GENERAL TERMS AND CONDITIONS

De: 01/07/2026

GENERAL PROVISIONS

These General Terms and Conditions of Business of Digital Assets d.o.o. (hereinafter: the "Terms") constitute a contract between Digital Assets d.o.o. (hereinafter: the "Company", "we", "us", "our"), as a crypto-asset service provider, and you (the "Client", "you", "your") on the other hand.

The Terms define the Services, including the use of the Platform, the Mobile Application, and the provision of crypto-asset Services within the Company's business network.

By using the Company's Services, you accept these Terms. Please read the Terms carefully before using the Platform or the Services. These Terms were last updated on 01 July 2026.

The Company reserves the right to amend, supplement, or remove parts of these Terms at any time, in accordance with the provisions of the chapter "Amendments to the Terms". The Terms, all their amendments, and related policies are published on the Platform, in the Bitcoin Store Wallet Mobile Application, and are available to Clients at Branch in physical form, where they must be accepted prior to the execution of an occasional transaction. Notifications of amendments to the Terms are sent by the Company via email (with a summary of the key changes and a link to the full text), via notifications on the Platform, and, where necessary, via notifications at Branch.

These Terms incorporate by reference the Privacy Policy, the Cookie Policy, the Crypto-Asset Listing and Delisting Policy, the Crypto-Asset and Services Pricing Policy, the Complaints Handling Policy, the Custody Policy, and the Conflict of Interest Prevention Policy, together with all their amendments and supplements. By using our Services, you accept the Terms and the related policies.

The Company communicates with Clients via email, notifications on the Platform, notifications in the Mobile Application, by telephone, by post, and in person at Branch. Depending on the nature of the enquiry, request, complaint, or regulatory notification, the Company may use one or more of the aforementioned communication channels. Communication with Clients is conducted in Croatian and English.

The Company uses the following email addresses for Client communications:

hello@bitstore.net – general enquiries and client support

info@bitstore.net – general enquiries

zop@bitcoin-store.hr – submission of complaints

compliance@bitcoin-store.hr – compliance-related enquiries

whistleblowing@bitstore.net – reporting of irregularities

listing@bitstore.net – crypto-asset listing enquiries

transactions@email.bitstore.net – transaction notifications (deposits, withdrawals and exchanges)

hello@hello.bitstore.net – newsletter

The Company may amend and supplement these Terms for the purpose of compliance with regulations and regulatory requirements, security requirements, changes in the scope of Services, changes in fees, and other justified business reasons. Clients will be notified in advance of material amendments via email, with a summary of the key changes and the date on which they take effect. Clients may be notified of non-material amendments by publication on the Platform and/or in the Mobile Application. Continued use of the Services after the amendments enter into force shall be deemed acceptance of the amendments, unless these Terms or mandatory regulations provide for the Client's right to terminate the agreement in the event of non-acceptance of the amendments.

These Terms are available in Croatian and English. These Terms are governed by the law of the Republic of Croatia. In the event of any discrepancy between the different language versions, the Croatian language version shall prevail.

DEFINITIONS

The meaning of the terms used in these Terms:

Account – see Bitcoin Store Wallet.

Bitcoin Store Branches (hereinafter: Branches) – the Company's physical points of sale where Clients are provided with crypto-asset Services and other related services, in accordance with these Terms and applicable regulations.

Bitcoin Store Platform (hereinafter: the Platform) – the Company's website available at https://www.bitstore.net/.

Bitcoin Store Services (hereinafter: Services) – crypto-asset Services provided by the Company through the Platform, the Mobile Application, and Branches.

Bitcoin Store Wallet (hereinafter: Account) – is a service within the Bitcoin Store Platform and Mobile application that allows buying, selling, exchanging, and storing crypto-assets, depositing and withdrawing fiat currencies (EUR) to/from Bitcoin Store Accounts, and enables tracking the status of client’s investments in real-time. Bitcoin Store Wallet is also the name of the Mobile application.

Client – a natural or legal person who has established a business relationship with the Company or uses the Company's Services.

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.

Crypto-asset custody and administration service on behalf of Clients – a service involving the safekeeping or control of crypto-assets or the means of access to such crypto-assets on behalf of a Client, where applicable in the form of private cryptographic keys. Within the scope of this Service, the Company enables the disposal of such crypto-assets exclusively in accordance with the Client's instructions, these Terms, and applicable regulations.

Fiat currency – a currency issued by a central bank or a public authority of a state and designated as the sole legal tender. In these Terms, “EUR” refers to the euro, the official currency of the Republic of Croatia and a large number of European Union member states.

Mobile Application – see Bitcoin Store Wallet Mobile Application.

Bitcoin Store Wallet Mobile Application (hereinafter: Mobile Application) – the Company's application designed for use on mobile devices. The Company's Digital Channels are a collective term for the Website and the Mobile Application. Where a particular Service is available exclusively through one of the channels listed, this will be specifically indicated in the description of that Service.

Referral Programme – a tool that encourages Referrers to recommend the Services to people in their immediate circle, such as family, friends, and others, via a Unique Link.

Referral Programme Reward – the monetary amount earned by the Referrer for each successful transaction on the Referred Client's Account.

Referred Client – a natural person who receives the Referrer's Unique Link and uses that link to create an Account.

Referrer – a natural person who holds an active Account and who, via a Unique Link, invites another natural person to become a Client and use the Services, thereby earning a Referral Programme Reward.

SEF token – a crypto-asset issued by the Company.

Transaction – any receipt, payment, transfer from one account to another (and vice versa), exchange, custody, disposal, or other handling of fiat currency and crypto-assets.

Unique Link – a unique URL associated with an individual Account and used to invite Referred Clients to create an Account via the Platform, enabling the Referrer to earn rewards under the Referral Programme.

Verified Client – a natural or legal person who has completed the mandatory verification process, i.e., identity verification ("Know Your Client"), and may use all Services.

For any term not defined in these Terms, the usual meaning in similar contexts or common internet usage applies.

SERVICES

The Services are provided by the Company, whose registered office is at Hrv. mornarice 1C, 21000 Split, Croatia, registered with the Commercial Court in Split, MBS: 060297216, PIN: 37096783668.

The Company also provides Services and information to Clients at Branches; the list of locations and opening hours is available at https://www.bitstore.net/en/stores/.

Services provided via the Platform and Mobile Application:

depositing fiat currency (EUR) to the Account by bank transfer and payment cards;
withdrawing fiat currency to a personal payment account held with a payment service provider;
purchasing crypto-assets with fiat currency (EUR);
selling crypto-assets for fiat currency (EUR);
exchanging crypto-assets;
depositing crypto-assets into the Account;
transferring crypto-assets to/from other digital wallets;
providing transfer services for crypto-assets on behalf of clients;
storage of crypto-assets in the Account;
holding fiat currency in the Account;
providing custody and administration of crypto-assets on behalf of Clients;
placing of crypto-assets;
Services related to the Bitstore debit card;
Services related to the SEF token;
real-time investment tracking.

By accepting these Terms upon registration of an Account or when executing an occasional transaction at a Company Branch, the Client enters into an agreement with the Company for the provision of the following services: custody and administration of crypto-assets on behalf of Clients, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, placing of crypto-assets, and provision of crypto-asset transfer services on behalf of Clients, to the extent and on the terms defined in these Terms.

Clients executing an occasional transaction at a Branch accept these Terms by signing a written Statement of Acceptance of Terms, the form of which is available at Branches.

Services provided via Branches include:

cash purchase of crypto-assets with fiat currency (EUR);
cash sale of crypto-assets for fiat currency (EUR);
cash deposit of fiat currency (EUR) at a Company Branch for the purpose of topping up the Account;
non-cash transactions: bank transfers for buying/selling crypto-assets and crypto-asset exchange;
sale of hardware wallets.

Note: the use of the Company's Services may be restricted or prohibited under applicable regulations, internal risk management rules, anti-money laundering and counter-terrorist financing rules, sanctions regimes, and the rules of infrastructure providers (e.g. card schemes, payment institutions).

The following provisions apply to the execution of occasional transactions at Branches: Clients who do not have an established business relationship with the Company and are executing an occasional transaction at a Branches 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 Branches are available exclusively to natural persons; legal entities may not execute them.

Types of crypto-assets covered by the Services

E-money tokens (EMT) – crypto-assets whose value is pegged to a single official currency. The Company plans to provide exchange and custody services for this type of crypto-asset exclusively in accordance with the relevant provisions of MiCA.

Other crypto-assets – crypto-assets that are neither e-money tokens nor asset-referenced tokens, including Bitcoin (BTC), Ethereum (ETH), and a wide range of tokens. This type of crypto-asset constitutes the predominant part of the Company's offering.

ART tokens (asset-referenced tokens) – crypto-assets whose value is pegged to another value or right, or a combination thereof, including one or more official currencies.

All tokens available on the Platform are subject to risk assessment, the Company's internal rules, and the applicable regulatory framework.

ACCOUNT

Account Registration

You can register via the Platform. After successful registration, an email will be sent so you can complete Account verification.

By registering the Account, the Client confirms that they:

have the legal and contractual capacity to accept these Terms and enter into a business relationship with the Company;
understand and accept these Terms;
are at least 18 years of age;
are authorised to represent the entity or hold the necessary power of attorney when acting for a legal entity;
are aware of the price volatility of crypto-assets and that the Company does not guarantee any profit or stability of invested value;
accept the rules on data collection, processing and storage under the Privacy Policy;
accept that the Company may close the Account if the Client breaches the Terms or acts contrary to applicable laws or regulatory requirements.

Account Verification

The Company carries out a verification procedure in order to fulfil its legal obligations, prevent unlawful activities such as money laundering and terrorist financing, and protect Clients and their funds. Client verification is the process of confirming a Client's identity using documents, data, and information obtained from reliable and independent sources.

Personal Account – identification of an adult natural person, authorised representative, sole trader, or person carrying out another independent activity. A natural person may hold only one verified Account on the Platform. If the same person attempts to open multiple accounts, the Company may restrict Platform access and take further measures. 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.
Business Account – identification of the legal entity's representative(s) and beneficial owner(s). A natural person may hold multiple Business Accounts, but each legal entity may hold only one. 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.

By providing the requested documents, data, and information, the Client confirms that they are accurate, complete, and genuine, and accepts the obligation to notify the Company of any changes.

The Company performs checks for each Client during and after entering into a business relationship. The Client will not be able to use Account functionalities until verification is completed. The Company reserves the right to refuse verification if it doubts the accuracy or authenticity of the information provided.

Please see the Privacy Policy for more information on personal data collection, processing and storage.

The Company may refuse to verify a Client, including the establishment of a business relationship, in particular where:

the Client (or related persons/beneficial owner) appears on international, EU, national, or internal sanctions lists;
the Client is from a jurisdiction in which the Company does not operate or from a high-risk jurisdiction;
it is not possible to carry out the prescribed identity and source of funds verification;
there are indications of fraud, misuse, circumvention of security measures, or other unlawful activities;
the documents and data provided are not accurate, complete, or genuine;
providing the Service would be contrary to mandatory regulations, internal policies, or the Company's risk management rules.

FIAT CURRENCY TRANSACTIONS

Funds received by the Company for the purpose of providing the Services constitute Client funds and are recorded separately from the Company's own funds. Fiat currency held in the Account belongs exclusively to the Client who opened the Account and may be held only in EUR. Such funds are deposited in a designated account or accounts opened with a payment service provider for the purpose of holding Client funds, in accordance with applicable regulations and internal Client asset protection rules.

The Company maintains an up-to-date internal record that enables the determination of the amount of each individual Client's funds at any time, as well as the reconciliation of the books and the balances of the accounts in which Client funds are held.

Client funds are held on a pooled basis. Clients are clearly informed of this through these Terms and are warned of the meaning and risks of such pooled holding, which are described in detail in the Custody Policy available on the Platform. By accepting these Terms, the Client confirms that they have been informed of this method of holding funds and gives explicit consent for their funds to be held on a pooled basis, without the opening of a separate bank account in the Client's name.

Client funds may be transferred to a third party exclusively on the basis of an instruction from the Client given in a pre-agreed manner, or where such a transfer arises from the agreed method of providing the Service. The Company has no influence over the timescales and scheduling of the execution of instructions by third parties, including the Client's payment service providers.

The Company is not liable for the non-execution or delayed execution of a payment instruction if the instruction was submitted incorrectly or incompletely, or if execution of the instruction has not been authorised or has been deferred by a third party over which the Company has no control.

Client funds are held in a segregated account opened with Croatia banka d.d., IBAN: HR2124850031300012049.

Deposits to the Account

There is no minimum fiat deposit amount.

The Company will notify the Client by email and Platform notification once the transaction is processed and the funds are available in the Account. The Account balance will equal the fiat funds received by the Company from the Client.

In the event that the Client deposits an amount exceeding the order amount, the full amount received is recorded and credited to the Client's Account. The Client may use the total deposited amount in accordance with these Terms.

Supported deposit methods

Cash – verified Clients may deposit cash to their personal Account at a Branches; funds become visible immediately. Cash deposited at a Branches constitutes Client funds from the moment of receipt. The Company transfers the equivalent amount to the designated segregated account held with Croatia banka d.d. no later than the next business day.
Bank transfer – funds become visible once your bank executes the payment to the Company. You will receive payment details with the Company's bank details and reference number. You must enter the Reference number in the "Payment description" field. The Client may use the funds only after they have been credited to the Account, that is, once the Company has received the payment, the processing time of which depends on the sender's bank. The Company automatically notifies the Client of the received payment via email and/or a notification within the Account.
Payment cards (including Google Pay and Apple Pay) – funds become visible when the card issuer executes the payment to the Company. The Client may use the funds only after they have been credited to the Account. You must enter: cardholder name, card number, expiry date and CVV/CVC. If the card is not issued in the Client's name, the transaction will not be executed. You are solely responsible for using a card issued in your name; the Company is not responsible for informing you if your authorised representative uses your card.

A non-cash transaction is authorised if executed from your own payment account or with your own payment card. The Company is not responsible for unauthorised use of such accounts or cards and cannot stop any transaction subject to unauthorised use. The Company may request proof of payment to establish transaction details. The Company is not liable for delays caused by banking or card systems.

Withdrawals from the Account

The minimum withdrawal of fiat currency is EUR 1.

The Company will notify the Client by email and Platform notification once the withdrawal is processed. The Account balance will be reduced by the fiat amount paid out to the Client.

Supported withdrawal methods:

Cash – verified Clients may withdraw cash from their personal Account at a Branch.
Bank transfer – non-cash transfer to your personal account held with a payment service provider. The destination account must be within the SEPA area.

CRYPTO-ASSET TRANSACTIONS

The minimum amount for purchasing, selling, and exchanging crypto-assets depends on the asset type and the blockchain network used.

For the purchase, sale, and exchange of crypto-assets, an order becomes final and irrevocable at the moment the Client confirms the order on the Platform or in the Mobile Application, or when the Company receives and confirms the Client's order at a Branch provided that all conditions for execution have been met in advance and that the Client has been shown a final transaction summary prior to confirming the order. A transaction is deemed to have been executed when the Company records the corresponding amounts in the Client's Account and, where applicable, takes the action required for settlement, including initiating the corresponding blockchain transaction.

By displaying the exchange rate, the quantity of crypto-assets, and the total transaction amount in the final summary, the Company makes an offer to the Client to conclude an exchange agreement. The offer is binding on the Company exclusively for the duration of the exchange rate validity period defined below. The Client accepts the offer by confirming the order on the Platform or in the Mobile Application, or by verbal or written confirmation of the order at Branches. At the moment of acceptance of the offer, the exchange agreement is deemed to have been concluded and the order becomes final and irrevocable, provided that all conditions for its execution have been fulfilled.

The exchange rate displayed in the final transaction summary is fixed and binding on the Company for a period of 60 (sixty) seconds from the moment it is displayed to the Client (exchange rate validity period). This applies to all types of exchange provided by the Company, including: purchase of cryptoassets for fiat currency (EUR), sale of crypto-assets for fiat currency (EUR), and exchange of one crypto-asset for another.

The exchange rate ceases to be binding even before the expiry of the validity period if the market deviation from the displayed rate exceeds 1% in either direction. In that case, as well as upon expiry of the validity period, the exchange rate is automatically refreshed and the Client is shown a new final transaction summary with the then-current terms.

If the Client does not confirm the order within the exchange rate validity period, the offer is deemed to have been declined and no obligations arise for either the Client or the Company. The Client may initiate a new order at any time.

Purchases of crypto-assets with fiat currency can be made by:

cash transaction at a Branch;
non-cash transaction at a Branch;
using fiat currency available in the Account.

Sales of crypto-assets for fiat currency can be made by:

cash transaction at a Branch;
non-cash transaction at a Branch;
non-cash transaction to the Account.

Crypto-asset exchange is a process in which the Client exchanges one crypto-asset for another at current market rates, without first converting to fiat currency, thereby reducing transaction costs and time.

Exchanges can be made via a non-cash transaction through the Account.

The minimum exchange amount is the equivalent of EUR 0.01 in the relevant crypto-asset, as determined by the current market rate.

Transfers of crypto-assets

The agreement for the crypto-asset transfer service on behalf of the Client is concluded upon acceptance of these Terms. The service provider is the Company, and the Client's identity is established through the verification process described in the ACCOUNT chapter.

The crypto-asset transfer service encompasses the transfer of crypto-assets from the Client's Account to another address, or from an external address to the Client's Account, exclusively on the Client's instruction, via the corresponding blockchain network. Supported blockchain networks and minimum transfer amounts depend on the type of crypto-asset and are visible to the Client during the order submission process.

In providing the transfer service, the Company applies the technical and organisational security measures described in the SECURITY MEASURES chapter of these Terms.

The fee for the transfer service is determined in accordance with the Crypto-Asset and Services Pricing Policy available on the Platform and is visible to the Client prior to confirming the transfer order. Current fees can be viewed at any time on the Company's website: https://www.bitstore.net/en/fees/.

The agreement for the crypto-asset transfer service is governed by MiCA and other applicable EU and Croatian regulations.

The minimum transfer amount depends on the type of crypto-asset and the blockchain network used.

Crypto-asset transfers are irreversible. The Company cannot cancel or recall a transfer sent to an incorrect deposit address.

Note: network withdrawal fees apply for transfers to personal digital wallets and are shown during the process.

Transfer speed depends on the blockchain network(s) used, their congestion, and the type of digital wallets involved. The Company is not liable for any delays.

After the execution of a crypto-asset transfer, the Company provides the Client with an electronic confirmation containing at least: the names of the sender and recipient, the distributed ledger addresses of the sender and recipient, the transfer reference, the type and amount of crypto-assets transferred, the date of execution, and the amount of all fees applied. You must keep your email address accurate and promptly notify the Company of any change.

CUSTODY SERVICE

The agreement for the crypto-asset custody and administration service on behalf of the Client is concluded upon acceptance of these Terms. The service provider is the Company, and the Client's identity is established through the verification process described in the ACCOUNT chapter. The Company's Crypto-Asset Custody Policy, available to Clients in electronic form on the Platform and in the Mobile Application, forms an integral part of that contractual relationship.

The Company provides the crypto-asset custody and administration service on behalf of the Client, within the scope of its authorised Services and in accordance with applicable regulations. Within the scope of this Service, the Company stores the Client's crypto-assets or the means of access to such crypto-assets, maintains the corresponding records of the Client's rights, and undertakes custody-related actions exclusively in accordance with the applicable contractual relationship, the Client's instructions, the Company's internal rules and controls, and applicable regulations.

The custody service may encompass: the safekeeping of private cryptographic keys or other credentials required for the disposal of crypto-assets; the execution of transfers in accordance with duly submitted Client instructions; the implementation of controls aimed at protecting crypto-assets from loss, theft, unauthorised access, or misuse; and the provision of information to the Client regarding the status of and changes to assets held in custody. The Company is authorised to apply appropriate security, operational, identification, and compliance measures, including the temporary deferral or refusal of a particular action, where this is necessary for the protection of the Client or the Company or for the fulfilment of legal and regulatory obligations, in particular in the area of AML/CFT, sanctions, and the prevention of unauthorised disposal of assets.

For the purpose of providing the custody service, the Company may use third parties (sub-custodians) for the storage of Client crypto-assets. The Company currently uses Bitstamp Europe S.A. (Luxembourg) as the primary sub-custodian and Payward Europe Digital Asset Services d.o.o. (Kraken, Dublin, Ireland) as the reserve sub-custodian. The Company will notify Clients by email of any change in the use of sub-custodians at least 15 days prior to the commencement of use of the services of a new subcustodian, except in urgent operational circumstances, in which case notification will be provided without delay. An up-to-date list of sub-custodians is available on the Platform.

Communication between the Company and the Client in relation to the custody service takes place through the channels described in the GENERAL PROVISIONS chapter. Access to the Account and the disposal of crypto-assets are protected by an authentication system that includes multi-factor authentication.

In providing the custody service, the Company applies the technical and organisational security measures described in the SECURITY MEASURES chapter of these Terms.

Fees for the custody service are determined in accordance with the Crypto-Asset and Services Pricing Policy available on the Platform and on the Company's website: https://www.bitstore.net/en/fees/.

The agreement for the crypto-asset custody service is governed by MiCA and other applicable EU and Croatian regulations.

The Company provides the Client with a statement of position the crypto-assets held on their behalf at least once every three months and upon the Client's request. The statement is delivered electronically and contains details of the type of crypto-asset, the balance and value, and transfers executed during the relevant period. The Company notifies the Client without delay of all operations relating to the cryptoassets that require a response from the Client.

The Company is liable to the Client for the loss of crypto-assets or the means of access to crypto-assets resulting from an incident caused by an act or omission of the Company. The Company's liability is limited to the market value of the lost crypto-assets at the time the loss occurred. The Company is not liable for losses resulting from events that arise independently of the provision of the Service or independently of the Company's operations, including issues inherent in the functioning of distributed ledger technology over which the Company has no control.

The Company may hold Client crypto-assets on a pooled basis exclusively with the Client's prior explicit consent. By accepting these Terms, the Client gives consent for the pooled holding of cryptoassets.

USE OF THE ACCOUNT

You are responsible for maintaining the confidentiality of Account credentials (password, email address) and for restricting access to your mobile device and/or personal computer; you are responsible for all activities under your Account. While the Account is active and verified, you may manage fiat currency and trade crypto-assets; if the Account is not active (not verified), you may only withdraw your funds.

Upon the Company's request, you agree to provide documented proof of the source of funds and source of wealth. There are several important reasons why the Company requires evidence that funds originate from legitimate sources: to protect Clients and their funds from fraud and to prevent any potential connection to unlawful activities. In addition, the Company is required to comply with applicable AML/CFT laws and regulations.

The Company may request additional information and/or documentation in line with applicable legislation, supervisory rules, and internal policies and procedures.

ACCOUNT RESTRICTIONS

The Company may temporarily disable disposal of funds in the Account at the Account holder's request, in the event of the Client's death, or based on a court order or other decision/instruction of a competent authority. Where possible, the Company will notify the Client by phone and/or email before imposing the restriction; if that is not possible, it will do so immediately after. The Company is not obliged to notify the Client if doing so would be contrary to justified security reasons or the law.

REFUSAL OF SERVICE AND/OR ACCOUNT CLOSURE

The Company may refuse a transaction, the establishment of a business relationship, and/or close an Account for any reason, including but not limited to:

doubts regarding the truthfulness of information, documents or other documentation provided;
suspicion of money laundering, terrorist financing, or any other unlawful activity;
if required by a competent authority;
if required by mandatory regulations, laws, supervisory recommendations, or conventions;
failure to provide the requested additional information or documentation;
failure to notify the Company of material changes to data required under applicable law;
damaging the Company's reputation in any way;
breaching these Terms or related policies and any other Company terms and policies.

You may close the Account at any time via the Account settings on the Platform.

The Company may temporarily prohibit or defer Account closure where necessary for the purpose of:

complying with a legal obligation or an instruction of a competent authority;
preventing money laundering, terrorist financing, and carrying out sanctions screening;
completing pending, unexecuted transactions;
resolving open disputes, complaints, chargeback proceedings, or refunds;
recovering outstanding amounts owed by the Client to the Company.

Upon receipt of a duly submitted request from the Client and the fulfilment of all conditions set out in these Terms, the Company's obligations upon Account closure include:

verifying whether there are any unexecuted orders, open proceedings, security restrictions, or regulatory impediments to Account closure;
enabling the transfer or withdrawal of the Client's remaining assets in the manner permitted by these Terms and applicable regulations;
recording the termination of the business relationship and Account closure in its systems;
providing the Client, upon request or where applicable, with a confirmation of Account closure;
retaining and storing documentation relating to the business relationship and Account closure for the periods prescribed by applicable regulations.

The Client's obligations upon Account closure:

cancelling all active orders and settling all outstanding obligations and fees;
transferring all crypto-assets to their own external wallet;
withdrawing all fiat funds to their own payment account (IBAN within the SEPA area);
providing any additionally requested documentation for the purpose of regulatory compliance.

Note: once closed, the Account cannot be reactivated.

An Account is considered inactive if the Client has not executed any transaction within a period of 24 months. The Company will notify the Client by email of the upcoming deactivation 21, 14, and 7 days prior to the deactivation date.

If the Client holds funds or crypto-assets in their Account, the Company will invite the Client in the notification to transfer them to an external account or wallet prior to the deactivation date. If the Client holds no funds or crypto-assets, the notification serves solely as information regarding the upcoming deactivation.

The Client may prevent deactivation by logging in to the Platform before the deactivation date. Assets held in a deactivated Account remain protected and accessible; the Client may contact the Company at any time to request withdrawal or transfer of funds.

SEF TOKEN

Clients may use the SEF token to pay fees on the Platform, whereby holding a certain quantity of SEF tokens may be a condition for obtaining a discount on fees. In addition, the SEF token serves as a substitute crypto-asset in situations where the Company, due to the removal of a particular crypto-asset from an external liquidity source or the discontinuation of the last required trading pair, can no longer support that crypto-asset in its offering. The rules and conditions governing the listing and delisting of crypto-assets are set out in the Crypto-Asset Listing and Delisting Policy, published together with these Terms and available on the Platform.

Delisting procedure and automatic conversion to SEF

If a partner trading platform removes a particular crypto-asset or discontinues the last supported trading pair used by the Company for that crypto-asset, the Company is no longer able to ensure the necessary liquidity and orderly execution of transactions and is therefore required to remove the relevant crypto-asset from its offering. Such removal is not a discretionary measure aimed at restricting Client rights, but an operational consequence and compliance measure arising from the cessation of availability of the appropriate market liquidity source.

Prior to removing a crypto-asset from its offering, the Company notifies Clients one to three days before the planned removal. During this period, the Client may:

independently convert the relevant crypto-asset into EUR or another supported crypto-asset;
transfer the relevant crypto-asset to an external wallet outside the Platform.

If the Client does not take any of the aforementioned actions within the period allowed, upon its expiry the remaining balance of the relevant crypto-asset in the Client's Account is automatically converted into SEF. Automatic conversion does not mean a loss of the Client's assets, but the substitution of the delisted crypto-asset with a substitute crypto-asset within the Company's system, in circumstances where the Company can no longer objectively provide services relating to that crypto-asset.

The quantity of SEF tokens credited to the Client is determined by the amount obtained from the sale of the delisted crypto-asset at the time of execution and by the value of the SEF token at the time of its purchase. The standard Company fee in accordance with the applicable price list at the time of conversion shall apply.

Client's rights in relation to the SEF token

Following the automatic conversion, the Client may use the SEF tokens acquired in the following ways:

holding the SEF in the Account;
using them to pay fees on the Platform;
converting them into EUR or another supported crypto-asset;
transferring the SEF to a wallet of their choice, within the Platform or to an external wallet.

SEF tokens held by the Client in the Account constitute the Client's assets and are subject to all provisions of these Terms relating to custody and protection of Client assets. By accepting these Terms, the Client gives their explicit and irrevocable consent that, if they do not take any of the aforementioned actions within the period allowed, the remaining balance of the delisted crypto-asset will be automatically converted into SEF tokens.

FEES AND EXCHANGE RATES

The Company does not charge fees for opening or closing an Account.

Fees for the custody service and crypto-asset transfer service, the price of the Service, the applicable exchange rate, and margins are determined in accordance with the Crypto-Asset and Services Pricing Policy, publicly available. The reference price of crypto-assets is formed from relevant market liquidity sources, and the applicable buy/sell exchange rate is calculated by applying a margin to the reference price.

Margins for Clients are variable and depend on the type of asset, liquidity, volatility, payment method, and associated costs.

Crypto-assets may be purchased, sold, or exchanged only at the quoted buy or sell rate. The Company will clearly display the exact amount you must pay when placing an order.

Prior to confirming an order, you will be shown the final transaction amount and the applicable exchange rate, which includes all fees.

The current price of crypto-assets on the Platform is displayed at the mid-market rate; during the actual purchase/sale flow you will see the current buy or sell rate.

The displayed rate includes the Company's margin, which varies between 0.5% and 6%, depending on the liquidity of the crypto-asset.

For sales of crypto-assets, proceeds are paid out in EUR only. Non-cash rates are more favourable than cash rates; cash rates are visible at Branches and update in real time. In Branches, you can also obtain the non-cash rate if you indicate you wish to deposit or withdraw by bank transfer.

By accepting these Terms, you acknowledge that rates are updated every second and may change when placing an order due to global market movements. The Company is not liable for rate changes or for transfers executed at the time of a rate change.

POWER OF ATTORNEY

You may authorise another person to dispose of funds in your Account; the power of attorney must be notarised (and apostilled/legalised as applicable) and delivered to the Company.

It must not be older than one month. You are solely responsible for the actions of your authorised representative; the Company has no obligation to inform you of their actions and is not liable if the authorised representative breaches these Terms.

The power of attorney ceases upon the Company's receipt of a statement or confirmation of revocation, upon Account closure, or upon receipt of a statement or confirmation of the death of the Client or the authorised representative.

Personal data collected during verification are not automatically deleted upon Account closure. See the Privacy Policy for details.

RISK

Risk warning: transactions in crypto-assets carry a high level of risk and may result in the partial or complete loss of the value of invested assets. The Client acknowledges that the following risks are particularly relevant: price volatility risk, liquidity risk, technological and blockchain risk, operational risk, cyber risk, regulatory and legal risk, currency and tax risk, and the risk of transaction irreversibility. The Client is required to carefully assess, prior to using the Services, whether such transactions are appropriate given their knowledge, experience, financial position, and risk tolerance. Where applicable under Regulation (EU) 2023/1114, the Company will make available to the Client links to the relevant crypto-asset white papers.

By accepting these Terms, you acknowledge that trading in crypto-assets involves the following risks:

Market risk – the value of crypto-assets may rise or fall rapidly, including the possibility of a total loss of value.
Volatility and price slippage risk – the price at the time of order confirmation may differ from the price at the time of execution.
Liquidity risk – for certain tokens it may be difficult or impossible to execute a transaction at the expected price.
Regulatory and legal risk – changes to laws, secondary legislation, tax rules and regulatory requirements may affect the availability of Services and the value of assets.
Operational risk – technical failures, system outages, third-party errors, and extraordinary events.
Technological and blockchain risk – network congestion, confirmation delays, hard forks, protocol changes, and increased network fees.
Cyber risk – phishing, malware, and unauthorised access to the Account.
Transaction irreversibility risk – blockchain transactions are generally irreversible. An incorrectly entered address or network may result in permanent loss of funds.
Third-party risk – dependence on banks, card schemes, infrastructure providers, token issuers, and other partners.
Currency risk – additional costs and differences arising from conversion between currencies.
Tax risk – tax treatment depends on the Client's country of residence and individual circumstances.

You confirm that the Company does not provide investment advice, does not guarantee returns or the stability of the value of investments, and is not liable for the consequences of your investment decisions.

The Company holds Client funds in a pooled account. By accepting these Terms, you confirm that you are aware of this and are warned of the following risks: in the event of the Company's insolvency, your funds may not be unambiguously distinguishable from those of other Clients, which may complicate or delay their return. The Company may hold Client crypto-assets on a pooled basis exclusively with the Client's prior explicit consent. By accepting these Terms, you give consent for the pooled holding of crypto-assets and acknowledge the following risks: the risk of asset segregation in the event of insolvency, operational risk, the risk of record-keeping errors, and the risk that a loss suffered by one Client may affect the assets of others in the pooled wallet.

Where Client crypto-assets or funds are stored with third parties (sub-custodians), you are exposed to additional risks, including the operational risk of the third party, the risk of limited or delayed access to assets, and the risk of insolvency or other difficulties affecting the third party.

The Company is responsible for the diligent and careful selection of sub-custodians and for ongoing monitoring of their adequacy. The Company is not liable for Client losses arising solely as a consequence of a sub-custodian's insolvency, provided that the Company acted with due professional care in the selection and monitoring of the sub-custodian.

REFERRAL PROGRAMME

Eligibility

By sharing a Unique Link to earn a Referral Programme Reward, the Referrer is deemed to have accepted these Terms. If they disagree, they must not use or benefit from the Programme.

A Referred Client may be a natural person. A person who is already registered before receiving a Unique Link cannot be considered a Referred Client.

How to participate

The Referrer sends their Unique Link to the Referred Client. After the Referred Client opens an Account and completes a transaction, the Referrer receives 20% of the Company's revenue from that transaction and from all future transactions of that Referred Client. Rewards may be earned for two years from the Referred Client's Account opening; the number of referrals is unlimited.

The Referrer earns the reward when the Referred Client completes a cash transaction at a Branch or an online transaction via the Platform. Rewards are credited to the Referrer's Account within 24 hours of the Referred Client's successful transaction.

If multiple Unique Links are received, the last clicked link used to register will apply. The Unique Link is intended as a personal, non-commercial invitation. Referrers can track accrued rewards in their Account.

Restrictions

The Company reserves the right to deny participation to a Referrer or Referred Client in cases of suspected fraud, manipulation, abuse of the Programme rules, or technical errors, and bears no liability towards the Referrer or others for such actions. By accepting these Terms, the Referrer undertakes not to:

engage in offensive, misleading, or non-compliant activities;
use the Unique Link or the Bitcoin Store name in a negative or offensive context.

In case of violations, the Company may:

close the Referrer's Account;
refuse verification of the Referred Client's Account;
remove the Unique Link and mark all related referrals as ineligible for rewards;
withhold or cancel accrued or already paid rewards;
review and investigate Programme activities as deemed necessary.

Changes to the Referral Programme

The Company may cancel, discontinue, or amend the Programme at any time without prior notice, including:

changing Programme criteria;
changing rewards;
changing participation conditions;

amending the Terms due to fraud risk, market conditions, or other reasons.

CLIENT'S RESPONSIBILITIES

You use the Platform at your own risk.

You are responsible for keeping your Account credentials confidential and for restricting access to your device(s); you are responsible for all activities under your Account. Take all protective measures to prevent loss, theft, misuse, and unauthorised use of your Account, and promptly notify the Company of any loss, theft, misuse, or unauthorised use of personal data or unauthorised transactions.

Use the Platform in accordance with applicable laws, rules, and ethical standards and avoid any actions that could damage the Company's reputation. If the Company requests additional documentation during standard checks, ensure that all data and documents provided are accurate and truthful and provide clarifications or updates if requested.

You will not use the Platform or Services for any illegal, unethical, or non-compliant purpose. You agree to indemnify the Company, its employees, partners, and service providers for losses arising from your breach of these Terms or misuse of the Services.

You will not use the Platform to transmit viruses or any other tools or mechanisms intended to compromise, disrupt, or otherwise harm the computer system or any related operations.

You acknowledge that the content of https://www.bitstore.net and the Bitcoin Store Wallet Mobile Application is the Company's property. Copying, resale, publishing, and/or modification of any part of the Platform without consent is strictly prohibited. You will not infringe the Company's copyrights, patents, trademarks, or other intellectual property rights.

Tax rules on crypto-assets vary by country of residence; you are responsible for reporting and paying any applicable taxes to the competent authority.

COMPANY'S LIABILITY

The Company does not warrant that the Platform will operate uninterrupted or error-free.

We may modify Platform functions, upgrade systems, enhance security, or suspend/disable access and execution of transactions at any time without notice.

Services may be unavailable due to scheduled maintenance (of which Clients will be notified) or extraordinary circumstances, which will be remedied as soon as possible.

This disclaimer covers any damage or injury arising from errors, interruptions, delays in operation or data transmission, computer viruses, internet outages, other actions, and force majeure.

The Company may limit Services, delist crypto-assets, or cancel transactions in the event of market disruptions, third-party service issues, cyberattacks, or other unexpected risks, and is not liable for damage resulting from such events.

Liability for ordinary negligence is excluded to the maximum extent permitted, and you waive claims for such damages. The Company is also not liable for actions taken to comply with legal obligations or orders of competent authorities.

SECURITY MEASURES

Collected data is stored electronically and protected by an SSL certificate which encrypts personal data to ensure secure communication between the Client and the Platform.

We take appropriate technical and organisational measures to protect personal data against loss, misuse, destruction, disclosure, unauthorised access, or alteration, including two-factor authentication (2FA), passwords, and monitoring of Client activity.

Built-in safeguards ensure that personal data are not automatically available to others and that only data necessary for the purpose of processing are processed.

Do not open, forward, or reply to emails, attachments, or links from suspicious senders.

You are informed that all Company emails originate from the following domains:

@hello.bitstore.net;

@email.bitstore.net;

@bitstore.net;

@digital-assets.hr;

@bitcoin-store.net;

@hello.bitcoin-store.hr;

@bitcoin-store.hr.

COMPLAINTS

If you have a complaint about the Services, you may:

speak to a staff member at a Branch;
email: zop@bitcoin-store.hr;
send postal mail to: Digital Assets d.o.o., Complaints Handling Officer, Hrv. mornarice 1C, 21000 Split, Republic of Croatia.

Written complaints are recommended to ensure that all relevant information is clearly stated.

When submitting a complaint, please provide:

name, surname, address, and contact details;
description and date of the event that gave rise to the complaint;
details of any partner or employee concerned (if applicable);
copies of supporting documents.

See the Complaints Handling Policy for more information. The complaints form is available here.

DISPUTE RESOLUTION

These Terms are governed by and construed in accordance with the laws of the Republic of Croatia. Any disputes shall be resolved before the Commercial Court in Split.

AMENDMENTS TO THE TERMS

The Company may amend these Terms for the purpose of compliance with laws and regulatory requirements, improvements to security, changes in the scope of Services, changes in fees, and other justified business reasons.

Notice periods and method of notification:

Material amendments (amendments affecting the rights and obligations of Clients, the method of calculating fees, risks, or the scope of Services) – at least 15 days prior to entry into force.

Non-material amendments (technical, editorial, or administrative amendments without a material impact on the Client) – at least 7 days prior to entry into force.

Emergency amendments (required by a legal obligation, regulatory instruction, or security reasons) – may enter into force immediately or within a shorter period, with prompt notification to Clients.

Client notification channels include email, notifications on the Platform, and, where necessary, notifications at Branches.

If you do not accept material amendments, you have the right to terminate the agreement and close your Account without charge before the date on which the amendments enter into force, having first fulfilled all obligations under these Terms.

Continued use of the Services after the date on which the amendments enter into force shall be deemed acceptance of the amendments.