General Terms and Conditions (GTC) of honesto AG, Adliswil

Version dated 09 April 2026
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 incorporated under Swiss law and registered in the Commercial Register of the Canton of Zurich, with its registered office at Soodstrasse 59, 8134 Adliswil, Switzerland (“honesto”).
2. honesto operates the honesto App and makes it available to users in accordance with these GTC.
3a. honesto qualifies as a financial intermediary within the meaning of Article 2 paragraph 3 of the Swiss Anti-Money Laundering Act (AMLA) and is a member of the self-regulatory organisation (SRO) Association for Quality Assurance of Financial Services (VQF) under membership number 100947/SRO.
3b. honesto expressly points out that it does not qualify as a “bank” within the meaning of Article 1 paragraph 4 and Article 1a of the Swiss Banking Act.
3c. In cooperation with the fully FINMA-regulated InCore Bank AG and carefully selected institutional third parties, honesto provides various services in connection with fiat currencies and crypto-assets. These services include, in particular, transaction processing, the custody and holding of cryptocurrencies, liquidity provision, settlement, and related operational and technical processes.
B. Registration & Your honesto Account
4. Before gaining access to the honesto App, you must complete the registration process. Registration, the associated collection of data, identity verification procedures and any further review processes are carried out by honesto and by third parties appointed by honesto (e.g. for the identification of the contracting party). You are required to provide honesto with all documents and information requested and necessary for registration. honesto and any appointed third parties shall have the right to contact you for this purpose.
5. honesto reserves the right, at its sole discretion and without stating any reasons, to reject your registration and therefore deny you access to and use of the honesto App. Upon successful registration, you will receive confirmation from honesto.
6. It is your responsibility to keep your access credentials secure, to choose a secure password and to change it regularly. honesto accepts no liability whatsoever for transactions initiated and executed by any other person using your login credentials.
7. If you become aware of any misuse of your honesto Account, you must notify honesto immediately. Such notification must be made by telephone at +41 43 377 12 70 or by e-mail to compliance@honesto.swiss. Upon receipt of such notification, honesto will block your account without undue delay.
8. The user undertakes not to use the honesto App for any illegal activities of any kind.
C. Limited Software Licence
9. honesto grants the user the right to use the honesto App in accordance with the terms and conditions set out in these GTC.
10. In particular, honesto grants the user a personal, worldwide, free of charge, non-transferable, non-exclusive, revocable and non-sublicensable licence to:
a. download, install and use the honesto App on one or more mobile devices running an operating system supported by the honesto App; and
b. access and use the honesto App for non-commercial purposes.
11. honesto retains all rights, title and interest worldwide 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 musical works.
12. The honesto App may not be copied, reproduced or distributed, in whole or in part, in any manner or medium whatsoever without the prior written consent of 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 other new features and may periodically transmit log data to honesto. The user may adjust such automatic downloads through the settings of their mobile device.
14. From time to time, honesto may offer new “Beta” features or tools with which users may experiment. Such features or tools are provided solely for testing purposes and without any warranty whatsoever and may be modified or discontinued by honesto at its sole discretion.
15. The user may not sell, rent, lease, assign, distribute, copy, modify or host the honesto App. Furthermore, the user may not adapt, merge, create derivative works from, disassemble, decompile, reverse compile, attempt to derive the source code of, or reverse engineer any part of the honesto App, unless such restrictions are expressly prohibited by applicable law.
D. Trading via the honesto App
16. Through the honesto App, honesto aggregates pricing information from multiple cryptocurrency trading venues and enables users to place orders directly through the honesto App for the purchase and sale of cryptocurrencies.
17. Settlement of trades takes place directly between the user and honesto AG.
18. Purchase and sale orders placed via the honesto App may be submitted 24 hours a day, 7 days a week and are displayed immediately in the user’s honesto Account. The effective settlement of trades takes place once per day.
19. In the event of inactivity for a period of 30 days (no trades), customers will be reminded by e-mail at regular intervals. In the event of inactivity for a period of 60 days, the procedure set out in Clause 32 shall apply.
E. Omnibus Account
20. honesto maintains an omnibus account with InCore Bank AG under the designation “honesto Client Transaction Account”, through which purchase and sale orders placed via the honesto App are processed.
21. Funds deposited by users are not segregated but are held together with funds of other users of the honesto App in an omnibus account maintained with InCore Bank AG. However, such funds are not commingled with funds belonging to honesto AG itself. Funds that are economically attributable to honesto AG are held in a separate account of honesto AG with InCore Bank AG.
22. Dispositions over balances held in the honesto Client Transaction Account shall only be made where such dispositions have been initiated by the user via the honesto App. This does not apply to dispositions made in accordance with Clause 29.
23. honesto maintains ongoing internal records of holdings, bookings and allocations relating to fiat funds and cryptocurrencies economically attributable to individual users.
To the extent that assets are held within the InCore structure, InCore Bank AG has access to the relevant individual user information and account balances required for such purposes.
To the extent that assets are held, made available or processed in whole or in part by carefully selected institutional third parties, allocations are made on the basis of the internal records maintained by honesto as well as the holdings and transaction data provided by the respective third parties.
F. Deposit of Funds
24. Upon successful registration, users may deposit funds into the honesto Client Transaction Account held with InCore Bank AG for the purpose of purchasing cryptocurrencies. Currently, deposits may be made in the following currencies: Euro (EUR) and Swiss Francs (CHF). Funds transferred in other currencies will automatically be converted into CHF.
25. The first deposit made by a user into the honesto Client Transaction Account shall constitute an identification transfer within the meaning of Clause 33 of FINMA Circular 2016/7. The deposit must originate from a bank account meeting the applicable regulatory requirements.
26. The minimum deposit amount is CHF 200.00 or EUR 200.00.
27. No fees are charged for deposits made in CHF or EUR.
G. Purchase of Cryptocurrencies
28. Currently, users may purchase Bitcoin (BTC), Ethereum (ETH) and additional cryptocurrencies via the honesto App. honesto intends to continuously expand the range of cryptocurrencies available through the honesto App.
29. If a user places a purchase order, the honesto App shall:
• instruct the market maker(s), liquidity provider(s) or other execution partner(s) engaged by honesto to execute the required purchases at the best available price on one or more available cryptocurrency trading venues; and
• instruct InCore Bank AG to transfer the amounts required for settlement of the purchase price from the honesto Client Transaction Account to the relevant execution partner, to the extent that payment processing is carried out via InCore Bank AG.
The cryptocurrencies acquired for the account and benefit of the user may subsequently, in whole or in part:
a. be held in wallet or custody structures maintained by InCore Bank AG for the benefit of users; and/or
b. be held, made available or processed in wallet or custody structures operated by carefully selected institutional third parties, in particular market makers or liquidity providers, in connection with trade execution, settlement, liquidity management, inventory management or related temporary custody arrangements.
Cryptocurrencies acquired for the benefit and account of users are not necessarily segregated and may be held together with cryptocurrencies belonging to other users in omnibus or pooled custody structures.
Users shall have no claim to the allocation of a specific wallet address, a specific custodian, a specific execution partner or specific individual coin or token units.
29a. The user acknowledges and agrees that cryptocurrencies are not required to be held exclusively with InCore Bank AG. honesto shall be entitled to engage, in addition to InCore Bank AG, further carefully selected institutional third parties in Switzerland and abroad, including in particular market makers, liquidity providers, trading venues, custodians, sub-custodians, settlement partners and technical service providers.
Such third parties may, in connection with the purchase, sale, delivery, settlement, liquidity management, inventory management, temporary custody or operational processing of transactions, obtain access to cryptocurrencies or related information or may hold cryptocurrencies in whole or in part.
30. Purchase orders shall only be executed, and only to the extent executed, if sufficient assets are available to cover the purchase price. If multiple purchase orders are submitted in chronological succession, potentially in relation to several cryptocurrencies, and sufficient coverage is not available, orders received first in time shall be executed first, on a pro rata basis where applicable.
31. If a user has deposited fiat amounts exceeding the amount required to purchase the requested cryptocurrencies, such excess funds shall, after fourteen (14) banking business days and upon instruction through the honesto App, be used to purchase additional units of the cryptocurrency most recently acquired by the user.
32. RETURN TRANSFER AND/OR PURCHASE OF CRYPTOCURRENCIES: For regulatory reasons, user funds may only be held in the honesto Client Transaction Account for a maximum period of sixty (60) days. honesto therefore reserves the right, after expiry of such sixty-day period, either to transfer the funds back to the bank account from which they originated or to convert such funds automatically into Bitcoin and/or Ethereum.
The decision whether to effect a return transfer and/or conversion into Bitcoin and/or Ethereum shall remain at the sole discretion of honesto.
H. Sale of Cryptocurrencies
33. If a user places a sell order for cryptocurrencies, the honesto App shall instruct the wallet, custody or inventory structure relevant to the respective position to transfer the corresponding cryptocurrencies to the market maker, liquidity provider or other execution partner engaged by honesto, to make such cryptocurrencies available to such party or to release them for sale within the existing settlement structure.
The sale proceeds shall subsequently be transferred to the honesto Client Transaction Account or to any other account structure used by honesto for settlement purposes.
I. Withdrawal and Transfer of Assets
34. Users may request the transfer of funds from the honesto Client Transaction Account to the bank account specified by the user during the registration process. InCore Bank AG shall execute such transfer within a maximum period of fourteen (14) banking business days.
35. Users currently do not have the possibility to transfer cryptocurrencies from the wallet, inventory or custody structures used by honesto to an external wallet, unless such functionality is explicitly offered by honesto.
Should a user wish to withdraw the relevant assets, the user must first sell the cryptocurrencies and may subsequently request payment of the resulting sale proceeds.
J. Costs
36. Registration Costs for Natural Persons:
For the registration of a natural person in the honesto App, the user shall owe honesto a registration fee of CHF 19.50 or EUR 19.00 in the event of video identification. The registration costs shall be deducted from the user’s first deposit into the honesto Client Transaction Account and transferred to honesto.
37. Registration Costs for Legal Entities:
The costs for the registration of legal entities shall be charged on a time-spent basis at an hourly rate of CHF 120.00 (plus applicable VAT). honesto shall be entitled to provide a cost estimate and to request an advance payment on costs from the user.
38. Transaction Fees:
For each purchase or sale of cryptocurrencies, the user shall pay honesto transaction fees based on the transaction value in the amount of 1% per transaction.
The applicable transaction fees shall be displayed to the user prior to the execution of a cryptocurrency purchase and shall be transferred to honesto from the user’s balance in the honesto Client Transaction Account immediately upon confirmation of the purchase by the user.
In the event of a sale of cryptocurrencies, the transaction fees shall be transferred to honesto immediately following the completion of the sale transaction.
39. Individually Agreed Transactions:
For certain transactions, in particular transactions involving larger volumes or transactions outside the standard offerings of the honesto App (e.g. individual requests from institutional clients), conditions differing from the standard transaction fees may apply if individually agreed between the parties.
Such conditions shall be communicated by honesto within the framework of a separate offer and shall only become valid upon the express written agreement of both parties.
40. Custody Fees:
The user shall pay honesto custody fees in connection with the custody of assets within the honesto App in the amount of 0.5% per annum.
Custody fees shall be charged to the user on a quarterly basis and transferred from the user’s balance in the honesto Client Transaction Account to honesto.
41. honesto reserves the right to pass on to the user any changes to custody, settlement, execution or third-party service costs, including in particular costs charged by InCore Bank AG or any additional institutional partners engaged by honesto, insofar as such costs arise in connection with the services offered by honesto.
42. Withdrawal Fees:
If the user wishes to withdraw EUR or CHF from the honesto App to their bank account, a withdrawal fee of CHF 2.00 or EUR 7.50 per withdrawal shall apply, in addition to any third-party charges and expenses.
43. Return Transfer Costs:
In the event of a return transfer pursuant to Clause 32, the user shall owe honesto an amount of CHF 200.00.
Should honesto decide, instead of a return transfer, to purchase cryptocurrencies on behalf of the user, the standard fees shall apply, including transaction fees and custody fees.
K. Extended Services
honesto may, upon request, provide selected users, business partners or third parties with extended services beyond the standard functionalities of the honesto App.
Such services include, in particular:
• White Label Solutions: Provision of technical infrastructure (e.g. APIs, application frameworks and user management systems) enabling partner companies to offer services under their own brand and identity.
• Tokenisation Services: Advisory and technical implementation services relating to the digital representation of economic rights or assets (e.g. real estate, energy infrastructure, CO₂ certificates, contractual rights or other assets) in the form of tokens, including utility tokens, asset-backed tokens and non-fungible tokens (NFTs).
Such services shall in each case be provided on the basis of separate contractual agreements and shall not be subject to the standard fees applicable to the honesto App.
honesto reserves the right to define and impose specific eligibility criteria, prerequisites and onboarding requirements for the use of such services.
L. Risks
44. The user acknowledges and understands that the use of the honesto App and, consequently, any execution of purchase or sale orders relating to cryptocurrencies via the honesto App, as well as the holding, custody or settlement of assets through InCore Bank AG and/or additional institutional third parties, involve technical, economic, legal, operational and counterparty risks.
44a. The user acknowledges that, in addition to InCore Bank AG, honesto may engage further institutional third parties for the provision of its services.
As a result, additional counterparty risks, custody risks, operational risks, execution risks, settlement delay risks, legal and regulatory risks, as well as risks relating to the disclosure of data to involved third parties in Switzerland and abroad may arise.
45. The provision of the honesto App and the information contained therein shall neither constitute investment advice nor a recommendation or solicitation to purchase or sell cryptocurrencies.
The decision to place any purchase or sale order shall remain solely with the user.
46. honesto does not provide investment advice, financial advice or similar services and does not assess whether any investment or divestment transaction requested by the user is appropriate, suitable or adequate for the user’s individual circumstances.
47. By accepting these General Terms and Conditions, the user expressly and irrevocably agrees to assume fully and unconditionally all risks associated with the use of the honesto App, including direct, indirect and ancillary risks.
48. honesto recommends that users consult their financial advisor and insurance advisor prior to using the honesto App and obtain advice regarding the risks associated with the use of the honesto App.
M. Disclaimer and Limitation of Liability
49. To the maximum extent permitted by applicable laws, regulations and rules, and unless otherwise provided for in these Terms and Conditions, honesto hereby excludes any and all liability for damages and consequential damages (whether direct or indirect) arising out of or in connection with the use of the honesto App and, in particular, shall not be liable for, including but not limited to:
a. any failure, malfunction or other issues in connection with the use of the honesto App;
b. the use of the honesto App in connection with money laundering, terrorist financing or any other activities that violate applicable laws, regulations or rules;
c. any omission, failure or delay relating to purchase and/or sale orders placed by the user;
d. any outage, malfunction, breakdown or interruption of the operation of the honesto App or of any tools, systems or platforms on which the honesto App relies, including but not limited to events resulting from hacking, cyberattacks, vulnerabilities, defects, programming errors, source code errors or similar events, irrespective of when such outage, malfunction, breakdown or interruption occurs;
e. viruses, errors, bugs, defects or any other adverse effects impacting the operation, functionality, use, storage or transmission mechanisms of the honesto App;
f. activities and responsibilities performed by InCore Bank AG and/or any other third parties engaged by honesto in connection with omnibus accounts, wallet structures, inventory structures and custody arrangements, including but not limited to account administration, credits, debits, wallet management, inventory management, temporary custody, settlement and the management of private keys or comparable access credentials;
g. any refusal by InCore Bank AG to accept a user and/or any instructions, requirements or actions imposed by InCore Bank AG relating to the acceptance of funds from such user;
h. activities and responsibilities performed by market makers, liquidity providers or other execution partners in connection with the purchase, sale, pricing, liquidity provision, settlement, transfer or temporary holding of cryptocurrencies;
i. any indirect, special, incidental, consequential or other losses of any kind, whether arising in tort, contract or otherwise, including but not limited to loss of revenue, income, profits, business opportunities, use or data, arising out of or in connection with the use of the honesto App.
50. In any event, the aggregate liability of honesto, whether arising in tort, contract or otherwise, in connection with or resulting from the use of the honesto App shall be limited to the volume of the order placed by the respective user giving rise to the claim.
51. To the extent legally permissible, the user agrees to waive any rights to pursue claims under applicable laws, regulations and rules and agrees that any claims shall exclusively be asserted on the basis of these Terms and Conditions.
N. Indemnification
52. To the extent permitted by applicable laws, regulations and rules, the user shall indemnify, defend and hold harmless honesto and/or its subsidiaries, affiliates, directors, officers, employees, representatives, successors and permitted assigns (collectively, the “Indemnified Parties”) from and against any and all claims, damages, losses, actions, proceedings, expenses and/or liabilities of any kind whatsoever, including, without limitation, reasonable legal fees and expenses and any costs reasonably incurred in successfully establishing a right to indemnification, asserted against or incurred by any of the Indemnified Parties and arising out of or relating to:
• any breach by the user of any representation, warranty, undertaking or obligation under these Terms and Conditions;
• any violation by the user of applicable laws, regulations or rules;
• any misuse of the honesto App by the user; or
• any act, omission or negligence attributable to the user.
The obligations under this Clause shall survive the termination of the contractual relationship between the user and honesto.
O. Termination
53. The user may terminate the use of the honesto App at any time with immediate effect. The honesto App provides a corresponding option within the account settings for this purpose. Any actions already confirmed by the user (such as cryptocurrency purchases) shall nevertheless be executed.
54. honesto reserves the right to terminate the contractual relationship with any user at any time and with immediate effect and/or to restrict and/or block a user’s access to the honesto App.
55. If a user terminates their honesto Account or if such account is terminated by honesto, all outstanding fees, charges and costs shall become immediately due and payable.
56. Upon termination, any positive balance remaining after deduction of all outstanding fees, charges and costs shall be transferred to the bank account specified by the user during the registration process.
Any cryptocurrencies held for the benefit of the user shall be sold in advance and the resulting sale proceeds shall be taken into account when calculating the final balance payable to the user.
P. Local Access Restrictions
57. The honesto App may contain information and opinions relating to products that may not be traded in certain jurisdictions or that may be subject to registration, licensing or authorisation requirements.
The honesto App is not intended for persons whose use of or access to the honesto App would violate applicable laws or regulations due to their place of residence, domicile, nationality or for any other reason.
Such persons are not permitted to download and/or use the honesto App.
This restriction applies in particular to:
• citizens of the United States of America;
• persons residing or domiciled in the United States of America; and
• any other persons subject to legal or regulatory restrictions that prohibit access to the products and services offered by honesto.
Q. Taxes
58. The user shall be solely responsible for the determination, calculation, reporting and payment of all taxes, duties and levies, including but not limited to sales taxes, use taxes, transfer taxes, value added taxes, withholding taxes and any other taxes, charges or governmental assessments that may arise, be imposed, accrue, be collected, paid or withheld in connection with:
• the use of the honesto App;
• the acquisition, holding or disposal of crypto-assets; or
• any act, omission or transaction of the user related thereto.
59. honesto recommends that the user consult their tax advisor prior to using the honesto App and obtain professional advice regarding the tax implications associated with the use of the honesto App and the acquisition, holding and disposal of crypto-assets.
R. Data Protection
60. The Privacy Policy of honesto shall apply.
The user acknowledges and agrees that personal data may be collected, processed, stored and transferred by honesto and by third parties engaged by honesto to the extent necessary for:
• the provision of the services offered through the honesto App;
• compliance with applicable legal and regulatory obligations;
• anti-money laundering, sanctions screening and fraud prevention purposes; and
• the operation, maintenance and further development of the honesto App.
Further details regarding the processing of personal data are set out in the Privacy Policy of honesto, which forms an integral part of these Terms and Conditions.
S. Entire Agreement and Amendments
61. These Terms and Conditions constitute the entire agreement and understanding between the user and honesto and supersede all prior agreements, understandings, arrangements and representations, whether oral or written, relating to the use of the honesto App.
62. honesto reserves the right, at any time and without requiring the consent of the user, to amend, modify, supplement or replace these Terms and Conditions with new provisions.
Such amendments may result in restrictions regarding access to or use of the honesto App.
The user shall be informed of such amendments upon restarting the honesto App.
By continuing to use the honesto App following notification of such amendments, the user shall be deemed to have accepted the amended Terms and Conditions.
T. Governing Law, Dispute Resolution and Jurisdiction
63. These Terms and Conditions and the relationship between the user and honesto shall be governed exclusively by the laws of Switzerland, to the maximum extent possible excluding the application of international conventions, insofar as such exclusion is legally permissible and enforceable.
64. In the event of any dispute between honesto and a user, the following procedure shall apply:
a. The user must notify honesto in writing, specifying the nature and full details of the dispute and enclosing any relevant supporting documentation.
Such notification shall be sent to:
E-mail: info@honesto.swiss
or in writing to:
honesto AG
Soodstrasse 59
8134 Adliswil
Switzerland
b. Upon receipt of such notification, honesto shall contact the user and the parties shall attempt in good faith to resolve the dispute amicably.
65. If, for any reason, the parties are unable to resolve the dispute within thirty (30) days following the notification referred to in Clause 64(a), either party may initiate legal proceedings in respect of such dispute, provided that no such proceedings may be commenced prior to the expiry of such period.
66. The courts of Adliswil, Canton of Zurich, Switzerland, shall have exclusive jurisdiction over all disputes and claims arising out of or in connection with these Terms and Conditions.