COMMERCIAL POLICY

Exchange of Crypto-Assets for Funds or for Other Crypto-Assets

KEY TERMS AND ABBREVIATIONS

Bitcoin Store Wallet (hereinafter: Account) – a service within the Platform that enables the purchase, sale, exchange, and storage of crypto-assets, the deposit and withdrawal of fiat currencies (EUR) to/from the Account, and real-time monitoring of the Client's investment portfolio. Bitcoin Store Wallet is also the name of the Mobile Application owned by the Company, which provides crypto-asset trading services.

Company – refers to Digital Assets d.o.o.

Crypto-asset – a digital representation of value or rights which may be transferred and stored electronically, using distributed ledger technology or similar technology. Depending on its characteristics, it may have an investment, utility, or payment function.

Funds – refers to fiat currency EUR.

Client – a natural or legal person who uses the Company's Services.

Business relationship – a business, professional, or commercial relationship connected with the professional activities of the Company and which is expected, at the time of its establishment, to have an element of duration, including the opening of a Bitcoin Store Account with the Company.

Occasional transaction – a transaction carried out outside an established business relationship.

Transaction – any receipt, payment, transfer from one account to another, exchange, custody, disposal, or other handling of fiat currency and crypto-assets within the Platform and Branch Offices.

Exchange of crypto-assets for other crypto-assets – the conclusion of orders for the purchase or sale of client crypto-assets for another crypto-asset, using the Company's own funds.

Exchange of crypto-assets for funds – the conclusion of orders for the purchase or sale of crypto-assets with clients for funds, using the Company's own funds.

1. INTRODUCTION

The Company operates a non-discriminatory policy governing the provision of services for the exchange of crypto-assets for funds or for other crypto-assets.

The Policy applies to all clients and all channels, including the website www.bitstore.net, the Bitcoin Store mobile application, the Company's own physical branch offices and the exchange offices of contractual partners, and the Bitstore debit card.

2. CLIENT TYPE

The types of clients with whom the Company does business are natural persons and legal entities.

The following criteria apply to the establishment of a business relationship with the Company:

• Natural persons: must hold citizenship or residence in the European Union (EU), the European Economic Area (EEA), or the SEPA area, with the exception of the United Kingdom and the Vatican.
• Legal entities: must have their registered office in the European Union (EU), the European Economic Area (EEA), or the SEPA area, with the exception of the United Kingdom and the Vatican. The same conditions regarding citizenship or residence apply to legal representatives and beneficial owners of the legal entity.

The following provisions apply to the execution of occasional transactions at Branch Offices:

Clients who do not have an established business relationship with the Company and are executing an occasional transaction at a Branch Office may be nationals or residents of any country, provided that such country does not appear on the internal list of prohibited states or countries.

Occasional transactions at Branch Offices are available exclusively to natural persons; legal entities may not execute them.

The conditions that clients must fulfil for the exchange of crypto-assets for funds service are as follows:

• a natural person accepts the General Terms and Conditions of Business upon entering into a business relationship with the Company
• a natural person accepts the Bitstore Card Terms of Use when ordering the card
• a legal entity accepts the General Terms and Conditions of Business upon entering into a business relationship with the Company
• a natural person executing an occasional transaction at a Branch Office who satisfies the customer due diligence requirements.

The conditions that clients must fulfil for the exchange of crypto-assets for other crypto-assets service are as follows:

• a natural person accepts the General Terms and Conditions of Business upon entering into a business relationship with the Company
• a legal entity accepts the General Terms and Conditions of Business upon entering into a business relationship with the Company.

3. CRYPTO-ASSET PRICING METHODOLOGY

The Company determines the price of crypto-assets offered for exchange on the basis of its own exchange rate, formed in real time. The Company does not publish fees and spreads separately; instead, it displays the final price as a fixed exchange rate that is clear to the client at the moment of order confirmation. This methodology ensures transparency and consistency, as all clients have access to the same pricing mechanism and the offered rate does not change once the client has confirmed the transaction.

The Company publicly discloses the price offered for the exchange of crypto-assets for funds or for other crypto-assets.

The following factors influence the pricing of crypto-assets:

• market supply and demand (order books)
• liquidity providers and market makers
• volatility
• large orders
• fees and spreads (buy/sell differentials).

The price of crypto-assets within the exchange of crypto-assets for funds or for other crypto-assets services is variable and adjusts on the basis of real-time prices offered by the liquidity providers available to the Company. In doing so, the Company takes into account the risk factors mentioned above.

4. ORDER PROCESSING

The client may submit an order for the exchange of crypto-assets for funds or for other crypto-assets within their Account or in person, by verbal request, at a physical branch office.

The following steps are required in order for an order to be executed:

• The client must confirm by instruction how much in funds or crypto-assets they wish to exchange.
• The Company will display a summary of the exchange offer at the price applicable at that moment. For orders placed within the user interface, the client is shown a time limit for confirming the order (a 60-second countdown). If the market price changes by more than 1% in either direction within that period, the exchange rate is automatically refreshed and the Company will notify the client of the price change. For orders placed at a Branch Office, the price is updated prior to concluding the transaction and the client is informed accordingly.
• If the client confirms the order, this means that they have accepted the offer and that the Company will execute the order at the price displayed at that moment.
• If the client is selling crypto-assets for funds, they will receive the proceeds in fiat currency EUR.
• If the client is selling crypto-assets for other crypto-assets, they will receive the crypto-asset proceeds in their crypto-asset account.
• The Company will in all cases notify the client of the successful authorisation of payment/receipt of funds or crypto-assets, including the exchange quantity and price.

The Company publishes information on all executed crypto-asset exchange transactions, including quantities and prices, through various communication channels (real-time display within the Account, quarterly statements, email notifications).

Exchanges of crypto-assets for funds or for other crypto-assets are processed immediately. Upon receipt of a valid request, the Company carries out the necessary checks and assessment of the client's circumstances and the transaction. If there are no grounds for refusing the order, the Company executes it as promptly as possible.

If the value of the crypto-assets the client is selling is less than 0.01 of the base currency in the client's account (e.g. less than EUR 0.01), the Company cannot pay out fiat currency in exchange for the sale of the crypto-asset. Such transactions fall below the minimum and do not meet the Company's minimum thresholds for conversion into fiat currency.

• Where the client holds a Bitstore debit card, each time they execute a transaction, the crypto-assets are automatically converted into the corresponding amount of funds in order for the transaction to be executed. Following the conversion, the updated crypto-asset balance is displayed within the Account, along with the details of the executed transaction.
• If the client requests a refund from a merchant, the amount due will be paid out in fiat currency EUR to the Account.
• If the transaction was pending and was subsequently reversed, the Company will display the balance of the crypto-assets used for the original transaction.
• If the client does not have sufficient funds in their Account, the transaction will be declined.

5. ORDER REFUSAL

The Company reserves the right to refuse the execution of a submitted order in the following circumstances:

• Insufficient market liquidity: there is insufficient crypto-asset liquidity in the market for the requested transaction.
• Insufficient funds: the client does not have sufficient crypto-assets in their account.
• Operational unavailability and extraordinary events: the Company, or the exchange offices or trading platforms of contractual partners used by the Company for order execution, are temporarily unavailable, or events have occurred that prevent order execution (e.g. system failure, service interruption or delay, unforeseen events beyond the Company's control).
• Compliance: where there is reasonable suspicion that the order is subject to money laundering, terrorist financing, fraud, misuse, or other risks.

If such an event occurs, the Company will notify clients without undue delay. Upon receipt of the notification, the client acknowledges that the Company is not obliged to complete the submitted order and that it shall be deemed cancelled.

The Company is not liable for losses arising from the refusal of an order, unless caused by the Company's wilful misconduct or gross negligence.

6. FEES

The Company displays crypto-asset prices inclusive of fees.

• Prices for crypto-asset-to-crypto-asset exchanges are quoted at the time of the offer and include the fee.

The Company displays fees for crypto-asset transfers, Bitstore card, and cash-related services, available at: Transfer Fees