General Terms and Conditions

What you are agreeing to — plain language summary

This is a summary to help you understand the key points. It is not a substitute for reading the full terms below.

1. General Provisions

1.1 Scope and Purpose

These General Terms and Conditions ("GTC") govern all business relationships between Eti-Tech AG ("Eti-Tech", "we", "us", "the Company") and its customers ("Customer", "you") in connection with the use of the Eti-Tech platform, website (www.eti-tech.ch), mobile applications, APIs, and all associated products and services (collectively, the "Platform"). By completing the registration process and clicking "I agree to the General Terms and Conditions" (or equivalent acceptance checkbox), you enter into a legally binding contract with Eti-Tech on the terms set out in this document, together with the Privacy Policy, the Risk Disclosure Statement (www.eti-tech.ch/risk-disclosure), the Pricing page, and any product-specific addenda published on the Platform (collectively, the "Agreement"). Your acceptance is recorded electronically at the time of registration. No signature is required for this Agreement to be validly formed under Swiss law, and Eti-Tech retains the electronic record as evidence of your consent.

If you do not agree to these GTC, you must not click "I agree" and must immediately cease using the Platform.

1.2 Regulatory Status

Eti-Tech AG is a member of the Self-Regulatory Organisation VQF (Verband für qualitätsbewusste Finanzdienstleistungen) and is a Virtual Asset Service Provider (VASP) within the meaning of Art. 2 para. 3 of the Swiss Federal Act on Combating Money Laundering and Terrorist Financing (AMLA), supervised in that capacity through its VQF membership. Eti-Tech is subject to Swiss financial market law, FINMA guidance applicable to VQF members, and the VQF Regulations, and maintains its AML/CTF Policy and internal controls to meet these requirements.

Eti-Tech AG is not a bank and does not hold a banking licence. It does not accept deposits in the legal sense and does not offer investment advice, portfolio management, or any service regulated under the Swiss Financial Institutions Act (FinIA) or Financial Services Act (FinSA).

1.3 Amendments

Eti-Tech reserves the right to amend these GTC from time to time, subject to the following notice requirements:

• Minor or clarificatory amendments (e.g., formatting, contact details, non-substantive wording) take effect 14 days after notice via email or prominent notice on the Platform. Continued use of the Platform after the effective date constitutes acceptance.
• Material amendments (affecting fees, Customer rights, or obligations) require at least 30 days' notice via email or prominent notice on the Platform. For Customers other than Consumer Customers, continued use after the effective date constitutes acceptance. For Consumer Customers (natural persons acting outside professional or commercial activity), material amendments additionally require active re-consent before they take effect; continued use alone does not constitute acceptance of a material amendment for Consumer Customers.
• Legally mandated amendments expressly required by VQF, SECO, or applicable Swiss statutory law (including where such requirements flow from FINMA action toward VQF as the recognising authority) may take effect immediately upon notice, without regard to the notice periods above.

If you do not accept an amendment that requires your acceptance, you must close your account before the effective date.

1.4 Language

These GTC are provided in English and may be made available in German, French and Italian. In the event of any discrepancy between a translation and the English version, the English version shall prevail.

1.5 Electronic Communications

By creating an account, you consent to receive all communications from Eti-Tech electronically, including order confirmations, compliance notices, account updates, amendment notifications, and any other formal notices. Electronic communications sent to the email address registered on your account satisfy any legal requirement that such communications be "in writing." You are responsible for ensuring your registered email address is current and accessible. Eti-Tech is not liable for losses arising from your failure to receive electronic communications due to an incorrect or inaccessible email address.

You may withdraw your consent to receive marketing communications at any time as described in the Privacy Policy, Section 12 (Newsletter and Marketing Communications). You may not withdraw consent to receive compliance, legal, or account-related communications, as these are necessary for the performance of the Agreement and our regulatory obligations.

1.6 Mobile Applications

Where Eti-Tech makes mobile applications available via third-party platforms (including the Apple App Store and Google Play Store), your use of those applications is also subject to the terms of service of the relevant platform operator. In the event of conflict between those platform terms and these GTC, these GTC shall prevail to the maximum extent permitted. Eti-Tech's mobile applications are provided "as is" and updates may be required from time to time. Eti-Tech accepts no liability for losses arising from your failure to install required updates or from platform operator restrictions on availability.

2. Definitions

For the purposes of these GTC, the following terms have the meanings set out below:

• "AML/CTF Policy" means Eti-Tech's Anti-Money Laundering and Combating of Terrorism Financing Policy, as amended from time to time.
• "AMLA File" means the compliance file maintained by Eti-Tech for each Customer containing all KYC documentation, risk profile, transaction journal, and related compliance records.
• "Beneficial Owner" means the natural person who ultimately and effectively owns or controls the assets involved in a transaction or business relationship.
• "Crypto Assets" or "Virtual Assets" means digital representations of value that can be transferred, stored, or traded electronically, including cryptocurrencies such as Bitcoin (BTC), Ether (ETH), BNB and TRON (TRX), and stablecoins such as Tether (USDT). The Crypto Assets currently supported are listed on the Platform (Section 8.4).
• "Escrow" means the escrow mechanism operated by a P2P Platform, by which Crypto Assets are locked on the P2P Platform pending confirmation of payment (Section 5.9). Eti-Tech itself does not provide escrow services.
• "Fiat Currency" means government-issued legal tender, such as Swiss Francs (CHF) or Euros (EUR). The Fiat Currencies currently supported are indicated on the Platform.
• "Identity Verification Provider" means the third-party provider engaged by Eti-Tech for identity verification and onboarding, as named in the Privacy Policy.
• "KYC" means Know Your Customer — the identity verification and due diligence process required by Swiss AML law.
• "Order" means an instruction submitted by a Customer to buy or sell Crypto Assets or exchange currencies through the Platform.
• "P2P Platform" means a third-party peer-to-peer (P2P) trading platform on which Eti-Tech acts as merchant, as described in Section 5.9.
• "Pending Settlement Claim" means the contractual claim of a Customer against Eti-Tech for settlement of an Order after Eti-Tech has received the Customer's input, as described in Section 7.6.
• "Permanent Business Relationship (PBR)" means a business relationship established under a customer account that is not limited to the execution of a single transaction.
• "Platform" means the Eti-Tech website, applications, APIs, and all associated services.
• "Provisioned Wallet" means the self-custodial Wallet created by Eti-Tech for the Customer through its Wallet Infrastructure Provider (Section 5.5).
• "Spread" means the difference between the buy and sell price offered by Eti-Tech, which constitutes part of Eti-Tech's remuneration.
• "Travel Rule" means the requirements of Art. 14 VQF-Regulation and FATF Recommendation 16 regarding the transmission of customer information alongside virtual asset transfers.
• "Treasury Wallet" means Eti-Tech's own wallet used for its proprietary inventory of Crypto Assets; it does not hold Crypto Assets of Customers.
• "Verified Bank Account" means a bank account held in the Customer's own name that has been verified by means of a verification payment (penny transfer) in accordance with Section 4.3.
• "Wallet" means a blockchain-based address for sending, receiving, and holding Crypto Assets.
• "Wallet Infrastructure Provider" means the third-party provider of wallet infrastructure engaged by Eti-Tech for the Provisioned Wallets, as named in the Privacy Policy.
• "Wallet Screening" means the verification and analytics processes described in Section 8.2 used to establish Wallet ownership/control and to assess a Wallet's risk profile.

3. Eligibility and Account Registration

3.1 Eligibility

To use the Platform and open an account, you must:

• Be a natural person of at least 18 years of age;
• Have the legal capacity to enter into binding contracts under the law of your jurisdiction;
• Not be resident in or incorporated in a jurisdiction classified as prohibited under Eti-Tech's AML/CTF Policy (Appendix C, Country Risk Assessment), including but not limited to: North Korea, Iran, Myanmar, Syria, Cuba, Russia, Belarus, Venezuela, Afghanistan, Algeria, Angola, Bangladesh, and other jurisdictions listed in the AML/CTF Policy;
• Not be subject to any international or national sanctions (UN, EU, SECO, OFAC, UK OFSI);
• Not be a US person (including US citizens, US tax residents and persons resident in the United States);
• Not be opening an account on behalf of another person without proper authorisation and disclosure;
• Use the Platform only for lawful purposes consistent with these GTC.

The prohibited-jurisdictions list above is illustrative and non-exhaustive. The authoritative and current list is maintained in Eti-Tech's AML/CTF Policy, Appendix C (Country Risk Assessment). In the event of any discrepancy between this Section and the AML/CTF Policy, the AML/CTF Policy's Appendix C controls. Eti-Tech may update this list at any time without prior notice, consistent with its ongoing AML/CTF risk-assessment obligations.

Eti-Tech's services are directed at clients in Switzerland. Persons resident outside Switzerland may use the Platform only where they have approached Eti-Tech on their own exclusive initiative (reverse solicitation) and where this is permitted under the laws applicable to them. Eti-Tech is not authorised under the EU Markets in Crypto-Assets Regulation (MiCA). Eti-Tech may restrict access for residents of any jurisdiction at any time.

Eti-Tech reserves the right to decline any application for an account without stating reasons.

3.2 Account Registration

To establish a Permanent Business Relationship and access the full functionality of the Platform, you must complete the following registration steps:

• Provide accurate and complete personal information as required by the registration form.
• Complete the KYC onboarding process, including identity verification, as described in Section 4.
• Register at least one Verified Bank Account by means of a verification payment (penny transfer), see Section 4.3.
• Accept these General Terms and Conditions and acknowledge the Privacy Policy.
• Create a login with email and password or via single sign-on (Google or Apple); you can activate two-factor authentication (2FA, TOTP) in your profile.

You represent that all information provided during registration is true, accurate, current, and complete. You undertake to promptly update your account information if any details change. Providing false or misleading information constitutes grounds for immediate account termination and may constitute a criminal offence.

3.3 Account Types

Eti-Tech currently offers the following account type:

• Individual Account: for natural persons acting in their personal capacity.

Accounts for legal entities are not currently offered. Where Eti-Tech introduces them, the applicable additional requirements will be set out in updated terms.

Accounts are personal and non-transferable. You must not allow third parties to access your account. You are responsible for all activity conducted under your account credentials.

3.4 Account Security

You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your account. You must:

• Use a strong, unique password (where you log in with email and password), keep your Google or Apple account secure (where you use single sign-on), and enable 2FA, which Eti-Tech strongly recommends;
• Notify Eti-Tech immediately at compliance@eti-tech.ch if you suspect any unauthorised access to your account;
• Not share your credentials with any third party;
• Log out of your account at the end of each session.

Eti-Tech and its staff will never ask you for your password, 2FA codes or the private key of your Wallet, and will never ask you to send Crypto Assets to an address outside an Order on the Platform. Disregard any such request and report it to compliance@eti-tech.ch. Eti-Tech shall not be liable for losses arising from your failure to maintain adequate account security, except in cases of Eti-Tech's gross negligence or wilful misconduct.

3.5 Unauthorised Transactions

Any Order, Wallet operation or other instruction given using your login credentials or an active session of your account is deemed to have been given by you. Eti-Tech may execute it without further verification and is not obliged to check whether it was actually given by you.

You must review your transaction history regularly. You must report any suspected unauthorised access to your account, and any transaction you did not authorise or that was executed incorrectly, to compliance@eti-tech.ch immediately and at the latest within 7 days of becoming aware of it. Any loss resulting from a later report is deemed caused by your own fault, and Eti-Tech is not liable for it.

Transactions to which you do not object within 30 days of their execution are deemed approved. An objection does not oblige Eti-Tech to reverse, cancel or reimburse a transaction. It only preserves a claim you may have for an execution error attributable to Eti-Tech (for example, an incorrect amount paid out), subject to Section 12.

Blockchain transactions are irreversible. Eti-Tech is not obliged to reverse or reimburse unauthorised or incorrect transactions and is not liable for any resulting loss, unless the loss was caused by Eti-Tech intentionally or through gross negligence.

4. Know Your Customer (KYC) and AML Compliance

4.1 Legal Obligation

As a VASP and VQF SRO member, Eti-Tech is legally required under the AMLA, AMLO, AMLO-FINMA, and VQF Regulations to verify the identity of all Customers before providing services. No services will be provided until KYC onboarding is complete and approved. As a firm policy, Eti-Tech applies KYC to all Customers without exception, even where Swiss AML law provides limited de minimis thresholds for certain occasional, low-value transactions (Art. 3 AMLA). You acknowledge and agree that Eti-Tech's compliance obligations take precedence over service provision at all times.

4.2 Required Documentation

Individual Customers

You must provide:

• Valid government-issued photo identification with machine-readable zone (passport, national ID card, or driver's licence);
• Proof of residential address (utility bill, official correspondence, not older than 3 months);
• Geolocation data (GPS location of your device, only after you grant your device's location permission, and IP address) captured during onboarding to support the verification of your residential address;
• Biometric verification (photograph and liveness check);
• Declaration of source of funds and source of wealth and, where required under Eti-Tech's risk-based approach, supporting evidence;
• Completed KYC questionnaire including profession, income, intended use of the Platform, and planned transaction volumes;
• Declaration of Beneficial Owner (Form A, as required by AMLO-FINMA).
• Verification payment (penny transfer) from a bank account held in your own name (Section 4.3).

4.3 Verification Methods

Identity verification is carried out via online identification through Eti-Tech's Identity Verification Provider, in accordance with FINMA Circular 2016/7. The checks include document verification, biometric liveness check, proof of address, and PEP, sanctions and adverse-media screening, and may in future include reading the biometric chip of your identity document (NFC).

As part of the online identification process, Eti-Tech requires you to send a small confirmation payment from a bank account held in your name at a bank domiciled in a permissible FATF member state, in order to authenticate your identity and bank relationship. Eti-Tech verifies the account holder name and IBAN of this payment against your identity. The bank account used is registered as your Verified Bank Account. You may register further bank accounts held in your own name by the same procedure. All fiat payments to and from Eti-Tech are made exclusively from and to a Verified Bank Account.

4.4 Risk Classification

Upon completion of KYC, Eti-Tech assigns each Customer a risk classification in accordance with its internal AML/CTF Policy. This classification determines the level of due diligence, transaction monitoring, and periodic review applicable to your account. Risk classification is a legal requirement and is not subject to your objection, although you may request a review by contacting compliance@eti-tech.ch.

4.5 Ongoing Monitoring and Periodic Review

Eti-Tech monitors all accounts and transactions on an ongoing basis. In addition, all customer files are subject to periodic review at intervals determined by the Customer's risk classification, in accordance with Eti-Tech's internal AML/CTF Policy.

Eti-Tech may request updated documentation or information at any time. Failure to provide requested information within a reasonable timeframe may result in restriction or termination of your account.

4.6 Right to Refuse and Terminate

Eti-Tech reserves the right, in its sole discretion and without stating reasons (to the extent permitted by law), to:

• Decline to open an account or establish a business relationship;
• Suspend or restrict access to any account or service;
• Terminate an account and wind down the business relationship;
• Refuse to execute any transaction;
• Report the business relationship or any transaction to MROS, SECO, or other authorities as required by law.

Eti-Tech will exercise these rights in a manner consistent with its regulatory obligations and its AML/CTF Policy, and, where legally permissible, will give you as much information about the reason as the circumstances allow.

4.7 Account Dormancy (Soft Close)

If your account has had no login or transaction activity for a period of 364 days, Eti-Tech will place it into a dormant state ("Soft Close"). A dormant account cannot be used to place Orders or access Wallet functionality. To reactivate a dormant account, you will be required to complete the KYC onboarding process again in full, including updated identity verification, as though opening a new account. Eti-Tech will retain your existing AMLA file and transaction records for the applicable statutory retention periods regardless of dormancy status, Crypto Assets in your Provisioned Wallet remain under your control and are not affected by the Soft Close. Any Pending Settlement Claim existing at the time of the Soft Close is settled or returned in accordance with Section 7.6.

5. Services

5.1 Overview

Subject to your successful onboarding and continued compliance with these GTC, Eti-Tech offers the services described in this Section. This document describes the services currently available. Additional features may be introduced in the future and will be governed by updated terms published at launch. Eti-Tech does not hold Crypto Assets in custody for Customers.

5.2 Conversion and Exchange Terminal

Eti-Tech's core service is a Converter / Terminal enabling Customers to buy and sell Crypto Assets. The following exchange pairs are supported:

• Fiat to Crypto (Onramp) (e.g. CHF → BTC, CHF → ETH)
• Crypto to Fiat (Offramp) (e.g. BTC → CHF, ETH → CHF)
• Crypto to Crypto (Swap) (e.g. BTC → ETH)

Eti-Tech acts as principal and as your direct counterparty for each Order. Eti-Tech fulfils Orders from its own inventory held in its Treasury Wallet or, where required, acquires the relevant Crypto Assets from third-party liquidity providers.

Accepted payment methods currently include: bank transfer in CHF via the Swiss Interbank Clearing system (SIC). Further payment methods (e.g. SWIFT, SEPA, TWINT or card payments via a payment service provider) and currencies (e.g. EUR) may be added; the methods available for each Order are shown on the Platform. Not all payment methods are available for all transaction types or amounts.

5.3 Third-Party Liquidity, Payment and Wallet Infrastructure

Eti-Tech uses third-party liquidity providers, banking and payment partners, and wallet infrastructure providers to fulfil Orders. These providers are independent third parties engaged by Eti-Tech; you have no contractual relationship with them, and your contractual rights under these GTC exist against Eti-Tech only. This does not extend Eti-Tech's liability for such providers beyond this Section 5.3 and Section 12. Your separate relationship with a P2P Platform (Section 5.9) and with your own bank remains unaffected; neither is a provider of Eti-Tech.

Eti-Tech selects, instructs and monitors these providers with due care.

In the event that a third-party provider fails to perform, becomes insolvent, or suffers a material operational disruption during the execution of a Customer's Order, Eti-Tech will use reasonable efforts to: (a) notify the affected Customer; (b) re-execute the Order via an alternative provider at the rate applicable under Section 6.3 where possible; and (c) where re-execution is not possible, return to the Customer the full amount delivered by the Customer for that Order, less any amounts irrecoverably transmitted prior to failure.

Eti-Tech is liable only for losses caused by its failure to exercise due care in the selection, instruction and monitoring of third-party providers; any further liability for the acts and omissions of such providers is excluded to the extent permitted by Art. 101 para. 2 and 3 CO.

5.4 User Platform and Accounts

Registered Customers have access to a personal user account on the Platform offering:

• Secure login via email and password or single sign-on (Google, Apple), with optional two-factor authentication (TOTP);
• Order history and transaction records;
• Individual account profile.

5.5 Wallet Custody — Non-Custodial

Eti-Tech provides a decentralised (non-custodial) blockchain-based Wallet service allowing Customers to hold, send, receive, and exchange Crypto Assets. Your Wallet is created when you request a deposit address or a Wallet, or automatically when an Order pays out to a blockchain for which you do not yet have a Wallet (one Wallet per blockchain family). Key features include:

• Standard Wallet functions: send, receive, exchange;
• Support for mainstream blockchains and networks designated by Eti-Tech;
• Multi-chain support across approved asset lists.

The Wallet is accessible only to Customers who have completed KYC verification.

Eti-Tech's Wallet uses wallet infrastructure supplied by its third-party Wallet Infrastructure Provider. No single party — including Eti-Tech and its Wallet Infrastructure Provider — ever holds a complete, usable private key for your Wallet, and Eti-Tech has implemented technical and organisational measures to prevent any transfer of your Crypto Assets without your participation. The private key is split into encrypted key shares (Shamir secret sharing) held on separate infrastructure and exists in complete form only temporarily within a trusted execution environment (TEE) during signing. Eti-Tech holds no key share, recovery share, persistent signer or signing policy for your Wallet; Wallet operations require a valid authenticated session of your Eti-Tech account. You can view and export the private key of your Wallet at any time through the Wallet interface; account-recovery options are also provided there, which you should review and set up. If you lose access to your authenticated login and have not separately exported your key material, Eti-Tech cannot recover access to your Wallet on your behalf.

Because Eti-Tech has no access to the private key of your Wallet and is not authorised to move your Crypto Assets without your participation, Eti-Tech does not treat these assets as part of its own balance sheet. How such assets would be treated in the event of Eti-Tech's insolvency is ultimately a matter of Swiss law and is not determined by these GTC.

You have no direct contractual relationship with the Wallet Infrastructure Provider; it acts as Eti-Tech's subcontractor, and Eti-Tech's liability in connection with the Wallet is governed exclusively by Sections 5.3 and 12. If your account is closed, suspended or placed in Soft Close, your Wallet and the Crypto Assets in it remain accessible to you with your private key; Eti-Tech's services in relation to the Wallet end with the account.

5.6 Platform Availability

Eti-Tech aims to provide continuous availability of the Platform but does not guarantee uninterrupted access. The Platform may be temporarily unavailable due to:

• Scheduled maintenance (Eti-Tech will provide advance notice where possible, typically via the Platform or email);
• Unplanned technical incidents, security events, or infrastructure failures;
• Blockchain network congestion, outages, or protocol-level events;
• Regulatory or legal requirements mandating suspension of the Platform or specific services;
• Force majeure events (see Section 16.5).

Eti-Tech will use reasonable efforts to restore availability as quickly as possible following any unplanned outage. Eti-Tech shall not be liable for losses arising from Platform unavailability unless caused by Eti-Tech's gross negligence or wilful misconduct. During periods of scheduled maintenance, existing Orders will not be affected; new Orders cannot be placed. Eti-Tech maintains the right to suspend trading in specific assets, asset pairs, or services at any time for technical, regulatory, or risk management reasons, with or without prior notice depending on the urgency of the situation.

5.7 Beta and Preview Features

From time to time, Eti-Tech may make new features, products, or services available in beta or preview form prior to their full commercial launch. Beta and preview features are provided on an "as is, as available" basis without warranty of any kind. By using a beta or preview feature, you acknowledge that:

• The feature may contain bugs, errors, or incomplete functionality;
• The feature may be modified, suspended, or withdrawn at any time without notice;
• Eti-Tech's liability in respect of beta features is limited to the maximum extent permitted by law;
• Beta features are not covered by any service level commitments or availability guarantees.

Beta and preview features are clearly labelled as such on the Platform. Your feedback on beta features is welcome at compliance@eti-tech.ch.

5.8 Third-Party Services and Links

The Platform may contain links to, or integrations with, third-party websites, services, or platforms (including KYC providers, blockchain analytics tools, payment processors, and banking partners). Eti-Tech provides these links and integrations for convenience only. Eti-Tech does not endorse, control, or accept responsibility for the content, privacy practices, or terms of any third-party service.

Your use of any third-party service is governed exclusively by the terms and conditions of that third party. Eti-Tech is not liable for any loss or damage arising from your use of, or reliance on, any third-party service. You should review the terms and privacy policies of any third-party service before using it.

Where Eti-Tech engages third-party processors to perform regulated functions (such as identity verification for KYC), those providers act under Eti-Tech's instruction and under contractual data protection obligations. Eti-Tech's regulatory responsibility for such outsourced functions remains unaffected; this does not extend Eti-Tech's civil liability beyond Sections 5.3 and 12.

5.9 Peer-to-Peer (P2P) Merchant Services

In addition to the Platform, Eti-Tech acts as a verified professional merchant on P2P Platforms. Eti-Tech publishes offers on the P2P Platform to sell Crypto Assets against Fiat Currency. The following applies:

• Eti-Tech only transacts with P2P users who have completed Eti-Tech's full KYC onboarding in accordance with Section 4 and have accepted these GTC and the Privacy Policy. Eti-Tech provides the link to its onboarding process via the P2P Platform.
• Eti-Tech's P2P offers are directed exclusively at users resident in Switzerland.
• You must pay the Fiat Currency amount exclusively from a bank account held in your own name to the bank account designated by Eti-Tech in the P2P order. The account holder name must match the name verified in your KYC onboarding and on your P2P Platform account. Payments from third parties are returned.
• Upon confirmed receipt of your payment and completion of AML checks, Eti-Tech releases the Crypto Assets through the Escrow of the P2P Platform to your account on the P2P Platform. Delivery to your P2P Platform account constitutes fulfilment of Eti-Tech's delivery obligation.
• The P2P Platform is an independent third party. Your use of the P2P Platform, including its Escrow, appeal and dispute-resolution procedures, is governed by the P2P Platform's own terms. Disputes about a P2P order submitted to the P2P Platform are decided by the P2P Platform under its rules; Eti-Tech is not responsible for the acts, omissions or decisions of the P2P Platform. This does not affect your claims against Eti-Tech under these GTC.
• In the relationship between you and Eti-Tech, these GTC apply to P2P transactions. Sections 5.5 and 7.3 to 7.4A do not apply to P2P transactions.

6. Fees, Pricing, and Spread

6.1 General Pricing Principles

Eti-Tech's remuneration consists of the fees published on the Pricing page (www.eti-tech.ch/pricing). Where applicable, Eti-Tech may also apply a Spread, which is reflected in the rate shown on the Platform. All applicable fees and the current Spread are displayed on the Platform before you confirm an Order. Where the final amount depends on the amount received or the final exchange rate (Section 6.3), the fee is calculated on that basis. By confirming an Order, you accept the fees displayed at that time and the pricing mechanism described in Section 6.3.

Eti-Tech operates on a transparent, no-hidden-fees basis. Any fees will be clearly disclosed prior to order confirmation.

6.2 Fee Schedule

The current fee schedule is published on the Platform at www.eti-tech.ch/pricing and may be updated from time to time. The following general principles apply:

• Exchange / conversion fee: charged as published on the Pricing page and displayed at the time of order (subject to Section 6.3); a minimum fee per Order may apply. For crypto-to-crypto Orders, the swap fee is included in the quoted swap rate.
• Wallet transaction fees: network (blockchain) gas fees for outgoing Crypto Asset transfers are passed on to the Customer at cost. This applies to transfers you initiate from your Wallet. For Orders, Eti-Tech bears the network fees for transfers from its Treasury Wallet to your Provisioned Wallet and for collecting Crypto Assets from your Provisioned Wallet, except for the Bitcoin network (miner) fee for collecting BTC, which is borne by you and shown before you confirm the Order.

Fees for any additional features introduced in the future will be published on the Platform before launch.

6.3 Indicative Prices and Determination of the Exchange Rate

When you initiate an Order, the exchange rate displayed is indicative for fiat-to-crypto Orders and is not locked: the applicable exchange rate is determined at the time your payment is received on Eti-Tech's bank account, so the amount you receive may differ from the amount shown when you placed the Order. For crypto-to-fiat and crypto-to-crypto Orders, the exchange rate is fixed in the quote: once you accept the quote within its validity period (shown in the quote), the quoted rate applies and is not recalculated; if the quote expires before acceptance, a new quote is required. The final rate, fees and amount are shown in your transaction record.

6.4 Taxes

You are solely responsible for determining and meeting any tax obligations arising from your use of the Platform, including but not limited to income tax, capital gains tax, and value-added tax. Eti-Tech does not provide tax advice.

6.5 Transaction Limits

For compliance, risk-management, and business policy reasons, Eti-Tech applies minimum and maximum amounts per Order as well as daily and monthly maximum amounts per Customer. The limits applicable to you are shown on the Platform. Eti-Tech may set, change or individually adjust limits at any time, in particular based on your risk classification, without stating reasons. Orders or payments exceeding an applicable limit may be rejected, or the excess amount returned in accordance with Section 7.5A.

7. Order Process and Settlement

7.1 Order Placement

To place an Order, you must:

• Select the asset pair and enter the desired amount on the calculator/terminal.
• Review the rate (indicative for fiat-to-crypto Orders; fixed quote for crypto-to-fiat and crypto-to-crypto Orders) and the applicable fees.
• Select your payment method.
• Confirm the Order. By confirming, you enter into a binding agreement to complete the transaction on the terms displayed, with the exchange rate determined in accordance with Section 6.3.

Orders may not be cancelled after confirmation except where explicitly permitted by Eti-Tech (e.g. where payment has not been initiated within the payment window).

7.2 Payment Obligations

You should pay the amount specified in the Order confirmation using the payment method and account details provided. The following rules apply:

• Payment must be made exclusively from your Verified Bank Account (for fiat) or from your Provisioned Wallet (for Crypto Assets). Payments from third-party accounts will be rejected and returned (less any applicable bank charges).
• For fiat payments, you must include the payment reference number provided in the Order confirmation. Orders cannot be matched without the correct reference. Payments without a correct reference are held and analysed and, where they cannot be matched to an Order, returned to the originating account in accordance with Section 7.5A.
• For fiat payments, Eti-Tech provides you with a Swiss QR code (QR-bill standard) in the Order confirmation containing Eti-Tech's account details, the amount and the payment reference, which you can scan with your banking app to pre-fill your payment order. You remain responsible for checking the pre-filled data before releasing the payment.
• Payment must be received within the payment window specified in the Order confirmation. Late payments may result in Order cancellation.
• Overpayment: where you pay more than the Order amount, the full amount received is converted at the rate determined under Section 6.3.
• Underpayment: where you pay less than the Order amount, the amount received is converted provided it reaches the applicable minimum Order amount (currently CHF 100); otherwise, Eti-Tech retains a processing fee (currently CHF 10, as published on the Pricing page) and returns the residual amount to your Verified Bank Account in accordance with Section 7.5A.

7.3 Crypto Asset Deliveries

Crypto Assets will be released to your Provisioned Wallet only after:

• Receipt of cleared funds (for fiat-to-crypto Orders) or incoming Crypto Assets (for crypto-to-crypto or crypto-to-fiat Orders) has been confirmed by Eti-Tech;
• Verification of the destination Wallet's ownership/control in accordance with Section 8.2;
• All applicable AML checks have been completed.

Delivery times depend on network congestion and blockchain confirmation requirements. Eti-Tech targets release of Crypto Assets within one (1) hour of confirmed receipt of your funds, on a best-effort basis, but does not guarantee specific delivery times. The time until your fiat payment is received depends on the processing by the banks involved.

7.4 Settlement of Fiat-to-Crypto Orders

For fiat-to-crypto Orders, the following applies:

• You must transfer the fiat amount and provide the bank transfer receipt where required.
• Upon confirmation of receipt of cleared funds into Eti-Tech's bank account, the exchange rate is determined in accordance with Section 6.3 and Eti-Tech transfers the corresponding Crypto Assets from its Treasury Wallet to your Provisioned Wallet.
• The release may be automated via bank API or confirmed manually by Eti-Tech.

Disputes arising from fiat-to-crypto Orders (e.g. incorrect payment amount, payment from a third-party account) are handled in accordance with Section 7.5.

7.4A Settlement of Crypto-to-Fiat and Crypto-to-Crypto Orders

The following protections apply to Orders where the Customer delivers Crypto Assets as the input:

• Crypto Assets for an Order may only be delivered from your Provisioned Wallet to Eti-Tech's Treasury Wallet. Crypto Assets sent from any other wallet or to any other address do not constitute delivery for an Order.
• Crypto-to-Fiat Orders (e.g. BTC → CHF): Eti-Tech will confirm receipt and AML screening of incoming Crypto Assets before paying the fiat output to your Verified Bank Account. Eti-Tech targets release, on a best-effort basis, within two (2) business days of confirmed on-chain receipt. If release cannot occur within five (5) business days, Eti-Tech will notify the Customer with an estimated timeline.
• Crypto-to-Crypto Orders (e.g. BTC → ETH): Eti-Tech will confirm receipt of the input Crypto Asset before releasing the output Crypto Asset.

In the event that Eti-Tech receives a Customer's Crypto Asset input but is unable to deliver the output, Eti-Tech will use reasonable efforts to: (a) notify the Customer; (b) deliver the output via an alternative route; or (c) return the input Crypto Assets (or, where this is not possible, their equivalent value at the prevailing market rate) to the Customer's Provisioned Wallet, less network fees. Eti-Tech's obligation to deliver or refund is a direct contractual obligation of Eti-Tech and is not contingent on the Customer's ability to reverse the input transaction.

7.5 Disputes and Order Cancellation

An Order may be cancelled or disputed in the following circumstances:

• Payment of an incorrect amount;
• Payment received from a third-party account;
• Failure to pay within the payment window;
• AML or sanctions concerns arising after Order confirmation;
• Technical errors affecting the Order at no fault of the Customer (Eti-Tech will offer a revised Order in such cases).

In the event of a dispute, you must contact Eti-Tech promptly at compliance@eti-tech.ch with your Order ID and supporting documentation. Eti-Tech will aim to resolve disputes within 10 business days.

7.5A Refund and Cancellation Mechanics

Where an Order is cancelled, the following mechanics apply:

• Timeline: Eti-Tech will return funds within five (5) business days of cancellation, or as soon as AML/sanctions clearance permits.
• Currency: Refunds are made in the original payment currency (fiat to originating bank account; Crypto Assets to originating or designated Wallet).
• Exchange rate: Refunds are at the face value of the amount received. Any quoted rate is not preserved for refund purposes.
• Charges: Bank and network fees incurred in returning funds are deducted at cost, without mark-up, and disclosed at the time of refund.
• Third-party delays: Where refund is delayed because a third-party provider has not yet returned funds to Eti-Tech, Eti-Tech will notify the Customer and provide updates every five (5) business days until completion.

7.6 Pending Settlement Claims

From the moment Eti-Tech receives your fiat payment or your Crypto Assets for an Order until the Order is settled, you hold a Pending Settlement Claim against Eti-Tech for delivery of the corresponding output. The funds or Crypto Assets received become the property of Eti-Tech upon receipt, and Eti-Tech records the corresponding delivery obligation in its books.

A Pending Settlement Claim is not a deposit, bears no interest, cannot be transferred or used for any other purpose and is solely a claim for settlement of the specific Order. Eti-Tech does not maintain account balances for Customers. Pending Settlement Claims are not protected by deposit insurance (esisuisse).

Eti-Tech settles each Order without undue delay and in any event within 60 days of receipt of your funds or Crypto Assets. Where an Order cannot be settled within that period, Eti-Tech returns the funds or Crypto Assets received exclusively to their source (your Verified Bank Account or your Provisioned Wallet), subject to Sections 5.3 and 7.5A and to any legal obligation to block assets.

Repeated payments and returns without executed Orders are not permitted and may lead to suspension of your account.

8. Virtual Assets: Special Provisions

8.1 Travel Rule Compliance

In accordance with the Crypto Travel Rule (Art. 14 VQF-Regulation and FATF Recommendation 16), where Eti-Tech itself transfers Crypto Assets to, or receives Crypto Assets from, a wallet or account held at another VASP (for example, a P2P Platform), Eti-Tech is required to transmit or obtain the following information:

• Your full name;
• Your public Wallet address;
• Your residential address;
• The name and public address of the beneficiary.

You authorise Eti-Tech to transmit this information to the receiving or sending VASP as required by law. Eti-Tech may reject, delay, or hold any incoming transfer where the Travel Rule information required from the sending institution is insufficient, cannot be validated, or is not provided in a form Eti-Tech can process. Transfers from non-compliant or unverifiable senders may be rejected or returned.

Where the counterparty VASP, including a P2P Platform, does not support the transmission of Travel Rule information, Eti-Tech may use other appropriate means to obtain the information required under applicable law, in particular to establish that the account concerned is held in your name and under your control. You must cooperate and provide the information or evidence requested. Eti-Tech may refuse or suspend the transfer if the required information cannot be obtained.

8.1A External Wallets and Permitted Use

Outgoing transfers. You may send Crypto Assets from your Wallet under your sole control. Such transfers are initiated by you and are not executed by Eti-Tech; you are solely responsible for them and for their compliance with applicable law. The Wallet service is provided for your own personal or business use (as applicable to your Account Type); you must not use it to send Crypto Assets on behalf of, or for the benefit of, any other person, business, or organisation.

Incoming transfers. You may receive Crypto Assets from any external wallet, including a wallet belonging to a third party. Where Crypto Assets received from third parties are subsequently delivered to Eti-Tech for an Order, they are subject to Eti-Tech's Travel Rule, AML, and Wallet ownership verification procedures described in Sections 8.1 and 8.2. Eti-Tech may request information about the source of incoming funds, and may restrict, delay, or hold a transfer pending review in accordance with those Sections.

8.2 Wallet Ownership Verification and Screening

Eti-Tech provides access to a non-custodial Wallet environment through its Wallet Infrastructure Provider (see Section 5.5). Before releasing Crypto Assets to, or accepting Crypto Assets from, an external Wallet where verification is required, Eti-Tech verifies that the destination or source Wallet is genuinely owned and controlled by the intended counterparty, as required by the Crypto Travel Rule (Art. 14 VQF-Regulation). Eti-Tech also screens Crypto Assets delivered to it, and the transaction history of the delivering wallet, using blockchain analytics tools.

Where a Wallet was provisioned through Eti-Tech's Wallet service for a Customer who has completed KYC, and the allocation of that Wallet to the Customer is recorded by Eti-Tech, the provisioning constitutes evidence of the Customer's ownership and control of the Wallet in accordance with Eti-Tech's AML/CTF Policy; Eti-Tech may nevertheless require additional verification on a risk-based basis. Before completing a transfer where verification is required, Eti-Tech verifies ownership and control of the relevant Wallet using one or more recognised methods, which may include digital-signature / message-signing verification, micro-transaction verification ("Satoshi test"), equivalent blockchain-analytics proof-of-control checks, or another technically robust verification method that Eti-Tech reasonably accepts as adequate in the circumstances. The same verification methods apply where a Customer sends to or receives from a Wallet not provisioned through Eti-Tech's Wallet service.

You must provide the public key of your external Wallet prior to the transaction where technically possible. Eti-Tech reserves the right to:

• Refuse to accept Crypto Assets from, or release Crypto Assets to, a Wallet where ownership or control cannot be adequately verified;
• Place a Wallet on a watchlist or blacklist;
• Suspend an account pending further investigation following a verification failure or other risk indicator.

Where a micro-transaction verification (Satoshi Test) is required to confirm your control over an external Wallet, you agree to perform this verification as instructed.

8.3 Wallet Custody — Customer Responsibility

You acknowledge and accept the following risks associated with Crypto Assets and Wallets:

• Blockchain transactions are irreversible once confirmed. Eti-Tech cannot reverse a completed on-chain transaction.
• You are solely responsible for providing accurate Wallet addresses. Errors in Wallet addresses may result in permanent loss of assets. Eti-Tech is not liable for transfers made to incorrect addresses provided by the Customer.
• If you view or export the private key of your Wallet, you are solely responsible for keeping it secure. Anyone who obtains your private key can move your Crypto Assets. Eti-Tech is not liable for losses resulting from the disclosure, loss or misuse of your private key or login credentials, including through phishing, malware or social engineering.
• Network fees (gas) for transfers you initiate from your Wallet are borne by you and may vary; for Orders, Section 6.2 applies.
• Smart contract risks, protocol upgrades, hard forks, and other blockchain-level events may affect the value or accessibility of your assets. Eti-Tech accepts no liability for losses arising from such events beyond its reasonable control.

8.4 Supported Assets

Eti-Tech maintains a list of supported Crypto Assets on the Platform. Assets not on the approved list cannot be traded, held, or transferred on the Platform. Eti-Tech may add or remove supported assets at any time with reasonable notice. Currently supported: Bitcoin (BTC), Ether (ETH), Tether (USDT), BNB and TRON (TRX), on the networks indicated on the Platform.

8.5 Fraud and Scam Prevention

Eti-Tech may ask you about the purpose of a transaction and the intended recipient of Crypto Assets. You must inform Eti-Tech if you are acting on instructions from another person, such as an investment platform, broker, adviser or online acquaintance.

Eti-Tech may delay or refuse an Order or a transfer if there are indications that you may be the victim of fraud, coercion, social engineering or an investment scam. Such measures do not constitute investment advice. Eti-Tech has no obligation to detect or prevent fraud against you and is not liable for losses resulting from fraud by third parties, nor for any delay or refusal made in good faith.

9. Prohibited Uses

You must not use the Platform for any of the following purposes:

• Money laundering, terrorist financing, or any activity that violates applicable AML/CTF laws;
• Circumventing any sanctions regime (UN, EU, SECO, OFAC, UK OFSI);
• Fraud, identity theft, or misrepresentation;
• Trading on behalf of a sanctioned person or entity, or a person resident in a prohibited jurisdiction;
• Providing false, incomplete, or misleading information during onboarding or at any time thereafter;
• Using automated bots, scripts, or other tools to manipulate the Platform or circumvent security measures;
• Conducting market manipulation, wash trading, or other deceptive trading practices;
• Violating any applicable law or regulation;
• Any activity that could damage, disable, overburden, or impair the Platform or its infrastructure;
• Attempting to gain unauthorised access to any part of the Platform, other user accounts, or Eti-Tech's systems.

Eti-Tech reserves the right to immediately suspend or terminate any account where prohibited use is suspected, without prior notice and without liability to the Customer. Eti-Tech will cooperate fully with law enforcement authorities in connection with any suspected illegal activity.

10. Risk Disclosures

10.1 Market Risk

The value of Crypto Assets is highly volatile and can change rapidly and significantly. Prices may be affected by regulatory developments, technological changes, market sentiment, macroeconomic factors, and other variables. Eti-Tech does not guarantee the price, liquidity, or future value of any Crypto Asset.

10.2 Regulatory and Legal Risk

The regulatory environment for Crypto Assets is evolving rapidly. Changes in law or regulation in Switzerland or any other jurisdiction may affect the legality, availability, or terms of services offered by Eti-Tech. Eti-Tech may need to discontinue or modify services in response to regulatory changes.

Depending on their specific design and economic function, certain Crypto Assets may qualify as securities or other financial instruments under the Swiss Financial Services Act (FinSA) or Financial Institutions Act (FinIA), or as payment tokens, asset (security) tokens, or utility tokens under FINMA's token classification guidance. This classification can affect the legality or terms of trading a given asset and may change over time. Eti-Tech assesses the classification of the Crypto Assets it supports on an ongoing basis; classification frameworks and regulatory guidance in this area continue to evolve.

10.3 Technology Risk

Blockchain networks, smart contracts, and cryptographic systems may contain bugs, vulnerabilities, or be subject to attacks. Eti-Tech implements industry-standard security measures but cannot guarantee complete protection against all technical failures or cyberattacks. In the event of a critical security incident, Eti-Tech may suspend the Platform temporarily.

10.4 Counterparty and Operational Risk

Eti-Tech relies on third-party service providers including banking partners, KYC providers, blockchain analytics tools, wallet infrastructure providers, and payment processors. Failure, disruption, or termination of any such third-party service may affect the availability or performance of the Platform.

10.5 No Investment Advice

Nothing on the Platform, in these GTC, or in any communication from Eti-Tech constitutes investment advice, financial advice, trading advice, or any other form of regulated advice. All decisions to buy, sell, or hold Crypto Assets are made by you independently and at your sole risk. You should seek independent professional advice before making any financial decisions.

10.6 Tax Risk

The tax treatment of Crypto Assets is uncertain and varies by jurisdiction. Changes in tax law may result in additional tax liabilities. You are solely responsible for your own tax affairs.

International Tax Reporting (AEOI/CRS): Switzerland participates in the OECD Automatic Exchange of Information (AEOI) framework (Common Reporting Standard / CRS) via the AEOI Act (AEIA). Depending on your country of residence, Eti-Tech may be required to report your account information and transaction data to the Swiss Federal Tax Administration (FTA), which may onward-transmit this to the tax authority of your country of residence. Switzerland has also adopted the OECD Crypto-Asset Reporting Framework (CARF). Once it applies, Eti-Tech may be required to collect a tax-residence self-certification from you and to report information on your Crypto Asset transactions to the FTA.

Additionally, FINMA recognises and oversees VQF as part of its supervision of the Swiss financial market. In that capacity, FINMA has the power under AMLA Art. 29 to share supervisory information with foreign financial market authorities. Where such information originates from Eti-Tech, it flows to FINMA via VQF's supervisory process rather than directly from Eti-Tech. These disclosures are mandatory legal obligations. Swiss banking secrecy does not apply to Eti-Tech as a non-bank VASP.

11. Intellectual Property

All intellectual property rights in the Platform, including the software, design, text, graphics, logos, and trademarks, are owned by or licensed to Eti-Tech AG. Nothing in these GTC grants you any right or licence to use Eti-Tech's intellectual property except as strictly necessary to use the Platform in accordance with these GTC.

You must not copy, reproduce, distribute, modify, create derivative works from, publicly display, or reverse engineer any part of the Platform without prior written consent from Eti-Tech.

12. Liability and Indemnification

12.1 Limitation of Liability

To the maximum extent permitted by Swiss law, Eti-Tech's liability to you is limited as follows:

• Eti-Tech shall not be liable for any indirect, consequential, incidental, special, or punitive damages, including but not limited to loss of profits, loss of data, or loss of business opportunity, arising from your use of the Platform.
• For damage caused by slight negligence, Eti-Tech's total aggregate liability to you for direct damages arising from or related to these GTC or the Platform shall not exceed the greater of: (a) the total fees and Spread earned by Eti-Tech on your transactions in the 12-month period preceding the event giving rise to the claim; and (b) CHF 500. For the avoidance of doubt, the Spread earned on a transaction is included in "fees" for the purposes of this cap.
• Eti-Tech shall not be liable for losses arising from: market volatility; your failure to secure your account credentials; errors in Wallet addresses provided by you; blockchain network failures or delays; regulatory changes; force majeure events; or actions required by law or regulatory order.
• Eti-Tech shall not be liable for any loss of Crypto Assets held in your Provisioned Wallet, including loss resulting from transfers made using your login credentials or session, the disclosure or loss of your private key or credentials, phishing, malware, or acts of third parties (subject to Section 5.3).
• These limitations apply to the extent permitted by law; in accordance with Art. 100 para. 1 CO, they do not apply to damage caused intentionally or through gross negligence. They do not affect your Pending Settlement Claim under Section 7.6, which is a claim for performance and not for damages.

Consumer notice (Art. 8 Swiss Unfair Competition Act, UWG): Swiss unfair competition law (Art. 8 UWG) prohibits standard terms that create a significant imbalance in consumer contracts. The 12-month fee cap above is intended to operate within the limits permitted by Swiss law for consumer transactions. Where you are a consumer (natural person acting outside professional or commercial activity), mandatory statutory protections under Swiss law apply and prevail over this limitation to the extent required. Nothing in this Section limits or excludes liability for death or personal injury caused by negligence, fraud, or any other liability that cannot lawfully be excluded under Swiss law.

12.2 Indemnification

You agree to indemnify, defend, and hold harmless Eti-Tech AG and its directors, officers, employees, and agents from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising from:

• Your breach of these GTC;
• Your violation of any applicable law or regulation;
• Your use of the Platform in a manner not authorised by these GTC;
• Any false or misleading information provided to Eti-Tech.

12.3 Exclusions

Nothing in these GTC excludes or limits Eti-Tech's liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited under Swiss law.

13. Suspension, Termination, and Exit

13.1 Suspension by Eti-Tech

Eti-Tech may suspend your account or restrict access to services, with or without notice, in the following circumstances:

• Suspected breach of these GTC or applicable law;
• AML, KYC, or sanctions concerns;
• A Wallet ownership-verification or risk-screening concern pending investigation (see Section 8.2);
• Pending MROS or SECO reporting procedure;
• Technical or security incident affecting the Platform;
• Non-provision of requested KYC documentation within the required timeframe.

A suspension will be proportionate to the concern that gave rise to it and will be lifted as soon as that concern has been resolved.

13.2 Termination by Eti-Tech

Eti-Tech may terminate the business relationship and close your account:

• Where a material breach of these GTC has occurred and has not been remedied within 10 business days of notice;
• Where continued operation of the account would violate applicable law or regulatory requirements;
• Where the Customer has provided false or misleading information during onboarding or at any time thereafter;
• Upon regulatory instruction;
• At any time on 30 days' written notice for any other reason.

On termination, Eti-Tech will settle or return any Pending Settlement Claims in accordance with Section 7.6 (subject to AML obligations, pending disputes, and applicable law) after deduction of outstanding fees and charges. Where asset return is legally restricted (e.g. pending an MROS freezing order), Eti-Tech will act in accordance with its legal obligations.

13.3 Termination by Customer

You may close your account at any time by providing written notice to compliance@eti-tech.ch. Account closure will be effected after all pending Orders are settled and outstanding fees are paid. You remain bound by these GTC in respect of all activity prior to account closure. Eti-Tech will retain your AMLA file and transaction records for the mandatory 10-year retention periods irrespective of account closure. Your Provisioned Wallet and the Crypto Assets in it remain accessible to you with your private key after account closure.

14. Data Protection and Privacy

The collection, processing, and use of your personal data is governed by Eti-Tech's Privacy Policy, available at www.eti-tech.ch/privacy-policy. The Privacy Policy is incorporated into these GTC by reference. Key points:

• Your data is processed in accordance with the Swiss Federal Act on Data Protection (revDSG) and, where applicable, the GDPR.
• Your AMLA file is kept in Switzerland in accordance with Art. 63 VQF-Regulation, and Eti-Tech's platform is hosted in Switzerland (Amazon Web Services, Zurich region). Certain service providers (e.g. for identity verification, wallet infrastructure and analytics) process personal data outside Switzerland, as described in the Privacy Policy.
• Eti-Tech is legally required to retain your KYC and transaction records for a minimum of 10 years following termination of the business relationship (Art. 7 AMLA).

15. Customer Support, Complaints, and Governing Law

15.1 Where to Go for What

Eti-Tech provides three distinct channels depending on the nature of your query:

• Customer support: for account, platform, or transaction questions, contact info@eti-tech.ch.
• Compliance contact: for KYC, AML, or regulatory matters concerning your account, contact compliance@eti-tech.ch.
• Legal notices: formal notices under these GTC must be sent in accordance with Section 16.6 (Notices).
• Automated chat assistant: where Eti-Tech offers an automated (AI-based) chat assistant, its answers are general information only and do not constitute binding statements, instructions or advice by Eti-Tech.

If you are unsure which channel applies, contact info@eti-tech.ch and Eti-Tech will direct your query to the right team. If you have a complaint, see Section 15.4 (Complaints and Escalation Process).

15.2 Governing Law

These GTC and all disputes arising out of or in connection with them are governed exclusively by Swiss law, excluding its conflict of law provisions and the UN Convention on Contracts for the International Sale of Goods (CISG).

15.3 Jurisdiction

The courts of the Canton of Thurgau, Switzerland shall have exclusive jurisdiction over any dispute arising out of or in connection with these GTC, subject to any mandatory statutory rights you may have in your country of residence.

15.4 Complaints and Escalation Process

If you have a complaint about our services, the following escalation process applies:

• Submit a written complaint to compliance@eti-tech.ch, describing the issue and any relevant Order ID or account reference. Eti-Tech will acknowledge receipt within 2 business days and aim to provide a substantive response within 20 business days.
• If you are not satisfied with the response, you may request escalation to a member of Management, who will review the complaint and respond within a further 10 business days.
• If the complaint is not resolved to your satisfaction, either party may refer the dispute to mediation before a mediator agreed by the parties.
• If mediation fails, the parties may commence legal proceedings before the courts specified in Section 15.3.

Independently of this process, you may at any time file a regulatory complaint as described in Section 15.5.

15.5 Regulatory Complaints

If you believe Eti-Tech has violated its regulatory obligations, you may file a complaint with our supervisory authority, the VQF Self-Regulatory Organisation (www.vqf.ch). Complaints concerning systemic regulatory matters may, in appropriate cases, also be addressed to the Swiss Financial Market Supervisory Authority FINMA (www.finma.ch), which oversees VQF as a recognised SRO.

16. General

16.1 Entire Agreement

These GTC, together with the Privacy Policy and any applicable product-specific addenda, constitute the entire agreement between you and Eti-Tech with respect to the Platform and supersede all prior agreements, representations, and understandings.

16.2 Severability

If any provision of these GTC is found to be invalid, unlawful, or unenforceable, that provision shall be modified to the minimum extent necessary to make it valid, lawful, and enforceable. If modification is not possible, the provision shall be severed. The remaining provisions shall continue in full force and effect.

16.3 No Waiver

Eti-Tech's failure to enforce any provision of these GTC shall not constitute a waiver of its right to enforce that provision in the future.

16.4 Assignment

You may not assign any of your rights or obligations under these GTC without Eti-Tech's prior written consent. Eti-Tech may assign its rights and obligations to a successor entity in connection with a merger, acquisition, or sale of substantially all assets, provided that: (a) the successor entity assumes all of Eti-Tech's obligations under these GTC; and (b) the successor entity holds regulatory authorisation equivalent to Eti-Tech's VQF SRO membership and VASP status. Eti-Tech will provide Customers with at least 30 days' written notice prior to any assignment. Within that 30-day period, Customers who do not wish to continue with the successor entity may close their account without penalty and receive settlement or return of any Pending Settlement Claims, subject to AML obligations and pending Orders.

16.5 Force Majeure

Eti-Tech shall not be liable for any delay or failure to perform its obligations under these GTC due to circumstances beyond its reasonable control, including but not limited to: acts of God, war, civil unrest, regulatory action, cyberattacks, power outages, blockchain network failures, or disruption of third-party services. The following crypto-asset-specific events additionally constitute force majeure: (a) Hard forks: Eti-Tech will designate the chain it supports as primary within 48 hours and notify Customers; it is not obligated to support both chains; (b) Stablecoin depeg: Eti-Tech may immediately suspend trading in a stablecoin that loses its peg without prior notice; (c) Protocol deprecation: Eti-Tech will provide 30 days' notice where possible; (d) Regulatory prohibition of a specific asset: Eti-Tech will comply immediately and is not liable for losses from mandated cessation. Eti-Tech will use reasonable efforts to resume normal service as soon as practicable.

16.6 Notices

All formal notices under these GTC must be in writing. Notices to Eti-Tech must be sent by email to compliance@eti-tech.ch or by post to Müligässli 1, 8598 Bottighofen, Switzerland. Notices to you will be sent to the email address registered on your account.

16.7 Contact

Eti-Tech AG is a member of the VQF Self-Regulatory Organisation (SRO) and is a Virtual Asset Service Provider (VASP) within the meaning of Art. 2 para. 3 AMLA, supervised in that capacity through its VQF membership. | General Terms and Conditions — Version 2.2 — 29 July 2026 | Supersedes Version 2.1