Terms & Conditions

1. Contractual Relationship

a. These Terms constitute a legal agreement and create a binding contract between you and Capital Wallet. The agreement is governed by the financial and regulatory frameworks set by the HCMC of Greece, ensuring compliance with EU financial regulations.

b. Supplementary Terms

Due to the rapid development of Digital Currencies and Capital Wallet, these Terms between you and Capital Wallet do not enumerate or cover all rights and obligations of each party, and do not guarantee full alignment with needs arising from future development. Therefore, the Privacy Policy and all other agreements entered into separately between you and Capital Wallet are deemed supplementary terms that are an integral part of these terms and shall have the same legal effect. Your use of Capital Wallet services is deemed your acceptance of the above supplementary terms.

2. Changes to These Terms

Capital Wallet reserves the right to change or modify these Terms in its discretion at any time. Capital Wallet will notify such changes by updating the terms on its website and modifying the last revised date displayed on this page. Any and all modifications or changes to these terms will become effective upon publication on the website or release to users. Therefore, your continued use of Capital Wallet services is deemed your acceptance of the modified agreement and rules. If you do not agree to any changes to these terms, you must stop using Capital Wallet services immediately. You are recommended to frequently review these terms to ensure your understanding of the terms and conditions that apply to your access to and use of Capital Wallet services.

3. Prohibition of Use

Capital Wallet may restrict services in certain jurisdictions at its discretion. Users must ensure compliance with applicable laws in their respective countries before using Capital Wallet services. Access to services may be restricted based on regional financial regulations or other compliance concerns. By accessing and using Capital Wallet services, you represent and warrant that you have not been included in any trade embargoes or economic sanctions list (such as the United Nations Security Council Sanctions List), the list of specially designated nationals maintained by OFAC (the office of foreign assets control of the U.S. Department of the Treasury), or the denied persons or entity list of the U.S. Department of Commerce. Capital Wallet reserves the right to choose markets and jurisdictions to conduct business, and may restrict or refuse, in its discretion, the provision of Capital Wallet services in certain countries or regions.

Capital Wallet mainly serves as a global online (https://www.capitalwallet.com/global/merchant-solution)Virtual Assets (https://www.capitalwallet.com/global/merchant-solution)service provider. It provides Virtual Asset Services, consisting in the provisioning of a virtual asset wallet/account and providing virtual asset exchange and transfer services, Payment Card related services, consisting in Payment API infrastructure, Virtual Debit Card issuing and transactions.

Users must register and open an account with Capital Wallet and complete KYC/KYB Process prior to starting using its services. Users may, subject to the restrictions set forth in these Terms, apply for the withdrawal of Digital Assets.

Although Capital Wallet has been committed to maintaining the accuracy of the information provided through Capital Wallet Services, Capital Wallet cannot and does not guarantee its accuracy, applicability, reliability, integrity, performance or appropriateness, nor shall Capital Wallet be liable for any loss or damage that may be caused directly or indirectly by your use of these contents. The information about Capital Wallet Services may change without notice, and the main purpose of providing such information is to help Users make independent decisions. Capital Wallet does not provide investment or consulting advice of any kind, and is not responsible for the use or interpretation of information on Capital Wallet or any other communication medium. All Users of Capital Wallet Services must understand the risks involved in Digital Assets trading, and are recommended to exercise prudence and trade responsibly within their own capabilities.

1. Capital Wallet Account Registration and Requirements

a. Registration

All Users must apply for a Capital Wallet Account before using Capital Wallet Services. When you register a Capital Wallet Account, you must provide the information requested by Capital Wallet, and accept these Terms. Capital Wallet may refuse, in its discretion, to open a Capital Wallet Account for you. You agree to provide complete and accurate information when opening a Capital Wallet Account, and agree to timely update any information you provide to Capital Wallet to maintain the integrity and accuracy of the information. Each user may maintain only one main account at any given time. The registration, use, protection and management of such an account is governed by the provisions of this Section, unless otherwise stated in these terms or the supplementary Terms.

b. Eligibility

By registering to use a Capital Wallet Account, you represent and warrant that: (i) as an Individual representing a Legal Entity, you are at least 18 or are of legal age to form a binding contract under applicable laws; (ii) as an Individual representing a Legal Entity you have full legal capacity and sufficient authorizations to enter into these Terms; (iii) as an Individual representing a Legal Entity and as a Legal Person you have not been previously suspended or removed from using the Capital Wallet Platform or the Capital Wallet Services; (iv) as a Legal Entity you do not have an existing Capital Wallet Account; (v) you are not resident, located in or otherwise attempting to access the Capital Wallet Platform or the Capital Wallet Services from, or otherwise acting on behalf of a person or legal entity that is resident or located in, a Restricted Location. For the purposes hereof, “Restricted Location” shall include locations as designated by Capital Wallet from time to time as a “Restricted Location” for the purposes hereof; (vi) if you act as a Representative / Trustee of a legal entity, and enter into these Terms on their behalf, you represent and warrant that you have all the necessary rights and authorizations to bind such legal entity and to access and use the Capital Wallet Platform and Capital Wallet Services on behalf of such legal entity; and (vii) your use of the Capital Wallet Platform and the Capital Wallet Services will not violate any and all laws and regulations applicable to you or the legal entity on whose behalf you are acting, including but not limited to regulations on anti-money laundering, anti-corruption, and counter-terrorist financing.

Please note that there are legal requirements in various countries which may restrict the products and services that Capital Wallet can lawfully provide. Accordingly, some products and services and certain functionality within the Capital Wallet Platform may not be available or may be restricted in certain jurisdictions or regions or to certain users. You shall be responsible for informing yourself about and observing any restrictions and/or requirements imposed with respect to the access to and use of the Capital Wallet Platform and the Capital Wallet Services in each country from which the Capital Wallet Platform and the Capital Wallet Services are accessed by you or on your behalf. Capital Wallet reserves the right to change, modify or impose additional restrictions with respect to the access to and use of the Capital Wallet Platform and/the Capital Wallet Services from time to time at their discretion at any time without prior notification.

c. User Identity Verification

Your registration of an account with Capital Wallet will be deemed your agreement to provide required personal information for identity verification. Such information will be used to verify Users’ (either individual or legal entity) identity, identify traces of money laundering, terrorist financing, fraud and other financial crimes through Capital Wallet, or for other lawful purposes stated by Capital Wallet. We will collect, use and share such information in accordance with our Privacy and Cookies Policy.In addition to providing such information, you agree to allow us to keep a record of that information during the period for which your account is active and within five (5) years after your account is closed, in compliance with global industry standards on data storage. You also authorize us to conduct necessary investigations directly or through a third party to verify your identity and/or legal entity’s documentation or protect you and/or us from financial crimes, such as fraud. The information we require for the Legal Entities is documentation for the company, Directors, Ultimate Beneficial Owners and/or Trustee. When providing the required information, you confirm it is true and accurate. After registration, you must ensure that the information is true, complete, and timely updated when changed. If there are any grounds for believing that any of the information you provided is incorrect, false, outdated or incomplete, Capital Wallet reserves the right to send you a notice to demand correction, directly delete the relevant information, and, as the case may be, terminate all or part of Capital Wallet services we provide for you. If we are unable to reach you with the contact information you provided, you shall be fully liable for any loss or expense caused to Capital Wallet during your use of Capital Wallet services. You hereby acknowledge and agree that you have the obligation to update all the information if there is any change. By registering an account, you hereby authorize Capital Wallet to conduct investigations that Capital Wallet considers necessary, either directly or through a third party, to verify your identity and / or the legal entity’s documentation or protect you, other users and/or Capital Wallet from fraud or other financial crimes, and to take necessary actions based on the results of such investigations. You also acknowledge and agree that the documentation of the legal entity (including individuals that are linked with it - Shareholders, Directors, UBOs, Trustees) may be disclosed to credit bureaus and agencies for fraud prevention or financial crime prevention, which may respond to our investigations in full.

The identity verification system is operated through Capital Wallet's regulated onboarding partner Sumsub Tech Ltd. (Cyprus), certified under ISO/IEC 27001 and SOC 2 Type II. Required documentation includes: (i) a valid government-issued identification document (passport, national ID card, or driving licence); (ii) facial biometric capture with liveness detection; (iii) proof of residential address dated within the last three months (utility bill, bank statement, or government correspondence); (iv) for corporate clients, articles of incorporation, certificate of good standing, register of beneficial owners (UBOs), and identification documents for each UBO with a stake of 25% or more. Capital Wallet performs sanctions screening, PEP screening, and adverse media screening on all clients and beneficial owners at onboarding and on an ongoing basis. Further detail on communication channels and authentication is provided in Section XIV of these Terms.

d. Account Usage Requirements

The Capital Wallet Account can only be used by the account registrant. Capital Wallet reserves the right to suspend, freeze or cancel the use of Capital Wallet Accounts by persons other than account registrant. If you suspect or become aware of any unauthorized use of your username and password, you should notify Capital Wallet immediately. Capital Wallet assumes no liability for any loss or damage arising from the use of Capital Wallet Account by you or any third party with or without your authorization.

e. Account Security

For the wallet and payment services, Capital Wallet has been committed to maintaining the security of user entrusted funds, and has implemented industry standard protection for Capital Wallet Services. However, the actions of individual Users may pose risks. You shall agree to treat your access credentials (such as username and password) as confidential information, and not to disclose such information to any third party. You also agree to be solely responsible for taking the necessary security measures to protect your Capital Wallet Account and personal information.

You should be solely responsible for keeping your Capital Wallet Account username and password safe, and be responsible for all the transactions under your Capital Wallet Account. Capital Wallet assumes no liability for any loss or consequences caused by authorized or unauthorized use of your account credentials, including but not limited to information disclosure, information release, consent or submission of various rules and agreements by clicking on the website, online agreement renewal, etc.

By creating a Capital Wallet Account, you hereby agree that:

1. you will notify Capital Wallet immediately if you are aware of any unauthorized use of your Capital Wallet Account and password or any other violation of security rules;
2. you will strictly abide by all mechanisms or procedures of Capital Wallet regarding security, authentication, trading, charging, and withdrawal; and
3. you will take appropriate steps to logout from Capital Wallet at the end of each visit.

a. License

Provided that you constantly comply with the express terms and conditions stated in these Terms, Capital Wallet grants you a revocable, limited, royalty-free, non-exclusive, non-transferable, and non-sublicensable license to access and use Capital Wallet Services through Internet compatible devices for your corporate purposes. You are prohibited to use Capital Wallet Services for resale or commercial purposes, including transactions on behalf of other persons or entities. All the above actions are expressly prohibited and constitute a material violation of these Terms. The content layout, format, function and access rights regarding Capital Wallet Services should be stipulated in the discretion of Capital Wallet. Capital Wallet reserves all rights not expressly granted in these Terms. Therefore, you are hereby prohibited from using Capital Wallet Services in any way not expressly authorized by these Terms.

These Terms only grant a limited license to access and use Capital Wallet Services. Therefore, you hereby agree that when you use Capital Wallet Services, Capital Wallet does not transfer Capital Wallet Services or the ownership of intellectual property rights of any Capital Wallet intellectual property to you or anyone else. All the text, graphics, user interfaces, visual interface, photos, sounds, process flow diagrams, computer code (including html code), programs, software, products, information and documents, as well as the design, structure, selection, coordination, expression, look and feel, and layout of any content included in the services or provided through Capital Wallet Services, are exclusively owned, controlled and/or licensed by Capital Wallet or its members, parent companies, licensors or affiliates.

Capital Wallet owns any feedback, suggestions, ideas, or other information or materials (hereinafter collectively referred to as “Feedback”) about Capital Wallet or Capital Wallet Services that you provide through email, Capital Wallet Services, or other ways. You hereby transfer all rights, ownership and interests of the Feedback and all related intellectual property rights to Capital Wallet. You have no right and hereby waive any request for acknowledgment or compensation based on any Feedback, or any modifications based on any Feedback.

b. Restriction

When you use Capital Wallet Services, you agree and undertake to comply with the following provisions:

• During the use of Capital Wallet Services, all activities you carry out should comply with the requirements of applicable laws and regulations, these Terms, and various guidelines of Capital Wallet;
• Your use of Capital Wallet Services should not violate public interests, public morals, or the legitimate interests of others, including any actions that would interfere with, disrupt, negatively affect, or prohibit other Users (individuals or legal entities) from using Capital Wallet Services;
• You agree not to use the services for market manipulation (such as pump and dump schemes, wash trading, self-trading, front running, quote stuffing, and spoofing or layering, regardless of whether prohibited by law);
• Without prior written consent from Capital Wallet, you may not modify, replicate, duplicate, copy, download, store, further transmit, disseminate, transfer, disassemble, broadcast, publish, remove or alter any copyright statement or label, or license, sub-license, sell, mirror, design, rent, lease, private label, grant security interests in the properties or any part of the properties, or create their derivative works or otherwise take advantage of any part of the properties.
• You may not (i) use any deep linking, web crawlers, bots, spiders or other automatic devices, programs, scripts, algorithms or methods, or any similar or equivalent manual processes to access, obtain, copy or monitor any part of the properties, or replicate or bypass the navigational structure or presentation of Capital Wallet Services in any way, in order to obtain or attempt to obtain any materials, documents or information in any manner not purposely provided through Capital Wallet Services; (ii) attempt to access any part or function of the properties without authorization, or connect to Capital Wallet Services or any Capital Wallet servers or any other systems or networks of any Capital Wallet Services provided through the services by hacking, password mining or any other unlawful or prohibited means; (iii) probe, scan or test the vulnerabilities of Capital Wallet Services or any network connected to the properties, or violate any security or authentication measures on Capital Wallet Services or any network connected to Capital Wallet Services; (iv) reverse look-up, track or seek to track any information of any other Users or visitors of Capital Wallet Services; (v) take any actions that imposes an unreasonable or disproportionately large load on the infrastructure of systems or networks of Capital Wallet Services or Capital Wallet, or the infrastructure of any systems or networks connected to Capital Wallet services; (vi) use any devices, software or routine programs to interfere with the normal operation of Capital Wallet Services or any transactions on Capital Wallet Services, or any other person’s use of Capital Wallet Services; (vii) forge headers, impersonate, or otherwise manipulate identification, to disguise your identity or the origin of any messages or transmissions you send to Capital Wallet, or (viii) use Capital Wallet Services in an illegal way.

By accessing Capital Wallet Services, you agree that Capital Wallet has the right to investigate any violation of these Terms, unilaterally determine whether you have violated these Terms, and take actions under relevant regulations without your consent or prior notice. Examples of such actions include, but are not limited to:

1. Blocking and closing order requests;
2. Reporting the incident to the authorities;
3. Publishing the alleged violations and actions that have been taken;
4. Deleting any information, you publish that are found to be violations.

1. Payment Solutions

Overview
As an authorised Crypto-Asset Service Provider (CASP) supervised by the Hellenic Capital Market Commission under Regulation (EU) 2023/1114 (MiCAR) and Greek Law 5193/2025, Capital Wallet provides the following regulated crypto-asset services to its users:

Service Scope
(i) Custody and administration of crypto-assets on behalf of clients (MiCAR Art. 75) — provided through the qualified custodian BitGo Europe GmbH; (ii) Execution of orders for crypto-assets on behalf of clients (MiCAR Art. 78); (iii) Reception and transmission of orders for crypto-assets on behalf of clients (MiCAR Art. 80); (iv) Exchange of crypto-assets for funds (MiCAR Art. 77); (v) Exchange of crypto-assets for other crypto-assets (MiCAR Art. 77); (vi) Providing transfer services for crypto-assets on behalf of clients (MiCAR Art. 82), excluding e-money tokens (EMTs). Detailed terms applicable to each service are set out in the subsections that follow and in the corresponding regulatory disclosures in later sections.

Authorisation
By using Capital Wallet Services, you authorise Capital Wallet to provide you with the services described in these Terms, including the safe custody of your crypto-assets, the execution and transmission of your orders, the exchange of crypto-assets, the transfer of crypto-assets at your instruction, and to take all necessary steps to ensure compliance with applicable laws and regulations (including anti-money laundering, sanctions, transfer of funds regulation, and tax reporting frameworks).

2. Crypto-to-Fiat Exchange

Upon completion of the registration and identity verification for your Capital Wallet Account, you may conduct Crypto-to-crypto / Crypto-to-Fiat/ Crypto-to-Stablecoin Trading on Capital Wallet in accordance with the provisions of these Terms. Users may submit a request to convert one digital asset into another or exchange fiat currency for a digital asset (or vice versa), depending on available trading pairs.

1. Capital Wallet offers a locked exchange rate for 30 seconds, during which the user may confirm the transaction. If the user does not confirm within this timeframe, the order will not be placed and a new exchange rate may apply.
2. To request a conversion, users must place a market order specifying the type and amount of the asset they wish to convert. Capital Wallet may provide a non-binding indicative quote, which the user can accept or decline within the designated timeframe. Acceptance of the quote results in a trade request submission, authorizing Capital Wallet to temporarily lock the necessary assets until the conversion is completed.
3. Capital Wallet retains the right to accept or reject any conversion request at its sole discretion, depending on market conditions and other relevant factors. If a request is accepted, the agreed-upon price and asset amounts will be honored, and the converted assets will be credited to the user's account. While most conversions are processed within seconds, settlement times may vary due to market fluctuations, technical issues, or other unforeseen circumstances.
4. Once a conversion request is accepted, it cannot be canceled. Users are responsible for assessing price competitiveness before confirming a trade. Capital Wallet is not liable for any losses or opportunity costs resulting from price fluctuations during the settlement period.
5. Capital Wallet has the exclusive authority to determine which Assets are listed on the Platform and are available for the purposes of any Conversion and may add or remove Assets and/or particular trading pairs from the Platform in its sole discretion, from time to time without prior notice. In respect of any such additions, removals, or changes, Capital Wallet may, but is not obliged to, notify Users in advance and Capital Wallet shall have no liability to Users in connection with such additions, removals or changes.
6. It is recommended that Users conduct independent research into different Digital Assets prior to using Capital Wallet Instant Conversion Services and that Users take steps to ensure they understand the risks associated with the trading of Digital Assets. Users bear full responsibility for ensuring that the Capital Wallet Instant Conversion Services are suitable for them, taking into account their own financial objectives and circumstances, and shall be solely responsible for any profit or loss sustained in connection with their use of the Capital Wallet Instant Conversion Services. Capital Wallet does not make any representation of guarantee as to the outcome to be received by the trading of Digital Assets whether pursuant to the Capital Wallet Instant Conversion Services or otherwise.

3. Fiat Settlement

Capital Wallet may collaborate with liquidity providers to facilitate fiat settlement for merchants who choose to convert cryptocurrency payments into fiat currency. By using this service, you acknowledge that Capital Wallet may select liquidity providers at its discretion, and you accept their involvement in the conversion and settlement process without object.

4. Custody and Administration of Crypto-Assets (MiCAR Art. 75)

Custody Agreement — MiCAR Art. 75(1). By accepting these Terms, the Client enters into a standardized custody agreement with Capital Wallet in accordance with Article 75(1) of Regulation (EU) 2023/1114 (MiCAR). These Terms, taken as a whole, constitute the written agreement between Capital Wallet and the Client governing the custody and administration of crypto-assets, and contain the minimum content required by Article 75(1) MiCAR, including: (a) identification of the parties (Sections I and III); (b) the nature and description of the custody services (this Section V.4 and Section XIII); (c) the duties and responsibilities of Capital Wallet, including segregation measures and insolvency protection (Sections XIII and XVIII); (d) the means by which the Client accesses, controls and recovers the crypto-assets in custody and the related recovery policy (Sections XIII and XIV); (e) the security systems employed (Section XIII and Document 4 / Document 15 of the regulatory dossier); (f) the fee structure (Section XV); (g) the liability of Capital Wallet under Article 75(8) MiCAR (Sections VI, XIII and XVIII); and (h) the communication channels and customer identity verification system (Section XIV). A plain-language summary of the custody policy is provided in Section XIII (Custody Policy Summary — MiCAR Art. 75(3)). The detailed Custody Policy is made available to the Client upon request at no charge.

Capital Wallet provides custody and administration of crypto-assets on behalf of clients through the qualified sub-custodian BitGo Europe GmbH (Frankfurt am Main, Germany), an institution authorised by BaFin and certified to SOC 1 Type II, SOC 2 Type II and ISO/IEC 27001. Clients' crypto-assets are held in omnibus wallets per crypto-asset, with segregation between Capital Wallet's proprietary holdings and client holdings effected at on-chain level (separate wallet addresses) and within Capital Wallet's internal ledger (unique Customer ID per client). Custody is supported by insurance coverage of USD 250,000,000 provided through Lloyd's of London and Munich Re via BitGo.

Capital Wallet does not use client crypto-assets for its own account. The Company does not engage in proprietary trading, rehypothecation, lending, or use of client assets as collateral. The terms governing custody are set out in the Custody Agreement signed between you and Capital Wallet, and are further summarised in Section XIII (Custody Policy Summary) of these Terms.

5. Execution of Orders (MiCAR Art. 78)

Capital Wallet executes orders for crypto-assets on behalf of its clients in accordance with its Order Execution Policy (forming part of Document 4 of the regulatory dossier). The Order Execution Policy applies the seven factors of best execution: price, costs, speed, likelihood of execution and settlement, size, nature, and conditions of custody.

Prior Consent to the Order Execution Policy — MiCAR Art. 78(3). In accordance with Article 78(3) of MiCAR, Capital Wallet shall not execute any client order unless the relevant client has given prior express consent. Capital Wallet relies on the general agreement model permitted by Article 78(3): the Client's electronic acceptance of these Terms (including this Section V.5) at onboarding through a single confirmation mechanism constitutes the Client's prior express consent both to the Order Execution Policy generally and specifically to the off-venue execution model described below in this Section. The acceptance is recorded with a timestamp, IP address, user identifier and document version in an immutable audit log retained for at least seven (7) years. Where Capital Wallet materially amends the Order Execution Policy or its off-venue execution model, the Client is notified at least thirty (30) calendar days in advance and is required to re-accept the updated Terms before any further order may be submitted; failure to re-accept shall block the submission of further orders until renewed acceptance is given. A confirmation screen displayed prior to the execution of each order may, as a matter of best practice, reiterate the off-venue nature of execution and identify the counterparty, but such per-transaction information is provided for transparency only and is not required for the validity of the Client's prior consent.

By accepting these Terms at onboarding, you hereby provide your prior express consent to the Order Execution Policy of Capital Wallet, both for the execution of orders on any trading platform (where applicable) and for the execution of orders outside a regulated trading venue (off-venue, including through third-party regulated liquidity providers and OTC bilateral arrangements where Capital Wallet acts as principal). You acknowledge and accept that Capital Wallet does not operate a trading platform under MiCAR Article 76, and that all orders are accordingly executed off-venue. You may withdraw such consent at any time by notice through the Capital Wallet portal or by email to [email protected], with the consequence that Capital Wallet shall no longer be permitted to execute your orders until renewed consent is given by re-accepting these Terms.

Capital Wallet does not accept inducements (monetary or non-monetary) in return for routing client orders to specific execution venues. Specific client instructions may prevent Capital Wallet from achieving the best possible result for the elements covered by those instructions; this risk is hereby brought to your attention as required by MiCAR Art. 78(1) subparagraph 2. Capital Wallet shall, upon your written request, demonstrate that it has executed your orders in accordance with its Order Execution Policy and shall make available evidence of the compliance of any specific execution with such Policy within five (5) business days of receipt of the request.

6. Reception and Transmission of Orders (MiCAR Art. 80)

Where Capital Wallet receives orders from you that are not executed by Capital Wallet itself, the Company transmits such orders promptly and accurately to a third-party crypto-asset service provider or trading platform for execution, in accordance with the Order Reception and Transmission Policy (forming part of Document 4 of the regulatory dossier). Capital Wallet does not accept inducements for the routing of orders. Capital Wallet does not misuse information relating to pending client orders, in accordance with MiCAR Art. 80(3).

7. Transfer Services and Travel Rule Compliance (MiCAR Art. 82 — Regulation (EU) 2023/1113)

Capital Wallet provides transfer services for crypto-assets on behalf of clients, excluding electronic money tokens (EMTs). Each transfer is executed in accordance with Capital Wallet's Transfer Services Policy and the Transfer of Funds Regulation (TFR — Regulation (EU) 2023/1113). For every transfer, Capital Wallet collects and transmits the originator and beneficiary information required under Articles 14-16 TFR, including, depending on the value and the type of counterparty, the originator's and beneficiary's name, account identifier, address or official personal document number, customer identification number or date and place of birth.

By using Capital Wallet's transfer services, you authorise Capital Wallet to collect, process, and transmit the required Travel Rule information to the beneficiary's crypto-asset service provider and to receive such information from the originator's crypto-asset service provider. For transfers to or from self-hosted wallets equal to or above EUR 1,000, Capital Wallet performs enhanced due diligence and may request additional verification (e.g., proof of wallet ownership, blockchain analytics screening) before executing the transfer.

1. Disclaimer of Warranties

To the maximum extent permitted under applicable law, Capital Wallet services, Capital Wallet materials and any product, service or other item provided by or on behalf of Capital Wallet are offered on an “as is” and “as available” basis, and Capital Wallet expressly disclaims, and you waive, any and all other warranties of any kind, whether express or implied, including, without limitation, warranties of merchantability, fitness for a particular purpose, title or non-infringement or warranties arising from course of performance, course of dealing or usage in trade. Without limiting the foregoing, Capital Wallet does not represent or warrant that the site, Capital Wallet services or Capital Wallet materials are accurate, complete, reliable, current, error-free, or free of viruses or other harmful components. Capital Wallet does not guarantee that any order will be executed, accepted, recorded or remain open. Except for the express statements, agreements and rules set forth in these terms, you hereby acknowledge and agree that you have not relied upon any other statement or agreement, whether written or oral, with respect to your use and access of Capital Wallet services. Without limiting the foregoing, you hereby understand and agree that Capital Wallet will not be liable for any losses or damages arising out of or relating to: (a) any inaccuracy, defect or omission of digital assets price data, (b) any error or delay in the transmission of such data, (c) interruption in any such data, (d) regular or unscheduled maintenance carried out by Capital Wallet and service interruption and change resulting from such maintenance, (e) any damages incurred by other users’ actions, omissions or violation of these terms, (f) any damage caused by illegal actions of other third parties or actions without authorized by Capital Wallet; and (g) other exemptions mentioned in disclaimers and platform rules issued by Capital Wallet.

The disclaimer of implied warranties contained herein may not apply if and to the extent it is prohibited by applicable law of the jurisdiction in which you reside

2. Disclaimer of Damages and Limitation of Liability

To the maximum extent permitted by applicable law, in no event will Capital Wallet, its affiliates and their respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors be liable for any incidental, indirect, special, punitive, consequential or similar damages or liabilities whatsoever (including, without limitation, damages for loss of data, information, revenue, profits or other businesses or financial benefits) arising out of Capital Wallet services, any performance or non-performance of Capital Wallet services, or any other product, service or other item provided by or on behalf of Capital Wallet and its affiliates, whether under contract, statute, strict liability or other theory even if Capital Wallet has been advised of the possibility of such damages except to the extent of a final judicial determination that such damages were a result of Capital Wallet’s gross negligence, fraud, willful misconduct or intentional violation of law. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitation may not apply to you.

Notwithstanding the foregoing, in no event will the liability of Capital Wallet, its referrals, affiliates and their respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors arising out of services offered by or on behalf of Capital Wallet and its affiliates, any performance or non-performance of Capital Wallet services, or any other product, service or other item, whether under contract, statute, strict liability or other theory, exceed the amount of the fees paid by you to Capital Wallet under these terms in the twelve-month period immediately preceding the event giving rise to the claim for liability.

Computer Viruses. We shall not bear any liability, whatsoever, for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks.

3. Indemnification

You agree to indemnify and hold harmless Capital Wallet, their affiliates, contractors, licensors, and their respective directors, officers, employees and agents from and against any claims, actions, proceedings, investigations, demands, suits, costs, expenses and damages (including attorneys’ fees, fines or penalties imposed by any regulatory authority) arising out of or related to (i) your use of, or conduct in connection with, Capital Wallet Services, (ii) your breach or our enforcement of these Terms, or (iii) your violation of any applicable law, regulation, or rights of any third party during your use of Capital Wallet Services. If you are obligated to indemnify Capital Wallet, their affiliates, contractors, licensors, and their respective directors, officers, employees or agents pursuant to these Terms, Capital Wallet will have the right, in its sole discretion, to control any action or proceeding and to determine whether Capital Wallet wishes to settle, and if so, on what terms.

Capital Wallet has the exclusive authority to determine which Digital Assets are listed on the platform and may add or remove Digital Assets from the platform in its sole discretion, from time to time. Capital Wallet may also change the order size available for each Digital Asset. In respect of such additions, removals, or amendments, Capital Wallet may, but is not obliged to, notify Users in advance and Capital Wallet shall have no liability to Users in connection with such additions, removals or amendments.

Please be aware that all official announcements, news, promotions, competitions and airdrops will be listed on www.capitalwallet.com/resources. Users undertake to refer to these materials regularly and promptly. Users undertake to refer to these materials regularly and promptly. Capital Wallet will not be held liable or responsible in any manner of compensation should users incur personal losses arising from ignorance or negligence of the announcements.

1. Suspension of Capital Wallet Accounts

You agree that Capital Wallet shall have the right to immediately suspend your Capital Wallet Account, freeze or lock the Digital Assets or funds in your account, and suspend your access to Capital Wallet for any reason including if Capital Wallet suspects any such accounts to be in violation of these Terms, our Privacy (https://www.capitalwallet.com/eu/privacy-policy) Policy, or any applicable laws and regulations with HCMC and EU regulations.. You agree that Capital Wallet shall not be liable to you for any permanent or temporary modification of your Capital Wallet Account, or suspension or termination of your access to all or any portion of Capital Wallet Services. Capital Wallet shall reserve the right to keep and use the transaction data or other information related to such Capital Wallet Accounts. The above account controls may also be applied in the following cases:

• The Capital Wallet Account is subject to a governmental proceeding, criminal investigation or other pending litigation;
• We detect unusual activities in the Capital Wallet Account;
• We detect unauthorized access to the Capital Wallet Account;
• We are required to do so by a court order or command by a regulatory/government authority.
• You refuse to provide Capital Wallet with enhanced due diligence documentation, when applicable, for processing a transaction or an order or an instant conversion.

2. Cancellation of Capital Wallet Accounts

In case of any of the following events, Capital Wallet shall have the right to directly terminate these Terms by canceling your Capital Wallet Account, and shall enjoy the right but not the obligation to permanently freeze (cancel) the authorizations of your Capital Wallet Account on Capital Wallet and withdraw the corresponding Capital Wallet Account thereof:

• after Capital Wallet terminates services to you;
• you allegedly register or register in any other person’s name as a Capital Wallet User again, directly or indirectly;
• the information that you have provided is untruthful, inaccurate, outdated or incomplete;
• when these Terms are amended, you state your unwillingness to accept the amended Terms by applying for cancellation of your Capital Wallet Account or by other means;
• you request that Capital Wallet Services be terminated; and
• any other circumstances where Capital Wallet deems it should terminate Capital Wallet Services.

Should your Capital Wallet Account be terminated, the account and transactional information that meet data retention standards will be securely stored for 5 years. In addition, if a transaction is unfinished during the account termination process, Capital Wallet shall have the right to notify your counterparty of the situation at that time. You acknowledge that a user-initiated account exit (right to erasure under GDPR or other equivalent regulations) will also be subjected to the termination protocol stated above.

If Capital Wallet is informed that any Digital Assets or funds held in your Capital Wallet Account are stolen or otherwise are not lawfully possessed by you, Capital Wallet may, but has no obligation to, place an administrative hold on the affected funds and your Capital Wallet Account. If Capital Wallet does lay down an administrative hold on some or all of your funds or Capital Wallet Account, Capital Wallet may continue such hold until such time as the dispute has been resolved and evidence of the resolution acceptable to Capital Wallet has been provided to Capital Wallet in a form acceptable to Capital Wallet. Capital Wallet will not involve itself in any such dispute or the resolution of the dispute. You agree that Capital Wallet will have no liability or responsibility for any such hold, or for your inability to withdraw Digital Assets or funds or execute trades during the period of any such hold.

3. Remaining Funds After Capital Wallet Account Termination

Except as set forth above, once a Capital Wallet Account is closed, all remaining account balance (which includes charges and liabilities owed to Capital Wallet) will be payable immediately to Capital Wallet. Upon payment of all outstanding charges to Capital Wallet (if any), Users will have 30 calendar days to withdraw all Digital Assets or funds from the account.

4. Remaining Funds After Capital Wallet Account Termination Due to Fraud, Violation of Law, or Violation of These Terms

Capital Wallet maintains full custody of the Digital Assets, funds and User data/information which may be turned over to governmental authorities in the event of Capital Wallet Accounts’ suspension/closure arising from fraud investigations, investigations of violation of law or violation of these Terms.

5. Dormant Accounts

Notwithstanding any provision of this Section, Capital Wallet may provide a written notice requiring you to close all of your open positions and withdraw all of your Digital Assets from your Capital Wallet Account within a specified period of time, determined on a per case situation. In the event that you fail to do so, Capital Wallet may in its absolute discretion and without prior notice to you:

1. deem your Capital Wallet account as a dormant account;
2. close any open positions in any Capital Wallet products;
3. convert the Digital Assets to a different type of Digital Asset. For the avoidance of doubt, none of the Capital Wallet shall be liable for any loss of profit, tax obligations or any other loss, damage or expense incurred by you resulting from such conversion;
4. charge a dormant account fee to cover the cost of maintaining the assets by the Capital Wallet, its affiliates or any third-party and such fee shall be withdrawn directly from the dormant account on a monthly basis; and

close a dormant account at any time, and Capital Wallet will not be liable for any loss, damage or expense incurred by you as a result of the closure of a dormant account unless there was fraud or willful default by Capital Wallet. Any assets in these dormant accounts will be transferred in accordance with paragraph above. After a dormant account is closed, it cannot be reactivated by you (i.e. you will need to register a new Capital Wallet account if you wish to continue to use Capital Wallet Services).

Capital Wallet is not a broker, intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in connection with any trades or other decisions or activities affected by you using Capital Wallet Services. No communication or information provided to you by Capital Wallet is intended as, or shall be considered or construed as, investment advice, financial advice, trading advice, or any other sort of advice. Unless otherwise specified in these Terms, all trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you according to your personal investment objectives, financial circumstances and risk tolerance, and you shall be solely responsible for any loss or liability therefrom. You should consult legal or tax professionals regarding your specific situation. Capital Wallet does not recommend that any Digital Asset should be bought, earned, sold, or held by you. Before making the decision to buy, sell or hold any Digital Asset, you should conduct your own due diligence and consult your financial advisors prior to making any investment decision. Capital Wallet will not be held responsible for the decisions you make to buy, sell, or hold Digital Asset based on the information provided by Capital Wallet.

Users are responsible for ensuring compliance with their local regulations regarding digital asset usage. As Capital Wallet operates under the HCMC of Greece, all transactions and financial activities must adhere to Greek financial laws and European Union regulations governing virtual asset service providers.

By using Capital Wallet services, you agree to our Privacy Policy available at www.capitalwallet.com/eu/privacy. The processing of personal data is conducted in accordance with GDPR (General Data Protection Regulation) and applicable data protection laws in Greece and the EU.

Capital Wallet is the data controller for personal data processed in connection with the provision of its services. The Data Protection Officer (DPO) can be contacted at [email protected].

Your personal data is processed for the following purposes: (i) provision of the services and performance of these Terms; (ii) compliance with legal obligations including KYC/KYB, AML/CFT, sanctions screening, Travel Rule, and tax reporting (DAC8); (iii) security, fraud prevention, and incident response; (iv) communications with you about your account and services; and (v) where you have consented, for marketing communications. The legal bases for processing are: performance of contract, legal obligation, legitimate interests (security and fraud prevention), and consent (marketing).

Categories of personal data processed include: identification data (name, date of birth, ID/passport, biometric data); contact data (address, email, phone); financial data (transactions, balances, bank account); tax residence; source of funds; sanctions and PEP screening results; technical data (IP address, device identifiers, log data); and any other data necessary for the provision of the services.

Data recipients include: BitGo Europe GmbH (custody); Sumsub Tech Ltd (KYC/AML); Stackflow Technologies (IT infrastructure); credit institutions where client funds are deposited; regulatory and tax authorities (HCMC, ΑΠΔΠΧ, ΑΚΝΕΔ, Α.Α.Δ.Ε.); courts; and other recipients where required by law. International transfers of personal data outside the EU/EEA, where they occur, are protected by Standard Contractual Clauses (SCCs — Commission Decision 2021/914) or equivalent safeguards.

Retention periods: KYC and transaction data are retained for at least five (5) years after the end of the business relationship in accordance with Greek Law 4557/2018; tax reporting data is retained in accordance with DAC8; other data is retained as long as necessary for the purpose for which it was collected. After expiry of retention periods, data is securely deleted or anonymised.

Your rights under the GDPR include: right of access, rectification, erasure, restriction of processing, data portability, objection, and the right not to be subject to a decision based solely on automated processing including profiling. You may exercise your rights by contacting [email protected]. You have the right to lodge a complaint with the Hellenic Data Protection Authority (ΑΠΔΠΧ, www.dpa.gr) or your local supervisory authority.

When you use our Website, Capital Wallet will use cookies to distinguish you from other users of our Website. This helps us provide you with a more relevant and effective experience, including presenting the Website according to your needs and preferences.

This Cookie Policy provides you with comprehensive information about the cookies we use and the way in which we use them. You should also read our Privacy Policy in conjunction with this Policy.

If you wish to know more about cookies please consult the help menu on your web browser or visit independent information providers such as www.allaboutcookies.org.

This Section constitutes the summary of Capital Wallet's custody policy that is provided to clients in clear, concise, and non-technical language, in accordance with Article 75(3) of Regulation (EU) 2023/1114 (MiCAR). A copy of the full Custody Policy is available upon written request to [email protected], free of charge, within five (5) business days. By accepting these Terms, you acknowledge that you have received and read this Custody Policy Summary.

Who holds your crypto-assets: Your crypto-assets are held in custody by Capital Wallet through its qualified sub-custodian, BitGo Europe GmbH, a German institution authorised by BaFin and certified under SOC 2 Type II and ISO/IEC 27001. Capital Wallet remains fully responsible to you for the safekeeping of your assets.

How your assets are protected:Your crypto-assets are stored using a combination of cold storage (offline, in hardware security modules — HSMs), warm storage, and hot wallets with multi-signature 2-of-3 and Multi-Party Computation (MPC) technology. At least 95% of total assets under custody are kept in cold storage. The custody system is supported by an insurance policy of USD 250,000,000 underwritten by Lloyd's of London and Munich Re, covering crime, employee dishonesty, and physical loss.

Segregation from Capital Wallet's own assets: Your crypto-assets are kept legally and operationally separate from Capital Wallet's own assets. They are held in omnibus wallets shared with other clients (one wallet per crypto-asset), and segregation between clients is maintained through Capital Wallet's internal ledger, where each client has a unique customer identifier and balance. On-chain, the omnibus wallets are entirely separate from any wallet holding Capital Wallet's own funds.

Your funds (fiat money) are deposited in a segregated client account at Optima Bank S.A. by the end of the business day following receipt (T+1). Capital Wallet never uses your funds or your crypto-assets for its own account — no proprietary trading, no lending, no rehypothecation, no use as collateral for Capital Wallet's obligations.

Insolvency protection: In the event Capital Wallet becomes insolvent or is wound up, your crypto-assets and your funds do not form part of the insolvency estate of Capital Wallet (MiCAR Art. 75(7) and Greek law). They remain your property and will be returned to you in an orderly process under Capital Wallet's Wind-down Plan.

How you access and withdraw your crypto-assets: You may withdraw your crypto-assets at any time through the Capital Wallet portal, subject to identity verification (multi-factor authentication), address whitelisting with a 24-hour cooling-off period for new addresses, anti-fraud screening, and blockchain analytics checks. Standard withdrawals are processed within 1 hour (hot wallet) or within 24-48 hours (cold storage). Withdrawal limits apply: retail clients up to EUR 10,000 per 24-hour period (EUR 50,000 monthly); corporate clients up to EUR 100,000 per 24-hour period, with pre-approval required for transactions of EUR 50,000 or more.

Your rights linked to your crypto-assets: While your crypto-assets are held in custody, Capital Wallet does not exercise governance or voting rights, does not participate in airdrops, and does not provide staking services on your behalf. Should you wish to participate in such activities, you must withdraw your crypto-assets to a wallet under your own control. In the event of a hard fork, Capital Wallet recognises only the dominant chain (based on hashrate, market capitalisation, and ecosystem support); if you wish to claim tokens on a minority chain, you must withdraw before the fork date.

In case of loss. Capital Wallet is fully liable for loss of crypto-assets caused by an incident attributable to it or to its sub-custodian, in accordance with MiCAR Art. 75(8). In such case, you will be notified within 24 hours and compensated through the insurance coverage referred to above or, where necessary, from Capital Wallet's own funds. Capital Wallet shall advance compensation where required so that you are not burdened by insurance claim timelines.

Reporting on your account: You will receive electronic account statements at least quarterly, free of charge, and at any time upon request within five (5) business days. Statements are also available on demand through the Capital Wallet portal as a self-service export.

How to contact us: For questions about custody, please contact: [email protected] (general inquiries) or [email protected] (regulatory matters). For complaints, please follow the procedure set out in Section XXII (Resolving Disputes).

Communication channels: Capital Wallet communicates with you through the following channels: (i) the Capital Wallet portal (in-app messaging and notifications); (ii) email at the address you have designated during onboarding; (iii) where applicable, registered postal mail to your verified address. You are required to keep your contact details accurate and up to date. Material notifications (including changes to these Terms, breach notifications, or wind-down notices) shall be sent both through the portal and by email. Time-sensitive notices (e.g., security alerts) may also be sent via secure mobile push notification.

Your communications to Capital Wallet must be made through: (i) the secure messaging function in the Capital Wallet portal; (ii) email to [email protected] (general matters) or [email protected] (regulatory and AML matters); or (iii) registered postal mail to Capital Wallet Greece Single-Member SA, Leoforos Vouliagmenis 580, 16452 Argyroupoli, Athens, Greece. Capital Wallet shall acknowledge receipt of substantive communications within two (2) business days and provide a substantive response within ten (10) business days, except where a longer period is justified.

Identity verification system: Capital Wallet uses an electronic Know-Your-Customer (KYC) and Know-Your-Business (KYB) system operated through its onboarding partner Sumsub Tech Ltd. (Cyprus, EU), certified under ISO/IEC 27001 and SOC 2 Type II. Identity verification involves: (i) capture of an officially recognised identity document (ID card, passport, or driving licence); (ii) facial biometrics with liveness detection; (iii) verification of residential address (utility bill or bank statement no older than 3 months); (iv) screening against international sanctions lists, politically exposed persons (PEP) databases, and adverse media sources; and (v) for corporate clients, additional verification of beneficial owners (UBOs) and corporate documentation.

Ongoing identity verification: Capital Wallet performs ongoing monitoring of client identification data, including periodic re-verification, transaction monitoring, and re-screening against sanctions and PEP lists. You undertake to provide updated information and supporting documentation upon request within ten (10) business days, in accordance with Greek Law 4557/2018 (AML/CFT) and applicable EU directives. Failure to provide updated information may result in the suspension or termination of your account.

Authentication: For each login and for each transaction above defined thresholds, Capital Wallet enforces multi-factor authentication (MFA) using a Time-based One-Time Password (TOTP) authenticator app, a FIDO2 security key, or an equivalent second-factor mechanism. You undertake to safeguard your authentication credentials and to notify Capital Wallet immediately at [email protected] in case of suspected compromise.

Capital Wallet's fees and charges (including trading fees, custody fees, withdrawal network fees, conversion spreads, and any third-party fees passed on to you) are published in advance on the Capital Wallet website (https://www.capitalwallet.gr/fees) and within the Capital Wallet portal. By accepting these Terms, you acknowledge having reviewed the applicable fee schedule. Capital Wallet shall notify you of any material change to its fee schedule at least thirty (30) calendar days prior to the change becoming effective, by email and through the portal. Retail consumers shall have the right to terminate the contractual relationship without penalty before the new fee schedule becomes effective.

Capital Wallet does not impose hidden charges. All fees applicable to a transaction are disclosed before the transaction is confirmed. Capital Wallet does not accept or pay inducements in return for the routing of client orders to specific execution venues, in line with MiCAR Articles 78(5) and 80(2).

Investment in or use of crypto-assets involves significant risks. By using Capital Wallet Services, you acknowledge and accept the following risks, in particular:

(i) Price volatility. The value of crypto-assets may fluctuate substantially and rapidly. You may lose the entire amount you have invested or transferred. Past performance is not indicative of future results.

(ii) Liquidity risk. Some crypto-assets may have limited liquidity, which may prevent prompt sale or transfer at a reasonable price, particularly during periods of market stress.

(iii) Technological and cybersecurity risk. Blockchain networks, smart contracts, custodial infrastructure, and crypto-asset wallets may be subject to bugs, vulnerabilities, hacking, key compromise, denial-of-service attacks, or other technological failures, despite the security measures employed by Capital Wallet and BitGo.

(iv) Regulatory and legal risk. The legal status of crypto-assets varies across jurisdictions and is evolving. Changes in laws or regulations (including tax laws under DAC8 — Directive (EU) 2023/2226) may adversely affect the value, transferability, or usability of crypto-assets.

(v) Forks, airdrops, and protocol risks. Crypto-asset networks may undergo forks (hard or soft), airdrops, or other protocol-level events that may affect your holdings. Capital Wallet's policy in such cases is described in Document 4 of the regulatory dossier and is summarised in Section XIII.

(vi) Operational and counterparty risk. Despite all measures taken, Capital Wallet's services may be affected by operational failures, including failures of third-party providers (BitGo, Sumsub, Stackflow Technologies, cloud infrastructure). Capital Wallet maintains business continuity and exit strategies, but service interruptions remain possible.

(vii) No deposit guarantee for crypto-assets. Crypto-assets held in custody by Capital Wallet are not covered by the Greek Deposit Guarantee Scheme or any equivalent national or EU scheme. However, MiCAR insolvency protection applies (see Section XVIII). Client fiat funds held in a segregated client account at a credit institution benefit from that institution's Deposit Guarantee Scheme up to EUR 100,000 per depositor in accordance with Directive 2014/49/EU.

(viii) Crypto-assets are not legal tender. Crypto-assets are not legal tender or fiat currency and are not backed by any government, central bank, or other authority.

Capital Wallet does not provide investment advice, tax advice, or legal advice. Before engaging in transactions, you should carefully consider whether the use of Capital Wallet Services is appropriate for you in light of your circumstances, knowledge, experience, and risk tolerance. Where you have any doubt, you should consult an independent qualified advisor.

Capital Wallet is subject to and complies with anti-money laundering and counter-terrorism financing requirements under Greek Law 4557/2018, Directive (EU) 2015/849 (as amended), Regulation (EU) 2023/1113 (TFR), and the sanctions framework of the European Union, the United Nations, OFAC, and other applicable regimes. By using Capital Wallet Services, you acknowledge that Capital Wallet:

(i) is required to conduct due diligence on its clients (KYC/KYB) and to perform ongoing monitoring of client activity;

(ii) is required to screen clients, transactions, and counterparties against international sanctions lists and to refuse or delay transactions where applicable;

(iii) is required to report suspicious activity to the Anti-Money Laundering Authority (Αρχή Καταπολέμησης της Νομιμοποίησης Εσόδων από Εγκληματικές Δραστηριότητες — ΑΚΝΕΔ) without informing you of such report ("tipping-off" is prohibited by law);

(iv) collects and transmits originator and beneficiary information for crypto-asset transfers in accordance with the Travel Rule (TFR Articles 14-16);

(v) reports information on reportable users (tax residents in the EU and certain third countries) to the Greek Independent Authority for Public Revenue (Α.Α.Δ.Ε.) in accordance with Directive (EU) 2023/2226 (DAC8 — Crypto-Asset Reporting Framework). You agree that Capital Wallet may collect, process, and share such information with the Α.Α.Δ.Ε. and, indirectly, with the tax authorities of the country of your tax residence.

You undertake to provide truthful, accurate, and complete information at onboarding and throughout the relationship, and to update such information without delay in case of changes (including changes of tax residence). Failure to do so may result in the suspension or termination of your account and in regulatory or legal consequences.

In accordance with Article 75(7) of MiCAR and applicable Greek insolvency law, all crypto-assets held by Capital Wallet on your behalf shall be deemed separate from Capital Wallet's own assets and shall not form part of Capital Wallet's insolvency estate in the event of insolvency, restructuring, or liquidation. Client fiat funds held in segregated client accounts at credit institutions enjoy equivalent protection.

In the event of orderly wind-down, your crypto-assets shall be returned to you through the procedure set out in Capital Wallet's Wind-Down Plan, namely: Phase 1 (Customer Notification, Weeks 1-2); Phase 2 (Voluntary Withdrawal Window, Weeks 3-16, during which you withdraw your crypto-assets to a wallet of your choosing or to an alternative authorised CASP); and Phase 3 (Bulk Transfer, Weeks 17-24, during which any remaining assets are transferred to an escrow arrangement or to a designated alternative custodian under the supervision of the liquidator). Crypto-assets shall in no circumstance be used to satisfy claims of Capital Wallet's general creditors.

In addition to the statutory insolvency protection, Capital Wallet's sub-custodian BitGo Europe GmbH carries insurance coverage of USD 250,000,000 underwritten by Lloyd's of London and Munich Re. The sole shareholder of Capital Wallet has also undertaken a commitment to provide additional capital injection of up to EUR 100,000 should the capital adequacy ratio of Capital Wallet fall below 120% of the minimum regulatory requirement (Class 2: EUR 125,000).

Capital Wallet maintains and operates a Conflicts of Interest Policy designed to identify, prevent, manage, and disclose conflicts of interest that may arise in the course of providing its services. Where a conflict of interest cannot be sufficiently mitigated to prevent the risk of damage to your interests, Capital Wallet shall disclose the nature and sources of the conflict to you before undertaking the relevant transaction or service.

Specifically, Capital Wallet has identified the outsourcing of custody services to BitGo Europe GmbH as a potential source of conflicts (e.g., concentration risk, pricing transparency, exclusivity). The Company has assessed and mitigated these conflicts through: (i) independent verification that no ownership or affiliation exists between BitGo and Capital Wallet's shareholder or directors; (ii) maintenance of a list of pre-vetted alternative custodians (Komainu, Bitstamp Custody, Fireblocks Custody); (iii) annual review of BitGo's pricing and performance; and (iv) compliance with the conditions of MiCAR Article 75(8) governing sub-custody. The full Conflicts of Interest Policy is available on request.

In accordance with Article 66(5) of MiCAR and the related Regulatory Technical Standards, Capital Wallet publishes on its website (https://www.capitalwallet.gr/environmental-disclosures) information on the principal adverse impacts on climate and other environment-related adverse impacts of the consensus mechanism used to issue each crypto-asset in relation to which it provides services. The information is presented per crypto-asset and includes the type of consensus mechanism (Proof of Work, Proof of Stake, other), estimated energy consumption per validated transaction, estimated greenhouse gas emissions, and any mitigation measures known to Capital Wallet.

You are encouraged to consult the environmental disclosures before engaging in transactions involving crypto-assets the consensus mechanism of which may be material to your environmental considerations.

In accordance with MiCAR Article 78(11), Capital Wallet shall make available on its website, on an annual basis and free of charge, summary information on the top five execution venues used during the preceding year, in terms of volumes traded, and the quality of execution achieved. The first such report shall be published within four months following the end of the first full calendar year of operation as an authorised CASP.

You may request from Capital Wallet, at any time and free of charge, evidence that your orders have been executed in accordance with the Order Execution Policy. Capital Wallet shall provide such evidence within five (5) business days of receipt of the request.

1. Notice of Claim and Dispute Resolution Period. First action should be towards the Capital Wallet. Your concerns will be resolved without resorting to formal legal proceedings, if possible. If you have a dispute with Capital Wallet, then you should contact Capital Wallet and a ticket number will be assigned. Capital Wallet will attempt to resolve your dispute internally as soon as possible. The parties agree to negotiate in good faith to resolve the dispute (which discussions shall remain confidential and be subject to applicable rules protecting settlement discussions from use as evidence in any legal proceeding).

In the event the dispute cannot be resolved satisfactorily, and you wish to assert a legal claim against Capital Wallet, then you agree to set forth the basis of such claim in writing in a “Notice of Claim,” as a form of prior notice to Capital Wallet. The Notice of Claim must (1) describe the nature and basis of the claim or dispute, (2) set forth the specific relief sought, (3) provide the original ticket number, and (4) include your Capital Wallet account email. For the avoidance of doubt, the submission of a dispute to Capital Wallet for resolution internally and the delivery of a Notice of Claim to Capital Wallet are prerequisites to commencement of any legal proceeding.

2. Governing Law and Jurisdiction. These Terms are governed by the laws of the Hellenic Republic and the regulations of the HCMC, together with applicable European Union law (MiCAR, DORA, GDPR, TFR). Subject to mandatory consumer protection rules under Greek Law 2251/1994, retail (consumer) clients may bring legal proceedings against Capital Wallet before the competent Greek courts of their place of residence, and Capital Wallet shall bring proceedings against a retail client only before the courts of the client's place of residence. For professional and corporate clients, the courts of Athens, Greece shall have exclusive jurisdiction. Retail clients may also resort to alternative dispute resolution (ADR) through the Hellenic Consumer Ombudsman (Συνήγορος του Καταναλωτή, www.synigoroskatanaloti.gr) or the European Online Dispute Resolution platform (https://ec.europa.eu/consumers/odr).

3. Severability. If any portion of these Terms are adjudged to be invalid or unenforceable for any reason or to any extent, the remainder of these Terms will remain valid and enforceable and the invalid or unenforceable portion will be given effect to the greatest extent permitted by law. pending closure of your account.

1. Independent Parties: Capital Wallet is an independent contractor but not an agent of yours in the performance of these Terms. These Terms shall not be interpreted as facts or evidence of an association, joint venture, partnership, or franchise between the parties.

2. Entire Agreement: These Terms constitute the entire agreement between the parties regarding use of Capital Wallet Services and will supersede all prior written or oral agreements between the parties. No usage of trade or other regular practice or method of dealing between the parties will be used to modify, interpret, supplement, or alter the terms herein.

3. Interpretation and Revision: Capital Wallet reserves the right to alter, revise, modify, and/or change these Terms at any time. All changes will take effect immediately upon being published on Capital Wallet websites. It is your responsibility to regularly check relevant pages on our websites/applications to confirm the latest version of these Terms. If you do not agree to any such modifications, your only remedy is to terminate your usage of Capital Wallet Services and cancel your account. You agree that, unless otherwise expressly provided in these Terms, Capital Wallet will not be responsible for any modification or termination of Capital Wallet Services by you or any third party, or suspension or termination of your access to Capital Wallet Services.

For further inquiries, contact [email protected].