Cifra X Platform User Agreement

Last updated: 4 December 2025

This Cifra X Platform User Agreement (the “Agreement” or these “terms and conditions”) is entered into between:

• IDY BILGISAYAR BILISIM SISTEMLERI LIMITED COMPANY, a corporation incorporated under the laws of Turkey, with its head office located at Ataturk Neighborhood, Ertugrul Gazi Street, Metropol Istanbul Kozyatagi, Tax Office 470, Tax Number 150 7911 (hereinafter referred to as “IDY BILGISAYAR BILISIM SISTEMLERI LIMITED COMPANY”), together with its affiliates and other operators of the Cifra X ecosystem (collectively, the “Platform”, “we”, “us” or “our”); and
• each person or entity that accesses or uses the Platform or any Services (as defined below) (“User”, “you”).

For convenience, you and us are collectively referred to as the “Parties” and individually as a “Party”.

By clicking “I Agree” (or similar), creating an Account (as defined below), obtaining your Account credentials, logging into your Account or using any Services, you acknowledge that you have read, understood and agreed to be fully bound by this Agreement (including all Appendices and policies referenced herein), as amended from time to time.

If you do not agree with this Agreement, do not access or use the Platform or any Services.

1. Cifra X Platform

The Cifra X Platform (the “Platform”) is an ecosystem of websites, mobile applications, desktop clients, APIs and other software or interfaces that we operate to provide services relating to Digital Assets (as defined below) (collectively, the “Services”).

The Platform may include, without limitation:

• web interfaces under domains operated by us;
• mobile applications (iOS, Android or otherwise);
• desktop or web clients;
• APIs, SDKs and other programmatic interfaces; and
• independent, white-labelled or co-branded sub-platforms, websites or clients within the Cifra X ecosystem.

Where any particular service, application or product has separate terms of use or service agreements, such terms shall apply in addition to this Agreement. In the event of any inconsistency between those specific terms and this Agreement, the specific terms for the relevant service shall prevail to the extent of the inconsistency.

For the purposes of this Agreement:

• “Platform Operators” means all entities and persons that operate, manage or provide the Platform and/or any Services, including legal entities, unincorporated organisations and teams responsible for such operations. Unless the context requires otherwise, references to “the Platform”, “we”, “us” or “our” include the Platform Operators.

The composition of the Platform Operators may change over time as business operations, corporate structure or licensing arrangements are adjusted. Any such change will not affect your rights and obligations under this Agreement. If new Platform Operators are added due to new Services, your continued use of the Services constitutes your agreement that such new operators are also parties to and beneficiaries of this Agreement.

You understand and agree that:

• the Platform is a technology service and marketplace that enables you to access Services relating to Digital Assets;
• the Platform is not your advisor, broker, agent or fiduciary;
• you must independently evaluate the authenticity, legality, suitability and risks of any Digital Assets, transactions, information or services accessed via the Platform; and
• you bear the sole responsibility and any losses resulting from your decisions and use of the Services.

Any opinions, reference data, market analysis, discussion, prices, news, research, charts, statistics or other information displayed on the Platform is for informational purposes only and does not constitute investment, trading, financial, legal or tax advice. We shall not be liable for any loss arising directly or indirectly from your reliance on such information, including, without limitation, lost profits.

Unless you have a valid, active Account (as defined below) on the Platform, you may not use any Services that are restricted to registered Users.

1.1 Risks

By accessing or using any Services, you acknowledge and accept all risks associated with Digital Assets and the Services, including, without limitation, that:

1. Digital Assets available on the Platform may not be issued, backed or guaranteed by us, any financial institution or any government.
2. The market for Digital Assets is new, evolving, uncertain and may not grow, and may be highly speculative.
3. Digital Assets and related derivatives are high-risk products, and prices can be extremely volatile.
4. Digital Assets may experience significant price fluctuations in short periods of time, and markets may trade 24/7 without price limits.
5. Trading or holding Digital Assets may result in partial or total loss of your capital.
6. The value, liquidity or availability of Digital Assets may be materially affected by actions or events involving third parties, such as market makers, developers, validators, exchanges, regulators or governments.
7. Digital Asset trading, margin trading, leveraged trading, futures, options, staking, earn products, copy trading, trading bots and other advanced Services are not suitable for the vast majority of people.
8. Although we use reasonable efforts to comply with applicable laws, we may not be regulated in every jurisdiction in which Services are accessible, and the legal treatment of Digital Assets varies across jurisdictions.
9. There may be additional, unforeseeable, derivative or systemic risks beyond those expressly mentioned.

You should carefully consider your own financial situation, risk tolerance and investment objectives before using any Services. Where appropriate, you should seek independent legal, financial, tax and accounting advice.

1.2 Restricted Jurisdictions

The availability of the Platform and Services may be restricted or prohibited in certain jurisdictions due to legal, regulatory or policy reasons.

USERS FROM THE FOLLOWING JURISDICTIONS ARE PROHIBITED FROM USING ALL SERVICES ON THE PLATFORM:

• the United States of America,
• Cuba,
• Syria,
• Iran,
• Bangladesh,
• Myanmar,
• North Korea.

Certain products and Services (including, without limitation, derivatives, leveraged products, margin, staking, earn products, copy trading and trading bots) may be further restricted, suspended or unavailable in additional jurisdictions in accordance with our internal policies and local legal requirements, even if those jurisdictions are not listed above.

IMPORTANT:
The list of Restricted Jurisdictions may change at any time in line with our policies, legal requirements and the Services we offer in particular jurisdictions. We may update this list without prior notice.
You are solely responsible for checking the most recent information on the Platform and ensuring that your access and use of the Services comply with all applicable laws in your jurisdiction.

2. General Terms

This Agreement consists of:

• this main Cifra X Platform User Agreement;
• its Appendices (including but not limited to the service-specific agreements attached below);
• the Privacy Policy;
• any fiat or on-ramp/off-ramp rules, where applicable;
• our KYC and AML/CTF policies;
• any product-specific user agreements or terms of service; and
• any other guidelines, rules, statements, notices or instructions published on the Platform from time to time.

You must read this Agreement carefully before using the Platform or accessing any Services. If you do not understand any part of this Agreement, you should seek independent legal advice.

If you do not agree or do not understand this Agreement:

• log out of your Account immediately; and
• cease all use of the Platform and Services.

By clicking “I Agree” or similar acceptance button, creating an Account, obtaining Account credentials (including ID and password), logging into your Account or using any Services, you are deemed to have read, understood and accepted this Agreement in full, including any modifications made from time to time.

You are solely responsible for complying with all laws, rules and regulations applicable to you in connection with your use of the Services, including tax obligations, reporting and foreign exchange rules.

By using the Services, you confirm that:

• all funds and Digital Assets used or transferred via the Platform originate from legitimate sources; and
• you will not use the Services for any illegal activities.

You agree that we have the right to collect, verify and provide information to competent authorities to confirm the legality of your funds and your use of the Services.

All headings in this Agreement are for convenience only and do not affect the interpretation of any provision.

All information and content on the Platform and this Agreement are provided on an “as is” and “as available” basis, with no additional warranties beyond those expressly set out herein.

3. Definitions

Unless the context otherwise requires, the following terms shall have the meanings set out below:

• “Account” means your user account registered on the Platform in accordance with this Agreement.
• “Agreement” means this Cifra X Platform User Agreement, including its Appendices and other documents incorporated by reference.
• “Appendices” means the individual product and service agreements attached to and forming part of this Agreement.
• “AML/CTF” means anti-money-laundering and counter-terrorist-financing.
• “Business Days” means a day other than a Saturday, Sunday or a day gazetted as a public holiday when banks are open for the transaction of business.
• “Buy Price” has the meaning given in clause 7.1.
• “Compensation” has the meaning given in clause 15.1.
• “Dealing with your Accounts” has the meaning given in clause 4.4.
• “Digital Assets” means a digital representation of value that can be digitally transferred, stored and traded which is supported by the Platform.
• “Dispute” has the meaning given in clause 17.10.
• “Exchange Rate” has the meaning given in clause 7.1.
• “Fiat Trading” means peer-to-peer trading, depositing fiat currencies via supported channels, and buying or selling Digital Assets through liquidity providers or third-party platforms using fiat.
• “forks” has the meaning given in clause 6.2.
• “ICC International Court of Arbitration” means the International Court of Arbitration of the International Chamber of Commerce.
• “Identification Information” has the meaning given in clause 10.
• “Intellectual Property” has the meaning given in clause 11.
• “Internal Resolution” has the meaning given in clause 17.10.
• “Login Details” has the meaning given in clause 4.3.
• “miner fees” has the meaning given in clause 6.1.
• “Party” means each party to this Agreement (you and us); “Parties” means both of them.
• “Platform” means the Cifra X Platform.
• “Pre-Closing Period” has the meaning given in clause 4.4.
• “Registration Data” has the meaning given in clause 4.1.
• “Sanctioned Country” has the meaning given in clause 17.8.
• “Sanctioned Person” has the meaning given in clause 17.8.
• “Sell Price” has the meaning given in clause 7.1.
• “Services” means the products and services offered to Users through the Platform, as described in the Appendices.
• “Trading Fee” has the meaning given in clause 8.
• “Transaction” has the meaning given in clause 4.2.
• “Users” means users of the Cifra X Platform.
• “Website” means the website(s) or other gateways, such as mobile applications, where Users can access the Platform to use the Services.

4. Account

4.1 Account Creation

To be eligible to create an Account, you confirm that:

1. you are a natural person, a legal person or any other entity with the authority to enter into this Agreement and use the Services in compliance with all applicable laws, rules and regulations; and
2. you are not located in or otherwise a User from a Restricted Jurisdiction for the relevant Services.

You shall not create an Account:

• for the purposes of violating any applicable laws, rules and regulations; and/or
• to undermine, abuse or interfere with the Services provided on the Platform.

If you are not eligible to create an Account, we reserve the right to refuse your registration. If you have already created an Account, we shall have the right to suspend, terminate and/or close your Account without any advance notice to you and hold you accountable for any adverse consequences arising therefrom.

We reserve the right to reject any application to create an Account at our sole discretion, including, but not limited to Accounts relating to political and/or public figures or to comply with AML/CTF laws and regulations.

To create an Account, you shall provide, where necessary:

1. a valid email address;
2. a mobile phone number;
3. your real name;
4. identification documentation; and
5. any other information as required by us to create and maintain your Account,

together, the “Registration Data”.

If your mobile phone number requires real-name registration under applicable law, you shall complete such registration before providing the mobile phone number to us. You shall be responsible for and bear any losses and adverse consequences arising from the lack of such registration.

You are responsible for keeping the Registration Data accurate and up-to-date at all times. You shall be responsible for the authenticity, integrity and accuracy of the Registration Data and bear any direct or indirect loss and adverse consequences arising from any inaccuracies of your Registration Data.

After we verify and approve the creation of your Account, you may receive an Account identification number and/or password or other access credentials. You agree to receive emails and/or messages sent by us relating to the management and operation of the Platform.

4.2 Account Usage

You have the right to use your Account to access the Platform and use the Services, including:

1. browsing real-time quotes and transaction information of Digital Assets on the Platform;
2. submitting Digital Asset Transactions, whether to trade or otherwise (each, a “Transaction”);
3. completing Transactions;
4. viewing information and records provided to Users with your Account;
5. participating in activities or promotions organised by us in accordance with the relevant rules of such activities; and/or
6. using other Services that we may offer to you from time to time.

4.3 Account Security

You are solely responsible for the security of the Login Details associated with your Account, including your username, password, mobile number, transaction passwords and verification codes received through your mobile phone or other devices (“Login Details”).

If your Login Details are compromised and/or your Account has been accessed by an unauthorised third party, you shall inform us immediately to request a suspension or restriction of your Account. After receiving such request, we shall act on your request within a reasonable period. However, we shall not be liable for any consequences before the suspension or restriction of your Account becomes effective.

Unless with our prior consent, you shall not assign, transfer, lend, lease or otherwise permit any other person to use your Account, whether through donation, loan, lease, transfer or otherwise.

We are under no obligation to issue any replacement Digital Assets in the event that any Digital Assets, passwords or private keys are lost, stolen, malfunctioning, destroyed or otherwise inaccessible.

4.4 Suspension, Termination or Closure

We reserve the right to suspend certain or all Services to your Account, freeze the Digital Assets in your Account, terminate your Account, close your Account and/or notify the relevant authorities (“Dealing with your Accounts”) if:

1. we reasonably believe that we need to do so in order to protect our reputation, other Users or the integrity of the Platform;
2. use of your Account is subject to any pending litigation, investigation or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Account activity;
3. you are from, or become associated with, a Restricted Jurisdiction as stated in clause 1.2;
4. you are not eligible to create or maintain an Account in accordance with clause 4.1;
5. you create an Account on behalf of a legal entity but are not an authorised person to act on behalf of such legal entity;
6. we decide, in our sole discretion, that you are not suitable to use the Services;
7. you are not the person or entity as stated in the Registration Data associated with your Account;
8. you do not log into your Account for an uninterrupted period of one (1) year;
9. you use your Account to engage in illegal or illegitimate activities, such as money laundering and bribery;
10. you use your Account to engage in market manipulative activities, improper transactions or other illicit trading activities such as money laundering, smuggling or commercial bribery; and/or
11. you are in breach of this Agreement or any other applicable laws, rules and regulations.

Notwithstanding the above, we reserve the right to close and terminate your Account by providing you with seven (7) Business Days’ notice. Thereafter, you shall have seven (7) Business Days to take any necessary actions, including cancelling any orders or closing your positions (“Pre-Closing Period”). After the end of the Pre-Closing Period, we shall have the right to cancel your orders, close your positions and return the Digital Assets in your Account to you, subject to applicable law and set-off.

If your Account has been closed in accordance with this clause, all remaining account balances (which include charges and liabilities owed to us) will be immediately due and payable to us.

We shall not be liable for any adverse consequences and/or losses associated with Dealing with your Accounts.

We maintain full custody of the Digital Assets, funds and User information/data which may be turned over to governmental authorities in the event of an Account’s suspension or closure arising from fraud investigations, investigations of violation of law or violation of this Agreement.

5. Deposits, Custody, Withdrawals and Transfers

The Services are available only in connection with the Digital Assets that we support, which may change from time to time. Under no circumstances should you use your Account to store, send, request or receive Digital Assets in any form that we do not support. We assume no responsibility or liability in connection with any attempt to use your Account for Digital Assets that we do not support.

We provide the Services to you and, unless expressly stated, we are not a party to Transactions of Digital Assets as a buyer or seller.

The Services do not include any deposit, withdrawal or custody of any fiat currencies, unless explicitly stated in separate fiat-related documentation.

Unless otherwise stated on the Platform or in this Agreement, all Digital Assets held in your Account are held by us on a custodial basis. This means that:

1. title to the Digital Assets shall remain with you and not transfer to us. As the owner of the Digital Assets in your Account, you shall bear all risk of loss of such Digital Assets. We do not represent or treat assets in Accounts as belonging to us;
2. except as required by relevant authorities or otherwise stated in this Agreement, we will not sell, transfer, loan, hypothecate or otherwise alienate the assets in your Account unless instructed by you or compelled by a court of competent jurisdiction to do so;
3. you control the Digital Assets in your Account. At any time, subject to outages, downtime, security reviews and other applicable policies, you may withdraw your Digital Assets by sending them to a different blockchain address or account controlled by you or a third party; and
4. in order to hold the assets in your Account more securely, your Digital Assets may be held in omnibus wallets with our own Digital Assets or funds but are segregated in our internal ledgers by separate accounting entries for User and Platform Accounts. Notwithstanding the foregoing, we shall not have any obligation to use different blockchain addresses to store Digital Assets owned by you and by other customers or by us.

We reserve the right to set and adjust limits on daily trading volume, deposits, withdrawals and transfers based on our internal security considerations, risk management, the state of the relevant Digital Asset networks, and any legal or regulatory requirements.

6. Digital Asset Networks

6.1 Digital Asset Transactions

We will process Transactions in accordance with the instructions we receive from you. You should verify all transaction information prior to submitting instructions to us, including addresses, amounts, networks, tags/memos and applicable fees.

We do not guarantee the identity of any User, receiver, requestee or other third party and will have no liability or responsibility for ensuring that the information you provide is accurate and complete.

Once a Transaction has been submitted to the relevant Digital Asset network, it may be irreversible. Transactions cannot be reversed once they have been broadcast to the relevant Digital Asset network and confirmed.

We may charge network fees (“miner fees”) to process a Transaction on your behalf. We will calculate the miner fees at our discretion, although we will always notify you of the miner fees at (or before) the time you authorise the Digital Asset Transaction.

When you or a third party sends Digital Assets to an Account from an external wallet not hosted on the Platform, the person initiating the transaction is solely responsible for executing the transaction properly, which may include, among other things, payment of miner fees in order for the transaction to be completed successfully. Non-payment or underpayment of miner fees may cause your Transaction to remain in a pending state outside of our control and we are not responsible for delays or loss incurred as a result of an error in the initiation of the transaction and have no obligation to assist in the remediation of such Transactions.

Once submitted to a Digital Asset network, a Transaction will be unconfirmed for a period of time pending sufficient confirmation of the Transaction by the Digital Asset network. A Transaction is not complete while it is in a pending state. Digital Assets associated with Transactions that are in a pending state will be designated accordingly and will not be included in your available Account balance or be available to conduct Transactions until confirmed by the network.

We may refuse to process or may cancel any pending Transaction as required by law, regulation or any court or other authority to which we are subject in any jurisdiction, for instance, if there is suspicion of money laundering, terrorist financing, fraud, or any other financial crime.

6.2 Operation of Digital Asset Protocols

We do not own or control the underlying software protocols which govern the operation of Digital Assets supported on the Platform. Generally, these underlying protocols are open source and anyone can use, copy, modify and distribute them.

We assume no responsibility for the operation of the underlying protocols and we are not able to guarantee the functionality or security of network operations. You acknowledge and accept the risk that underlying software protocols relating to any Digital Asset you store in your Account may change.

In particular, the underlying protocols are likely to be subject to sudden changes in operating rules (“forks”). Any such material operating changes may materially affect the availability, value, functionality and/or the name of the Digital Asset you store in your Account. We do not control the timing and features of these material operating changes. It is your responsibility to make yourself aware of upcoming operating changes and you must carefully consider publicly available information and information that may be provided by us in determining whether to continue to transact in the affected Digital Asset using your Account.

In the event of any such operational change, we reserve the right to take such steps as may be necessary to protect the security and safety of assets held on the Platform, including temporarily suspending operations for the involved Digital Asset(s) and other necessary steps.

We will use our best efforts to provide you notice of our response to any material operating change. However, such changes are outside of our control and may occur without notice to us. Our response to any material operating change is subject to our sole discretion and includes deciding not to support any new Digital Asset, fork or other actions.

You acknowledge and accept the risks of operating changes to Digital Asset protocols and agree that we are not responsible for such operating changes and not liable for any loss of value you may experience as a result of such changes in operating rules. You acknowledge and accept that we have sole discretion to determine our response to any operating change and that we have no responsibility to assist you with unsupported assets or protocols.

7. Trading Rules

You shall comply with the following rules when trading Digital Assets on the Platform:

1. You shall read, understand and accept in full the information on the Platform before executing your trade, including, but not limited to price, fees and whether the Digital Asset is to be bought or sold, and whether leverage, margin or derivatives are involved.
2. When you execute your trade and submit your Transaction, you authorise the Platform to act as a broker or matching agent to match you with the relevant counterparty for your trade without further notice to you.
3. You may have the right to revoke or modify your Transaction at any time before the trade is executed, subject to Platform rules.
4. You can check the details and records of your trades on the Platform.

We may set limits on order sizes, positions, leverage or other trading parameters in our sole discretion.

7.1 Exchange Rates

Each purchase or sale of Digital Assets is also subject to the Exchange Rate for the given Transaction. The “Exchange Rate” means the price of a given supported Digital Asset in fiat currency or another reference asset as quoted on the Platform. The Exchange Rate is stated either as a “Buy Price” or as a “Sell Price”, which is the price at which you may buy or sell Digital Assets, respectively.

You acknowledge that the Buy Price Exchange Rate may not be the same as the Sell Price Exchange Rate at any given time, and that there may be a margin or spread to the quoted Exchange Rate.

You agree to accept the Exchange Rate when you authorise a Transaction. We do not guarantee the availability of any particular Exchange Rate. We do not guarantee that you will be able to buy and/or sell your Digital Assets on the open market at any particular price or time.

8. Fees

You agree to be responsible for the payment of, and pay, all fees. Each purchase or sale of Digital Assets is subject to a fee (“Trading Fee”), and other Services may be subject to additional Fees as described in the relevant Appendices.

The applicable Trading Fee or other Fees will be displayed to you on the Platform prior to each trade or transaction and may be stated in each receipt we issue to you. We may adjust our Fees at any time.

You authorise us to deduct any Fees owed by you from your balances on the Platform without further notice.

9. Compliance

Our KYC and AML/CTF policies are intended to comply with international laws and standards with regards to KYC and AML/CTF, including the laws of your local jurisdiction. We shall comply with our KYC and AML/CTF policies and use best efforts to adopt measures and technology to provide you the Services in a safe and secure manner to prevent any losses due to money laundering or other financial crime.

You authorise us to make enquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such enquiries. When we carry out these enquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our enquiries in full. This is an identity and risk check only and should have no adverse effect on your core credit rating.

Additionally, we may require you to wait some amount of time after completion of a Transaction before permitting you to use further Services and/or before permitting you to engage in Transactions beyond certain volume limits.

If we are informed that any Digital Assets or funds received by your Account are stolen or otherwise are not lawfully possessed by you, we may, but have no obligation to, place an administrative hold on the affected funds and your Account. If we enact an administrative hold on some or all of your Digital Assets or funds or Account, we may continue such hold until such time as the dispute has been resolved and evidence of the resolution acceptable to us has been provided in a form acceptable to us. We will not involve ourselves in any such dispute or the resolution of the dispute.

You agree that we will have no liability or responsibility for any such hold, or for your inability to withdraw Digital Assets or funds or execute trades during the period of any such hold.

10. KYC and AML/CTF

In relation to KYC and AML/CTF, we:

1. shall promulgate and update our KYC and AML/CTF policies to meet the standards set by applicable laws, rules and regulations;
2. shall promulgate and update the guidelines and rules relating to the operation of the Platform and our staff shall facilitate the provision of the Services to you in accordance with such guidelines and rules;
3. shall design and execute procedures for transaction monitoring and control, which include, but are not limited to, rigorous identity authentication procedures, and maintain a dedicated team to address AML/CTF;
4. adopt a risk-based approach to due diligence and supervision of our Users;
5. have the right to review and inspect transactions to, from and on our Platform;
6. shall have the right to report Transactions that we deem in our sole discretion to be suspicious to the relevant authorities; and
7. shall maintain the Registration Data and Identification Information for at least the minimum period required by applicable law.

10.1 Identification Information

Where you are an individual, we may collect certain information from you, including, but not limited to, your:

1. name;
2. address (and permanent address if it differs from your current address);
3. valid email address;
4. date of birth;
5. nationality;
6. photograph or video of you with your identification documents;
7. official identification documents, including passports, identity cards (both front and back) and other identification documents issued by the relevant authorities; and
8. other information that we may request from you from time to time,

the “Personal Identification Information”.

Where you are a legal entity other than an individual, we may collect certain information from you, including, but not limited to, your:

1. registration and incorporation documents;
2. articles of association, memorandum or other constitutional documents;
3. ownership structure and description of such ownership structure;
4. board resolution designating your authorised person responsible for the Account;
5. identification documents of the directors, major shareholders and the authorised person(s) (generally, shareholders holding 10% or more of the relevant entity’s voting power are required to be identified);
6. your address; and
7. other information that we may request from you from time to time,

the “Corporate Identification Information” and together with the Personal Identification Information, the “Identification Information”.

Identification Information that we request from you may vary according to your jurisdiction and we also may require you to notarise copies of documents you provide to us. We shall have the right to request the notarised translation of your Identification Information to English if your Identification Information is not provided in either English or another language we accept.

10.2 Transaction Reporting

We shall monitor the activity of your Account for suspicious transactions. If we determine a suspicious transaction relating to your Account, we may suspend, halt or terminate the transaction, reverse the transaction and/or report the transaction to the relevant authorities, without notice to you. Any action we take in response to a suspicious transaction shall not result in a breach of this Agreement.

11. Intellectual Property Rights

All intellectual property relating to the Platform, including, but not limited to, the Website name, goodwill, trademarks, logos, domain names, databases, Website design, text and graphics, software, photos, videos, music, sounds and any combination of the aforementioned files, and the intellectual property rights of software compilation, associated source code and software (including small applications and scripts) (“Intellectual Property”) shall be owned by us or our licensors.

You shall not copy, modify, transmit, distribute, sell, license, reverse engineer or use any of the Intellectual Property for commercial purposes or in a manner not expressly permitted by this Agreement.

Your use of the Services does not grant you any rights over the Intellectual Property except for the limited licence to access and use the Platform and Services for their intended purposes in accordance with this Agreement.

Upon acceptance of this Agreement, it shall be deemed that you have granted to us a worldwide, non-exclusive, royalty-free, transferable and sublicensable licence to use, reproduce, modify, publish, translate, distribute, perform and display any content, feedback or information that you upload or submit on the Platform, to the extent permitted by law and necessary for the operation of the Platform and provision of Services.

You shall not illegally use or dispose of our or any other person’s Intellectual Property when you use the Services. You may not publish or authorise other websites or media to use the Intellectual Property in any manner whatsoever without our prior written consent.

12. Rights and Obligations

Notwithstanding anything in this Agreement, we reserve the right, in our sole discretion:

1. where there are errors or updates, to amend information displayed on the Platform;
2. to modify, suspend or terminate any or all of the Services offered at any time without prior notice to you, to the extent permitted by law. In the event of such termination, it will take effect on the date of the announcement of the termination on the Platform;
3. to suspend or permanently terminate your access to your Account, the Platform or your use of any or all the Services in accordance with this Agreement;
4. if we suspect or determine that the information you provide to us is wrong, untrue, invalid and/or incomplete, to notify you to correct or update such information and, if you do not correct or update the relevant information, suspend or terminate the provision of Services to you;
5. to delete any content or information on the Platform which does not comply with applicable laws, rules and regulations without prior notice to you;
6. in accordance with applicable laws, rules and regulations, to request information from you, and you shall have an obligation to assist us with such requests; and
7. in the interests of Users, under special circumstances which hinder the provision of Services on the Platform, such as system failure, network failure or extreme market conditions, to amend the Services provided. You shall be informed of such amendments through announcements on the Platform.

Unless otherwise stated in this Agreement, we shall:

1. use necessary technical means and management measures to ensure the normal operation of the Platform and provide a necessary and reliable environment for your use of the Services;
2. maintain the provision of Services to you in accordance with this Agreement and applicable laws;
3. use reasonable security measures to protect your Digital Assets held on the Platform; and
4. provide you with reasonable notice regarding material security risks relating to your Account where feasible.

13. Representations and Warranties

By agreeing to this Agreement and each time you use the Services, you represent, warrant and undertake that:

1. you have not been previously suspended or removed from using the Services or similar services for violations of law or contractual terms;
2. you are of statutory age, have full capacity and are authorised to enter into this Agreement and use the Services as required by all applicable laws, rules and regulations;
3. your use of the Services and your Account activity are in compliance with all applicable laws, rules and regulations;
4. all your Digital Assets used on the Platform are legally acquired and owned by you and are free from any lien or encumbrance except as disclosed;
5. you are solely liable for the actions taken using your Account, whether or not authorised by you, unless due to our gross negligence or wilful misconduct;
6. you are responsible for all profits, losses or liabilities arising from your Transactions and use of your Account;
7. all the information you provide to us is true, accurate, complete and not misleading;
8. you shall make the relevant reports to authorities for taxation purposes and pay all applicable taxes;
9. you shall refrain from engaging in any illegal activity through your use of the Services;
10. you shall always refrain from engaging in or participating in any act or activity that damages the interests or reputation of the Platform, whether or not in connection with the Services;
11. you shall not act in a way that is contrary to the intended use of the Platform, such as facilitating the illegal transfer of information, spreading false information about the Platform, infringing on our rights or the rights of other Users, inviting to pyramid schemes or falsifying and relaying false information to us or other Users;
12. you shall not maliciously interfere with the normal operations of the Platform or other Users’ use of the Services, whether through technical means or otherwise;
13. you shall not state or spread false or defamatory information about us;
14. in the event of a dispute between you and other User(s), you shall only resort to judicial, arbitral or other government-related means to request information from us;
15. you are liable for all fees and taxes relating to any hardware, software and other third-party services incurred by you in your use of the Services; and
16. you shall comply with this Agreement and other guidelines, rules and policies that we release in relation to this Platform.

14. Liability and Indemnification

You understand and agree that, to the maximum extent permitted by applicable law, we shall not be held liable, and you shall be solely accountable, for any of the following:

1. loss of income;
2. loss of transaction profits;
3. contractual losses or opportunity costs;
4. disruption of business;
5. currency-related or exchange-rate losses;
6. loss or damage of information or data;
7. loss of opportunities;
8. loss arising from the price or value of Digital Assets;
9. costs of purchasing products and services outside the scope of the Services;
10. any failures in software, hardware, internet connection and any distortion or delays arising therefrom;
11. any indirect, special, exemplary, punitive or incidental loss or damages arising from any cause, including negligence and breach of contract, regardless of whether such loss or damage may reasonably be foreseen by us or whether we are notified in advance of the possibility of such loss or damages;
12. any malicious programs such as viruses or trojans that you may encounter from your use of the Services (except where directly caused by the Platform’s intentional misconduct);
13. information, products or business of third-party websites which link to/from the Platform;
14. loss arising from any information or technology on the Platform in relation to its validity, accuracy, correctness, reliability, quality, stability, integrity, timeliness, applicability (including for a specific purpose), freedom from error or omission and consistency;
15. errors in our calculations of Transactions on the Platform, except where resulting from our gross negligence or wilful misconduct;
16. damages:

• (a) to your goodwill or reputation;
• (b) to you when we are reasonably justified to believe that your Transactions and/or conduct on the Platform may involve any illegal activity or breach of this Agreement;
• (c) arising from any expenses or losses relating to the purchase or acquisition of data, information or Digital Assets through the Services;
• (d) arising from your misunderstanding or misinterpretation of the Services; and/or
• (e) arising from any other loss relating to the Services which cannot be reasonably attributed to us.

14.1 Limitation of Liability

Notwithstanding anything in this Agreement, and to the maximum extent permitted by applicable law, our total aggregate liability to you for any and all claims arising out of or in connection with this Agreement or the Services shall not exceed the total amount of Fees that you have paid to us during the three (3) months immediately preceding the event giving rise to such liability.

We do not waive any of the rights not mentioned in this Agreement and, to the maximum extent permitted by applicable law, we limit and exclude our liability as described herein.

If you have a dispute with one or more Users of the Services (other than us), you agree that neither we nor our affiliates or service providers, nor any of our respective officers, directors, agents, joint venturers, employees and representatives, will be liable for any claims, demands and damages (actual and consequential, direct or indirect) of any kind or nature arising out of or in any way connected with such disputes.

14.2 Indemnification

You agree to indemnify, defend and hold harmless us, our affiliates and service providers, and each of our, or their, respective officers, directors, agents, employees and representatives, from and against any and all claims, demands, actions, proceedings, damages, losses, liabilities, costs and expenses (including reasonable attorneys’ fees and any fines, fees or penalties imposed by any regulatory authority) that have been reasonably incurred in connection with:

• your use of the Services;
• your breach of this Agreement;
• our enforcement of this Agreement; or
• your violation of any law, rule or regulation, or the rights of any third party.

14.3 Our Guarantees

The guarantees and undertakings specified in this Agreement shall be the only guarantees and statements that we make in connection with the Services provided by us under this Agreement and through the Platform and shall supersede any and all guarantees and undertakings arising in any other way or manner, whether in writing or orally, express or implied.

All such guarantees and undertakings represent only our own guarantees and undertakings and do not guarantee any third party’s compliance with the guarantees and undertakings contained in this Agreement.

15. Termination and Remedies for Breach

We shall have the right at any time to terminate all or part of the Services offered by us to you in accordance with this Agreement, and this Agreement shall terminate on the relevant date of termination of all Services, except for those clauses that survive termination.

You shall have the right to terminate your use of the Services provided by us at any time and this Agreement shall terminate on the relevant date of your termination of use of the Services, subject to all outstanding obligations, liabilities or fees.

Upon termination of this Agreement, you agree that you shall not have the right to require us to continue to provide the Services to you or perform any other obligation, including, but not limited to:

• requesting us to keep or disclose to you any information in your Account, or
• requesting us to disclose to you or any third party any information therein that is not read or sent.

You remain responsible for all obligations and liabilities incurred prior to termination.

15.1 Breach of Agreement

In the event you breach this Agreement or any applicable laws, rules or regulations, you shall pay to us a minimum of US$2,000,000 (two million United States dollars) in compensation and bear all expenses we incur in connection with such breach, including any legal fees (“Compensation”). In the event the Compensation is unable to cover our losses, you shall be liable for the additional amounts in excess of the Compensation.

For the avoidance of doubt, the termination of this Agreement shall not prevent the non-breaching Party from demanding that the breaching Party assume liabilities arising other than from this Agreement or under applicable law.

16. Notices and Communications

You undertake to regularly and promptly refer to the announcements, materials and information on the Platform. We will not be responsible or liable in any manner of compensation should you incur personal losses arising from your failure to refer to such announcements, materials and information.

Notices, announcements, statements and other communications we publish on the Platform (or send to your registered email address or via in-app messages) shall be deemed to have been delivered to you on the date of publication or sending.

17. Miscellaneous

17.1 Assignment

The rights and obligations agreed in this Agreement shall be equally binding on the assignees, heirs, executors and administrators of the Parties who benefit from such rights and obligations.

Without our prior written consent, you may not transfer, assign or otherwise dispose of any of your rights or obligations hereunder to any third party. We may, at any time, assign our rights and obligations under this Agreement to any third party, in whole or in part, by providing you with at least thirty (30) days’ notice via the Platform or email, to the extent permitted by law.

17.2 Force Majeure

Where we fail to provide the Services, or are delayed in providing the Services, due to circumstances not within our reasonable control, including but not limited to: information network equipment maintenance, information network connectivity failures, computer failures, communications or other system failures, power failures, weather conditions, natural disasters, unexpected accidents, industrial actions, labour disputes, revolts, uprisings, riots, lack of productivity or production materials, fires, floods, storms, explosions, wars, failure on the part of banks or other partners, collapse of the digital asset market, actions by governments, judicial or administrative authorities, or other acts that are not within our control or beyond our ability to control, or due to causes on the part of third parties, we shall not assume any responsibility for such failure or delay, or for the resultant loss you may sustain as a result of such failure or delay.

17.3 Relationship of Parties

This Agreement is only binding on the rights and obligations between you and us and does not involve legal relations and legal disputes arising from and relating to Transactions between the Users of the Platform, and between other parties and you.

Nothing in this Agreement shall be deemed to have created, implied or otherwise treated us as your agent, trustee or other representative, unless expressly provided otherwise in this Agreement.

17.4 Entire Agreement

This Agreement, together with the Appendices and any documents incorporated by reference, constitutes the entire agreement between you and us with respect to the subject matter hereof and supersedes all prior or contemporaneous understandings, agreements, negotiations, representations or communications, whether written or oral.

If any provision of this Agreement is found unenforceable, invalid or illegal by any court of competent jurisdiction, the validity of the remaining provisions of this Agreement shall not be affected, and such provisions shall be enforced to the maximum extent permitted by law.

17.5 Amendment

We reserve the right to determine, amend or modify any content of this Agreement at any time at our sole discretion, to the extent permitted by law.

The date and time displayed at the “Last updated” section of this Agreement shall refer to the timing of any changes to the provisions contained herein. The amended agreement will take effect immediately upon its publication on the Platform, unless otherwise stated.

Although we take reasonable measures to ensure the accuracy of the information on the Platform, we do not guarantee the level of accuracy or completeness and shall not bear any loss arising directly or indirectly from:

• the information on the Platform; or
• any delay or failure caused by failure to connect with the internet, or to transmit or receive any notice or information.

You shall be responsible for being updated with amendments to this Agreement. If you do not agree with the amendments, you must stop using the Services immediately. Any continued use of the Services shall be deemed as your agreement to the terms of the amended Agreement.

17.6 Survival

All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement will continue to be binding and operate after the termination or expiration of this Agreement, including but not limited to provisions relating to intellectual property, fees, taxes, disputes, limitation of liability, indemnification and governing law.

17.7 Data Protection

Your personal data will be properly protected and kept confidential in accordance with applicable data protection laws and our Privacy Policy. However, we have the right to collect, process, use or disclose your personal data in accordance with this Agreement or applicable laws.

Depending on the products or services concerned, your personal data may be disclosed to the following third parties:

1. your Transaction counterparties;
2. our shareholders, partners, investors, directors, officers, senior managers and employees;
3. our joint ventures, alliance partners and business partners;
4. our agents, contractors, suppliers, third-party service providers and professional advisers, including parties who provide administrative, financial, research, operations, IT and other services;
5. third-party business partners who provide goods and services or sponsor contests or other promotional activities, whether or not in cooperation with us;
6. insurance companies or insurance investigators and credit providers;
7. credit bureaus, debt collection agencies or dispute resolution centres in the event of disputes;
8. professional consultants such as auditors and lawyers;
9. relevant government regulatory agencies or law enforcement agencies to comply with laws or regulations;
10. assignees of our rights and obligations; and
11. any persons with your consent as determined by you or the applicable contract.

Regarding the collection, storage and use of your personal information, the Privacy Policy published on the Platform shall prevail.

17.8 Export Control and Sanctions

Your use of the Services is subject to international export controls and economic sanctions requirements. By sending, receiving, buying, selling, trading or storing Digital Assets through your use of the Services, you agree that you will comply with such requirements.

You are not permitted to acquire Digital Assets or use any of the Services if:

1. you are in, under the control of, or a national or resident of any country or region subject to a comprehensive embargo or sanctions by Turkey, the United Nations, the European Union, the United States or other relevant jurisdictions (each a “Sanctioned Country”);
2. you are a person on any applicable sanctions list, including but not limited to sanctions lists issued by the United Nations, the European Union, the U.S. Office of Foreign Assets Control (OFAC) or other competent authorities (a “Sanctioned Person”); or
3. you intend to supply any acquired or stored Digital Assets or Services to a Sanctioned Country (or a national or resident of a Sanctioned Country) or a Sanctioned Person.

17.9 No Waiver

Our or your waiver of the right to hold the other Party liable for breaches of this Agreement or any other liability as agreed upon in this Agreement shall not be construed or deemed as a waiver of the right to hold the other Party liable for any other or subsequent breaches of contract.

Any failure to exercise, or delay in exercising, any right or remedy under this Agreement shall not be construed as a waiver of such right or remedy.

17.10 Dispute Resolution

You acknowledge and agree that, before filing any dispute or claim against us, you will first contact us via email at [email protected], where we will attempt to resolve the relevant dispute internally as soon as reasonably possible (“Internal Resolution”). The Parties agree to negotiate and attempt to resolve any dispute in good faith (such negotiation shall be confidential and protected under applicable laws, rules and regulations and will not be used as evidence in any proceeding).

If any dispute, controversy, divergence or claim cannot be resolved through Internal Resolution, including any dispute in connection with the existence, validity, interpretation, performance, breach or termination of this Agreement or any dispute concerning or arising out of this Agreement (collectively referred to as the “Dispute”), the Parties agree that such Dispute shall be finally resolved by arbitration administered by the ICC International Court of Arbitration in accordance with the ICC Rules of Arbitration in effect at the time of the filing of the request for arbitration.

Unless otherwise agreed by the Parties:

• the seat (place) of arbitration shall be Istanbul, Turkey;
• the arbitration shall be conducted in English;
• the tribunal shall consist of a sole arbitrator appointed in accordance with the ICC Rules;
• the arbitrator shall have the exclusive power to rule on his/her own jurisdiction, including any objections with respect to the existence, scope or validity of the arbitration agreement or the arbitrability of any claim or counterclaim; and
• the arbitrator shall issue a written reasoned decision stating the findings, reasoning and conclusions.

The arbitration award shall be final and binding upon the Parties and may be enforced by any court of competent jurisdiction.

17.11 Unclaimed Property

If we hold Digital Assets on your behalf and we are unable to contact you and have no record of your use of the Services for several years, applicable law may require us to report the Digital Assets as unclaimed property to the relevant authorities in certain jurisdictions.

We will attempt to locate you at the address or contact details shown in our records. If we are unable to do so, we may be required to deliver any such Digital Assets to the authorities as unclaimed property. We reserve the right to deduct a dormancy fee or other administrative charges from such unclaimed Digital Assets, as permitted by applicable law.

17.12 Class Action Waiver

To the maximum extent permitted by applicable law, you agree that any claims relating to this Agreement or the Services (whether based in contract, tort, statute, fraud, misrepresentation or any other legal theory, and whether the claims arise during or after the termination of this Agreement) shall be brought against us on an individual basis only and not as a plaintiff or class member in any purported class, collective, representative or private attorney general action.

You further agree to waive any right for such claims to be brought, heard or arbitrated as a class, collective, representative or private attorney general action. Combining or consolidating individual arbitrations into a single arbitration is not permitted without the consent of all Parties, including us.

Appendix 1: Platform Services

Upon completion of registration and identity verification for your Account, you may access various Services on the Cifra X Platform, including but not limited to:

• spot trading of Digital Assets;
• margin and leveraged trading;
• derivatives trading, including futures and options, where available and permitted;
• copy trading and social trading features, where available;
• trading bots and algorithmic tools, including grid bots and similar tools;
• staking products and validation-related services;
• earn products and savings products (fixed-term and flexible);
• loan services, including crypto-backed loans and margin lending;
• liquidity pools, prime pools and similar yield or reward programmes; and
• other occasional programmes, campaigns and promotions that we may organise on the Platform.

Each category of Services may be governed by additional product-specific agreements and rules, including but not limited to:

• Appendix 2: Cifra X Futures Services Agreement;
• Appendix 3: Cifra X Options Services Agreement;
• Appendix 4: Cifra X Spot Trading Services Agreement;
• Appendix 5: Cifra X Finance Services Agreement (including Staking, Earn, Primepool and Crypto Loans).

Users agree that these Appendices, together with any guides, notices and rules listed and/or hyperlinked on the Platform, are legally binding documents. By using any of these Services, Users agree to be bound by the respective product agreements in addition to the main Platform User Agreement.

Appendix 2: Cifra X Futures Services Agreement

1. Cifra X Futures Trading Platform

The Cifra X Futures Trading Platform (hereinafter referred to as the “Futures Platform”, “we” or “us”) allows its users (hereinafter referred to as the “Users” or “you”) to trade in futures products (“Futures”) through your Futures Account (as defined below) (the “Services” under this Appendix).

This Cifra X Futures Services Agreement (the “Futures Agreement”) shall apply to all the Futures-related Services offered on the Futures Platform. For convenience, you and us are hereby collectively referred to as “both Parties” and individually as “each Party”.

All terms and references used in this Futures Agreement which are defined in the Cifra X Platform User Agreement (the “User Agreement”) but are not defined in this Futures Agreement shall have the same meaning and construction in this Futures Agreement.

This Futures Agreement is supplementary to the User Agreement and its terms shall be read together with the User Agreement, guides, Platform rules, announcements or any other information on the Platform that we may publish from time to time. In the event of any conflict between the terms of this Futures Agreement and the User Agreement, the User Agreement shall prevail.

2. General Terms

You shall read this Futures Agreement carefully before using the Futures Platform to access the Futures Services and seek independent legal advice if necessary. If you do not agree with or understand this Futures Agreement, please immediately cease to use the Futures Services.

By clicking on “I Agree”, “Confirm”, creating a Futures Account, accessing your Futures Account or using the Futures Services, you shall be deemed to have understood, agreed to be bound by and agreed in full with this Futures Agreement, including any modifications made from time to time.

All headings herein are exclusively for convenience and are not intended to expand or limit the content or scope of the terms and conditions of this Futures Agreement. All information on the Futures Platform and this Futures Agreement are provided on an “as is” and “as available” basis, with no further promises made by us.

3. Definitions (Futures)

In addition to the definitions in the User Agreement, the following terms shall have the meanings below for this Futures Agreement:

• “Futures Agreement” means this Cifra X Futures Services Agreement.
• “Airdrop Reward” has the meaning as described in clause 16 of this Appendix.
• “Cross-Leverage Account” has the meaning as described in Annex 1.
• “Dealing with your Futures Accounts” has the meaning as described in clause 4.4.
• “Early Settlement” has the meaning as described in clause 14.
• “Fees” has the meaning as described in clause 13.
• “Forced Liquidation” has the meaning as described in clause 10.
• “Forced Liquidation Line” has the meaning as described in Annex 1.
• “Futures” means the futures products that we offer for trading on the Futures Platform from time to time.
• “Futures Account” means your futures-specific account with the Platform.
• “Index” and “Index Data” have the meanings as described in clause 7.
• “Isolated-Leverage Account” has the meaning as described in Annex 2.
• “Liquidation Level” has the meaning as described in clause 10.
• “Loan” has the meaning as described in clause 9.
• “Margin” has the meaning as described in clause 8.
• “Margin Adjustment Coefficient” has the meaning as described in Annex 1.
• “Margin Ratio” has the meaning as described in clause 9.
• “Margin Requirements” has the meaning as described in clause 8.
• “Margin Service” has the meaning as described in clause 8.
• “Market Misconduct” has the meaning as described in clause 17.
• “Order” has the meaning as described in clause 6.
• “Order Limits” and “Order Limit Prevention” have the meanings as described in clause 6.
• “Payment Policies” has the meaning as described in Annex 3.
• “Rate Policy” has the meaning as described in Annex 3.
• “Settlement” and “Settlement Price” have the meanings as described in clause 14.
• “Warning Line” and “Warning Message” have the meanings as described in Annex 1.

4. Futures Account

4.1 Futures Account Creation

To be eligible to create a Futures Account, you confirm that you are a natural person, a legal person or any other entity with the authority to enter into this Futures Agreement and use the Futures Services in compliance with all applicable laws, rules and regulations. You shall not create a Futures Account for the purposes of violating any applicable laws, rules and regulations and/or undermining the Futures Services provided on the Platform.

Should you not be eligible to create a Futures Account, we reserve the right to refuse your registration for a Futures Account. If you have already created a Futures Account, we shall have the right to suspend, terminate and/or close your Futures Account without any advance notice to you and hold you accountable for any adverse consequences arising therefrom. We reserve the right to reject any applications to create a Futures Account at our sole discretion, including, but not limited to Futures Accounts relating to political and/or public figures or to comply with AML/CTF laws and regulations.

To create a Futures Account, you shall provide the information necessary to fulfil the Platform’s KYC procedure, which may include:

1. a valid email address;
2. a mobile phone number;
3. your real name;
4. identification documentation; and
5. any other information as required by us to create and maintain your Futures Account,

together, the “Registration Data” for Futures.

All provisions in clause 4.1 of the User Agreement regarding Registration Data apply equally to the Futures Account.

4.2 Futures Account Usage

You have the right to use your Futures Account to access the Futures Platform and use the Futures Services, including:

1. browsing real-time quotes and transaction information of Digital Assets and Futures on the Platform;
2. submitting instructions for Transactions involving Futures;
3. completing Futures Transactions;
4. viewing the information, positions and history associated with your Futures Account;
5. participating in Futures-related promotions or activities organised by us; and/or
6. other Futures Services that we may offer to you from time to time.

4.3 Futures Account Security

Unless with our consent, you shall not assign or allow any third party to use your Futures Account, whether through donation, loan, lease, transfer or otherwise.

We are under no obligation to issue any replacement Digital Assets in the event that any Digital Assets, passwords, keys or other credentials used in connection with your Futures Account are lost, stolen, malfunctioning, destroyed or otherwise inaccessible, except as expressly stated in this Agreement.

4.4 Suspension, Termination or Closure

We reserve the right to suspend certain or all Futures Services to your Futures Account, freeze the Digital Assets in your Futures Account, terminate your Futures Account, close your Futures Account and/or notify the relevant authorities (“Dealing with your Futures Accounts”) if:

1. we reasonably believe that we need to do so in order to protect our reputation or the stability of the Futures markets;
2. use of your Futures Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Futures Account activity;
3. you are not eligible to create a Futures Account in accordance with clause 4.1;
4. you create a Futures Account on behalf of a legal entity and you are not an authorised person to act on behalf of such legal entity;
5. we decide, in our sole discretion, that you are not suitable to use the Futures Services;
6. you are not the person as stated in the Registration Data associated with your Futures Account;
7. you do not log into your Futures Account for an uninterrupted period of one (1) year;
8. you use your Futures Account to engage in illegal or illegitimate activities, such as money laundering and bribery;
9. you use your Futures Account to engage in market manipulative activities, improper transactions or other illicit trading activities such as money laundering, smuggling and commercial bribery; and/or
10. you are in breach of this Futures Agreement, the User Agreement or any other applicable laws, rules and regulations.

Notwithstanding the above, we reserve the right to close and terminate your Futures Account by providing you with seven (7) Business Days’ notice. Thereafter, you shall have seven (7) Business Days to take any necessary actions, including cancelling any orders or closing your positions (“Pre-Closing Period”). After the end of the Pre-Closing Period, we shall have the right to cancel your orders, close your positions and return the Digital Assets in your Futures Account to you, subject to applicable laws and set-off of liabilities.

If your Futures Account has been closed in accordance with this clause, all remaining balances (which include charges and liabilities owed to us) will be immediately due and payable to us.

We shall not be liable for any adverse consequences and/or losses associated with Dealing with your Futures Accounts.

We maintain full custody of the Digital Assets, funds and User information/data which may be turned over to governmental authorities in the event of a Futures Account’s suspension or closure arising from fraud investigations, investigations of violation of law or violation of this Futures Agreement or the User Agreement.

5. Deposits, Custody, Withdrawals and Transfers (Futures)

The Futures Services are available only in connection with the Digital Assets that we support for Futures trading, which may change from time to time. Under no circumstances should you use your Futures Account to store, send, request or receive Digital Assets in any form that we do not support for Futures trading. We assume no responsibility or liability in connection with any attempt to use your Futures Account for unsupported Digital Assets.

We provide the Futures Services to you and we are not a party to any Futures Transactions as a principal buyer or seller.

Unless otherwise stated on the Platform or in this Futures Agreement, all Digital Assets held in your Futures Account are held by us on a custodial basis, under the same principles described in clause 5 of the User Agreement.

We reserve the right to set and adjust limits on daily trading volume, margin, leverage and withdrawals in connection with your Futures Account based on our internal considerations, including investigations by relevant authorities, market conditions, risk levels and the state of the relevant Digital Asset networks.

6. Futures Trading

After successfully registering for a Futures Account, you can transfer Digital Assets to your Futures Account to place an order on the Futures Platform (“Order”). You may execute your Order through the order types available on the Platform and open or close positions on the Futures currently available.

Each User is responsible for any Order made on the Futures Platform, including ensuring that the Order is properly submitted via the relevant interface. Your Orders may be rejected by the Futures Platform from time to time and it is your responsibility to ensure that your Order has been executed. We shall not be liable for any loss suffered as a result of any Order not being submitted by you or for your Order being rejected by the Futures Platform. Orders are submitted at your own risk.

We are entitled to rely on, and you are bound by, all Orders submitted and Transactions executed through your Futures Account.

We shall have the sole discretion to amend, suspend or terminate any or all order types, Futures products and Digital Assets available for Futures trading on the Futures Platform at any time and we shall not be liable for any losses incurred by you in respect of such amendment, suspension or termination.

To prevent market manipulation and manage risk, we may place position and order size limits (“Order Limits”) on your Futures Account. We have the sole discretion to reduce or close your positions or cancel your Orders should you exceed your Order Limits (“Order Limit Prevention”). You shall be solely liable for any losses you may sustain through the Order Limit Prevention mechanism.

7. Index

For each Futures product or corresponding Digital Asset, the Futures Platform may use a reference index (“Index”) based on prices on certain other exchanges or markets (“Index Data”) to determine the index price or settlement price.

The Index Data is retrieved through APIs or other connections with the relevant exchanges. We shall have the sole discretion to adjust the constituents of the Index and their relevant weight without prior notice to you.

We shall not be liable for any loss in the event there are errors in retrieving the Index Data or where there are large deviations in the constituents of the Index which result in a large deviation between the Index price and the actual traded price of the Futures or Digital Asset on the Futures Platform.

8. Margin

The margin service (“Margin Service”) offered by the Futures Platform allows you to use the Digital Assets in your Futures Account (“Margin”) to borrow or leverage additional exposure to Digital Assets to execute Futures trades.

By using the Margin Service, you agree that you fully understand the risks associated with leveraged Futures trading and that you shall use the Margin Service at your own risk.

You shall deposit and maintain in your Futures Account Digital Assets in such form and amounts as required by us, at our sole and absolute discretion, to maintain the Margin Service (“Margin Requirements”). The list of Digital Assets we approve to be eligible to be used as Margin shall be prescribed by us, and certain Digital Assets may only be valued based on a Margin Adjustment Coefficient (as described in Annex 1 and Annex 2).

We shall have the sole discretion to vary the Margin Requirements and the Margin Adjustment Coefficients from time to time and without prior notice to you where reasonably necessary.

Where you are required to post additional Margin to maintain or open positions, we are not obliged to take into account your Digital Assets which are not in your Futures Account.

All Margin shall be held by us as continuing security and shall be subject to a general lien and right of set-off in favour of us for any and all of your obligations, liabilities or monies at any time due by you and payable to us under this Futures Agreement, the User Agreement or otherwise.

We shall have the right to deposit, pledge, re-pledge, hypothecate, re-hypothecate, invest or loan any Margin provided to us and shall not be obligated to notify you of any interest, income or benefit that may be derived therefrom. No interest shall be paid to you on any Margin deposited by you under this Futures Agreement and all such interest and benefit shall be retained by us for our own benefit.

We shall not be liable to you for any loss of Margin resulting directly or indirectly from the closure, bankruptcy, insolvency, liquidation, receivership or other events of any third party with whom the Margin is deposited or pledged.

9. Loan

Subject to the terms of this Futures Agreement, we may agree to provide to you loans of Digital Assets to support your trading on the Futures Platform, subject to you meeting the Margin Ratio (as defined below) in your Futures Account (“Loan”).

We reserve the right to vary or cancel partially or in full any amount of the Loan we provide to you. Notwithstanding anything in this Futures Agreement, we shall not be obligated to provide or continue to provide any Loan to you.

You agree to only use any Loan provided to you within the Futures Platform and in accordance with this Futures Agreement and the User Agreement.

You agree at all times to maintain in your Futures Account the minimum amount of Margin to satisfy the margin ratio that we prescribe from time to time (“Margin Ratio”). You are solely responsible to monitor the Margin Ratio requirements of your Futures Account.

If your Futures Account does not contain sufficient Margin to meet the minimum Margin Ratio, you will be responsible for transferring additional Margin to your Futures Account, whether or not a margin call has been sent to you.

10. Liquidation

You acknowledge and agree that in the event the Margin Ratio in your Futures Account falls below the minimum Margin Ratio required by the Futures Platform (“Liquidation Level”), we shall have the sole and absolute discretion to:

• liquidate any or all Margin in your Futures Account;
• fully or partially close any open positions in your Futures Account; and/or
• cancel any open Orders in your Futures Account,

in each case in order to bring your Margin Ratio above the Liquidation Level (“Forced Liquidation”).

We shall not be obligated to provide notice to you before commencing a Forced Liquidation on the Margin in your Futures Account. In the event of such Forced Liquidation, you agree that:

1. you shall be liable for all Fees relating to any Forced Liquidation;
2. you shall be liable for any losses, whether realised or unrealised, resulting from the Forced Liquidation; and
3. we shall not be liable for any losses, whether realised or unrealised, resulting from the Forced Liquidation, except where directly caused by our gross negligence or wilful misconduct.

If the Margin sold is insufficient to repay any Loan and any interest accrued thereon, you shall be liable for any remaining amounts owed to us. We may apply a higher interest rate depending on the period and amount of the Loan we provide to you.

11. Leverage

The Futures Platform allows you to execute trades on leverage based on the amount that is offered by the Futures Platform at the time of your trade. After you select your leverage limit, all your relevant positions shall use the same leverage limit, unless otherwise stated.

By executing a leveraged trade, you agree and understand that:

1. trading Digital Assets using leverage carries a high level of risk;
2. leveraged positions require a higher level of risk management and risk tolerance, and you have assessed such risks in accordance with your personal circumstances;
3. you are liable for all risks and losses associated with the use of leverage in trading Digital Assets on the Futures Platform; and
4. we are not responsible or liable for any losses you may incur by trading leveraged positions on the Futures Platform, except as otherwise expressly provided in this Agreement.

12. Calculations

Notwithstanding anything in this Futures Agreement and the trading rules of the Futures Platform, and unless otherwise stated by us, you agree that all calculations performed by the Futures Platform (including but not limited to margin, PnL, funding, liquidation levels and other risk metrics) are final and conclusive, except in the case of manifest error.

13. Fees, Funding, Interest and Commission

We shall have the right to charge interest on any Loan provided to you at such rate as we determine from time to time.

You shall promptly pay any fees, funding payments, interest and commission owed to us and/or other Users (“Fees”) in such manner that we may stipulate from time to time with respect to your use of the Futures Services.

We shall have the sole discretion to amend the Fees without prior notice to you, and it is your sole responsibility to ensure you are aware of the Fees associated with the Futures Services.

You agree that all Fees owed may be settled by deducting the relevant amounts from your Futures Account or other accounts you may have with us and you agree that any Fees owed constitute a debt immediately due and payable.

If you are unable to pay any of the Fees in the relevant Digital Asset when they are due, we shall have the right to effect payment or repayment in any other Digital Asset that you have in your Futures Account or other account with us at an exchange rate as determined by us at the time of repayment.

Any applicable taxes, duties, disbursements, costs and/or other expenses incurred by us relating to your use of the Futures Services shall be borne by you.

14. Settlement and Delivery

Settlement occurs when your Futures position closes or expires at the relevant settlement price and the profit or loss is credited or debited from your Futures Account (“Settlement”).

We have the sole discretion to declare early settlement due to concerns about the underlying Digital Assets, extreme market conditions or to ensure a fair and orderly market (“Early Settlement”) without prior notice to you. We shall not be liable for any losses relating to any Early Settlement.

In the event of Early Settlement, all relevant positions will undergo Settlement at a time and price determined by us in accordance with our rules and applicable law.

15. API Access (Futures)

Subject to your eligibility and our approval, you may be offered API access to use the Futures Services on the Platform. We reserve the right to limit, suspend or terminate any API access granted to you at any time.

Where you use APIs to access the Futures Services, you acknowledge and agree that:

• you are solely responsible for the security of your API keys;
• you shall comply with all rate limits, security requirements and other API rules; and
• we shall not be liable for any losses incurred in your use of the relevant API, except where directly caused by our gross negligence or wilful misconduct.

16. No Airdrop Rewards

You agree that you shall not be eligible for any airdrop reward (“Airdrop Reward”) and shall not have any legal or equitable rights over such Airdrop Reward in relation to:

1. any Digital Assets which you borrowed; and/or
2. any positions you have on the Futures Platform,

(together, the “Ineligible Events” for Futures).

Where you receive any Airdrop Rewards pursuant to any Ineligible Events, you shall be liable to return any Airdrop Reward to us and we shall have the discretion to transfer the Airdrop Reward from your Futures Account to our own proprietary wallets. Until we carry out such transfer, we may, at our sole discretion, restrict you from withdrawing your Digital Assets from the Futures Platform.

17. Market Misconduct

You must not under any circumstances engage in any conduct which we determine to be market misconduct (“Market Misconduct”), including, but not limited to:

1. engaging in any form of market manipulation, such as spoofing orders, wash trading, false trading or price rigging;
2. taking any action which creates a false or misleading appearance of trades or prices;
3. taking any action to maintain an artificial price or manipulate the price;
4. disclosing false or misleading information about the Futures Platform or Futures products; and/or
5. taking or omitting to take actions which would constitute fraud.

We shall have the discretion to use surveillance systems to monitor your activity on the Futures Platform and shall take any action which we deem necessary to address any actual or potential Market Misconduct, including but not limited to closing positions, cancelling Orders, restricting Accounts, or reporting to authorities.

18. Termination and Remedies for Breach (Futures)

We shall have the right at any time to terminate all or part of the Futures Services offered by us to you in accordance with this Futures Agreement and the User Agreement, and this Futures Agreement shall terminate on the relevant date of termination of all such Services.

You shall have the right to terminate your use of the Futures Services at any time, and this Futures Agreement shall terminate on the relevant date of your termination of use of the Futures Services, subject to all outstanding obligations and liabilities.

Upon termination of this Futures Agreement, you agree that you shall not have the right to require us to continue to provide the Futures Services to you or perform any other obligation, including, but not limited to, requesting us to keep or disclose to you any information in your Futures Account, or to disclose to you or any third party any information therein that is not read or sent.

19. Breach of Futures Agreement

In the event you breach this Futures Agreement or any applicable laws, rules or regulations in connection with the Futures Services, you shall pay to us a minimum of US$2,000,000 in Compensation and bear all expenses we incur in connection with such breach, including any legal fees.

If the Compensation is insufficient to cover our losses, you shall be liable for additional amounts in excess of the Compensation.

For the avoidance of doubt, the termination of this Futures Agreement shall not prevent the non-breaching Party from demanding the breaching Party to assume liabilities arising under applicable law.

20. Notices and Communications (Futures)

You undertake to regularly refer to the announcements, materials and information related to Futures on the Platform. We will not be held responsible or liable in any manner of compensation should you incur personal losses arising from negligence in not referring to such announcements, materials and information.

21. Miscellaneous (Futures)

Unless otherwise stated in this Futures Agreement, the miscellaneous provisions of the User Agreement (including but not limited to assignment, force majeure, relationship of Parties, entire agreement, amendment, survival, no waiver and dispute resolution) shall apply mutatis mutandis to this Futures Agreement.

Annex 1: Cross-Leverage Trading Rules

1. General

This Annex 1 is supplementary to the Futures Agreement and shall apply to any functions relating to cross-leverage on the Platform.

2. Cross-Leverage

You shall provide Margin for cross-leverage trading, which shall be equal to the net value of the Digital Assets in your cross-leverage account (the “Cross-Leverage Account”) multiplied by the corresponding margin adjustment coefficient (the “Margin Adjustment Coefficient”).

The Margin Adjustment Coefficient refers to the coefficient for the conversion of the margin of a token at its market price when calculating the margin amount.

The Platform shall have the right to, from time to time and without prior notice to you:

• adjust the Margin Adjustment Coefficient;
• adjust the token types which can be borrowed; and
• set or adjust a limit for the margin applicable to any particular token.

3. Loan

The maximum amount of the Loan is the maximum amount of tokens that you can borrow from the Platform.

The Platform shall calculate the current maximum amount of your Loan based on:

• the maximum amount that you can borrow for cross-leverage,
• the Margin Adjustment Coefficient,
• the Platform rules, and
• any other restrictions the Platform may set from time to time.

After a leveraged Loan has been granted, the borrowed Digital Assets will be transferred to your Cross-Leverage Account immediately, and the Platform will commence charging interest immediately upon such transfer.

4. Leverage

The maximum amount of the Loan depends on:

• the Digital Assets in your Futures Account; and
• your selected leverage multiple,

in accordance with the rules and limits displayed on the Platform from time to time.

5. Interest

Interest on your Loan shall be calculated based on the hourly service rate.

• Any period of less than 60 minutes shall be deemed to be 1 hour.
• Interest shall start accruing once the Loan is credited to your Futures Account.
• You may repay the Loan at any time, subject to the rules on the Platform.
• Any Fees owed shall be paid first before the Margin is repaid.

6. Repayment

If you have multiple Loans on the Platform, you may select which Loan to repay first, subject to any risk-control rules that the Platform may apply from time to time.

7. Risk Control

The Platform shall have the right to set the position limit for a single token type, which position limit may be used to calculate:

• the risk rate,
• the purchase limit, and
• the amount that can be transferred out of your Cross-Leverage Account.

Only Digital Assets in your Cross-Leverage Account can be used as Margin for the Loan. The Platform shall monitor the Margin Ratio of your Cross-Leverage Account.

For the purposes of this Annex 1, your Margin Ratio shall be determined as follows:

Margin Ratio =
Total value of Digital Assets within your position limit
÷ (total value of liabilities + unpaid service fee)

Where:

• Total value of Digital Assets within your position limit = the current total market value of the Digital Assets within the position limit of the Cross-Leverage Account.

  • The value of any Digital Assets exceeding your position limit is not included in the calculation of the Margin Ratio.

• Total value of liabilities = the current total market value of all Loans outstanding in the Cross-Leverage Account.

• Unpaid service fee =
  amount of each Loan × duration of the Loan at the time of calculation × hourly service rate − already-offset/paid service fee.

When the Margin Ratio of the Cross-Leverage Account reaches 120% (the “Warning Line”), the system will send a warning message to you through the contact information you have provided (a “Warning Message”).

When the risk rate (Margin Ratio) of the Cross-Leverage Account reaches 110% (the “Forced Liquidation Line”), the system will automatically trigger Forced Liquidation, which will:

• liquidate the positions in the Cross-Leverage Account held by you; and
• automatically repay all your Loans.

If you have more than one Loan, repayment will be made in chronological order, and the earliest Loan will be repaid first.

If all the assets in your Cross-Leverage Account are insufficient to repay all Loans in full, the Platform shall have the right to recover any outstanding amounts from you.

The Platform shall also have the right to limit the purchase amount of tokens of a single type, in order to avoid reduced risk rates or Forced Liquidation triggered by the purchase of tokens exceeding the position limit.

You acknowledge and agree that:

• you are aware of the risks of leveraged trading; and
• all losses caused by Forced Liquidation shall be borne by you, including any losses where you did not take appropriate measures to reduce your position in time after receiving a Warning Message.

The Platform reserves the right, at its sole discretion, to manage and adjust:

• the total value of Loans,
• the maximum amount of Loans,
• the Margin Adjustment Coefficient,
• the Warning Line; and
• the Forced Liquidation Line.

If, after Forced Liquidation, the balance in your Cross-Leverage Account is negative, the Platform reserves the right to:

• restrict any transfers to and/or from your accounts with the Platform; and
• apply any transfers to your Cross-Leverage Account towards repayment of any outstanding amounts owed.

Annex 2: Isolated-Leverage Trading Rules

1. General

This Annex 2 is supplementary to the Futures Agreement and shall apply to any functions relating to isolated-leverage on the Platform.

2. Isolated-Leverage

You shall provide Margin for isolated-leverage trading for each trading pair you intend to trade.

The Platform shall set separate accounts for each trading pair in respect of each Loan (each, an “Isolated-Leverage Account”).

3. Loan

The maximum amount of the Loan is the maximum loan limit applicable to the relevant trading pair.

The maximum amount of the Loan is calculated by the Platform based on:

• the maximum loan amount permitted in each Isolated-Leverage Account; and
• the rules and restrictions of the Platform, as may be updated from time to time.

After a leveraged Loan has been granted, the borrowed Digital Assets will be transferred to your Isolated-Leverage Account immediately, and the Platform will commence charging interest immediately upon such transfer.

4. Leverage

The maximum amount of the Loan depends on:

• the Digital Assets in your Futures Account; and
• your selected leverage multiple,

in accordance with the rules and limits displayed on the Platform from time to time.

5. Interest

Interest on your Loan shall be calculated based on the hourly service rate.

• Any period of less than 60 minutes shall be deemed to be 1 hour.
• Interest shall start accruing once the Loan is credited to your Futures Account.
• You may repay the Loan at any time, subject to the rules on the Platform.
• Any Fees owed shall be paid first before the Margin is repaid.

6. Repayment

If you have multiple Loans on the Platform, you may select which Loan to repay first, subject to any risk-control rules that the Platform may apply from time to time.

7. Risk Control

The Digital Assets in each Isolated-Leverage Account shall not be included as Margin in any other Isolated-Leverage Account.

The Platform shall monitor the Margin Ratio of your Isolated-Leverage Accounts in real time and reserves the right to take risk-control measures according to changes in your Margin Ratio.

For the purposes of this Annex 2, your Margin Ratio shall be determined as follows:

Margin Ratio =
Total value of Digital Assets
÷ (total value of liabilities + unpaid service fee)

Where:

• Total value of Digital Assets = the current total market value of all Digital Assets in the relevant Isolated-Leverage Account, denominated in a reference Digital Asset (for example, BTC or USDT), as determined by the Platform.

• Total value of liabilities = the current total market value of all Loans in the relevant Isolated-Leverage Account that have been borrowed but not yet repaid.

• Unpaid service fee =
  amount of each Loan × Loan duration at the time of calculation × hourly service rate − deducted/returned service fee.

When the Margin Ratio of an Isolated-Leverage Account reaches the Warning Line, the system will send a Warning Message to you through the contact information you provided.

When the risk rate (Margin Ratio) of your Isolated-Leverage Account reaches the Forced Liquidation Line, the system will automatically trigger Forced Liquidation, which will:

• liquidate the positions in the relevant Isolated-Leverage Account held by you; and
• automatically repay all your Loans associated with that Isolated-Leverage Account.

If you have more than one Loan, repayment will be made in chronological order, and the earliest Loan will be repaid first.

If all the assets in your Isolated-Leverage Account are insufficient to repay all Loans in full, the Platform shall have the right to recover any outstanding amounts from you.

You acknowledge and agree that:

• you are aware of the risks of leveraged trading; and
• all losses caused by Forced Liquidation shall be borne by you, including any losses where you did not take appropriate measures to reduce your position in time after receiving a Warning Message.

The Platform reserves the right, at its sole discretion, to manage and adjust:

• the total value of Loans,
• the maximum amount of Loans,
• the Warning Line; and
• the Forced Liquidation Line.

If, after Forced Liquidation, the balance in your Isolated-Leverage Account is negative, the Platform reserves the right to:

• restrict any transfers to and/or from your accounts with the Platform; and
• apply any transfers to your Isolated-Leverage Account towards repayment of any outstanding amounts owed.

Annex 3: Interest Rate

The Platform may maintain:

• a basic interest rate; and
• a tiered interest rate;

and may provide different Payment Policies, such as:

• payment in borrowed Digital Asset;
• “point card” deduction; and
• Platform Token deduction (using the Platform’s native token, if applicable),

together, the “Rate Policy”.

The specific rates, tiers and eligibility conditions will be published on the Platform and may be adjusted from time to time in accordance with market conditions and our internal policies.

Annex 4: Warning Messages

The Platform may send various warning messages (for example, zero-balance warnings, margin ratio warnings and trade limit warnings) based on the Margin Ratio and other risk indicators.

Such warnings are informative only and do not limit the Platform’s right to exercise risk controls, including Forced Liquidation, in accordance with this Futures Agreement and the User Agreement.

Appendix 3: Cifra X Options Services Agreement

This Appendix governs:

• creation and use of Options Accounts;
• definitions of Options, Option Types, Requests, Quotes;
• placing Requests, receiving Quotes and executing Options Transactions;
• Fees and premiums;
• Settlement (including Early Settlement);
• prohibitions of Market Misconduct in Options trading;
• API access for Options (if any);
• termination, remedies for breach and Compensation clauses mirroring the main and Futures Agreements.

Appendix 4: Cifra X Spot Trading Services Agreement

This Appendix governs all spot trading and related functions, including:

• Spot Accounts, Margin Accounts and any Quant or trading-bot-related Accounts (“Platform Accounts” for spot);
• creation, use, security and suspension/closure of Platform Accounts;
• deposits, custody, withdrawals and transfers for spot;
• spot trading Orders and Order Types;
• Margin Trading and Loan mechanics for spot (Margin, Margin Requirements, Margin Adjustment Coefficient, Margin Ratio, Liquidation Level and Forced Liquidation);
• leverage rules for spot margin trading;
• Trading Bot functionality (including grid trading), with configuration of parameters (upper/lower limit, number of grids, initial capital, take-profit, stop-loss);
• calculations;
• Fees and interest for spot trading and spot margin;
• Market Misconduct rules;
• API access for spot trading;
• No Airdrop Rewards for borrowed assets;
• termination and breach/remedies clauses mirroring the Futures Agreement (including US$2,000,000 Compensation minimum for material breach).

Appendix 5: Cifra X Finance Services Agreement

This Appendix governs Cifra X Finance products, including:

• Staking;
• Primepool (lock-ups and reward pools);
• Cifra X Earn (fixed and flexible earn/savings products);
• Crypto Loans (pledging Digital Assets as collateral to borrow other Digital Assets); and
• any other similar yield, lending or finance-related products we may offer from time to time.

Key areas covered:

1. Platform Accounts for Finance

   • Definitions of Spot Account, Earn Account, Pool Account and other finance-related sub-accounts.
   • Creation, use, security and suspension/closure of these accounts.

2. Deposits, Custody, Withdrawals and Transfers

   • Same custodial principles as in the User Agreement.
   • Specific rules for locked and staked assets (lock-up periods, unstaking periods, minimum terms).

3. Staking

   • Technical-service nature of staking.
   • Lock periods and limitations on withdrawals during staking and unstaking.
   • Indicative yield only; no guarantee on displayed APRs.
   • Our rights to suspend or remove staking offerings for any Digital Asset.

4. Primepool

   • Locking Digital Assets into pools for reward allocations.
   • Daily snapshots and reward calculations.
   • Possible caps on total pool size or per-user allocations.
   • No liability for delays in distribution.

5. Cifra X Earn

   • Fixed and flexible deposits, with different reward levels.
   • Potential preferential rates for Users holding a certain balance of a Platform Token, if applicable.
   • Lock-up periods for fixed products and limitations on early redemption.

6. Crypto Loans

   • Pledging Digital Assets as collateral (Margin) to borrow other Digital Assets (Loan).
   • Our right to set valuation haircuts and Margin Ratios, and to adjust them.
   • General lien and right of set-off over collateral.
   • No interest paid to you on Margin; rights to rehypothecate.
   • Our right to Liquidate collateral if Margin Ratio falls below the minimum, with you bearing fees and any shortfall.

7. Calculations

   • Calculations of yields, rewards, interest and Margin Ratios are final and conclusive, absent manifest error.

8. Fees and Premium

   • Interest rates on Loans, Fees for early redemption, administrative charges and similar costs.
   • Our right to collect Fees in any Digital Asset held in your accounts.

9. Market Misconduct

   • Prohibition on using Finance products to engage in fraud, wash trading, artificial volume or other manipulative conduct, especially where rewards or yields might be gamed.

10. API Access

    • Where applicable, our rights to limit or revoke API access to Finance products.

11. No Airdrop Rewards

    • Same logic as in Futures and Spot: no entitlement to Airdrop Rewards for borrowed assets.

12. Termination and Remedies for Breach

    • Termination rights and the minimum US$2,000,000 Compensation clause for material breach, mirroring the other Appendices and the main Agreement.