General Terms and Conditions for Crypto Asset Services

Last Updated: 16.06.2025

You acknowledge that you have read, understood, and agree to these General Terms and Conditions.

Crypto Asset Service Provider (CASP) Registration under the Supervision of the Cyprus Securities and Exchange Commission (CySEC).

These General Terms and Conditions ("Terms") govern the use of the Crypto Asset Services ("Services") provided by ZERO21 LTD (ΗΕ 447449), a Limited Company registered and incorporated under the laws of Cyprus with registered address 19 Spyrou Kyprianou, Silver House 4th Floor, 3070, Limassol, Cyprus (Hereinafter: ZERO21 or Company). The Company is authorized by the Cyprus Securities and Exchange Commission (CySEC), with CASP registration No. 016/24. The following services ("Services") are provided exclusively to e-commerce businesse (legal entities).

By accepting the provisions of these Terms, the Merchant enters into a legally binding Terms with the Company. To protect the Merchant’s interests, the Merchant is requested to carefully read these terms and provisions before opening an account with the Company. Please note that there are other documents and information available on the Company’s official Website, which do form part of the Terms and provide more details on the Company and the Merchant’s activities carried on with the Company such as the Privacy Policy.

1. DEFINITIONS
  1. Crypto Assets: Digital assets, tokens, or cryptocurrencies based on blockchain or similar distributed ledger technology.
  2. Fiat Currency: Traditional government-issued currency such as USD, EUR, GBP, etc.
  3. Merchant: A legal entity (e-commerce business) registered and authorized to use the Services provided by the Company.
  4. Services: The services provided by the Company through the Merchant Portal, including:

    Crypto Asset Services:

    1. Exchange between crypto-assets and fiat currency
    2. Exchange between crypto-assets
    3. Management, transfer, holding and/or safekeeping, including custody, of crypto-assets or cryptographic keys or means which allow the exercise of control over crypto-assets

    Financial Services Related to Crypto Assets:

    1. Reception Transmission of Orders
    2. Execution of orders on behalf of Merchants
2. ACCEPTANCE OF TERMS

By accessing and using the Merchant Portal, You confirm that You are an authorized representative of a legal entity and that You accept and agree to be bound by these Terms. If You do not agree to these Terms, You must refrain from using the Merchant Portal and Services. The Company reserves the right to modify these Terms from time to time, and such modifications will be communicated to You. Continued use of the Merchant Portal after any changes constitutes acceptance of the modified Terms.

3. SERVICES PROVIDED

The Company provides the following regulated services through the Merchant Portal:

3.1 Reception and Transmission of Orders

We facilitate the reception and transmission of orders relating to one or more financial instruments, including crypto assets, tokens, or other digital financial instruments. These orders will be transmitted to execution venues or other counterparties as specified by the Company. We will act as an intermediary for the transmission of such orders and will do so according to the instructions provided by the Merchant.

3.2 Execution of Orders on Behalf of Merchants

The Company may execute orders on behalf of Merchant in relation to financial instruments, including buying, selling, or trading crypto assets. Execution will occur at the best available terms and in accordance with CySEC's regulatory guidelines and principles, ensuring fair treatment and best execution for Merchants.

3.3 Exchange between Crypto Assets and Fiat Currency

The Company provides a service to exchange crypto assets for fiat currency and vice versa. The exchange rates will be determined based on prevailing market conditions. The Company reserves the right to apply spreads or adjust rates depending on liquidity, market conditions, and regulatory requirements.

3.4 Exchange between Crypto Assets

The Merchant Portal allows Merchants to exchange one crypto asset for another (crypto-to-crypto exchange). Rates for crypto-to-crypto exchanges will be determined by the market at the time of the transaction, subject to the Company's internal policies.

3.5 Administration, Custody, and Safekeeping of Crypto Assets

The Company provides custody services for crypto assets, which may include the administration, transfer of ownership, safekeeping, and/or holding of crypto assets, cryptographic keys, or other means enabling control over such assets. The Company undertakes reasonable measures to secure the custody of crypto assets, but absolute security cannot be guaranteed. The Merchant acknowledges the risks associated with the custody and safekeeping of digital assets.

4. MERCHANT ELIGIBILITY AND OBLIGATIONS
  1. Eligibility: You represent and warrant that Your business is a legal entity registered as an e-commerce business and that You are authorized to engage in the activities described in these Terms. You must also ensure that Your business complies with CySEC's regulations and the laws of the Republic of Cyprus.
  2. Account Registration: To use the Services, You must register with the Company and complete any required Know Your Customer (KYC) and Anti- Money Laundering (AML) checks. You agree to provide true, accurate, current, and complete information when creating Your account and updating Your details. The Company holds the right to request any documentation related to the legal or natural person(s) of the entity to perform its KYC/KYB procedures in order to satisfy the requirements and its internal controls to assure compliance under EU AML directives.
  3. Security: You are solely responsible for maintaining the confidentiality and security of Your account credentials, cryptographic keys, and any other access mechanisms used in connection with the Services. You must notify Us immediately if You suspect any unauthorized access to Your account or crypto assets.
  4. Compliance: You agree to comply with all applicable laws, including CySEC's regulations and the relevant AML and CFT laws. The Company may request further documentation to verify Your compliance and/or to confirm the source of Your funds and/or during periodic account reviews, and You agree to cooperate with these requests.

The Terms shall commence once the Merchant has been informed about their account completes the registration and the Company has completed due diligence and satisfied its requirements in terms of Know Your Customer (KYC) or any other procedures. It is hereby noted that no payment or fee is applicable for the execution and commencement of the present Terms. However, this does not preclude the application of administration fees or other charges that may be introduced or apply under this document or separate terms or policies communicated to the Merchant.

By accepting and agreeing to the Terms during the online registration process, you agree to the provision of information through electronic means such as the Company’s website(s) and/or the verified email of the Merchant and/or any other durable mediums due to the nature of the relationship established between the relevant parties, which to our view is deemed acceptable and appropriate. The provision of information by means of electronic communication is treated as appropriate and acceptable since you have regular access to the internet. The provision by the Merchant of an email address for the purposes of the carrying on of that business is considered as sufficient evidence. The Company ensures that the information available in its Website and/or other durable mediums will be always kept up to date.

For avoidance of any doubt, the Company shall not be responsible for any authorised access and/or use of the Website and/or other durable mediums by Minors and/or any other third party which has access to your laptop/pc/phone/tablet and/or account, in any way or manner. You shall ensure that at all times the devices through which you access our Website and/or other durable mediums are not left unattended and any passwords and access codes as well as security data used for accessing your account are kept safe and out of the reach of other persons. You are solely responsible for all and any loss resulting from unauthorised use of your Account, including loss suffered as a result of lost or stolen passwords.

In accordance with the foregoing, you hereby represent and warrant, without prejudice to any other representations, warranties and/or covenants made under this Terms: (a) that you are an individual who can form legally binding contracts under the laws applicable in your country of residence; (b) that you are above the age of 18 or otherwise above the legal age in your country of residence; (c) that all of the information provided by you to us for the purposes of, or in the context of, opening an account with us and/or accessing and/or using our Website and/or other durable mediums is correct and fully updated; (d) that you have all necessary rights, power, and authority to enter into this Terms and to perform the acts required of you hereunder.

The Company will not provide you with any legal, tax or investment advice. Any and all information on the Company’s Website and/or other durable mediums is for informative and educational purposes only and no guarantee is represented from any statements about profits or income, whether express or implied.

5. FEES AND CHARGES

The Company may charge fees for providing the Services, which may include but are not limited to:

  1. Transaction fees (e.g. crypto-to-fiat and crypto-to-crypto exchanges).
  2. Custody and safekeeping fees.
  3. Execution fees.
  4. Administration fees

These fees will be disclosed within the Merchant Portal or on the Company’s website and may be updated periodically. By using the Services, You agree to pay the applicable fees as disclosed at the time of the transaction or as otherwise communicated by the Company.

6. RISK DISCLOSURE

By using the Services, You acknowledge and agree to the following risks:

  1. Market Risk: Crypto assets are volatile and subject to significant price fluctuations, which may lead to financial losses.
  2. Security Risks: The custody, storage, and transfer of crypto assets may involve risks such as hacking, fraud, or technological failures.
  3. Regulatory Risk: The regulatory environment for crypto assets is evolving, and changes in laws or regulations could impact the availability or functionality of the Services.
  4. Operational Risks: Due to the nature of blockchain technology, technical failures, or interruptions in the services provided by third parties could affect the execution or settlement of transactions.

You understand and accept these risks and agree that the Company is not liable for any financial loss resulting from the use of the Merchant Portal and Services.

7. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law, the Company's liability is limited to the amount of fees paid for the specific Service in question. The Company will not be liable for any indirect, incidental, special, or consequential damages, including but not limited to loss of profits, loss of data, or loss of crypto assets, arising from the use of the Merchant Portal or the Services.

The Company is not responsible for any loss or damage arising from events beyond its reasonable control, including but not limited to technical failures, force majeure events, or actions by third parties.

8. TERMINATION AND SUSPENSION

Without prejudice to the Company’s rights under these Terms to terminate it immediately without prior notice to the Merchant, either the Company or the Merchant may terminate these Terms with immediate effect by giving at least thirty (30) calendar days written notice to the other Party. Termination will be without prejudice to transactions already initiated. In the case of such termination, all pending transactions on behalf of the Merchant shall be cancelled. Upon termination of these Terms, the Company will be entitled, without prior notice to the Merchant, to cease the access of the Merchant to the Company’s Platform.

Should the Merchant wish to terminate these Terms, a notice in writing should be sent to the contact details that are set out on the Company’s website or electronically through the Support of the Company.

Termination by any Party will not affect any obligation which has already been incurred by either Party or any legal rights or obligations which may already have arisen under the Terms, or any transactions made hereunder.

Upon termination of these Terms, all amounts payable by the Merchant to the Company will become immediately due and payable including (but without limitation) all outstanding costs and any other amounts payable to the Company, any charges and additional expenses incurred or to be incurred by the Company as a result of the termination of the Terms.

Once a written notice of termination of these Terms is sent and before the termination date:

  1. The Merchant will have an obligation to provide the Company with a destination wallet address that has already been whitelisted by the company, that he/she wishes to transfer any remaining funds to.
  2. The Company will have the right to cease any access to the platform(s) that the Merchant may have had and/or limit any functionalities that the Merchant is permitted via the platform.
  3. The Company will be entitled to refuse to accept any new or existing requests that the Merchant may have.
  4. The Company will be entitled to refuse to the Merchant to withdraw funds from his/her account and the Company reserves the right to keep that funds as necessary to close positions which have already been opened and/or pay any pending obligations of the Merchant under the Terms.

Upon Termination any or all the following may apply:

  1. The Company reserves the right to close the Merchant’s account with the Company.
  2. The Company reserves the right to convert/exchange any of the Merchant’s cryptoassets to another crypto-asset(s) for the purposes of returning the funds to the Merchant.
  3. In absence of illegal activity or suspected illegal activity or fraud of the Merchant or instructions from the relevant authorities, if there is Balance in the Merchant’s favour, the Company will (after withholding such amounts that, at the Company’s absolute discretion, it considers appropriate in respect of future liabilities) pay such Balance to the Merchant as soon as reasonably practicable and, where appropriate, instruct any Nominee or/and any Custodian to also pay any applicable amounts.
  4. The Company reserves the right to refuse, at its sole discretion, to effect any transfers to any wallet addresses that it considers to be (or potentially be) any third party’s wallet address.
  5. Termination of the Merchant’s crypto-asset account held with the Company shall not, in any case, affect any rights which have arisen, existing commitments, and/or any contractual provision which was intended to remain in force after the termination of the account.
  6. Any pending fees/commissions due to the Company (and any other amounts that may be due) shall be payable by the Merchant.
  7. The Company also reserves the right to claim from the Merchant any charges or additional expenses incurred (or to be incurred) by the Company as a result of the termination of these Terms. This shall include any damages which arose during the arrangement or settlement of pending obligations.

The Company reserves the right to terminate these Terms immediately, without giving thirty (30) calendar days written notice, in the event that the Company, at its sole discretion, deems that the Merchant has materially breached these Terms. Grounds for breach shall include, but shall not be limited to, the provision of forged documents by the Merchant (or documents believed by the Company to be forged, and that the Merchant does not prove beyond reasonable doubt that it is legitimate), the provision of false information by the Merchant, suspicious activity by the Merchant, fraud or legal violations are suspected, regulatory risks are posed, unauthorized use is suspected, and any other applicable scenario that may be unlawful or deemed a breach of these Terms.

The Company reserves the right to terminate these Terms in the event that an application be made and/or any order is issued, and/or a resolution is approved, and/or any measures of bankruptcy and/or winding up of the Merchant are taken. The Company may terminate these Terms in the event that the termination in question is required by any Competent Regulatory Authority and/or Governmental Body and/or Court of Law.

The Company may terminate these Terms in the event that it has grounds to believe that the Merchants investments in crypto-assets affects, in any manner, the reliability and/or smooth/orderly operation of the Company’s platform.

The Company may terminate these Terms in the event that the Merchant has failed to provide any information requested by the Company. This information may pertain to, but is not limited to, any investigation and/or verification procedure undertaken by the Company and/or any Competent Authority.

The Company may terminate these Terms in the event that the Merchant acts and/or communicates in any rude or abusive manner to any employee of the Company, and/or threatens any employee of the Company.

The Company may terminate these Terms in the event of the death of the Merchant, in cases where the Merchant is a physical person. In the event that the Merchant is a legal entity, then the Company reserves the right to terminate these Terms should the Merchant enter liquidation and/or dissolution and/or any other procedure where the outcome is the closure/winding down of the Merchant.

9. PRIVACY AND DATA PROTECTION

The Company will process Your personal data in accordance with its Privacy Policy, which is designed to comply with the General Data Protection Regulation (GDPR) and relevant Cypriot data protection laws. By using the Services, You consent to the collection and use of Your personal data as described in the Privacy Policy.

10. AMENDMENTS

The Company reserves the right to modify or amend these Terms at any time. Any changes will be communicated to You via the Merchant Portal or through the Company’s website. The modified Terms will take effect immediately upon publication, and Your continued use of the Services will constitute acceptance of the modified Terms.

11. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms are governed by and construed in accordance with the laws of the Republic of Cyprus. Any disputes arising from these Terms shall be resolved through binding arbitration in Cyprus, in accordance with the rules of the Cyprus Arbitration and Mediation Centre (CAMC).

12. INTELLECTUAL PROPERTY

Unless otherwise stated, the Company owns the intellectual property rights on the website including all the content of the website. Users must not reproduce, republish, modify, distribute, sell, duplicate or otherwise exploit material on the website without prior written consent from the Company.

13. LINKS TO THIRD-PARTY WEBSITES

The website may include links to third-party websites not controlled by the Company. Users may access such links at their own risk. The Company assumes no responsibility for the content or practices of these third-party websites.

14. AML/CTF Statement

Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Know-Your- Customer (KYC) measures are focus areas of our Company. Below you will find a summary of our policy in regard to these areas.

The Company has adopted an Internal Policy Document on the prevention of money laundering and terrorist financing. It requires the Company to have effective programs in place to comply with applicable laws and regulations.

The Company's Anti-Money Laundering Compliance Officer oversees these policies, practices and procedures. Furthermore, all Company employees are obliged to report to the Anti-Money Laundering Compliance Officer any suspicious activity or transactions.

We have implemented procedures and routines regarding Know-Your-Customer and Customer Due Diligence, e.g. identifying customers and beneficial owners and verifying their identity on the basis of documents, data or information obtained from reliable and independent sources.

Furthermore, the Company pays special attention to:

  1. Understanding the ownership and control structure of our customers
  2. Obtaining information on the purpose and intended nature of the business relationship, and
  3. Monitoring the business relationship.

We have established processes enabling us to identify persons and legal entities identified by government agencies to be involved in terrorist financing, money laundering, etc. (e.g. EU's, UN, HMT's and OFAC's sanction lists).

We have established processes enabling us to identify persons who qualify to be a PEP (Politically Exposed Person) or related to a PEP.

We have developed procedures that assist in the monitoring of transactions for the purpose of identifying possible suspicious activity. If the Company identifies any suspicious transaction and/or behaviour, the Company may report this to the Competent Regulatory Authority and/or Governmental Body and/or Financial Intelligence Unit in compliance with the applicable law.

We have established a blockchain analytics tool to screen and monitor the wallets, to identify the owner of the wallet and its source and destination of funds, and the crypto- asset transactions to detect if the crypto-asset is linked to terrorist financing, sanctioned entities, dark web etc.

We have established employee training programs to educate and assist employees in the ways of preventing the Company from executing transactions related to money laundering and terrorist financing.

The following list predetermines the type of Merchants who are not acceptable for establishing a business relationship or execution of an occasional transaction with the Company:

  1. Merchants who fail or refuse to submit, the requisite data and information for the verification of their identity and the creation of their economic profile, without adequate justification
  2. Shell Banks
  3. Merchants who belong to the negative target market for the respective product
  4. Merchants who are sanction related or have been convicted of financial crimes
  5. Merchants that are based/from and/or receive/send funds in countries designated as prohibited by the company

Furthermore, the Company does not allow anonymous accounts nor shall it enter into a business relationship if the Merchant is unable to comply with the customer due diligence requirements.

We cooperate with law enforcement and regulatory agencies in accordance with national regulations.

15. CONTACT INFORMATION

For any questions, concerns, or clarifications regarding these Terms, please contact our support team at physical address: 19 Spyrou Kyprianou, Silver House 4th Floor, 3070, Limassol, Cyprus; or by electronic way of communication via email: contact@zero21.eu