Last Updated: 08.04.2026
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 businesses (legal
entities).
By accepting the provisions of these Terms, the Client (hereinafter 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.
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.
The Company provides the following regulated services through the Merchant Portal:
The Company facilitates the reception and transmission of orders relating to crypto assets, tokens, or other digital assets. Such orders may be transmitted to execution venues or other counterparties as specified by the Company, taking into account the nature of the Services provided. We will act as an intermediary for the transmission of such orders and will do so according to the instructions provided by the Merchant, on a non-discretionary basis.
The Company may execute orders on behalf of the Merchant, including buying, selling, or exchange of crypto assets. Execution will occur based on available market conditions and the nature of the Services provided, ensuring fair and consistent treatment of Merchants. The Company shall take reasonable steps to obtain the best possible result for the Merchant, taking into account factors including price, costs, speed, likelihood of execution and settlement, size, nature of the transaction, and the prevailing market conditions. Where the Services are provided in the context of payment processing, execution is performed on a non-discretionary basis, based solely on the payment instructions, generated through the Merchant’s integration, for the purpose of facilitating payment processing and settlement.
The Company provides a service to exchange crypto assets for fiat currency. Exchange rates are based on reference market prices derived from publicly available data sources, including blockchain-based markets and venues, at the time of execution. The Company reserves the right to apply margin or adjust rates depending on liquidity, market conditions, and regulatory requirements.
The Merchant Portal allows Merchants to exchange one crypto asset for another (crypto-to-crypto exchange). Exchange rates are based on reference market prices derived from publicly available data sources, including blockchain-based markets and venues, at the time of execution.
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. Crypto assets held in custody by the Company are segregated from the Company’s own assets and are not used, lent, or otherwise encumbered unless explicitly agreed. The Company undertakes reasonable technical and organizational measures to secure the custody of crypto assets; however absolute security cannot be guaranteed. The Merchant acknowledges the risks associated with the custody and safekeeping of digital assets.
The Company provides transfer services for crypto assets on behalf of the Merchant, including the processing and execution of crypto asset transfers to and from blockchain addresses designated by the Merchant. Such transfers are executed on a non-discretionary basis, based on the payment instructions generated through the Merchant’s integration and subject to the Company’s compliance, security, and risk management controls.
The Terms shall commence once the Merchant has been notified that its account
has been activated. Activation shall occur only after the Merchant has completed the
registration process and the Company has completed its due diligence procedures,
including compliance with all applicable AML, CTF, and KYC requirements under
applicable laws and regulations. The Merchant shall be notified of the account
activation via email or any other approved communication method. 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 purpose 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 duly authorized to act on behalf of the Merchant and to enter
into legally binding agreements on behalf of the Merchant under the laws applicable
in the Merchant’s jurisdiction of incorporation and/or operation; (b) 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; (c) 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.
The Company may charge fees for providing the Services, which may include but are not limited to:
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.
By using the Services, You acknowledge and agree to the following risks:
Furthermore, you acknowledge that crypto asset services provided by the Company
are not covered by any investor compensation scheme, including the Investor
Compensation Fund (ICF), nor by any deposit guarantee scheme under applicable
law.
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.
To the maximum extent permitted by applicable law, the Company's total aggregate
liability arising out of or in connection with the Services shall be limited to the amount
of fees paid by the Merchant to the Company for the specific Service giving rise to
the claim.
The Company will not be liable for any indirect, incidental, special, or consequential,
or punitive damages, including but not limited to loss of profits, loss of revenue, loss
of business opportunity, loss of data, or loss of crypto assets, arising out of or in
connection with the use of the Merchant Portal or the Services, whether arising in
contract, tort, negligence, or otherwise.
The Company shall not be responsible for any loss, damage, delay, or failure arising
from events beyond its reasonable control, including but not limited to technical
failures, system outages, cyber incidents, force majeure events, interruptions of
third-party services, or actions or omissions of third parties.
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 payment interface and portal.
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:
Upon Termination any or all the following may apply:
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 the
Merchant becomes subject to any bankruptcy, liquidation, dissolution, winding-up or
similar proceedings, including where any application is filed, order issued, resolution
adopted, or measure taken in connection with such proceedings or where the
outcome may result in the closure or winding down of the Merchant.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 interface.
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 where the Merchant is a legal entity that
has a sole director, sole shareholder, or sole ultimate beneficial owner, and such
individual dies, becomes legally incapacitated, or is otherwise unable to continue the
operation of the Merchant, where the Company reasonably determines that the
continuation of the business relationship is no longer operationally, legally, or
commercially feasible.
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.
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.
These Terms are governed by and construed in accordance with the laws of the Republic of Cyprus. Any dispute arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of the Republic of Cyprus.
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.
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.
The Company maintains and operates effective organisational and administrative
arrangements to identify, prevent, manage, and disclose conflicts of interest that may
arise in connection with the provision of crypto-asset services.
The Company may engage with third-party service providers, execution venues,
liquidity providers, custody providers, or affiliated entities in connection with the
Services. Where conflicts of interest arise, the Company shall take reasonable steps
to ensure fair treatment of Merchants and compliance with applicable regulatory
obligations.
Further information regarding the Company’s conflicts of interest arrangements is
available upon request.
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:
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:
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.
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