Clapp Crypto Credit Line Terms

Last Revised: 25.08.2026

These Credit Line Terms are a binding agreement between you and respective Clapp Group entity (“Clapp”, “we”, “us”). They supplement the Clapp Terms of Service (the “General Terms”). Terms defined in the General Terms have the same meaning here. In case of conflict regarding the Credit Line, these Credit Line Terms prevail.

Nature of the product. The Credit Line is an over-collateralized loan secured by a transfer of ownership of your collateral. When your Credit Line is opened, full legal and beneficial ownership of the Digital Assets you pledge passes to us for the life of the facility; on full repayment we return an equivalent amount of assets of the same type. We are not a bank, we do not accept deposits, and this product is not covered by any deposit guarantee or investor compensation scheme. Crypto lending and borrowing are outside the scope of Regulation (EU) 2023/1114 (MiCA), and the Credit Line is not within the service categories covered by our registration as a money services business with FINTRAC; no registration or license attaches to this product. If your loan-to-value ratio reaches the liquidation threshold, your collateral may be sold without prior notice.

1. Definitions

“APR” means the annualized interest rate applicable to a Credit Line.

“Collateral” means the Digital Assets you pledge, ownership of which is transferred to us to secure your obligations under a Credit Line.

“Collateral Value” means the value of the Collateral calculated using our Price Sources, after haircuts, spreads and liquidity discounts where applied.

“Credit Currency” means the currency or Digital Asset in which a Credit Line is denominated and drawn.

“Credit Line” means a revolving crypto-backed facility enabling you to borrow up to a limit determined by the LTV Policy and these Terms.

“Liquidation LTV” means the LTV level at or above which we may liquidate Collateral.

“Liquidation Risk LTV” means the warning zone below the Liquidation LTV (typically 5 to 10 percentage points below it).

“LTV” means (Outstanding Balance divided by Collateral Value) multiplied by 100 percent.

“LTV Policy” means the asset-level advance rates, LTV tiers and thresholds published in the App.

“Outstanding Balance” means the principal, accrued interest, fees, costs and expenses you owe at any time.

“Price Sources” means the pricing methodology described in Section 9.

2. Eligibility and Onboarding

2.1 You must be at least 18 years old, have full legal capacity, hold an active Clapp Account, and complete identity verification and ongoing screening under the General Terms. We may request information about your source of funds or wealth and monitor your activity for AML/CTF purposes.

2.2 You represent that you are not subject to EU, UK, US, UN or Canadian sanctions and are not resident in a Restricted Jurisdiction. For the avoidance of doubt, the Credit Line is not offered to residents of Canada, the United States or the United Kingdom. Credit Line availability by country is shown in the App.

2.3 The Credit Line is not investment advice and may not be suitable for everyone. We do not assess your personal financial situation.

3. Opening a Credit Line

3.1 Each Credit Line is denominated in one Credit Currency. You may open more than one Credit Line, subject to our risk limits.

3.2 Your borrowing capacity is determined algorithmically from the LTV Policy and may be adjusted per user. Applications are subject to automated review; requests above certain thresholds or outside policy may undergo manual review and be accepted, modified or declined at our discretion.

3.3 On approval, we open a Credit Line with a specified borrowing capacity. No funds are credited automatically. You may draw on the Credit Line, in whole or in part, to your Wallet, or use it as a source for other supported in-app services, in accordance with these Terms.

3.4 After full repayment, a Credit Line remains open unless you close it or we close it under Section 11.

4. Collateral

4.1 You may pledge one or more supported Digital Assets. On submission of your application, the pledged Collateral is locked; if the application goes to manual review, it remains locked until the review completes; if the application is declined, it is released to your Wallet.

4.2 Ownership transfer. Upon approval of the loan, you irrevocably transfer to us full legal and beneficial ownership of the Collateral as security for all of your obligations under the Credit Line. The Collateral becomes our property and may be used, transferred, pledged or otherwise disposed of by us. You have a contractual claim, upon full repayment, to the transfer back of an equivalent amount of Digital Assets of the same type as the Collateral. While the facility is outstanding, you do not hold title to the Collateral, and in the event of our insolvency your claim in respect of the Collateral is an unsecured contractual claim.

4.3 You may add Collateral, including new supported asset types, at any time. Partial withdrawal of Collateral is permitted subject to the resulting LTV and these Terms. Full withdrawal is permitted only when no Outstanding Balance remains.

4.4 We hold assets corresponding to the Collateral in our custody or with sub-custodians, subject to Section 4.2.

5. LTV Policy and Valuation

5.1 For multi-asset Collateral, we compute a weighted-average LTV using the asset-level advance rates published in the App. Different assets carry different maximum LTVs.

5.2 Your LTV changes with market prices, drawdowns and accrued interest and fees. Your available limit may decrease automatically if Collateral Value declines and increase if it rises, subject to the LTV Policy and risk controls.

5.3 We may change asset-level LTV schedules for new Credit Lines and, with notice where feasible, for existing Credit Lines. Updates required for risk control take effect immediately.

5.4 Collateral Value is calculated using our Price Sources. We may apply haircuts, spreads and liquidity discounts.

6. Interest and Fees

6.1 You pay interest only on the drawn portion of your Credit Line. Interest accrues daily at 00:00 UTC for the prior day, based on the maximum drawn principal during that day and the applicable APR tier.

6.2 Your APR depends on your LTV tier at the time of accrual (higher LTV, higher APR). The APR schedule applicable to a Credit Line is shown in the App at opening and is fixed for the life of that Credit Line unless changed by mutual agreement or as required by law. Interest is calculated on a 360-day year basis with daily compounding.

6.3 Worked example. You borrow 10,000 USDC for 30 days at a 10 percent APR. Daily interest on day 1 equals 10,000 x 10% / 360 = 2.78 USDC. Each subsequent day, interest is calculated on the updated Outstanding Balance, including previously accrued interest. After 30 days, total interest is approximately 84.03 USDC.

6.4 A minimum daily interest amount (equivalent to 0.01 EUR or 0.01 USD, depending on the Credit Currency) accrues each day. We may set and adjust the minimum per currency.

6.5 You agree to pay the fees listed in the Fees Schedule published in the App, which may include origination, withdrawal, network, custody, manual review, margin-call and liquidation fees.

6.6 Interest, fees and charges under a Credit Line will in no event exceed the maximum permitted by applicable law, including any maximum effective annual rate under the laws applicable to us or to you. If any amount would exceed such a maximum, it is automatically reduced to the highest permitted amount, and any excess received will be applied to reduce principal or refunded.

7. Drawdowns and Repayments

7.1 Draws are permitted up to your available limit. We may impose per-transaction or daily caps.

7.2 Repayments must be made in the Credit Currency. Payments are applied first to accrued interest, then to fees and costs, and finally to principal.

7.3 You may repay at any time. On full repayment, interest for the current day is accrued at the moment of repayment and included in the total, so that the entire debt is settled at that moment.

7.4 We may set off amounts you owe under the Credit Line against balances in your Accounts, converting currencies or assets where needed at our prevailing rates. All payments by you under these Terms must be made in full, without set-off, counterclaim, deduction or withholding, except where required by law.

8. Margin Calls and Liquidation

8.1 You are responsible for monitoring your LTV and maintaining Collateral at safe levels. We may, but are not obliged to, send alerts when your LTV enters the Liquidation Risk zone.

8.2 Each supported asset may have its own Liquidation LTV, set at our discretion based on volatility and liquidity. For high-volatility or low-liquidity assets, the threshold may be set at or above 60 percent.

8.3 We may require you to add Collateral or make repayments within stated timeframes. Failure to do so may result in liquidation.

8.4 If your LTV reaches or exceeds the Liquidation LTV, or upon an Event of Default, we may liquidate part or all of the Collateral without prior notice, through on-exchange or off-exchange sales, OTC transactions, auctions or transfers, to cover the Outstanding Balance, fees and costs. In highly volatile or illiquid markets we may liquidate the entire Collateral position. No additional interest accrues on the calendar day a liquidation occurs. Any surplus after full settlement is credited to your Wallet.

9. Prices, Oracles and Market Disruptions

9.1 Our pricing uses a composite index across multiple reputable venues, with time-weighted averaging and outlier removal, and fallback procedures if a primary source fails.

9.2 During market disruptions (depegging, forks, chain halts, illiquidity), we may widen spreads and haircuts, pause draws and withdrawals, adjust LTV thresholds, and liquidate using commercially reasonable efforts. Triggers and calculations are based on our internal rates, which may diverge from external markets.

10. Asset Support, Forks and Airdrops

10.1 Only assets listed in the App qualify as Collateral or Credit Currencies. We may add or remove assets at any time for risk reasons. Allocation of forks and airdrops relating to Collateral is at our discretion, reflecting the ownership transfer in Section 4.2.

11. Account Management

11.1 We communicate through the App and email; you must keep your contact details current and monitor alerts. You must secure your credentials and devices; we are not responsible for unauthorized access caused by your failure to do so.

11.2 Statements are available in the App. Report discrepancies within 30 days. Our books and records are conclusive evidence of drawdowns, repayments, interest, fees and Collateral movements, absent manifest error.

11.3 Credit Lines do not close automatically after repayment. We may close inactive lines, and suspend or close facilities for risk, legal or security reasons, with notice where feasible. You remain liable for all outstanding amounts.

12. Taxes

12.1 You bear sole responsibility for taxes and reporting connected with the Credit Line, including any tax arising from the transfer of Collateral, liquidations or repayments. We may withhold where legally required. We do not provide tax advice.

13. Prohibited Uses and Jurisdictions

13.1 You must not use the Credit Line for unlawful activity, including money laundering, terrorist financing, sanctions evasion, fraud or market abuse. The Credit Line is not available to residents of Restricted Jurisdictions, and accounts may be closed if restrictions later apply to you.

14. Events of Default

14.1 Each of the following is an Event of Default: (a) failure to meet a margin call or make a payment when due; (b) LTV at or above the Liquidation LTV; (c) breach of these Terms or the General Terms; (d) false or misleading information; (e) your insolvency or bankruptcy; (f) chargebacks or fraud attempts; (g) a legal or regulatory prohibition on our providing the facility.

14.2 On an Event of Default we may: suspend or terminate services; declare the Outstanding Balance immediately due; liquidate Collateral; and exercise all other rights and remedies.

15. Representations and Warranties

15.1 You represent that: (a) you own the Collateral free of liens and third-party rights; (b) you act for your own account and not for a prohibited person; (c) your use of the Credit Line complies with all laws applicable to you; (d) you understand the risks of Digital Assets and of collateralized borrowing; and (e) you rely only on the express terms of this agreement.

16. Liability and Indemnity

16.1 We do not provide legal, tax or investment advice. To the maximum extent permitted by law, we are not liable for indirect, incidental, special, punitive or consequential damages, loss of profits or data, or losses due to market movements, network failures or acts of third parties.

16.2 Our total aggregate liability under these Terms shall not exceed the total fees you paid to us in the 12 months preceding the claim. Nothing in these Terms excludes liability that cannot be excluded by law or limits your mandatory consumer rights.

16.3 You will indemnify us against claims and costs arising from your breach of these Terms or misuse of the Credit Line.

16.4 We are not liable for failures caused by events beyond our reasonable control, including severe market dislocation, exchange outages, cyberattacks, chain halts and regulatory actions.

17. Changes to the Terms

17.1 We may update these Terms by posting the new version in the App, with email notice where required. For material adverse changes we will give reasonable advance notice where feasible, and no less than 30 days except where changes are required by law or for risk control. Changes do not reduce your accrued rights.

18. Data Protection

18.1 The controller of personal data processed in connection with the Credit Line is Clapp Finance Limited. Processing is described in the Clapp Privacy Policy, including purposes (contract performance, AML/CTF and sanctions compliance, risk management on the basis of legitimate interests, and consent where required), sharing with group companies, KYC, custody and analytics providers and authorities, transfers outside the EEA with safeguards, retention, and your rights. AlphaEX s.r.o. acts as EU representative under Article 27 GDPR. Contact: [email protected]

19. Risk Disclosure

19.1 Key risks include: rapid adverse price moves triggering liquidation and loss of Collateral; stablecoin depeg; illiquid markets forcing wider spreads or larger liquidations; smart contract bugs, chain halts and congestion; rapid changes in law and policy; and tax consequences of borrowing, repayment and liquidation. Read the Risk Disclosure Statement before using the Credit Line.

20. Complaints and Contact

20.1 Complaints are handled under the Clapp Complaints Policy: we acknowledge within 2 Business Days and aim to respond within 15 Business Days. Contact: [email protected]

21. Miscellaneous

21.1 These Terms, the General Terms and the posted policies form the entire agreement for the Credit Line. You may not assign without our consent; we may assign to a Clapp group company or an acquirer with notice. If any provision is invalid, the rest remains in force. A failure to enforce is not a waiver.

21.2 These Credit Line Terms are governed by the laws of England and Wales. Disputes are resolved as set out in Section 18 of the General Terms (good-faith negotiations, then LCIA arbitration in London), without prejudice to your mandatory consumer rights and your right to complain to a competent authority.