Version dated June 3, 2025

Introduction
These General Terms and Conditions (“GTC”) govern the contractual relationship between honesto AG and you as a user of the honesto App operated and provided by honesto AG.

By registering for and using the honesto App, you confirm that you have read, understood, and accepted these GTC as well as the Privacy Policy, which forms an integral part of these GTC.

These GTC are legally binding for every user of the honesto App. Please read them carefully before completing your registration and using the honesto App. By using the honesto App, you agree to these GTC.

A. honesto AG, Adliswil / honesto App
1. honesto AG (CHE-308.013.290) is a stock corporation under Swiss law, registered in the Commercial Register of the Canton of Zurich, with its registered office at Soodstrasse 59, 8134 Adliswil (“honesto”).
2. honesto operates the honesto App and makes it available to users in accordance with the terms of these GTC.
3a. honesto is qualified as a financial intermediary within the meaning of Art. 2 para. 3 of the Anti-Money Laundering Act (AMLA) and is a member of the self-regulatory organization (SRO) VQF – Association for the Quality Assurance of Financial Services, with membership number 100947/SRO.
3b. honesto explicitly points out that it does not qualify as a “bank” according to Art. 1 para. 4 and Art. 1a of the Swiss Banking Act (BankG).
3c. In cooperation with the fully FINMA-regulated IncoreBank AG, honesto offers various services such as the custody of cryptocurrencies (Art. G 29) or the holding of client funds in an omnibus account (Art. E 20).

B. Registration & Your honesto Account
4. Before you gain access to the honesto App, you must register. Registration, the associated data collection, identity verification, and other verification processes are carried out by honesto and third parties commissioned by honesto (e.g., for identifying the contracting party). You are required to provide honesto with all documents and information necessary for registration. honesto and any third-party providers have the right to contact you.
5. honesto reserves the right to reject your registration without providing reasons and may deny you access to use the honesto App. After successful registration, you will receive a confirmation from honesto.
6. You are responsible for keeping your login credentials secure, choosing a secure password, and changing it regularly. honesto accepts no liability for transactions carried out by any other person using your login credentials.
7. If you become aware of any misuse of your honesto account, you must report this to honesto immediately. The report must be made by phone at +41 43 377 12 70 or by email at compliance@honesto.swiss. honesto will block your account upon receipt of the notification.
8. The user agrees not to use the honesto App for any illegal activity.

C. Limited Software License
9. honesto grants the user the right to use the honesto App under the terms set out in these GTC.
10. Specifically, honesto grants the user a personal, worldwide, royalty-free, non-transferable, non-exclusive, revocable, and non-sublicensable license to:
a. download, install, and use the honesto App on one or more mobile devices that run an operating system supported by the honesto App; and
b. access and use the honesto App for non-commercial purposes.
11. honesto retains all worldwide rights, titles, and interests in and to the honesto App, including but not limited to all copyrights, trademarks, trade secrets, trade names, proprietary rights, patents, titles, software code, audiovisual effects, themes, characters, character names, stories, dialogues, settings, artwork, sound effects, and music compositions.
12. The honesto App may not be copied, reproduced, or distributed in whole or in part in any form or by any means without prior written consent from honesto. All rights not expressly granted to the user herein are reserved by honesto.
13. The user acknowledges and agrees that the software provided by honesto may automatically download and install upgrades, updates, or new features and may regularly send log data to honesto. The user can adjust these automatic downloads via the settings of their mobile device. These updates and upgrades are intended to improve and extend the honesto App and may include bug fixes, enhancements, and new modules. honesto may update and enhance the honesto App at any time and without prior notice.
14. From time to time, honesto may offer new “beta” features or tools for users to experiment with. These features or tools are offered exclusively for testing purposes, without any warranty, and may be modified or discontinued at honesto’s discretion.
15. The user may not sell, rent, lease, assign, distribute, copy, modify, or host the honesto App. The user may also not adapt, merge, derive from, disassemble, decompile, reverse compile, attempt to discover the source code, or perform reverse engineering on any part of the honesto App, unless such restrictions are expressly prohibited by applicable law.

D. Trading via the honesto App
16. honesto aggregates pricing information from multiple crypto trading platforms through the honesto App and allows users to place buy or sell orders for cryptocurrencies directly through the honesto App.
17. The settlement of trades is carried out directly between the user and honesto AG.
18. Buy or sell orders can be placed 24/7 via the honesto App and are immediately reflected in your honesto account. The actual settlement of trades is carried out once per day.
19. After 30 days of inactivity (no trades), customers will be reminded via email at regular intervals. After 60 days of inactivity, the procedure under section 32 applies.

E. Omnibus Account
20. honesto maintains an omnibus account at InCore Bank AG titled “honesto Client Transaction Account” through which purchase and sale orders via the honesto App are processed.
21. Funds deposited by you are not held in segregated accounts but are pooled with funds of other honesto App users in an omnibus account at InCore Bank AG. However, they are not commingled with funds belonging to honesto AG. Funds economically attributable to honesto AG are held in a separate account at InCore Bank AG.
22. Dispositions over balances in the honesto Client Transaction Account are made exclusively based on instructions initiated by the user via the honesto App. Exceptions apply as per Clause 28.
23. InCore Bank AG has access at all times to individual user information at the honesto App level, including current account balances, which are transmitted at least once daily. This ensures InCore Bank AG can allocate funds to individual users even in the event of an honesto App outage.

F. Depositing Funds
24. Once registered, you can deposit funds into the honesto Client Transaction Account at InCore Bank AG to purchase cryptocurrencies. Currently, deposits in EUR and CHF are accepted. Other currencies will be automatically converted into CHF.
25. The first deposit from a user into the honesto Client Transaction Account qualifies as an identification transfer under Clause 33 of FINMA Circular 2016/7. The deposit must originate from a bank account meeting the relevant requirements.
26. The minimum deposit amount is CHF 200.00 or EUR 200.00.
27. No fees are charged for deposits in CHF or EUR.

G. Purchasing Cryptocurrencies
28. Currently, you can purchase Bitcoin (BTC), Ethereum (ETH), and other cryptocurrencies via the honesto App. honesto intends to regularly expand the App to support additional cryptocurrencies.
29. When a user places a buy order, the honesto App instructs the Market Maker to make the necessary purchases at the best available price on any of the supported crypto trading platforms and transfers the acquired assets to a pooled crypto wallet held and managed by InCore Bank AG on behalf of the honesto App users. The App also instructs InCore Bank AG to transfer the required funds from the honesto Client Transaction Account to the Market Maker. Cryptocurrencies acquired on your behalf are not segregated but pooled with other users’ assets in the omnibus wallet at InCore Bank AG. Only InCore Bank AG has access to the private keys of this wallet.
30. Purchase orders will only be executed if sufficient funds are available. If multiple orders are placed in sequence and funds are insufficient, the earliest orders will be executed proportionally.
31. If a user deposits fiat exceeding the amount required for the desired cryptocurrency purchases, after 14 banking days, honesto may use the surplus to purchase more of the last acquired cryptocurrency.
32. REFUNDS AND/OR CRYPTO PURCHASES: For regulatory reasons, user funds may only be held in the honesto Client Transaction Account for a maximum of 60 days. After this period, honesto reserves the right to either return the funds to the originating account or convert them automatically into Bitcoin and/or Ethereum. The decision is at the sole discretion of honesto.

H. Selling Cryptocurrencies
33. When a user places a sell order, the honesto App instructs InCore Bank AG to transfer the respective cryptocurrencies from the omnibus wallet to the Market Maker’s wallet. The Market Maker is instructed to sell the assets and credit the proceeds to the honesto Client Transaction Account.

I. Withdrawal and Transfer of Assets
34. Users can instruct withdrawals from the honesto Client Transaction Account to the bank account specified during registration. InCore Bank AG will process the transfer within a maximum of 14 banking days.
35. Users currently cannot transfer cryptocurrencies from the omnibus wallet at InCore Bank AG to another wallet. To withdraw, users must first sell their cryptocurrencies, after which they can withdraw the fiat proceeds.

J. Fees
36. Registration fee for natural persons: Users owe honesto a fee of CHF 19.50 or EUR 19.00 for registration via video identification. This amount is deducted from the user’s first deposit and forwarded to honesto.
37. Registration fee for legal entities: Registration fees are calculated on a time-spent basis at CHF 120/hour (plus VAT). honesto may provide a cost estimate and require an advance payment.
38. Transaction fees: For each cryptocurrency buy or sell, a transaction fee of 1% applies. This fee is shown to the user before order execution and deducted immediately upon confirmation.
39. Individually agreed transactions: For large-volume or non-standard transactions, custom conditions may apply and must be agreed in writing.
40. Custody fees: Users owe honesto a custody fee of 0.5% per annum, billed quarterly and deducted from the honesto Client Transaction Account.
41. We reserve the right to pass on changes to custody fees by InCore Bank AG to the user.
42. Withdrawal fees: Withdrawals of CHF or EUR to the user’s bank account incur a fee of CHF 2.00 or EUR 7.50 plus third-party fees per withdrawal.
43. Refund handling fee: In the case of a refund per Clause 32, a fee of CHF 200 is charged. If honesto instead converts the funds into crypto, standard transaction and custody fees apply.

K. Extended Services
honesto may offer extended services upon request to selected users, business partners, or third parties, beyond the standard functions of the honesto App. These include:
• White-label solutions: Provision of technical infrastructure (e.g., API, app framework, user management) for use by partner companies under their own brand.
• Tokenization services: Advisory and technical implementation for the digital representation of economic rights or assets (e.g., real estate, energy plants, CO₂ certificates, contracts) in the form of tokens (e.g., utility tokens, asset-backed tokens, or NFTs).
These services are governed by separate contractual agreements and are not subject to the standard fees of the honesto App. honesto reserves the right to define specific eligibility criteria for accessing such services.

L. Risks
44. The user acknowledges that using the honesto App and executing cryptocurrency transactions via the App and its omnibus account involve technical, economic, and legal risks.
45. The honesto App and the information contained therein do not constitute a sales recommendation or an invitation to buy or sell cryptocurrencies. Decisions to place buy or sell orders are the sole responsibility of the user.
46. honesto does not provide investment advice or assess the appropriateness or suitability of investments for the user.
47. By accepting these GTC, the user expressly and irrevocably agrees to assume all risks (including direct, indirect, or additional risks) associated with using the honesto App unconditionally.
48. honesto recommends that users consult their financial and insurance advisors regarding the risks associated with using the honesto App before engaging with the platform.

M. Disclaimer and Limitation of Liability
49. To the extent permitted by applicable laws and regulations, and unless otherwise stated herein, honesto excludes any liability for damages arising from or related to the use of the honesto App, including but not limited to:
a. failure, malfunction, or other issues related to App usage;
b. use of the App in connection with money laundering, terrorism financing, or other illegal acts;
c. delays or failures in executing buy/sell orders;
d. outages, malfunctions, crashes, or interruptions, including those due to hacks, cyber-attacks, code defects, vulnerabilities, or programming errors;
e. viruses, bugs, defects, or other adverse effects on the App’s operation or data storage;
f. responsibilities of InCore Bank AG regarding the omnibus account and wallet;
g. refusal by InCore Bank AG to accept a user or execute instructions;
h. responsibilities of the Market Maker in crypto transactions;
i. indirect, special, incidental, or consequential losses, including loss of revenue, profits, data, or usage.
50. In any case, honesto’s liability is limited to the value of the transaction placed by the user.
51. The user agrees, as far as legally permissible, to waive any claims not based on these GTC and to assert any claims exclusively under these terms.

N. Indemnification
52. To the extent permitted by applicable law, the user agrees to indemnify, defend, and hold harmless honesto and its affiliates, directors, officers, employees, agents, successors, and assigns from any claims, damages, losses, suits, proceedings, expenses, or liabilities (including reasonable attorney’s fees) asserted by third parties arising from the user’s breach of warranties, representations, or obligations under these GTC.

O. Termination
53. The user may terminate use of the honesto App at any time with immediate effect via account settings. Confirmed actions (e.g., crypto purchases) will still be executed.
54. honesto reserves the right to terminate the contractual relationship with a user and/or restrict or block App access at any time and with immediate effect.
55. If a user terminates their account or if honesto does so, all outstanding fees become immediately due.
56. Upon termination, after deducting outstanding fees, any remaining positive balance will be transferred to the bank account specified during registration. Cryptocurrencies will be sold beforehand, and proceeds included in the balance.

P. Local Access Restrictions
57. The honesto App may include information or opinions on products that are restricted or subject to registration or approval in certain jurisdictions. It is not intended for individuals whose use or access would violate applicable laws based on residency, nationality, or other reasons. Such individuals, especially U.S. persons or residents, are prohibited from using the App.

Q. Taxes
58. The user is solely responsible for determining and paying all applicable taxes, including sales, use, transfer, VAT, withholding, or other taxes, related to the use of the honesto App, acquisition, holding, or sale of crypto assets, or any user activity.
59. honesto recommends users consult a tax advisor regarding tax obligations before using the App.

R. Data Protection
60. The honesto Privacy Policy applies.

S. Entire Agreement and Amendments
61. These GTC constitute the entire agreement between the user and honesto and supersede all prior agreements, whether oral or written, regarding use of the honesto App.
62. honesto reserves the right to modify, update, or replace these GTC at any time without user consent. Changes may affect access or use. Users will be informed upon restarting the App. Continued use constitutes acceptance.

T. Governing Law, Dispute Resolution, and Jurisdiction
63. These GTC and the relationship between the user and honesto are governed exclusively by Swiss law, excluding international treaties to the extent legally permissible.
64. In case of a dispute, the following procedure applies:
a. The user must notify honesto in writing with full details and supporting documents at info@honesto.swiss or:
honesto AG, Soodstr. 59, 8134 Adliswil, Switzerland.
b. After receipt, honesto will contact the user and the parties will attempt good-faith resolution.
65. If unresolved within 30 days from notification, either party may initiate legal proceedings.
66. The courts of Adliswil, Canton of Zurich, Switzerland, shall have exclusive jurisdiction over all disputes arising out of or in connection with these GTC.