General Terms and Conditions of Transaction

CAMBIUMWAY SP. Z.O.O.

Last updated: February 20, 2025

1. INTRODUCTION

1.1 About the Company

These General Terms and Conditions of Transaction ("Terms") govern the relationship between Cambiumway sp. z.o.o. ("the Company", "we", "us", or "our"), a company registered in the Republic of Poland under KRS number 0001143376, NIP: 7252350588, with its registered office at Hoza 86/210, 00-682 Warszawa, Poland, and any individual or legal entity ("Client", "you", or "your") who uses or wishes to use the Company's services.

1.2 Scope of Services

The Company provides virtual asset exchange services, including but not limited to the conversion of virtual assets (cryptocurrencies) into fiat currency (EUR) and the transfer of fiat currency to bank accounts within the European Union. The Company operates as a registered Virtual Asset Service Provider (VASP) in accordance with applicable Polish and EU regulations.

1.3 Acceptance of Terms

By using the Company's services, the Client confirms that they have read, understood, and agree to be bound by these Terms, as well as the Company's Privacy Policy, Cookie Policy, and AML/CTF & KYC Policy. If the Client does not agree to these Terms, they must refrain from using the Company's services.

2. DEFINITIONS

For the purposes of these Terms, the following definitions shall apply:

• "Virtual Asset" means any digital representation of value that can be digitally traded, transferred, or used for payment, including but not limited to Bitcoin (BTC), Ethereum (ETH), Tether (USDT), USD Coin (USDC), and other cryptocurrencies supported by the Company.
• "Fiat Currency" means government-issued currency, specifically EUR (Euro) for the purposes of the Company's services.
• "Transaction" means any exchange of virtual assets for fiat currency or any related transfer of funds facilitated by the Company.
• "Client" means any natural person aged 18 or older, or any legal entity that has been verified in accordance with the Company's KYC procedures and uses or intends to use the Company's services.
• "Business Relationship" means the ongoing relationship between the Company and the Client for the purpose of providing services.
• "Wallet Address" means a unique alphanumeric identifier used to send and receive virtual assets on a blockchain network.
• "Exchange Rate" means the rate at which a virtual asset is converted into fiat currency, as determined by the Company at the time of the transaction.
• "Service Fee" means the fee charged by the Company for the execution of a transaction, as communicated to the Client prior to the transaction.

3. GENERAL PROVISIONS

3.1 Eligibility

To use the Company's services, the Client must:

• Be at least 18 years of age (or the age of legal majority in their jurisdiction);
• Have full legal capacity to enter into binding agreements;
• Not be a resident or citizen of a jurisdiction where the use of the Company's services is prohibited or restricted;
• Not be listed on any sanctions lists or associated with prohibited activities;
• Successfully complete the Company's KYC verification process.

3.2 Client Obligations

The Client agrees to:

• Provide accurate, complete, and up-to-date information during the KYC process and throughout the business relationship;
• Use the Company's services only for lawful purposes;
• Not use the Company's services for money laundering, terrorist financing, fraud, tax evasion, or any other illegal activity;
• Promptly notify the Company of any changes to their personal or business information;
• Maintain the confidentiality and security of their account credentials;
• Comply with all applicable laws and regulations in their jurisdiction.

3.3 Company Rights

The Company reserves the right to:

• Refuse to provide services to any Client at its sole discretion;
• Suspend or terminate the business relationship if the Client fails to comply with these Terms or applicable laws;
• Request additional information or documentation at any time during the business relationship;
• Modify, suspend, or discontinue any service at any time with reasonable notice;
• Set and modify transaction limits, fees, and exchange rates;
• Freeze or suspend transactions that are suspected of being related to illegal activities.

4. TERMS OF TRANSACTION

4.1 Transaction Process

The transaction process consists of the following steps:

• The Client initiates a transaction request by specifying the virtual asset to be exchanged, the amount, and the destination bank account;
• The Company provides the Client with the applicable exchange rate, service fee, and the total amount of fiat currency to be received;
• Upon the Client's confirmation, the Company provides a wallet address for the Client to send the virtual assets;
• The Client transfers the virtual assets to the designated wallet address;
• Upon receipt and confirmation of the virtual asset transfer on the blockchain, the Company converts the virtual assets to fiat currency and initiates a bank transfer to the Client's designated bank account;
• The bank transfer is typically processed within 1-5 business days, depending on the receiving bank and jurisdiction.

4.2 Exchange Rates and Fees

The exchange rate for each transaction is determined at the time of the transaction confirmation and is subject to market fluctuations. The Company makes reasonable efforts to provide competitive exchange rates but does not guarantee any specific rate.

Service fees are disclosed to the Client before the transaction is confirmed. Fees may vary depending on the transaction amount, the virtual asset involved, and other factors. The Company reserves the right to modify its fee structure with prior notice.

4.3 Transaction Limits

The Company may set minimum and maximum transaction limits. These limits may vary depending on the Client's verification level, risk profile, and the virtual asset involved. Current transaction limits are communicated to the Client during the transaction process or upon request.

4.4 Cancellation and Refunds

Once a transaction has been confirmed and the virtual assets have been sent to the designated wallet address, the transaction cannot be cancelled or reversed. Due to the nature of blockchain transactions, the Company cannot guarantee the return of virtual assets once they have been transferred.

In exceptional circumstances, such as a system error or a duplicate transaction, the Company may, at its sole discretion, process a refund. Refunds will be processed in the original virtual asset or fiat currency, as determined by the Company.

5. AML/CFT COMPLIANCE

5.1 KYC Requirements

All Clients must complete the Company's KYC verification process before using the services. The KYC process is conducted in accordance with the Company's AML/CTF & KYC Policy and applicable legal requirements. The Company reserves the right to request additional documentation at any time.

5.2 Source of Funds

The Company may require the Client to provide documentation or information regarding the source of the virtual assets or funds involved in a transaction. This may include, but is not limited to, bank statements, proof of mining, exchange history, or other documentation demonstrating the legitimate origin of the assets.

5.3 Transaction Monitoring

The Company monitors all transactions for suspicious activity in accordance with its AML/CTF & KYC Policy. The Company reserves the right to suspend, delay, or refuse any transaction that raises concerns about potential money laundering, terrorist financing, or other illegal activity.

6. RISK DISCLOSURE

6.1 Market Risk

Virtual assets are highly volatile and their value can fluctuate significantly in a short period of time. The Client acknowledges and accepts the risk that the value of their virtual assets may decrease before or during a transaction, and that the final amount of fiat currency received may be less than expected.

6.2 Regulatory Risk

The legal and regulatory framework governing virtual assets is evolving and may change. Changes in regulations may affect the availability or terms of the Company's services. The Company does not guarantee that its services will remain available in all jurisdictions.

6.3 Technology Risk

Blockchain technology and virtual asset transactions carry inherent technological risks, including but not limited to network congestion, smart contract vulnerabilities, wallet security breaches, and protocol changes. The Client acknowledges and accepts these risks.

6.4 Limitation of Liability

To the maximum extent permitted by applicable law, the Company shall not be liable for any direct, indirect, incidental, consequential, or special damages arising from the use of its services, including but not limited to losses resulting from market fluctuations, delays in transaction processing, system failures, or unauthorized access to the Client's account.

7. DATA PROTECTION

7.1 Personal Data Processing

The Company processes personal data in accordance with the General Data Protection Regulation (GDPR) and applicable Polish data protection laws. For detailed information on data processing practices, please refer to the Company's Privacy Policy.

7.2 Data Sharing

The Company may share personal data with third parties to the extent necessary for the provision of services, compliance with legal obligations, or with the Client's consent. Third parties include payment processors, banking partners, identity verification providers, and regulatory authorities.

8. DISPUTE RESOLUTION

8.1 Complaints

Clients may submit complaints or inquiries to the Company via email at info@cambiumway.com. The Company shall acknowledge receipt of the complaint within five (5) business days and endeavor to resolve the matter within thirty (30) business days.

8.2 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Republic of Poland, without regard to its conflict of law provisions.

8.3 Jurisdiction

Any disputes arising out of or in connection with these Terms shall be submitted to the exclusive jurisdiction of the competent courts of Warsaw, Poland. Notwithstanding the foregoing, the Company may seek injunctive relief or other equitable remedies in any court of competent jurisdiction.

9. FORCE MAJEURE

The Company shall not be liable for any failure or delay in the performance of its obligations under these Terms if such failure or delay is caused by circumstances beyond its reasonable control, including but not limited to natural disasters, wars, acts of terrorism, government actions, power outages, internet disruptions, cyberattacks, pandemics, or changes in applicable laws or regulations.

In the event of a force majeure event, the Company shall use reasonable efforts to minimize the impact on the Client and resume normal operations as soon as practicable.

10. TERMINATION

10.1 Termination by the Client

The Client may terminate the business relationship at any time by providing written notice to the Company. Any pending transactions at the time of termination shall be completed in accordance with these Terms.

10.2 Termination by the Company

The Company may terminate the business relationship immediately and without prior notice if:

• The Client breaches any provision of these Terms;
• The Client provides false, misleading, or incomplete information;
• The Client is suspected of engaging in money laundering, terrorist financing, or other illegal activities;
• The Company is required to do so by law, regulation, or a competent authority;
• The Client's risk profile changes to an unacceptable level.

10.3 Effects of Termination

Upon termination, the Company shall complete any pending transactions and return any remaining funds or virtual assets to the Client, subject to applicable legal obligations (including data retention requirements). The Company's obligations regarding data retention and confidentiality shall survive termination.

11. FINAL PROVISIONS

11.1 Amendments

The Company reserves the right to amend these Terms at any time. Changes shall be communicated to the Client via email or through the Company's website. Continued use of the Company's services after the effective date of the amendments constitutes acceptance of the revised Terms.

11.2 Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. The invalid or unenforceable provision shall be replaced with a valid provision that most closely reflects the original intent.

11.3 Entire Agreement

These Terms, together with the Privacy Policy, Cookie Policy, and AML/CTF & KYC Policy, constitute the entire agreement between the Company and the Client regarding the use of the Company's services and supersede all prior agreements, representations, and understandings.

11.4 Contact Information

For questions or concerns regarding these Terms, please contact:

Cambiumway sp. z.o.o.
Hoza 86/210, 00-682 Warszawa, Poland
Email: info@cambiumway.com