General Terms and Conditions

Version: v.1.0
Date: 6 Aug 2026

nbnq swiss ag, a financial technology enterprise registered in Switzerland, specialises in cross-border payment and virtual-asset solutions. nbnq swiss ag is a member of the Financial Services Standards Association (VQF) and operates in accordance with applicable Swiss legal and regulatory requirements.

The products and services offered by nbnq swiss ag are primarily intended for individuals and entities connected to Switzerland or otherwise accepted under applicable Swiss legal and regulatory frameworks.

By accepting these General Terms and Conditions, the Client confirms that it has reviewed and understood them. Where nbnq accepts the Client on a reverse-solicitation basis, the Client further confirms that its initial request for the relevant Services was made on its own initiative. This confirmation does not override applicable local law, replace nbnq’s jurisdictional assessment or create a right to receive Services.

1. Scope of Application

These General Terms and Conditions ("GTC") govern the commercial relationship between the Client and nbnq swiss ag ("nbnq"). For the purposes of these GTC, "Client" means any natural person or legal entity that applies for, is accepted for, or uses the Services.

These GTC apply together with, and are subject to, any specific terms, pricing schedules and conditions applicable to particular products or services made available by nbnq or by a Third-Party provider.

nbnq operates a technology platform (the "Platform") through which eligible Clients may access custodial virtual-asset wallet, virtual-asset transfer and virtual-asset exchange services. Where made available, fiat account, payment, foreign-exchange and card services are provided by regulated Third-Party providers under their own terms and responsibility. The products and services made available through the Platform are referred to collectively as the "Services". nbnq does not itself provide banking or card-issuing services.

nbnq IS NOT A BANK AND DOES NOT ACCEPT DEPOSITS FROM THE PUBLIC. FIAT ACCOUNT, PAYMENT OR CARD BALANCES, WHERE AVAILABLE, ARE MAINTAINED BY THE RELEVANT THIRD-PARTY PROVIDER AND ARE SUBJECT TO THAT PROVIDER’S TERMS AND ANY APPLICABLE PROTECTION ARRANGEMENTS. VIRTUAL ASSETS HELD THROUGH nbnq’s CUSTODIAL WALLET SERVICE ARE NOT BANK DEPOSITS AND ARE NOT COVERED BY A DEPOSIT GUARANTEE SCHEME. nbnq DOES NOT PAY INTEREST ON CLIENT BALANCES OR EXTEND CREDIT.

nbnq is a member of the Financial Services Standards Association (VQF), under membership no. 101372. VQF is an officially recognised self-regulatory organisation pursuant to the Swiss Anti-Money Laundering Act. It is recognised by the Swiss Financial Market Supervisory Authority FINMA for anti-money laundering supervision. nbnq is not directly prudentially supervised by FINMA, and VQF membership does not constitute a FINMA licence.

Fiat funds made available in connection with account, payment or card services are maintained and processed by the relevant regulated Third-Party provider under that provider’s account structure, regulatory framework and contractual terms. nbnq does not hold such fiat funds as its own assets. Virtual assets held through nbnq’s custodial wallet service are maintained in dedicated client wallet infrastructure and recorded separately from nbnq’s proprietary assets. Neither nbnq’s VQF SRO membership nor these operational separation arrangements constitute a statutory deposit guarantee scheme. Any protection applicable to fiat funds depends on the legal and contractual framework of the relevant Third-Party provider, and virtual assets held through nbnq are not covered by a statutory deposit guarantee scheme.

nbnq does not guarantee uninterrupted or error-free availability of the Services. To the fullest extent permitted by law and subject to Section 17, nbnq is not liable for delays, interruptions, failures or unavailability caused by events outside its reasonable control, including failures or unavailability of Third-Party providers, payment or communication systems or blockchain networks. Transactions are carried out on the Client’s instructions and at the Client’s risk, except to the extent a loss is caused by nbnq’s wilful misconduct or gross negligence.

2. Client Initiative (Reverse Solicitation) and Cross-Border Restrictions

2.1. nbnq may provide Services to a Client outside Switzerland only where nbnq has determined that doing so is legally permissible.

2.2. Where a Client is accepted on a reverse-solicitation basis, the Client confirms that the initial request for the relevant Services was made on its own initiative and was not the result of solicitation, targeting or promotion by nbnq or any person acting on its behalf.

2.3. The Client’s confirmation constitutes supporting evidence only. It does not override applicable local law, replace nbnq’s jurisdictional assessment or create a right to receive Services.

2.4. nbnq may request evidence concerning the manner in which the relationship was initiated and may refuse, limit, suspend or terminate Services where the applicable requirements are not met.

2.5. nbnq provides the Services from Switzerland and does not maintain a physical establishment or local representative outside Switzerland unless expressly disclosed. Services are not intended to be offered or provided in any jurisdiction where doing so would be unlawful or require an authorisation that nbnq does not hold.

2.6. Any subsequent request for additional Services may be subject to a renewed cross-border assessment.

3. Account Opening Procedures

3.1. Clients signify their adherence to these GTC by activating the relevant selection on the nbnq website or Platform prior to submitting the information and documentation required for due-diligence purposes. Receipt of an application or documents does not oblige nbnq to establish an account or business relationship. Account establishment is subject to successful examination of the information and documentation submitted by the Client and a positive decision in accordance with nbnq’s internal policies and procedures. The Client will be notified of nbnq’s decision through the Platform and/or verified electronic mail. A legally binding business relationship is established only when nbnq confirms the opening or activation of the relevant account or Service.

3.2. nbnq extends its Services solely to Clients who have successfully completed the onboarding process and possess an account with nbnq. Clients agree to cooperate with all legitimate requests issued by nbnq or any third-party service provider acting on nbnq’s behalf, in accordance with applicable law, for the purpose of identifying or authenticating the Client, verifying source of funds or assets, or reviewing transactions.

3.3. Where the Client is a legal entity, nbnq accepts only entities that are duly incorporated or established, validly existing and registered or otherwise legally recognised under the laws of the jurisdiction specified in the account-opening documentation.

3.4. The Client shall formally notify nbnq in writing of the individuals or authorised representatives (collectively, the "Representatives") empowered to act on its behalf.

3.5. Only the Client and its Representatives are empowered to issue binding instructions to nbnq, and nbnq is authorised to execute those instructions. Any individual who has authenticated through an approved electronic identification or authentication method and has the required account permission shall be deemed authorised to issue the corresponding instructions.

3.6. Binding instructions relating to transactions or account activity may be submitted only through the Platform or another secure channel expressly designated by nbnq. Telephone, ordinary email and postal communications do not constitute binding transaction instructions unless nbnq expressly agrees otherwise.

3.7. nbnq verifies the identity, authority and signing powers of the Client and its Representatives using the electronic identification, authentication and authorisation methods, account permissions, powers of attorney and corporate documentation required by nbnq. Where a manual process is used, nbnq may also rely on original or certified identification documents, signatures and other evidence of authority. nbnq may request additional verification at any time. nbnq may rely on an instruction authenticated through an approved method unless nbnq knew, or through gross negligence failed to identify, that the instruction was unauthorised.

3.8. The Client undertakes to secure and safeguard all information, credentials, devices and documents related to its account and to exercise due care to prevent any unauthorised use of or access to its account by third parties. Any instruction or action authenticated and executed through the Client’s account is presumed to have been authorised by the Client. The Client acknowledges that devices, systems, software and networks on the Client’s side are outside nbnq’s control and may be vulnerable to unauthorised access. The Client must notify nbnq immediately of any suspected irregularity, compromise or unauthorised use.

THE CLIENT SHALL BE SOLELY RESPONSIBLE FOR THE LOSS OR MISUSE OF ITS DEVICES, SOFTWARE, CREDENTIALS OR AUTHENTICATION FACTORS AND SHALL BEAR THE CONSEQUENCES OF THEIR USE BY UNAUTHORISED PERSONS, EXCEPT TO THE EXTENT CAUSED BY nbnq’s WILFUL MISCONDUCT OR GROSS NEGLIGENCE.

4. Prohibition of Deposit Acceptance and Client Categorisation

4.1. nbnq does not accept deposits from the public. To the extent that nbnq itself receives non-interest-bearing fiat funds solely for the execution and settlement of a specific Client transaction, such balances may be maintained only in accordance with Article 5 paragraph 3 letter c of the Swiss Banking Ordinance ("BankO"). Where the statutory 60-day settlement period applies, the relevant transaction must be settled, or the funds otherwise returned or transferred in accordance with applicable law, within that period. nbnq does not pay interest on such balances.

4.2. Where a transaction cannot be completed within the legally permitted settlement period, nbnq may reject or cancel the transaction and return the relevant funds to the verified originating account or another verified account accepted by nbnq, subject to applicable anti-money laundering, sanctions, asset-freezing and other legal or regulatory requirements.

4.3. The Client is obliged to provide nbnq with accurate, current and complete Client Data, including bank account and wallet details, and any other information deemed necessary by nbnq for the provision of the Services. nbnq is entitled to rely on the information most recently provided by the Client as being current and accurate.

4.4. The Client shall indemnify, hold harmless and defend nbnq against third-party claims arising from the Client’s breach of its contractual obligations towards nbnq or applicable law, to the extent permitted by law.

4.5. Under Article 5 paragraph 2 letters a and d BankO, funds received from (a) domestic or foreign banks or other state-supervised companies and (b) institutional investors with professional treasury operations are not treated as deposits from the public where the applicable statutory conditions are met. Corresponding exclusions for collectively held crypto-based assets are set out in Article 5a paragraph 2 letters b and c BankO. Clients falling within these categories are referred to in these GTC as "Exempt Clients".

4.6. A Client requesting classification as an Exempt Client must provide all information and supporting documentation required by nbnq, including evidence of its regulatory status or professional treasury operations. nbnq shall determine, in accordance with applicable law and its internal classification policy, whether the relevant conditions are met and may reassess or withdraw the classification at any time. Classification as an Exempt Client does not create any entitlement to onboarding, continued access to the Services or acceptance of particular funds or virtual assets.

5. Service Provision and Instruction Execution

5.1. The Client must submit complete and accurate transaction instructions through the approved channel, maintain any required available balance, protect all login credentials, authentication factors and security features, and immediately notify nbnq of any suspected loss, compromise or unauthorised use. Any payment instrument made available by a Third-Party provider is additionally governed by that provider’s terms.

5.2. nbnq may, in its sole discretion, determine the acceptance and execution of instructions issued by the Client or any amount to be credited to an account of the Client. nbnq shall incur no obligation or liability to the Client as a result of implementing instructions that nbnq, in good faith and based on its internal verification procedures, believes to have been issued by the Client or its authorised Representative.

5.3. nbnq reserves the right to decline acceptance or execution of a Client instruction or any amount received in connection with the Client’s account, in whole or in part and without providing a reason where legally permitted. This applies in particular where nbnq considers an activity irregular, suspects a breach of these GTC or other applicable terms, or considers refusal necessary to comply with legal, regulatory, self-regulatory, contractual or internal requirements.

5.4. nbnq may request additional documentation or information from the Client or its Representatives at any time and may refuse, restrict, suspend or cease a Service where the documentation or information provided is insufficient.

5.5. If the Client issues an instruction that, individually or together with other orders, exceeds the Client’s available balance, nbnq may determine, at its discretion, which instructions and to what extent they will be executed.

5.6. DAMAGES RESULTING FROM DELAYS, LOSSES OR ERRORS IN THE TRANSMISSION OF INSTRUCTIONS SHALL BE BORNE BY THE CLIENT TO THE EXTENT THEY ARE NOT ATTRIBUTABLE TO nbnq’s BREACH OF ITS DUTY OF CARE. THE CLIENT SHALL ALSO BEAR LOSSES RESULTING FROM FORGERIES, UNAUTHORISED INSTRUCTIONS OR DEFECTS IN IDENTIFICATION OR CAPACITY THAT nbnq DID NOT DISCOVER, EXCEPT IN CASES OF nbnq’s WILFUL MISCONDUCT OR GROSS NEGLIGENCE.

5.7. Virtual-asset transfers are supported only between the Client’s nbnq custodial wallet and external wallets that have been verified and approved by nbnq as being owned or controlled by the Client in accordance with nbnq’s proof-of-control procedures. Transfers to or from external wallets owned or controlled by third parties are not supported. nbnq may require renewed proof of control at any time and may suspend, restrict or reject a transfer where ownership or control of the relevant external wallet cannot be satisfactorily established. Incoming transfers from an unverified external wallet may be held, restricted, investigated, rejected or, where technically and legally possible, returned.

6. Statements and Objections

6.1. The Client may access its transaction history and available account or wallet statements through the Platform. nbnq may additionally provide periodic or annual statements where required by law, agreed with the Client or made available operationally.

6.2. Any objection concerning a statement or an allegedly defective, delayed, unauthorised, incorrectly executed or non-executed transaction must be submitted to nbnq in writing within thirty (30) calendar days after the relevant statement or transaction information was made available through the Platform or otherwise communicated to the Client.

6.3. If no objection is submitted within the thirty (30) calendar-day period, the relevant statement and transaction information shall be deemed accepted by the Client to the fullest extent permitted by law. This does not prevent nbnq from correcting a manifest error. Failure to notify nbnq in a timely manner constitutes a breach of the Client’s duty to mitigate losses, and nbnq may charge the Client for reasonable costs and expenses caused by a delayed objection.

7. Fees and Expenses

7.1. nbnq may debit the Client’s account or balance for applicable fees, expenses, taxes, commissions, mark-ups and other charges in accordance with the applicable pricing schedule, product terms and law.

7.2. nbnq’s pricing schedule is provided to the Client separately, including through individual product or service agreements and dedicated pricing schedules.

7.3. nbnq reserves the right to adjust and amend its pricing schedules and other fees at any time. Changes will be communicated to the Client through the appropriate designated channels.

8. Rights of Retention, Lien and Set-off

8.1. As security for all present and future, actual or contingent claims of nbnq arising out of or in connection with the business relationship, including claims relating to fees, expenses, taxes, commissions, mark-ups, indemnities, transaction reversals, chargebacks, negative balances, losses, legal costs and Third-Party charges, the Client grants nbnq, to the fullest extent permitted by law, a contractual right of retention and lien over all fiat amounts, virtual assets, claims and other rights:

(a) held or controlled by nbnq for the Client; or

(b) in respect of which nbnq is entitled to issue transfer, blocking, conversion or disposal instructions under an applicable Third-Party arrangement.

nbnq may block, retain or withhold the release or transfer of such assets until its secured claims have been fully satisfied.

8.2. Where the Client is in default, the business relationship has been terminated, insolvency or enforcement proceedings have been initiated against the Client, or nbnq reasonably considers its claims to be at risk, nbnq may, to the extent permitted by law, declare its claims immediately due and:

(a) set off any amounts or assets owed to the Client against claims held by nbnq against the Client; and/or

(b) realise, sell, exchange or convert the relevant fiat amounts or virtual assets in a commercially reasonable manner and apply the proceeds towards satisfaction of its claims.

Set-off and conversion may be carried out irrespective of the currency or asset type involved. nbnq may apply a commercially reasonable exchange or conversion rate based on available market data and may deduct all reasonable costs connected with the retention, realisation, conversion or enforcement. nbnq may acquire an asset for its own account only where permitted by mandatory law and at a commercially reasonable market value.

9. Death, Insolvency, Legal Incapacity or Change of Authority

In the event of the death, presumed death, legal incapacity, bankruptcy, insolvency or dissolution of the Client, or the resignation, death, incapacity or termination of authority of a Representative, the Client, its Representatives or its legal successors must promptly notify nbnq and provide the documents required to establish succession, representation and authority. Upon becoming aware of such an event, nbnq may suspend or decline any instruction and may restrict the affected account or Services until the relevant authority has been satisfactorily established. Any loss resulting from delayed or incomplete notification shall be borne by the Client to the extent permitted by law, except to the extent caused by nbnq’s wilful misconduct or gross negligence.

10. Communication Protocols

10.1. nbnq and the Client will exchange documents and information primarily through the Platform, verified email addresses or other secure digital channels designated by nbnq. nbnq may also accept scanned copies through verified email where a manual process is used. Postal delivery or original documents may be required where applicable law, a competent authority or nbnq’s procedures require them.

10.2. nbnq may determine the form in which a document must be provided and may request an original, a certified copy, an acceptable electronic signature or additional verification where necessary. Where an original signed document is required, the original is deemed to be either (i) the original hand-signed physical document delivered by post or other approved means, or (ii) a document bearing a qualified electronic signature in accordance with Article 14 paragraph 2bis of the Swiss Code of Obligations in conjunction with the Federal Act on Electronic Signatures of 18 March 2016. For an unsigned document, the original is the physical or electronic original issued by the relevant authority or source, as accepted by nbnq.

10.3. Communications conveyed through a communication channel permitted under these GTC shall be deemed duly transmitted and validly effective upon dispatch to the address or contact details most recently provided by the respective party, unless mandatory law provides otherwise.

10.4. nbnq may process and, where legally permitted, record communications for service provision, security, evidentiary, quality-assurance, compliance and dispute-resolution purposes, as further described in Section 13 and the nbnq Data Protection and Privacy Notice. Operational, security and legally required communications are not marketing communications and may be sent regardless of the Client’s marketing preferences. Marketing communications will be sent only where permitted by law, and the Client may opt out at any time.

10.5. The use of communication channels permitted by these GTC, particularly unencrypted communications, entails risks that may result in loss or damage. In handling incoming and outgoing communications, orders, instructions and notifications, nbnq exercises due care and implements customary measures to identify and prevent fraudulent activity.

10.6. THE CLIENT ACKNOWLEDGES AND ACCEPTS THE RISKS ASSOCIATED WITH COMMUNICATION CHANNELS AND AGREES TO BEAR ANY LOSS OR DAMAGE THAT CANNOT BE ATTRIBUTED TO nbnq’s BREACH OF ITS DUTY OF CARE. IN PARTICULAR, THE CLIENT SHALL BEAR LOSS OR DAMAGE RESULTING FROM ITS OWN FAILURE TO EXERCISE DUE CARE OR FROM RISKS OUTSIDE nbnq’S SPHERE OF INFLUENCE, INCLUDING THE USE OF OR TRANSMISSION TO, FROM OR THROUGH ANY DEVICE, SYSTEM, SOFTWARE OR NETWORK OUTSIDE nbnq’S CONTROL.

11. Notification and Information Obligations

11.1. The Client shall promptly notify nbnq of any change to information held by nbnq or any other relevant information, including name, address, domicile, email address, telephone number, bank account or wallet details and other data relevant to the business relationship, a Service or a transaction. nbnq is entitled to rely on the most recently notified information provided by the Client.

11.2. Upon request, the Client shall promptly provide information reasonably required for legal, regulatory, tax, contractual or compliance purposes, including information concerning the background and purpose of the business relationship, individual transactions, source of funds or assets, tax residence, taxpayer identification number and any relevant FATCA or CRS classification or U.S. indicia where required by nbnq or a Third Party.

11.3. The Client is responsible for ensuring that all information provided to nbnq is complete, accurate, current and not misleading. Where nbnq is required to undertake special efforts to maintain contact with the Client, prevent dormancy or clarify outdated or incomplete information, the Client shall bear the reasonable resulting costs. Such costs are non-refundable.

12. Outsourcing and Third-Party Involvement

12.1. Subject to applicable law, nbnq may outsource operations, business areas, systems, Services and functions, in whole or in part, including IT and research, compliance and risk control, internal audit, client onboarding and servicing, anti-money laundering, due diligence and monitoring, forensic services, administration, transaction and exchange-execution support, and custody or safekeeping of virtual assets, to service providers situated within or outside Switzerland (collectively, "Outsourcing Partners"). Outsourcing Partners may engage subprocessors. This may require the processing, transmission and disclosure of data relating to the Client, including client-identifying data ("CID") and Personal Data relating to directors, officers, shareholders, beneficial owners, controlling persons, Representatives and other connected persons. The Client acknowledges that such data may be processed by Outsourcing Partners and their subprocessors within or outside Switzerland in accordance with applicable law and the nbnq Data Protection and Privacy Notice.

12.2. The provision of the Services may require nbnq to cooperate, directly or indirectly, with partner banks, correspondent banks, payment and clearing systems, payment networks, card issuers, card processors, card schemes, financial messaging systems, crypto exchanges, liquidity providers and other execution providers, custody and wallet-infrastructure providers, blockchain networks, KYC/KYB providers, sanctions-screening providers, blockchain analytics providers, Travel Rule providers and other financial or technology service providers in Switzerland or abroad (collectively, "Third Parties"). The Services may be subject to the legal, regulatory, sanctions, market-integrity, payment-network, card-scheme, execution, technical, operational and contractual requirements of such Third Parties. Those requirements may change and may result in a transaction or Service being rejected, delayed, suspended, restricted, reversed or unavailable, without liability on the part of nbnq where nbnq has acted in accordance with applicable law, these GTC or the relevant Third-Party requirements.

12.3. The Client acknowledges that Third Parties may require information to fulfil their internal, legal, regulatory and contractual compliance obligations, particularly in relation to anti-money laundering, sanctions, embargoes, fraud prevention and market-conduct requirements. The Client must promptly provide nbnq with the information required to satisfy such obligations, including information concerning the circumstances and background of a planned or completed transaction.

12.4. Where nbnq considers it necessary to comply with internal, legal, regulatory, contractual, due-diligence or market requirements, nbnq may limit or suspend Services in whole or in part. nbnq may in particular decline or refrain from executing an order, refuse a particular asset, block or restrict an account or wallet, halt a withdrawal or deposit, or take another measure considered necessary.

12.5. ANY LOSS RESULTING FROM THE NON-EXECUTION OR DELAYED EXECUTION OF AN ORDER OR INSTRUCTION SHALL BE BORNE BY THE CLIENT WHERE nbnq ACTED IN ACCORDANCE WITH APPLICABLE LAW, REGULATORY OR SELF-REGULATORY REQUIREMENTS, THESE GTC OR APPLICABLE THIRD-PARTY REQUIREMENTS, EXCEPT TO THE EXTENT CAUSED BY nbnq’S WILFUL MISCONDUCT OR GROSS NEGLIGENCE.

12.6. Certain Third Parties may require the Client to accept their own terms and conditions before their services can be used, directly or through nbnq. A list of relevant Third Parties may be made available upon request or through the Platform. By using a Third-Party service, the Client:

(a) accepts the terms and conditions applicable to that Third-Party service; and

(b) authorises nbnq, where necessary, to initiate payments, transfers or other transactions on the Client’s behalf through the Third Party’s systems.

12.7. nbnq may be required under applicable legal, regulatory or contractual provisions to disclose the identity of the Client, including its beneficial owner or other relevant controlling persons, to Third Parties involved in executing or processing a transaction inside or outside Switzerland. Those Third Parties may further transmit the data for processing or storage in other jurisdictions.

12.8. Personal Data disclosed or otherwise processed outside Switzerland remains subject to nbnq’s obligations under applicable Swiss data-protection law in relation to the disclosure and processing activities for which nbnq is responsible. Such Personal Data may additionally be subject to the laws, regulatory requirements and lawful access rights of the destination jurisdiction, which may provide a different level of protection or different rights and remedies from those available in Switzerland. nbnq applies the transfer mechanisms, transparency requirements and safeguards required under applicable law, as further described in the nbnq Data Protection and Privacy Notice.

12.9. nbnq requires Outsourcing Partners acting as processors to observe appropriate confidentiality, information-security and data-protection obligations and, where applicable, to impose corresponding obligations on approved subprocessors. Where Personal Data or CID is transferred to a jurisdiction that does not provide an adequate level of data protection, nbnq applies an appropriate transfer mechanism or safeguard recognised under applicable law, as further described in the nbnq Data Protection and Privacy Notice.

12.10. IN RELATION TO SERVICES PERFORMED BY THIRD PARTIES OUTSIDE nbnq’s DIRECT CONTROL, nbnq’S LIABILITY IS LIMITED, TO THE FULLEST EXTENT PERMITTED BY LAW, TO THE DUE CARE EXERCISED IN SELECTING, INSTRUCTING AND ENGAGING THE RELEVANT THIRD PARTY, SUBJECT TO SECTION 17.

13. Personal Data and Data Protection

13.1. nbnq processes Personal Data in accordance with the Swiss Federal Act on Data Protection (FADP), the Swiss Data Protection Ordinance and any other data-protection laws applicable to the relevant processing activity. Where a particular processing activity falls within the territorial or substantive scope of the General Data Protection Regulation (GDPR), the corresponding GDPR requirements also apply.

13.2. nbnq may transmit information or Personal Data concerning a Client, connected persons or account activity to law-enforcement bodies, state authorities, financial institutions and other competent recipients where the transmission is required or permitted by applicable law, necessary to provide the Services, or necessary to investigate a suspected breach of these GTC or applicable law.

13.3. nbnq may process approximate or precise location data where necessary for identity or address verification, security, fraud prevention, authentication, jurisdictional eligibility or transaction-risk controls, as further described in the nbnq Data Protection and Privacy Notice.

13.4. Where legally permitted and operationally implemented, nbnq may record telephone, video or other communications for transaction evidence, security, quality assurance, training or dispute resolution. Participants will be informed in advance, and consent will be obtained where required. Not all communications are recorded, and nbnq does not guarantee that a recording of a particular communication will be retained or retrievable.

13.5. nbnq may use Client information to operate, review, develop and enhance its products, Services and controls. This may involve disclosing information to partners, affiliates, agents, distributors, suppliers and other service providers for transaction processing, support, statistical analysis and other purposes described in the nbnq Data Protection and Privacy Notice.

13.6. nbnq may use profiling and analytics for service provision, security, fraud prevention, compliance and risk-management purposes as described in the nbnq Data Protection and Privacy Notice. Marketing communications will be sent only where permitted by law and, where required, after separate consent has been obtained. The Client may object to direct marketing or withdraw consent at any time with effect for the future.

13.7. The Client acknowledges that Client Data may be used and presented as evidence in proceedings relating to a disputed instruction or transaction and for the purpose of complying with legal, regulatory or evidentiary requirements.

13.8. nbnq generally retains Client, onboarding, KYC/KYB, account, wallet, transaction and contractual records for ten (10) years after the end of the relevant business relationship or completion of the relevant transaction. Other Personal Data is retained for as long as required or permitted for the relevant purpose, including compliance, accounting, contractual, dispute-resolution, security and fraud-prevention purposes. A longer retention period may apply where required by law or due to a pending investigation, regulatory matter, dispute or legal claim.

13.9. The principles applied by nbnq when processing Personal Data, the purposes of processing, categories of recipients, international transfers, profiling and data-subject rights are described in the nbnq Data Protection and Privacy Notice available at https://nbnq.ch/data-protection/. nbnq may update that Notice to reflect legal, regulatory, technical or operational changes.

14. Foreign-Currency Transactions and Currency Conversion

14.1. Where currency conversion is available through the Platform or a Third-Party provider, the applicable exchange rate, margin, fees and estimated amount to be received will be displayed or otherwise communicated to the Client before confirmation.

14.2. A payment or transfer received in a currency that is not supported by the relevant account may be rejected, returned or converted only where the Client has agreed or the applicable Third-Party terms permit such treatment.

14.3. A returned, reversed or delayed transaction may be converted at the exchange rate applicable when the funds are received back and may result in exchange-rate differences or additional charges.

14.4. Unless otherwise agreed, the reference currency for pricing and invoicing is Swiss francs (CHF).

15. Exchange Rates

Where currency conversion is offered, the applicable exchange rate, margin and fees will be displayed or otherwise communicated before the Client confirms the transaction. Rates may be supplied by a Third-Party provider or market-data source and may change until the transaction is confirmed. By confirming the transaction, the Client accepts the displayed rate and charges.

16. Public Holidays

For the purposes of the relationship between the Client and nbnq, Saturdays, Sundays and official public holidays of the Swiss Confederation and of the Canton and City of Zug are non-business days. Depending on the jurisdictions and Third Parties involved in an individual transaction, additional local holidays or non-processing days may apply and may affect execution, processing or settlement.

17. Liability of nbnq

17.1. nbnq’s obligation towards its Clients consists of and is limited to the diligent performance of its Services and contractual duties and, where applicable, the diligent selection and instruction of Third-Party service providers.

17.2. Any liability of nbnq for loss or damage incurred in the absence of a breach of nbnq’s duty of care is excluded to the fullest extent permitted by law. This exclusion includes, without limitation, force majeure, local or global epidemics or pandemics, delays or failures of banks or other Third Parties, postal or electronic communication failures, payment-network or blockchain-network disruptions, accidents, emergencies, acts of God, abnormal or unforeseeable circumstances, and losses resulting from requirements imposed by Swiss law, VQF, FINMA, MROS, another competent authority or any other applicable law or regulatory obligation.

17.3. Where loss or damage results from nbnq’s breach of its applicable duty of care, nbnq is liable only for direct loss caused by wilful misconduct or gross negligence. nbnq excludes liability for indirect, incidental, special or consequential loss to the fullest extent permitted by law. Nothing in this clause excludes or limits liability where exclusion or limitation is prohibited by mandatory law, including Article 100 paragraph 1 of the Swiss Code of Obligations.

17.4. nbnq is not liable for loss or damage attributable to events or risks outside its sphere of influence or for loss or damage caused or aggravated by the Client, its Representatives or persons for whom the Client is responsible.

18. Restrictions on the Use of nbnq’s Services

18.1. The following activities are prohibited:

(a) using the Services for any illegal purpose, including fraud, money laundering, terrorist financing, trafficking in counterfeit products, unlawful gambling, or the unlawful purchase or sale of tobacco, firearms, prescription drugs, controlled substances or other prohibited goods or services;

(b) breaching these GTC or any other agreement, policy or Third-Party terms applicable to the Client;

(d) using the Services in violation of any law, statute, ordinance, regulation, sanction, court order or regulatory requirement;

(e) infringing nbnq’s or a third party’s copyright, patent, trademark, trade secret, other intellectual-property right, publicity right or privacy right;

(f) providing false, inaccurate, incomplete or misleading information to nbnq or a Third Party;

(g) instructing nbnq to send or receive funds or virtual assets that nbnq reasonably believes may be fraudulent, unlawful or connected with prohibited activity;

(h) refusing to cooperate with an investigation or refusing to provide confirmation of identity, source of funds or assets, transaction background or other information reasonably requested by nbnq;

(i) permitting any account, wallet or currency balance to become negative, unless expressly authorised by nbnq or the relevant Third Party;

(j) using the Services in any way that disrupts, interferes with, compromises or places an unreasonable burden on nbnq systems or the Services, including by introducing malicious code, using anonymising tools to evade controls, using automated tools to access or copy the Services without permission, bypassing security measures, intercepting data or attempting to interfere with the operation of the Services;

(k) taking any action that may cause nbnq to lose or have restricted any service provided by an internet service provider, payment processor, bank, card provider, custody provider, liquidity provider or other supplier;

(l) using the Services in a manner that nbnq believes may violate an applicable payment-network, card-scheme, blockchain-network or other Third-Party rule;

(m) refusing or failing to provide further information concerning the Client, its business activities, connected persons or transactions that nbnq may reasonably request.

(n) using the Services to send virtual assets to, or receive virtual assets from, any external wallet unless that wallet has first been verified and approved by nbnq as being owned or controlled by the Client in accordance with nbnq’s proof-of-control procedures. Transfers involving external wallets owned or controlled by third parties are not supported. nbnq may permit a limited micro-transfer or other verification transaction solely for the purpose of establishing proof of control over an external wallet;

(o) using the account or Services to provide payment, money-transmission, collection, settlement or similar services to or on behalf of any third party, or otherwise operating a platform, nested account, pass-through arrangement or payment intermediary for persons other than the Client, without nbnq’s prior written consent. This prohibition does not prevent ordinary commercial payments made or received by the Client for its own account in connection with its declared business activities, provided that the Client is not acting as a payment service provider or intermediary for another person.

18.2. Unless expressly approved by nbnq, withdrawals of virtual assets may be made only to an external wallet that has been verified as being owned or controlled by the Client and has been approved or whitelisted in accordance with nbnq’s procedures. Verification or whitelisting of a wallet does not create an obligation for nbnq to execute any transaction. nbnq may reject, restrict, delay or require additional review of any transaction involving a third-party wallet.

18.3 The Client must use the Services only for lawful purposes and in connection with activities, goods, services and transactions that comply with applicable law, these GTC and any applicable Third-Party or network rules. nbnq’s processing or acceptance of a transaction does not constitute confirmation that the underlying activity is lawful.

18.4. nbnq may refuse to perform a transaction directly or indirectly associated with a restricted country, sanctioned person or entity, exposed person or company, or other prohibited risk, including under applicable Swiss SECO sanctions, United Nations sanctions and, where relevant to nbnq or a Third Party, EU, UK, OFAC or other international restrictive measures.

18.5. If nbnq believes that the Client may have breached these GTC or that action is otherwise required to protect nbnq, other users or third parties, nbnq may take one or more of the following measures:

(a) close, suspend or limit the Client’s access to its account or any Service;

(b) contact other users who have transacted with the Client, the Client’s bank or relevant Third Parties, and where legally permitted warn affected persons, law-enforcement bodies or other competent authorities;

(d) initiate legal or enforcement action against the Client;

(e) terminate the business relationship, these GTC or access to the website, Platform or Services;

(f) fully or partially reverse, return or refuse a transaction where technically and legally possible or where required by a competent authority or Third Party; and/or

(g) temporarily or permanently block the Client’s account, wallet, assets or access to the Services.

18.5. Where feasible and legally permitted, nbnq will provide the Client with relevant information regarding a measure imposed under this Section. nbnq may withhold such information where disclosure is prohibited, could reveal protected third-party information, could facilitate circumvention of controls or could interfere with an investigation.

19. Miscellaneous Provisions

19.1. If any provision of these GTC is or becomes invalid or unenforceable, the remaining provisions remain binding. Any resulting gap shall be addressed in a manner that, to the extent legally possible, preserves the economic purpose and contractual balance of the affected provision.

19.2. The Client may not assign the business relationship or any obligation arising under it to a third party without nbnq’s prior written consent.

19.3. nbnq does not provide investment, legal, tax or other professional advice. Information made available by nbnq is for general informational purposes only and does not constitute a recommendation or advice. The Client makes all decisions concerning the use of the Services independently and at its own risk.

20. Amendments to the GTC

20.1. The current version of these GTC is available on the nbnq website or through the Platform.

20.2. nbnq may amend these GTC at any time. nbnq will notify the Client of material amendments in advance through an agreed communication channel under Section 10, unless an immediate amendment is required by law, a competent authority, security considerations or a Third-Party requirement.

20.3. The Client is deemed to have accepted amended GTC unless it objects in writing within thirty (30) calendar days after receipt of the notice. The notice will explain the objection period and the consequences of remaining silent. Where the Client objects, nbnq may terminate or restrict the affected Service or business relationship.

21. Term and Termination of the Business Relationship

21.1. The business relationship between the Client and nbnq is established for an indefinite period.

21.2. nbnq or the Client may terminate the business relationship at any time with immediate effect, subject to mandatory law and any transaction or restriction that must remain in place. Fees, expenses, costs and other amounts already incurred become immediately due and payable.

21.3. Any remaining fiat funds or virtual assets will be transferred to a verified account or wallet designated by the Client, subject to compliance checks, legal restrictions and deduction of amounts owed to nbnq. If valid instructions are not provided, nbnq may retain the remaining balance pending clarification or otherwise deal with it in the manner permitted by law and may charge the related costs.

22. Dormant (Inactive) Accounts

22.1. nbnq may classify a Client as dormant or inactive where no Client-initiated transaction has been executed on any of the Client’s accounts or wallets for more than twelve (12) consecutive months. Fees or charges debited by nbnq are not treated as Client-initiated transactions. nbnq may amend the applicable inactivity period and will notify the Client where required.

22.2. Once classified as dormant, the Client may, subject to applicable legal and regulatory requirements, request closure or reactivation of its account or wallet.

22.3. nbnq may suspend or block a dormant account or wallet and may refuse credits, debits, transfers or other operations until it has been reactivated.

22.4. To reactivate a dormant account or wallet, the Client must submit a reactivation request and may be required to complete renewed identification, due-diligence, security and data-update procedures. Reactivation is subject to nbnq’s approval and any applicable Third-Party requirements.

22.5. nbnq may charge dormancy, administration, reactivation or closure fees in accordance with the applicable pricing schedule. nbnq may close a dormant or inactive account or wallet with a zero balance or with a balance insufficient to cover the applicable fees and may apply the remaining balance towards those fees, subject to applicable law and any legally required notice.

23. Intellectual Property Rights

23.1. The Services, the website, the Platform and all intellectual-property rights contained in or relating to them, including content, software, designs, databases, domain names, trademarks, trade dress, page headers, graphics, icons and scripts, are owned by or licensed to nbnq. nbnq’s intellectual property includes, where applicable, "nbnq.ch", "nbnq.io", "nbnq.dev". Reproduction, imitation or use without nbnq’s prior written consent is prohibited and may result in legal action or suspension of access to the Services.

23.2. nbnq reserves all rights in its intellectual property and remains entitled to use, licence, protect and enforce those rights as it considers appropriate.

23.3. Nothing in these GTC grants the Client any right in the website, Platform or Services except the limited right to access and use them in accordance with these GTC. The Client must not alter, circumvent or remove any proprietary, intellectual-property, digital-rights or security notice or mechanism contained in the website, Platform or Services.

24. Applicable Law and Jurisdiction

24.1. All legal matters between the Client and nbnq are governed by and construed in accordance with the substantive laws of Switzerland, excluding its conflict-of-law rules.

24.2. The exclusive place of jurisdiction for all legal proceedings is the City of Zug, Switzerland, subject to any mandatory place of jurisdiction.

24.3. Notwithstanding Clause 24.2, nbnq may initiate proceedings at the Client’s domicile or before any other competent court or authority where permitted by applicable law, particularly in connection with enforcement, interim measures, insolvency or international asset recovery.