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") and any natural person or legal entity ("Customer", "you") who accesses or uses the Eti-Tech platform ("Platform"). The Platform provides virtual asset exchange, wallet, and ancillary services.

By clicking 'I agree' at registration and ticking the checkbox next to these Terms of Service, you enter into a legally binding contract with Eti-Tech. If you do not agree to these GTC in their entirety, you must not use the Platform.

These GTC apply to all services offered by Eti-Tech, whether accessed via the web, mobile application, API, or any other means, unless a separate written agreement supersedes them.

1.2 Regulatory Status

Eti-Tech AG is a member of the Self-Regulatory Organisation VQF (Verein zur Qualitätssicherung von Finanzdienstleistungen), supervised in its capacity as a virtual asset service provider (VASP) under the Swiss Anti-Money Laundering Act (AMLA).

Eti-Tech AG is not a bank, securities dealer, or licensed investment adviser under Swiss law. Eti-Tech does not provide investment advice, portfolio management, or financial planning services. Nothing in these GTC or on the Platform constitutes investment advice.

1.3 Amendments

Eti-Tech reserves the right to amend these GTC at any time. Material amendments will be notified to Customers at least 30 days in advance via registered email to the email address on file. Continued use of the Platform after the effective date of an amendment constitutes acceptance.

Amendments required to comply with applicable law or regulatory guidance shall take effect immediately upon notification and Customers must accept them to continue using the Platform.

1.4 Language

These GTC are provided in English. In the event of any discrepancy between English and any translation provided for convenience, 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 (see Section 15). 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), and stablecoins such as USDT, USDC.
• "ETI-Points" means the loyalty points issued by Eti-Tech to Customers as part of the ETI-Points Programme described in Section 11.
• "Escrow" means the mechanism by which Eti-Tech temporarily locks crypto assets pending confirmation of payment, as described in Section 7.4.
• "Fiat Currency" means government-issued legal tender, including Swiss Francs (CHF), Euros (EUR), and US Dollars (USD).
• "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.
• "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.
• "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.
• "Wallet" means a blockchain-based address for sending, receiving, and holding Crypto Assets.
• "Wallet Screening" means blockchain analytics conducted on a Wallet address to assess its 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, or a duly incorporated legal entity;
• Have the legal capacity to enter into binding contracts under the law of your jurisdiction;
• Not be resident in, incorporated in, or a national of 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 opening an account on behalf of another person without proper authorisation and disclosure;
• Use the Platform only for lawful purposes consistent with these GTC.

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:

1. Provide accurate and complete personal information as required by the registration form.
2. Complete the KYC onboarding process, including identity verification, as described in Section 4.
3. Accept these GTC and the Privacy Policy.
4. Create a secure login with password and two-factor authentication (2FA).

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 offers the following account types:

• Individual Account: for natural persons acting in their personal capacity.
• Business Account: for legal entities, companies, partnerships, and professional investors. Additional documentation is required (see Section 4.2).

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 and enable 2FA at all times;
• 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 will never ask you to disclose your password. 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.

4. Know Your Customer (KYC) and AML Compliance

4.1 Legal Obligation

As a regulated 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. 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);
• Biometric verification (photograph and liveness check);
• Proof of source of funds and source of wealth;
• 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).

Business Customers

In addition to the above for each representative, you must provide:

• Certificate of Incorporation and Articles of Association;
• Certified extract from the commercial register (not older than 12 months);
• Shareholder structure and beneficial ownership declaration (Form K);
• Documentation evidencing the authority of the representative(s);
• Financial information (turnover, profit, expected transaction volumes);
• Business description and intended use of the Platform.

4.3 Verification Methods

Identity verification is carried out via one or more of the following methods, in accordance with FINMA Circular 2016/7 and the VQF Regulations:

• Online identification via our integrated provider (Sumsub), in accordance with FINMA Circular 2016/7;
• Video identification (live audio-visual session);
• Identification by correspondence (certified copy of identity document);
• Identification in person at Eti-Tech's registered offices.

As part of the online or video identification process, Eti-Tech may require 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.

4.4 Risk Classification

Upon completion of KYC, Eti-Tech assigns each Customer a risk category (Low, Medium, or High) in accordance with its AML/CTF Policy. This classification determines the level of due diligence, transaction monitoring thresholds, and periodic review frequency 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 the following minimum intervals:

• Low risk: every 6 years;
• Medium risk: every 4 years;
• High risk: annually.

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.

5. Services

5.1 Overview

Subject to your successful onboarding and continued compliance with these GTC, Eti-Tech offers the following services. Services are introduced in phases and may not all be available at all times. Current service availability is published on the Platform.

5.2 Conversion and Exchange Terminal (Phase 1)

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

• Fiat to Crypto (e.g. CHF → USDT, CHF → BTC)
• Crypto to Fiat (e.g. USDT → CHF)
• Crypto to Crypto (e.g. BTC → ETH)
• Fiat to Fiat (e.g. CHF → EUR)

Orders may be processed via the Platform's automated terminal, via third-party exchange infrastructure, or manually for large or institutional orders. The available processing method for each Order is indicated at the time of order placement.

Accepted payment methods include: bank transfer (SWIFT/SEPA), SEPA Instant, SIC5, SIX, Twint, and card payment via approved Payment Service Providers (PSPs). Not all payment methods are available for all transaction types or amounts.

5.3 User Platform and Accounts (Phase 1)

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

• Secure login with 2FA and password protection;
• Order history and transaction records;
• ETI-Points balance and leaderboard;
• Discount system for reduced commission rates (granted automatically or manually by Eti-Tech);
• CRM panel for business account holders;
• Support for collectible NFT profile items (linked to Wallet, where applicable);
• Individual and business account profiles.

5.4 Wallet Custody — Non-Custodial (Phase 1)

Eti-Tech provides a decentralised (non-custodial) blockchain-based Wallet service allowing Customers to hold, send, receive, and exchange Crypto Assets. Key features include:

• Standard Wallet functions: send, receive, exchange;
• QR-code invoice payment (Swiss QR-bill standard);
• Support for mainstream blockchains and networks, with ability to add further networks;
• Support for NFT storage, receipt, and transfer;
• Multi-chain support across approved asset lists.

The Wallet is accessible only to Customers who have completed KYC verification. Eti-Tech does not hold your private keys in the non-custodial Wallet product; you are solely responsible for the security of your private keys. Loss of your private key means permanent loss of access to your Wallet and its contents — Eti-Tech cannot recover lost private keys.

During the development of Eti-Tech's proprietary Wallet, third-party custody solutions (such as Fireblocks or Zodia Custody) may be used as an interim measure. Where this is the case, Customers will be informed.

5.5 B2B Exchange Terminal (Phase 2)

Eti-Tech offers an API-based exchange terminal for banks, funds, and institutional clients, enabling buy/sell operations via API connection. Eti-Tech acts as a third-party infrastructure and liquidity provider. Separate B2B service agreements apply to this product.

5.6 Peer-to-Peer (P2P) Marketplace (Phase 2)

Eti-Tech intends to operate a P2P trading platform enabling direct transactions between verified users, including escrow functionality and a dispute resolution mechanism. This service is not yet active. Specific terms for P2P trading will be published as a separate addendum to these GTC before the service launches. Until that addendum is published and you have accepted it, no P2P trading functionality will be accessible. Eti-Tech makes no commitment as to the launch date of the P2P Marketplace.

5.7 Future Services (Phase 3)

Eti-Tech intends to introduce the following services in later phases, subject to regulatory approval and platform readiness:

• ETI-Coin: Eti-Tech's native token, including airdrop and token sale mechanics;
• Techcubator: a launchpad platform for vetted crypto startup token issuances;
• Memecubator: a meme token creation and trading ecosystem;
• ZK-KYC Solution: AI-powered and blockchain-based identity verification infrastructure;
• Crypto Payment Card: a payment card linked to Customer Wallets with Apple Pay / Google Pay support.

Separate terms and conditions will apply to each Phase 3 service. Eti-Tech makes no commitment as to the timeline or availability of Phase 3 services.

5.8 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 17.5).

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.

5.9 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.

5.10 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 (e.g. Sumsub for KYC), those providers act under Eti-Tech's instruction and under contractual data protection obligations. Eti-Tech remains responsible for ensuring compliance with applicable law in respect of such outsourced functions.

6. Fees, Pricing, and Spread

6.1 General Pricing Principles

Eti-Tech's primary remuneration is earned through the Spread applied to exchange rates. Eti-Tech may also charge explicit fees for certain services. All applicable fees and the current Spread are displayed on the Platform before you confirm an Order. By confirming an Order, you accept the price and any fees displayed at that time.

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/fees and may be updated from time to time. The following general principles apply:

• Exchange / conversion fee: included in the Spread or charged as a percentage of transaction value, as displayed at the time of order.
• Wallet transaction fees: network (blockchain) gas fees for outgoing Crypto Asset transfers are passed on to the Customer at cost.
• B2B terminal: fees are set out in the applicable B2B service agreement.
• Card payment surcharge: where a PSP surcharge applies to card payments, this will be disclosed prior to payment.
• ETI-Points discount: Customers who have accumulated sufficient ETI-Points may receive reduced commission rates as described in Section 11.

6.3 Rate Locking and Order Validity

When you initiate an Order, the exchange rate displayed is indicative until you submit the Order. Upon Order submission and confirmation, the rate is locked (together with the corresponding Crypto Asset amount held in Escrow) for the payment window specified in the Order confirmation. If payment is not received within the payment window, the Order may lapse and the rate will no longer be guaranteed.

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. Eti-Tech may be required to report certain transactions to Swiss or foreign tax authorities in accordance with applicable law.

7. Order Process and Escrow Mechanism

7.1 Order Placement

To place an Order, you must:

1. Select the asset pair and enter the desired amount on the calculator/terminal.
2. Review the quoted rate, Spread, and applicable fees.
3. Select your payment method.
4. Confirm the Order. By confirming, you enter into a binding agreement to complete the transaction on the terms displayed.

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

7.2 Payment Obligations

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

• Payment must be made exclusively from a bank account or wallet held in your own name. 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.
• Payment must be received within the payment window specified in the Order confirmation. Late payments may result in Order cancellation and a revised rate being applied.

7.3 Crypto Asset Deliveries

Crypto Assets will be released to your designated Wallet address only after:

1. 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;
2. Successful Wallet Screening of the destination address (see Section 8.2);
3. All applicable AML checks have been completed.

Delivery times depend on network congestion and blockchain confirmation requirements. Eti-Tech targets prompt delivery but does not guarantee specific delivery times.

7.4 Escrow Mechanism

For fiat-to-crypto Orders, Eti-Tech employs an Escrow mechanism to protect both parties:

1. Upon Order confirmation, Eti-Tech locks the corresponding amount of Crypto Assets in Escrow at the confirmed rate.
2. You must transfer the exact fiat amount and provide the bank transfer receipt where required.
3. Upon confirmation of receipt of cleared funds into Eti-Tech's bank account, the Crypto Assets are released from Escrow and transferred to your Wallet.
4. The release from Escrow may be automated via bank API or confirmed manually by Eti-Tech.

Disputes arising from Escrow transactions (e.g. incorrect payment amount, payment from a third-party account) are handled in accordance with Section 14.

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.

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), when you send or receive Crypto Assets to or from an external Wallet at another regulated VASP, Eti-Tech is required to transmit the following information alongside the transaction:

• 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 will only accept incoming crypto transfers that comply with equivalent Travel Rule obligations on the sending side. Transfers from non-compliant senders may be rejected or returned.

8.2 Wallet Screening and Blockchain Analytics

Prior to accepting incoming Crypto Assets from an external Wallet, and prior to releasing Crypto Assets to an external Wallet, Eti-Tech conducts Wallet Screening using specialist blockchain analytics tools. This process assesses the risk profile of the Wallet address against known risk indicators including:

• Exposure to sanctioned entities or addresses;
• Association with darknet markets, mixing services, or ransomware;
• Other risk signals identified by the blockchain analytics provider.

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 that fails Wallet Screening;
• Place a Wallet on a watchlist or blacklist;
• Suspend an account pending further investigation following a Wallet Screening alert.

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.
• Network fees (gas) are borne by the Customer and may vary.
• 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.

You may add tokens manually to a non-custodial Wallet via contract address at your own risk. Eti-Tech accepts no liability for losses arising from interaction with unverified or malicious smart contracts. Clear risk warnings are displayed for any such manual addition.

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.

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, 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.

11. ETI-Points Loyalty Programme

11.1 General

Eti-Tech operates the ETI-Points loyalty programme to reward Customers for their engagement with the Platform. ETI-Points are awarded for activities including:

• Completing exchange transactions;
• Participating in community activities;
• Referring new Customers to the Platform (subject to referral programme terms);
• Other qualifying activities as announced on the Platform from time to time.

11.2 Use of ETI-Points

ETI-Points may be redeemed for:

• Reduced commission rates on exchange transactions;
• Other benefits and rewards as published on the Platform.

In Phase 3, ETI-Points will become convertible into ETI-Coins (Eti-Tech's native token) once the ETI-Coin is launched. The conversion rate and mechanics will be published at that time.