GENERAL TERMS AND CONDITIONS OF USE AND SERVICE PROVISION – BNKA

Last updated: 28 January 2026

TABLE OF CONTENTS

1. Identification of the Owner and Nature of the Platform
2. Definitions
3. Acceptance of the Terms and Amendments
4. General Description of the Platform and Operational Architecture
5. Applicable Regulatory Framework (MiCA, PSD2 and others)
6. User Eligibility
7. Registration, Account Opening and KYC/AML Procedures
8. Crypto-Asset Related Services
9. Execution of Transactions and Price Formation
10. Safekeeping of Crypto-Assets
11. Crypto-Asset Transfers (On-Chain)
12. EUR Operations and vIBANs (Payment Services)
13. Fees, Costs and Charges
14. Risks Inherent to Crypto-Assets
15. Liability and Limitation of Liability
16. Account Security and User Obligations
17. Suspension, Restriction and Account Closure
18. Personal Data Protection
19. Customer Support and Complaints
20. Intellectual Property
21. Assignment and Subcontracting
22. Force Majeure
23. Partial Invalidity
24. Governing Law and Jurisdiction

1. Identification of the Owner and Nature of the Platform

The digital platform known as BNKA (the “Platform”) is owned by Block Ventures, S.L., a company incorporated under the laws of Spain, with registered office at  Barcelona, Spain, tax identification number B72527682, and legal contact email legal@bnka.com (hereinafter, “BNKA” or the “Company”).

BNKA is not a financial institution, bank, credit institution, electronic money institution, payment service provider, financial advisor, investment manager, or securities intermediary. None of the services offered through the Platform constitute financial, investment, tax or legal advice.

2. Definitions

For the purposes of these Terms, the following definitions shall apply:
- User: a natural person of legal age who accesses the Platform and accepts these Terms.
- BNKA Account: an internal record within the Platform reflecting the User’s positions.
- Crypto-Assets: digital assets based on distributed ledger technology.
- PSP/EMI: a payment service provider or electronic money institution authorised within the EEA.
- vIBAN: a virtual payment account issued by a PSP/EMI in the name of the User.
- MiCA: Regulation (EU) 2023/1114 on markets in crypto-assets.

3. Acceptance of the Terms and Amendments

Access to and use of the Platform implies full and unconditional acceptance of these Terms. BNKA may amend these Terms when required for legal, regulatory or operational reasons. Where amendments are material, Users shall be notified with the legally required prior notice and granted the right to terminate the contract without penalty.

4. General Description of the Platform and Operational Architecture

The Platform allows Users to access crypto-asset related services and EUR operational functionalities through a clearly segmented group architecture:

BNKA (Spain): entity responsible for all crypto-asset related services provided to Users.
Block Digital UAB (Lithuania): group entity acting exclusively as a technical service provider for the integration of the Platform with banking and payment infrastructure.

Block Digital UAB facilitates the technical assignment of vIBAN identifiers to Users and provides integration, reconciliation and reporting support, acting solely as a technological intermediary. Block Digital UAB does not provide payment services, does not execute payment orders, does not hold or safeguard Users’ funds, and does not act as a custodian of fiat funds or as a financial intermediary.

5. Applicable Regulatory Framework

BNKA is registered in the Bank of Spain’s register of virtual currency exchange service providers prior to 30 December 2024. Accordingly, BNKA operates under the grandfathering regime provided for in Regulation (EU) 2023/1114 (MiCA) and its national implementing provisions, allowing continued operation until the granting of a Crypto-Asset Service Provider (CASP) authorisation or until June 2026, whichever occurs first.

As of the date of these Terms, BNKA does not declare to be authorised as a CASP under MiCA. Services are provided in accordance with the applicable transitional regime and without prejudice to the future granting of such authorisation.

6. User Eligibility

Only natural persons aged eighteen (18) or over, resident in the European Economic Area, who successfully complete BNKA’s verification processes may register as Users.

7. Registration, Account Opening and KYC/AML Procedures

To use the Platform, Users must complete the registration process and provide accurate and up-to-date information. BNKA may verify such information through internal and external sources and may suspend or close the BNKA Account if compliance requirements are not met.

8. Crypto-Asset Related Services

Depending on availability and User profile, BNKA may offer crypto-asset exchange, execution, transfer and safekeeping services. The availability of each service may vary for regulatory, technical or risk-related reasons.

9. Execution of Transactions and Price Formation

Transactions shall be executed at the prices displayed on the Platform prior to confirmation. Users must expressly confirm each transaction. Prices may include applicable spreads and fees.

10. Safekeeping of Crypto-Assets

Where the User opts for the safekeeping service, BNKA shall safeguard crypto-assets on behalf of the User, maintaining such assets segregated from its own assets. BNKA may rely on specialised sub-custodians selected in accordance with due diligence and security criteria.

In the event of BNKA’s insolvency, safeguarded crypto-assets shall not form part of BNKA’s own estate, to the extent permitted by law.

In the event of a loss of crypto-assets attributable to failures in the safekeeping arrangements of BNKA or its sub-custodians, BNKA’s liability shall be limited to the market value of the affected crypto-asset, without prejudice to any mandatory restitution and strict liability obligations imposed by Article 75 of Regulation (EU) 2023/1114 (MiCA), where applicable.

11. Crypto-Asset Transfers (On-Chain)

Crypto-asset transfers require strong authentication and express confirmation by the User. Users acknowledge the generally irreversible nature of blockchain transactions. BNKA may suspend or reject transfers for legal, regulatory or security reasons.

12. EUR Operations and vIBANs

12.1 Issuance and Safeguarding

Payment account services, EUR fund safeguarding and vIBAN issuance are provided exclusively by one or more authorised PSPs/EMIs within the European Economic Area.

12.2 Custody Relationship and Mandate

By activating EUR operations, the User instructs BNKA and Block Digital UAB to facilitate the opening of a payment account or funds ledger (vIBAN) with an authorised electronic money institution or credit institution (the “Custodian Entity”).

The User acknowledges and accepts that:

(i) funds transferred to the vIBAN shall be safeguarded by the Custodian Entity in accordance with applicable European safeguarding regulations;

(ii) the identity of the Custodian Entity shall be indicated in the payment details (IBAN/BIC) displayed in the Platform for the purpose of executing transfers; and

(iii) the User authorises BNKA to manage such funds operationally and exclusively in accordance with the User’s instructions submitted through the Platform.

12.3 Role of BNKA and Block Digital UAB

BNKA and Block Digital UAB act solely as a technological and visual interface (frontend) enabling the User to access services provided by the PSP/EMI and to transmit instructions. Funds deposited in the vIBAN are safeguarded by the PSP/EMI and do not form part of the balance sheet or assets of BNKA or Block Digital UAB.

13. Fees, Costs and Charges

Applicable fees are detailed in the Pricing Policy published on the Platform, which forms an integral part of these Terms.

14. Risks Inherent to Crypto-Assets

Crypto-assets are highly volatile and may lose their entire value. They are not covered by deposit guarantee schemes or investor compensation funds. Users fully assume the risks associated with crypto-assets.

15. Liability and Limitation of Liability

To the extent permitted by law, BNKA shall not be liable for indirect losses, third-party service interruptions, market fluctuations or the User’s investment decisions.

16. Account Security and User Obligations

Users are responsible for maintaining the confidentiality of their credentials. BNKA implements reasonable security measures but does not guarantee the complete absence of risks.

17. Suspension, Restriction and Account Closure

BNKA may suspend or close a BNKA Account in the event of breach of these Terms, applicable law, or by order of a competent authority.

18. Personal Data Protection

BNKA processes personal data in accordance with the General Data Protection Regulation (GDPR) and its Privacy Policy.

19. Customer Support and Complaints

Users may contact BNKA through the channels indicated on the Platform. Complaints shall be handled in accordance with applicable regulations.

20. Intellectual Property

All intellectual property rights in the Platform belong to BNKA or its licensors.

21. Assignment and Subcontracting

BNKA may subcontract or assign certain functions to group entities or third parties, without prejudice to its obligations towards Users.

22. Force Majeure

BNKA shall not be liable for failures caused by force majeure events.

23. Partial Invalidity

If any provision is declared invalid, the remaining provisions shall remain in full force and effect.

24. Governing Law and Jurisdiction

These Terms shall be governed by Spanish law. Users may bring claims before the courts of their place of residence where mandatory consumer protection rules so provide.