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Terms & Conditions

PRELIMINARY INFORMATION AND INTRODUCTION

These General Terms and Conditions (“General Terms and Conditions” or “Terms”) constitute an agreement between you (herein referred to as “you” and “Client”) and BFINANCE EOOD (herein referred to as “Provider,” “Blockforia,” “we,” “us”, “our”), which governs: (i) access to and use of the Blockforia website and platform; and (ii) the terms and conditions for the provision of services, including the service of “custody and administration of crypto-assets on behalf of clients” (Article 75 of Regulation (EU) 2023/1114 – “MiCA”).

By signing up for an account, clicking the “Agree” button (or its equivalent), signing or electronically accepting these Terms, and by using the Platform, you confirm that you have read, understood, and accepted these Terms and any supplements thereto.

If you do not agree to these Terms, do not use the Platform and/or discontinue your use of it by closing your account and withdrawing or transferring your available crypto-assets in accordance with these Terms.

RISK WARNING

You should be aware that the risk of loss in trading or holding crypto-assets can be substantial. Investing in crypto-assets involves significant risk. The value of crypto-assets is highly volatile and can fluctuate significantly over short periods of time. You may lose some or all of your investment. Crypto-assets are not covered by deposit guarantee schemes or investor compensation schemes under EU law.

Crypto-assets are high-risk and highly volatile. Transactions on blockchain networks are irreversible by definition. Before using these services, carefully consider whether they are appropriate for you, taking into account your financial situation and risk profile. You

bear full responsibility for the protection of your login details. Losing access could result in the permanent loss of your crypto-assets.

Preliminary Information

BFINANCE provides preliminary information about its services to all of its clients (individual and corporate), including: (i) the identity of the CAMC and its regulatory status; (ii) all services and the associated risks; (iii) the fees and the method of their calculation; (iv) the procedure for filing Complaints; (v) the applicable law and the competent court.

The information described is made available in a transparent and understandable manner prior to the acceptance of the registration confirmation and the General Terms and Conditions (for individual clients – natural persons) or the relevant Service Agreement with corporate clients (for corporate clients). The Client cannot complete the registration process without checking the box “I have read and accept the Terms and Conditions”; however, the Terms and Conditions are freely available on the Company’s website for individual clients to review before agreeing to them, and corporate clients can receive a sample Corporate Client Service Agreement via email upon request from support@bfinance.com.

1. PROVIDER INFORMATION AND SCOPE

1.1. Provider

The service provider is BFinance EOOD, Company Registation No. 206805699, operating under the brand name “Blockforia,” website: www.blockforia.com, address: Sofia City, 11 Petko R. Slaveykov Sq, fl. 6, Bulgaria, email: support@blockforia.com.

1.2. Scope

These Terms and Conditions apply to all visitors and users of the website and the Platform, as well as to all services that the Provider offers through them to individual Clients. Special terms and conditions apply to corporate clients (legal entities), as separately agreed upon by the parties in an individual agreement.

1.3. Regulatory Status

BFINANCE is a crypto-asset service provider whose activities, falling within the scope of Regulation (EU) 2023/1114 on Markets in Crypto-Assets (“MiCA”), are subject to regulatory oversight by the competent authority in the Republic of Bulgaria – the Financial Supervision Commission (“FSC”), following the issuance of the relevant authorization/license.

Information regarding the status of the license, applicable registrations, the competent supervisory authority, and any material changes to BFINANCE’s regulatory status is published on the website. The Provider may also hold other registrations or certificates, including the registration or certificate number listed on the title page.

1.4. Appendices to the General Terms and Conditions

These General Terms and Conditions include the following appendices, which form an integral part thereof: Appendix 1 (Summary of the Custody Policy); Appendix 2 (Fee and Commission Schedule); Appendix 3 (List of Supported Crypto-Assets); Appendix 4 (Prohibited and Restricted Use Policy); Appendix 5 (Verification Procedures and Restrictions); Appendix 6 (Electronic Delivery of Notices and Electronic Signatures); Appendix 7 (Disclosure Regarding Bitcoin – Article 66(3) of MiCA).

2. DEFINITIONS

Unless the context requires otherwise, the following terms and abbreviations have the meanings specified below:

Term Definition
“Platform” The web-based “Blockforia” platform and related features available via www.blockforia.com and/or other official domains/apps of the Provider.
“Profile/Account” A user profile on the Platform created in the name of the Client, after registering and successfully passing the applicable checks.
“Crypto-Asset” A digital representation of value or a right that can be transferred and stored electronically using DLT or similar technology (as defined in MiCA).
“Digital Currency / Cryptocurrency” A type of crypto-asset used as a medium of exchange (e.g., Bitcoin).
“DLT” Distributed ledger technology.
“Wallet” A hosted wallet/address or a set of addresses and/or an internal accounting entry used to record the Client’s rights to crypto-assets within the Platform.
“Register of Positions” A register maintained by the Provider in the name of each Client, reflecting the Client’s rights to the crypto-assets held in custody, pursuant to Article 75(2) of MiCA.
“Instruction” A valid order/instruction from the Client via the Platform (or other agreed-upon channel) for performing transactions involving crypto-assets (e.g., transfers, withdrawals).
“Fees/Rates” Fees, charges, and commissions for services and actions published on the Platform and/or in Appendix 2.
“MiCA” Regulation (EU) 2023/1114 on Markets in Crypto-Assets, including subsequent amendments and applicable implementing acts.
“CAMC” Crypto-Asset Management Company.
“GTC” These General Terms and Conditions.
“BTC” Bitcoin.
“AML/CFT” Anti-Money Laundering and Countering the Financing of Terrorism.
“PEP” Politically Exposed Persons.
“KYC” Know Your Client – procedures for identifying and verifying a client’s identity.

3. ELIGIBILITY. REGISTRATION AND ACCESS

3.1 Age and Legal Capacity

To use the Provider’s services, you must be at least 18 years old and have the legal capacity to enter into contracts. To be eligible to use BFINANCE’s services, you must:

  • Be an individual at least 18 years of age.
  • Have full legal capacity to enter into a legally binding contract with us.
  • Not be a citizen or resident of a jurisdiction outside the European Economic Area.
  • Not be prohibited from accepting these Terms and Conditions and using the BFINANCE website and services.
  • Agree to use the BFINANCE website and services strictly in accordance with these General Terms and Conditions and applicable law.

Your right to access certain BFINANCE services also depends on the country in which you reside.

BFINANCE also provides its services to legal entities, subject to additional terms and conditions. Legal entities wishing to apply for BFINANCE’s services may contact us by email, after which they will receive our standard agreement for corporate clients.

3.2. Services Provided

We provide the following BFINANCE services, which are explained in more detail in Section 5:

  • Custody and Administration of Crypto-Assets (Custody) – BFINANCE allows you to hold your crypto-assets with us following a transaction to exchange fiat currencies for crypto-assets.
  • Crypto-Asset Exchange Service – allows you to convert fiat currency into crypto-assets or vice versa.
  • Crypto-Asset Transfer Service – allows you to transfer converted crypto-assets to a third party through your account with us. Transfer Completion Timeframes: The Company executes transfer orders within the following maximum timeframes: (i) internal transfer (between accounts within the Platform) – up to 1 (one) minute; (ii) external transfer on the Bitcoin network – up to 30 (thirty) minutes. These timeframes may be extended in the event of blockchain network congestion, if the order is suspended or rejected, or due to AML/CFT checks and sanctions. For a transfer, the Client is only charged network fees.

3.3. Geographical Restrictions

    Access to certain services may be restricted depending on the country of residence or incorporation, sanctions regimes, or internal risk management policies. The Provider may refuse to provide services when required or justified by law or for regulatory or risk-related reasons.

    3.4. Registration

    To use services that require an account, you must register and create an account by providing the requested information (e.g., name/company name, email address, password) and accepting these Terms. The Provider may, at its sole discretion, refuse to create a Profile or limit the number of profiles you may have.

    3.5. Access

    To access the Platform, you need a device and an Internet connection. You are responsible for any costs associated with your Internet access and for meeting the minimum technical requirements published by the Provider (if any).

    3.6. Authentication

    Access to the Profile and the submission of Instructions are carried out by logging in to the Platform. The Provider may use multi-factor authentication (MFA) and other control measures. You are required to keep your login details confidential and to keep your contact information up to date.

    4. CUSTOMER IDENTIFICATION. AML/CFT. SANCTIONS

    4.1. Identity verification

    Before you are authorized to use certain services, the Provider requires that you complete identity verification (KYC) and risk assessment procedures, as well as provide documents and/or information in accordance with applicable laws and internal procedures (AML/CFT).

    4.2. Data and Documents

    The requested information may include, but is not limited to: names/company name, address, date of birth, personal identification number/foreign identification number, tax identification number, identification document, phone number, email address, information on the source of funds (SoF) and source of wealth (SoW), as well as other data necessary for risk assessment and compliance with the law.

    4.3. Third-Party Verification and Screening

    The Provider may conduct checks directly or through third parties (KYC/AML service providers), including sanctions and politically exposed person (PEP) checks, as well as transaction monitoring. By providing this information, you confirm that it is accurate and up-to-date, and you agree to notify the Provider of any changes.

    By accepting these Terms and Conditions, you, as a Client, acknowledge and agree that we may make inquiries, either directly or through third parties, that we deem necessary to verify your identity or to protect you and us from fraud or other financial crimes.

    To comply with anti-money laundering, countering the financing of terrorism, and regulatory requirements, we implement a rigorous client verification process. The process involves checking registered clients against sanctions lists and lists of politically exposed persons. To comply with regulatory requirements, we may need to determine the source of your funds and wealth. Checks are conducted at the time of initial registration and subsequently at regular intervals.

    4.4. Enhanced Due Diligence (EDD)

    Under certain circumstances (e.g., increased risk, limits, suspicious transactions), the Provider may request additional information or documents, an in-person or video identification, or other measures. In the event of non-compliance, the Provider may restrict or terminate your access to certain services.

    4.5. AML/CFT-Based Refusal or Termination

    The Provider may refuse to open an Account, block transactions, or suspend or terminate the relationship when it has reason to believe that this is necessary to comply with the law or to prevent fraud, money laundering, terrorist financing, or other financial crimes.

    4.6. Electronic Delivery of Notices

    You agree to receive electronically all communications, agreements, documents, notices, and disclosures related to your account and your use of our services. Details regarding the electronic delivery of notices and consent to electronic signatures are set forth in Section 17 and Appendix 6 of these Terms and Conditions.

    5. SERVICES

    5.1. General Information

    BFINANCE’s services are available only through the Company’s website www.blockforia.com, after successfully registering as a Client (i.e., opening an account with us), as described above.

    We provide only the services of BFINANCE; we do not provide any other services, including personalized investment recommendations, investment advice, or tax advice, nor do we assess whether a particular instrument is suitable for you. Any decision to buy or sell a crypto-asset is entirely yours.

    5.2. Account and Wallet

    You will be able to view your account balance and transaction history on the BFINANCE website, including: (i) the amount and currency of each crypto-asset transaction; (ii) a reference for identifying the payer and/or the payee; (iii) all fees charged; (iv) the exchange rate and the amount after conversion; and (v) a statement of the status of the crypto-assets, provided on a quarterly basis.

    5.3. Supported Crypto-Assets

    BFINANCE’s services are only available in connection with Bitcoin (BTC). The current list of supported crypto-assets is published on the Platform and in Appendix 3 to these Terms and Conditions.

    The Client should be aware that Bitcoin is a decentralized crypto-asset with no identified issuer. In accordance with Article 66(3) of MiCA, BFINANCE provides Clients with a hyperlink to publicly available information regarding Bitcoin: https://bitcoin.org/. The hyperlink provided is for informational purposes only. BFINANCE does not control the content on bitcoin.org.

    Bitcoin uses the “Proof-of-Work” consensus mechanism. Crypto-assets that rely on such a mechanism can have a significant negative impact on the climate and the environment due to their high energy consumption. Under no circumstances should you attempt to use your Wallet for crypto-assets that we do not support.

    5.4. Crypto-Asset Exchange – General Information

    The Platform allows users to buy and/or sell supported crypto-assets in exchange for fiat currency or via payment instruments (e.g., a card), as well as to convert between supported crypto-assets, in accordance with the features available on the Platform. The “Crypto-Asset Exchange” service is provided in accordance with Article 77 of Regulation (EU) 2023/1114 (MiCA).

    Your account allows you to purchase crypto-assets using fiat funds supported by the Provider, and vice versa – when you sell crypto-assets, you can receive fiat funds in a supported currency. BFINANCE exchanges fiat currency exclusively for Bitcoin (BTC). All exchange transactions are executed using the Company’s own fiat funds.

    5.5. Payment Methods and Supported Currencies

    The supported fiat currencies are EUR, NOK, DKK, SEK, HUF, and PLN. You can pay the purchase price using a VISA/Mastercard card or by transferring funds from your payment account with your payment service provider. Upon sale, you authorize the Provider to credit the corresponding amount of fiat currency to your VISA/Mastercard card or to the relevant payment account.

    The availability of a specific payment method depends on a number of factors (location, identification results, limits, payment scheme/bank rules, etc.). To process payments, the Provider may use third-party payment service providers

    whose data is provided at the time of the transaction. Your payment service provider may refuse to process the transaction for reasons beyond the Provider’s control. Fiat funds may be debited from your payment account before the corresponding crypto-assets are credited to your Wallet.

    It is not possible to hold fiat (cash) funds in your account with the Provider. BFINANCE does not hold fiat funds of retail individual Clients in accounts with the Company. When crypto-assets are sold, funds for individual clients are transferred to the payment account specified by the Client. The procedures for holding and safeguarding corporate clients’ funds are set forth in the Corporate Client Agreement and the Custody Policy.

    5.6. Exchange Rates, Spread, and Reference Price (Kraken; Article 73 of MiCA)

    Each purchase or sale is subject to the BFINANCE exchange rate for the respective transaction – the price of the relevant crypto-asset in fiat currency, as indicated on the Platform at any given time as the “Buy Price” or “Sell Price.” The Client acknowledges that the purchase price may not match the selling price at any given time and that the Provider may add a margin (“spread”) to the quoted rate. Before the order is finalized, the Client is provided with a fixed price that includes all applicable fees as set forth in Appendix 2. By confirming the transaction, the Client accepts the exchange rate and fees.

    To determine the real-time market price of Bitcoin, BFINANCE uses Kraken (Payward Ltd. – a regulated crypto-asset exchange) as a reference platform via a direct API connection. The price provided by this platform is a mandatory component of the Provider’s pricing mechanism. The Company does not take any positions of its own and does not assume market risk; each trade is executed at the reference market price at the time of the transaction, plus the applicable fee (see Appendix 2).

    The use of Kraken constitutes outsourcing within the meaning of Article 73 of MiCA. BFINANCE maintains contractual arrangements with Kraken in accordance with applicable outsourcing requirements. The complete list of critical service providers is available on the Company’s website.

    In the event of temporary or complete unavailability of the API connection with Kraken, the Provider may suspend the acceptance of new exchange orders for the duration of the unavailability, notifying Clients via an announcement on the website. Custody and transfer services are not affected by Kraken’s availability and continue to operate normally during

    an interruption. The Provider does not guarantee the availability of an exchange rate or the ability to buy or sell at a specific price at any given time.

    5.7. Procedure for Executing Exchange Orders

    BFINANCE processes exchange orders in accordance with the instructions received from the Client through the Client’s account. To complete a transaction, the Client enters the order details (the amount in Bitcoin or fiat currency) and selects “Buy” or

    “Sell”; Clients using the service for the first time can only choose

    “Buy.” When placing a sell order, the Client must also specify the payment account or the address recorded in the Register of Positions to which the fiat funds or crypto-assets, respectively, are to be transferred.

    Before finalization, the Client is presented with the fixed price of the transaction, including all applicable fees, in a supported fiat currency. The Client authorizes the order and confirms the submitted information using the appropriate options in their account.

    BFINANCE records the order as of the timestamp indicating its successful receipt by the Company’s systems, as recorded by the relevant transaction processing infrastructure. Once confirmed, orders cannot be canceled.

    The order is subject to validation and verification, which may result in a delay, suspension, or rejection of its execution (for the grounds, see Section 4 and Section 9).

    The Provider makes every reasonable effort to fulfill the orders; if this is not possible, the Provider notifies the Client and requests approval to make a new attempt at the current exchange rate. After a successful transaction, the Client is immediately notified of the details via their account, including any applicable fees and charges.

    The Provider does not hold the Client’s fiat funds in accounts with the Company. Upon sale, the funds are transferred immediately to the payment account specified by the Client. If the contract is terminated with an uncompleted transaction in which fiat funds have been debited from the Client but the crypto-assets have not been delivered, the Provider shall refund the full amount of the funds via the same payment method within 14 (fourteen) calendar days. Transaction data is available through the Client’s account for the entire duration of the relationship and for 5 (five) years after its termination.

    5.8. Authorizations, Failed Payments, and Cancellations

    By clicking the “Buy” or “Sell” button, the Client authorizes BFINANCE to initiate the transaction at the specified “Buy” or “Sell” price and accepts all associated fees. The Client cannot cancel, revoke, or modify a transaction that is marked as completed or in progress.

    If the payment fails or there are insufficient funds in the payment account, the Provider may refuse to fulfill the order and/or request reconfirmation, and the Client authorizes the Provider to cancel the transaction. The Client is responsible for maintaining a sufficient balance and/or credit limit to avoid overdrafts, insufficient funds fees, or similar fees charged by their payment service provider.

    5.9. Transaction Limits

    The use of BFINANCE’s services is subject to restrictions on the amount that can be traded or transferred during a given period:

    • Minimum amount: EUR 0 (zero euros);
    • Maximum amount: EUR 5,000 (five thousand euros) (or the equivalent in another currency, including crypto-assets);
    • Maximum number of transactions per 10 minutes: 10 (ten) transactions.

    The Provider may also apply additional limits depending on the Client’s verification level (see Section 9.2 and Appendix 5). The current limits are available on the Platform.

    5.10. Enhanced Due Diligence During Exchange Transactions

    The Provider may request additional information from the Client regarding the Client or the Client’s business, as well as documents and meetings with Company employees, including a scanned copy of a debit/credit card or passport, in accordance with Section 4.4 (EDD). As a rule, such a request is made when a client has purchased more than EUR 5,000 in a single day or EUR 50,000 in a single month. At its sole discretion, the Provider may refuse to increase the Client’s limits or may subsequently reduce them, even after enhanced due diligence has been performed.

    5.11. Disclosure of Completed Exchange Transactions (Article 77(4) of MiCA)

    In accordance with Article 77(4) of MiCA, BFINANCE publishes information on executed exchange transactions – including volumes and prices – on a publicly accessible page of the website www.blockforia.com (section “Market Information” / “Transactions”), accessible without registration. The information remains available until the end of the next business day following the date on which the relevant transaction was executed. The information disclosed to the public is in aggregated or anonymized form and does not contain any personal data of clients. The Client may view a detailed transaction history of their own account through the Platform for a period of 5 (five) years following execution.

    5.12. Withdrawal/Sale of Crypto-Assets

    You may sell all or part of the crypto-assets held in your Wallet at any time by selecting the appropriate option on the BFINANCE website and following the instructions. Unless otherwise agreed, when crypto-assets are sold, the funds will be transferred to the payment account you have provided to us.

    Before we process the sale of crypto-assets from your Wallet, we may conduct checks to prevent fraud, money laundering, terrorist financing, and other financial crimes.

    5.13. Unauthorized and Incorrect Transactions

    When a purchase, sale, or transfer of crypto-assets using your credentials is authorized through your account, we may and will assume that you have authorized that transaction, unless you expressly notify us otherwise.

    If you believe that you did not authorize a particular transaction or that it was processed incorrectly, you must contact us no later than 12 months after the transaction took place. It is important to check your Wallet balance and transaction history regularly.

    5.14. Refund Rights

    If an unauthorized transaction occurs for which BFINANCE is liable, we will reimburse you within one business day of the date on which we became aware of it, based on the market value of the crypto-assets at the time of the transaction. Additional Conditions:

    • If you commit fraud or fail to fulfill your obligations, whether intentionally or negligently, you will be liable for any and all resulting losses.
    • In the event of a dispute regarding an unauthorized transaction, we may temporarily freeze your balance until the dispute is resolved.
    • If a transaction is processed incorrectly, we will refund the amount to you without undue delay and restore your Wallet to its previous state.

    5.15. Security Incidents and Liability

    BFINANCE is liable for any loss of crypto-assets or the means to access them resulting from an incident that can be attributed to the Company. BFINANCE’s liability is limited to the market value of the lost crypto-assets at the time the loss occurred.

    You are required to report any incident as soon as possible and no later than 12 months after the incident. Incidents that cannot be attributed to BFINANCE include issues inherent in the operation of a distributed ledger over which the Company has no control.

    6. “CUSTODY AND ADMINISTRATION OF CRYPTO-ASSETS” SERVICE (MiCA, Art. 75)

    These General Terms and Conditions, in the part regarding the “Custody and Administration of Crypto-assets” service (Sections 6, 8, 9, 10, 13, and Appendix 1), fully incorporate and supersede the separate “Standard Service Agreement”

    for the “Custody and Administration of Crypto-Assets” service as defined in Article 75(1) of MiCA. By accepting these General Terms and Conditions, the Client also enters into the custody agreement required by MiCA, without the need for a separate document.

    6.1. Description

    The Provider offers the Client a service titled “custody and administration of crypto-assets on behalf of clients,” which includes the safekeeping or control (on behalf of the Client) of crypto-assets or the means of accessing them (including private cryptographic keys), as well as related administrative activities. The Company provides custody and administration services only in respect to Bitcoin acquired through a fiat-to-crypto exchange transaction with BFINANCE.

    BFINANCE does not provide its clients with individual distributed ledger addresses. All crypto-assets belonging to clients and held in custody by BFINANCE are consolidated into one or more addresses on distributed ledgers, registered in the name of BFINANCE and stored in a central cold wallet.

    6.2. Method of Provision

    The service is provided through the Platform and the Client’s Profile. Through the Platform, the Client can submit transfer/withdrawal instructions and receive information about their positions.

    6.3. Supported Crypto-Assets

    As of the date of this version, the Provider offers Bitcoin (BTC) custody services. The Provider may add or discontinue support for crypto-assets following a risk assessment and technical integration. The current list is published on the Platform and in Appendix 3 to these Terms and Conditions.

    6.4. Custody Policy

    The Provider maintains a Custody Policy that describes the principles, controls, and procedures for minimizing the risk of loss due to fraud, cyber threats, or negligence, in accordance with Article 75(3) of MiCA. A summary for clients is included in Appendix 1 and can be provided via email upon request.

    6.5. Register of Positions and Statements

    The Provider maintains a Register of Positions in the Client’s name and provides a statement at least on a quarterly basis and upon request, in electronic format, in accordance with Article 75(5) of MiCA.

    6.6. Segregation

    The Provider shall segregate the Client’s crypto-assets from its own crypto-assets and ensure that the means of access are clearly identified as belonging to the Client, including on the DLT, in accordance with Article 75(6) of MiCA. The Company does not engage in any activities involving crypto-assets for its own account, through decentralized finance applications, or in any other manner, other than those necessary to provide the service of exchanging funds for crypto-assets for clients.

    6.7. Withdrawals

    For security and control purposes, the Provider may not offer immediate withdrawals. Withdrawal requests are subject to verification procedures and approval, including AML/CFT checks and anti-fraud controls.

    6.8. Return of Crypto-Assets

    Upon termination of the agreement, the Provider shall ensure the transfer/return of the Client’s crypto-assets within 10 (ten) business days of receiving a valid transfer instruction, unless such execution is prevented by an order from a competent authority, AML/CFT checks, or technical reasons. Any fiat amounts

    owed to the Client shall be refunded via the same payment method within 14 (fourteen) calendar days of termination.

    6.9. Right of Withdrawal

    The Client may terminate the custody service at any time. The right of withdrawal under MiCA (Article 13) applies to natural persons acting outside the scope of a commercial or professional activity – only in the case of the purchase of crypto-assets in a public offering, provided that the relevant crypto-assets are not admitted to trading. Bitcoin is listed for trading on numerous platforms; therefore, the Company does not apply the right of withdrawal to purchases of Bitcoin.

    6.10. Change of Custody Provider and Portability of Crypto-Assets Client Rights

    At any time, the Client has the right to request the transfer of their crypto-assets

    and/or the means of accessing them from BFINANCE EOOD to another provider of a

    custody and administration of crypto-assets services as defined in MiCA (hereinafter referred to as “New Provider”), without being required to state any reason.

    Conditions for Transfer

    BFINANCE EOOD will process the transfer request provided that all of the following conditions are met:

    • The Client has submitted a valid written transfer request through their account on the Platform or via email to support@blockforia.com, containing: (i) the full name and contact information of the New Provider; (ii) the DLT address or other identifying information; (iii) confirmation that the New Provider is the recipient of the transfer.
    • All fees and amounts owed by the Client to BFINANCE EOOD have been paid.
    • BFINANCE EOOD has completed the applicable AML/CFT and sanctions compliance checks. The transfer order is not subject to a freeze or any other order issued by a competent authority.

    Processing Time

    BFINANCE processes a valid transfer request within 5 (five) business days from the date on which all conditions are met. If additional AML/CFT checks are required or for technical reasons, the deadline may be extended by an additional 5 (five) business days, in which case the Client will be notified immediately.

    Fees

    BFINANCE does not charge a separate fee for the administrative processing of a request to switch providers. The Client only pays the actual network fees (gas/miner fees) charged by the relevant blockchain network, in accordance with the Fee Schedule (Appendix 2). Network fees are disclosed to the Client prior to the confirmation of the transfer.

    Client Responsibility

    The Client bears full responsibility for the accuracy of the DLT address or identification information provided for the New Provider. BFINANCE EOOD is not liable for any loss of crypto-assets resulting from an incorrect address provided by the Client.

    Suspension of Processing

    BFINANCE EOOD may suspend the processing of a transfer request only when: (i) there is an order from a competent authority; (ii) there are reasonable grounds to suspect fraud or unauthorized access; (iii) the transfer would violate AML/CFT requirements or sanctions legislation. BFINANCE EOOD shall immediately notify the Client of the suspension and the reasons for it.

    7. HOSTED WALLET. CRYPTOASSET TRANSACTIONS

    7.1. Wallet

    The Platform may provide one or more hosted Wallets that allow users to store, track, transfer, and manage balances of supported crypto-assets.

    7.2. Instructions and Irreversibility

    The Provider processes crypto-asset transactions in accordance with the Instructions received from the Client. The Client should carefully review all details (address, network, amount, fees) before confirming the instruction. As a rule, transactions on blockchain networks cannot be reversed once they have been broadcast to the network.

    7.3. Network Confirmations

    A transaction is considered complete after 4 confirmations/validations on the respective network. Until then, it may be in “pending” status, and the funds associated with it may not be available for use.

    8. FEES AND PAYMENTS

    The fees for each service are described in detail in Appendix 2 (Fee and Commission Schedule), which is an integral part of these Terms and Conditions. The Provider shall present the fees to the Client in a clear, transparent, and understandable manner prior to the acceptance of the General Terms and Conditions and prior to the execution of any transfer instruction.

    8.1. Exchange Fee

    The Company charges a fixed trading fee of 8% on the value of each BTC purchase or sale for individual clients – natural persons. For corporate clients, the fee is negotiated on a case-by-case basis.

    8.2. Network Fees

    When transferring crypto-assets, the Client only pays the actual network fees (gas fees/miner fees) due. These fees are not set by the Company and are disclosed before the transaction is confirmed.

    8.3. Changes to Fees

    Any changes to the applicable fees will be communicated to the Client in advance. Within 14 calendar days of receiving notice of the changes, the Client may express their disagreement and terminate their business relationship with the Company.

    9. RESTRICTIONS, SUSPENSION, AND TERMINATION

    9.1. Suspension the Profile

    The Provider may temporarily suspend access to the Profile or to certain services in the following cases:

    (i) suspicion of fraud, unauthorized access, or a security breach; (ii) failure to comply with AML/CFT requirements; (iii) an order from a competent authority; (iv) technical reasons or scheduled maintenance.

    9.2. Transaction Limits

    The Provider may apply transaction volume limits (daily, weekly, monthly) based on the Client’s verification level. The current limits are published on the Platform.

    9.3. Termination by the Client

    The Client may terminate these Terms at any time by closing their Account and withdrawing or transferring their available crypto-assets. For the terms and conditions regarding transfers and refunds, see Section 6.8.

    9.4. Termination by the Provider

    The Provider may terminate these Terms and close the Account in the following cases: (i) a breach of the Terms; (ii) requirements under applicable law, AML/CFT regulations, or sanctions legislation; (iii) a decision to cease operations.

    10. ASSET SEGREGATION. PROTECTION IN THE EVENT OF INSOLVENCY

    The Provider segregates Clients’ crypto-assets from its own crypto-assets. Client crypto-assets cannot be used to satisfy the creditors of BFINANCE EOOD. Segregation is implemented, including at the distributed ledger (DLT) level, pursuant to Article 75(6) of MiCA and internal procedures. As stated above in these General Terms & Conditions, the Company does not engage in any activities involving crypto-assets for its own account, through decentralized finance applications, or in any other manner, other than those necessary to provide the service of exchanging funds for crypto-assets for clients.

    In the event of insolvency or enforcement proceedings against BFINANCE EOOD, clients’ crypto-assets are protected and are subject to return in accordance with applicable law.

    11. Blockchain Forks and Events

    In the event of changes to the DLT or other events that may create or modify rights (e.g., a fork, an airdrop), the Client is entitled to the newly created assets/rights to the extent of their position at the time of the event, unless the agreement expressly provides otherwise.

    BFINANCE EOOD assesses the technical feasibility, legal risks, and AML/CFT risks associated with each such event. We may not support certain forks or airdrops when necessary for security or legal compliance. The Client is notified via the Platform or by email.

    12. TERMINATION AND CONSEQUENCES

    In the event of termination of the agreement, the procedure set forth in Section 6.8 shall apply. The Provider shall ensure:

    • Transfer of crypto-assets within 10 business days.
    • Refunds of fiat funds within 14 calendar days.
    • Provision of a final statement of positions.

    Termination does not affect fees already due and does not relieve the Client of liability for any violations of the Terms and Conditions.

    Upon termination, unless prohibited by applicable law or by an order of a competent authority, the Client may provide instructions for the sale or transfer of the crypto-assets held by the Provider within 90 (ninety) days. If no instructions are provided within this time frame, the Provider shall transfer the available crypto-assets to a distributed ledger address specified by the Client.

    The Provider may require that the identity verification process be repeated before authorizing a withdrawal or transfer.

    13. LIABILITY. LIMITATIONS

    13.1. Provider’s Liability

    BFINANCE EOOD is liable for any direct losses resulting from a breach of its obligations under these Terms and Conditions or applicable law. Liability is limited to the market value of the affected crypto-assets at the time the loss occurred.

    13.2. Limitation of Liability

    To the extent permitted by applicable law, BFINANCE EOOD shall not be liable for:

    • Loss of profits or loss of expected revenue, including actual or hypothetical business losses.
    • Loss or damage to reputation; loss of business opportunities, clients, or contracts.
    • Loss of hardware, software, or data; inaccuracies in crypto-asset price data.
    • Losses or damages that do not result directly from a breach of these Terms and Conditions.

    We will make reasonable efforts to ensure that requests are processed in a timely manner, but we do not guarantee a completion time, as this depends on factors beyond our control.

    14. ACCOUNT AND DEVICE SECURITY. SECURITY INCIDENTS

    14.1. Client Responsibilities

    The Client is required to keep their login credentials (passwords, codes, seed phrases, TOTP, etc.) secure and not to share them with third parties. Clients should use MFA when available and keep their devices secure (password, PIN, biometrics, up-to-date software, antivirus protection).

    14.2. Risk of Phishing and Fraud

    The Provider will never ask the Client to share two-factor authentication codes, seed phrases, or passwords. The Client should be cautious about messages claiming to be from the Provider and should access the Platform only through official channels.

    14.3. Security Breach Notification

    If the Client suspects that their Account has been compromised or that an unauthorized transaction has occurred, they must immediately notify the Provider at support@blockforia.com and provide the necessary information.

    14.4. Updating Contact Details

    The Client is responsible for keeping their email address and phone number up to date in their Profile so they can receive notifications, including those related to security.

    14.5. Accuracy of the Website

    Links to third-party materials may be provided for your convenience, but these materials are not under our control. We are not responsible for the information, content, or services contained in third-party materials.

    14.6. Third-Party Apps

    To access BFINANCE’s services, users must provide an email address and create a password. BFINANCE offers two-factor authentication (2FA/TOTP). Users are responsible for the security of the electronic devices used to access BFINANCE’s services.

    14.7. Password Protection

    To access BFINANCE’s services, you will need to create security credentials, including a username and password. You are responsible for the security of the electronic device you use to access the site. If you know or suspect that someone else has obtained your password, please contact us immediately at support@blockforia.com.

    14.8. Security Breach

    If you suspect that your account or security credentials have been compromised, you should notify BFINANCE support as soon as possible and take all necessary steps to limit the damage.

    15. PROHIBITED USE. PROHIBITED BUSINESS ACTIVITIES. CONDITIONAL USE

    15.1. General Principle

    The Client agrees to use the Platform and the services only for lawful purposes and in accordance with these Terms and Conditions.

    15.2. Prohibited Use

    The following are prohibited, including but not limited to: (i) illegal activity; (ii) fraudulent or deceptive conduct; (iii) unauthorized access, attacks on systems, or the distribution of malware; (iv) violations of third-party rights; (v) harassment, threats, or incitement to hatred.

    15.3. Prohibited Business Activities

    The Provider does not permit the use of its services in connection with certain categories of regulated or high-risk goods or services (e.g., weapons, illegal drugs, pornography, illegal gambling, unlicensed investment schemes, etc.), as detailed in Appendix 4.

    15.4. Conditional Use

    For certain categories of business or use, prior written approval from the Provider may be required, as described in Appendix 4.

    16. PERSONAL DATA, CONFIDENTIALITY, AND DATA SHARING

    16.1. Data Controller

    The Provider processes personal data as a data controller in accordance with Regulation (EU) 2016/679 (GDPR) and applicable national legislation. Further details are provided in the Privacy Policy published on the Platform.

    16.2. Purposes of Processing

    Personal data is processed for the purpose of providing services. The processing is based on Article 6(1)(b) of the GDPR (performance of a contract), Article 6(1)(f) (legitimate interest), and Article 6(1)(c) (legal obligation).

    16.3. Sharing with Service Providers (KYC/AML)

    The Provider may share the minimum necessary data with third-party service providers performing identification and AML/CFT checks, anti-fraud checks, hosting/infrastructure, auditing, etc., subject to contractual confidentiality and security obligations.

    16.4. Disclosure to Competent Authorities

    The Provider may disclose data to regulators, law enforcement agencies, or other competent authorities when required by law or by a valid order.

    16.5. Account and Service Notifications

    The Provider may send the Client mandatory notifications related to the account, security, and operations necessary for the provision of the services.

    16.6. Rights of Data Subjects

    The Client has the rights of access, rectification, erasure, restriction, objection, and data portability, as well as the right to lodge a Complaint with a supervisory authority. Information on how to exercise your rights is available in the Privacy Policy.

    17. ELECTRONIC COMMUNICATION AND ELECTRONIC SIGNATURE

    17.1. Electronic Delivery

    The Client agrees to receive electronically all messages, notifications, documents, confirmations, and announcements related to the Profile and the services, including: (i) updated terms and policies; (ii) account information and transaction history; (iii) legal, regulatory, and tax disclosures; (iv) responses to Complaints and inquiries.

    17.2. Channels

    Communications may be submitted via: (i) posts on the Platform/website; (ii) an email sent to the address listed in the Account; (iii) in-app notifications; (iv) a text message or mobile push notification.

    17.3. Client Responsibilities

    It is your responsibility to provide us with a valid, accurate, and complete email address and to keep that information up to date. If BFINANCE sends a message but the Client does not receive it due to an incorrect or outdated email address, the message will be deemed to have been delivered.

    17.4. Electronic Acceptance and Signature

    The Client agrees that electronic acceptance of the Terms and Conditions and instructions, confirmed through the Platform and authentication, has legal effect equivalent to a handwritten signature, to the extent permitted by law.

    18. SUPPORT, COMPLAINTS, AND DISPUTE RESOLUTION. CONFLICTS OF INTEREST

    18.1. Support

    If you have any questions or need assistance, please contact us at support@blockforia.com.Please provide your full name/company name, the email address associated with the profile, and a description of the issue.

    18.2. Complaints

    If you wish to file a Complaint, please state clearly: (i) the reason for the Complaint; (ii) the resolution you expect; (iii) any relevant information or evidence. Complaints can be submitted at support@blockforia.com or through the Platform’s built-in functionality.

    18.3. Timeframes

    Each Complaint is immediately entered into the Complaints Register and assigned a unique reference number. A confirmation of receipt will be sent within 5 business days. The Provider will provide a final response within 15 business days. In exceptional circumstances, that may be extended to no more than 35 business days.

    18.4. Internal Review

    If you are not satisfied with the response, you can request an internal review by replying to the correspondence and indicating “Complaint Review.”

    18.5. Escalation

    Where permitted or required by applicable law, the Client may escalate the Complaint to a competent authority or an alternative dispute resolution body.

    18.6. Competent Court

    If no agreement is reached, the dispute shall be referred to the competent Bulgarian court for resolution, unless the applicable law provides otherwise.

    18.7. Conflict of Interest Policy

    BFINANCE EOOD maintains and implements effective organizational and administrative measures to identify, prevent, and manage conflicts of interest between the Company (including managers, employees, and related parties) and clients, or between clients themselves. The full text of the Conflict of Interest Policy is published at www.blockforia.com.

    The Company has identified the following categories of potential conflicts: (i) Custody and trading – governed by a prohibition on the independent initiation of transactions; (ii) Employee personal transactions – governed by a personal transaction policy.

    The Conflict of Interest Policy is subject to review at least once a year. If the Client believes there is a conflict of interest, they may contact compliance@blockforia.com.

    19. CHANGES TO THESE TERMS AND CONDITIONS

    19.1. Notification

    The Provider may amend these Terms and Conditions and/or the attachments thereto. BFINANCE shall notify clients in advance (including via email and/or a notification on the Platform) of any changes, including by publishing the current version on the Company’s website.

    Within 14 calendar days of receiving notice of the changes, the Client may express their disagreement with the changes and terminate their business relationship with the Company.

    The Company reviews these General Terms and Conditions at least once a year, as well as whenever a material change occurs.

    19.2. Entry into Force and Adoption

    The amendments take effect on the specified date. If the Client does not agree with the changes, they may terminate the contract and withdraw or transfer their assets before the changes take effect. Continued use after the effective date shall be deemed acceptance.

    19.3. Latest Version

    The most recent version of the Terms and Conditions is available on the Platform. Upon request, the Provider may provide a copy electronically.

    20. APPLICABLE LAW. LANGUAGE. JURISDICTION

    20.1. Applicable Law

    For all unresolved matters, the laws of the Republic of Bulgaria shall apply, as well as the directly applicable laws of the European Union, including MiCA.

    20.2. Language

    These Terms and Conditions are available in all languages supported by the website: Bulgarian, English, Spanish, Portuguese. Communication between BFINANCE and the Client shall take place in Bulgarian and/or English. In the event of a conflict between language versions, the Bulgarian version shall prevail, unless applicable law requires otherwise.

    20.3. Jurisdiction

    Any disputes arising out of or in connection with these Terms shall be submitted for resolution to the competent Bulgarian court, unless the applicable law provides for a different jurisdiction.

    21. FINAL PROVISIONS

    21.1. Entire Agreement

    These Terms and Conditions and the attachments hereto constitute the entire agreement (contract) between the parties regarding their subject matter and supersede all prior oral or written agreements on the same subject matter, if any.

    21.2. Severability

    If any provision is found to be invalid or unenforceable, the remaining provisions shall remain in effect.

    21.3. Assignment

    The Client may not transfer any rights or obligations under these Terms and Conditions without the Provider’s prior written consent. The Provider may transfer the agreement to another legal entity in the event of a reorganization of its legal structure, provided that this is permitted by law and agreed upon with the regulator. Clients shall be notified in advance and shall have the right to cancel within 14 days.

    21.4. Contacts

    Current contact information and communication channels are posted on the Platform.

    APPENDIX 1: SUMMARY OF THE CUSTODY POLICY

    This document is a brief, client-oriented summary of BFINANCE EOOD’s Custordy Policy. This summary is for informational purposes only and should be read in conjunction with the agreement/general terms and conditions for the “custody and administration of crypto-assets” service.

    1. What “Custody and Administration of Crypto-Assets” Means

    The “custody and administration” service means that BFINANCE EOOD holds or controls your crypto-assets or the means of accessing them (such as private cryptographic keys) on your behalf, and executes your transfer/withdrawal instructions.

    2. What Crypto-Assets Are Supported

    As of the date of this document, BFINANCE EOOD provides custody services for Bitcoin (BTC). When new assets are added, the updated list shall be published on the Platform (see Appendix 3).

    3. Where and How Crypto-Assets Are Stored

    BFINANCE EOOD uses a “hot-wallet/cold-wallet” architecture: Cold storage – the majority of the reserves are kept offline, without a direct connection to the Internet. Hot wallet – A limited balance is maintained for daily liquidity. Cold storage operations are carried out under enhanced controls, including multi-signature (M-of-N).

    4. How Keys and Access Are Protected

    We use hardware-based storage and signing solutions. Staff access is restricted and protected by MFA and the “need-to-know” principle.

    We use a threshold multisignature scheme. We maintain a documented audit trail (logs) and perform control checks.

    5. How Withdrawals and Transfers Are Processed

    BFINANCE EOOD does not offer instant withdrawals. Withdrawal and transfer requests are subject to manual review and approval. BFINANCE EOOD may request additional confirmation and may delay or refuse to process a transaction in case of suspected fraud.

    6. Register of Positions and Statements

    We maintain a register of the positions held in each client’s name. We provide an account statement at least on a quarterly basis and, upon request, in electronic format.

    7. Segregation and Protection in the Event of Insolvency

    We hold our clients’ crypto-assets separately from those of BFINANCE EOOD. The goal is to ensure that the crypto-assets held in custody are protected and are not used to satisfy creditors of BFINANCE EOOD.

    When BFINANCE uses its own capital or its own inventory of crypto-assets to execute transactions involving the purchase or sale of crypto-assets with clients, this is done solely within the scope of the service of exchanging crypto-assets for funds and/or exchanging crypto-assets for other crypto-assets, in accordance with the applicable requirements of Regulation (EU) 2023/1114.

    The crypto-assets held by BFINANCE for its own account are kept separate from clients’ crypto-assets. BFINANCE does not use clients’ crypto-assets for its own account, for proprietary trading, as collateral, for investment, lending, or any purposes other than the execution of valid client instructions or other expressly permitted grounds under applicable law and the contractual documentation.

    We hold our clients’ crypto-assets separately from the crypto-assets held by BFINANCE EOOD for its own account. The goal is to ensure that the crypto-assets held in custody are protected and are not used to satisfy creditors of BFINANCE EOOD. With regard to fiat funds: For individual clients, the Company does not hold fiat funds (funds are transferred directly to and from the Client’s payment account). Corporate clients’ fiat funds are deposited and safeguarded at the credit institution Mano Bank (Lithuania) in accordance with Article 70 of MiCA.

    8. Forks and Other Blockchain Events

    In the event of a fork or similar occurrence, the Client is entitled to the newly created assets to the extent of their position. BFINANCE EOOD assesses the technical and legal aspects of each such event and notifies its clients.

    9. Audits and Incident Response

    We conduct periodic internal cybersecurity audits and annual external cybersecurity audits. We maintain an incident response team and protocols.

    10. Your Responsibilities

    Keep your login credentials secure; use MFA; do not share codes or passwords; keep your contact information up to date; notify us immediately if you suspect unauthorized access.

    11. Liability for Loss

    BFINANCE EOOD is liable for any loss of crypto-assets resulting from an incident caused by BFINANCE EOOD. Liability is limited to the market value of the lost crypto-assets at the time of the loss.

    12. Contact

    Email Address: support@blockforia.com | Website: www.blockforia.com | Address:  11 Petko R. Slaveykov Sq, fl. 6, Sofia, Bulgaria

    APPENDIX 2: FEE AND COMMISSION SCHEDULE

    I. General Provisions

    This Schedule governs the fees and commissions applicable to the provision of crypto-asset services by

    BFINANCE EOOD, including the exchange of crypto-assets for fiat currency and vice versa, the custody and administration of crypto-assets on behalf of clients, as well as the transfer of crypto-assets on behalf of clients.

    II. Table of Applicable Fees (Individual Clients – natural persons)

    Type of service Fee Amount Basis for Charging Explanation
    Exchange fee 8% Buying/selling BTC The Company’s principal fee.
    Bank Fees According to payment method When purchasing BTC Additional fees from the payment service provider, the bank, or the card issuer. They are not revenue for the Company.
    Transfer Fee 0 EUR For transfers The Company does not charge its own fee. The Client only pays network fees (gas/miner fees).
    Custody Fee 0 EUR For storage and administration This service is provided as an ancillary service to the exchange service.

    Note: Your bank may charge additional fees for transfers between your bank account and your account with us, as well as for credit card purchases. To avoid these fees, consider switching to a debit card.

    III. Justification of the Pricing Model

    The pricing model of “BFINANCE” EOOD is structured so that revenue is generated primarily through the trading fee (8%) charged on the purchase and sale of BTC. The Company does not charge a separate custodial fee and does not charge its own transfer fee.

    IV. Fees and Commissions – details

    1. Network fees (for transfers)

    BFINANCE charges only network fees when providing transfer services to individual clients. They are displayed to the Client before the transaction is completed. The Provider shall notify the Client of the applicable network fees prior to confirming the Instruction, except in cases where the amount cannot be precisely determined in advance due to network volatility. In such cases, the Provider displays the current approximate estimate. The final amount is confirmed on the receipt.

    Network fees are not fixed and depend on: network load; transaction data size (in bytes); alternative networks; transaction speed.

    2. Custody

    The Company does not charge a separate fee for the custody and administration of crypto-assets. The custody service is provided as an ancillary service, funded through the exchange fee.

    3. Transfer

    The Company does not charge its own fee for crypto-asset transfers. The Client is only responsible for the actual network fees (gas fees, miner fees, etc.).

    4. Corporate Clients

    For corporate clients, fees are negotiated on a case-by-case basis upon registration and the signing of an individual contract. The standard Service Agreement for corporate clients is available on the Company’s website.

    5. Transparency and Changes

    BFINANCE ensures that all fees are presented to the Client in a clear, transparent, and understandable manner before the General Terms and Conditions are accepted and before any instruction is executed. Changes to fees are announced in advance, with a 14-day period for objection.

    V. Supported Crypto-Assets

    The Company maintains a specific list of crypto-assets available for trading, consisting solely of BTC (see Appendix 3).

    VI. Eligible Clients

    This service is available exclusively to clients who have completed the onboarding process, including identity verification and AML/CFT checks.

    VII. Execution of Orders and Counterparty

    The Company receives real-time exchange rates via a direct API connection with Kraken – a regulated crypto-asset exchange. The Company does not take its own positions, nor does it assume market risk. Each exchange is executed at Kraken’s market price at the time of the transaction.

    VIII. Price and Fees – Disclosure to the Client

    For each transaction, the Client sees: (i) the current market price from Kraken; (ii) the service fee. Both elements are displayed prior to the confirmation of the transaction, in accordance with Article 77(2) of MiCA.

    IX. Pricing Method

    The Company uses a static, rule-based pricing model: Exchange rate = Real-time market reference price + Fixed fee (8% for individuals / negotiable for corporate clients). This formula is fixed and does not depend on the type of client, the size of the order, the time of day, or market conditions.

    While the outcome of the mechanism (the specific exchange rate) will fluctuate with market prices, the mechanism itself is static and transparent. Market volatility affects the reference price, but not the price-setting mechanism.

    X. Public Disclosure

    In accordance with Article 77(2) of MiCA and ESMA’s guidelines (ESMA_QA_2181), the Company publishes its pricing methodology in a publicly accessible section of its website, without requiring registration.

    APPENDIX 3: LIST OF SUPPORTED CRYPTO-ASSETS

    Crypto-Asset Symbol Supported Services Note
    Bitcoin BTC Exchange, Custody, Transfer Current as of 1 June 2026. This list is subject to change when support is added or discontinued.

    The Company may add new crypto-assets following a risk assessment, legal analysis, and technical integration. In the event of a change, Clients will be notified in accordance with Section 19.

    APPENDIX 4: PROHIBITED USE, PROHIBITED BUSINESS ACTIVITIES, AND CONDITIONAL USES

    Prohibited Use

    You are not permitted to use your Blockforia.com Account for the following types of activities. The uses listed below are representative but not exhaustive:

    • Illegal activity – violation of a law, charter, regulation, or provision; participation in sanctions programs; distribution of illegal materials.
    • Abuse – imposing a disproportionate load on the infrastructure; spreading viruses, Trojan horses, or malicious code; attempting unauthorized access.
    • Abuse of other users – defamation, harassment, threats, violation of the legal rights of third parties; incitement of hatred.
    • Fraud – any activity intended to defraud BFINANCE or third parties; providing false, inaccurate, or misleading information.

    Prohibited Business Activities

    The following categories of business activities are prohibited when using the services:

    • Unlicensed investment and credit services: securities brokerage; loan advisory services; unlicensed investment schemes.
    • Restricted financial services: check cashing; issuance of surety bonds; debt collection services.
    • Infringement of intellectual property rights: pirated music, films, software, or licensed materials distributed without authorization.
    • Counterfeit or unauthorized goods: the sale or resale of brand-name products without authorization; illegally imported or stolen goods.
    • Regulated products without a license: marijuana; tobacco/e-cigarettes; online prescriptions/pharmaceutical services; weapons and ammunition; toxic, flammable, and radioactive materials.
    • Drugs and controlled substances.
    • Illegal content and adult services: pornography and obscene material; services related to sexual relations.
    • Illegal or unlicensed gambling.
    • Multi-level marketing: pyramid schemes, network marketing.
    • Unfair, predatory, or fraudulent practices: ICOs promising unrealistic returns; resale of services with no added value.
    • High-risk businesses with increased financial risk or legal liability.

    Conditional Use

    The following categories require express written consent from BFINANCE prior to using the services:

    • Financial services: money transfers; currency exchange; gift cards; prepaid cards; acting as a payment aggregator.
    • Charitable organizations: accepting donations for nonprofit purposes.
    • Religious or spiritual organizations engaged in commercial activities

    APPENDIX 5: VERIFICATION PROCEDURES AND RESTRICTIONS

    BFINANCE uses multi-tiered systems and procedures to collect and verify information about you in order to protect BFINANCE and the community from fraudulent users.

    Your access to the services and limits (daily and weekly conversion limits, withdrawal and trading limits, transaction limits) may be based on the identification information and/or proof of identity you provide.

    BFINANCE may require you to provide or confirm additional information, or to wait until a transaction is completed, before allowing you to execute transactions exceeding certain volume limits. You can view the volume limits associated with your verification level by visiting your account page.

    The use of these services is subject to international export controls and economic sanctions requirements. By sending, receiving, buying, selling, trading, or holding crypto-assets, you agree to comply with these requirements.

    APPENDIX 6: ELECTRONIC DELIVERY OF NOTICES AND ELECTRONIC SIGNATURES

    This policy describes how BFINANCE delivers electronic communications to you. We may change this policy at any time by posting a revised version on our website.

    Electronic Delivery of Notices

    You acknowledge and agree to receive electronically all communications, agreements, documents, notices, and disclosures related to your account and your use of the services. These communications include: (i) terms of use and policies, including updates; (ii) account details and transaction history; (iii) legal, regulatory, and tax disclosures; (iv) responses to support requests.

    We shall provide these communications by posting them on the website, sending them via email, instant chat, and/or via text message or mobile notification.

    Hardware and Software Requirements

    To access your email, you will need: a device with an Internet connection; a modern web browser with 128-bit encryption; a valid email address; sufficient storage space or a printer.

    How to Withdraw Your Consent

    You can withdraw your consent to receive electronic communications by contacting us through the contact page. If you withdraw your consent, BFINANCE reserves the right to close your account or charge additional fees for paper copies.

    Updating Your Information

    It is your responsibility to provide us with a valid, accurate, and complete email address and to keep this information up to date. If BFINANCE sends a message but you do not receive it due to an incorrect or outdated email address, the message will be considered delivered. You can update your information by logging into your account and opening the settings.

    APPENDIX 7: DISCLOSURE REGARDING BITCOIN (Article 66(3) of MiCA)

    Since Bitcoin (BTC) has no identified issuer, there is no white paper within the meaning of Regulation (EU) 2023/1114 (MiCA).

    Clients are provided with a warning regarding the risks associated with Bitcoin, including a hyperlink to publicly available information about Bitcoin on the official bitcoin.org website, in accordance with Article 66(3) of MiCA.

    Hyperlink: https://bitcoin.org/

    The hyperlink provided is for informational purposes only. BFINANCE does not control the content on bitcoin.org and is not responsible for its accuracy, completeness, timeliness, or availability.

    Bitcoin is a high-risk and highly volatile crypto-asset. The Client may lose some or all of the value of the Bitcoin they hold. Transactions on the Bitcoin blockchain are generally irreversible. The information provided does not constitute investment, legal, tax, or other advice.

    © 2026 BFINANCE EOOD | www.blockforia.com