Terms of Service

These Terms of Service (hereinafter: the "Terms") are entered into between:

StaBillon sp. z o.o. is a party to these Terms (the Provider) and the controller of personal data in relation to the services provided under these Terms. StaBillon sp. z o.o., registered in Poland (KRS 0000682897, NIP 5272811301, REGON 367554369), has its registered office at Aleje Jerozolimskie 123A, 02-017 Warsaw, e-mail address: Contact Address specified in the "Domains and Addresses" definition

and

a natural person acting as a Consumer, who (i) visits or uses an ATM, the Website, or a website of the Provider's partner where the Provider's interface is made available, and/or (ii) uses the Services offered therein, as defined in the "Definitions" section of these Terms.

StaBillon is a national electronic money institution, operating under the authorization of the Polish Financial Supervision Authority (authorization no. KIPE1/2019), and the sole issuer of electronic money tokens (PLNdt, EURdt) in accordance with Title IV of the MiCA Regulation, included in the register maintained by ESMA.

StaBillon provides the Client with an electronic money service: the issuance of E-Money Tokens (EMT) in exchange for funds, their redemption at par value, and the custody and transfer exclusively of its own EMTs (Art. 60(4) of MiCA). StaBillon operates directly at ATMs — StaBillon is the sole party to the Agreement and the sole service provider to the Client, without the involvement of intermediaries. "Localcoin" is merely a commercial brand of the devices (ATM equipment) used by StaBillon based on an agreement with their technical provider; this provider only supplies the hardware and its technical maintenance, is not a party to the Agreement, does not accept Client orders, and at no time comes into possession of the Client's funds, EMTs, or Digital Assets.

The exchange of EMT for Digital Assets is not provided by StaBillon or by the ATM Operator. The exchange is performed exclusively by a CASP — a crypto-asset service provider authorized under Title V of MiCA in an EU Member State other than Poland, providing services on the territory of Poland on the basis of the notification referred to in Art. 65 of MiCA — with whom the Client enters into an agreement directly by placing an order on the platform of the CASP of their choice from the CASP List (Annex 1).

For the avoidance of doubt: on the territory of the Republic of Poland, only the acquisition (issuance) and disposal (redemption) of StaBillon's own electronic money tokens — PLNdt and EURdt — as well as their custody and transfer by StaBillon as the issuer, take place. Any further action — in particular, the exchange of EMTs for other crypto-assets or other crypto-assets for EMTs — constitutes a separate, optional, second step, performed by a CASP solely upon the Client's instruction and solely for their convenience; the acquisition, holding, or redemption of EMTs is not contingent upon using CASP services.

The process of using the Services may be initiated at an ATM, on the StaBillon Website, or on the website of a StaBillon partner providing the StaBillon interface; regardless of the initiation channel, the sole service provider and contracting party of the Client for the Service is StaBillon. The Client may also store funds in Polish zloty (PLN) or euros (EUR), in the form of stablecoins (EMT tokens) PLNdt and/or EURdt, in the form of electronic money recorded in an account maintained by StaBillon under its national electronic money institution authorization — both permanently and temporarily (e.g., awaiting withdrawal or a subsequent instruction); these funds are subject to protection (safeguarding) in accordance with the Payment Services Act.

These Terms also constitute the rules for the provision of electronic services within the meaning of the Act of July 18, 2002, on the provision of electronic services, and define the rules for using the Website and the services provided electronically by StaBillon.

Definitions

In addition to the terms defined elsewhere in these Terms, capitalized terms have the meanings set forth below, both in the singular and in the plural.

Digital Asset – a virtual currency within the meaning of Article 2(2)(26) of the Anti-Money Laundering Act, being a digital representation of value that is not:

a) a legal tender issued by the National Bank of Poland (NBP), foreign central banks, or other public authorities,

b) an international unit of account established by an international organization and accepted by individual countries belonging to or cooperating with that organization,

c) electronic money within the meaning of the Payment Services Act of August 19, 2011,

d) a financial instrument within the meaning of the Act of July 29, 2005, on Trading in Financial Instruments,

e) a promissory note or a check,

and which is exchangeable in economic trade for legal tender and is accepted as a medium of exchange, and can also be stored, transferred electronically, or be the subject of electronic commerce;

or a "token" being a payment token, utility token, or investment token within the meaning of the Position of the Polish Financial Supervision Authority of December 10, 2020, on the issuance of and trading in crypto-assets; for the purposes of these Terms, an intangible good is considered to be a good representing in digital form one or more rights, which can be issued, recorded, stored, or transferred using a shared electronic recording device that allows for the direct or indirect identification of the owner of such a good.

ATM (Bitcoin ATM): a physical self-service device through which the Provider directly provides the Service, enabling the acquisition of EMTs for cash and the redemption of EMTs (cash withdrawal), as well as — at the Client's instruction — placing an order to exchange EMTs for Digital Assets on the CASP platform chosen by the Client from the CASP List. The devices may be branded with the "Localcoin" trademark, which is the brand of the equipment supplied to the Provider by the ATM Operator acting as a technical provider.

Blockchain: a technology enabling the representation and transmission of digital assets and the tracking of transactions involving such assets.

CASP: a crypto-asset service provider within the meaning of Article 3(1)(15) of MiCA, authorized under Title V of MiCA, having its registered office in an EU Member State other than Poland and entitled to provide crypto-asset services on the territory of Poland on the basis of the notification referred to in Article 65 of MiCA, indicated on the CASP List — who provides the Client with the service of exchanging EMTs for Digital Assets and, to the relevant extent, the custody and transfer of the acquired Digital Assets. The Client enters into an agreement directly with the CASP of their choice, and the CASP services are provided on the basis of separate terms and conditions of that CASP, accepted by the Client directly with the CASP; the Provider is not a party to this agreement.

CASP List: a list of CASPs with whom the Client may conclude an agreement under the model described in these Terms, constituting Annex 1 to the Terms. The current CASP List is made available to the Client on the Website and at the ATM before placing an exchange order. Adding a CASP to the CASP List or removing a CASP from the CASP List is done by publishing an updated Annex 1 and does not constitute an amendment to the Terms requiring the procedure provided for amending the Terms, provided that each CASP indicated on the CASP List meets the requirements of the CASP definition; the updated CASP List is effective from the date of its publication.

ATM Operator (Technical Provider): Coinlab sp. z o.o. with its registered office in Białystok, ul. Jana Henryka Dąbrowskiego 28, 15-872 Białystok, KRS 0000685866, NIP 5423278952 — the technical provider from whom the Provider leases ATM devices branded with the "Localcoin" trademark and their technical maintenance. The ATM Operator is not a party to the Agreement, does not intermediate in the provision of Services, does not accept the Client's orders or statements regarding the Services, and does not provide electronic money services, payment services, or crypto-asset services to the Client, but serves as the first point of contact for the technical maintenance of ATMs and device user support, acting in this respect on behalf of and at the behest of the Provider. At no time does it come into possession of the Client's funds, EMTs, or Digital Assets; the contractual relationship regarding the Services exists solely and directly between the Client and the Provider.

Custodial Wallets: wallets maintained by the Provider used exclusively for the custody and transfer of EMTs issued by the Provider (Art. 60(4) of MiCA): (a) a first custodial wallet, maintained in Poland, to which the Client's EMTs are credited after their issuance, and (b) a second custodial wallet, maintained in another jurisdiction, to which the Client's EMTs are transferred solely for the purpose of executing an exchange order placed by the Client. The value of the EMT remains with the Client until the exchange is executed by the CASP. The Client may at any time instruct the transfer of their EMTs from the Custodial Wallet to the Client's Own Wallet or leave the EMTs in the Custodial Wallet for an indefinite period.

Client's Own Wallet: a wallet (address) on a distributed ledger indicated by the Client other than the Custodial Wallets — a self-hosted (self-custody) wallet, the private keys of which are controlled exclusively by the Client, or a wallet (account) maintained for the Client by a third party, including a CASP, on the basis of a separate agreement between the Client and that entity — to which EMTs are credited or Digital Assets are delivered in accordance with the Client's instruction. The Provider has no access to the Client's Own Wallet and is not responsible for managing it, including the storage and loss of private keys.

E-Money Token (EMT): a token constituting electronic money within the meaning of Art. 3(1)(7) of MiCA, issued by the Provider (PLNdt or EURdt), issued at par value in exchange for funds received, and subject to redemption at any time at par value (Art. 49 of MiCA). EMT constitutes electronic money and does not constitute a Digital Asset within the meaning of these Terms. Electronic money is excluded from the definition of a virtual currency (Art. 2(2)(26)(c) of the AML Act).

Digital Asset Price: the value of Digital Asset A expressed in PLN, EUR, or another fiat currency or the value of another Digital Asset B, consistent with supply and demand, in particular supply and demand on all Digital Asset exchange platforms (i.e., the Digital Asset "market"), updated in near real-time.

Consequently, StaBillon, as a rule, cannot determine the Digital Asset Price in advance or guarantee the future Digital Asset Price or its stability over time. The Digital Asset Price at a given moment is stated on the Website, but this indication does not determine the price of a given Digital Asset at the time a Transaction is executed.

Provider: StaBillon spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, Aleje Jerozolimskie 123A, 02-017 Warsaw, entered into the register of entrepreneurs of the National Court Register under KRS number 0000682897, NIP 5272811301, REGON 367554369 — a national electronic money institution supervised by the Polish Financial Supervision Authority (authorization no. KIPE1/2019), issuer of electronic money tokens PLNdt and EURdt in accordance with Title IV of MiCA; contact e-mail address: Contact Address (see definition of "Domains and Addresses").

Domains and Addresses: a list of internet domains and electronic addresses used in the provision of the Services: (a) Provider's domains: [StaBillon domain — to be completed] along with subdomains; (b) domains of the Provider's partners where the Provider's interface is made available: localcoinatm.com along with subdomains and subpages; (c) Contact Address — an e-mail address used to contact the Provider, including for submitting statements, reports, and complaints: [email protected]; (d) technical support address: [email protected]; phone number: +48 800 013 086. Whenever the Terms refer to the Website, its sections, or an e-mail address, it is understood respectively as the domains and addresses indicated above. SMS communication with the Client is conducted from the number +48 732 126 788. Updating the Domains and Addresses is done by publishing the updated list on the Website and does not constitute an amendment to the Terms, provided it does not worsen the legal situation of the Client; Clients possessing a Portal are informed of a change to the Contact Address on a Durable Medium.

Login Data: the primary method by which registered Clients can access the Services at an ATM.

Civil Code: the Act of April 23, 1964 – Civil Code (Journal of Laws of 2025, item 1071).

Client: a natural person using the Services as a Consumer on their own behalf, and not on behalf of a third-party Entrepreneur.

Consumer: a natural person entering into a legal transaction with an entrepreneur not directly related to their business or professional activity within the meaning of Art. 221 of the Civil Code.

Limits:

a) the amount of Digital Assets or its corresponding value in Fiat Currency that can be purchased, sold, exchanged, withdrawn, or deposited by the Client in a single Transaction,

b) the daily, monthly, or annual amount of Digital Assets or its corresponding value in Fiat Currency that can be purchased, sold, exchanged, withdrawn, or deposited by the Client,

c) the number of Transactions executed by the Client in a given period of time, as determined by the Provider.

MiCA: Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937.

Fee: the remuneration due to the Provider for using the Services.

Consumer Rights Regulations: Act of May 30, 2014, on consumer rights (Journal of Laws of 2024, item 1796).

Entrepreneur – a natural person, legal person, and an organizational unit lacking legal personality, to which the law grants legal capacity, conducting business or professional activity in its own name within the meaning of Article 431 of the Civil Code.

Intellectual Property Rights (IPR): intellectual property rights, including copyright and related rights, as well as industrial property rights, relating to the Services, the Website, or other data made available to the Client by the Provider under the Agreement, which fully belong to the Provider.

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

AML Act: Act of March 1, 2018, on counteracting money laundering and terrorism financing (Journal of Laws of 2025, item 644, as amended).

Agreement: the agreement between the Provider and the Client regarding the use of the Services, consisting of these Terms.

Services: services provided to the Client by the Provider under the Agreement via the Website and ATMs provided by the ATM Operator.

Force Majeure: any force majeure events, such as: natural disasters, war, acts of terrorism, rebellions, riots, embargoes, actions of civil or military authorities, fires, floods, accidents, strikes, epidemics, natural calamities, social unrest, uprisings or revolutions, or other similar events that are unavoidable and cannot be attributed to either Party.

Party: the Client or the Provider.

Website: the website through which the Services are made available. The Provider's interface may also be made available in ATMs and — based on an agreement with the Provider — within the websites of the Provider's partners (including at https://localcoinatm.com/); regardless of where the interface is provided, the Service is provided exclusively by the Provider.

Transaction: any transaction executed at the Client's request via the Website and the Client Portal or via an ATM, concerning Digital Assets. Transactions include:

Purchase Transaction (or Purchase): a transaction in which the Client exchanges a specific amount of fiat currency for a specific amount of digital assets via the website or an ATM.

Sale Transaction (or Sale): a transaction in which the Client exchanges a specific amount of Digital Assets for a specific amount of Fiat Currency via the Website or an ATM.

In the ATM channel, a Purchase Transaction consists of two stages: (1) the issuance of EMTs by the Provider in exchange for cash deposited by the Client (the electronic money stage) and (2) — only if the Client places such an order — the exchange of EMTs for Digital Assets executed by the CASP (the crypto-asset stage). A Sale Transaction proceeds respectively in reverse order, where the withdrawal of funds constitutes the redemption of EMTs by the Provider at par value.

Durable Medium: a medium enabling the Client to store information addressed personally to them, in a way accessible for future reference for a period adequate for the purposes of the information, and allowing the unchanged reproduction of the information stored; the Parties consider e-mails and messages posted in the Client Portal, SMS messages, and printouts issued by an ATM to be a durable medium.

Service: the electronic money service provided by the Provider comprising: the issuance of EMTs in exchange for funds received, the redemption of EMTs at any time at par value (Art. 49 of MiCA), the custody and transfer exclusively of its own EMTs (Art. 60(4) of MiCA), the custody of the Client's funds in PLN or EUR (in the form of electronic money), the acceptance and execution of the Client's payment orders relating to these funds — including withdrawals, transfers, and, as an ancillary service strictly linked to the payment transaction executed or the redemption of EMTs, currency exchange PLN/EUR and the exchange of other currencies (FX) for the purpose of executing the service — the exchange of PLNdt to EURdt and vice versa, executed as a sale or simultaneous redemption and issuance of its own EMTs at par value, the acceptance and execution of the Client's instructions regarding the transfer of their EMTs (Art. 60(4) of MiCA), including to the Client's Own Wallet or a specified address. The Provider also provides a technical interface for transmitting transactional data and self-placing orders, and for the technical transmission (relay) of the Client's orders — and with their separate consent, also the Client's data — to the CASP. For the avoidance of doubt, the Provider does not provide crypto-asset services — it does not exchange crypto-assets and does not receive or transmit orders relating to crypto-assets on behalf of or for the account of Clients.

At ATMs, StaBillon acts directly - StaBillon is the sole party to the Agreement and the service provider to the Client, without the involvement of intermediaries. "Localcoin" is merely a commercial brand of the devices (ATM equipment) used by StaBillon based on an agreement with their technical provider; this provider only supplies the hardware and its technical maintenance, is not a party to the Agreement, does not accept Client orders, and at no time comes into possession of the Client's funds, EMTs, or Digital Assets.

Fiat Currency: legal tender managed by the National Bank of Poland and controlled by the Republic of Poland, as well as any other national or supranational currency issued by a government or central bank, or any other monetary obligation denominated in such a currency that is not a Digital Asset.

2. Subject

StaBillon has created the Website to present the Services it offers.

The Website is also intended to provide Clients with information enabling them to familiarize themselves with StaBillon's activities, its news (events, publications, etc.), as well as tutorials aimed at facilitating the use of the Website and the Provider's Services. It also offers functionalities and/or information allowing Clients to contact StaBillon.

The purpose of these Terms is to define the conditions of access to the Website, as well as the terms of use of the Website and the content and functionalities offered online. These Terms also govern the provision of the Services to the Client in exchange for the Client's compliance with the obligations and guarantees set forth in these Terms.

These Terms constitute the sole binding contractual document for StaBillon, to the exclusion of any other documents, which are purely indicative and have no contractual nature, and to the exclusion of any other possible terms of service, sale, or purchase of the Client, which under no circumstances will be binding upon StaBillon.

StaBillon provides the Services in accordance with the MiCA Regulation, including the provisions of Title IV applicable to issuers of electronic money tokens, and in accordance with the Payment Services Act of August 19, 2011. The obligations of crypto-asset service providers set out in Articles 59-63 et seq. of MiCA and the CASP terms and conditions apply to the services provided by the CASP.

3. Acceptance and Enforceability of the Terms

All Clients accessing the Website are obliged to read these Terms, which are available and can be downloaded in the "Terms and Conditions" section of the Provider's Website and at the ATM.

The Terms may also be sent by the Company electronically or in paper form at the Client's request to the following address: Contact Address. Every update will be published with a clearly visible date.

StaBillon reserves the right to change or modify these Terms solely for valid reasons specified below. Any new version published online shall prevail over and replace any previous versions, printed versions, or those saved in digital or paper format by the Client. Consequently, the Client is obliged to regularly review these Terms. The binding version of the Terms is the version available online at the time of the Client's visit and use of the Website.

Valid reasons for amending the Terms are considered to be: (a) the need to adapt the Terms to new or amended laws (e.g., MiCA, AMLR, AML Act, Payment Services Act, consumer protection regulations) or to decisions, recommendations, or guidelines of supervisory authorities (KNF, GIIF, EBA, ESMA, UOKiK); (b) the need to adapt the Terms to the results of the money laundering and terrorism financing risk assessment carried out by the Provider as an obligated institution, including changes to KYC/KYT requirements, Limits, or verification thresholds; (c) the need to adapt the Services to new technical solutions or security requirements (including cybersecurity and blockchain network availability) or to mitigate the effects of failures or Force Majeure events; (d) technical and organizational changes on the part of the Provider or its suppliers, including changes in identification data, addresses, or communication channels that do not worsen the Consumer's legal situation; (e) the introduction of new or changes to the scope of existing Services. A change to the Terms cannot lead to a restriction of Consumer rights beyond what arises from mandatory provisions of law; Transactions initiated before the effective date of the changes are governed by the previous wording of the Terms.

In all cases, Clients with access to the Portal will be notified of the new Terms taking effect — at least 14 days in advance — by e-mail to the address provided during the creation of the Portal and asked to read them. A Client who is a Consumer may, at their discretion, accept the changes on the terms set forth in these Terms or terminate the Agreement within 14 days on the terms set forth in these Terms.

Executing a Transaction and/or logging into the Portal and/or using the Website and/or Services constitutes acceptance of the current Terms. Therefore, for each executed Transaction or each Service, the Client is subject to the Terms in effect on the date of executing the Transaction or using the Service. It is recommended that the Client keep a copy of the Terms in effect on the date of performing each Service and/or completing each Transaction, regardless of any archiving arrangements implemented by StaBillon.

Clients who do not wish to accept the new Terms may terminate the Terms and delete their Portal in accordance with the conditions set forth below.

The Client declares and confirms that they are over 18 years of age and have full legal capacity to enter into these Terms.

These Terms are concluded for an indefinite period and have no expiration date.

Client's Declarations Prior to Using the Provider's Services

The Client confirms that they have familiarized themselves with the nature, purpose, and functionality of the Website and the Services, as well as the conditions necessary for their use, and the terms regarding the creation of the Portal. The Client confirms that they have requested and obtained all necessary information, particularly regarding the quantitative and qualitative characteristics of the Services, allowing them to assess their suitability for their needs and to enter into the Terms with full awareness.

The Client assumes sole responsibility for the decision to use the Website and the Services and to execute Transactions. StaBillon bears no liability in this regard and cannot be held responsible in this respect.

At the latest at the time the Client who is a Consumer expresses the will to be bound by the Agreement, StaBillon will inform the Consumer on a Durable Medium, in a clear and comprehensible manner, indicating the intent to conclude the Agreement and in a form appropriate to the type of distance communication used, about:

the name, address of StaBillon's registered office, the authority that registered StaBillon's business activity, and the registration number under which StaBillon was registered, and if StaBillon's activity requires an authorization – details of the authority granting such authorization;
the name and residential address (registered office) in the territory of the Republic of Poland of StaBillon's representative, if any;
the name and residential address (registered office) of an entity other than StaBillon providing financial services at a distance, including the operator of the means of distance communication, and the role that this entity plays towards the Consumer and StaBillon;
the essential characteristics of the Service and its subject matter;
the Digital Asset Price or Remuneration, including all its components, such as fees and taxes, and if it is not possible to determine the exact Digital Asset Price or Remuneration – the basis for calculating the Digital Asset Price or Remuneration, enabling the Consumer to verify it;
the risks associated with services concerning Digital Assets, if such risks result from their specific characteristics or the nature of the activities performed, or if the Digital Asset Price or Remuneration depends entirely on movements in the financial market/Digital Asset market;
the rules for paying the price or fees;
the costs, timeframe, and method of providing the Service;
the right and method of withdrawal from the agreement available to the Consumer, as referred to in Article 40 sections 1 and 2 of the Consumer Rights Act, or a statement on the lack of such right and the amount of the price or remuneration that the Consumer is obliged to pay for the actually provided Service in the case referred to in Article 40 section 4 of the Consumer Rights Act, i.e., when the provision commenced with the Consumer's consent before the deadline to withdraw from the agreement;
any additional costs incurred by the Consumer in connection with the use of means of distance communication, provided such costs may arise;
the period for which the price or fee information for digital assets remains binding;
the minimum duration of an agreement for continuous or periodic services;
the place and method of submitting complaints;
the possibility of out-of-court dispute resolution arising from the agreement;
the right of withdrawal referred to in Article 42 of the Consumer Rights Act, and the consequences of such withdrawal, including contractual penalties, or the absence of such a right;
the existence of a guarantee fund or other guarantee systems, if any;
the language used in the relations between StaBillon and the Consumer;
the law applicable to relations between StaBillon and the Consumer before concluding a distance agreement and the law applicable to the conclusion and execution of the agreement;
the court competent to resolve disputes related to the performance of the agreement.

This means that at the latest when the Client, acting as a Consumer, expresses their intention to be bound by the Agreement, StaBillon clearly and comprehensively provides the Client with the information required under the Consumer Rights Act, concerning:

a) StaBillon's identification data,

b) the main characteristics of the Services,

c) the total price of the service inclusive of taxes, and where this cannot be determined precisely – the method of its calculation,

d) the method of communicating with StaBillon,

e) the method and timeframe for executing the Services,

f) the rights vested in the Client, including the right of withdrawal from the agreement or the absence of such right,

g) the rules for filing complaints and out-of-court dispute resolution methods.

Such information is provided to the Client in these Terms, the Personal Data Protection Policy, the Cookie Policy, and the fee schedule available on the Website, and may also be provided in separate documents on a Durable Medium. In the ATM channel, pre-contractual information is presented on the ATM screen before approving a Transaction, and at the Client's request or when required by law — delivered on a Durable Medium (as a printout issued by the ATM, an e-mail, SMS, or a message in the Portal).

Furthermore, the Client is aware that the provision of the Services may be conditional upon the Client accepting the terms and conditions or other contractual documentation of one or more third parties, provided that the Client may be required to enter into an agreement directly with third parties.

Communication with the Client and Durable Medium

All communication related to the conclusion, execution, and amendment of the Agreement, including the transmission of information required by law, in particular consumer rights protection laws and laws regarding Digital Asset services, will be conducted via:

a) e-mail, to the e-mail address provided by the Client when creating the Portal; and/or

b) messages made available to the Client in their Portal on the Website.

The Client acknowledges that e-mails and messages made available in the Portal constitute a Durable Medium within the meaning of applicable law and these Terms and agrees to receive all information and documents required by law in this manner, including pre-contractual information and confirmations of concluding the Agreement.

Access to the Client Portal is protected by at least a combination of a unique identifier (e-mail address) and a password set by the Client. To increase security, StaBillon may introduce additional authentication mechanisms (in particular two-factor authentication), about which it will inform the Client via a Durable Medium. The Client is obliged to use the authentication mechanisms in accordance with StaBillon's instructions.

4. Description of Services

StaBillon provides technical support to supply information and assistance regarding the Services. Support is provided in a two-tier model:

First line of support (technical): Handling of tickets regarding the technical operation of the devices (ATMs) is provided by the ATM Operator (Technical Provider).

Second line of support (substantive and legal): Matters relating to transactions, complaints, legal issues, and settlements are handled directly by StaBillon.

The ATM Operator, acting as the first line of support, is authorized to provide explanations regarding the operation of the devices. In matters beyond this scope or requiring a decision from the Provider, tickets will be escalated by the ATM Operator to StaBillon.

The Client is solely responsible for their decisions regarding the use of the Services, in particular the decision to execute or refrain from Transactions involving Digital Assets, according to their own investment horizon and risk tolerance, and is solely responsible for the consequences of any Transactions involving Digital Assets. StaBillon does not provide investment advice, does not manage a portfolio, and does not provide any personalized recommendations regarding transactions or holding digital assets. It also does not provide financial or strategic advice.

4.1. Services Available Without Creating a Portal

The Website along with its subpages is accessible to all internet users. The purpose of these pages is to provide Clients with information to understand StaBillon's operations, news (events, publications, etc.), as well as tutorials to facilitate the use of the Website and Services. The Website also offers features and/or information enabling Clients to contact StaBillon.

4.2. Services Available Subject to Creating a Portal

To use the Services described below, the Client is required to create a Portal in accordance with the provisions of the "Creating a Client Portal" section of these Terms.

4.2.1. Access to and Use of the Portal

The Portal allows the Client to:

(i) view historical buy/sell transactions with fiat equivalents solely for informational purposes (PLN/EUR for PL, if available) and export to CSV,

(ii) check identity verification status and spending limits,

(iii) an ATM locator,

(iv) links to existing StaBillon services,

(v) basic profile/preferences and logout.

The Portal may contain links to StaBillon services where transactions can be initiated; transactions are not executed within the Portal. The information is for informational/self-tax-reporting purposes only; it does not constitute an official statement; feature availability varies by country; the Portal does not store any funds or digital assets.

4.2.1.1. A Purchase Transaction proceeds as follows:

a) The Client deposits cash at an ATM or — if the process was initiated on the Website or a partner's website — transfers funds using another available method (e.g., bank transfer, BLIK, or card); upon accepting the deposit, the Provider issues EMTs (PLNdt or EURdt) to the Client at par value and credits them to the first Custodial Wallet maintained for the Client in Poland or — according to the Client's instruction — transfers them to the Client's Own Wallet. From the moment of acceptance, the cash constitutes funds received by the Provider in exchange for issued electronic money and is subject to safeguarding under the Payment Services Act;

b) identification and verification of the Client's identity (KYC/AML) for the Service is carried out by the Provider as an obligated institution — at the ATM, on the Website, or on the Client's mobile device (smartphone), including by continuing a process on the Client's device that was started at the ATM —, using an external identity verification provider;

c) if the Client intends to exchange EMTs for Digital Assets, they select a CASP from the CASP List and place an exchange order directly on the web platform of that CASP. Before placing an order, the CASP List is made available to the Client, and the Client receives explicit notice that they are leaving the Provider's electronic money service and are using the CASP service subject to that CASP's terms; placing an exchange order is a separate, optional step made purely for the Client's convenience, on which the acquisition, holding, or redemption of EMTs does not depend; To the extent necessary, the Provider may provide currency exchange (FX) services for the purpose of executing the Client's order on the CASP platform.

d) to execute the Client's instruction, the Provider - as part of the service of transferring its own EMTs (Art. 60(4) of MiCA) - transfers the Client's EMTs from the first to the second Custodial Wallet — along with the data required under Regulation (EU) 2023/1113 (Travel Rule). Optionally, at the Client's request, the Provider transmits the content of the payment order and/or exchange order placed by the Client to the CASP. This transmission is purely technical in nature (message relay); neither the Provider nor the ATM Operator accepts or transmits orders relating to Digital Assets for their own account, they do not execute the exchange and are not a party to it;

e) the CASP executes the exchange, notifies the Provider's IT system of its execution, and delivers the Digital Assets to the wallet specified by the Client (the Client's Own Wallet — self-hosted or maintained for the Client by the CASP). EMTs received by the CASP as payment are subject to redemption by the Provider at par value.

f) if the Client does not have an account with the selected CASP, the Provider — solely based on separate, explicit consent from the Client — transmits the Client's identification and verification data to that CASP to the extent necessary to set up a Client account with the CASP and execute the placed order; the acquired Digital Assets then remain credited to the Client's account (wallet) maintained by the CASP until the Client issues a different instruction directly to the CASP (including an instruction to transfer to the Client's Own Wallet).

In the case of a Sale Transaction, the Client's Digital Assets are exchanged by the CASP for EMTs, and then the EMTs are subject to redemption by the Provider at par value (Art. 49 of MiCA). Instead of redemption, the Client may order the received EMTs to be credited to the Custodial Wallet or transferred to the Client's Own Wallet. The funds from the redemption are disbursed to the Client in cash at the ATM or — according to the Client's choice and available methods — by bank transfer, BLIK, to a card, or by another available method. Until disbursed, funds from redemption may be stored as electronic money on an account maintained by the Provider.

The above provisions apply accordingly to all available variants of using the Services — regardless of the initiation channel (ATM, Website, partner website), the direction of the Transaction, and the sequence of steps — in particular when the Client: (i) acquires EMTs and stores them on a Custodial Wallet or on the Client's Own Wallet, (ii) in a separate, optional step, instructs a CASP to exchange EMTs for other crypto-assets or other crypto-assets for EMTs, specifying the delivery location for the acquired assets, (iii) presents EMTs for redemption, or (iv) stores funds in the form of electronic money on an account maintained by the Provider. In each variant on the territory of the Republic of Poland, the Provider solely issues (sells), stores, transfers, and redeems (buys back) its own EMTs (PLNdt, EURdt) and performs electronic money activities, while any crypto-asset exchange constitutes a separate CASP service executed upon the Client's instruction.

An agreement to execute a given Transaction is concluded at the moment the Client approves the Transaction on the ATM screen or in another available channel — after the Client has been provided with the Terms, pre-contractual information, and information about the Fees (and regarding the crypto-asset stage — the price and terms applied by the CASP). Confirmation of the conclusion and execution of the Transaction is provided to the Client on a Durable Medium.

A Client wishing to execute a Purchase or Sale Transaction is obliged to follow the procedure set out on the Website, and is obliged to verify whether the offered Service meets their needs (in particular regarding the type and operating model of the offered Services, the types of Digital Assets that can be the subject of a Purchase or Sale Transaction, accepted payment methods, contractual terms applicable to the offered Services, exchange rates, and the amount of Fees associated with the Services, etc.).

StaBillon shall under no circumstances be liable for any consequences, in the context of Purchase or Sale Transactions, of delays in sending and receiving funds (fiat currency) to the Client's bank portal, or delays in StaBillon receiving funds in the case of a Purchase, as such operations are carried out by an authorized third-party payment service provider.

Similarly, Purchase or Sale Transactions may be subject to minimum or maximum Limits, which in certain cases may prevent the Client from carrying out certain Transactions.

The Client expressly accepts these risks and acknowledges that StaBillon bears no liability in this regard, particularly in cases where the Client is unable to proceed with a Sale or Purchase Transaction involving some of their Digital Assets, for example due to a decision not to list or not to accept certain Digital Assets or due to any Minimum Limits that may be set (see so-called "liquidity risk").

The Client is also aware that Purchase and Sale Transactions may be subject to exchange rates and fees or commissions, as a result of which:

in the case of a Purchase Transaction, the value of Digital Assets actually acquired is inevitably lower than the Fiat Currency equivalent amount actually paid by the Client;
in the case of a Sale Transaction, the Fiat Currency amount received by the Client is inevitably lower than the Digital Asset equivalent amount actually deducted from their Wallet

which the Client expressly accepts. The Client is obliged to familiarize themselves with the financial terms of a Purchase and Sale before executing such a Transaction and acknowledges that StaBillon bears no liability in this regard.

Finally, the Client undertakes not to attempt to execute a Sale Transaction involving a value of Digital Assets higher than the value actually held in the Wallet to which the Sale relates.

4.3. New Services, Payment Services, and the Role of the Payment Service Provider

StaBillon may expand the scope of its Services by adding new services on the Website, regardless of whether these Services are available to all Clients or only via the Client Portal. Such new Services will be deemed an integral part of the Services defined in the "Definitions" article and will be governed by these Terms. Unless stated otherwise, the Client may use the new Services from the moment they are actually made available on the Website, provided that, if necessary, the Client has previously created a Portal.

Deposits and withdrawals of fiat currencies associated with the use of the Services may be carried out via a Payment Service Provider. In this case, the execution of payment services is subject to the Payment Service Provider's terms and conditions, provided to the Client by that entity, subject to mandatory provisions of law.

The Provider, as a national electronic money institution, provides the Client with the service of issuing electronic money (EMTs) and its redemption. Funds received in exchange for issued EMTs are safeguarded on a segregated account, in accordance with the Payment Services Act. To the extent that deposits or withdrawals are executed with the involvement of a third-party Payment Service Provider, their execution is subject to that entity's terms and conditions.

The Provider stores the Client's EMTs on Custodial Wallets (Art. 60(4) of MiCA), unless the Client instructed the transfer of EMTs to the Client's Own Wallet; the value remains with the Client until the Digital Assets are delivered by the CASP or the funds from EMT redemption are disbursed. The Provider does not store the Client's Digital Assets. At no time does the ATM Operator come into possession of the Client's funds, their EMTs, or Digital Assets; cash deposited at an ATM upon acceptance constitutes the Provider's funds received in exchange for issued electronic money.

4.4. Service Development

Without prejudice to the consumer rights provided for in point 3 of these Terms, StaBillon may at any time and without notice modify, add to, develop, improve, or adapt the Website and the Services, and more generally, the Services offered, in order to improve the functionalities offered on the Website or within the Services. This may include, in particular, deploying updates, new versions, or adapting or modifying existing functionalities. Where applicable and as far as possible, the Client is obliged to adapt their IT resources to the changes on the Website and in the Services to be able to use them under optimal conditions.

Furthermore, to the extent that certain changes, updates, new versions, modifications, etc., may be introduced, particularly to ensure business continuity of the Website and Services, the Client may not refuse to accept the changes, updates, new versions, or modifications introduced by StaBillon.

Besides StaBillon's ability to introduce certain changes to the functionalities offered on the Website or within the Services, StaBillon may also be required, at any time and without prior notice, to cease providing certain Services. In the event of the permanent removal of one or more existing Services, StaBillon will use its best efforts to notify Clients of such a change with reasonable notice and, where possible, offer alternative solutions.

In the event of the final removal of all Services, StaBillon or the Client may terminate this Agreement on the terms set out in the "Termination" article.

4.5. Technical Support

StaBillon provides technical support to supply information and assistance regarding the technical aspects and functionalities of the Website and Services.

StaBillon does not provide investment advice, does not manage a portfolio, and does not provide any personalized recommendations regarding transactions or holding digital assets. It also does not provide financial or strategic advice.

Such support is available via:

– e-mail address: specified in the "Domains and Addresses" definition

– live chat on the website

– contact phone number: +48 800 013 086

Support hours:

Mon. - Fri.: 24 hours

Saturday: 10:00 AM - 6:00 PM

Sunday: 10:00 AM - 6:00 PM

StaBillon will use its best efforts to respond to the Client's request within a reasonable timeframe and, if possible, provide an answer that effectively resolves or leads to the resolution of the Client's request.

StaBillon furthermore does not provide brokerage services in relation to digital assets, and in particular does not provide strategic advice, trading advice, or any other form of advice.

Unless these Terms provide otherwise, Transactions are executed autonomously by the Client, who bears full responsibility for any Transactions regarding Digital Assets and for reviewing all information made available by StaBillon before concluding any Transaction involving Digital Assets.

5. Terms of Use of the Website and Services

5.1. Access to the Website and Services

To access the Website, Portal, and Services, the Client must have adequate hardware and telecommunications resources, as well as an internet connection. The Client bears sole responsibility for the costs associated with such hardware and access (and for the effectiveness, efficiency, and speed of such access).

The Client undertakes to use the functionalities of the Website, Portal, and Services in accordance with these Terms and applicable legal regulations, in particular anti-money laundering and terrorism financing regulations, consumer protection laws, personal data protection laws, and regulations concerning Digital Assets.

Furthermore, the Client acknowledges that they are responsible for ensuring that their access to and use of the Website and Services, as well as the execution of Transactions, comply with the law applicable to the Client (in particular with the law of the country of residence or the place from which they use the Services). StaBillon does not guarantee that the Services comply with the laws in force in countries other than Poland and in no way undertakes to take actions on behalf of Clients to ensure such compliance.

5.2. Nature of the Content Posted on the Website

The Company undertakes to provide Clients with clear, accurate, and non-misleading information.

Content (such as information, elements, documents in any form, in particular texts, drawings, still or animated images, logos, sounds, graphics, photos, and files) made available and/or disseminated on the Website is purely informational.

However, the content of the Website should not be considered binding or a substitute for the Client's personal judgment and should not be the sole basis for decisions made by the Client.

5.3. Generating Links to the Website

StaBillon reserves the right to include links on the Website that provide access to websites, subpages, or applications other than those located on the Website, and to redirect Clients to other websites, subpages, or applications.

Clients are formally informed that the websites, web subpages, or applications they can access via these links do not belong to StaBillon, which reserves the right to remove the aforementioned links offered via its Website to third-party applications or websites if they contravene applicable law or StaBillon's values. StaBillon bears no liability for Clients' access via links provided on the Website to third-party websites or other resources available on the Internet, nor for the content of information provided by those websites or other third-party resources accessed by activating the aforementioned links.

5.4. Availability of the Website and Services

StaBillon makes every effort to provide high-quality services and allow the Client to use the Website and Services under optimal conditions. In principle, the Website and Services are available 7 days a week, 24 hours a day. However, StaBillon is not bound by an obligation of result, but only an obligation of means, and does not guarantee availability, optimal performance, or speed of the Website or Services, nor their constant and uninterrupted availability.

The Client is hereby informed and accepts that access to the Website and/or Services may be delayed, modified, prevented, or interrupted as a result of the following events:

force majeure;

a technical problem or difficulty related to the functioning of (i) the Internet and/or the blockchain;

unavailability or random access to IT systems, applications, websites, or platforms used by StaBillon's partners (e.g., liquidity providers, KYC (Know Your Client) or KYT (Know Your Transactions) service providers, or other IT systems, applications, websites, or platforms used by StaBillon and/or its partners to provide the Services;

unavailability or loss by the Client of the Identifiers allowing access to the Portal;

illegal, malicious, or unfortunate activities (including actions resulting from the activities of "cybercriminals" or "hackers," logical or other attacks, such as computer viruses, malware, etc.) aimed at or resulting in damage to the IT systems, applications, websites, or platforms of the Client; StaBillon, its partners (including KYC (Know Your Client) or KYT (Know Your Transactions) service providers) aimed at or resulting in damage to the IT systems, applications, websites, or platforms of the Client, StaBillon, its partners (including KYC (Know Your Client) or KYT (Know Your Transactions) service providers) or platforms used by StaBillon or its partners to provide the Services.

Furthermore, StaBillon reserves the right to close access to all or part of the Website and/or suspend the provision or delivery of all or part of the Services in the event of one of the aforementioned scenarios or in the event of a threat or danger to its human resources (e.g., staff members, internal or external consultants, or other individuals – staff members or internal or external consultants – working for StaBillon or for an entity within the group of companies to which StaBillon belongs) or its technical resources of any kind.

The Website may be temporarily closed without prior notice or compensation, and access to it, the Services, or their functionalities may be limited, to carry out technical, operational, or other interventions necessary for their proper functioning (e.g., testing, maintenance, control, troubleshooting, operational modifications or changes, evolution, etc.), updates, deployment of a new version, or any other operation deemed necessary by StaBillon, updates, deployment of a new version, or any other operation deemed necessary by StaBillon or its partners (including KYC (Know Your Client) or KYT (Know Your Transactions) service providers), which the Client accepts.

StaBillon bears no liability for any interruptions in the functioning of the Website and/or Services caused by one of the events listed in this "Availability of the Website and Services" article.

5.5. Technical Requirements and Maintenance of the Website and Services

The Client declares and confirms that they have the technical competence to use the Website and the Services. In this respect, the Client guarantees that they possess the knowledge and skills necessary to correctly use the Website and Services, including the Portal, enabling them to use the functions offered by the Website and Services in accordance with applicable legal regulations.

The Client also undertakes to take appropriate measures to ensure the security of their hardware and/or data and/or content and/or software against contamination by viruses, malicious code, or other harmful technologies or logic infections and to ensure that such viruses are not introduced to the Website.

The Client undertakes not to disrupt the proper functioning of the Website or the Services and not to undertake any actions that could compromise the computer security of StaBillon or any of StaBillon's partners (including KYC (Know Your Client) or KYT (Know Your Transactions) service providers). The Client undertakes not to use any devices or software that could interfere, disrupt, or interrupt the normal operation of the Website or Services or that would impose a disproportionate load (in terms of hosting volume, bandwidth, etc.) on the Website.

The Client also undertakes not to use, for commercial purposes or as expressly prohibited, all or part of the information or data contained on the Website, and not to use robots, in particular crawlers or spiders, software, automated systems, scripts, programs, web searching or downloading applications, or any other means enabling the extraction or indexing of all or part of the content of these applications. In particular, crawling, scraping, and screen scraping are expressly prohibited.

The content contained on the Website may not be downloaded, collected, copied, altered, modified, deleted, distributed, sent, transmitted, rented, sold, transferred, used in whole or in part, and in any way without StaBillon's express prior written consent.

The Website is an automated data processing system. The same applies to Client Portals. The Client is prohibited from fraudulently accessing or maintaining access to all or part of the Website or Portal that is not their property. The Client is prohibited from using any access method other than the interface provided by StaBillon. If such a method is detected or if the Client inadvertently enters a restricted access area (for example, another Client's Portal) without authorization, the Client undertakes to immediately notify StaBillon by e-mail at: Contact Address, so that StaBillon can take all necessary measures.

StaBillon reserves the right to take any actions or bring any claims necessary to prevent, stop, and penalize any infringements of the Website, the Website's content, the Portal, or the Services, including taking legal action without prior notice.

The Client bears sole liability towards StaBillon or its partners (including KYC (Know Your Client) or KYT (Know Your Transactions) service providers) for any damages arising from accessing and using the Website, Portal, and Services.

Any violation by the Client of the provisions of this article constitutes a material breach, which may result in the termination of the Terms without notice, exclusively to the Client's detriment, as well as a permanent ban on the Client's access to and use of the Website and Services.

5.6. Rules for Using the Website and Services

The Client is obliged, throughout the period of using the Website or Services, to comply with applicable laws (regarding tax returns and/or social security contributions, which must be filed in connection with the execution of specific Operations and for which the Client is solely responsible), as well as with instructions, information, and messages from StaBillon, provided in particular via these Terms, the Website, or the Client Portal. In this regard, it should be emphasized that the Client is obliged to take all necessary steps regarding their tax obligations (such as capital gains declarations, for example) and social security obligations, and StaBillon under no circumstances takes such steps on behalf of Clients.

Furthermore, the Client undertakes not to disrupt, negatively affect, or prevent the use of the Website or Services by any other Client (regardless of whether they are a Client).

The Client is prohibited from using the Website or Services to engage in practices aimed at or resulting in market manipulation (such as wash trading, cross trading, spoofing trading, front running, sell wall, dark pool, pump-and-dump, etc.), regardless of whether such practices are explicitly prohibited by applicable laws and regulations.

The Client is also prohibited from using the Website or Services to launder money, operate financial pyramids, or engage in other risky or illegal activities or to participate in such activities.

Furthermore, any commercial use of data, in particular market data, obtained or made available via the Website and/or Services is prohibited, as is copying, extracting, etc.

The Client grants StaBillon and StaBillon's partners (including KYC (Know Your Client) or KYT (Know Your Transaction) service providers) permission to temporarily monitor digital assets in the client's wallet or held on an exchange platform when necessary to provide services.

Any violation of the provisions of this article by the Client constitutes a material breach that may result in the termination of the Terms without notice, exclusively to the Client's detriment, as well as a permanent ban on the Client's access to and use of the Website and Services.

The Client is informed that StaBillon may voluntarily disclose information and data concerning the Client or generated by the Client to law enforcement authorities in any country or jurisdiction without needing to request or seek the Client's prior consent.

5.7 General Rules Applicable to the Services

5.7.1 General Limitations on Using the Services

The Services are available to Clients whose Portal has been approved by StaBillon and which was not and is not the subject of any proceedings, sanctions, restrictions, closure, or deletion.

StaBillon further reserves the right, in order to decide whether a given Service can be executed by the Client, to request additional, specific information and/or documents from the Client.

Furthermore, StaBillon reserves the right, without prior notice and without the Client's right to compensation, to refuse to execute a Transaction ordered by the Client, to cancel a Transaction ordered by the Client, in the event the Client breaches their duties or obligations under these Terms or if StaBillon determines there is sufficient evidence suggesting that the Client may breach their duties and obligations under these Terms, or:

in the event of detecting unusual or suspicious activity on the Client's Portal or doubts regarding the Client's identity;
in the event of detecting or receiving a report of unauthorized access to the Client's Portal;
if requested by a competent authority (request, court decision, ongoing investigation, etc.);
if the Client fails to provide additional information or documents requested by StaBillon;
in the event of inappropriate behavior and/or misconduct on the part of the Client.

StaBillon also reserves the right, in order to prevent fraud and combat illegal or fraudulent activities, to impose Limits on the Client individually on the conditions defined below and/or to restrict or limit the Client's use of specific Services.

StaBillon may lift these restrictions if it considers that the reasons and premises that led to their introduction have ceased, provided the Client supplies any information and documents that StaBillon may request. Furthermore, Fees may be charged/invoiced to the Client in accordance with the provisions of the "Financial Terms" article.

5.7.2 Limitations Arising from Digital Assets Available for a Given Service

The Client may execute Transactions on various Digital Assets offered/accepted on the Website. The list of Digital Assets accepted on the Website is available on the Website and may be subject to change at any time without notice. In the event of a Digital Asset being permanently delisted from the Website, StaBillon will make every effort to notify Clients of this change in advance and enable the Client to execute Purchase or Sale Transactions of the aforementioned Digital Assets.

Furthermore, not all Services are available for all types of Digital Assets offered on the Website, but some are only available for types of Digital Assets specified as such on the Website. Consequently, some Services may only be available subject to using specific types of Digital Assets. The Client must therefore, via their Portal, and more generally via the Website, ensure which Digital Assets they can use within the Services they wish to use, particularly when using these Services.

5.7.3 Limitations Arising from Setting Limits

The Client may use the Services provided they comply with the Minimum and Maximum Limits set by StaBillon, for example, for certain Transactions and for certain types of Digital Assets, in accordance with the details contained in the "Fees" section on the Website and/or information contained in the Client Portal, in the event that a Maximum or Minimum Limit has been imposed on them personally (or not) by StaBillon. Changes to the Limits take place for valid reasons indicated in the Terms and are published on the Website; Clients possessing a Portal are informed of changes on a Durable Medium, and changes do not apply to Transactions initiated before they take effect. Therefore, the Client is requested to familiarize themselves with the minimum and maximum limits applicable at the time of executing the Transaction and undertakes to abide by them.

StaBillon may also impose a General Limit on all Clients or all their Transactions, or for example on all Transactions executed on a specific type of Digital Asset. Clients will be informed of the existence of such Limits via the Website, in the "Fees" section.

Changes to the Limits take place for valid reasons indicated in the Terms and are published on the Website; Clients possessing a Portal are informed of changes on a Durable Medium, and changes do not apply to Transactions initiated before they take effect. Therefore, the Client is requested to check the Limits applicable to them at the time they intend to execute a Transaction and undertakes to abide by them.

5.8 Risks Associated with the Services

The Client acknowledges that Transactions executed under the Services involve risks for which StaBillon bears no liability:

macroeconomic risk: changes in the macroeconomic situation may lead, among other things, to unusual price fluctuations that could affect the Client;
political/fiscal/regulatory risk: changes in applicable laws and regulations may lead, among other things, to unusual price fluctuations, or even to a review of the terms of use of the Website and the terms of provision and use of the Services, which could affect the Client;
reversal risk: due to the nature of Digital Assets and the irreversibility of on-chain Transactions, all Transactions concluded with the Company are generally final and non-refundable; however, the irreversibility of a Transaction does not limit the Client's right to redeem EMTs at par value (Art. 49 of MiCA);
volatility risk: Digital Assets are subject to high market volatility, meaning that Transactions involving Digital Assets are exposed to an exceptionally high risk of volatility. Furthermore, Transactions are executed 24/7 without interruption and without limits on price increases or decreases, meaning that the price of Digital Assets can be subject to sudden fluctuations, resulting in a partial or total loss of Clients' assets. Buying and selling Digital Assets involves substantial risk: Clients are advised never to buy more than they can afford to lose;
operational risk: hardware, software, or network failures (Internet, telecommunications, electronic communication, telephony, etc.) can in some cases result in the loss of digital assets;
risks caused by force majeure;
regulatory risk: the risk that StaBillon will be unable to continue its operations due to changes in laws or regulations, including new laws or regulations in a given country or jurisdiction, including the Client's place of residence or stay or the place where StaBillon is registered, has its registered office or main place of business;
risk of theft or loss of private keys and other operational errors (e.g., risk of the Client's identifiers being stolen or lost), which could result in a partial or total loss of digital assets;
liquidity risk: the exchange of Digital Assets into Fiat Currency is not always guaranteed, nor is the exchange into another type of Digital Asset;
tax risk: the Client is responsible for determining the taxes they are subject to in connection with investments and operations executed via StaBillon's services. The Client is obliged to declare and pay all taxes and other fees they are subject to in connection with executed transactions.

The aforementioned volatility, liquidity, and price risks concern Digital Assets and the crypto-asset stage executed by the CASP. The EMT is issued and redeemed at par value and is not subject to price volatility risk against the currency in which it is denominated. Funds received in exchange for EMTs are protected in accordance with the Payment Services Act; however, an EMT is not a bank deposit and is not covered by the Bank Guarantee Fund scheme.

StaBillon also emphasizes that digital assets and blockchain are new technologies subject to specific rules that differ from traditional financial systems, and digital assets are highly volatile. Consequently, any use of digital assets, whether as an investment or as a cash equivalent, carries risks that the Client must factor into the Portal.

The Client is obliged to ensure they have the knowledge and training regarding the operation and characteristics of Blockchain technology and digital assets.

In particular, StaBillon provides Clients with information and tutorials to facilitate the use of the Website and Services. However, we encourage Clients to use various sources of information and visit websites other than StaBillon's Website for information and training on the risks associated with the Services, noting that the information and details contained on the Website are not exhaustive or necessarily up-to-date and are purely for informational purposes.

Users must therefore exercise extreme caution when using the Website and Services and ensure they possess all skills and knowledge, particularly technical and financial, necessary to handle Digital Assets. StaBillon explicitly reminds Clients that past performance does not guarantee future results, and the Purchase and Sale of Digital Assets involves the risk of partial or total loss of capital. In all cases, Clients are advised to consult experts specializing in financial, legal, or tax advisory services prior to executing any transaction involving Digital Assets.

The provisions of this article do not exclude or limit StaBillon's liability arising from mandatory provisions of law, in particular the MiCA Regulation and the "Liability of the Parties" section of these Terms.

6. Terms of Use of the Client Portal

6.1 Creating a Client Portal

To create a Portal, the Client must:

fill in the required fields of the online form and provide the requested information, including (but not limited to): first name(s) and surname, e-mail address, phone number, date of birth;
provide the documents required for this purpose online, in accordance with the obligations set out in the "Know Your Client" and "Know Your Transactions" sections of these terms.

The information and documents indicated above, as well as their technical parameters (format, size, etc.), may be subject to change over time. A full and up-to-date list of the information and documents, along with their technical parameters, which the Client must provide when applying to create a Portal, is made available to the Client where such information and documents are requested by StaBillon or any external service provider contracted by StaBillon to perform these activities.

Failure to provide such information and documents will result in the Client Portal not being created, and the Client will be unable to use Services requiring the prior creation of such a Portal. The Client confirms the truthfulness and accuracy of the information provided (including documents provided automatically or upon request) when creating the Portal, and StaBillon will be entitled to hold the Client or any involved person liable in the event the information provided turns out to be false, inaccurate, or misleading. The Client is obliged to provide truthful identification data (e.g., real name and surname) and contact details. The Client is also obliged, where applicable, to update the provided information to ensure its accuracy at all times, providing guarantees to StaBillon in this respect. StaBillon shall under no circumstances be liable for any difficulties encountered by the Client, for example in accessing the Portal or using the Website or Services, that could be directly or indirectly related to the Client providing false or incomplete information or failing to update this information. StaBillon may condition the use of the Services on the Client providing up-to-date information and documents (in particular a valid identity document), and even additional information or documents (proof of source of funds, answers to a KYC questionnaire, proof of "client status verification" / "proof of client status", proof of address, etc.). Providing false or incomplete information or false documents, as well as the Client's failure to update such information or documents, constitutes a serious breach by the Client of these Terms, entitling StaBillon to terminate the Terms and delete the Client Portal without notice, in accordance with the "Notice – Termination" article.

StaBillon may also request additional information and/or documents if the Client requests a modification of the information concerning their Portal.

6.1.1 Conditions for Creating a Client Portal

Only one natural person can be the owner of a Portal, and each natural person can be the owner of only one Portal.

Each natural person wishing to create a Portal must be over 18 years of age, possess full legal capacity, and the capacity to incur obligations in accordance with these Terms. Creating a Portal may also be restricted to specific countries, depending on the KYC (Know Your Client) process implemented by StaBillon or an external service provider (see the "Know Your Client" and "Know Your Transactions" article herein). The Client is responsible for ensuring compliance with these conditions.

The content of the above section and the eligibility conditions or restrictions regarding the creation of a Portal may be subject to change at any time, at StaBillon's sole discretion, in particular, but not exclusively, to comply with legal or regulatory obligations. StaBillon is not liable for the consequences of restrictions (such as refusal to create a Portal or closure/deletion of a Client Portal), even new ones, which may apply in the Client's country of residence, citizenship, or establishment, or which may arise from legal or regulatory obligations.

6.1.2 Client Identity Verification (Know Your Client) and Transaction Monitoring (Know Your Transactions)

The information provided by the Client to create a Portal is used to verify their identity, as part of StaBillon's "Know Your Client" (hereinafter "KYC") program, and also to prevent or detect any attempts or activities related to fraud, corruption, money laundering, or terrorism financing, and more generally – any potential illegal or fraudulent activities. This may include additional processes, such as meeting requirements for the Client's "proof of life" or "liveness" checks.

The Company's request for the Client to provide this information results, among other things, from the Company's obligations regarding anti-money laundering and terrorism financing within the meaning of the Anti-Money Laundering and Terrorism Financing Act (AMLA). Therefore, the Client undertakes and guarantees to StaBillon that they will comply with the KYC process and answer any questions and provide the information required for this purpose.

The obligated institution within the meaning of the AML Act regarding the Service (issuance, custody, transfer, and redemption of EMTs) is the Provider, who carries out the identification and verification of the Client's identity at the ATM, on the Website, or on the Client's mobile device (smartphone) — including by continuing a process on the Client's device that was started in another channel. The CASP applies its own customer due diligence (CDD) measures, obligations arising from Regulation (EU) 2023/1113 (Travel Rule), and verification of self-hosted wallets with respect to the crypto-asset stage. Activities of identifying and verifying the Client's identity are not entrusted to the ATM Operator.

StaBillon may outsource KYC activities, and in particular Client identity verification, to an external service provider. In any case, the Client is obliged to comply with all instructions given by StaBillon and/or this service provider.

Furthermore, StaBillon may use transaction tracking and analysis solutions (hereinafter referred to as "KYT") to better detect anomalies and prevent or detect any attempts or activities related to fraud, corruption, money laundering, or terrorism financing, and more generally, any potentially illegal or fraudulent activities or actions, which the Client acknowledges and accepts.

StaBillon may outsource KYT handling to an external service provider. In any case, the Client is obliged to comply with all instructions given by StaBillon and/or this service provider.

Consequently, it is specified that KYC and KYT operations may result in refusing the Client the use of certain Services or the execution of certain Transactions, with this decision being made at StaBillon's sole discretion and carrying no liability on its part. Refusal to execute or cancellation of a Transaction may occur in the case of reasonable suspicion of splitting transactions to bypass Limits or verification thresholds (so-called structuring).

6.1.3 Prohibitions Regarding the Client Portal

Creating or opening a Portal is prohibited for any Client whose Portal was previously closed by StaBillon.

A Client who requests the creation of a Portal guarantees that their use of the Website and Services will not expose StaBillon to any sanctions and will not violate any applicable legal regulations concerning the fight against terrorism, corruption, financing the proliferation of weapons of mass destruction, and money laundering. The Client guarantees that they:

are not subject to any bans on using the Services arising from statutory or executive regulations or, for example, from an administrative or judicial decision;
are not subject to restrictions on access to financial services, such as those adopted by the United Nations, the Council of the European Union, the United Kingdom, the United States, Poland, or any other country or jurisdiction in the fight against terrorism, corruption, financing the proliferation of weapons of mass destruction, and money laundering;
are not on sanction lists maintained, inter alia, by OFAC, nor on the United States Department of Commerce's Denied Persons List, nor on any sanction list or list of designated persons or countries maintained by the United Kingdom, the United States of America, Poland, or any other country or jurisdiction.

Any violation by the Client of the provisions of this "Creating a Client Portal" article constitutes a material breach, which may result in the termination of the Terms without notice, exclusively to the Client's detriment, as well as a permanent ban on the Client's access to and use of the Website and Services.

Furthermore, the Company reserves the right to refuse to create a Portal for a Client who does not meet or comply with the conditions specified in this "Creating a Client Portal" article and, more generally, in these Terms, as well as to close/delete the Client's Portal on the conditions specified in the "Closing and Deleting the Portal" article.

6.2 Confidentiality and Security of the Client Portal

Creating a Portal requires the Client to choose Login Data that is confidential, personal, unique (i.e., not used on other websites) and will be necessary to access the Portal. For this purpose, the Client will be asked to choose an identifier or login (i.e., an e-mail address) and a password, which must comply with the required format and characteristics indicated in the online form requesting the creation of a Portal.

The Client bears sole responsibility for maintaining the confidentiality of their Identifiers, which are exclusively their personal data, and undertakes to take all necessary measures to ensure this complete confidentiality, in particular to change the password regularly. The Client is also obliged to keep their Identifiers confidential and protect them from third-party access or disclosure. The Client bears sole responsibility for using their Identifiers exclusively for personal purposes and guarantees this to StaBillon.

In the event of password loss or theft, or unauthorized access to the Client Portal, the Client is obliged to immediately notify StaBillon by e-mail at the Contact Address and comply with all of the Company's instructions, in particular regarding blocking access to the Client Portal. Re-opening the Client Portal following such a request to block will be subject to the Client providing additional information and/or documents to confirm their identity and the validity of the reopening request. StaBillon bears no liability if the Client fails to provide the required information and/or documents.

Access to the Portal and the use of the Services by the Client takes place under their sole responsibility, and StaBillon bears no liability for any fraudulent use or access to the Portal attributable to the Client or their conduct, including negligence. Accordingly, using the Client's Identifiers to connect to the Portal and execute Transactions is, as a rule, an issue between the Parties, and except in cases of fault attributable to StaBillon, the Client is liable for (i) operations performed on or via their Portal, (ii) any use of the Website and Services simultaneously while connected to their Portal, and (iii) any facts or actions related thereto.

The Client is also hereby informed that logging in or gaining access to the Portal using Identifiers constitutes, as a rule and in the absence of evidence to the contrary, proof of the Client's authentication and identification.

6.3 Closing and Deleting the Client Portal

The Client may request the closure and deletion of their Portal by sending an e-mail to: Contact Address.

StaBillon will in any case automatically close and delete the Client's Portal within 7 (seven) days of the Client's last login to the Portal, if there were no Digital Assets in their Wallet during this period.

Furthermore, in the event of termination of these Terms, StaBillon will close and delete the Client Portal.

The Client is solely responsible for storing and backing up information and documents sent by StaBillon or to StaBillon, or more generally via the Website and/or recorded or stored in the Portal, as StaBillon does not provide storage, backup, or archiving services for third parties in this regard.

The closure and deletion of the Client Portal, regardless of the reason or the initiator, does not create an obligation to compensate the Client.

7. Financial Terms of Service Provision

Transactions are services offered to the Client for a fee. Accordingly, the Client is obliged to pay StaBillon (unless these Terms stipulate otherwise that Fees are payable to a third party) the Transaction Fees specified below.

Fees charged on the Website, in particular the rates used to calculate various Transaction Fees, are specified on the Website in the "Fees" section and, where applicable, on ATM screens.

Rates may be subject to change at any time. In the event of rate updates, the new rates will apply to all Operations initiated and approved by the Client after the effective date of the new rates.

The amount of the Fees for Purchase or Sale Transactions depends on StaBillon and is determined by StaBillon based on the weighted volatility risk and market conditions of digital assets, taking into account the costs incurred by the Company. StaBillon provides the Client with the relevant information at its own discretion and responsibility. These fees are payable (and paid by the Client) directly to StaBillon. The Fees will be increased by the applicable VAT rate (only if VAT applies).

7.1 Warnings Regarding Prices and Fees

The Price of Digital Assets and the amount of Transaction Fees are determined at the moment the Client approves the Transaction. However, given the particularly high volatility of Digital Assets, it is possible that the Digital Asset Price and the amount of the Transaction Fees may not be identical at the time they are previously displayed to the Client and the time the Transaction is actually confirmed.

Prices and fees for Operations may therefore be subject to changes, both continuously and periodically, at any time. Except in cases where a Transaction can be canceled in accordance with these Terms, Transactions are irreversible, and the Client may not request their cancellation as a result of a change in Prices or Fee Rates that occurred after the Transaction was approved.

Furthermore, the price determined at the moment the Client approves the transaction is not guaranteed, nor is the amount of the associated Transaction Fees:

considering the delay in the Portal between order approval and its actual execution;
in the case of an approved Operation that was not successfully completed and executed;
as a result of a modification to the Operation at the Client's request or as a result of an error or mishandling attributable to the Client;
in the event of the Client's non-compliance with the provisions of these Terms;
in the event of the closure/deletion of the Portal by StaBillon or by the Client;
in the event the Transaction is canceled by the Client or by StaBillon under the conditions set out in the Terms;
in the event of force majeure;
in the event of a failure or interruption in the functioning of the Website and/or Services caused by one of the circumstances described in the "Availability of the Website and Services" article.

7.2. Rules for Setting Prices and Fees

7.2.1. The current Fee rates and information on how the Digital Asset Price is calculated are available to the Client on the Website in the "Fees" section and, where applicable, on ATM screens. This information is provided to the Client before initiating a given Transaction and forms an integral part of these Terms.

7.2.2. The Digital Asset Price presented to the Client prior to confirming the Transaction may include both the market price of the Digital Asset and the CASP's margin (spread) resulting from the terms of execution of the exchange by the CASP. The Provider does not charge a margin (spread) for the issuance or redemption of EMTs — EMTs are issued and redeemed at par value (Art. 49 of MiCA), and the Provider's remuneration consists solely of the Fees indicated in the "Fees" section. In a Purchase Transaction, the par value of EMTs issued to the Client corresponds to the amount of funds deposited minus the Fees charged. Before confirming the Transaction, the Client receives information about the Digital Asset Price and the amount of Fees associated with the Transaction, allowing them to verify the total cost of the Transaction.

7.2.3. Changes in fee rates and the rules for calculating the Digital Asset Price apply only to Transactions initiated after the effective date of those changes. StaBillon will inform Clients with Portals about changes in fee rates and the rules for calculating the Digital Asset Price via a Durable Medium, with appropriate advance notice, unless the law provides otherwise.

7.2.4. The Client may conclude a Transaction only after reviewing the current Digital Asset Prices and Fees and accepting them by confirming the Transaction. Confirming the Transaction signifies the Client's consent to the application of the Digital Asset Price and Fees indicated at the time of confirming the Transaction.

8. Obligations of the Parties

8.1 Provider's Obligations

StaBillon is bound by the terms set out in these Terms. StaBillon provides the Client with the Services, including access to the Website and ATMs, and is therefore subject to an obligation to apply preventive measures.

StaBillon strives to maintain the availability of the Website and Services, as well as ATMs, in accordance with the provisions of the "Terms of Use of the Website and Services" article herein.

8.2 Client's Obligations

The Client guarantees that they are authorized in their country of residence or the jurisdiction in which they live and are registered to access and use the Website and the Services offered by StaBillon. The Client also ensures that the Website and Services are suitable for their needs, meet their expectations, and that they possess the appropriate skills, technical and financial knowledge, and the necessary computer environment to use the Website and Services correctly.

The Client is bound by the provisions of these Terms. The Client assumes sole responsibility for their use of the Website, ATMs, Portal, and Services, as well as for the acts and actions of individuals to whom they have granted authorization to access their Personal Space, including any subsequent transactions.

The Client is obliged to use the Website and Services, as well as ATMs, in accordance with the laws and regulations in force in the countries and jurisdictions where activities and interests related to Operations and transactions on Digital Assets are conducted, and may not use the Website and/or Services for illegal or unlawful purposes, or for purposes other than those for which the Website and Services have been made available to the Client.

The Client is obliged to file appropriate tax returns, keeping in mind that the taxation of income from investments in digital assets varies depending on the laws of the country where the Client is a resident.

9. Liability of the Parties

9.1. Each Party is liable for the non-performance or improper performance of its obligations under these Terms in accordance with the principles set out in mandatory provisions of law, in particular the Civil Code, taking into account the provisions of this paragraph regarding the Portal.

9.2. It is StaBillon's obligation to provide the Services with the due care expected of a professional entity operating in the Digital Asset services market. StaBillon does not provide investment, legal, tax, or other advisory services, unless expressly stipulated otherwise in a separate agreement concluded with the Client.

9.3. StaBillon may only be held liable to the Client for damages that are a normal, typical consequence of a breach of obligations under these Terms, wherein:

a) as a rule, StaBillon's liability covers only actual damages (damnum emergens), excluding lost profits (lucrum cessans), unless mandatory legal provisions state otherwise or the damage resulted from StaBillon's willful misconduct or gross negligence;

b) StaBillon is not liable for indirect damages, in particular for loss of anticipated profits, loss of reputation, or business interruption, unless the damage was caused by StaBillon's intentional error or gross negligence;

c) the provisions of this paragraph do not affect the rights of a Client acting as a Consumer vested in them under mandatory legal provisions.

9.4. StaBillon is not liable for non-performance or improper performance of its obligations under these Terms to the extent this is caused by:

a) the occurrence of Force Majeure within the meaning of these Terms, subject to the provisions of section 9.6;

b) the actions or omissions of third parties for whom StaBillon is not responsible, in particular Payment Service Providers, telecommunications service providers, KYC/KYT service providers, liquidity providers, or blockchain network operators;

c) use of the Website, Portal, ATMs, or Services in a manner contrary to these Terms, the provided instructions, or applicable law;

d) incorrect operation or misconfiguration of the Client's computer hardware, software, or telecommunications connections;

e) the Client's failure to fulfill obligations arising from legal regulations (in particular tax, foreign exchange, anti-money laundering, and terrorism financing laws) or these Terms, including the obligation to update data and provide required documents.

10. Termination of Services

Without prejudice to the specific right of withdrawal available to Clients who are Consumers, Clients may terminate these Terms at any time and without notice, provided the Portal is deleted in accordance with the terms set out in the "Closing and Deleting the Portal" section. StaBillon is entitled to terminate and cancel these Terms, without the Client's right to claim any compensation on this account, under the following conditions:

if a law, regulation, or decision of a competent authority or jurisdiction prevents maintaining all or part of the Terms (and thereby the Services) between the Parties or if StaBillon has reason to believe that maintaining all or part of the Terms (and thereby the Services) is therefore impossible, subject to a thirty (30) day notice period, unless the law, regulation, or decision referred to in this article prohibits or does not allow StaBillon to maintain such a notice period. Furthermore, StaBillon may, at its sole discretion, subject to compliance with the aforementioned notice period, unless circumstances prevent maintaining such a notice period, terminate part or all of the Terms (and thereby terminate part or all of the Services) in order to comply with all laws, regulations, or decisions applicable to transactions or manipulative actions on Digital Assets;
in the event of technical problems or security issues affecting the Website and/or the provision of the Services, with a thirty (30) day advance notice, or if circumstances do not allow for such notification, immediately without prior notice;

Unless this article provides otherwise and unless prohibited by law or a decision of a competent authority, any termination of the agreement initiated by StaBillon will be preceded by sending an e-mail to the e-mail address provided by the Client, informing the Client of such termination and its effective date, in accordance with the terms and notice periods set out herein. If there is no obligation for prior notification from StaBillon, this message will be sent simultaneously with the termination of the agreement.

To the fullest extent permitted by law (and consumer protection in the case of a Client acting as a consumer), the Terms may be terminated at StaBillon's initiative, in addition to the cases expressly provided for in the provisions of these Terms and without prejudice to any compensation that may be sought from the Client, in the following cases:

in the event the Client breaches any of their duties or obligations under these Terms, in particular if they breach their obligations under the "Description of Services", "Terms of Use of the Website and Services", "Terms of Use of the Portal", "Financial Terms", and "Obligations of the Parties" articles, seven (7) days after formally notifying the Client to fulfill their duties and/or obligations, which remained ineffective;
In the event of a serious breach by the Client that entitles StaBillon to terminate the Terms without notice and without prior formal notification, StaBillon may in such case terminate these Terms by sending an e-mail to the e-mail address provided by the Client. Accordingly, serious breaches by the Client that entitle StaBillon to terminate the Terms without notice include:
the fact that the Client registers on behalf of another person to bypass the prohibition on creating a Portal;
the fact that the Client provides misleading, inaccurate, outdated, obsolete, or incomplete information (for example, information concerning their identity or contact details) or fails to update some of this information or provides false documents (e.g., a false identity document), refuses to provide information or documents required by anti-money laundering regulations, or attempts to split transactions to bypass Limits or verification thresholds (structuring);
the fact that the Client refuses to accept the amended Terms by requesting the deletion of the Portal;
using the Website and/or Services, voluntarily or involuntarily, for illegal or fraudulent purposes or activities;
any other serious breach of these Terms or applicable legal regulations.

Formal notifications referred to in this article will be sent by StaBillon via e-mail to the e-mail address provided by the Client and will include a reference to this article. StaBillon will then inform the Client in the same manner of the effective termination of the Terms. In the absence of an obligation for StaBillon to notify the Client in advance, the Client will receive an e-mail informing them of the termination of the Terms.

11. Personal Data and Cookies

StaBillon is responsible for the processing of Clients' personal data via the Website. StaBillon's personal data protection policy is available on the Website.

The controller of the Client's personal data in relation to the Services is StaBillon. Personal data is processed: (a) for the purpose of concluding and performing the Agreement and executing Transactions — Art. 6(1)(b) of the GDPR; (b) to fulfill legal obligations incumbent on StaBillon, including those arising from the AML Act, Regulation (EU) 2023/1113 (Travel Rule), payment services regulations, and MiCA, as well as accounting and tax obligations — Art. 6(1)(c) of the GDPR; (c) for StaBillon's legitimate interests, including fraud prevention, ensuring the security of the Services, and the establishment, exercise, and defense of legal claims — Art. 6(1)(f) of the GDPR.

If identity verification involves processing biometric data (e.g., comparing a facial image with an identity document, liveness test), this processing takes place on the basis of separate, explicit consent from the Client (Art. 9(2)(a) of the GDPR), expressed prior to initiating the verification — at the ATM, on the Website, or on the Client's mobile device. Consent may be withdrawn at any time, which does not affect the lawfulness of processing based on consent before its withdrawal; however, withdrawing consent may prevent the completion of verification and, consequently, the use of the Services.

Transfer of the Client's data to the CASP occurs only to the extent necessary to execute the instruction placed by the Client, after informing the Client at a given stage (step) of the process: (a) data accompanying the EMT transfer (originator and beneficiary data) are transferred in fulfillment of a legal obligation arising from Regulation (EU) 2023/1113 (Travel Rule) — Art. 6(1)(c) of the GDPR — and do not require the Client's consent; (b) the Client's identification and verification data necessary to set up a Client account with the CASP are transferred solely on the basis of the Client's separate, voluntary, and explicit consent, expressed prior to their transfer; lack of this consent merely prevents the execution of an exchange via the given CASP, but does not affect the acquisition, holding, or redemption of EMTs. Consents are collected separately for individual actions (steps) and documented by StaBillon. From the moment the data is transferred, the CASP becomes a separate data controller and processes it in accordance with its own privacy policy, which the Client should review.

Cookies and other trackers or similar technologies may be installed and/or read in your web browser while visiting the Website. StaBillon's cookie management policy is available on the Website. With regard to the websites of the Provider's partners (outside the Provider's interface), the respective partner remains the controller of technical data and cookies, in accordance with their own policy.

12. Intellectual Property

These Terms do not entail the transfer, concession, or licensing of intellectual property rights or sui generis database rights to the Client.

The entire Website, as well as each of its individual components, in particular programs and developments, its structure and content, including data, text, still or animated images, logos, sounds, graphics, photos, and files, constitute the exclusive property of StaBillon or third parties who have provided or granted rights to use them.

Any representation or reproduction, in whole or in part, of the Website or any of its elements without StaBillon's express consent is prohibited and constitutes an infringement punishable by law pursuant to the Act of February 4, 1994, on copyright and related rights (Journal of Laws of 2025, item 24) or an act of unfair competition or parasitism and/or a fault in general for which the author is liable. In any case, any representation or reproduction of the Website or its elements, in whole or in part, authorized by StaBillon must include the notation "Copyright StaBillon – all rights reserved".

Trademarks and logos visible on the Website are registered trademarks of StaBillon or third parties. Any reproduction, imitation, or use, in whole or in part, of these distinctive signs without the express consent of the rights holder or in violation of intellectual property rights will result in the author's liability.

Any other distinctive signs, in particular company names, trade names, brand names, and domain names appearing on the Website constitute the property of StaBillon or respective third parties. Any reproduction, dissemination, or other use without the prior express consent of the rights holder may constitute an infringement of rights, and more broadly, a misleading action for which the perpetrator bears sole liability.

13. Right of Withdrawal

A Client who is a Consumer and enters into a Distance Agreement with StaBillon generally has the right to withdraw from the Agreement within 14 days from the date of its conclusion, without giving any reason and without incurring costs, subject to the exceptions provided for by law, in particular the Act of May 30, 2014, on Consumer Rights.

A Client who is a Consumer acknowledges that pursuant to Art. 38 section 2 of the Consumer Rights Act, the right to withdraw from a distance agreement does not apply to agreements where the price or remuneration depends on fluctuations in the financial market over which the entrepreneur exercises no control, and which may occur before the deadline to withdraw from the agreement, in particular with regard to services relating to Digital Assets.

To the extent the Agreement relates to services concerning Digital Assets, the Price of which depends exclusively on price changes in the financial market or Digital Asset market, the Client who is a Consumer acknowledges and accepts that – if the conditions defined in Art. 38 of the Consumer Rights Act are met – they do not have the right to withdraw from the Agreement pursuant to Art. 27 of that Act. StaBillon will inform the Client of the above at the latest before the Client submits a declaration of intent to enter into the Agreement on a Durable Medium.

If, pursuant to the Agreement, StaBillon is to commence the provision of services regarding Digital Assets before the deadline to withdraw from the Agreement expires, the Client who is a Consumer, by submitting a declaration of intent to conclude the Agreement and initiating the first Transaction, gives explicit consent to the commencement of service provision before the withdrawal deadline expires and acknowledges that to the extent referred to in point 13.3, they lose the right to withdraw from the Agreement.

The above exclusions and limitations of the right of withdrawal apply to services the price of which depends on market fluctuations, i.e., the crypto-asset stage executed by the CASP under the CASP terms. Regarding the electronic money Service, EMTs are issued and redeemed at par value — their price does not depend on financial market fluctuations, and therefore the exclusion referred to in Art. 38 section 2 of the Consumer Rights Act does not apply to them; regardless of the right of withdrawal, the Client may at any time demand the redemption of held EMTs at par value (Art. 49 of MiCA).

To the extent the Agreement also encompasses other services to which the right of withdrawal applies, a Client who is a Consumer may exercise the right to withdraw from the agreement on the terms set out in the Consumer Rights Act, by submitting a withdrawal statement to StaBillon in writing or in the form of an e-mail sent to the address indicated in these Terms.

Pursuant to Art. 38 section 1 point 2 of the Act of August 23, 2007, on counteracting unfair market practices (Journal of Laws of 2023, item 845), the right to withdraw from an agreement concluded off-premises or at a distance does not apply to the Consumer in respect of agreements where the price or remuneration depends on fluctuations in the financial market over which the entrepreneur has no control, and which may occur before the withdrawal deadline expires, i.e., agreements concerning Digital Assets.

14. Miscellaneous

To the fullest extent permitted by Polish law (and in the case of a Client acting as a consumer, unless consumer protection laws state otherwise), the Client and StaBillon shall not be liable to the other Party for any failure to perform their obligations under these Terms as a result of force majeure.

By the express agreement of the Parties, force majeure is understood as:

power supply interruptions, including any outages, limitations, or power instability;
disruptions in communication networks, both public and private, including in particular a complete or partial blockage of Internet access;
cyberattacks or IT breaches causing the inability to recover data or provide Services by StaBillon and/or its partners;
weather phenomena and extreme climatic conditions, such as storms, hail, lightning, hurricanes, and other similar events;
natural disasters, including earthquakes, floods, and water damage;
the impact of magnetic fields;
aviation accidents, including plane crashes;
acts of terrorism;
war, riots, armed conflicts, fires, explosions, strikes (internal or external), lockouts, or occupation of StaBillon's premises;
statutory restrictions or decisions of public authorities, including changes in regulations concerning forms of marketing;
accidents of any kind;
epidemics, pandemics, or illnesses affecting at least 10% of StaBillon's employees or associates (including internal and external consultants and persons employed by entities in StaBillon's capital group) within two consecutive months;
blockades, supply chain interruptions, or supply shortages,

preventing a Party from the normal performance of its obligations under the Terms.

StaBillon draws the Client's attention to the risks associated with any business transaction, particularly transactions regarding Digital Assets. The Client's use of the Services implies acceptance of these risks. Consequently, any financial losses incurred by the Client as a result of using the Services do not constitute a situation of unforeseeability and do not entitle the Client to invoke the legal regime of unforeseeability provided for in this article, nor any legal or regulatory provisions that may apply in such a situation, which the Client expressly recognizes and accepts. The same applies, more generally, to a situation where the contractual balance is disrupted by circumstances that could not have been foreseen at the time of entering into the Terms, even if their performance proves excessively burdensome. The Client agrees to bear all economic and financial consequences and waives in such case the right to invoke the legal regime of unforeseeability provided for in the aforementioned article of the Civil Code, as well as any legal or regulatory provisions that may apply in such a situation.

In the event of interpretative difficulties arising from a conflict between any of the headings placed at the beginning of an article and the content of any of the articles, these headings will be deemed non-existent.

If one or more provisions of the Terms are held to be invalid, ineffective, illegal, or unenforceable, or are declared as such in application of a law, regulation, or following a final decision of a court or competent authority, the remaining provisions will remain in force and retain their full force and scope.

The Parties acknowledge that each acts on its own behalf as an independent party and that these Terms shall not be construed otherwise.

In order to execute the Terms, and in particular to provide the Services, StaBillon may, at its own discretion, use the services of subcontractors (including the ATM Operator as a technical provider), wherein StaBillon remains liable to the Client for executing the Terms in accordance with their provisions.

The Client Portal may not be transferred or passed on to a third party, and the Client may not transfer or assign the Terms or any or all of their rights and obligations under the Terms to a third party.

Unless stated otherwise, the times and periods indicated in these Terms are expressed in calendar days.

The Client undertakes not to transmit via the Website content of an unlawful nature or content that disrupts the proper functioning of the Website or Services.

15. Complaints, Mediation, and Alternative Dispute Resolution Methods

Complaints may be submitted: (a) in electronic form — to the Contact Address or, if the function is available, via the Portal; (b) in written form — to the address of the Provider's registered office indicated in the Terms; (c) verbally — by phone, at the number indicated in the "Domains and Addresses" definition. The complaint should indicate data allowing for the identification of the Client and the Transaction, as well as the subject matter of the objections.

A response to the complaint should be provided without undue delay, but no later than within 30 days from the date of its receipt. To meet the deadline, it is sufficient to send the response before it expires. In particularly complex cases, preventing the processing of the complaint and the provision of an answer within the aforementioned timeframe, StaBillon will, in the information provided to the complaining Client:

explain the reason for the delay;
indicate the circumstances that need to be established for the case to be resolved;
specify the expected date for resolving the complaint and providing a response, which may not exceed 60 days from the date of receiving the complaint. In the event of failure to meet the above deadlines, the complaint is considered resolved in accordance with the Client's wishes.

Any Client acting as a Consumer and remaining in dispute with the Company may contact the Financial Ombudsman at the following address: Office of the Financial Ombudsman, ul. Nowogrodzka 47A, 00-695 Warsaw, or via the website: https://rf.gov.pl/ under the rules specified in the Act of August 5, 2015, on the handling of complaints by financial market entities, on the Financial Ombudsman, and on the Financial Education Fund (Journal of Laws of 2024, item 1109).

The current register of such entities is maintained by the President of the Office of Competition and Consumer Protection (UOKiK): https://uokik.gov.pl/bip/sprawy-konsumenckie

A Client acting as a consumer may also use alternative out-of-court dispute resolution methods before the locally competent permanent consumer arbitration court and via the European Commission's ODR platform.

16. Governing Law and Jurisdiction

The original version of these Terms is drawn up in Polish. In the event of translation into one or more foreign languages, the Polish text shall prevail, particularly in the event of legal disputes.

The Website is governed by Polish law. Consequently, the content offered complies with applicable Polish law. StaBillon bears no liability in the event of non-compliance with the laws of the country the Client comes from.

These Terms, as well as the relationship between StaBillon and the Client, are also governed by Polish law. This applies to both substantive and formal provisions, regardless of the place of performance of primary or ancillary obligations.

In the event of any disputes regarding the interpretation or performance of these Terms, the Parties will make every effort to reach an amicable solution. In the absence of an amicable solution, Polish courts have exclusive jurisdiction to resolve disputes arising from the application of these Terms or arising directly or indirectly from the use of the Website. The competent language for resolving any disputes is Polish.

These provisions concerning governing law and jurisdiction are subject to any mandatory legal provisions that may apply to a Client who is a Consumer within the meaning of the Act of May 30, 2014, on Consumer Rights (Journal of Laws of 2024, item 1796).

Annex No. 1 — CASP List

As of the date of adopting these Terms, the CASP List includes the following entities:

OKX Europe Ltd — a company with its registered office in Malta; authorized to provide crypto-asset services (CASP, Title V of MiCA) granted by the Malta Financial Services Authority (MFSA) on January 27, 2025; LEI: 54930069NLWEIGLHXU42; services on the territory of Poland provided on the basis of the notification referred to in Art. 65 of MiCA; website: www.okx.com.

[entry template for subsequent CASP: name and legal form — registered office; CASP authorization granted by (supervisory authority, country) on (date); LEI: (…); notification under Art. 65 of MiCA covering Poland: (date/confirmation); website: (…)]

Updating the CASP List occurs by publishing an updated Annex No. 1 on the Website, in accordance with the "CASP List" definition.

Buy Crypto With Cash

GAIN ACCESS

Sign Up