Clapp Terms of Service

Last Revised: 25.08.2026

1. Introduction

1.1 Welcome to Clapp. Clapp is a digital asset platform that offers custodial wallet, exchange, savings, credit and card services through the website https://clapp.finance/ (the “Website”) and the Clapp mobile application (the “App”, and together with the Website, the “Platform”).

1.2 “Clapp” is a brand name used by several companies within the Clapp group (the “Clapp Group”). Each service available on the Platform is provided to you by the specific Clapp Group company identified in these Terms and in the App for your country of residence (each a “Service Provider”). When these Terms say “Clapp”, “we”, “us” or “our” in connection with a particular service, they refer to the Service Provider of that service. Schedule 2 lists the Clapp Group companies and their roles.

1.3 By registering for an Account, accessing or using the Services, you confirm that you have read, understood and agreed to these Terms and to the policies referenced in them, including the Privacy Policy, the Risk Disclosure Statement and, where you use the relevant products, the Savings Terms, the Credit Line Terms and the Card Terms. If you do not agree with any part of these Terms, you must stop using the Services.

1.4 The rights and obligations of each Clapp Group company under these Terms are several and not joint. Each Service Provider is responsible only for the services it provides to you. No Clapp Group company is liable for the acts or omissions of another Clapp Group company, and you agree not to pursue any Clapp Group company in respect of a service it does not provide to you.

1.5 We may modify these Terms at any time. Changes will be posted on the Platform with an updated “Last Revised” date. Where a change is material and adverse to you, we will give you at least 30 days’ advance notice through the App or by email, unless the change is required by law, by a regulator or for security reasons, in which case it may take effect immediately. Your continued use of the Services after the effective date constitutes acceptance of the updated Terms. If you do not agree to a change, you must stop using the Services and close your Account before the effective date.

2. Definitions

2.1 In these Terms:

“Account” means the user profile registered on the Platform through which you access the Services.

“App Operator” means AlphaEX s.r.o., a company incorporated in the Czech Republic, business ID 17805791, registered office Primátorská 296/38, Libeň, 180 00 Prague, Czech Republic, which operates the Platform as the technology and distribution company of the Clapp Group. The App Operator is not a Service Provider and does not provide any regulated financial or crypto-asset service.

“Bitcoin Services” means the services described in Section 7.

“Card” and “Card Terms” have the meanings given in Section 8.3.

“Clapp Canada” means Clapp Finance Limited, a company incorporated in Canada with its place of business at 600 - 1285 West Broadway, Vancouver, British Columbia, V6H 3X8, Canada, registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business, registration number N300000907.

“Clapp El Salvador” means Clapp S.A. de C.V., a company incorporated in El Salvador, business ID 363802-9, registered address C.C. Feria Rosa, Local 303 EF, San Salvador, El Salvador, registered as a Bitcoin Service Provider with the Central Reserve Bank of El Salvador.

“Clapp Group” means the companies operating under the “Clapp” brand, including the companies listed in Schedule 2 and their affiliates.

“Clapp Hong Kong” means Clapp Limited, a company incorporated in Hong Kong, company number 78435441.

“Digital Assets” means cryptocurrencies, stablecoins and other virtual assets supported on the Platform from time to time.

“Fiat Currency” means government-issued currency, such as EUR or USD.

“KYC” means the identity verification and customer due diligence process we apply to comply with anti-money laundering and counter-terrorism financing laws.

“Partner Financial Institutions” means the third-party licensed banks, electronic money institutions, payment institutions and card issuers through which certain fiat and card services are provided, as identified in the App.

“Restricted Jurisdiction” means any country or territory listed in Schedule 1, and any other country or territory where the Services, or a particular Service, may not lawfully be offered or where we decide not to offer them, as indicated in the App.

“Services” means the services described in Sections 5 to 8 and any related features of the Platform.

“Wallet” means the custodial wallet service described in Section 5.

3. Eligibility, Account and Verification

3.1 To use the Services you must: (1) be at least 18 years old, or the age of majority in your jurisdiction if higher; (2) have full legal capacity to enter into a binding agreement; (3) not be a resident of, located in, or accessing the Services from a Restricted Jurisdiction; (4) not be subject to sanctions administered by the United Nations, the European Union, the United Kingdom, the United States (OFAC), Canada or any other applicable authority, and not act on behalf of any person who is; and (5) not have been previously suspended or removed from the Services. These representations are continuing: they are deemed repeated each time you use the Services, and you must notify us immediately if any of them ceases to be true.

3.2 You must create an Account by providing accurate, complete and current information, and you must keep it up to date. You may hold only one Account unless we agree otherwise in writing.

3.3 You must complete KYC before using the Services and provide any documents and information we request, which may include a government-issued identification document, proof of residence, source of funds or wealth information and biometric verification data. We may refuse, suspend or terminate an Account, and delay or decline any transaction, if verification is incomplete, if we cannot satisfy our regulatory obligations, or if fraudulent or false information is suspected. We may also refuse to open an Account for any lawful reason at our discretion.

3.4 Not all Services are available in all countries. The Services available to you, and the Service Provider of each Service, depend on your verified country of residence and are shown in the App. We may add, restrict or withdraw Services for a given country at any time for legal, regulatory or risk reasons.

3.5 You are solely responsible for maintaining the confidentiality of your login credentials, passcodes and two-factor authentication settings. We will never ask you for your password. You must notify us immediately at [email protected] if you suspect unauthorized access to your Account. Subject to applicable law, you are responsible for activity that occurs under your Account, and we are not liable for losses resulting from unauthorized access caused by your failure to secure your credentials or devices.

3.6 Business accounts are subject to additional verification and to any separate terms we agree with the business. The individual opening a business account confirms that they are authorized to bind the business.

4. The Service Providers

4.1 The respective Clapp entity acts as the Service Provider of each respective Service. The App may identify in more detail the exact Service Provider applicable to you before you first use a Service, and the applicable product terms confirm it.

4.2 Where a Service is provided by a Partner Financial Institution, your contractual relationship for that service is with the Partner Financial Institution under its own terms, which will be made available to you in the App. We are not responsible for services provided by Partner Financial Institutions.

4.3 Registration of Clapp Canada as a money services business with FINTRAC is an anti-money laundering registration covering foreign exchange dealing, money transferring, dealing in virtual currencies and payment services. It does not mean that FINTRAC or any other Canadian authority endorses, licenses or supervises the quality of the products offered, and it does not constitute investor protection. The Savings and Credit Line products are lending arrangements; they are not within the service categories covered by the FINTRAC registration, and no registration or license attaches to them.

5. Wallet and Custody

5.1 Clapp provides a custodial Wallet allowing you to deposit, store and withdraw supported Digital Assets. Private keys are managed on your behalf using institutional custody technology with multi-party computation, provided through qualified custody infrastructure providers.

5.2 Digital Assets credited to your Wallet are held for you on a segregated basis, separate from our own assets, and are recorded in our books as client assets. Unless you use the Savings or Credit Line products (which have their own asset arrangements described in their terms), we do not lend, pledge or rehypothecate the Digital Assets held in your Wallet.

5.3 Withdrawals may be subject to security checks, verification steps, processing times and transaction limits shown in the App. We may delay or decline a withdrawal where required for security, legal or regulatory reasons, and we will inform you of the reason unless the law prevents us from doing so.

5.4 Deposits of unsupported assets, transfers to incorrect addresses and transfers on incorrect networks may result in permanent loss. We have no obligation to recover such assets, and any recovery we attempt is without guarantee and may be subject to a fee.

5.5 Digital Assets held in the Wallet are not bank deposits. They are not protected by any deposit guarantee scheme or investor compensation scheme, and their value can go down as well as up.

6. Exchange and Fiat Services

6.1 Clapp provides an exchange service enabling you to buy, sell and swap supported Digital Assets (other than transactions forming part of the Bitcoin Services) at prices quoted in the App. When you trade, Clapp acts as your counterparty at the quoted price; quotes include our fee or spread as disclosed in the App. Executed transactions are final and irreversible, and we do not guarantee any specific execution price where market conditions move between quote and execution. We may decline, reverse or unwind a transaction executed at a manifestly erroneous price caused by a pricing or system error, restoring the parties to their prior positions.

6.2 Clapp also provides fiat currency exchange and money transfer services outside the EEA, and business-to-business on/off-ramp services for corporate clients under separate agreements.

6.3 EUR accounts, personal IBANs and SEPA payments available in the App are provided by Partner Financial Institutions authorized in the EEA. Fiat funds held with a Partner Financial Institution are held under that institution’s safeguarding arrangements and its terms, not ours.

6.4 We may add or remove supported Digital Assets and Fiat Currencies at any time for legal, regulatory, risk or operational reasons, with notice where feasible. We are not liable for losses resulting from the delisting of an asset, provided we give you a reasonable opportunity to withdraw it. Where you fail to withdraw a delisted asset within the period stated in our notice, we may convert it into a supported stablecoin or Fiat Currency at prevailing rates and credit the proceeds to your Account.

7. Bitcoin Services

7.1 Bitcoin custody, purchase, sale, transfer and payment services (including payments over the Lightning network, where available) are provided inter alia by Clapp as a registered Bitcoin Service Provider under the laws of El Salvador.

7.2 Bitcoin Services relate to bitcoin (BTC) only. All services relating to other Digital Assets are provided by Clapp under Sections 5 and 6.

7.3 When you buy or sell bitcoin through the App, the App may show which exact Clapp entity acts as your counterparty for that transaction. The economic terms shown to you do not change based on the identity of the counterparty.

8. Savings, Credit Line and Card

8.1 The Savings product (flexible and fixed term) is provided by Clapp under the Savings Terms and Conditions. Savings are lending arrangements under which you transfer Digital Assets to the provider in exchange for interest. They are not bank deposits, they are not covered by any deposit guarantee scheme, they are not within the categories covered by the FINTRAC registration, and they are not crypto-asset services within the meaning of Regulation (EU) 2023/1114 (MiCA). The Savings Terms contain the full terms, including risk disclosures.

8.2 The Credit Line product is provided by Clapp under the Crypto Credit Line Terms. The Credit Line is an over-collateralized lending product. It is not a bank product and is not covered by any deposit guarantee or investor compensation scheme.

8.3 The Clapp Card is a Visa debit card issued by a licensed financial institution (the “Card Issuer”) identified in the App, with Clapp Hong Kong acting as program distributor and servicer. Your use of the Card is governed by the Clapp Card Terms and Conditions (the “Card Terms”).

8.4 If there is any conflict between these Terms and the Savings Terms, the Credit Line Terms or the Card Terms in relation to the relevant product, the product terms prevail.

8.5 We may modify, suspend or discontinue any product or feature, in any country or entirely, for commercial, legal, regulatory or risk reasons, with notice where feasible. Discontinuation does not affect your accrued rights.

9. User Obligations and Prohibited Activities

9.1 You agree to comply with all laws applicable to you when using the Services, including anti-money laundering and counter-terrorism financing laws, sanctions laws, tax laws and reporting obligations. You are solely responsible for determining whether your use of the Services is lawful in your jurisdiction and for paying any taxes arising from your transactions.

9.2 You must not: (1) use the Services for any unlawful purpose, including money laundering, terrorist financing, fraud, market abuse or sanctions evasion; (2) access or attempt to access the Services from a Restricted Jurisdiction, including through a VPN or other location-masking tools; (3) interfere with the Platform’s systems, security or operation, or introduce malicious code; (4) use bots, scrapers or other automated tools without our prior written consent; (5) engage in wash trading, spoofing, front running or other manipulative or abusive practices, including abuse of promotions, rates, errors or latency; (6) create multiple Accounts or provide false information, including to circumvent KYC or limits; (7) allow any third party to use your Account, or use the Services on behalf of a third party without our prior written approval; or (8) use the Services in connection with businesses or activities we have designated as prohibited in the App (such as darknet marketplaces, mixers, unlicensed gambling or Ponzi schemes).

9.3 We may suspend, restrict or terminate any Account involved in prohibited activities, cancel or reverse related transactions and rewards, report suspicious activity to competent authorities, cooperate with law enforcement, and freeze or surrender assets where required by law, a court order or a directive of a competent authority.

10. License and Intellectual Property

10.1 We grant you a limited, personal, revocable, non-exclusive, non-transferable license to install and use the App and access the Platform for your own lawful use of the Services in accordance with these Terms.

10.2 The Platform, including all software, designs, text, data, trademarks, logos and content, is the property of the Clapp Group and its licensors and is protected by intellectual property laws. Except for the license in Section 10.1, no rights are granted to you. You must not copy, modify, reverse engineer, decompile, distribute, sell, or create derivative works of any part of the Platform, or use the “Clapp” name or logos, without prior written consent, except to the extent such a restriction is prohibited by law.

10.3 If you send us ideas, suggestions or feedback, you grant the Clapp Group a perpetual, irrevocable, royalty-free, worldwide license to use them without restriction or compensation.

11. Risk Disclosure

11.1 Digital Assets are high risk and highly volatile. You can lose all invested funds. Digital Assets are not legal tender in most jurisdictions and are not covered by deposit guarantee or investor compensation schemes. Transactions in Digital Assets are generally irreversible.

11.2 Before using the Services you must read the Risk Disclosure Statement published on the Website, which forms part of these Terms. It describes market, liquidity, technology, custody, stablecoin, regulatory, tax and product-specific risks. By using the Services you confirm that you understand and accept those risks.

11.3 Nothing on the Platform constitutes investment, legal, accounting or tax advice or a recommendation to buy, sell or hold any Digital Asset. We do not assess the suitability of the Services for your personal circumstances, no fiduciary or advisory relationship arises between you and any Clapp Group company, and you act at all times on your own judgment.

12. Fees

12.1 We charge fees for certain Services. Applicable fees, spreads and limits are disclosed in the App before you confirm a transaction and in the fee information published on the Website. Product-specific fees are set out in the Savings Terms, the Credit Line Terms and the Card Terms.

12.2 We may change our fees with notice where feasible. Fee changes apply to transactions entered into after the change takes effect.

12.3 You bear third-party costs outside our control, including blockchain network (gas) fees and charges of your bank or payment provider. Fees paid to us are non-refundable unless otherwise required by law or expressly stated in the applicable terms.

12.4 We may deduct any fees, costs or other amounts you owe to a Service Provider from your balances, and each Service Provider may set off amounts you owe it against amounts it owes you, converting between currencies and Digital Assets where needed at prevailing rates.

13. Security

13.1 We implement industry-standard technical and organizational security measures, including multi-party computation custody, cold storage arrangements, two-factor authentication, transaction monitoring and independent security audits.

13.2 No security system is impenetrable. You acknowledge that the custody of Digital Assets involves inherent risks, including cyberattacks. We are not responsible for losses resulting from unauthorized access attributable to your failure to secure your credentials or devices.

14. Records

14.1 Our books and records (including transaction logs, price records, communications logs and account statements generated by the Platform) are conclusive evidence of your transactions and balances, absent manifest error. You must review your statements and transaction history and notify us of any discrepancy within 30 days; absent notice, they are deemed accepted, except where a manifest error is shown.

15. Liability

15.1 Nothing in these Terms excludes or limits any liability that cannot lawfully be excluded, including liability for fraud, for wilful misconduct, or for death or personal injury caused by negligence, and nothing in these Terms limits any mandatory statutory rights you have as a consumer.

15.2 Subject to Section 15.1, no Service Provider, nor its affiliates, directors, employees or service providers, is liable for: (1) indirect, incidental, special, punitive or consequential damages, or loss of profits, revenue, data or business opportunity; (2) losses caused by market movements or the volatility of Digital Assets; (3) losses caused by events of Force Majeure (Section 16); (4) losses caused by third parties, including Partner Financial Institutions, custody infrastructure providers, card networks and liquidity venues, except to the extent caused by our own gross negligence or wilful misconduct; (5) service interruptions for maintenance, security or reasons outside our reasonable control; or (6) your own acts or omissions, including sending assets to wrong addresses or networks and failing to secure your credentials.

15.3 Subject to Sections 15.1 and 15.2, the total aggregate liability of a Service Provider to you for all claims arising in any 12-month period shall not exceed the total fees you paid to that Service Provider in the three months preceding the event giving rise to the first claim, or EUR 1,000, whichever is greater. Where a product’s terms (Savings Terms, Credit Line Terms, Card Terms) contain a different cap for that product, that cap applies to that product.

15.4 Each Service Provider is liable only for its own services. You agree not to bring a claim against a Clapp Group company in respect of a service it does not provide to you.

15.5 The Services are provided on an “as is” and “as available” basis. We do not guarantee uninterrupted or error-free access to the Platform, and we disclaim all implied warranties to the maximum extent permitted by law.

16. Force Majeure

16.1 No Service Provider is liable for any failure or delay caused by events beyond its reasonable control, including natural disasters, war, terrorism, civil unrest, strikes, epidemics, government or regulatory action, sanctions, court orders, cyberattacks, failures of banks or Partner Financial Institutions, power or telecommunications failures, and failures, forks, halts or congestion of blockchain networks. Obligations are suspended while such an event continues, and we will take reasonable steps to mitigate its effects.

17. Indemnification

17.1 To the maximum extent permitted by law, you will indemnify and hold harmless each Clapp Group company and its officers, directors, employees and agents from and against claims, demands, losses, damages, fines and expenses (including reasonable legal fees) arising out of or connected with: (1) your breach of these Terms or any product terms; (2) your violation of any law or the rights of any third party; (3) your misuse of the Services; or (4) inaccurate or incomplete information you provide to us. This Section does not apply to the extent a claim results from our own fraud, gross negligence or wilful misconduct, and does not limit any mandatory consumer rights.

18. Suspension and Termination

18.1 We may suspend or restrict your Account, or particular Services, where: (1) we suspect a breach of these Terms or prohibited activity; (2) required by law, a regulator, a court or a card network; (3) your KYC or ongoing screening is incomplete or fails; (4) we identify security concerns; or (5) needed for maintenance. We will give you notice where legally permitted.

18.2 We may terminate these Terms and close your Account with at least 30 days’ notice for any reason, or immediately where required by law or justified by a serious breach. You may close your Account at any time through the App or by contacting support, subject to settling outstanding obligations.

18.3 On closure, you must withdraw your Digital Assets and fiat balances within the period stated in our notice. Where you fail to do so, or where we cannot return assets to you for legal reasons, we may convert and hold the balances, or transfer them to a custodian or an authority, as permitted by applicable law, and may deduct reasonable safekeeping costs where the law allows. Closure does not affect accrued rights and obligations, and we may retain records as required by law.

19. Complaints

19.1 If you are unhappy with any Service, contact [email protected]. We will acknowledge your complaint within 2 business days and aim to respond within 15 business days. Our Complaints Policy, published on the Website, describes the process, escalation options and any out-of-court dispute resolution bodies available to you depending on the Service and your country of residence.

20. Privacy

20.1 Personal data is processed in accordance with our Privacy Policy, which identifies the controller for each Service, the purposes and legal bases of processing, retention periods, international transfer safeguards and your rights. The App Operator acts as the representative of the non-EEA Clapp Group companies for the purposes of Article 27 of the EU GDPR.

21. Electronic Communications

21.1 You consent to receive agreements, notices, disclosures and other communications from us electronically, as described in the E-Sign and Electronic Communications Notice published on the Website. You may request paper copies and withdraw consent as described in that notice.

22. Governing Law and Dispute Resolution

22.1 These Terms, and any non-contractual obligations arising out of or in connection with them, are governed by the laws of England and Wales, without regard to conflict of laws principles.

22.2 Before starting formal proceedings, you agree to contact us and engage in good-faith negotiations for at least 30 days.

22.3 Subject to Section 22.5, any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by arbitration under the LCIA Rules, which Rules are deemed to be incorporated by reference into this clause. The number of arbitrators shall be one. The seat of arbitration shall be London, England. The language of the arbitration shall be English.

22.4 To the extent permitted by applicable law, disputes must be brought in an individual capacity only, and not as a plaintiff or class member in any class, collective, consolidated or representative proceeding. The arbitrator may not consolidate more than one person’s claims. If this Section 22.4 is found unenforceable for a particular claim, that claim, and only that claim, may proceed in court.

22.5 Nothing in this Section 22 deprives you of the protection of mandatory consumer protection rules of the country where you reside, prevents you from bringing proceedings before the courts of your country of residence where applicable law gives you that right, or restricts your right to complain to a competent supervisory or consumer protection authority.

22.6 Any claim arising out of or relating to the Services must be filed within one year after the date on which you became aware, or reasonably should have become aware, of the facts giving rise to the claim, unless a longer period is required by applicable law.

23. Miscellaneous

23.1 These Terms, together with the documents referenced in them, constitute the entire agreement between you and the relevant Service Provider regarding the Services.

23.2 A Service Provider may assign or transfer its rights and obligations under these Terms, in whole or in part, to another Clapp Group company or to a successor, provided this does not materially reduce your rights, and will give you notice of any such transfer. You may not assign your rights under these Terms without our prior written consent.

23.3 Nothing in these Terms creates a partnership, joint venture, employment or agency relationship between you and any Clapp Group company.

23.4 If any provision of these Terms is found invalid or unenforceable, the remaining provisions remain in full force, and the invalid provision is deemed replaced by a valid provision that comes closest to its intent.

23.5 A failure to enforce any provision of these Terms is not a waiver of it.

23.6 These Terms are published in English. Translations are provided for convenience only, and the English version prevails in the event of any inconsistency.

23.7 Notices to you will be given through the App or to your registered email address. Legal notices to a Service Provider must be sent to its registered office listed in Schedule 2, with a copy to [email protected]

23.8 Sections 9, 10, 12.4, 14, 15, 16, 17, 18.3, 22 and 23 survive closure of your Account and termination of these Terms, together with any provision that by its nature should survive.

Contact: [email protected]

Data protection: [email protected]

Schedule 1. Restricted Jurisdictions

Comprehensive restrictions (no Services available): Afghanistan, Belarus, Central African Republic, Cuba, Democratic Republic of the Congo, Iran, Iraq, Libya, Mali, Myanmar, Nicaragua, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, and the temporarily occupied territories of Ukraine (including Crimea, and the non-government controlled areas of the Donetsk, Luhansk, Kherson and Zaporizhzhia regions).

We may update this Schedule at any time. The current list of countries where each Service is available is shown in the App.

Schedule 2. Clapp Group Companies