General Terms and Conditions of Use and Service Provision – EU

Version: 28 January 2026

Entity: Byte Neok AI, S.L. (B72527682)

Contact: legal@bnka.com

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. Right of Withdrawal

25. Governing Law and Jurisdiction

Annex — Footer: Required Legal Elements

1. Identification of the Owner and Nature of the Platform

The digital platform known as BNKA (the "Platform") is owned and operated by Byte Neok AI, S.L., a company incorporated under the laws of Spain, with tax identification number B72527682, and legal contact email legal@bnka.com (hereinafter, "BNKA" or the "Company").

BNKA operates as a technology infrastructure provider enabling access to crypto-asset and payment-related services delivered by regulated entities. BNKA is not a bank, credit institution, or electronic money institution, and does not provide investment, tax, or legal advice. Payment services in EUR offered through the Platform are provided exclusively by the authorised PSP/EMI referenced in Section 12, and not by BNKA.

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.

–  Framework Agreement: the contractual relationship established between the User and BNKA upon completion of registration.

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:

Byte Neok AI, S.L. (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, does not act as a custodian of fiat funds or as a financial intermediary, and does not enter into any contractual relationship with Users.

5. Applicable Regulatory Framework

Byte Neok AI, S.L. is registered in the Bank of Spain's register of virtual currency service providers under registration number E117, as a provider of virtual currency exchange services and electronic wallet custody services. Accordingly, BNKA operates under the transitional regime provided for in Article 143 of Regulation (EU) 2023/1114 (MiCA), as implemented in Spain, allowing continued operation until 30 June 2026 or until CASP authorisation is granted, whichever occurs first.

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

Byte Neok AI, S.L. (B72527682) is registered in the Banco de España registry of virtual currency service providers under registration number E117, as a provider of virtual currency exchange services and electronic wallet custody services. Registration does not imply supervision equivalent to that of credit institutions or payment institutions, nor does it constitute a guarantee of the services or products offered. Services are provided in accordance with the applicable regulatory framework at any given time.

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. BNKA may restrict access to certain services or functionalities based on the User's country of residence in accordance with applicable law.

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. BNKA is subject to anti-money laundering and counter-terrorist financing obligations under Directive (EU) 2015/849 (5AMLD) and applicable Spanish law.

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 as detailed in the Pricing Policy.

10. Safekeeping of Crypto-Assets

Where the User opts for safekeeping functionalities, BNKA facilitates the safeguarding of crypto-assets through internal or third-party custody arrangements, including specialised custodians where applicable. Assets are maintained segregated from BNKA's own assets.

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 custody 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:

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

–  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

–  the User authorises BNKA solely to transmit and process instructions to the Custodian Entity through the Platform interface, without BNKA holding, controlling, having access to, or disposing of the User's funds at any time.

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 at bnka.com/en/pricing. Fees may vary depending on market conditions, liquidity, and operational factors, and will be displayed to the User prior to transaction confirmation. The Pricing Policy shall be accessible at all times on the Platform. BNKA shall notify Users of any material changes with adequate prior notice.

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. The User is solely responsible for assessing whether crypto-assets are appropriate for their financial situation. Nothing in these Terms constitutes investment advice.

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. Nothing in these Terms shall exclude or limit liability where such exclusion or limitation is prohibited by mandatory applicable law. Nothing in these Terms shall affect the User's mandatory rights under applicable consumer protection law. The foregoing applies without prejudice to any liability that cannot be limited under applicable law.

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. Users must notify BNKA immediately of any suspected unauthorised access to their account.

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. Where legally permitted, BNKA shall provide prior notice to the User.

18. Personal Data Protection

BNKA processes personal data in accordance with the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679), Organic Law 3/2018 (LOPDGDD), and its Privacy Policy available on the Platform, which forms an integral part of these Terms.

19. Customer Support and Complaints

Users may contact BNKA's Customer Service at support@bnka.com or at support.bnka.com. Complaints will be handled in a fair, transparent and timely manner in accordance with applicable consumer protection regulations, within a maximum of fifteen (15) business days (or two (2) months in exceptional circumstances).

If the User's complaint is not resolved satisfactorily, the User may contact the Banco de España Complaints Service (Servicio de Reclamaciones del Banco de España), Calle Alcalá 48, 28014 Madrid, www.bde.es. Prior exhaustion of BNKA's internal complaints procedure is required. BNKA shall maintain a register of complaints submitted in accordance with applicable regulations.

In accordance with Regulation (EU) 524/2013, Users may also access the European Commission's ODR platform: https://ec.europa.eu/consumers/odr.

20. Intellectual Property

All intellectual property rights in the Platform belong to BNKA or its licensors. Users may not reproduce, distribute, or modify any content without prior written authorisation.

21. Assignment and Subcontracting

BNKA may subcontract or assign certain functions to group entities or third parties, without prejudice to its obligations towards Users. Users may not assign their rights or obligations without prior written consent from BNKA.

22. Force Majeure

BNKA shall not be liable for failures caused by force majeure events, including but not limited to natural disasters, regulatory changes, cyberattacks, infrastructure failures, or acts of government.

23. Partial Invalidity

If any provision of these Terms is declared invalid or unenforceable, the remaining provisions shall continue in full force and effect.

24. Right of Withdrawal

In accordance with Directive 2002/65/EC, as transposed by Ley 22/2007, the User has the right to withdraw from the Framework Agreement within fourteen (14) calendar days from the date of conclusion, without penalty and without providing any reason.

To exercise this right, the User must notify BNKA at legal@bnka.com within the fourteen-day period. BNKA will reimburse any amounts paid for services not yet rendered within thirty (30) days of receiving the withdrawal notice.

The right of withdrawal does not apply to individual crypto-asset exchange or trading transactions whose price depends on fluctuations in financial markets outside BNKA's control, pursuant to Article 7(1)(a) of Directive 2002/65/EC and Article 10(1)(a) of Ley 22/2007.

25. Governing Law and Jurisdiction

These Terms shall be governed by Spanish law. Any disputes shall be subject to the jurisdiction of Spanish courts. Users who are consumers may bring claims before the courts of their place of residence where mandatory consumer protection rules so provide.