk mitigation and balance conversion functionalities are available through automatic rate locking mechanisms.

5.1.4. Transfer of crypto-assets on behalf of clients.

5.2. The exchange rate applicable to a particular order is guaranteed for the period displayed on the Platform, which shall be no less than 10 seconds. Upon expiry of that period, the exchange rate may automatically change depending on market conditions.

5.3. In addition to the Services, a Reporting Generation functionality is available, enabling the creation of periodic or one-off reports on client positions and their delivery by email or direct download. The content and structure of reports may vary depending on the selected filters. The Company provides Users of the Services with continuous access to information regarding their positions through their user account on the Platform, where each User of the Services may monitor current balances and transaction history at any time. In addition, the Company automatically generates quarterly position reports and delivers them to clients' registered email addresses on a durable medium without requiring a request. Users of the Services may also request the generation and delivery of such reports at any time, whereby the content and structure of the reports may be customised according to the selected filters.

5.4. The Services may only be used following successful KYC/KYB Verification on the Platform.

5.5. An instruction for the execution of any Service shall be deemed final and irrevocable at the moment the User of the Services accepts the fixed exchange rate or other applicable terms by clicking the "Execute" button.

5.6. The Company may cooperate with licensed payment institutions, banks, and liquidity providers in order to facilitate fiat currency settlements, card payments, and conversions between different currencies. Such third-party services are subject to their own regulatory authorisations and contractual terms. The Company remains responsible for ensuring that such partners apply equivalent standards of compliance with anti-money laundering and counter-terrorism financing (AML/CFT) requirements, data protection requirements, and operational integrity standards in accordance with European Union law.

5.7. The Services described herein may not be available in all jurisdictions. Access is restricted or prohibited for residents of jurisdictions subject to comprehensive international Sanctions or where crypto-asset services are restricted or prohibited under applicable law. The User of the Services bears sole responsibility for determining the legality of the use of the Services in its jurisdiction and for complying with all applicable local licensing, reporting, and tax obligations.

5.8. The Company reserves the right, at any time, to modify, suspend, or discontinue any Services, modules, or supported crypto-assets in order to comply with legal, technical, or commercial requirements. Such changes shall not affect Transactions that have already been confirmed and settled before the effective date of the change.

5.9. The Company shall ensure that any differentiation in pricing, access to services, or execution of exchange transactions is based solely on objective, proportionate, and pre-defined criteria.

5.10. The Company may, in whole or in part, refuse to provide a quote or execute an exchange transaction where necessary to comply with applicable law, regulatory obligations, including AML/CFT requirements, internal risk management limitations, or operational or liquidity constraints.

6. CLIENT ASSET CUSTODY MODEL AND CONSENT

6.1. The Company does not use the crypto-assets of Users of the Services for its own account or for the account of any other person or third-party client.

6.2. Crypto-assets belonging to Users of the Services are held in wallets under an omnibus custody model, with an initial degree of individualisation through transit wallets.

6.3. Each User of the Services is assigned a unique transit wallet for each supported blockchain network. Transit wallets are unique to each User of the Services and are used exclusively for receiving incoming deposits.

6.4. During the transit wallet stage, AML/CFT screening and transaction monitoring are performed on incoming assets before further processing.

6.5. Upon successful completion of such checks, the assets are transferred to the Company's wallets, which are omnibus in nature, meaning that they collectively hold the crypto-assets of multiple clients.

6.6. Notwithstanding the use of omnibus wallets, the Company maintains an Internal Ledger System which records the individual balances and entitlements of each User of the Services, ensures full segregation at the record-keeping level, and enables accurate and up-to-date identification of the assets of each individual User of the Services at all times.

6.7. By entering into a contract with the Company for the provision of custody services, the User of the Services expressly acknowledges that it has been informed of the custody model described in paragraphs 1 to 6 of this Article and consents thereto.

6.8. The User of the Services specifically acknowledges that its crypto-assets are held in omnibus wallets together with the assets of other clients and that segregation is not ensured at the blockchain record level, but solely through the Company's Internal Ledger System.

6.9. The User of the Services acknowledges that it understands that, in the event of the Company's insolvency or other circumstances preventing the disposal of assets, its crypto-assets may be exposed to risks arising from the omnibus custody model, including potential difficulties in the individual identification and recovery of assets. In such circumstances, the Company shall be liable for the loss of client assets in accordance with the applicable provisions governing limitations of liability.

6.10. The consent referred to in this Article is a condition for the use of the Company's custody services and may not subsequently be withdrawn without a prior written request for the transfer or withdrawal of assets.

6.11. Clients' funds are held on an omnibus account opened for that purpose with KentBank d.d., OIB: 73656725926, IBAN: HR10 4124 0031 3990 1185 8, SWIFT: KENBHR22, while segregation of assets is ensured through the Company's Internal Ledger System.

6.12. The User of the Services acknowledges that it understands that, in the event of the Company's insolvency or other circumstances preventing the disposal of assets, its assets may be exposed to risks arising from the omnibus custody model, including potential difficulties in the individual identification and recovery of assets. In such circumstances, the Company shall be liable for the loss of client assets in accordance with the applicable provisions governing limitations of liability.

6.13. By entering into a contract for the provision of custody services with the Company, the User of the Services expressly acknowledges that it has been informed of the funds custody model described in the preceding paragraphs of this Article and of the risks arising therefrom.

7. CONCLUSION OF THE CONTRACT AND CONTRACTUAL DOCUMENTATION

7.1. The contractual relationship between the Company and the User of the Services is established exclusively through the Company's Website. No contract is concluded in paper form.

7.2. Use of the Website is governed by separate Website Terms of Use available on the Company's Website.

7.3. The contract is concluded in two stages:

• 7.3.1. Whitely Account Registration – By accepting these General Terms and Conditions during registration, ticking the relevant confirmation box, and successfully completing the KYC/KYB Verification process, the User of the Services enters into a contract with the Company. These General Terms and Conditions constitute that contract.

• 7.3.2. Service Activation – The use of individual Services is governed by these General Terms and Conditions and by separate special terms applicable to the relevant Service. The special terms are presented to the User of the Services upon activation of each Service and are available on the Company's Website. The contract for a particular Service shall be deemed concluded when the User of the Services accepts these General Terms and Conditions and the applicable special terms displayed before activation of that Service by clicking the relevant acceptance button.

  7.4. The contractual documentation consists of:

• 7.4.1. these Terms;

• 7.4.2. the Privacy Policy ([insert link]);

• 7.4.3. the Fee Schedule ([insert link]);

• 7.4.4. the Risk Disclosure Statement ([insert link]);

• 7.4.5. the summary of the Company's Custody and Administration Policy ([insert link]);

• 7.4.6. for the Custody and Administration of Crypto-Assets on Behalf of Clients Service – the Custody Agreement;

• 7.4.7. for the Transfer Service – the Crypto-Asset Transfer Agreement.

  7.5. No separate contract is concluded for Exchange Services; such Services shall be governed by these General Terms and Conditions.

  7.6. Transfers of crypto-assets are carried out through the Platform.

  7.7. The Company maintains records of contract formation which, for each User of the Services, include the timestamp of acceptance, the IP address from which acceptance was given, and activity logs evidencing when and how the User of the Services accepted the contractual documentation.

  7.8. In the event of any inconsistency between the documents forming part of the contractual documentation, the following order of precedence shall apply: these General Terms and Conditions, followed by the special terms applicable to the relevant Service.

8. WEBSITE USER REGISTRATION, KYC/KYB VERIFICATION, AND ACCOUNT USE

8.1. In order to access and use the Services, a Website User must complete the registration process by providing the required information and documents through the Website or any authorised integration channel. Upon registration, a Whitely Account is opened, serving as a secure digital interface through which the Website User may access and use the Whitely Services.

8.2. During the KYC/KYB Verification process, the Website User is required to provide accurate and complete information and authentic documentation. The Website User acknowledges that the submission of inaccurate or incomplete information, or false or expired documents, may prevent successful registration or restrict future access to the Services.

8.3. When you intend to open an Account, we may request contact details such as your full name, telephone number, email address, and other information relating to you. In addition, we will require you to undergo our standard KYC Verification process, which may include the following:

• 8.3.1. providing a passport or other identification document issued by a competent governmental authority;

• 8.3.2. completing a liveness verification process;

• 8.3.3. providing documentation evidencing the source of funds;

• 8.3.4. the results of KYC screening or politically exposed person (PEP) screening, including information collected by our service providers;

• 8.3.5. other personal data provided during KYC, compliance, or verification procedures (including supplementary information), or similar information.

  8.4. Where applicable, we may also request information regarding your business, including the legal name of the business entity or its doing-business-as (DBA) name, the physical business address, the company's website, and similar information. In such a case, you and your company must undergo a Know Your Business (KYB) Verification process, which may include the provision of the following:

• 8.4.1. corporate documents of the company (Certificate of Incorporation or Articles / Memorandum of Association, extract from the court register or other competent register, resolution on the appointment of directors or a similar document, register of shareholders/members and beneficial owners);

• 8.4.2. documents relating to the director(s) and ultimate beneficial owner(s) (UBOs) (passport, identity card or other identification document issued by a competent governmental authority, proof of residential address – utility bill or bank statement not older than three months);

• 8.4.3. minutes or a resolution of the board of directors or director(s)/power of attorney, or other legal instrument confirming your authority to represent the company in dealings with us;

• 8.4.4. proof of address (lease agreement; utility bill not older than three months).

  8.5. The information you provide when opening an Account must be true, accurate, and complete, and you must notify us of any changes to such information within ten (10) Business Days.

  8.6. The Company reserves the right to refuse registration of your Account, subsequently close your Account, or restrict the provision of Services if you fail to provide or maintain accurate, complete, and satisfactory information.

  8.7. You retain sole control over your Access Credentials and bear sole responsibility for their storage and safekeeping, the security and confidentiality of the Access Credentials, the authorisation of all Transactions, and the protection of your Account and related access mechanisms against unauthorised access or use.

  8.8. Upon establishing a business relationship with us and/or before and/or after the execution of any individual Transaction through our Services, we shall have the right to request from you any documents and/or information, including, without limitation, documents and information evidencing the legal basis and sources (origin) of your funds and other assets, the purpose and intended nature of your business relationship with us, the nature of the business activities and management (ownership) structure of the legal entity you represent, its ultimate beneficial owners, and/or any other documents and information to the extent necessary to ensure compliance with applicable AML/CFT requirements.

  8.9. We may require additional information from you in order to verify your identity and assess risk, such as your date of birth, tax identification number, or an identification document issued by a competent governmental authority. We may also obtain information about you from third parties, such as credit registries and identity verification service providers. We reserve the right to refuse registration of your Account or subsequently close your Account if you fail to provide accurate, complete, and satisfactory information. For the purpose of verifying information provided during the registration and/or Account Verification process, we may request information from various third parties, including credit registries and identity verification service providers.

  8.10. By accepting these Terms, you authorise us to obtain information about you through third parties and acknowledge that, for this purpose, we may be required to share information previously provided by you.

  8.11. The Company may, from time to time, engage third parties to assist in various aspects of the provision of our Services. You acknowledge and agree that the use of the Services may require the sharing of your information with such third parties, which may assess your eligibility to use the Services in accordance with their own verification procedures.

  8.12. In accordance with our Policies, the Company prohibits the opening of Accounts and does not process Transactions for Sanctioned Persons, nor for nationals, residents or persons present in countries where Transactions are prohibited by international Sanctions or national laws, or in countries which, based on various criteria selected by the Company (such as Transparency International's Corruption Perceptions Index, FATF warnings, countries with weak anti-money laundering and counter-terrorism financing regimes that have been designated by a Sanctions Authority as Sanctioned Persons or Sanctioned Countries, and similar criteria), are considered to present a high AML/CFT risk.

  8.13. Upon successful completion of the verification process, the Website User shall receive confirmation and Access Credentials through the communication channel specified during registration. Such Access Credentials are personal and non-transferable. The User of the Services shall be solely responsible for maintaining the confidentiality of its login credentials and for all actions taken through its Account, whether authorised or unauthorised.

  8.14. The Company reserves the right to periodically verify the identity, ownership structure, or business activities of a User of the Services in order to ensure ongoing compliance with applicable laws and regulations. The User of the Services shall cooperate without undue delay in any such verification process and shall, upon request, provide updated documents or information.

  8.15. The Company may refuse to open an Account or provide access to the Services if the Website User does not meet the eligibility requirements, fails to complete the verification process, or is located in a jurisdiction where the provision of crypto-asset services or payment services is restricted or prohibited. The Company shall not be required to disclose the reasons for such refusal where prohibited by law.

  8.16. The User of the Services shall not permit any third party to access or operate the Account without the Company's prior written approval. Any unauthorised use, transfer, or assignment of Account access rights shall constitute a material breach of these Terms. The User of the Services shall immediately notify the Company of any suspected unauthorised access, data breach, or misuse of Access Credentials.

  8.17. The Company may suspend or restrict a User of the Services' Account without prior notice if it detects suspicious activity, unsuccessful verification, a breach of these Terms, or potential exposure to legal or financial risk. Such suspension shall remain in effect until the matter has been resolved to the Company's satisfaction or until the Account is terminated in accordance with Article 13 of these Terms.

  8.18. Each User of the Services may maintain only one active Account unless expressly authorised otherwise by the Company. Multiple registrations, the use of false identities, or circumvention of Service restrictions are strictly prohibited and may result in the termination of all related Accounts.

  8.19. Access to the Account and the Services may be protected by two-factor authentication (2FA) or other advanced security mechanisms. The User of the Services is responsible for enabling and maintaining such measures and for ensuring the security of all devices, networks, and environments through which the Account is accessed.

  8.20. The Company shall collect, store, and use your personal data for the purposes set out in the Privacy Policy. In the course of providing the Services, the Company may also use software and other tools and resources provided by third parties (independent service providers) (hereinafter referred to as: the Service Providers), which may also collect personal data of Website Users.

The process of collecting, processing, storing, and using personal data is governed by the privacy policy of the relevant Service Provider.

The privacy policies of the software products of the Service Providers are available at the following links:

• Zendesk: https://www.zendesk.co.uk/company/agreements-and-terms/privacy-notice
• Sumsub: https://sumsub.com/privacy-notice

This list of Service Providers is not exhaustive and may be amended from time to time. In any event, Website Users may review the privacy policies of the Service Providers engaged by the Company on their respective official websites.

9. REPRESENTATIONS AND WARRANTIES OF THE USER OF THE SERVICES

9.1. The User of the Services represents and warrants that:

• 9.1.1. all information and documents provided to the Company are true, accurate, complete, and up to date, and that it shall notify the Company of any material change without undue delay and, in any event, no later than ten (10) Business Days after such change occurs;

• 9.1.2. it has full legal capacity and authority to enter into these Terms and use the Services;

• 9.1.3. all funds, crypto-assets, and other assets used in connection with the Services originate from lawful sources and that it shall at all times comply with applicable AML/CFT regulations, anti-fraud and anti-corruption laws and regulations, and Sanctions requirements;

• 9.1.4. it shall use the Services solely for lawful commercial or operational purposes and shall not use them to conceal the origin of funds, facilitate prohibited transactions, or engage in activities that may expose the Company or other Users of the Services to reputational, legal, or financial risk;

• 9.1.5. it acknowledges that the loss, theft, compromise, or unauthorised use of Access Credentials may result in the permanent and irreversible loss of crypto-assets.

  9.2. The Authorised User represents and warrants that:

• 9.2.1. it is duly authorised to bind the Business User on whose behalf it acts;

• 9.2.2. all actions taken through the Account constitute valid and legally binding obligations of that Business User.

  9.3. The User of the Services agrees that the representations, warranties, and acknowledgements contained in this Article constitute essential conditions for the provision of the Services. Any inaccurate statement, omission, or breach of these obligations may result in the immediate suspension or termination of the Account in accordance with Article 13 of these Terms.

10. RISK DISCLOSURE

10.1. The User of the Services acknowledges that the value of crypto-assets is highly volatile and may fluctuate significantly. The User of the Services confirms that it understands and accepts the economic, technological, and regulatory risks associated with holding, trading, or receiving crypto-assets and that it is able to bear the potential financial consequences of such risks.

10.2. The User of the Services understands that the use of blockchain technology involves inherent technical limitations and risks, including transaction delays, network congestion, cyberattacks, smart contract vulnerabilities, and protocol changes. The Company has no control over the operation of blockchain networks and shall not be liable for any losses arising from such external factors.

10.3. Delays in transaction processing may occur due to congestion within the relevant blockchain networks. Transaction confirmation times and associated fees are subject to real-time network conditions. All users are equally affected by such external factors. Transactions are processed on a first-come, first-served basis, meaning that Users of the Services' orders are executed in the order in which they are received, without any possibility for a particular User of the Services to bypass the queue or otherwise obtain priority in processing. Transactions are not modified, expedited, or delayed for specific Users of the Services.

10.4. The User of the Services acknowledges that blockchain transactions are irreversible once they have been broadcast and confirmed. The Company has no ability to cancel, reverse, or modify completed transactions. The User of the Services is solely responsible for verifying recipient addresses, transaction amounts, and network parameters before confirmation.

10.5. The User of the Services is responsible for understanding and fulfilling all tax, accounting, and reporting obligations arising from the use of the Services and any crypto-asset transactions. The Company does not provide financial, tax, or accounting advice and assumes no responsibility for the User of the Services' compliance with such obligations.

10.6. The User of the Services understands that the regulatory treatment of crypto-assets and related services may vary across jurisdictions and may change over time. It is the sole responsibility of the User of the Services to ensure that its use of the Services complies with the laws and licensing requirements applicable in its jurisdiction.

10.7. The User of the Services acknowledges that the Company does not provide investment, financial, or legal advice. Any information provided through the Website, the Account, or support channels is for general informational purposes only and shall not be construed as a recommendation or an inducement to participate in any financial or investment activity.

10.8. All Users of the Services acknowledge that they have read and understood this Article and fully accept all risks associated with the use of the Services, including operational, technological, market, and regulatory risks associated with crypto-assets and payment processing.

10.9. The Risk Disclosure Statement is available on the Website as a separate document.

11. PAYMENTS AND FEES

11.1. All payments and Transactions carried out through the Services shall be processed exclusively in accordance with these Terms, the technical parameters of the relevant blockchain network, and the contractual framework applicable to the entity providing the relevant Service. By initiating or authorising a Transaction, the Business User or Retail Customer authorises the Company and its partners to process, record, convert, or settle such Transaction on behalf of the Business User or Retail Customer in accordance with applicable law and these Terms.

11.2. Information relating to completed Transactions shall be available through the Whitely Account interface for the period determined by the Company. The Business User or Retail Customer shall review such records and report any discrepancy within thirty (30) calendar days from the date of the relevant Transaction. Failure to notify the Company within such period shall be deemed acceptance of the records as accurate and final.

11.3. Users of the Services shall not send Unsupported Payments, unsupported crypto-assets or tokens, nor use unsupported blockchain networks in connection with wallet addresses generated through the use of the Services. Any such transfer shall be made solely at the risk of the Retail Customer or Business User. The Company and its partners shall have no responsibility for the identification, recovery, or reimbursement of unsupported or improperly formatted payments.

11.4. A Transaction may, where technically feasible, be rejected or reversed if, in the Company's reasonable opinion, it involves an incorrect amount, an unsupported currency, an incorrect network, an invalid wallet address, an insufficient network fee, unsuccessful verification, or any other circumstance rendering the Transaction technically or legally invalid. Rejected Transactions shall not be credited to the User of the Services' balance, and the Company shall not be liable for any losses arising from such errors.

11.5. The following operational statuses may appear in the Whitely Account to indicate the stages of Transaction processing:

• Pending – the Transaction has been initiated but has not yet been confirmed by the blockchain network;
• Processing – the Transaction is undergoing verification and is pending settlement;
• Complete – the Transaction has been confirmed and credited to the User of the Services' balance;
• Declined – the Transaction has been rejected or deemed invalid;
• Cancelled – the Transaction has been cancelled by the User of the Services before confirmation;
• Timeout – the Transaction was not confirmed within the permitted time period.

These statuses are provided for informational purposes only and may vary depending on network performance and the outcome of risk assessment procedures.

11.6. All blockchain Transactions are final and irreversible once confirmed. The Company has no technical ability to modify, cancel, or reverse completed Transactions. The User of the Services is solely responsible for verifying all Transaction details before submission, including recipient addresses, network types, and transaction amounts.

11.7. The Company may aggregate or batch multiple Transactions for operational efficiency or liquidity management purposes. Such aggregation shall not affect the validity of individual Transactions, and settlement reports shall include all relevant details and applicable Fees.

11.8. All Fees and charges associated with Transactions shall be automatically displayed and deducted from the credited amounts in accordance with the Fee Schedule displayed in the Account or otherwise communicated to the User of the Services. Network fees ("gas fees") are determined by the rules of the underlying blockchain network and are beyond the Company's control.

11.9. In all cases, the applicable Fee shall be communicated to the Business User or Retail Customer by being displayed before the confirmation of the relevant Transaction, order, or payment.

11.10. The Company applies applicable Fees to Services provided through the Website and/or the Platform. The User of the Services irrevocably authorises the Company to charge the applicable Fees to its Account. Detailed information regarding the Fee structure is available in the Company's Fee Schedule.

11.11. The Company may suspend or cancel any Transaction if it reasonably suspects fraud, money laundering, a breach of Sanctions, or any violation of these Terms. In such circumstances, the Company may also freeze the related balance and report the matter to the competent authorities in accordance with applicable laws and regulations.

12. TAXES AND FINANCIAL REPORTING

12.1. All Fees charged by the Company for the use of the Services are exclusive of any applicable taxes, duties, levies, or other public charges. The User of the Services shall be solely responsible for paying, or reimbursing the Company for, any applicable taxes that may arise in connection with the use of the Services, including, without limitation, value-added tax (VAT), sales tax, withholding tax, or similar charges imposed by a competent authority.

12.2. If the User of the Services claims an exemption from any tax obligation, such exemption must be supported by a valid tax exemption certificate or other documentation acceptable to the competent authority. The Company reserves the right to reject any claim for tax exemption that is incomplete, invalid, or incapable of verification.

12.3. The User of the Services acknowledges and agrees that it is solely responsible for determining, reporting, and fulfilling its tax obligations in accordance with the laws of its jurisdiction. This includes, without limitation, income tax, profit tax, VAT, or any other fiscal obligations associated with the sale of goods and services, the receipt of crypto-assets, the conversion of crypto-assets, or the realisation of gains or losses arising from Transactions.

12.4. The Company does not provide accounting, tax, or legal advice, and nothing contained in these Terms shall be construed as such advice. The User of the Services should consult independent professional advisers to ensure compliance with all applicable tax and reporting obligations arising from its activities on or through the Services.

12.5. All Transaction records, invoices, and statements made available through the Account are provided solely for operational and informational purposes. The accuracy, completeness, and adequacy of such data for accounting or tax reporting purposes shall remain the sole responsibility of the User of the Services.

12.6. As the Website operates as a payment gateway and technical service provider, responsibility for the submission of financial statements, tax returns, and related regulatory reports to the competent authorities rests solely with the User of the Services. The Company shall not be liable for any fines, penalties, or losses arising from the User of the Services' failure to comply with such obligations.

12.7. The User of the Services undertakes to maintain complete and accurate financial and transaction records for at least the minimum retention period prescribed by the laws of its jurisdiction, or for such longer period as may be required by the Company in order to comply with its legal obligations.

12.8. The Company may disclose information relating to Transactions, balances, or related activities of the User of the Services to tax authorities, regulators, or supervisory authorities where required by law, regulation, or an intergovernmental agreement, including, without limitation, anti-money laundering and tax transparency frameworks such as the OECD Crypto-Asset Reporting Framework (CARF).

12.9. If the Company is required by law to withhold or collect any tax on behalf of a competent authority, such amount may be deducted from the User of the Services' balance before settlement. The Company shall provide reasonable notice and appropriate documentation in respect of any such withholding.

12.10. The Company reserves the right to issue electronic invoices and accounting reports in digital form. Such documents shall be deemed valid and legally binding in accordance with applicable law.

13. TERMINATION AND SUSPENSION

13.1. The Company may suspend or terminate the provision of any or all Services to a Business User or Retail Customer at any time if, in its reasonable judgment, such action is necessary to protect the integrity of the Services, ensure compliance with applicable law, or prevent unlawful or fraudulent activities. Suspension or termination may take effect immediately and without prior notice in the event of a suspected breach of these Terms, non-compliance with AML/CFT requirements, or fraudulent conduct.

13.2. The Company may also suspend or terminate an Account upon written notice to the Business User or Retail Customer if the Account has a zero balance and has remained inactive for a continuous period of at least one hundred and twenty (120) calendar days. The Company shall make reasonable efforts to notify the Business User or Retail Customer before permanently deleting the Account. Users of the Services with inactive Accounts shall continue to receive periodic information regarding the status of their positions. The Company shall generate and deliver, on a quarterly basis, a report on positions and transaction history to the registered email address of each User of the Services, including users of inactive Accounts, on a durable medium within the meaning of applicable law.

13.3. The Company may terminate the provision of the Services upon fourteen (14) days' prior notice to the Business User or Retail Customer for any other reason, including business, regulatory, or risk management reasons.

13.4. The Company may suspend or restrict access to the Account and its associated functionalities if:

• the Business User or Retail Customer fails to provide the documentation requested as part of ongoing verification or compliance review procedures;
• the Company is required to do so by a competent authority, court order, or applicable law;
• there is reasonable suspicion that the Services are being misused for the purposes of money laundering, terrorist financing, or other criminal offences;
• the access of the Business User or Retail Customer presents an operational, reputational, or security risk to the Company or its partners.

Where permitted by law, the Company may notify the Business User or Retail Customer of the reasons for such suspension and the conditions for reactivation.

13.5. The Business User or Retail Customer may terminate its Account at any time through the Website or by providing the Company with at least fourteen (14) calendar days' prior written notice. The Company may require reasonable identity verification of the Business User or Retail Customer before processing such termination.

13.6. In the event of termination by either Party, the following shall apply:

• all rights granted to the Business User or Retail Customer under these Terms, including access to the Services, shall terminate immediately;

• the Business User or Retail Customer shall withdraw any remaining balances within twenty-four (24) hours from the effective date of termination (the "Withdrawal Period");

• the Company reserves the right to charge a termination fee equal to the remaining balance if the funds are not withdrawn within the Withdrawal Period;

• the Business User or Retail Customer shall immediately destroy or delete all copies of any Software, documentation, or confidential materials provided by the Company;

• the Company shall delete or anonymise the Account in accordance with its data retention policies, subject to its obligation to retain records for regulatory, legal, or dispute resolution purposes.

  13.7. The Company shall not be liable for any losses, damages, or costs arising from the suspension or termination of the Services, except for direct refunds of prepaid and unused Fees expressly owed to the Business User or Retail Customer at the time of termination.

  13.8. The Business User or Retail Customer shall be solely responsible for transferring or otherwise securing all Balances before the termination or suspension of the Account. The Company shall not be liable for any unwithdrawn, inaccessible, or lost assets following the expiry of the Withdrawal Period.

  13.9. Any termination by the Company pursuant to this Article shall be without prejudice to any other rights or remedies available to it under applicable law or these Terms.

14. INTELLECTUAL PROPERTY AND CONFIDENTIALITY

14.1. All intellectual property rights, proprietary materials, and technological components of the Services, including, without limitation, the Software, the Platform, the Website, interfaces, databases, design, layout, documentation, visual identity, and all related content (collectively, the "Materials"), shall remain the sole and exclusive property of the Company and its Affiliates.

14.2. By accessing and using the Services, the Business User or Retail Customer is granted a limited, non-exclusive, non-transferable, and revocable right to use the Software and the Materials solely for the purpose of accessing the Services in accordance with these Terms. Such right does not transfer any ownership or intellectual property rights to the Business User or Retail Customer.

14.3. The Authorised User and the User of the Services acknowledge that all trade names, company names, trademarks, logos, and service marks are the property of the Company or its Affiliates and are protected under applicable intellectual property laws. No person may copy, imitate, modify, or use such marks in any form without the Company's prior written consent.

14.4. The Authorised User and the User of the Services shall not reverse engineer, decompile, disassemble, copy, translate, adapt, modify, or create derivative works from any part of the Software or the Materials. Any unauthorised access to or use of the source code, architecture, or functionality of the Services is strictly prohibited.

14.5. Any suggestions, improvements, feedback, or other information provided to the Company by any person in relation to the Software, the Platform, or the Services shall become the sole property of the Company. The Company may freely use such feedback for product development or business improvement purposes without any obligation or compensation to the person providing it.

14.6. The Authorised User and the User of the Services acknowledge that the Company may use open-source libraries, APIs, and third-party integrations within the Software. The use of such components does not grant any person any rights other than those expressly permitted under the applicable open-source licences.

14.7. The Authorised User and the User of the Services undertake to maintain the confidentiality of all non-public information obtained through the Services, including, without limitation, business processes, technical documentation, pricing structures, operational methods, or client data ("Confidential Information"). The Authorised User and the User of the Services shall not disclose, copy, or reproduce such information except where necessary for the lawful use of the Services or with the Company's prior written consent.

14.8. The Authorised User and the User of the Services shall implement reasonable technical and organisational measures to protect Confidential Information provided by the Company against unauthorised access, disclosure, or use. Any breach or suspected breach of confidentiality shall be reported to the Company without undue delay.

14.9. The confidentiality obligations set out in these Terms shall survive the termination or expiry of these Terms for a period of five (5) years or such longer period as may be required under applicable law, whichever is longer.

14.10. The Company may disclose the Confidential Information of the Authorised User or the User of the Services only where required under applicable law, pursuant to a lawful order of a competent authority, or for the purpose of complying with regulatory and supervisory obligations, including obligations arising under MiCA, the Anti-Money Laundering and Counter-Terrorism Financing Act, the Act on Restrictive Measures, or the GDPR. The Company shall disclose only the minimum information necessary and, where permitted, shall notify the Authorised User or the User of the Services of such disclosure.

14.11. The Authorised User and the User of the Services acknowledge that the Company may charge reasonable administrative or technical costs for providing copies of, or evidence relating to, such disclosures if requested by that person, unless prohibited by law.

14.12. Nothing in these Terms shall prevent the Company from using aggregated or anonymised data derived from the operation of the Services for analytical, statistical, or commercial purposes.

15. AMENDMENTS TO THESE GENERAL TERMS AND CONDITIONS

15.1. The Company reserves the right to amend, supplement, or update these Terms, including any policies incorporated by reference herein, at any time and at its sole discretion. Any such amendments shall be published on the Website and shall take effect on the earlier of:

• fourteen (14) calendar days following their publication on the Website; or

• the User of the Services' express acceptance of the amended Terms when accessing the Services.

  15.2. The Authorised User and the User of the Services shall review the Terms before each access to the Account or the Services. Continued use of the Services following the effective date of any amendments shall constitute acceptance of the amended Terms.

  15.3. If the User of the Services does not accept the amended Terms, it shall not be able to complete registration or continue using the Services. Upon rejection of the amended Terms, the contractual relationship shall be deemed terminated, and the User of the Services shall only be entitled to withdraw any remaining funds from its Account.

16. CHANGES TO FEES, SERVICES, AND PRODUCTS

16.1. The Company may modify, update, or adapt the structure, functionality, content, or technical operation of its Services, including, without limitation, the Software, APIs, interfaces, security protocols, or other system components, without prior notice where such changes are necessary for operational, security, or regulatory reasons.

16.2. The Company reserves the right to introduce new Services or discontinue existing Services, as well as to temporarily suspend the provision of Services for maintenance, upgrades, or improvements. The Company shall make reasonable efforts to provide notice of material changes or interruptions where practicable.

16.3. The Company may amend its Fees, commissions, or other charges applicable to the Services by publishing an updated Fee Schedule on the Website or through the Account interface. Continued use of the Services following such amendments shall constitute acceptance of the updated Fees. By confirming a Transaction, order, or payment, the User of the Services confirms its acceptance of the applicable Fee.

16.4. The User of the Services acknowledges and agrees that all Fees are calculated and applied in accordance with the Fee Schedule in effect at the time the Transaction is processed. The Company shall not be liable for any discrepancies arising from outdated or temporarily stored (cached) Fee information reviewed before execution.

16.5. The Company may, at its sole discretion, offer promotional pricing, discounts, or fee waivers for a limited period or to specific Users of the Services. Such offers are temporary, non-transferable, and may be withdrawn at any time without prior notice.

16.6. The Company may modify its Products, Platform, or Services in order to comply with new legal, technical, or regulatory requirements, including those arising under Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), AMLD6, the laws of the Republic of Croatia, or related regulations. The Authorised User and the User of the Services acknowledge that such changes may affect certain functionalities or the availability of specific features.

16.7. If the Authorised User or the User of the Services does not agree with any amendment to the Terms, Fees, Services, or Products, its sole and exclusive remedy shall be to discontinue use of the Services and close the Account in accordance with Article 13. No compensation or refund shall be payable in respect of Services provided before such termination.

16.8. The Company shall not be liable for any losses, damages, or costs arising directly or indirectly from any modifications, updates, or discontinuation implemented in accordance with this Article, provided that such changes are made in good faith and in compliance with applicable law.

17. SECURITY

17.1. The User of the Services acknowledges and agrees that any access to and use of the Services through its Access Credentials shall be deemed authorised by the User of the Services. The Company shall be entitled to treat all instructions, communications, and Transactions originating from the User of the Services' Account as valid and binding upon the User of the Services.

17.2. The User of the Services shall be solely responsible for maintaining the confidentiality of its Access Credentials, including login details, passwords, authentication codes, API keys, and other security identifiers associated with the Account. The User of the Services shall not disclose, share, or transfer such Access Credentials to any third party without the Company's prior written consent.

17.3. If the User of the Services becomes aware of, or suspects, that an unauthorised person has gained access to its Account or Access Credentials, it shall immediately notify the Company and take all reasonable measures to prevent further unauthorised use. The User of the Services shall remain responsible for all activities and Transactions carried out through the Account until the Company has had a reasonable opportunity to suspend or restrict such access.

17.4. The User of the Services undertakes to enable and maintain all security features offered by the Company, including, where applicable, two-factor authentication (2FA), IP whitelisting, withdrawal protection, and anti-phishing measures. Disabling such features increases exposure to risk, for which the Company shall bear no responsibility.

17.5. The Company implements and maintains commercially reasonable organisational, physical, and technical measures designed to protect its systems, infrastructure, and data against unauthorised access, modification, disclosure, or destruction. Such measures include encryption, firewalls, multi-factor authentication, data segmentation, and real-time monitoring.

17.6. Although the Company takes reasonable measures to ensure the security and integrity of its Services, the User of the Services acknowledges that the transmission of data and crypto-assets through public or peer-to-peer networks, including blockchain networks, is inherently risky and beyond the Company's control. The Company does not warrant that the Services will at all times be free from errors, interruptions, or unauthorised intrusions.

17.7. The User of the Services undertakes to use secure hardware and software environments when accessing the Services, including regularly updated operating systems, antivirus software, and network protection measures. The Company shall not be liable for any damage arising from the User of the Services' failure to maintain an appropriate level of security of its own systems.

17.8. The Company reserves the right to suspend or restrict access to the Services if it reasonably suspects that the User's Account or device has been compromised, is being used for fraudulent activities, or poses a threat to the integrity of the system. The Company may require the User of the Services to undergo re-verification or complete a password reset procedure before access is restored.

17.9. The User of the Services undertakes to notify the Company immediately in the event of the loss, theft, or destruction of any device that enables access to the Account or software associated with the Services. The User of the Services shall also deactivate or sign out such device through the Account dashboard or by contacting the Company's support service.

17.10. The Company continuously monitors its operational infrastructure and third-party integrations in order to detect cybersecurity vulnerabilities. In the event of a security incident affecting the Services, the Company shall take immediate remedial measures and, where required by law, notify affected Users of the Services and the competent supervisory authorities in accordance with its internal policies.

17.11. The User of the Services acknowledges and agrees that certain Transactions may be delayed, rejected, or suspended if the Company identifies unusual or suspicious activity, network errors, or potential security risks. Such measures are taken for the protection of the User of the Services and the integrity of the Services.

17.12. The Company shall not be liable for any losses, damages, or costs arising from security incidents, unauthorised access, or data breaches resulting from circumstances beyond its reasonable control, including vulnerabilities affecting blockchain networks, third-party service providers, or communication systems.

18. ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING REQUIREMENTS

18.1. The Company is committed to full compliance with all applicable laws and regulations relating to the prevention of money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, including:

• Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets;

• Directive (EU) 2018/843 (AMLD5) and Directive (EU) 2018/1673 (AMLD6);

• Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA);

• the Anti-Money Laundering and Counter-Terrorism Financing Act of the Republic of Croatia.

  18.2. The Company establishes and implements a comprehensive anti-money laundering and counter-terrorism financing framework, which includes the following elements:

• customer due diligence (CDD) and enhanced due diligence (EDD) procedures;

• ongoing monitoring of Users of the Services and Transactions;

• ongoing screening for Sanctions and restrictive measures, politically exposed person (PEP) status, and adverse media;

• record-keeping and suspicious activity reporting mechanisms; and

• employee training, internal audits, and compliance oversight.

  18.3. The Company conducts Know Your Customer (KYC) and Know Your Business (KYB) procedures before the activation of any Account. Such procedures include, where applicable, verification of identity, beneficial ownership, source of funds, and the intended purpose of the business relationship. The User shall provide all requested documents, information, and explanations truthfully and without undue delay.

  18.4. The Company conducts ongoing monitoring of all Transactions carried out by Users of the Services. In the event of any unusual, atypical, or high-risk activity, the Company may take appropriate measures, including the temporary suspension of a Transaction or Account, delaying a Transaction, restricting withdrawals, or terminating the Account altogether, as well as making any required reports to the competent authorities.

  18.5. Where the Company determines, suspects, or has reasonable grounds to believe that a Transaction or activity of a User of the Services may be connected with money laundering or terrorist financing, it shall report such activity to the Financial Intelligence Unit – the Anti-Money Laundering Office – in accordance with its legal obligations. The Company shall not be liable to the User for any actions taken in fulfilment of such obligations.

  18.6. The Company reserves the right, at any time, including during the course of the business relationship, to request additional information or documentation from the User of the Services in order to ensure ongoing compliance with anti-money laundering and counter-terrorism financing requirements. Failure to provide such information within a reasonable period may result in the suspension or termination of the Services.

  18.7. The Company may, at its sole discretion, refuse or decline to process any Transaction or establish a business relationship if it reasonably believes that doing so would constitute a breach of anti-money laundering and counter-terrorism financing regulations, Sanctions programmes, or internal compliance policies. In addition, the Company shall be entitled, but not obliged, to request from the User any additional clarification, information, or documentation that it, in its sole discretion, considers necessary to eliminate such concerns.

  18.8. The User represents and warrants that it shall not use the Services for any purpose that violates applicable anti-money laundering and counter-terrorism financing regulations or Sanctions and restrictive measures regulations, including, without limitation, terrorist financing, weapons proliferation, corruption, tax evasion, or fraud.

  18.9. The Company applies a risk-based approach (RBA) to anti-money laundering and counter-terrorism financing compliance, ensuring that the scope, intensity, and frequency of due diligence measures are proportionate to the level of risk associated with the User, its jurisdiction, business activities, and transaction patterns.

  18.10. The Company may, without prior notice, suspend, restrict, or terminate its business relationship with a User of the Services if it determines that the continuation of such a relationship exposes the Company to an unacceptable risk of money laundering or terrorist financing.

  18.11. In accordance with applicable Sanctions and restrictive measures regulations, the Company strictly prohibits the provision of Services to, or the establishment of a business relationship with, any natural or legal person:

• listed on the Consolidated Financial Sanctions List of the European Union or on equivalent international Sanctions lists or lists maintained by a Sanctions Authority;

• located, incorporated, registered, or otherwise operating in jurisdictions subject to comprehensive Sanctions; or

• engaged in activities involving sanctioned sectors or sanctioned counterparties.

  18.12. The Company's anti-money laundering and counter-terrorism financing policies and procedures are reviewed and updated periodically in order to reflect legislative changes, guidance issued by supervisory authorities, and emerging typologies within the crypto-asset and payment services sectors.

  18.13. The User of the Services acknowledges that Transactions may be delayed and that temporary restrictions may be imposed on the Account as a result of anti-money laundering and counter-terrorism financing verification procedures, the application of restrictive measures and/or Sanctions, or statutory reporting obligations. The Company shall not be liable for any losses or damages arising from such compliance measures taken in good faith.

  18.14. All information collected and processed in connection with anti-money laundering and counter-terrorism financing obligations shall be processed in accordance with the Company's Privacy Policy and applicable data protection laws and regulations, including Regulation (EU) 2016/679 (GDPR).

19. LIMITATION OF LIABILITY

19.1. The Company shall not be liable for any loss of funds resulting from the insolvency or failure of the relevant credit institution to meet its obligations, except where such loss arises as a result of the Company's inappropriate selection of, or insufficient oversight over, such institution.

19.2. The User of the Services expressly acknowledges that the use of crypto-assets and the Services involves operational, technological, and market risks that are beyond the Company's control. These include, without limitation, blockchain network delays, network congestion, market volatility, cyberattacks, regulatory changes, and failures of third-party service providers. To the fullest extent permitted by applicable law, the Company shall not be liable for any loss or damage arising from such external factors.

19.3. The Services, the Software, and the Materials are provided on an "as is" and "as available" basis. To the fullest extent permitted by applicable law, the Company makes no representations, warranties or conditions, whether express or implied, including any implied warranties of merchantability, fitness for a particular purpose, accuracy, completeness, reliability or non-infringement of third-party rights. The User of the Services assumes full responsibility for its decisions and actions taken in connection with the use of the Services.

19.4. To the fullest extent permitted by applicable law, the Company shall not be liable for:

• 19.4.1. any interruption, delay, error, or failure in the operation of the Services, including system unavailability, blockchain network congestion, issues affecting third-party networks, or failures of third-party services or external systems;

• 19.4.2. any unauthorised access to, loss, theft, or corruption of data, Access Credentials, or crypto-assets, as well as any other security breaches attributable to the User of the Services;

• 19.4.3. any loss of profits, revenue, goodwill, or anticipated savings; or

• 19.4.4. any indirect, consequential, special, or punitive damages, whether or not such damages were foreseeable, even if the Company has been advised of the possibility of such damages.

  19.5. The User of the Services acknowledges that all actions and Transactions carried out through its Account are solely its responsibility. The Company shall not be liable for any damage arising from the User of the Services' failure to maintain appropriate security measures, protect its Access Credentials, or comply with operational instructions.

  19.6. To the fullest extent permitted by law, the total aggregate liability of the Company for any claims, losses or damages arising out of or in connection with these Terms, the Services or any Transaction shall be limited to the total amount of Fees paid by the User of the Services to the Company during the thirty (30) days immediately preceding the event giving rise to the claim. Any claim exceeding such limitation shall be deemed irrevocably waived.

  19.7. The Company shall not be liable for the acts or omissions of third parties, including liquidity providers, payment processors, or blockchain network operators, nor for any losses or damages caused by failures of external systems or regulatory actions beyond its control.

  19.8. The limitations of liability set out in these Terms shall apply irrespective of the legal basis of the claim, whether arising from contract, non-contractual liability, negligence, breach of statutory duty, or otherwise, and shall survive the termination or expiry of these Terms.

  19.9. Nothing in these Terms shall exclude or limit liability where such exclusion or limitation is prohibited by applicable law, including liability for gross negligence, fraud, or wilful misconduct.

20. INDEMNIFICATION AND SET-OFF

20.1. The Authorised User and the User of the Services undertake to fully indemnify, defend and hold harmless the Company, its Affiliates, third-party liquidity providers, directors, members of management, employees, agents and contractors (collectively, the "Indemnified Parties") from and against any and all losses, damages, liabilities, claims, demands, actions, penalties, fines, costs and expenses (including reasonable legal and professional fees) arising out of or in connection with:

• 20.1.1. any breach of these Terms or of any representation, warranty, or obligation contained herein by the Website User, the Authorised User, or the User of the Services;

• 20.1.2. any negligent, unlawful, fraudulent, or improper act or omission of the Website User, the Authorised User, or the User of the Services, or of any person acting on their behalf;

• 20.1.3. any claim, demand, or proceeding brought by a third party arising out of or relating to the activities, products, services, or Transactions of the User of the Services facilitated through the Services; and

• 20.1.4. any failure of the Website User, the Authorised User, or the User of the Services to comply with applicable laws, regulations, or orders of competent authorities.

  20.2. The Authorised User and the User of the Services undertake to cooperate fully with the Company in the defence of any claim, investigation, or proceeding. The Company reserves the right to assume exclusive control of the defence and settlement of any matter otherwise subject to indemnification by the User, at the User's expense.

  20.3. The Authorised User and the User of the Services shall not enter into any settlement or otherwise resolve any claim that may result in liability for the Company without the Company's prior written consent. Any unauthorised settlement shall be null and void and shall have no legal effect with respect to the Company.

  20.4. The indemnification obligations set out in this Article shall survive the termination or expiry of these Terms and shall remain in effect until all potential claims or liabilities arising therefrom have been fully extinguished in accordance with applicable law.

  20.5. To the extent permitted by applicable law, the Company may, at its sole discretion and without prior notice, set off against, or deduct from, any Balance, settlement funds, or other amounts payable to the User any amounts that are due, or are reasonably expected to become due, to the Company as a result of:

• 20.5.1.1. losses, damages, or costs incurred by the Company as a result of a breach of these Terms;

• 20.5.1.2. Transaction adjustments or reversals;

• 20.5.1.3. penalties, fines, or costs imposed by regulatory authorities or third parties as a consequence of the acts or omissions of the Authorised User or the User of the Services; or

• 20.5.1.4. any other payment obligation or indemnification obligation owed by the Authorised User or the User of the Services to the Company under these Terms.

  20.6. Where practicable, the Company shall notify the affected persons of any such set-off and, upon request, provide supporting documentation, provided that the disclosure of such information is not prohibited by law or regulatory obligation.

  20.7. The exercise of any right of set-off shall not limit or prejudice any other rights or remedies available to the Company under these Terms, applicable law, or principles of equity, including the right to damages, specific performance, or injunctive relief.

  20.8. The User of the Services acknowledges and agrees that the Company's right of set-off applies to all Balances and accounts maintained or controlled by the User of the Services with the Company, its Affiliates, or third-party liquidity providers engaged in connection with the Services, regardless of the currency or asset type in which such Balances are held.

21. INDEPENDENT PARTIES AND ASSIGNMENT

21.1. The User of the Services and the Company are independent contracting parties. Nothing in these Terms shall be construed or interpreted as creating a partnership, joint venture, agency relationship, employment relationship, fiduciary relationship, or franchisor-franchisee relationship between the User and the Company.

21.2. Neither Party has the authority to bind or incur obligations on behalf of the other Party, nor shall either Party represent to any third party that such authority exists, except where expressly permitted under these Terms or pursuant to a written authorisation.

21.3. The User of the Services acknowledges that the Services are provided on a non-exclusive basis and that the Company may provide similar services to other clients, including entities operating in the same or related industries, without restriction or obligation towards the User of the Services.

21.4. The Company may, at its sole discretion, subcontract or delegate the performance of certain technical, operational, or regulatory functions relating to the provision of the Services to third-party service providers, liquidity partners, or payment processors, provided that such subcontracting complies with applicable laws and regulatory requirements.

21.5. The Company shall remain responsible for the performance of its obligations under these Terms and for ensuring that its subcontractors maintain equivalent standards of confidentiality, data protection, and compliance with anti-money laundering and counter-terrorism financing requirements.

21.6. The User of the Services acknowledges and agrees that certain elements of the Services, including payment processing, swap execution, liquidity provision, and settlement operations, may be performed by authorised third parties or other licensed partners acting in accordance with applicable European Union and national laws and regulations.

21.7. The User of the Services' relationship with such partners may be governed by separate terms of use or other legal agreements, which the User accepts by participating in Transactions facilitated through such third parties.

21.8. The User of the Services shall not assign, transfer, delegate, or otherwise dispose of any of its rights or obligations under these Terms, in whole or in part, whether voluntarily, by operation of law, or otherwise, without the Company's prior written consent. Any attempted assignment or transfer without such consent shall be null and void and of no legal effect.

21.9. The Company may assign, transfer or delegate any of its rights or obligations under these Terms to its Affiliates, successors or assigns (including in connection with a merger, reorganisation or acquisition) without the User's prior consent, provided that such transfer does not materially diminish the User's rights under these Terms.

21.10. These Terms shall be binding upon the Parties and their respective successors and permitted assigns and shall benefit them accordingly. Any reference to the "Company" shall include its successors, assigns, and Affiliates.

21.11. The User of the Services acknowledges and agrees that any rights or obligations of the Company under these Terms may be exercised or performed by its affiliated companies, subsidiaries, or other entities under common ownership or control, to the extent necessary for the proper provision of the Services or compliance with applicable law.

22. DISPUTE RESOLUTION

22.1. These Terms, and any dispute, controversy or claim arising out of or in connection with these Terms, including their interpretation, performance or termination (a "Dispute"), shall be governed by and construed in accordance with the laws of the Republic of Croatia, without regard to its conflict of laws rules.

22.2. The Parties shall use reasonable efforts to resolve any Dispute amicably through good-faith negotiations. If a Dispute is not resolved within thirty (30) calendar days following the delivery of written notice of the claim, it shall be finally resolved by arbitration in accordance with the Rules of the Permanent Arbitration Court attached to the Croatian Chamber of Economy, which Rules are deemed incorporated into this Article by reference.

22.3. Unless otherwise agreed by the Parties in writing:

• 22.3.1. the number of arbitrators shall be three;

• 22.3.2. the seat of arbitration shall be Zagreb, Republic of Croatia;

• 22.3.3. the language of the arbitration proceedings shall be English or Croatian; and

• 22.3.4. each Party shall bear its own representation costs and an equal share of the arbitration costs, unless the arbitral tribunal determines otherwise.

  22.4. The arbitral award shall be final and binding upon the Parties. Recognition and enforcement of such an award may be sought before any court of competent jurisdiction. The Parties waive any right of appeal or review to the fullest extent permitted by law.

  22.5. Nothing in this Article shall prevent either Party from seeking interim measures, conservatory measures, or other urgent judicial relief before a court of competent jurisdiction for the purpose of protecting its legitimate rights or Confidential Information pending the final resolution of the arbitration proceedings.

23. FORCE MAJEURE

23.1. The Company shall not be liable for any delay, failure, or interruption in the performance of its obligations under these Terms where such performance is prevented, restricted, or materially hindered by circumstances beyond its reasonable control ("Force Majeure"), including, without limitation:

• 23.1.1. force majeure events, natural disasters, floods, fires, or earthquakes;

• 23.1.2. war, terrorism, armed conflict, civil unrest, or insurrection;

• 23.1.3. strikes, labour disputes, or industrial action;

• 23.1.4. failures or disruptions of telecommunications networks, internet connectivity, blockchain network congestion, or interruptions in the supply of electricity;

• 23.1.5. acts or omissions of governmental or regulatory authorities;

• 23.1.6. epidemics, pandemics, or other public health emergencies; or

• 23.1.7. any other event that the affected Party could not reasonably have foreseen, avoided, or mitigated.

  23.2. In the event of Force Majeure, the affected Party shall notify the other Party in writing without undue delay (and no later than three (3) Business Days thereafter), specifying the nature of the event, its expected duration, and the measures being taken to mitigate its effects. The performance of obligations shall be suspended for the duration of the Force Majeure event, without liability for any delay or non-performance.

  23.3. If a Force Majeure event continues for more than sixty (60) calendar days, either Party may terminate the Agreement by written notice to the other Party, without incurring any liability as a result of such termination.

  23.4. The User acknowledges that system maintenance, infrastructure upgrades, or disruptions affecting external networks may temporarily affect the availability of the Services. Such interruptions shall not constitute a Force Majeure event where they are necessary to ensure the continuity of the Services, provided that the Company uses commercially reasonable efforts to minimise their impact.

24. MISCELLANEOUS PROVISIONS (SURVIVAL, SEVERABILITY, AMENDMENTS AND WAIVERS)

24.1. The expiry or termination of the User of the Services' Account or of these Terms shall not release either Party from any obligations or liabilities accrued before such expiry or termination.

24.2. Any provisions of these Terms which by their nature are intended to survive termination, including, without limitation, provisions relating to intellectual property, confidentiality, indemnification, limitation of liability, compliance with anti-money laundering and counter-terrorism financing requirements, and governing law, shall remain in full force and effect.

24.3. If any provision of these Terms is determined by a competent court or arbitral tribunal to be invalid, illegal, or unenforceable, such provision shall be severed to the extent necessary to ensure that the remaining provisions remain valid and enforceable.

24.4. The Parties shall use their best efforts to replace any invalid or unenforceable provision with a valid provision that reflects, to the greatest extent possible, the original economic and legal purpose of such provision.

24.5. No failure or delay by either Party in exercising any right, power or remedy under these Terms shall operate as a waiver of such right, power or remedy, nor shall any single or partial exercise thereof preclude any other or further exercise of that or any other right, power or remedy.

24.6. Any waiver of rights or modification of obligations shall be made in writing and signed by an authorised representative of the Party granting such waiver or agreeing to such modification.

24.7. No amendment, supplement, or addendum to these Terms shall be valid or binding unless published on the Company's Website or made in writing and expressly accepted by both Parties.

24.8. Oral statements, marketing materials, or informal communications shall not constitute or modify any part of these Terms.

24.9. The headings used in these Terms are for convenience and reference purposes only and shall not affect their interpretation. Words in the singular include the plural and vice versa. References to one gender include all genders.

24.10. Nothing in these Terms shall be construed as conferring any rights or remedies upon any person other than the Parties and their permitted successors and assigns, except as expressly provided herein.

24.11. Unless expressly provided otherwise in these Terms, any request, notice, or other communication addressed to the Company shall be submitted in writing by email to support@whitely.hr or through any other contact details published on whitely.hr, as may be updated from time to time, including through the Account interface or the Website.

24.12. The User of the Services may also contact the Company's Support Service directly through its Account.

24.13. Any request, notice, or other communication addressed to the User may be delivered by email, fax, or electronic message using the contact details recorded in the system or made available through the Account or the Website dashboard.

24.14. The User of the Services may manage its communication preferences through its Account settings.

24.15. All notices or communications under these Terms shall be made in writing and delivered by email or through the Account interface. Notices shall be deemed received at the time of transmission unless the sender receives a notification of failed delivery.

24.16. The User of the Services or the Authorised User acknowledges and agrees that electronic communications from the Company shall have the same legal force and effect as written communications in paper form. These Terms constitute the entire agreement between the User of the Services and the Company with respect to the subject matter hereof and supersede all prior or contemporaneous communications, understandings, and agreements, whether written or oral.

25. LANGUAGE OF THE TERMS

25.1. In the event of any inconsistency or ambiguity, the Croatian-language version of these Terms shall prevail over any translation or localised version. Any translation is provided for convenience only and shall not affect the interpretation of the Croatian-language version.

SPECIAL PROVISIONS FOR CONSUMERS

26. INTRODUCTORY PROVISIONS

26.1. These Special Provisions for Consumers apply exclusively to Retail Customers who qualify as consumers under applicable consumer protection laws, namely natural persons who use the Services for purposes outside their trade, business, craft, or profession.

26.2. In the event of any inconsistency between these Special Provisions for Consumers and the remaining provisions of the General Terms, these Special Provisions shall prevail in matters relating to consumers, unless another provision affords the consumer a higher level of protection.

27. PRE-CONTRACTUAL AND POST-CONTRACTUAL INFORMATION

27.1. Before a consumer concludes a distance contract or becomes bound by a corresponding offer, the Company shall provide the consumer, in a clear and comprehensible manner, with pre-contractual information forming an integral part of the contract. The contractual documentation is listed in Article 7.4. of these Terms.

27.2. Such information shall include: (a) the main characteristics of the Service; (b) the Company's name and registered office; (c) its telephone number and email address; (d) other online communication tools enabling the storage of the time and content of communications on a durable medium; (e) the address of the Company's place of business for submitting complaints, where different from its registered office; (f) the total Fees and charges payable by the consumer to and/or through the Company or, where such charges cannot reasonably be calculated in advance, the method for calculating such Fees and charges; (g) the payment terms; (h) the conditions and time frame for the provision of the Service; (i) the consumer complaint handling procedure; (j) the duration of the contract and the conditions for termination where the contract is concluded for an indefinite period or is subject to automatic renewal; (k) any minimum commitment period applicable to the consumer; (l) any deposit or other financial guarantee required; (m) information regarding personalised pricing where the price is determined through automated decision-making; (n) the functionality of the digital service, including applicable technical protection measures; (o) the compatibility and interoperability of the digital service of which the Company is aware or may reasonably be expected to be aware; and (p) the available out-of-court dispute resolution mechanisms and the manner in which the consumer may access them.

27.3. Where the contract is concluded through a means of distance communication that imposes limitations on the space or time available for displaying information, the Company shall ensure that, before the conclusion of the contract, the consumer receives at least the information required to be provided in such circumstances under applicable law and that all information is adapted to the communication medium used and presented in a clear and comprehensible manner.

27.4. Where a consumer concludes a contract by electronic means involving a payment obligation, the Company shall, before the consumer places the order, clearly and prominently display the information that must be specifically highlighted before ordering. The Company shall ensure that, when placing the order, the consumer expressly acknowledges that the order entails an obligation to pay, and the order button or similar function shall be labelled "order with an obligation to pay" or by another equally clear and unambiguous expression.

27.5. Within a reasonable time after the conclusion of the distance contract, and no later than the commencement of the provision of the Service, the Company shall provide the consumer with confirmation of the concluded contract on a durable medium.

27.6. Such confirmation shall include all pre-contractual information required to be provided before the conclusion of the contract, unless such information has already been provided to the consumer on a durable medium, and shall, where applicable, include confirmation of the consumer's prior consent or declaration in cases where the consumer has agreed to the commencement of the provision of the Service before the expiry of the withdrawal period and/or acknowledged the loss of the right of withdrawal.

27.7. Following the conclusion of the contract, the Company shall provide the consumer, without undue delay, with confirmation of the contract on a durable medium.

27.8. Where required by law, such confirmation shall include information regarding the right of withdrawal and any express declarations of the consumer relevant to the commencement of the provision of the Service.

28. RIGHT OF WITHDRAWAL

28.1. In accordance with applicable consumer protection laws, a consumer generally has the right to withdraw from a distance contract within fourteen (14) days from the date of conclusion of the contract, without giving any reason.

28.2. The consumer shall not have a right of withdrawal in cases where such right is excluded by applicable law. In the context of crypto-asset-related Services, the Company specifically informs the consumer that, depending on the nature of the Transaction or Service, the product or Service may be of a nature whereby its price depends on fluctuations in the financial market beyond the Company's control, and that in such cases, the right of withdrawal may be excluded.

28.3. If the consumer expressly requests that the Company commence the provision of a digital service before the expiry of the withdrawal period, the Company shall, before commencement of performance, obtain the consumer's express consent and express acknowledgement that the consumer may thereby lose the right of withdrawal to the extent provided by applicable law. In the absence of such express consent and acknowledgement, the Company shall not commence performance of the Service before the expiry of the withdrawal period in cases where the right of withdrawal applies.

28.4. For the purposes of Services involving distributed ledger technology, the consumer acknowledges that performance may be deemed to commence at the moment the Company, acting on the consumer's instruction, submits a Transaction to the relevant network for execution. The consumer further acknowledges that such Transactions are technically irreversible once submitted to and/or confirmed on the network. Accordingly, the revocation of an instruction and/or withdrawal from the contract shall not affect any Transaction that has already been submitted and/or confirmed before receipt of the notice of withdrawal and is capable of producing legal effects.

28.5. Where a withdrawal is exercised, and the right of withdrawal applies, the Company shall issue a refund and determine the method of refund within the time limits and in the manner prescribed by applicable law, including by using the same means of payment used by the consumer, unless the consumer expressly agrees otherwise, and without any additional cost to the consumer.

28.6. For the purposes of Services involving blockchain or other distributed ledger technology, performance shall be deemed to commence at the moment a Transaction is submitted to the relevant network for execution.

28.7. Transactions executed through blockchain or similar distributed systems are technically irreversible once submitted to and confirmed on the network. The Company cannot cancel, reverse, or revoke such Transactions.

28.8. Accordingly, withdrawal from the contract is only possible before the commencement of such irreversible digital operations.

28.9. Withdrawal from the contract shall not affect any Transaction that has already been submitted to, or confirmed by, the network before the withdrawal takes legal effect.

28.10. Where the statutory conditions for the loss of the right of withdrawal have been satisfied, the consumer shall no longer have the right to withdraw once performance has commenced.

29. CONSUMER COMPLAINTS

29.1. The Company shall handle consumer complaints in accordance with applicable consumer protection laws and shall acknowledge receipt of the complaint without undue delay.

29.2. The Company shall provide the consumer with a reasoned written response regarding the merits of the complaint no later than fifteen (15) days from the date of receipt of the written complaint, unless otherwise required by applicable law.

29.3. If the consumer is not satisfied with the Company's response, or if the dispute is not resolved directly, the consumer shall be entitled, in accordance with applicable alternative consumer dispute resolution legislation, to initiate proceedings before the competent alternative dispute resolution body.

29.4. Where the contract was concluded online or by other electronic means, the consumer may also initiate dispute resolution through the European Commission's Online Dispute Resolution (ODR) Platform, available at: https://ec.europa.eu/consumers/odr.

29.5. Nothing in this provision shall affect the consumer's right to seek protection of his or her rights before a competent court or other competent authority in accordance with applicable law.

30. APPLICATION OF THE GENERAL TERMS

30.1. For all matters not expressly governed by these Special Provisions for Consumers, the relevant provisions of the General Terms shall apply, in particular with regard to:

• the subject matter of the contract, the scope and description of the Services, including their functionalities and the manner in which they are provided;

• the procedure for registration, opening, and use of the user account, as well as the conditions for access to the Services;

• the procedure for concluding contracts by means of distance communication, including the technical steps involved and the possibility of correcting input errors;

• Fees, prices, and charges, the method of their calculation, and the methods and conditions of payment;

• the execution of Transactions, orders, or other user instructions, including rules on irreversibility and technical limitations of execution where applicable;

• the rights and obligations of the Company in connection with the provision of the Services, including organisational and security measures, customer support, and operational procedures;

• the rights and obligations of the consumer or user, including the obligation to provide accurate information, to use the Services lawfully and in accordance with their intended purpose, and responsibility for actions taken through the user account;

• restrictions, suspension, or termination of access to the Services, including the grounds for and handling of such situations;

• the liability of the Company and/or the consumer, including limitations of liability to the extent permitted by mandatory law and indemnification provisions;

• the duration of the contractual relationship, termination or cancellation (except where expressly governed by these Special Provisions for Consumers), and the consequences thereof;

• communications with the consumer or user, notices, and the provision of information, including the use of a durable medium where applicable;

• privacy protection and the processing of personal data, including references to the Privacy Policy and related documents; and

• governing law and jurisdiction, as well as other final and procedural provisions, including amendments to the General Terms, severability, and waivers, subject to compliance with mandatory consumer protection laws.

  30.2. In the event of any inconsistency between these Special Provisions for Consumers and the General Terms, the provisions that afford the consumer a higher level of protection, or that are required by mandatory law, shall prevail.