Terms and Conditions – BITX, S.L.

This Agreement sets forth the terms and conditions governing the relationship between BITX and the User with respect to access to and use of the Services offered by BITX as a registered Virtual Asset Service Provider.

It defines the respective rights and obligations of the parties and establishes the general legal framework under which the Services are provided. The User’s acceptance of these Terms and Conditions constitutes a binding agreement to comply with all applicable provisions herein.

In order to access the Services, Users must meet the following eligibility criteria:

• Individuals must be at least eighteen (18) years of age or the legal age of majority in their jurisdiction, and must possess full legal capacity to enter into binding agreements.
• Corporate Users must be duly incorporated and validly existing under the laws of their country of incorporation.

By accepting these Terms and Conditions, the User confirms that they meet the above requirements.

Prior to the provision of any Services, the prospective User must complete the registration and identity verification (“KYC”) process, providing the information and documentation requested by BITX, which may include, among others: personal details, valid identification document, proof of residence, information regarding economic or professional activity, and additional documentation as may be required based on the assessed level of risk. BITX may request periodic updates of this information and conduct ongoing monitoring procedures in accordance with its AML/CFT Manual.

All Users are subject to screening against sanctions lists, Politically Exposed Person (PEP) databases, and other relevant watchlists, in line with applicable regulations and BITX’s internal policies. BITX uses third-party tools such as NeoCheck for digital identification and verification. The prospective User expressly consents to BITX’s use of such tools and to the sharing of relevant personal data with third-party providers solely for verification and compliance purposes.

Once all required documentation has been submitted, BITX will review the application and may approve or reject it at its sole discretion. Grounds for rejection may include, among others, failure to complete identification, presence on a sanctions or high-risk list, or the existence of compliance or legal risks that BITX deems unacceptable. Upon approval, the User must promptly notify BITX of any changes to the information provided during onboarding, including but not limited to changes in legal name, address, contact information, ownership or control structure (in the case of legal entities), banking details, or legal status (e.g., designation as a PEP or involvement in criminal proceedings). BITX may periodically request the revalidation or update of the User’s information, and failure to comply may result in the suspension or restriction of access to the Services.

Access to and use of BITX’s Services is strictly prohibited for persons or entities residing in jurisdictions subject to international sanctions or classified as high-risk by competent authorities, unless expressly authorized in writing by BITX following a satisfactory enhanced due diligence process.

The User agrees to use the Services lawfully and in compliance with applicable laws, refraining from carrying out any transactions that may constitute a legal violation, money laundering, terrorist financing, or any other criminal activity. BITX may, at its sole discretion, refuse or suspend any transaction it considers suspicious or non- compliant with its internal policies or applicable regulations.

Users may only use accounts and wallets that belong to them and have been verified with BITX. Users should only send crypto from wallets that they control and have been disclosed to BITX (we may ask to prove ownership of a wallet). BITX may refuse to execute a transaction involving third-party accounts or wallets that have not undergone due diligence.

Transactions involving virtual assets carry significant risks, including the potential total loss of the invested capital due to market volatility. The User acknowledges and accepts these risks, assuming full responsibility for any transactions executed through BITX.

BITX’s services are limited to the execution of requested trades. Any market information provided (pricing, market trends, etc.) is for informational purposes only. BITX does not provide legal, tax, or investment advice or any advisory service. The User is solely responsible for evaluating and understanding the risks of engaging in virtual asset transactions.

Fees applicable to the Services shall be agreed individually with the User and communicated in advance, either through specific contractual documentation or by other suitable means. Where applicable, general fee information may be made available on BITX’s website.

BITX reserves the right to amend its fees at any time, provided that such amendments are communicated in advance as set out in the preceding paragraph. Continued use of the Services following such communication shall constitute acceptance of the updated fees.

For the purposes of this clause, the publication of updated Terms and/or fee information on BITX’s official website shall be deemed valid notice to the User.

As a virtual asset service provider registered with the Bank of Spain, BITX maintains and enforces internal policies and procedures aimed at preventing money laundering and terrorist financing, in compliance with Law 10/2010 of April 28 and its implementing regulations, as well as any other applicable legislation.

BITX conducts ongoing monitoring of User activity and transactions. The size, frequency, and pattern of transactions may be reviewed to assess consistency with the information provided by the User regarding the origin of funds and intended use of the Services. BITX also employs blockchain analytics and risk-monitoring tools, such as BitRank Verified or equivalent services, to evaluate cryptocurrency addresses and transactions for potential links to illicit activity, including but not limited to fraud, theft, sanctioned entities, or darknet marketplaces. Where transactions raise alerts or appear suspicious, BITX may, at its sole discretion, delay processing and request additional documentation or clarification from the User, including but not limited to: proof of origin of funds; justification of the transaction purpose; or supporting legal or commercial documentation.

In accordance with FATF Recommendation 16 (the “Travel Rule”) and corresponding EU and Spanish regulatory provisions, BITX shall collect and may be required to transmit identifying information regarding the originator and beneficiary of cryptocurrency transfers. This obligation typically applies to transfers exceeding certain thresholds or to transfers executed in cooperation with other Virtual Asset Service Providers (VASPs). The data shared may include, inter alia, the name, address, account or wallet identifier, and national identification number of the parties involved. By using BITX’s Services, the User expressly consents to the collection and transfer of such data where legally required.

The User agrees to fully cooperate with BITX in fulfilling its legal obligations, including but not limited to providing accurate and updated information for identity verification purposes, disclosing the origin and destination of funds, and submitting any additional documentation or data required for due diligence or transaction monitoring.

The User expressly authorizes BITX to carry out any additional checks or enhanced due diligence measures it deems necessary to ensure compliance with its anti- money laundering and counter-terrorist financing obligations.

The User represents and warrants that they shall not use the Services, directly or indirectly, for any unlawful purpose or prohibited activities, including but not limited to the following:

• Money Laundering, Terrorism Financing, or Criminal Activity: The User shall not use the exchange service to disguise the origin of funds or to transact in proceeds of any unlawful activity. The User shall not engage in any dealings that finance or support terrorist organizations, or violate financial sanctions.
• Sanctions Violations: The User shall not be located in, be a citizen or resident of, or send/receive funds to or from any country or person embargoed or sanctioned by Spain, the European Union, United Nations, United States (OFAC), or other applicable sanctions authorities. The User shall not attempt to circumvent any sanctions through BITX.
• Fraud or Misrepresentation: The User shall not provide false information or documents to BITX or attempt to impersonate another person or entity. The User shall not use BITX to facilitate fraud against any third party (e.g., using BITX to convert funds obtained through scams or phishing).
• Unregistered Securities or Illegal Investments: The User shall not use BITX to trade any token or asset that is illegal or whose trading is not permitted by law.
• Gambling, Darknet Markets, or Other High-Risk Uses: Unless explicitly permitted by BITX in writing after enhanced due diligence, the User shall not use BITX to move funds related to online gambling, darknet marketplaces, mixers/tumblers, or other services that are commonly associated with high AML risk. BITX reserves the right to reject transactions involving certain privacy coins or services that impede traceability, unless the transparency of funds’ origin can be reasonably verified.
• Violation of Law: The User shall not use BITX’s platform in any manner that would violate any law, regulation, or these Terms. The User shall not engage in or assist any activity that is illegal in their jurisdiction or in Spain.

BITX reserves the right to block, suspend, or terminate any transaction or provision of Services to the User, at its sole discretion, if it identifies indications of suspicious activity, lack of cooperation, insufficient or inconsistent information, or any breach of applicable regulations. BITX may also report any such activity to the competent authorities, in accordance with its internal procedures and professional judgment.

BITX shall process the User’s personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018, ensuring the confidentiality and security of the information.

Data will be processed for the purposes of verifying the User’s identity, providing the Services, fraud prevention measures, in compliance with applicable anti-money laundering and counter-terrorist financing legislation, complying with legal and contractual obligations, and sending communications related to the contractual relationship.

BITX treats all User data as confidential and shall only disclose it to third parties under the following circumstances:

• Compliance and Verification Providers: BITX may share personal data with providers such as NeoCheck for identity verification and Blockchain Intelligence Group (or equivalent) for transaction analysis and monitoring. These service providers are subject to binding contractual obligations to process the data solely for the specified purposes and in accordance with applicable data protection standards.
• Banking and Payment Intermediaries: In order to execute fiat currency transfers, BITX may need to transmit certain personal data (e.g., full name, account number, address, transaction reference) through payment channels. Such data may be accessed by correspondent banks and payment intermediaries as part of the transaction flow.
• Corporate Service Providers: BITX may engage third-party service providers for cloud storage, IT infrastructure, and related services. In the event that such providers are located outside the European Economic Area, BITX shall ensure that appropriate safeguards are in place, such as EU adequacy decisions or the execution of Standard Contractual Clauses (SCCs), to guarantee the protection of personal data.
• Legal and Regulatory Requirements: BITX may disclose personal data when legally required to do so, including but not limited to: court orders, requests from regulatory authorities, or submission of Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU). BITX may also provide limited access to legal advisors, auditors, or consultants under strict confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, corporate restructuring, or sale of all or part of BITX’s business, personal data may be transferred to the acquiring entity or successor, subject to the same obligations of confidentiality and data protection.

BITX will never disclose more data than is strictly necessary for the specific processing purpose and will not share personal data with third parties for their own marketing or unrelated purposes.

Personal data shall be retained only for the period strictly necessary for the purposes described above. In accordance with AML regulations, BITX is legally required to retain KYC documentation and transaction records for a minimum of ten (10) years following the termination of the business relationship or the execution of an occasional transaction, whichever is later. Other categories of data shall be retained for shorter periods, in accordance with BITX’s data retention policy or applicable law. Once the retention period has expired, data will be securely erased or anonymized.

The User may exercise their rights of access, rectification, erasure, restriction of processing, data portability, and objection; by submitting a written request to the contact address specified in BITX’s Privacy Policy or by contacting:legal@bitx.es.

BITX shall not be liable for any loss, damage, or harm arising from the User’s use of the Services, except in cases of willful misconduct or gross negligence. The User acknowledges and agrees that cryptocurrency transactions involve significant risks, including, among others, value fluctuations, market risks, and potential regulatory limitations.

In no event shall BITX be liable for indirect losses, loss of profits, or damages arising from technical interruptions, network failures, or acts of third parties, provided such events are not the result of BITX’s willful misconduct or negligence.

BITX reserves the right to unilaterally amend or update these Terms and Conditions at any time, including for reasons related to legal or regulatory changes, operational adjustments, or modifications to the Services provided.

Any amendments shall become effective upon their publication on BITX’s official website, without the need for individual notification to the User. The effective date shall be indicated at the top of the updated version.

By continuing to use the Services after the publication of the updated Terms, the User is deemed to have accepted the revised version. If the User does not agree with the modifications, they must immediately discontinue use of the Services and may request the closure of their account.

Users are encouraged to consult these Terms and Conditions periodically in order to stay informed of any changes that may affect their rights and obligations.

BITX maintains archived versions of previous Terms and Conditions, which may be made available to the User upon request for reference purposes.

In the event of any inconsistency between a previous version and the one published on BITX’s website, the latter shall prevail. No oral or written communication by BITX staff shall have the effect of amending these Terms unless expressly stated in writing and published as part of the official version.

These Terms and Conditions shall be governed by and construed in accordance with Spanish law. Any dispute arising from the interpretation or performance of these Terms shall be submitted to the Courts of Barcelona, unless otherwise required by applicable law.

These Terms and Conditions are provided in English for convenience and broad accessibility. BITX maintains an official version of the Terms and Conditions in Spanish, which is the governing language for legal purposes. In case of any conflict or discrepancy between the English version and the Spanish version of these Terms, the Spanish version shall prevail and be deemed the binding version. Translations (including this English text) are for reference to aid understanding; the Spanish text will control in any dispute about the interpretation of these Terms.

Users have the right to request and review the Terms and Conditions in Spanish (and may contact BITX if they require a copy).

• Entire Agreement: These Terms and Conditions, together with any documents expressly incorporated herein by reference (including, but not limited to, the Privacy Policy and any specific agreements provided in connection with particular products or services), constitute the entire agreement between the User and BITX in relation to the use of the Services, except where a separate written contract has been executed between BITX and the User. In such a case, these Terms and Conditions shall be deemed supplementary, and in the event of any conflict or inconsistency between these Terms and the provisions of the private agreement, the Terms shall prevail. The User acknowledges not having relied on any statement, promise, or representation not expressly set out herein in deciding to accept this Agreement.
• Severability: Should any provision of these Terms be held invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be deemed severed from the remainder of the Agreement, which shall remain in full force and effect. The invalid or unenforceable clause shall be interpreted or, if necessary, replaced with a valid provision that most closely reflects the original intent.
• No Waiver: No failure or delay by BITX in exercising any right, power, or remedy under this Agreement shall operate as a waiver thereof. A waiver of any provision or breach shall only be effective if given expressly in writing, and shall not be construed as a waiver of any subsequent breach or of any other provision.
• Assignment: The User may not assign, delegate, or transfer any rights or obligations under these Terms without the prior written consent of BITX. Any attempted assignment in contravention of this clause shall be null and void. BITX may freely assign or transfer its rights and obligations to any affiliate or as part of a merger, acquisition, or transfer of all or substantially all of its business or assets, provided that such transfer does not materially diminish the rights of the User under this Agreement.
• Relationship of the Parties: Nothing in this Agreement shall be construed to create any partnership, joint venture, agency, or employment relationship between BITX and the User. Each party acts solely in its individual capacity and shall not have the authority to bind or represent the other in any way.
• Third-Party Rights: This Agreement is entered into solely for the benefit of the parties hereto and is not intended to create any rights or remedies in favor of any third party, except where expressly provided or where mandatory law requires otherwise.
• Notices: BITX may provide any notice required under these Terms by email, through the user interface, via announcements on its website, or by postal mail to the address provided by the User. It is the User’s responsibility to ensure their contact information remains accurate and up to date. Notices shall be deemed received (i) within 24 hours of transmission if sent by email or posted on the website, or (ii) within five (5) business days for domestic postal delivery and ten (10) business days for international delivery. Formal notices to BITX must be sent both to operations@bitx.es (or any other address notified for this purpose) and by registered mail or courier to BITX’s registered office as indicated on its website or in the relevant public register. Notices to BITX shall be deemed effective upon receipt.
• Headings and Interpretation: The section headings used in these Terms are for convenience only and shall not affect the interpretation of the clauses. Unless otherwise indicated by the context, words in the singular shall include the plural and vice versa, and references to one gender shall include all genders. The terms “including” and “for example” shall be understood as illustrative and not limiting.

By accepting these Terms and Conditions, the User confirms that they have read, understood, and agreed to all the provisions contained herein. For any doubts, clarifications, or concerns regarding these Terms or the services provided by BITX, the User is encouraged to contact us prior to acceptance. Our team remains at your disposal to ensure the relationship is clear, secure, and mutually beneficial.

Last Update Date: 01 August 2025