Clapp Savings Terms and Conditions

Last Revised: 25.08.2026

These Savings Terms are a binding agreement between you and Clapp Group (“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 Savings product, these Savings Terms prevail.

Nature of the product. Savings is a lending product. When you open a Savings position, you lend your Digital Assets to us: ownership of the deposited assets transfers to us, and you receive a contractual claim for the return of an equivalent amount of the same assets plus interest. Savings balances are not bank deposits, are not covered by any deposit guarantee or investor compensation scheme, and are not crypto-asset services under Regulation (EU) 2023/1114 (MiCA); they do not benefit from MiCA safeguarding requirements. Savings is also not within the service categories covered by our registration as a money services business with FINTRAC, and no registration or license attaches to this product. Deposited assets leave the custodial arrangements of your Wallet. You bear our credit risk: if we cannot meet our obligations, you may lose some or all of your assets. Interest earned on the use of your assets accrues to you at the rates published in the App; we retain the margin between what your assets earn and the interest paid to you as our fee.

1. Definitions

“Accrual Date” means the date on which interest is calculated and credited.

“Auto-Prolongation” means the automatic reinvestment of your deposit when a Fixed-Term Savings term ends.

“Business Day” means a day other than a Saturday, Sunday or public holiday in England and Wales.

“Daily Accrual” means the accrual of interest on each calendar day, including weekends and public holidays, on a 365-day year basis.

“Deposit” means the Digital Assets you transfer to a Savings position.

“Fixed-Term Savings” means Savings with a fixed interest rate for a term selected at opening, subject to Section 4.

“Flexible Savings” means Savings from which you may withdraw in full or in part at any time, without lock-up or early withdrawal penalties.

“Savings” means the Flexible Savings and Fixed-Term Savings products governed by these Terms.

“Termination Date” means the date your Savings position is closed at your request or by us.

2. Eligibility and Opening

2.1 You must be at least 18 years old, have full legal capacity, hold an active Clapp Account, have completed identity verification and ongoing screening under the General Terms, not be subject to EU, UK, US, UN or Canadian sanctions, and not be resident in a Restricted Jurisdiction. For the avoidance of doubt, the Savings product is not actively offered to residents of Canada, the United States or the United Kingdom. Savings availability by country is shown in the App.

2.2 To open Savings, submit the application in the App and select the Savings type. Once approved, your Savings position is active immediately. You may hold multiple Savings positions, subject to our risk limits.

2.3 Before your first Savings position is opened, the App will ask for your express consent to the transfer of ownership of the deposited assets described above. We will not move assets from your Wallet into Savings without that consent and your instruction.

2.4 The Savings product is not investment advice. We do not assess your personal financial situation, risk tolerance or objectives. You are solely responsible for determining whether Savings is suitable for you, and you have not relied on any statement not expressly set out in these Terms.

3. Flexible Savings

3.1 Flexible Savings allows you to deposit and withdraw supported Digital Assets at any time, without lock-up or penalties. Interest accrues and is credited daily.

3.2 You may deposit any supported Digital Asset at any time, subject to the minimum and maximum limits published in the App.

3.3 You may withdraw your Deposit and accrued interest, in full or in part, at any time without notice or penalty. Withdrawals are processed within the timeframes stated in the App, subject to network conditions and operational capacity. We may apply per-transaction or daily withdrawal caps as stated in the App.

3.4 The annual percentage yield (APY) for Flexible Savings is published in the App and reflects annual interest with daily compounding. We may change the APY at our discretion with notice where feasible; changes apply to new Deposits and to existing balances from the effective date. Interest is calculated daily from the published APY and credited on each Accrual Date.

3.5 Interest accrues daily on the minimum balance held during each calendar day, using the equivalent daily rate derived from the published APY. A minimum daily interest amount (equivalent to 0.001 EUR or 0.001 USD, depending on the Savings currency) may apply; we may set and adjust the minimum for each supported currency.

4. Fixed-Term Savings

4.1 Fixed-Term Savings allows you to deposit supported Digital Assets for a fixed term (as offered in the App) at an interest rate fixed at opening for the full term.

4.2 Auto-Prolongation is enabled by default. You may disable it at any time before the end of the term in your account settings. If Auto-Prolongation is enabled, a new Fixed-Term Savings position opens automatically at the end of the term, with an opening balance equal to your previous Deposit plus accrued interest, at the rate published in the App at the moment of renewal, which may differ from your original rate. If Auto-Prolongation is disabled, the position closes at the end of the term and your Deposit plus accrued interest is credited to your Wallet.

4.3 Early termination of Fixed-Term Savings is generally not permitted. You may request early termination through support, stating the reason. We assess requests based on regulatory, market and operational considerations; approval is not guaranteed. If early termination is approved, all accrued interest is forfeited and only the Deposit is returned.

5. Deposits and Asset Conversion

5.1 You may deposit any Digital Asset listed in the App as supported for Savings. We may add or remove supported assets at any time for risk, operational or regulatory reasons, with notice where feasible.

5.2 Fiat deposits into Savings are converted into EURC (a euro-referenced stablecoin) upon receipt at a 1:1 rate, free of commission. By using fiat for Savings you authorize this conversion. Your Savings balance and interest accrual are maintained in the post-conversion stablecoin or in the deposited crypto asset. Your position therefore carries the risks of the relevant stablecoin, including depeg risk.

5.3 On withdrawal, you may choose the Digital Asset you wish to receive. We convert your balance to the chosen asset at our price source at the time of withdrawal, without a conversion fee.

5.4 Minimum Deposit amounts per asset and per Savings type are published in the App and must be met at opening and maintained where specified.

6. Interest

6.1 Interest accrues daily on a 365-day year basis, calculated on the balance held at 00:00 UTC each day.

6.2 For Flexible Savings, interest is credited daily and compounds daily.

6.3 For Fixed-Term Savings, interest is paid at the end of the term at the rate locked at opening.

6.4 We may change the APY for Flexible Savings at any time, with notice where feasible; changes take effect on the date stated in the App.

6.5 Interest stops accruing on the Termination Date or on withdrawal of the relevant funds.

7. Withdrawals and Management

7.1 Flexible Savings withdrawals are described in Section 3.3. Fixed-Term early termination is described in Section 4.3.

7.2 We may suspend withdrawals or freeze Savings for operational, security, legal or regulatory reasons. During a suspension, interest continues to accrue on Flexible Savings unless the suspension results from regulatory or sanctions concerns relating to your Account.

8. Risks

8.1 The key risks of Savings are described in the Risk Disclosure Statement and include: our credit risk as borrower of your assets (Savings is an unsecured claim against us); market volatility of the deposited assets; stablecoin depeg risk (including for EURC balances); technology and blockchain risks; regulatory changes; and tax consequences. Deposits, interest, withdrawals and conversions may be taxable events; you are responsible for your taxes.

8.2 For users in the EEA: crypto lending is outside the scope of MiCA. This product is provided by a company established outside the EEA. It does not benefit from MiCA safeguarding, complaint handling or compensation arrangements, and the assets you lend are not held for you by a regulated custodian while in Savings.

9. Statements and Reconciliation

9.1 The App provides statements of your Savings balance, transactions and accrued interest. You must notify us in writing of any discrepancy within 30 days of the statement date; absent notice, the statement is deemed accepted, except where a manifest error is shown.

9.2 You are responsible for your own tax reporting. Transaction history can be exported from the App.

9.3 Our books and records are conclusive evidence of your Savings balances, transactions and accrued interest, absent manifest error.

9.4 We may set off any amounts you owe us under these Terms or the General Terms against your Savings balance or accrued interest, converting between assets where needed at prevailing rates.

10. Liability

10.1 The Savings service is provided on an “as is” and “as available” basis. We give no warranty of fitness for a particular purpose, pricing accuracy or uninterrupted access.

10.2 To the maximum extent permitted by law, we are not liable for indirect, incidental, special, punitive or consequential damages; loss of profits, data, revenue or opportunity; losses from market price fluctuations, conversions, smart contract failures, chain outages or network disruptions; or acts of third-party providers, except in each case to the extent caused by our gross negligence or wilful misconduct.

10.3 Our total aggregate liability under these Savings Terms shall not exceed the greater of: the total interest you received in the preceding 12 months; the total fees you paid to us in that period; or EUR 1,000. Nothing in these Terms excludes liability that cannot be excluded by law or limits your mandatory consumer rights.

10.4 We are not liable for failures caused by force majeure, including market dislocations, exchange outages, blockchain halts or forks, cyberattacks, regulatory actions, war, terrorism, strikes and natural disasters.

11. Suspension and Termination

11.1 We may suspend Savings for maintenance, security or investigations, or terminate Savings positions where: you breach these Terms; you fail to provide requested identity or source-of-funds information; you become subject to sanctions or become resident in a Restricted Jurisdiction; we suspect fraud or illegal activity; we make a business or risk decision to discontinue the product; or termination is required by law.

11.2 On termination, accrual stops and your balance is credited to your Wallet. We will give reasonable notice and instructions, except where immediate closure is required by law. Obligations that by their nature survive (including tax and compliance obligations) survive termination.

12. Amendments

12.1 We may amend these Terms at any time by posting the updated version in the App, with email notice where required. For material adverse changes (for example, a reduction of rates or new fees) we will give reasonable advance notice, no less than 30 days where feasible. Continued use after the effective date constitutes acceptance; if you do not agree, close your Savings positions before the effective date.

13. Governing Law and Disputes

13.1 These Savings 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.

13.2 Any claim under these Terms must be filed within one year of the date you became aware, or should reasonably have become aware, of the facts giving rise to it, unless a longer period is required by law.

14. General and Contact

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

14.2 Questions, complaints and legal notices: [email protected]