General Terms and Conditions for Users

Effective from: 27 September 2026

These Terms constitute a legal agreement between you and BlockDev PLC (“BlockDev”, “we”, “us”, “the Company”), a company incorporated under the laws of the Republic of Bulgaria (company number 208043482), with its registered office at 9A Pozitano Str., office 12, 1000 Sofia, Bulgaria. These Terms govern the use of the crypto-asset services provided by BlockDev PLC through a partner platform, including, where applicable and within BlockDev PLC’s authorised regulatory scope: exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, transfer of crypto-assets on behalf of clients, and custody and administration of crypto-assets on behalf of clients.

The Partner Platform provides the client interface, the technical integration and the channel for submitting instructions, but this does not change BlockDev PLC’s role as the provider/principal of the relevant crypto-asset service where such a service is provided by BlockDev PLC. BlockDev PLC is responsible for the applicable obligations in connection with the crypto-asset services, including service transparency, RFQ quoting, execution of exchanges/transfers, custody and administration (where applicable), AML/CFT/KYT checks, sanctions screening, transaction monitoring, application of the TFR/Travel Rule requirements, record-keeping, client disclosures and client protection.

For the avoidance of doubt, payment services, payment accounts, electronic money, open banking services, card payments, bank transfers, VIBAN services or other regulated payment functionalities are provided only by the relevant licensed payment service provider, electronic money institution, bank or other regulated partner, unless BlockDev PLC expressly holds the applicable regulatory status to provide such a service. In such cases, BlockDev PLC acts only in the applicable capacity, including as an agent/registered representative where relevant.

USDC, EURC and other e-money tokens (EMTs) are not provided by BlockDev as part of the transfer, custody or administration services, unless otherwise expressly provided in the future on the necessary regulatory basis, with updated client documentation and separate client acceptance.

Before you gain access to the sub-page and functionalities through which the Services are provided, you will be presented with these Terms and expressly invited to read them. To proceed to the relevant sub-page and gain access to the Services, you must confirm, by an affirmative action in the checkbox provided for that purpose, that you have read and understood these Terms and agree to be bound by them. Without this express confirmation, you will not be able to proceed to the sub-page relating to the provision of the Services or gain access to them. By giving this confirmation, you expressly accept these Terms and confirm that you have been informed that, with respect to the crypto-asset services, BlockDev PLC acts as the provider of the relevant service and, for the services of exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets, as principal and counterparty to the relevant transaction with you. Consent to these Terms is given before access to the Services is granted and is recorded electronically.

Please read these Terms carefully, as they contain important information about your rights and obligations, as well as limitations and exclusions of liability that apply to you when using the services. If you do not agree to these Terms, you must immediately stop using or accessing the services provided by BlockDev.

1. General provisions

1.1 The role of BlockDev

The Partner Platform provides the client interface, the technical integration and the channel for submitting instructions, but this does not change BlockDev PLC’s role and responsibility as the provider of the relevant crypto-asset service. BlockDev PLC is responsible for the applicable obligations in connection with the services it provides, including service transparency, RFQ quoting, execution of exchanges/transfers, AML/CFT/KYT checks, transaction monitoring, application of the TFR requirements, record-keeping and client protection.

All interactions with BlockDev’s services take place through the Partner Platform, which is responsible for the overall user experience and the provision of the services.

1.2 Services provided

The crypto-asset services provided by BlockDev PLC are described below in accordance with the regulatory scope for which the Company has applied. A particular service is provided only for eligible and supported crypto-assets and blockchain networks, subject to the successful completion of the applicable identification, due diligence, AML/CFT, sanctions screening and risk assessment procedures, and to the fulfilment of the applicable technical and regulatory conditions. USDC and other e-money tokens (EMTs) are excluded from the custody and administration services and from the transfer services for crypto-assets on behalf of clients.

1.2.1 Custody and administration of crypto-assets on behalf of clients

BlockDev PLC provides this service for eligible crypto-assets other than USDC and other EMTs. The service includes the safekeeping and/or control of crypto-assets or of the means of access to them, keeping a register of client positions, administering client instructions, providing statements, and the controlled return of assets on request or upon termination. Use of the service requires the conclusion of a separate standard custody agreement between BlockDev PLC and the client; acceptance of these Terms alone is not sufficient to access the service.

Once the client has been successfully onboarded, an individual segregated client crypto wallet is created through […]. Client crypto-assets are held separately from BlockDev PLC’s own assets and from the assets of other clients. When crypto-assets are received, a KYT check of their origin and risk is carried out, and operations are subject to transaction monitoring. BlockDev PLC maintains an internal register of client assets and performs a daily reconciliation between its internal records and the information from the custody infrastructure.

When an order for a withdrawal or transfer is given, BlockDev PLC verifies the validity of the order, the client’s authority and the applicable regulatory restrictions. After the necessary approvals, the transaction is signed and broadcast to the relevant blockchain network. BlockDev PLC remains the provider of the service to the client and bears responsibility under MiCA, regardless of its use of external technology providers.

1.2.2 Providing transfer services for crypto-assets on behalf of clients

BlockDev PLC executes valid client instructions to transfer eligible crypto-assets other than USDC and other EMTs between DLT addresses or accounts. In providing this service, BlockDev PLC executes the client’s order and does not act as counterparty to the transaction. The service is provided subject to the applicable KYC/KYB, AML/CFT, sanctions, KYT and Travel Rule checks.

The client submits an electronic order specifying the crypto-asset, the amount and the recipient’s address. BlockDev PLC verifies the validity and eligibility of the transaction and the risk associated with the recipient’s address, and the transaction is also subject to ongoing monitoring. In accordance with Regulation (EU) 2023/1113, BlockDev PLC collects, verifies and, where applicable, transmits the required information on the originator and the beneficiary to the recipient’s crypto-asset service provider. After approval, the transfer is signed and broadcast to the relevant blockchain network, after which the records are updated and the client is notified.

1.2.3 Exchange of crypto-assets for funds

BlockDev PLC provides this service for eligible spot crypto-assets and acts as principal/counterparty to the transaction with the client. The Company provides an RFQ quote in advance and executes the exchange once the client accepts it. Client orders are not routed to external platforms or liquidity providers. Liquidity providers may be used by BlockDev PLC for its own account to secure liquidity, for settlement or to replenish its own working reserve. The payment component of fiat pay-ins/pay-outs, where applicable, is provided through licensed payment/EMI or open banking partners; BlockDev PLC does not provide payment services in its own name.

When a crypto-asset is purchased for funds, once the client has been successfully onboarded, BlockDev PLC provides a quote including the type and amount of the crypto-asset, the applicable exchange rate, the amount of the spread and the validity period. Once the quote has been accepted and the payment in euro has been received, BlockDev PLC delivers the crypto-asset from its own working reserve to the individual client wallet. If the reserve is insufficient, BlockDev PLC enters into a separate transaction for its own account with an external liquidity provider; the client is not a party to that transaction and the client’s order is not passed on to the third party.

When a crypto-asset is sold for funds, the client transfers the crypto-asset to an individual deposit address. After a KYT check and transaction monitoring, BlockDev PLC provides a binding quote containing the exchange rate, the applicable spread and the validity period. Upon acceptance of the quote, BlockDev PLC acquires the crypto-asset for its own account and owes the client the corresponding cash equivalent in euro, which is paid through the applicable payment infrastructure. BlockDev PLC remains the sole counterparty to the exchange transaction with the client.

1.2.4 Exchange of crypto-assets for other crypto-assets

BlockDev PLC provides the service of exchanging one eligible spot crypto-asset for another eligible spot crypto-asset and acts as principal/counterparty to the transaction. The client enters into the transaction directly with BlockDev PLC. The supported assets and networks are set out in the Register of Supported Crypto-Assets and Blockchain Networks and are subject to prior legal, AML/CFT, technological, liquidity and operational assessment. The service may also cover e-money tokens (EMTs), including USDC, which may be exchanged for another eligible crypto-asset or vice versa; in these cases too, BlockDev PLC acts as principal and counterparty to the transaction.

Once the client has been successfully onboarded, an individual deposit address is created, to which the client transfers the crypto-asset to be exchanged. Upon its receipt, a KYT check and ongoing transaction monitoring are carried out. BlockDev PLC provides a binding quote containing the exchange rate between the two crypto-assets, the applicable spread and the validity period. Once the quote has been accepted, the requested crypto-asset is delivered from BlockDev PLC’s own working reserve to the individual client wallet. Where availability is insufficient, BlockDev PLC enters into a separate transaction for its own account with an external liquidity provider; that transaction does not constitute the execution or routing of a client order to a third party.

For all services, the applicable fees and charges are determined in accordance with BlockDev PLC’s current Tariff, which is a separate document available to the client via a link on the Partner Platform and/or the Company’s website. Where a quote is provided for a particular transaction, the applicable rate, the spread and the other applicable pricing elements, depending on the nature of the service, are shown to the client before it is confirmed.

2. User eligibility and account access

2.1 Eligibility criteria

2.1 Eligibility requirements

To access and use the services provided through the Partner Platform, you must meet the following eligibility requirements:

• You must be an adult, aged at least 18, or have reached the age of majority under the laws of your jurisdiction.
• You must be resident in a jurisdiction where the use of cryptocurrency transactions and related services is permitted by applicable law.
• You must not be a resident or citizen of any of the restricted jurisdictions described below.
• You must have accepted these Terms. Before you gain access to the sub-page and functionalities through which the Services are provided, you will be presented with these Terms and expressly invited to read them. To proceed to the relevant sub-page and gain access to the Services, you must confirm, by an affirmative action in the checkbox provided for that purpose, that you have read and understood these Terms and agree to be bound by them. Without this express confirmation, you will not be able to proceed to the sub-page relating to the provision of the Services or gain access to them. By giving this confirmation, you expressly accept these Terms and confirm that you have been informed that, with respect to the crypto-asset services, BlockDev PLC acts as the provider of the relevant service and, for the services of exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets, as principal and counterparty to the relevant transaction with you. Consent to these Terms is given before access to the Services is granted and is recorded electronically.

2.2 Restricted jurisdictions

Access to the Services is prohibited for natural and legal persons who are located in, established in, registered in or otherwise connected with countries or territories subject to sanctions, embargoes or other restrictive measures imposed by competent authorities, including, but not limited to, the US Office of Foreign Assets Control (OFAC), the European Union or other applicable national and international authorities. This includes jurisdictions subject to comprehensive sanctions regimes or to significant restrictions in respect of financial services, crypto-assets or payment transactions.

BlockDev reserves the right, at its sole discretion, to refuse to provide services to, or to restrict access by, persons from such jurisdictions.

By accepting these Terms, you represent and warrant that you are not located in, resident in or established in a restricted jurisdiction, and that you are not acting on behalf of a person who is subject to sanctions or restrictions.

If BlockDev determines that you fall within the scope of the above restrictions, the Company may immediately terminate or restrict your access to the Services, including by suspending or closing your account, without notice.

2.3 Reverse solicitation for users outside the EU

If you are not a citizen or resident of the European Union (EU), you acknowledge and accept that your use of the services provided by BlockDev is based on the principle of reverse solicitation. This means that you choose to access and use these services entirely on your own initiative, without any solicitation, advertising or marketing by BlockDev or its partners directed at you. By accepting these Terms, you confirm that you are fully aware of the legal and regulatory implications of accessing cryptocurrencies and financial services and that you do so voluntarily and at your own risk.

2.4 Account creation

To use BlockDev’s services through the Partner Platform, you may need to create an account on the Partner Platform. The account creation process may include providing personal information, including identity verification, as part of the Know Your Customer (KYC) requirements. By creating an account, you agree to provide accurate, complete and truthful information. You are also responsible for keeping the information in your account accurate and for updating it promptly when necessary.

You are solely responsible for safeguarding your login credentials and for ensuring the security of your account. This includes keeping your username, password and any other authentication information confidential. You are fully responsible for all activity carried out under your account, including transactions initiated by third parties, whether authorised or not, as a result of your failure to safeguard your login credentials.

For the avoidance of doubt, BlockDev informs you that the service of custody and administration of crypto-assets on behalf of clients requires acceptance of the General Terms and Conditions for Custody, Administration and Transfer of Crypto-Assets on behalf of Clients, as well as the conclusion of a Crypto-Asset Custody and Administration Agreement with BlockDev PLC. Acceptance of these Terms alone does not give you access to the custody and administration service for crypto-assets.

2.4 Account responsibility

BlockDev is not liable for unauthorised access to your account, for transactions initiated as a result of mishandling of, or negligence in protecting, your login credentials, or for actions resulting from unlawful or fraudulent activity initiated from your account. You agree to notify the Partner Platform immediately if you notice any unauthorised access or suspicious activity in connection with your account.

2.5 Acknowledgement of cryptocurrency risks

By intending to use crypto-asset services, you declare that you have been informed of and understand the inherent risks associated with holding and trading crypto-assets. These risks include, without limitation, significant fluctuations in the value of crypto-assets, partial or total loss of the funds invested, technological and operational risks, cyberattacks, interruptions or malfunctions of distributed ledgers, and changes in the applicable regulatory environment.

The client bears the risk of losses arising from market movements, from the characteristics and functioning of the relevant crypto-asset or of the technology used, and from other circumstances beyond BlockDev’s reasonable control, except where the loss concerned is caused by an act or omission of BlockDev for which the Company is liable under applicable law or these Terms.

Nothing in this section excludes or limits any liability of BlockDev that cannot be excluded or limited under applicable law, including for damage or for loss of crypto-assets or funds where the event concerned is attributable to an act or omission of BlockDev.

BlockDev maintains insurance coverage for certain risks relating to the services provided, in accordance with the terms, limits, exclusions and other limitations of the applicable insurance policy. Where an event that has occurred falls within the scope of that coverage, BlockDev takes the necessary steps to submit and administer the insurance claim. The existence of insurance does not automatically guarantee the payment of compensation to the client and does not extend BlockDev’s liability beyond what is provided for in applicable law and the insurance policy.

3. Transaction execution and risks

3.1 Transaction process

BlockDev facilitates the secure transfer of funds, carries out the necessary conversions and ensures the movement of assets between the financial institutions, partners and other service providers, if any, involved in the transaction.

Although BlockDev manages and executes the transactions, all transactions are subject to the terms set by the Partner Platform. You acknowledge that the Partner Platform is responsible for facilitating your access to BlockDev’s services, including the management of user accounts and the maintenance of the user interface.

3.1.1 Payment methods

Depending on the configuration of the Partner Platform and your location, you may be able to use one or more methods of funding or payout (“Payment Methods”), including bank transfer/open banking, payment cards (Visa and Mastercard), tokenised card payments (Apple Pay and Google Pay) and other local or alternative payment methods provided through third-party partners.

3.1.2 Availability; changes; third-party partners

The availability of payment methods may vary depending on the country/corridor, the bank/card issuer, the partners’ capabilities and your risk profile. BlockDev may route transactions through one or more third-party providers (for example, banks, payment service providers, open banking providers, card acquirers/processors and other partners) and may add, remove, suspend or restrict payment methods where necessary for compliance, fraud prevention, network/partner rules or risk management.

3.1.3 Crypto-assets for use on the platform; technical address; custody wallet

Where permitted by the Partner Platform and allowed under applicable law, the client may acquire, exchange, transfer or use supported crypto-assets for purposes related to the Partner Platform, including payments to merchants or other permitted transactions.

USDC, EURC and other e-money tokens (EMTs) are not provided by BlockDev as part of the transfer, custody or administration services, unless otherwise expressly provided in the future on the necessary regulatory basis, with updated client documentation and separate client acceptance.

Depending on the specific flow, the Partner Platform or BlockDev may create or provide a limited-purpose technical blockchain address. Such a technical address may be used solely for the execution or settlement of a specific transaction and does not constitute a general client wallet, unless the client has expressly accepted the separate custody and administration terms.

Where the client uses a service of custody and administration of crypto-assets on behalf of clients, BlockDev is the provider of that service to the client. In that case, client crypto-assets are held and administered on behalf of the client through custody/wallet infrastructure, which may be provided by an external technical provider. The external technical provider does not replace BlockDev as the provider of the service to the client.

BlockDev maintains an internal register of client positions, applies rules on the segregation of client assets, reconciles its internal records with the data from the external provider and on-chain balances, and executes instructions only after the necessary checks and approvals.

The client understands that, in the case of a custody service, the client may not have access to the private keys associated with the technical wallet infrastructure. Access, management and the execution of transactions are carried out in accordance with BlockDev’s procedures and the applicable custody terms.

The client acknowledges that blockchain transactions are generally irreversible once confirmed, that sending assets to an incorrect or unsupported address, an unsupported network or an unsupported asset may result in permanent loss, and that BlockDev may refuse, delay, suspend or block a transaction in the event of AML/CFT, sanctions, KYT, Travel Rule, fraud, security, technical or regulatory risk.

3.2 Transaction fees

Fees and charges may apply to BlockDev PLC’s services in accordance with BlockDev PLC’s current Tariff. The Tariff is a separate document available to the client via a link on the Partner Platform and/or the Company’s website. Before confirming a particular transaction, the client is informed of the fees applicable to it and, where applicable, of the exchange rate and the spread.

3.2.1 Payment method fees; classification of card transactions

In addition to the fees of BlockDev or the Partner Platform, the payment method you select may involve additional fees charged by third parties (for example, banks, card issuers, card networks, acquirers, processors, currency service providers or local payment partners). When you fund a purchase with a payment card, the transaction may be processed as an account funding transaction (“AFT”) (or equivalent), where applicable, which your card issuer may treat differently from a standard retail purchase.

3.2.2 Strong customer authentication / 3-D Secure

For some payment methods (including open banking and card payments), additional authentication may be required (for example, SCA and/or 3-D Secure). You agree to complete all necessary authentication steps and accept that, if you do not, the transaction may be declined.

3.2.3 Refunds, returns and reversals

All refunds, returns, reversals and cancelled transactions (including those relating to card payments and AFT transactions) are carried out in accordance with the rules, procedures and time limits of the relevant payment method, the applicable card scheme, the issuer of the payment instrument and/or the relevant third-party service providers.

Requests for refunds or transaction disputes should be submitted through the Partner Platform’s official support channels. In this connection, you may be asked to provide additional information, documents or evidence in support of your request.

In the event of a chargeback, return or reversal of a transaction, the relevant amounts may be withheld, set off, adjusted or refunded in accordance with the applicable rules.

3.3 Transaction confirmation

BlockDev is not liable for delays or errors in the processing of transactions due to factors beyond its control, including network congestion, system failures or delays in blockchain confirmations. BlockDev will make reasonable efforts to process transactions in a timely manner but does not guarantee that any transaction will be completed within a specific time.

3.4 Risks

By using BlockDev’s services through the Partner Platform, you acknowledge that cryptocurrency transactions carry inherent risks, including price volatility and the risk of loss due to market fluctuations. BlockDev is not liable for financial losses arising from these risks, nor is it responsible for the performance of assets exchanged through the services. Where the client uses a service of custody and administration of crypto-assets, there are additional risks, including the risk of a technology incident, cyberattack, operational outage, incorrect instruction, incorrect address or network, delay of a blockchain transaction, loss or compromise of the means of access, risk relating to the external wallet/custody infrastructure provider, risk relating to forks, airdrops or network events, and the risk that a transaction may be delayed, refused or blocked on AML/CFT, sanctions, KYT, Travel Rule, fraud, security or technical grounds.

BlockDev applies internal policies and control mechanisms to mitigate these risks, including segregation rules, approval of instructions, access control, monitoring, reconciliation and incident escalation, but cannot eliminate all risks inherent in crypto-assets, blockchain infrastructure and the use of external technology providers.

3.5 Suspicious activity and regulatory compliance

BlockDev reserves the right to refuse, suspend or delay any transaction if it detects suspicious activity or if there are grounds to believe that the transaction may be connected with money laundering (ML), terrorist financing (TF) or other illegal activities. This includes transactions originating from blockchain addresses that have been flagged as potentially connected with illegal activities, or where the transaction appears to breach applicable laws or regulatory requirements.

If BlockDev identifies a “tainted” or suspicious blockchain address, it may take action to block, suspend or cancel the transaction. You acknowledge that BlockDev’s decision to refuse or delay a transaction in such circumstances is taken at its sole discretion and that such actions are taken in accordance with anti-money laundering (AML), counter-terrorist financing (CTF) and other applicable regulatory frameworks.

3.6 No guarantee of completion

BlockDev does not guarantee the successful or timely completion of any transaction, in particular where delays or errors occur due to circumstances beyond BlockDev’s control, such as technical problems with the blockchain, network congestion or other third-party failures. BlockDev also reserves the right to refuse to provide services or to execute transactions if there are concerns relating to compliance, security or suspicious activity.

3.7 User responsibility

You are solely responsible for ensuring that the information provided during the transaction process, including wallet addresses and transaction details, is accurate and compliant with applicable laws. BlockDev is not liable for losses, delays or errors caused by inaccurate or non-compliant information provided by you.

4. Data protection and privacy

4.1 Collection and use of personal data

By using the Partner Platform and BlockDev’s services, you consent to the collection, storage and processing of your personal data by the Partner Platform and BlockDev in accordance with the General Data Protection Regulation (GDPR). The Partner Platform and BlockDev will process your data to facilitate transactions, comply with legal obligations and improve the services provided. You have the right to access, rectify or erase your personal data in accordance with the GDPR. To improve your user experience, the Partner Platform and/or BlockDev may store a saved preference relating to the open banking method you used most recently. We do not store your online banking login credentials. This information is used solely to pre-fill or suggest the option you used most recently.

4.2 Data security

BlockDev implements appropriate technical and organisational measures to protect your personal data and safeguard it against unauthorised access, disclosure or loss. However, you acknowledge that no method of data transmission over the internet is completely secure and that BlockDev cannot guarantee the security of data transmitted through the Partner Platform. The Partner Platform is responsible for the integrity and security of its systems.

4.3 Data breach notification

In the event of a data security breach, BlockDev will notify the Partner Platform, which in turn will notify you in accordance with applicable data protection laws. BlockDev will take appropriate measures to mitigate the damage caused by the breach.

5. Limitation of liability

5.1 BlockDev’s liability

BlockDev is not liable for any direct, indirect, incidental, special or consequential damages arising from or in connection with the use of the Partner Platform or BlockDev’s services, including, but not limited to, financial losses, lost profits, loss of data or unauthorised transactions.

BlockDev is not liable for acts or omissions of the Partner Platform, including, but not limited to, delays, errors, technical malfunctions or fraudulent activities carried out through the Platform.

5.2 No warranty

BlockDev provides the Services “as is” and “as available”, without any warranties, express, implied or statutory, including, but not limited to, warranties of merchantability, fitness for a particular purpose, title, non-infringement or security. BlockDev does not warrant that the Services will be uninterrupted, error-free or free of harmful components.

5.3 Indemnification

You acknowledge and accept that your use of BlockDev’s services, including all transactions initiated through our platform, is subject to the following terms:

1. Indemnification: To the extent permitted by law, you agree to indemnify, defend and hold harmless BlockDev, its affiliates, directors, employees, agents and representatives (collectively, the “Indemnified Parties”) from and against all claims, damages, losses, liabilities, penalties, fines, costs and expenses (including reasonable legal fees and court costs) arising from or relating to:
2. Your use or misuse of the Services, including, but not limited to, the initiation of payments to a Partner or the failure to make such payments.
3. Any inaccuracies, errors or omissions in the information or instructions you provide to BlockDev or its Partners.
4. Your breach of these Terms or of applicable laws, regulations or rules (including, but not limited to, those relating to anti-money laundering, fraud or financial regulation).
5. Any claims brought by third parties, including Partners, as a result of your acts or omissions, whether intentional or not, in using the Services.
6. Any losses or damage caused by unauthorised access to your account, negligence in securing your account access credentials, or failure to notify BlockDev of any suspected unauthorised activity.

Assumption of risk: You understand and acknowledge that cryptocurrency transactions are exposed to significant risks, including, but not limited to:

• (a) Market volatility: Cryptocurrency prices are highly volatile and may change dramatically within short periods. You assume all risks associated with such price fluctuations and acknowledge that BlockDev is not liable for changes in the value of cryptocurrencies before, during or after your transaction.
• (b) Regulatory risks: The regulatory environment for cryptocurrencies is constantly evolving. You are solely responsible for understanding and complying with the laws applicable to your use of the Services in your jurisdiction.
• (c) Transaction risks: Transactions carried out through the Services are irreversible once confirmed. BlockDev is not liable for losses arising from incorrect wallet addresses, payment details or other errors in your transaction instructions.
• (d) Technology risks: Cryptocurrency transactions rely on blockchain technology, which may be subject to delays, errors or security vulnerabilities. You acknowledge and accept the inherent risks associated with blockchain technology, including potential network congestion, smart contract bugs or other technical issues.

Limitation of liability:

• (a) To the maximum extent permitted by applicable law, BlockDev is not liable for any indirect, incidental, special or consequential damages, or for any loss of profits, revenue, data or reputation, arising from or in connection with the use of the Services, whether the claim is based on contract, tort (including negligence), strict liability or any other legal ground, even if the Company has been advised of the possibility of such damages.
• (b) BlockDev’s aggregate liability to you for any claims arising from or relating to the Services may not exceed the total amount of fees paid by you to BlockDev in connection with the particular transaction(s) giving rise to such liability, or USD 100, whichever is lower.

6. Suspension, termination and account deletion

6.1 Suspension and termination of access

BlockDev reserves the right to suspend or terminate your access to its services through the Partner Platform in the event of a breach of these Terms or unlawful activity, including, but not limited to, fraud, non-compliance with applicable regulations or misuse of the services. BlockDev reserves the right to terminate access in the event of suspected money laundering, terrorist financing or other illegal activities.

6.2 Termination by the user

You may stop using the services at any time by ending all transactions and closing your account on the Partner Platform. However, you will remain liable for all outstanding obligations or fees incurred before such termination.

6.3 Effect of termination

Upon termination of your access to BlockDev’s services, you must stop using all services and delete any confidential information relating to BlockDev and the Partner Platform, in accordance with the Partner Platform’s instructions. Upon termination of a custody and administration service, BlockDev will take reasonable steps to return or transfer the supported client crypto-assets to an eligible address/wallet designated by the client, provided that the applicable KYC, AML/CFT, sanctions, KYT, Travel Rule, security and technical checks have been completed.

BlockDev may delay, refuse or block a return or transfer where this is required by applicable law, a regulatory authority or internal policy, or where there is suspicion of fraud, sanctions risk, illegal activity, an unsupported asset, an unsupported network, an incorrect address or technical impossibility.

7. Changes to these Terms

7.1 Amendments

BlockDev reserves the right to amend or update these Terms at its discretion. All changes will be communicated to the Partner by email, and the Partner Platform is responsible for informing you, as its client, of such changes. Unless otherwise stated, all amendments take effect no earlier than thirty (30) days after such notice has been given.

7.2 Right to object

You have the right to object to any proposed amendments to these Terms within the thirty (30) day notice period. Such objections must be submitted to the Partner Platform and are free of charge. If you do not object within this period and continue to use the services after the amendments take effect, you will be deemed to have accepted the revised Terms.

8. Governing law and dispute resolution

8.1 Governing law

These Terms are governed by Bulgarian law. All disputes arising from or in connection with these Terms are resolved in accordance with Bulgarian law. For the avoidance of doubt, since you are a client of the Partner Platform, any legal relationship between you and BlockDev is indirect and depends on the services provided by the Partner Platform. Nevertheless, the courts of Bulgaria have exclusive jurisdiction over all disputes relating to these Terms or to BlockDev’s services.

8.2 Dispute resolution

In the event of a dispute, the parties undertake to make good-faith efforts to settle it amicably. If no agreement is reached, any dispute arising from or in connection with BlockDev’s services is referred for resolution to the competent court in the Republic of Bulgaria.

Before referring the dispute to a court, you should first raise it with the Partner Platform, which is your direct point of contact.

9. Final provisions

9.1 Severability

If any provision of these Terms is held by a competent court to be invalid, unlawful or unenforceable, it shall be deemed amended to the minimum extent necessary to make it valid and enforceable. If such an amendment is not possible, the relevant provision shall be deemed severed, without affecting the validity and effect of the remaining provisions, which remain in full force and effect.

Before you gain access to the sub-page and functionalities through which the Services are provided, you will be presented with these Terms and expressly invited to read them. To proceed to the relevant sub-page and gain access to the Services, you must confirm, by an affirmative action in the checkbox provided for that purpose, that you have read and understood these Terms and agree to be bound by them.

Without this express confirmation, you will not be able to proceed to the sub-page relating to the provision of the Services or gain access to them.

By giving this confirmation, you expressly accept these Terms and confirm that you have been informed that, with respect to the crypto-asset services, BlockDev PLC acts as the provider of the relevant service and, for the services of exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets, as principal and counterparty to the relevant transaction with you. The Partner Platform serves as the client interface and technical channel for accessing the Services and for submitting instructions, where applicable.

Consent to these Terms is given before access to the Services is granted and is recorded electronically.

With regard to payment services, payment accounts, VIBAN, open banking or other regulated payment functionalities, BlockDev PLC acts only in the applicable capacity, including as an agent of a licensed provider where relevant. BlockDev is not a provider of fiat custody services, a broker or a financial adviser, and does not assume any fiduciary duties towards you or towards third parties.

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