Terms and Conditions

1. General Provisions

These Terms and Conditions ("Terms") govern the rights and obligations of "28 APEX" Ltd., UIC 207773514, with its registered office and address of management in Sofia, Republic of Bulgaria (the "Company"), and its clients (the "Client") in relation to the provision of crypto-asset services.

The Company operates as a crypto-asset service provider (CASP) within the meaning of Regulation (EU) 2023/1114 (MiCA), in compliance with applicable European Union and national legislation.

These Terms constitute a legally binding agreement between the Company and the Client and apply to all services provided through the Company's electronic platform.

By registering with the platform and/or using the services, the Client confirms that they have read, understood, and agreed to be bound by these Terms.

2. Definitions

For the purposes of these Terms, "crypto-asset" means a digital representation of value or rights that can be transferred and stored electronically using distributed ledger technology.

"Platform" means the electronic system, including the website and related interfaces, through which the Company provides its services.

"Order" means any instruction submitted by the Client through the platform for the execution of a crypto-asset transaction.

3. Services Provided

The Company provides services consisting of the exchange of crypto-assets for funds, the exchange of crypto-assets for other crypto-assets, the execution of orders on behalf of clients, and the transfer of crypto-assets on behalf of clients.

The services are provided in relation to crypto-assets, including crypto-assets other than asset-referenced tokens, asset-referenced tokens, and e-money tokens.

The service of transferring crypto-assets is not provided in relation to e-money tokens, and the Company explicitly restricts this functionality in accordance with applicable regulatory requirements.

The Company reserves the right to determine which crypto-assets and distributed ledger networks are supported, based on internal risk assessments, technological compatibility, and regulatory considerations.

4. Nature of the Services

The services provided by the Company are of an execution-only nature, whereby the Company acts solely upon the Client's instructions.

The Company does not provide investment advice, recommendations, or any form of financial consultancy, nor does it assess the suitability or appropriateness of the services for the Client.

The Company does not provide custody services and does not hold crypto-assets on behalf of clients for investment purposes; transactions are carried out solely on the basis of specific client instructions.

The Company does not provide liquidity on its own account and does not engage in proprietary trading in relation to client transactions.

5. Establishment of Contractual Relationship

The contractual relationship between the Company and the Client is established upon the Client's acceptance of these Terms through electronic means.

The Company may enter into individual agreements with specific clients, in which case the provisions of such agreements shall prevail over these Terms in the event of any inconsistency.

6. Client Identification and Verification

Prior to providing services, the Company conducts client identification and verification procedures in accordance with applicable anti-money laundering and counter-terrorist financing legislation.

The Client is required to provide accurate, complete, and up-to-date information and all necessary documentation.

The Company may engage third-party service providers for verification purposes and may request additional information where necessary.

The Company reserves the right to refuse the provision of services where the required information is not provided or where there are doubts regarding its accuracy or legitimacy.

7. Client Rights and Obligations

The Client undertakes to use the services in good faith and in compliance with all applicable laws and regulations.

The Client bears full responsibility for the accuracy of the information provided, including wallet addresses and transaction details.

The Client shall not use the services for unlawful purposes, including but not limited to fraud, money laundering, or the circumvention of sanctions regimes.

8. Risks

The Client acknowledges that crypto-assets are subject to significant risks, including but not limited to market volatility, technological risks, operational risks, and the risk of total loss of value.

The Client understands that transactions executed on distributed ledger networks are irreversible and that errors in submitted information may result in irreversible loss of assets.

9. Execution of Orders

The Company executes Client orders subject to the availability of the necessary conditions, including technical feasibility and compliance with regulatory requirements.

The Company reserves the right to refuse, delay, or suspend the execution of an order where there are indications of fraud, legal violations, or risks to security.

10. Fees and Costs

All applicable fees and costs are disclosed to the Client in advance through the platform.

The confirmation of an order by the Client constitutes acceptance of the applicable fees.

11. Complaints

Clients have the right to submit complaints free of charge.

Complaints may be submitted via the platform, by email, or by post.

Complaints are handled in accordance with an internal procedure which is publicly available.

Oversight of the complaints handling process is performed by the Head of the Compliance Function.

12. Limitation of Liability

The Company shall not be liable for damages resulting from the Client's actions, technical issues within distributed ledger networks, or actions of third parties.

The Company does not guarantee uninterrupted or error-free operation of its services.

13. Personal Data Protection

The Company processes personal data in accordance with the General Data Protection Regulation (GDPR) and applicable legislation.

14. Applicable Law and Disputes

These Terms shall be governed by the laws of the Republic of Bulgaria.

Any disputes shall be resolved by the competent courts in the Republic of Bulgaria.

15. Amendments

The Company reserves the right to amend these Terms.

Amendments shall enter into force upon their publication.