Terms Of Service

Feb 4, 2026

support@mainframe.finance

Dammstrasse 16 6300 Zug Switzerland

These Terms of Service (the Terms) constitute a legally binding agreement between you, whether acting as an individual or on behalf of a legal entity (the Client, User, you, or your), and Mainframe Finance AG, a company incorporated under the laws of Switzerland, registered with the Swiss Commercial Register under number CHE-472.429.137, with its registered seat at Dammstrasse 16, 6300 Zug, Switzerland (Mainframe, the Company, we, us, or our).

These Terms govern your access to and use of the Mainframe technology platform, including any associated website, software, application, APIs, interfaces, tools, infrastructure and related services made available by Mainframe (the Platform).

Mainframe is not licensed or prudentially supervised by FINMA as a bank, securities firm, asset manager, DLT trading facility, trading venue, payment institution, collective investment scheme or financial market infrastructure. Mainframe does not provide services requiring any such FINMA prudential license. Mainframe operates as a financial intermediary within the meaning of the Swiss Anti-Money Laundering Act (AMLA) and is supervised for AMLA compliance through its membership in VQF, a self-regulatory organisation recognised by FINMA. The Platform does not constitute a multilateral trading facility, organised trading facility or DLT trading facility.

Mainframe provides a non-discretionary technology, compliance and operational intermediation layer enabling Clients to access and interact with independent third-party financial, digital asset and infrastructure service providers.

Mainframe acts as a non-discretionary intermediary and may act as a technical agent of the Client solely for the purpose of transmitting and facilitating Client Instructions to Third-Party Providers.

The Platform enables Clients to access and interact with third-party providers (Third-Party Providers), including, without limitation, centralised exchanges (CEXs), decentralised exchanges (DEXs), over-the-counter (OTC) counterparties, banking and payment institutions, fiat on/off-ramp providers, wallet and digital asset infrastructure providers, and compliance service providers.

Mainframe does not provide execution, trading, exchange, custody, banking, payment or DeFi services. Such services are provided exclusively by Third-Party Providers under their own legal, technical and operational terms.

Mainframe may, on a non-discretionary basis, transmit, route or facilitate Client Instructions and may interact with Third-Party Providers for the benefit of the Client and based solely on Client Instructions for operational, technical, compliance or administrative purposes. Mainframe does not make investment decisions, does not provide investment advice, does not manage Client Assets and does not act as a counterparty to Client transactions unless expressly agreed in writing.

Client Assets may be held with or through Third-Party Providers in accounts, wallets or infrastructure designated for, attributable to, or internally recorded for the benefit of the Client. Mainframe does not acquire beneficial ownership of Client Assets.

Fiat funds may be held in accounts opened in the name of Mainframe with third-party banking or payment providers and are internally designated for client fund purposes. Such accounts do not constitute personal bank accounts of the Client and may not benefit from depositor protection available to direct bank customers.

All Third-Party Providers operate independently and under their own terms. Mainframe does not guarantee the performance, availability, security, solvency or conduct of any Third-Party Provider.

By using the Platform, you authorise Mainframe to transmit your data, submit or facilitate Instructions, interact with Third-Party Providers and perform all operational, technical, compliance and administrative steps reasonably required to provide the Platform Services.

Your use of Third-Party Services may be subject to separate terms, policies and conditions imposed by the relevant Third-Party Providers. You are responsible for reviewing and understanding such terms before using any Third-Party Services.

In addition to these Terms, your use of the Platform is subject to applicable policies, disclosures and documents made available by Mainframe, including the Privacy Policy and any service-specific terms (together, the Annexes).

You should carefully review these Terms and all applicable Annexes before accessing or using the Platform.

IF YOU DO NOT AGREE TO THESE TERMS, YOU MUST NOT ACCESS OR USE THE PLATFORM.

We may amend these Terms from time to time. Any updated version will be published on the Platform and will indicate the date of the latest revision. Where required by applicable law or where Mainframe considers a change material, Mainframe may notify you by email, Platform notification or other appropriate means.

DEFINITIONS AND INTERPRETATION

Definitions. In these Terms, unless the context otherwise requires, the following terms shall have the meanings set out below:

“Mainframe”, “we”, “us”, “Company” - means Mainframe Finance AG, a company incorporated under the laws of Switzerland, registered with the Swiss Commercial Register under number CHE-472.429.137, with its registered seat in Zug, Switzerland.

“Client”, “User”, “you” - means any natural or legal person that accesses or uses the Platform and has accepted these Terms.

“Client Assets” - means any fiat funds and Digital Assets attributable to a Client, whether held directly or indirectly through Third-Party Providers, including on a segregated, omnibus or hybrid basis.

“Platform” - means the Mainframe technology platform, including any website, interface, software, APIs, infrastructure or tools made available by Mainframe through which Clients may access and interact with Third-Party Providers.

“Account” - means the user account established with Mainframe for the purpose of accessing the Platform.

“Instruction” - means any instruction, order, request or action submitted by the Client (or an Authorised Person) through the Platform in connection with Third-Party Services.

“Authorised Person” - means any person authorised by the Client and accepted by Mainframe to submit Instructions or otherwise act in relation to the Platform for the Client.

“Digital Assets” - means cryptocurrencies, tokens, stablecoins and other blockchain-based digital representations of value supported by the Platform.

“Third-Party Provider” - means any independent third party whose services may be accessed via the Platform, including but not limited to exchanges (CEXs or DEXs), OTC counterparties, banks, payment institutions, wallet or custody infrastructure providers, compliance providers, or other service providers.

“Third-Party Services” - means any services provided by Third-Party Providers, including but not limited to trading, execution, custody technology or wallet infrastructure services (but not legal custody services provided by Mainframe), fiat banking, payment services, on/off-ramp services and decentralised finance (DeFi) functionalities.

“Platform Services” - means the services provided by Mainframe consisting of: access to the Platform; transmission, routing or facilitation of Instructions to Third-Party Providers; onboarding, identification and KYC/AML compliance processes; and technical and operational integration with Third-Party Providers.

“Force Majeure Event” - means any event beyond the reasonable control of Mainframe, including but not limited to: natural disasters, epidemics or pandemics; war, terrorism or civil unrest; acts or orders of governmental or regulatory authorities; failures or disruptions of telecommunications, internet or IT infrastructure; cyberattacks, hacking, malware or security breaches; failures, delays or interruptions of Third-Party Providers; changes in applicable laws or regulatory interpretations; and extreme market conditions, including significant volatility, illiquidity or disruption in Digital Asset markets.

“Loss” - means any loss, damage, liability, claim, cost or expense (including reasonable legal fees), whether direct or indirect, to the extent recoverable under applicable law.

“Taxes” - means any taxes, levies, duties or similar governmental charges imposed by any competent authority.

“Restricted Jurisdiction” - means any jurisdiction which Mainframe designates as restricted due to applicable law, sanctions, regulatory requirements, licensing considerations, internal policies or restrictions imposed by Third-Party Providers.

Interpretation. Unless otherwise defined in these Terms, capitalised terms shall be interpreted in accordance with applicable Swiss law and, where relevant, industry practice.

No implication of regulated activities. Nothing in these Terms shall be construed as:
(a) creating a custody relationship between Mainframe and the Client;
(b) granting Mainframe discretionary investment authority or beneficial ownership over Client assets; or
(c) qualifying Mainframe as a bank, securities firm, asset manager, or licensed trading venue.

Third-party services and infrastructure. All Digital Asset Services and related financial, technical and infrastructure services are provided by independent Third-Party Providers, including exchanges, wallet and custody technology providers, banking and payment institutions, compliance providers and other infrastructure providers. Such providers act independently under their own legal, technical and operational terms. Mainframe may rely on such Third-Party Providers but does not control, operate or guarantee their performance, availability, security or conduct and shall not be liable for their acts or omissions.

Priority of documents. In the event of any inconsistency between these Terms and any Annex, these Terms shall prevail unless expressly stated otherwise.

ELIGIBILITY

Eligibility criteria. To access and use the Platform, you must, at all times, satisfy the following conditions:
(a) if you are a natural person, you must be at least 18 years old; if you act on behalf of a legal entity, you must be duly authorised to bind such entity;
(b) you must have full legal capacity and authority to enter into these Terms;
(c) you must successfully complete all onboarding, identification, and verification procedures required by Mainframe, including KYC/AML checks, to our satisfaction;
(d) you must not be resident, incorporated, established, located, operating from, or otherwise connected with any Restricted Jurisdiction, where such connection would make the provision of services unlawful or unacceptable to Mainframe;
(e) you must not be subject to any sanctions administered or enforced by Switzerland (including SECO), the European Union, the United Kingdom, the United States, or any other applicable authority;
(f) your access to and use of the Platform and any Third-Party Services must be lawful in your jurisdiction of residence and use;
(g) your use of the Platform must not result in Mainframe being required to obtain any licence, registration, or regulatory approval in any jurisdiction where it does not currently operate;
(h) you must provide accurate, complete, and up-to-date information at all times and promptly notify us of any changes.

Client categories. Unless otherwise specified by Mainframe for a particular service, the Platform may be made available to both retail and professional clients, subject to onboarding, risk assessment, jurisdictional restrictions and Third-Party Provider requirements.

Where the Client qualifies as a consumer under mandatory applicable law, nothing in these Terms limits any mandatory consumer rights that cannot be waived by contract.

Discretionary access and ongoing compliance. You shall ensure that you continue to meet the eligibility criteria set out in Clause 2.1 on an ongoing basis. Mainframe may, at any time, require you to provide additional information or documentation to verify your compliance.

Mainframe may, at its sole discretion and without providing reasons, refuse to onboard any Client, suspend, restrict or terminate access to the Platform, including where:
(a) you fail to meet or maintain any eligibility criteria;
(b) you fail to satisfy or maintain KYC/AML requirements; or
(c) Mainframe determines that continued provision of access presents legal, regulatory, operational or reputational risk.

Such measures may be taken at any time and without prior notice, where necessary to comply with applicable laws, regulations, internal policies or risk management considerations.

You must not use VPNs, proxies or any other technical means to circumvent jurisdictional, regulatory or access restrictions applicable to the Platform.

Regulatory and legal compliance. You are solely responsible for ensuring that your use of the Platform and any Third-Party Services complies with all applicable laws and regulations in your jurisdiction. Mainframe does not provide legal, tax, or regulatory advice.

Changes to eligibility. Mainframe may amend or impose additional eligibility criteria at any time, including on a per-service, per-product, or per-Third-Party Provider basis. Continued use of the Platform constitutes acceptance of such changes.

TERMS ACCEPTANCE

Review of Terms. You are responsible for carefully reviewing these Terms and all Annexes prior to accessing or using the Platform. If you do not understand any provision, you should seek independent legal or professional advice before using the Platform.

No advice. Mainframe does not provide legal, tax, investment or other professional advice.

Acceptance of Terms. By creating an Account, accessing the Platform, or submitting any Instruction, you acknowledge that you have read, understood, and agree to be bound by these Terms and all Annexes, as amended from time to time.

Binding effect. These Terms constitute a legally binding agreement between you and Mainframe. Acceptance of these Terms by electronic means, including through the Platform, shall have the same legal effect as a handwritten signature.

Personal data. In order to access the Platform, you may be required to provide personal and/or corporate information. The collection, use, storage, transfer and processing of such data are governed by the Privacy Policy, which forms an integral part of these Terms.

Access conditions. Mainframe may impose additional conditions for Account registration, activation or continued access to the Platform, including the use of invitation codes, enhanced verification measures, or service-specific requirements.

CLIENT WARRANTIES AND REPRESENTATIONS

Client warranties. By creating an Account and using the Platform, you represent and warrant, on an ongoing basis, that:
(a) you meet and will continue to meet all eligibility criteria set out in these Terms;
(b) you act on your own behalf as principal and beneficial owner of the assets, unless you have disclosed and Mainframe has accepted a different capacity during onboarding;
(c) you do not act as trustee, nominee, intermediary, agent or front person for any undisclosed third party;
(d) you are not using the Platform for the benefit of any undisclosed beneficial owner, nominee arrangement, pooled account or third-party client unless such arrangement has been fully disclosed to and expressly accepted by Mainframe;
(e) you will maintain the confidentiality and security of your Account credentials and will not grant access to any third party except through properly authorised access mechanisms;
(f) all information provided by you to Mainframe, including during onboarding and any KYC/AML procedures, is accurate, complete and not misleading;
(g) you will promptly update any information previously provided to Mainframe in the event of any change;
(h) all fiat funds and Digital Assets used by you are legally obtained, and you have full legal title to them, free of any third-party rights, claims, encumbrances or restrictions;
(i) your funds and Digital Assets are not derived from, and will not be used in connection with, any unlawful activity, including money laundering, terrorist financing, fraud or sanctions evasion;
(j) you are not subject to any applicable sanctions, nor acting on behalf of any sanctioned person or entity;
(k) your use of the Platform and any Third-Party Services complies with:
- these Terms;
- applicable laws and regulations of Switzerland; and
- any laws applicable in your jurisdiction of residence or operation;
(l) you understand and accept the risks associated with Digital Assets, Third-Party Providers, decentralised systems and financial markets, including the risk of total loss;
(m) you will not use mixers, tumblers, privacy-enhancing technologies, sanctioned wallets, high-risk services or any mechanism intended to obscure the origin, destination or ownership of assets, unless expressly disclosed to and accepted by Mainframe;
(n) you will not use the Platform in a manner that could expose Mainframe to legal, regulatory or reputational risk;
(o) you will not create or attempt to create multiple Accounts in circumvention of any restrictions imposed by Mainframe.

No reliance and no fiduciary duty. No fiduciary, advisory, discretionary or portfolio management relationship is created between the Client and Mainframe. You acknowledge that:
(a) Mainframe does not act as your fiduciary, investment adviser, asset manager, portfolio manager, broker, dealer or discretionary execution intermediary;
(b) any role of Mainframe is limited to non-discretionary transmission, routing or facilitation of Instructions;
(c) you make all decisions independently and at your own risk.

Breach of warranties. If you breach any of the warranties set out in this Clause, Mainframe may, at its sole discretion and without prior notice:
- suspend or restrict your access to the Platform;
- block, delay or refuse to transmit Instructions;
- terminate your Account; and/or
- take any other action deemed necessary to comply with applicable laws, regulatory obligations, sanctions requirements or internal risk policies.

Ongoing representations. The warranties set out in this Clause shall be deemed to be repeated each time you access the Platform, maintain an Account or submit an Instruction.

Amendments. Mainframe may amend or expand these warranties where reasonably required for legal, regulatory, compliance, sanctions, Third-Party Provider or risk management purposes. Material changes will be notified where required by applicable law.

PLATFORM SERVICES AND INSTRUCTIONS

Nature of Platform Services. Mainframe provides Platform Services consisting of non-discretionary technical, operational and compliance-related access to Third-Party Providers through the Platform.

Transmission and handling of Instructions. The Platform enables Clients to submit Instructions to Third-Party Providers.

For the avoidance of doubt, Mainframe does not operate any trading system, matching engine or execution venue and does not determine execution parameters beyond technical transmission of Client Instructions.

Mainframe may, on a non-discretionary basis, transmit, route or facilitate the technical submission of Client Instructions to Third-Party Providers based solely on Client input.

Mainframe does not act as a discretionary agent, broker, dealer or execution intermediary, does not execute transactions and does not assume responsibility for execution outcomes. Mainframe may act only as a non-discretionary technical agent for the limited purpose of transmitting or facilitating Client Instructions.

Mainframe is not responsible for monitoring execution outcomes or verifying whether an Instruction has been executed on terms favourable to the Client.

Client responsibility for Instructions. All Instructions are deemed to originate from the Client. The Client is solely responsible for the accuracy, completeness, and validity of any Instruction submitted through the Platform.

All Instructions are initiated and controlled by the Client, and Mainframe does not independently generate or modify Instructions.

Authentication and authorisation. Mainframe may implement authentication mechanisms, including two-factor authentication (2FA), to verify Instructions.

An Instruction shall be deemed validly submitted once the required authentication procedures have been successfully completed.

Mainframe may rely on such authentication without further verification, unless required by applicable law or internal compliance procedures.

Mainframe shall not be liable for any Loss arising from:
- unauthorised access resulting from compromised credentials; or
- failure by the Client to maintain adequate security measures.

Irreversibility and execution risk. Transactions involving Digital Assets may be irreversible. Once an Instruction has been transmitted to a Third-Party Provider, it may not be possible to cancel, reverse, or amend it.

The Client bears all risks associated with incorrect or erroneous Instructions, including incorrect wallet addresses or transaction parameters.

Manifest error and technical malfunction. Mainframe may cancel, reject, suspend, reverse, correct or disregard any Instruction or transaction record where Mainframe reasonably determines that it resulted from:
- a manifest error;
- a technical malfunction or system failure;
- incorrect, incomplete or corrupted data;
- unauthorised access or security breach;
- a Third-Party Provider error; or
- any abnormal or unintended system behaviour.

To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from such actions or from the underlying event.

Availability of assets and fees. The Client is responsible for ensuring that sufficient Client Assets are available with the relevant Third-Party Provider to cover:
- the intended transaction;
- any applicable fees of Third-Party Providers; and
- any fees payable to Mainframe.

Supported assets and providers. Mainframe may, at its sole discretion, determine:
- which Digital Assets are supported; and
- which Third-Party Providers are accessible via the Platform.

Such scope may be modified, restricted, or discontinued at any time without liability.

No execution or best execution obligation. Mainframe does not execute transactions and does not assume any obligation of best execution, price optimisation, routing quality or suitability.

Any execution is performed exclusively by Third-Party Providers under their own terms and conditions.

Routing and commercial arrangements. Routing of Instructions may depend on technical availability, integration status, liquidity access, operational considerations, compliance requirements and commercial arrangements with Third-Party Providers.

Mainframe may receive and retain rebates, commissions, spreads or other financial or non-financial benefits from Third-Party Providers in connection with services accessed through the Platform.

Mainframe is not required to pass on such benefits to the Client unless expressly agreed otherwise.

The Client acknowledges that such arrangements create inherent conflicts of interest.

Mainframe will manage such conflicts in accordance with its internal policies and applicable law.

Routing does not constitute execution, brokerage or order handling services by Mainframe. The Client acknowledges that routing of Instructions may not result in the best available price, speed, liquidity or total cost.

Third-party dependency. The transmission and execution of Instructions may be subject to delays, failures, or rejections caused by Third-Party Providers, technical issues, compliance checks, or market conditions.

Mainframe does not guarantee the timing, acceptance, or successful execution of any Instruction.

Compliance and enhanced due diligence. Mainframe may require additional information or perform enhanced due diligence measures at any time in order to comply with AML/CTF obligations.

Mainframe may suspend, delay, block or refuse to transmit any Instruction pending completion of such checks or where required by law, regulation or internal compliance policies.

Suspension in exceptional circumstances. Mainframe may suspend, restrict or disable submission or transmission of Instructions in whole or in part in the event of:
- extreme market conditions;
- failure or instability of Third-Party Providers;
- security incidents or cyber threats;
- regulatory or compliance concerns; or
- any other event requiring immediate risk mitigation.

System records and discrepancies. Clients must promptly review all transaction records and notify Mainframe of any discrepancies without undue delay.

Failure to do so may result in loss of rights to raise claims, to the extent permitted by applicable law.

Nature of role. The Platform operates as a technical and operational interface enabling Clients to access Third-Party Providers.

Mainframe does not act as a broker, dealer, exchange, trading venue or discretionary execution agent and does not assume any fiduciary or best execution obligations.

THIRD-PARTY SERVICES

Nature of Third-Party Services. Third-Party Services available through the Platform may include, without limitation:
- trading and execution services;
- digital asset custody and wallet infrastructure;
- fiat on/off-ramp and payment services; and
- decentralised finance (DeFi) functionalities, including liquidity provision.

All such services are provided exclusively by independent Third-Party Providers.

Access to decentralised protocols is provided solely through user-initiated interactions and does not involve intermediation or control by Mainframe over protocol logic or outcomes.

No provision of Third-Party Services by Mainframe. Mainframe does not provide Third-Party Services and does not act as a trading venue, exchange, payment service provider, legal custodian or financial counterparty.

The Platform enables Clients to access and interact with Third-Party Providers through a unified technological interface and intermediation layer.

Third-party terms and responsibility. Your use of any Third-Party Services is subject to the terms and conditions of the relevant Third-Party Provider.

You are solely responsible for reviewing, understanding and accepting such terms prior to using any Third-Party Services.

Relationship with Third-Party Providers. Mainframe may transmit Instructions, data and requests to Third-Party Providers and receive confirmations or responses from them based on Client Instructions and for operational, technical, compliance or administrative purposes.

Such interactions do not make Mainframe a party to the contractual relationship between you and the relevant Third-Party Provider, unless expressly stated otherwise.

No responsibility for Third-Party Providers. Mainframe does not control, operate or guarantee the performance, availability, security, solvency or reliability of any Third-Party Provider or its services.

To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- acts or omissions of Third-Party Providers;
- failures, delays or errors in their systems; or
- your access to or use of Third-Party Services.

Changes to Third-Party Providers and services. Mainframe may, at any time and without prior notice:
- add, remove or replace any Third-Party Provider; or
- modify, restrict or discontinue access to any Third-Party Services.

Mainframe shall not be liable for any Loss resulting from such changes or from the unavailability of any Third-Party Provider.

Termination of integrations. If Mainframe ceases integration with a Third-Party Provider, access to the relevant services through the Platform will be discontinued.

You remain solely responsible for managing any Client Assets, balances or positions held with such Third-Party Provider in accordance with its terms.

No endorsement or advice. The availability of any Third-Party Provider or service on the Platform does not constitute:
- any endorsement or recommendation;
- any investment, financial, legal or tax advice; or
- any representation that such provider or service is suitable for your individual circumstances.

You are solely responsible for conducting your own assessment of any Third-Party Provider and the risks associated with its use.

FIAT AND PAYMENT SERVICES

No banking or deposit-taking activity. Mainframe is not a bank and does not accept deposits from the public.

Mainframe does not act as a bank or licensed payment institution and does not provide payment services in its own name.

All fiat-related services are provided through independent Third-Party Providers.

Fiat account structure. Fiat funds may be held with third-party banking or payment institutions (including providers such as BCB Group or similar institutions) in accounts opened in the name of Mainframe and designated internally for client fund purposes.

Mainframe maintains internal records identifying fiat balances attributable to each Client.

Fiat funds held in accounts opened in the name of Mainframe are not bank accounts of the Client and may not benefit from depositor protection available to direct bank customers.

Such accounts may constitute pooled or omnibus accounts and do not create a direct claim of the Client against the banking provider.

The Client bears the credit risk of the relevant banking provider.

This structure does not constitute deposit-taking activity by Mainframe and is implemented solely for operational and settlement purposes in connection with Third-Party Providers.

Mainframe does not use fiat funds for its own account, does not pay interest on such funds and holds them solely for operational settlement and client-attribution purposes in connection with Platform Services.

Relationship with banking providers. Your use of fiat-related services is subject to the terms and conditions of the relevant Third-Party Provider.

The Client may not have a direct contractual relationship with the relevant banking or payment provider solely by virtue of using the Platform, unless explicitly established otherwise.

Third-party risk. The Client bears risks attributable to the relevant banking or payment provider, including, without limitation:
- insolvency or financial failure;
- regulatory intervention, freezing or account restrictions;
- delays, failures or reversals of payments; and
- operational or technical disruptions.

This allocation of risk does not apply to the extent that a Loss is directly caused by Mainframe’s wilful misconduct or gross negligence.

Mainframe may restrict, block or delay access to fiat funds where required by law, regulatory obligations or Third-Party Provider requirements.

No liability for payment services. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- acts or omissions of banks or payment service providers;
- delays, failures or restrictions in fiat transfers; or
- insolvency or regulatory actions affecting such providers.

No deposit protection or insurance. Unless expressly stated otherwise in writing, no deposit insurance, depositor protection scheme or equivalent protection applies to fiat funds accessible through the Platform. Clients expressly acknowledge that they may lose all fiat funds held through such structure in the event of insolvency of the banking provider.

Operational limitations. You acknowledge that fiat transactions may be subject to:
- banking hours and cut-off times;
- compliance checks and regulatory restrictions; and
- delays outside the control of Mainframe.

Changes to providers. Mainframe may change, replace or discontinue the use of any banking or payment provider at any time without prior notice.

Mainframe shall not be liable for any Loss resulting from such changes or from the unavailability of any provider.

CUSTODY AND CLIENT ASSETS

Client Assets (Digital Assets). Digital Assets forming part of Client Assets are held or recorded through Third-Party Providers, including wallet infrastructure providers, custody technology providers, exchanges and other service providers.

Mainframe does not act as a legal custodian of Digital Assets. Digital Assets are operated through Third-Party Provider infrastructure and subject to their legal and operational frameworks.

Mainframe does not acquire beneficial ownership of Digital Assets.

Mainframe does not hold private keys directly. Any ability to initiate or facilitate transfers is limited to the technical permissions, approval workflows and controls available within Third-Party Provider infrastructure and is exercised only on Client Instruction or where required by applicable law, regulatory obligations, compliance requirements or Third-Party Provider rules.

Any interaction with Digital Assets is performed through infrastructure provided by Third-Party Providers and initiated solely based on Client Instructions.

Private key management and transaction execution are performed within Third-Party Provider infrastructure.

Client Assets (Fiat Funds). Fiat funds forming part of Client Assets are subject to the structure described in Clause 7 (Fiat and Payment Services).

For the avoidance of doubt, such fiat funds may be held in accounts opened in the name of Mainframe with third-party banking or payment providers and internally attributed to Clients.

Ownership and title. As between Mainframe and the Client, Mainframe does not acquire beneficial ownership of Client Assets. The legal treatment of Client Assets held with or through Third-Party Providers depends on the applicable provider terms and account structure.

No deposit or fiduciary relationship. Nothing in these Terms creates a bank account, deposit, fiduciary deposit, loan, trust, escrow or similar relationship between the Client and Mainframe.

Segregation and record-keeping. Mainframe implements reasonable organisational and record-keeping measures to distinguish Client Assets from its own assets.

Client Assets may be held on a segregated, omnibus or hybrid basis depending on the relevant Third-Party Provider, service or transaction type.

Third-party risk. Client Assets remain subject to the legal, operational, insolvency, cybersecurity, regulatory and technical risks of the relevant Third-Party Providers.

Mainframe does not guarantee the solvency, performance, security or availability of any Third-Party Provider.

Client Assets may not be bankruptcy-remote from Third-Party Providers, including banks, exchanges, OTC counterparties or infrastructure providers.

Access and restrictions. The Client may access and use its Client Assets through the Platform, subject to technical, operational, compliance and Third-Party Provider limitations.

Mainframe may restrict, block, suspend or delay access to Client Assets where required for compliance, regulatory, security, technical, legal, operational or Third-Party Provider reasons.

No rehypothecation. Mainframe will not rehypothecate, lend, pledge or otherwise use Client Assets for its own account unless expressly agreed with the Client.

No insurance or protection. Unless expressly stated otherwise in writing, Client Assets are not covered by insurance, deposit protection, investor compensation schemes or any equivalent protection.

Service continuity and recovery. In the event of failure, insolvency or unavailability of a Third-Party Provider, access to Client Assets may be delayed, restricted or unavailable.

Mainframe does not guarantee recovery, availability or uninterrupted access to Client Assets in such circumstances.

FEES AND CHARGES

Mainframe fees. In consideration for the provision of Platform Services, you agree to pay fees to Mainframe (the Fees), as displayed on the Platform prior to submission of any Instruction.

Mainframe Fees relate solely to Platform Services and do not constitute consideration for any Third-Party Services.

Third-party fees. You acknowledge that Third-Party Providers may charge additional fees, commissions, spreads or network costs in connection with Third-Party Services.

Such fees are determined, charged and retained independently by the relevant Third-Party Provider and are outside the control of Mainframe.

Conflicts of interest and rebates. Mainframe may receive and retain fees, rebates, commissions, spreads or other financial or non-financial benefits from Third-Party Providers in connection with services accessed through the Platform.

The Client expressly acknowledges and consents to such arrangements and agrees that Mainframe may retain such benefits for its own account.

Such arrangements create inherent conflicts of interest.

Fee disclosure and acceptance. Applicable Mainframe Fees will be presented to you prior to submission of an Instruction.

By submitting an Instruction, you confirm your acceptance of all applicable Fees.

Availability of funds. You are responsible for ensuring that sufficient Client Assets are available with the relevant Third-Party Provider to cover:
- Mainframe Fees; and
- any applicable Third-Party Provider fees.

Failure to maintain sufficient balance may result in rejection or non-execution of an Instruction.

Fee collection and deduction. Where technically supported and legally permissible, Mainframe may deduct, set off or cause to be deducted any Fees or amounts due from Client Assets.

Such deduction is performed solely for the purpose of fee settlement and does not transfer ownership of Client Assets to Mainframe.

Any deduction of unpaid Fees from Client Assets will be performed only where technically available, legally permissible and properly recorded in Mainframe’s systems.

Fee validity. Any fee quotation displayed on the Platform is time-limited and may be recalculated if not accepted within the indicated period.

Changes to Fees. Mainframe may amend its Fees at any time.

Updated Fees will be made available on the Platform and will apply to future Instructions.

No liability for third-party fees. Mainframe shall not be liable for any changes to, or application of, fees by Third-Party Providers, including any Loss resulting therefrom.

Taxes. Mainframe Fees are exclusive of any applicable taxes, duties or charges, if any.

You are solely responsible for determining and fulfilling any tax obligations arising from your use of the Platform, including transactions, holdings, gains or losses.

DIGITAL ASSET PROTOCOL RISKS

No control over protocols. Digital Assets operate on distributed ledger protocols, including blockchain networks and smart contracts, which are typically open-source and not controlled by Mainframe.

Mainframe does not own, control, operate or maintain such protocols and assumes no responsibility for their functionality, security, availability or legality.

Protocol risks. You acknowledge and accept that Digital Asset protocols may:
- change, be modified or cease to operate;
- contain bugs, vulnerabilities or design flaws;
- be subject to cyberattacks, exploits or network disruptions; and
- result in partial or total loss of Digital Assets.

Forks, airdrops and network events. Protocols may undergo changes in operating rules, including forks, airdrops, upgrades or other network events.

Support for such events is determined by Third-Party Providers and, where applicable, by Mainframe at its sole discretion.

You have no entitlement to any forked asset, airdrop, staking reward, governance right or other protocol-derived benefit unless such benefit is supported and made available through the Platform.

Mainframe assumes no liability in respect of unsupported protocol changes or their consequences.

Third-party dependency. Support for Digital Assets and protocol events is dependent on Third-Party Providers, including exchanges, custodial infrastructure providers and liquidity providers.

Mainframe does not guarantee that any Digital Asset, protocol feature, fork, airdrop or network functionality will be supported or available.

No liability for protocol layer. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- operation or failure of any Digital Asset protocol;
- smart contract execution or failure;
- forks, airdrops or network changes; or
- any interaction with decentralised systems.

Counterparty and venue risk. You acknowledge that transactions involving centralised exchanges (CEXs), decentralised exchanges (DEXs), OTC counterparties, liquidity providers and DeFi protocols involve counterparty risk, liquidity risk, execution risk, settlement risk and may result in partial or total loss.

DeFi and smart contract risk. Interactions with decentralised finance (DeFi) protocols may involve additional risks, including but not limited to:
- smart contract vulnerabilities or exploits;
- oracle manipulation or failure;
- front-running, miner extractable value (MEV) or transaction reordering;
- liquidity pool imbalance or impermanent loss; and
- governance attacks or protocol-level manipulation.

Mainframe does not assess, monitor or guarantee the safety, reliability or performance of any DeFi protocol.

Client responsibility. You are solely responsible for understanding the technical, operational and economic risks associated with Digital Assets, protocols and Third-Party Services.

You acknowledge that you have sufficient knowledge and experience to assess such risks or have obtained independent advice where necessary.

Combined Risk Exposure. The Client acknowledges that the use of the Platform involves combined risks arising from Digital Asset markets, Third-Party Providers, infrastructure providers, regulatory actions and technological systems, any of which may result in partial or total loss of Client Assets.

AML/CTF, SANCTIONS, AND REGULATORY CONTROLS

Regulatory framework. Mainframe operates as a financial intermediary within the meaning of the Swiss Anti-Money Laundering Act (AMLA) and is subject to applicable AML/CTF laws, sanctions regimes and regulatory requirements.

Mainframe is a member of VQF, a self-regulatory organisation recognised and supervised by FINMA for AMLA purposes.

Onboarding and verification. Access to the Platform is conditional upon successful completion of all onboarding, identification and verification procedures, including KYC/AML checks, to the satisfaction of Mainframe.

Mainframe may, at any time and on an ongoing basis, require additional information, documentation or enhanced due diligence measures.

Ongoing monitoring. Mainframe may monitor Client activity on an ongoing basis, including transactions, behavior and risk indicators, for the purposes of detecting suspicious or unlawful activity and ensuring compliance with applicable laws and internal policies.

Client obligations. You represent and warrant that:
- your funds and Digital Assets are not derived from unlawful activity;
- you will not use the Platform for money laundering, terrorist financing, sanctions evasion or any other illegal purpose; and
- you will promptly notify Mainframe if you become aware of any suspicious or unlawful activity in connection with your Account.

Regulatory actions and restrictions. Mainframe may, at its sole discretion and without prior notice, take any action it considers necessary or appropriate to comply with applicable laws, regulations, sanctions requirements or internal risk policies, including without limitation:
- refuse, suspend or terminate access to the Platform;
- delay, block, reject or refuse to transmit Instructions;
- restrict withdrawals or access to Client Assets;
- freeze, hold, segregate or otherwise restrict assets or balances;
- request additional information or documentation; and/or
- report any activity to competent authorities.

Such actions may be taken immediately and without prior notice to the Client.

Sanctions and restricted jurisdictions. You must not:
- be subject to any applicable sanctions; or
- access or use the Platform from any Restricted Jurisdiction.

Mainframe may restrict, suspend or terminate access to the Platform in any jurisdiction at its sole discretion and without prior notice.

Information sharing. You authorise Mainframe to share your information with:
- regulators, supervisory authorities and law enforcement;
- financial institutions and Third-Party Providers; and
- service providers involved in compliance processes.

Such disclosure may be made without prior notice to or further consent from the Client where permitted or required by law, regulation, competent authority request, Third-Party Provider requirements or Mainframe’s internal compliance policies.

Mainframe may be legally prohibited from informing the Client of any report, investigation, restriction, freeze, block or suspicious activity assessment, including where such notification would constitute unlawful tipping-off under applicable law.

Such disclosures may include full transaction history, identity data and supporting documentation where required for compliance purposes.

Third-party compliance dependency. Mainframe may be required to comply with AML/CTF, sanctions and compliance requirements imposed by Third-Party Providers, including banks, exchanges, custodial infrastructure providers and liquidity providers.

Mainframe may take any action necessary to comply with such requirements, including restricting access, delaying or blocking Instructions or freezing assets.

No liability for regulatory actions. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from any action taken in good faith to comply with applicable laws, regulations, sanctions regimes, Third-Party Provider requirements or internal compliance policies.

SECURITY AND ACCOUNT ACCESS

Client responsibility. You are solely responsible for maintaining the confidentiality and security of your Account credentials, including usernames, passwords, authentication codes, and any other access information.

Use of Account. All Instructions and actions performed through your Account shall be deemed to have been authorised by you.

Mainframe may rely on completed authentication procedures and is not required to perform additional verification for each Instruction, unless required by applicable law or internal compliance procedures.

Unauthorised access. You are responsible for any use of your Account, whether authorised or unauthorised, except to the extent required under mandatory applicable law.

Security measures. Mainframe may implement security measures, including two-factor authentication (2FA) or other authentication mechanisms.

Such measures are intended to enhance security but do not guarantee prevention of unauthorised access, fraud or security breaches.

Client obligations in case of breach. You must:
- promptly notify Mainframe of any actual or suspected security breach; and
- take all reasonable steps to mitigate its impact, including securing your credentials and systems.

Platform security. Mainframe applies reasonable technical and organisational measures to protect the Platform and Client data.

However, Mainframe does not guarantee that the Platform will be uninterrupted, secure or free from errors, malware or vulnerabilities.

The Client acknowledges that the Platform is dependent on third-party infrastructure and may be unavailable, delayed or degraded at any time.

Third-party and external risks. Mainframe shall not be liable for any Loss arising from:
- security failures of Third-Party Providers;
- vulnerabilities in external systems, networks or software; or
- malware, cyberattacks or unauthorised access beyond Mainframe’s reasonable control.

Limitation of liability for security events. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- compromise of Client credentials;
- unauthorised access to the Account; or
- delays or failures in security systems.

Incident response and notification. In the event of a material security incident affecting the Platform or Client data, Mainframe will assess its obligations under applicable law and will notify affected Clients, regulators or competent authorities where required under applicable data protection, cybersecurity, AML/CTF or other mandatory laws.

LIMITATION OF LIABILITY

Basis of liability. Mainframe shall be liable only for Losses directly caused by its own wilful misconduct or gross negligence, to the extent required under applicable law.

To the maximum extent permitted by applicable law, Mainframe shall not be liable for any other Loss.

Exclusion of liability. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any:
(a) indirect, incidental, special, punitive, or consequential Loss;
(b) loss of profits, revenue, business opportunity, or anticipated savings;
(c) trading losses, including losses arising from market movements or failure to execute any transaction;
(d) loss, corruption, or inaccuracy of data; or
(e) reputational damage or loss of goodwill.

Third-party and external risks. Mainframe shall not be liable for any Loss arising from or in connection with:
(a) acts or omissions of any Third-Party Provider;
(b) insolvency, failure or unavailability of any Third-Party Provider;
(c) failures, delays or disruptions of external systems, networks or infrastructure;
(d) Digital Assets, blockchain protocols, smart contracts or decentralised systems;
(e) execution, non-execution, rejection or delay of any Instruction by a Third-Party Provider;
(f) Force Majeure Events; or
(g) any action taken by Mainframe in good faith for compliance, regulatory, legal, security or risk management purposes.

Client actions and Instructions. Mainframe shall not be liable for any Loss arising from:
- Instructions submitted through the Account;
- unauthorised access to the Account; or
- any error or omission in Instructions provided by the Client.

Platform provided “as is”. The Platform and all related services are provided on an “as is” and “as available” basis.

Mainframe makes no representation or warranty, whether express or implied, including as to:
- fitness for a particular purpose;
- accuracy, completeness or reliability;
- uninterrupted or error-free operation; or
- security, availability or performance.

Liability cap. Subject to Clause 13.7, to the maximum extent permitted by applicable law, the total aggregate liability of Mainframe arising out of or in connection with these Terms shall not exceed the total Fees paid by the Client to Mainframe in the twelve (12) months preceding the event giving rise to the claim, or CHF 10,000, whichever is higher.

Mandatory law carve-out. Nothing in these Terms excludes or limits liability to the extent such exclusion or limitation is not permitted under applicable law, including liability for:
- fraud or fraudulent misrepresentation;
- wilful misconduct; or
- gross negligence.

Service changes. Mainframe may modify, suspend, or discontinue any part of the Platform at any time without liability.

External resources. The Platform may contain links to or integrations with third-party websites or services. Mainframe is not responsible for the content, availability or accuracy of such external resources.

INDEMNITY AND CLIENT LIABILITY

Indemnity. You agree to indemnify, defend and hold harmless Mainframe, its affiliates and their respective directors, officers, employees and agents from and against any and all Loss arising out of or in connection with:
(a) your use of the Platform or any Third-Party Services;
(b) any breach of these Terms;
(c) any Instruction submitted through your Account;
(d) your violation of any applicable law, regulation or sanctions regime;
(e) any breach of AML/CTF, sanctions, tax, fraud prevention or source-of-funds representations;
(f) your interaction with any Third-Party Provider, including any transactions, losses or disputes arising therefrom; or
(g) any claim brought by a third party in connection with your actions or omissions.

Third-party claims and reimbursement. Where Mainframe becomes subject to any claim, investigation, regulatory request or proceeding as a result of your actions or omissions, you shall promptly indemnify and fully reimburse Mainframe for all resulting Loss, including legal fees, investigation costs and settlement amounts.

Such reimbursement obligation shall apply on demand, subject to mandatory applicable law and any finally determined defences available to the Client, and shall not require prior judicial determination to the extent permitted by applicable law.

Cooperation and information. You agree to provide all information, documentation and assistance reasonably requested by Mainframe in connection with any investigation, claim, audit or regulatory requirement.

Failure to provide such information may result in suspension or restriction of access to the Platform.

Fraud and unlawful activity. Where Mainframe reasonably suspects fraud, unlawful activity or breach of these Terms, it may take any action it deems appropriate, including requesting information, restricting access or reporting to authorities.

You agree to comply with such requests and acknowledge that failure to do so may result in immediate suspension or termination of your Account.

Survival and independence. The indemnity obligations under this Clause shall survive termination of these Terms and shall be independent of any limitation of liability set out in these Terms, to the extent permitted by applicable law.

DATA PROTECTION AND INFORMATION USE

Privacy Policy. The collection, use, storage, and processing of personal data by Mainframe are governed by the Privacy Policy, which forms an integral part of these Terms.

Data processing for service provision. You acknowledge and agree that Mainframe may process your personal and transactional data to:
- provide access to the Platform;
- facilitate interaction with Third-Party Providers; and
- perform onboarding, verification, and ongoing compliance checks.

Mainframe acts as controller for onboarding, AML/KYC, account, transaction and compliance data. Certain Third-Party Providers may act as independent controllers or processors depending on their role.

Regulatory and compliance use. Mainframe may process, retain and disclose your data where necessary to comply with AML/CTF laws, sanctions regimes, regulatory obligations and requests from competent authorities.

Such processing and disclosure may occur without prior notice where required or permitted by applicable law.

Data sharing with third parties. You acknowledge and agree that your data may be shared with:
- banks and payment institutions (e.g., fiat service providers);
- custodial infrastructure providers;
- exchanges, OTC counterparties, and other Third-Party Providers;
- KYC/AML service providers (e.g., identity verification providers); and
- regulatory or governmental authorities.

This may include, without limitation, service providers such as SumSub, Fireblocks, BCB Group, exchanges, OTC counterparties, cloud infrastructure providers and other operational or compliance partners.

Cross-border data transfers. Client data may be transferred to and processed in jurisdictions outside Switzerland or the European Economic Area only where permitted under applicable data protection law and subject to appropriate safeguards where required, including contractual or other legally recognised transfer mechanisms.

Where required, Mainframe may rely on the Federal Council adequacy list, standard contractual clauses, contractual safeguards, statutory exemptions or other mechanisms recognised under Swiss data protection law.

Data retention. Mainframe retains KYC, KYB, AML, transaction and related compliance records for at least ten (10) years, or such longer period as required under applicable law.

Other data may be retained for as long as necessary for legal, regulatory, operational, evidentiary or legitimate business purposes.

System testing and security. Mainframe may use anonymised or pseudonymised data, and where necessary copies of data, for system testing, security monitoring and infrastructure resilience purposes.

Third-party data processing. Third-Party Providers process data under their own legal terms and privacy policies. Mainframe does not control and is not responsible for the processing of data by such Third-Party Providers.

Priority of regulatory disclosures. In the event of any conflict between data protection obligations and obligations under AML/CTF, sanctions or regulatory requirements, Mainframe’s obligations to comply with such regulatory requirements shall prevail to the extent permitted by applicable law.

SUSPENSION, RESTRICTIONS AND REGULATORY ACTIONS

Right to suspend or restrict access. Mainframe may, at its sole discretion and without prior notice, suspend, restrict or limit your access to the Platform where:
(a) your use of the Platform violates or may violate applicable law, including AML/CTF or sanctions requirements;
(b) continued provision of the Platform may expose Mainframe to legal, regulatory or reputational risk;
(c) you breach these Terms or any applicable policies;
(d) you fail to meet ongoing eligibility or compliance requirements;
(e) you become subject to insolvency, bankruptcy or similar proceedings; or
(f) it is necessary to ensure the security, integrity or proper functioning of the Platform.

Such measures may be applied immediately and without prior notice where deemed necessary by Mainframe.

Measures. In such cases, Mainframe may, without limitation:
- suspend your Account;
- restrict or block access to the Platform;
- delay, reject or refuse to transmit Instructions;
- restrict access to Third-Party Services;
- restrict, suspend or delay access to Client Assets, balances or transactions; and/or
- take any other action deemed necessary for compliance, security or risk management purposes.

Regulatory and compliance actions. Mainframe may take any action required or deemed appropriate to comply with applicable laws, regulations, sanctions regimes, regulatory requests or Third-Party Provider requirements, including freezing, holding or restricting access to Client Assets or Accounts.

Client notification. Where permitted, Mainframe may notify you of any suspension, restriction, freeze, block or termination.

Mainframe shall not be obliged to provide prior notice or reasons, particularly where such disclosure may conflict with legal, regulatory, law enforcement or internal risk management requirements.

Effect of suspension. During any period of suspension or restriction:
- access to the Platform may be limited or disabled;
- Instructions may not be accepted, transmitted or executed; and
- access to Client Assets or balances may be restricted, delayed or unavailable.

No liability. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from any suspension, restriction, freeze, block, termination of access or related action taken in good faith.

Client obligation to notify. You shall promptly notify Mainframe if you become aware of any circumstances that may affect your eligibility, compliance or lawful use of the Platform.

INTELLECTUAL PROPERTY

Ownership. All intellectual property rights in and to the Platform, including its software, infrastructure, APIs, databases, design, content and all related materials (the IP), are owned by Mainframe or its licensors.

Nothing in these Terms shall operate to transfer any intellectual property rights to the Client.

Limited licence. Subject to compliance with these Terms, Mainframe grants you a limited, non-exclusive, non-transferable, non-sublicensable and revocable licence to access and use the Platform solely for its intended purpose.

This licence does not include any right to access underlying source code, algorithms, architecture or non-public interfaces of the Platform.

Restrictions. You shall not, without prior written consent of Mainframe:
- copy, reproduce, modify or create derivative works of the Platform;
- reverse engineer, decompile or attempt to extract source code;
- access or use the Platform in a manner that competes with or replicates the Platform or any of its functionalities;
- use the Platform for commercial exploitation beyond its intended use;
- scrape, extract or systematically collect data from the Platform;
- use automated tools, bots, crawlers or similar technologies without authorisation;
- interfere with, disrupt or attempt to gain unauthorised access to the Platform or its underlying systems; or
- infringe any intellectual property rights of Mainframe or any third party.

No transfer of rights. Nothing in these Terms shall be construed as transferring any intellectual property rights to you.

All rights not expressly granted are reserved by Mainframe.

Third-party intellectual property. The Platform may include intellectual property belonging to Third-Party Providers.

Such intellectual property is used under licence or integration arrangements and remains the property of the respective Third-Party Providers.

Your use of such intellectual property may be subject to the terms and conditions of the relevant Third-Party Providers.

Feedback. If you provide any feedback, suggestions or ideas relating to the Platform, you grant Mainframe a perpetual, irrevocable, worldwide, royalty-free, transferable and sublicensable right to use, modify and implement such feedback without restriction or compensation.

Data and usage rights. Mainframe may collect and use anonymised, aggregated or statistical data derived from the use of the Platform for analytics, performance improvement, security, compliance and business purposes.

Such data shall not identify the Client directly.

TERM AND TERMINATION

Term. These Terms shall commence upon your acceptance and remain in effect until terminated in accordance with this Clause.

Termination by the Client. You may request closure of your Account at any time through the Platform.

Mainframe may process such request within a reasonable period, subject to:
- completion of any pending obligations;
- settlement of any outstanding Fees; and
- compliance with applicable legal and regulatory requirements.

Termination by Mainframe. Mainframe may terminate these Terms and/or your access to the Platform at any time, with or without notice, including in accordance with Clause 16 or where continued provision of the Platform is no longer feasible for legal, regulatory, operational or risk management reasons.

Effect of termination. Upon termination:
- your access to the Platform will be disabled;
- Instructions may no longer be accepted or transmitted; and
- access to certain functionalities or services may be restricted or discontinued.

You remain solely responsible for managing any Client Assets, balances or positions held with Third-Party Providers.

Mainframe does not control or manage Client Assets and shall not be responsible for any actions required by the Client following termination.

Termination shall not affect any outstanding Fees, pending Instructions, regulatory holds, compliance reviews, reporting obligations or restrictions imposed by applicable law, Third-Party Providers or competent authorities.

Data retention. Notwithstanding termination, Mainframe may retain Client data to the extent required by applicable law, including AML/CTF obligations, and for legitimate business purposes.

Survival. Any provisions of these Terms which by their nature should survive termination shall remain in full force and effect, including, without limitation:
- limitation of liability;
- indemnity obligations;
- data protection and regulatory compliance; and
- any accrued rights or obligations.

No obligation to disclose reasons. Mainframe shall not be obliged to disclose the reasons for any suspension, restriction, freeze, block or termination where such disclosure would conflict with legal, regulatory, law enforcement or internal risk management requirements.

COMMUNICATIONS, SUPPORT, AND CONTACT

Electronic communications. You agree that Mainframe may communicate with you via electronic means, including email and through the Platform.

Such communications may include, without limitation, operational messages, regulatory notices, security alerts, updates to the Platform and amendments to these Terms.

Legal effect of communications. Any notice, communication or information provided by Mainframe via email or through the Platform shall be deemed received at the time it is sent, unless a delivery failure notice is received.

Electronic communications shall have the same legal effect as written communications.

Client contact details. You are responsible for maintaining accurate and up-to-date contact information, including your email address.

Mainframe shall not be responsible for any Loss arising from your failure to maintain accurate contact details.

Support and enquiries. If you have any questions, feedback or complaints, you may contact Mainframe using the contact details provided on the Platform.

Mainframe may, but is not obliged to, provide support services and does not guarantee response times or resolution of enquiries.

Contact information. Current contact details of Mainframe are made available on the Platform and may be updated from time to time.

Notices to Mainframe may be sent to: compliance@mainframe.finance, or such other contact details as may be communicated by Mainframe from time to time.

NO ADVICE AND TAX

No advice. No information, content or materials provided through the Platform constitute investment, financial, legal or tax advice, or a recommendation to buy, sell or transact in any Digital Asset or financial instrument.

Mainframe does not provide advisory, portfolio management or discretionary services.

Independent decisions. You are solely responsible for any decision to engage in transactions involving Digital Assets or Third-Party Services.

You acknowledge that you act on your own initiative and at your own risk and that you have sufficient knowledge and experience to assess such transactions or have obtained independent professional advice where necessary.

No reliance. You agree that you do not rely on any information provided by Mainframe as advice or as a basis for any investment or transaction decision.

Tax responsibility. You are solely responsible for determining, reporting and fulfilling any tax obligations arising from your use of the Platform or any Third-Party Services, including transactions, holdings, gains or losses.

Mainframe does not provide tax advice and makes no representation regarding the tax treatment of any transaction.

GENERAL PROVISIONS

Entire agreement. These Terms, together with any documents incorporated by reference (including the Annexes), constitute the entire agreement between you and Mainframe and supersede any prior agreements, understandings or representations.

Severability. If any provision of these Terms is found to be invalid, illegal or unenforceable, such provision shall be enforced to the maximum extent permissible and the remaining provisions shall remain in full force and effect.

Assignment. Mainframe may assign, transfer or otherwise dispose of its rights and obligations under these Terms, in whole or in part, at any time without restriction.

You may not assign, transfer or otherwise dispose of your rights or obligations without the prior written consent of Mainframe.

No waiver. Failure or delay by Mainframe to exercise any right, power or remedy shall not constitute a waiver of such right, power or remedy, nor shall any single or partial exercise prevent further exercise of that or any other right.

Amendments. Material changes will be notified by email, Platform notification or other appropriate means where required by applicable law or where Mainframe reasonably considers the change material.

Third-party rights. Except as expressly provided, no person other than the parties to these Terms shall have any right to enforce any provision of these Terms.

Language. These Terms may be made available in multiple languages. In the event of any inconsistency, the English version shall prevail.

GOVERNING LAW AND JURISDICTION

Governing law. These Terms and any non-contractual obligations arising out of or in connection with them shall be governed by the laws of Switzerland.

Jurisdiction. The courts of Zug, Switzerland shall have exclusive jurisdiction to resolve any disputes arising out of or in connection with these Terms. The place of performance shall be Zug, Switzerland, subject to mandatory consumer protection rules where applicable.

No class actions. To the extent permitted by applicable law and subject to mandatory applicable law, any claims shall be brought on an individual basis and not as part of any class or collective action.

These Terms of Service (the Terms) constitute a legally binding agreement between you, whether acting as an individual or on behalf of a legal entity (the Client, User, you, or your), and Mainframe Finance AG, a company incorporated under the laws of Switzerland, registered with the Swiss Commercial Register under number CHE-472.429.137, with its registered seat at Dammstrasse 16, 6300 Zug, Switzerland (Mainframe, the Company, we, us, or our).

These Terms govern your access to and use of the Mainframe technology platform, including any associated website, software, application, APIs, interfaces, tools, infrastructure and related services made available by Mainframe (the Platform).

Mainframe is not licensed or prudentially supervised by FINMA as a bank, securities firm, asset manager, DLT trading facility, trading venue, payment institution, collective investment scheme or financial market infrastructure. Mainframe does not provide services requiring any such FINMA prudential license. Mainframe operates as a financial intermediary within the meaning of the Swiss Anti-Money Laundering Act (AMLA) and is supervised for AMLA compliance through its membership in VQF, a self-regulatory organisation recognised by FINMA. The Platform does not constitute a multilateral trading facility, organised trading facility or DLT trading facility.

Mainframe provides a non-discretionary technology, compliance and operational intermediation layer enabling Clients to access and interact with independent third-party financial, digital asset and infrastructure service providers.

Mainframe acts as a non-discretionary intermediary and may act as a technical agent of the Client solely for the purpose of transmitting and facilitating Client Instructions to Third-Party Providers.

The Platform enables Clients to access and interact with third-party providers (Third-Party Providers), including, without limitation, centralised exchanges (CEXs), decentralised exchanges (DEXs), over-the-counter (OTC) counterparties, banking and payment institutions, fiat on/off-ramp providers, wallet and digital asset infrastructure providers, and compliance service providers.

Mainframe does not provide execution, trading, exchange, custody, banking, payment or DeFi services. Such services are provided exclusively by Third-Party Providers under their own legal, technical and operational terms.

Mainframe may, on a non-discretionary basis, transmit, route or facilitate Client Instructions and may interact with Third-Party Providers for the benefit of the Client and based solely on Client Instructions for operational, technical, compliance or administrative purposes. Mainframe does not make investment decisions, does not provide investment advice, does not manage Client Assets and does not act as a counterparty to Client transactions unless expressly agreed in writing.

Client Assets may be held with or through Third-Party Providers in accounts, wallets or infrastructure designated for, attributable to, or internally recorded for the benefit of the Client. Mainframe does not acquire beneficial ownership of Client Assets.

Fiat funds may be held in accounts opened in the name of Mainframe with third-party banking or payment providers and are internally designated for client fund purposes. Such accounts do not constitute personal bank accounts of the Client and may not benefit from depositor protection available to direct bank customers.

All Third-Party Providers operate independently and under their own terms. Mainframe does not guarantee the performance, availability, security, solvency or conduct of any Third-Party Provider.

By using the Platform, you authorise Mainframe to transmit your data, submit or facilitate Instructions, interact with Third-Party Providers and perform all operational, technical, compliance and administrative steps reasonably required to provide the Platform Services.

Your use of Third-Party Services may be subject to separate terms, policies and conditions imposed by the relevant Third-Party Providers. You are responsible for reviewing and understanding such terms before using any Third-Party Services.

In addition to these Terms, your use of the Platform is subject to applicable policies, disclosures and documents made available by Mainframe, including the Privacy Policy and any service-specific terms (together, the Annexes).

You should carefully review these Terms and all applicable Annexes before accessing or using the Platform.

IF YOU DO NOT AGREE TO THESE TERMS, YOU MUST NOT ACCESS OR USE THE PLATFORM.

We may amend these Terms from time to time. Any updated version will be published on the Platform and will indicate the date of the latest revision. Where required by applicable law or where Mainframe considers a change material, Mainframe may notify you by email, Platform notification or other appropriate means.

DEFINITIONS AND INTERPRETATION

Definitions. In these Terms, unless the context otherwise requires, the following terms shall have the meanings set out below:

“Mainframe”, “we”, “us”, “Company” - means Mainframe Finance AG, a company incorporated under the laws of Switzerland, registered with the Swiss Commercial Register under number CHE-472.429.137, with its registered seat in Zug, Switzerland.

“Client”, “User”, “you” - means any natural or legal person that accesses or uses the Platform and has accepted these Terms.

“Client Assets” - means any fiat funds and Digital Assets attributable to a Client, whether held directly or indirectly through Third-Party Providers, including on a segregated, omnibus or hybrid basis.

“Platform” - means the Mainframe technology platform, including any website, interface, software, APIs, infrastructure or tools made available by Mainframe through which Clients may access and interact with Third-Party Providers.

“Account” - means the user account established with Mainframe for the purpose of accessing the Platform.

“Instruction” - means any instruction, order, request or action submitted by the Client (or an Authorised Person) through the Platform in connection with Third-Party Services.

“Authorised Person” - means any person authorised by the Client and accepted by Mainframe to submit Instructions or otherwise act in relation to the Platform for the Client.

“Digital Assets” - means cryptocurrencies, tokens, stablecoins and other blockchain-based digital representations of value supported by the Platform.

“Third-Party Provider” - means any independent third party whose services may be accessed via the Platform, including but not limited to exchanges (CEXs or DEXs), OTC counterparties, banks, payment institutions, wallet or custody infrastructure providers, compliance providers, or other service providers.

“Third-Party Services” - means any services provided by Third-Party Providers, including but not limited to trading, execution, custody technology or wallet infrastructure services (but not legal custody services provided by Mainframe), fiat banking, payment services, on/off-ramp services and decentralised finance (DeFi) functionalities.

“Platform Services” - means the services provided by Mainframe consisting of: access to the Platform; transmission, routing or facilitation of Instructions to Third-Party Providers; onboarding, identification and KYC/AML compliance processes; and technical and operational integration with Third-Party Providers.

“Force Majeure Event” - means any event beyond the reasonable control of Mainframe, including but not limited to: natural disasters, epidemics or pandemics; war, terrorism or civil unrest; acts or orders of governmental or regulatory authorities; failures or disruptions of telecommunications, internet or IT infrastructure; cyberattacks, hacking, malware or security breaches; failures, delays or interruptions of Third-Party Providers; changes in applicable laws or regulatory interpretations; and extreme market conditions, including significant volatility, illiquidity or disruption in Digital Asset markets.

“Loss” - means any loss, damage, liability, claim, cost or expense (including reasonable legal fees), whether direct or indirect, to the extent recoverable under applicable law.

“Taxes” - means any taxes, levies, duties or similar governmental charges imposed by any competent authority.

“Restricted Jurisdiction” - means any jurisdiction which Mainframe designates as restricted due to applicable law, sanctions, regulatory requirements, licensing considerations, internal policies or restrictions imposed by Third-Party Providers.

Interpretation. Unless otherwise defined in these Terms, capitalised terms shall be interpreted in accordance with applicable Swiss law and, where relevant, industry practice.

No implication of regulated activities. Nothing in these Terms shall be construed as:
(a) creating a custody relationship between Mainframe and the Client;
(b) granting Mainframe discretionary investment authority or beneficial ownership over Client assets; or
(c) qualifying Mainframe as a bank, securities firm, asset manager, or licensed trading venue.

Third-party services and infrastructure. All Digital Asset Services and related financial, technical and infrastructure services are provided by independent Third-Party Providers, including exchanges, wallet and custody technology providers, banking and payment institutions, compliance providers and other infrastructure providers. Such providers act independently under their own legal, technical and operational terms. Mainframe may rely on such Third-Party Providers but does not control, operate or guarantee their performance, availability, security or conduct and shall not be liable for their acts or omissions.

Priority of documents. In the event of any inconsistency between these Terms and any Annex, these Terms shall prevail unless expressly stated otherwise.

ELIGIBILITY

Eligibility criteria. To access and use the Platform, you must, at all times, satisfy the following conditions:
(a) if you are a natural person, you must be at least 18 years old; if you act on behalf of a legal entity, you must be duly authorised to bind such entity;
(b) you must have full legal capacity and authority to enter into these Terms;
(c) you must successfully complete all onboarding, identification, and verification procedures required by Mainframe, including KYC/AML checks, to our satisfaction;
(d) you must not be resident, incorporated, established, located, operating from, or otherwise connected with any Restricted Jurisdiction, where such connection would make the provision of services unlawful or unacceptable to Mainframe;
(e) you must not be subject to any sanctions administered or enforced by Switzerland (including SECO), the European Union, the United Kingdom, the United States, or any other applicable authority;
(f) your access to and use of the Platform and any Third-Party Services must be lawful in your jurisdiction of residence and use;
(g) your use of the Platform must not result in Mainframe being required to obtain any licence, registration, or regulatory approval in any jurisdiction where it does not currently operate;
(h) you must provide accurate, complete, and up-to-date information at all times and promptly notify us of any changes.

Client categories. Unless otherwise specified by Mainframe for a particular service, the Platform may be made available to both retail and professional clients, subject to onboarding, risk assessment, jurisdictional restrictions and Third-Party Provider requirements.

Where the Client qualifies as a consumer under mandatory applicable law, nothing in these Terms limits any mandatory consumer rights that cannot be waived by contract.

Discretionary access and ongoing compliance. You shall ensure that you continue to meet the eligibility criteria set out in Clause 2.1 on an ongoing basis. Mainframe may, at any time, require you to provide additional information or documentation to verify your compliance.

Mainframe may, at its sole discretion and without providing reasons, refuse to onboard any Client, suspend, restrict or terminate access to the Platform, including where:
(a) you fail to meet or maintain any eligibility criteria;
(b) you fail to satisfy or maintain KYC/AML requirements; or
(c) Mainframe determines that continued provision of access presents legal, regulatory, operational or reputational risk.

Such measures may be taken at any time and without prior notice, where necessary to comply with applicable laws, regulations, internal policies or risk management considerations.

You must not use VPNs, proxies or any other technical means to circumvent jurisdictional, regulatory or access restrictions applicable to the Platform.

Regulatory and legal compliance. You are solely responsible for ensuring that your use of the Platform and any Third-Party Services complies with all applicable laws and regulations in your jurisdiction. Mainframe does not provide legal, tax, or regulatory advice.

Changes to eligibility. Mainframe may amend or impose additional eligibility criteria at any time, including on a per-service, per-product, or per-Third-Party Provider basis. Continued use of the Platform constitutes acceptance of such changes.

TERMS ACCEPTANCE

Review of Terms. You are responsible for carefully reviewing these Terms and all Annexes prior to accessing or using the Platform. If you do not understand any provision, you should seek independent legal or professional advice before using the Platform.

No advice. Mainframe does not provide legal, tax, investment or other professional advice.

Acceptance of Terms. By creating an Account, accessing the Platform, or submitting any Instruction, you acknowledge that you have read, understood, and agree to be bound by these Terms and all Annexes, as amended from time to time.

Binding effect. These Terms constitute a legally binding agreement between you and Mainframe. Acceptance of these Terms by electronic means, including through the Platform, shall have the same legal effect as a handwritten signature.

Personal data. In order to access the Platform, you may be required to provide personal and/or corporate information. The collection, use, storage, transfer and processing of such data are governed by the Privacy Policy, which forms an integral part of these Terms.

Access conditions. Mainframe may impose additional conditions for Account registration, activation or continued access to the Platform, including the use of invitation codes, enhanced verification measures, or service-specific requirements.

CLIENT WARRANTIES AND REPRESENTATIONS

Client warranties. By creating an Account and using the Platform, you represent and warrant, on an ongoing basis, that:
(a) you meet and will continue to meet all eligibility criteria set out in these Terms;
(b) you act on your own behalf as principal and beneficial owner of the assets, unless you have disclosed and Mainframe has accepted a different capacity during onboarding;
(c) you do not act as trustee, nominee, intermediary, agent or front person for any undisclosed third party;
(d) you are not using the Platform for the benefit of any undisclosed beneficial owner, nominee arrangement, pooled account or third-party client unless such arrangement has been fully disclosed to and expressly accepted by Mainframe;
(e) you will maintain the confidentiality and security of your Account credentials and will not grant access to any third party except through properly authorised access mechanisms;
(f) all information provided by you to Mainframe, including during onboarding and any KYC/AML procedures, is accurate, complete and not misleading;
(g) you will promptly update any information previously provided to Mainframe in the event of any change;
(h) all fiat funds and Digital Assets used by you are legally obtained, and you have full legal title to them, free of any third-party rights, claims, encumbrances or restrictions;
(i) your funds and Digital Assets are not derived from, and will not be used in connection with, any unlawful activity, including money laundering, terrorist financing, fraud or sanctions evasion;
(j) you are not subject to any applicable sanctions, nor acting on behalf of any sanctioned person or entity;
(k) your use of the Platform and any Third-Party Services complies with:
- these Terms;
- applicable laws and regulations of Switzerland; and
- any laws applicable in your jurisdiction of residence or operation;
(l) you understand and accept the risks associated with Digital Assets, Third-Party Providers, decentralised systems and financial markets, including the risk of total loss;
(m) you will not use mixers, tumblers, privacy-enhancing technologies, sanctioned wallets, high-risk services or any mechanism intended to obscure the origin, destination or ownership of assets, unless expressly disclosed to and accepted by Mainframe;
(n) you will not use the Platform in a manner that could expose Mainframe to legal, regulatory or reputational risk;
(o) you will not create or attempt to create multiple Accounts in circumvention of any restrictions imposed by Mainframe.

No reliance and no fiduciary duty. No fiduciary, advisory, discretionary or portfolio management relationship is created between the Client and Mainframe. You acknowledge that:
(a) Mainframe does not act as your fiduciary, investment adviser, asset manager, portfolio manager, broker, dealer or discretionary execution intermediary;
(b) any role of Mainframe is limited to non-discretionary transmission, routing or facilitation of Instructions;
(c) you make all decisions independently and at your own risk.

Breach of warranties. If you breach any of the warranties set out in this Clause, Mainframe may, at its sole discretion and without prior notice:
- suspend or restrict your access to the Platform;
- block, delay or refuse to transmit Instructions;
- terminate your Account; and/or
- take any other action deemed necessary to comply with applicable laws, regulatory obligations, sanctions requirements or internal risk policies.

Ongoing representations. The warranties set out in this Clause shall be deemed to be repeated each time you access the Platform, maintain an Account or submit an Instruction.

Amendments. Mainframe may amend or expand these warranties where reasonably required for legal, regulatory, compliance, sanctions, Third-Party Provider or risk management purposes. Material changes will be notified where required by applicable law.

PLATFORM SERVICES AND INSTRUCTIONS

Nature of Platform Services. Mainframe provides Platform Services consisting of non-discretionary technical, operational and compliance-related access to Third-Party Providers through the Platform.

Transmission and handling of Instructions. The Platform enables Clients to submit Instructions to Third-Party Providers.

For the avoidance of doubt, Mainframe does not operate any trading system, matching engine or execution venue and does not determine execution parameters beyond technical transmission of Client Instructions.

Mainframe may, on a non-discretionary basis, transmit, route or facilitate the technical submission of Client Instructions to Third-Party Providers based solely on Client input.

Mainframe does not act as a discretionary agent, broker, dealer or execution intermediary, does not execute transactions and does not assume responsibility for execution outcomes. Mainframe may act only as a non-discretionary technical agent for the limited purpose of transmitting or facilitating Client Instructions.

Mainframe is not responsible for monitoring execution outcomes or verifying whether an Instruction has been executed on terms favourable to the Client.

Client responsibility for Instructions. All Instructions are deemed to originate from the Client. The Client is solely responsible for the accuracy, completeness, and validity of any Instruction submitted through the Platform.

All Instructions are initiated and controlled by the Client, and Mainframe does not independently generate or modify Instructions.

Authentication and authorisation. Mainframe may implement authentication mechanisms, including two-factor authentication (2FA), to verify Instructions.

An Instruction shall be deemed validly submitted once the required authentication procedures have been successfully completed.

Mainframe may rely on such authentication without further verification, unless required by applicable law or internal compliance procedures.

Mainframe shall not be liable for any Loss arising from:
- unauthorised access resulting from compromised credentials; or
- failure by the Client to maintain adequate security measures.

Irreversibility and execution risk. Transactions involving Digital Assets may be irreversible. Once an Instruction has been transmitted to a Third-Party Provider, it may not be possible to cancel, reverse, or amend it.

The Client bears all risks associated with incorrect or erroneous Instructions, including incorrect wallet addresses or transaction parameters.

Manifest error and technical malfunction. Mainframe may cancel, reject, suspend, reverse, correct or disregard any Instruction or transaction record where Mainframe reasonably determines that it resulted from:
- a manifest error;
- a technical malfunction or system failure;
- incorrect, incomplete or corrupted data;
- unauthorised access or security breach;
- a Third-Party Provider error; or
- any abnormal or unintended system behaviour.

To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from such actions or from the underlying event.

Availability of assets and fees. The Client is responsible for ensuring that sufficient Client Assets are available with the relevant Third-Party Provider to cover:
- the intended transaction;
- any applicable fees of Third-Party Providers; and
- any fees payable to Mainframe.

Supported assets and providers. Mainframe may, at its sole discretion, determine:
- which Digital Assets are supported; and
- which Third-Party Providers are accessible via the Platform.

Such scope may be modified, restricted, or discontinued at any time without liability.

No execution or best execution obligation. Mainframe does not execute transactions and does not assume any obligation of best execution, price optimisation, routing quality or suitability.

Any execution is performed exclusively by Third-Party Providers under their own terms and conditions.

Routing and commercial arrangements. Routing of Instructions may depend on technical availability, integration status, liquidity access, operational considerations, compliance requirements and commercial arrangements with Third-Party Providers.

Mainframe may receive and retain rebates, commissions, spreads or other financial or non-financial benefits from Third-Party Providers in connection with services accessed through the Platform.

Mainframe is not required to pass on such benefits to the Client unless expressly agreed otherwise.

The Client acknowledges that such arrangements create inherent conflicts of interest.

Mainframe will manage such conflicts in accordance with its internal policies and applicable law.

Routing does not constitute execution, brokerage or order handling services by Mainframe. The Client acknowledges that routing of Instructions may not result in the best available price, speed, liquidity or total cost.

Third-party dependency. The transmission and execution of Instructions may be subject to delays, failures, or rejections caused by Third-Party Providers, technical issues, compliance checks, or market conditions.

Mainframe does not guarantee the timing, acceptance, or successful execution of any Instruction.

Compliance and enhanced due diligence. Mainframe may require additional information or perform enhanced due diligence measures at any time in order to comply with AML/CTF obligations.

Mainframe may suspend, delay, block or refuse to transmit any Instruction pending completion of such checks or where required by law, regulation or internal compliance policies.

Suspension in exceptional circumstances. Mainframe may suspend, restrict or disable submission or transmission of Instructions in whole or in part in the event of:
- extreme market conditions;
- failure or instability of Third-Party Providers;
- security incidents or cyber threats;
- regulatory or compliance concerns; or
- any other event requiring immediate risk mitigation.

System records and discrepancies. Clients must promptly review all transaction records and notify Mainframe of any discrepancies without undue delay.

Failure to do so may result in loss of rights to raise claims, to the extent permitted by applicable law.

Nature of role. The Platform operates as a technical and operational interface enabling Clients to access Third-Party Providers.

Mainframe does not act as a broker, dealer, exchange, trading venue or discretionary execution agent and does not assume any fiduciary or best execution obligations.

THIRD-PARTY SERVICES

Nature of Third-Party Services. Third-Party Services available through the Platform may include, without limitation:
- trading and execution services;
- digital asset custody and wallet infrastructure;
- fiat on/off-ramp and payment services; and
- decentralised finance (DeFi) functionalities, including liquidity provision.

All such services are provided exclusively by independent Third-Party Providers.

Access to decentralised protocols is provided solely through user-initiated interactions and does not involve intermediation or control by Mainframe over protocol logic or outcomes.

No provision of Third-Party Services by Mainframe. Mainframe does not provide Third-Party Services and does not act as a trading venue, exchange, payment service provider, legal custodian or financial counterparty.

The Platform enables Clients to access and interact with Third-Party Providers through a unified technological interface and intermediation layer.

Third-party terms and responsibility. Your use of any Third-Party Services is subject to the terms and conditions of the relevant Third-Party Provider.

You are solely responsible for reviewing, understanding and accepting such terms prior to using any Third-Party Services.

Relationship with Third-Party Providers. Mainframe may transmit Instructions, data and requests to Third-Party Providers and receive confirmations or responses from them based on Client Instructions and for operational, technical, compliance or administrative purposes.

Such interactions do not make Mainframe a party to the contractual relationship between you and the relevant Third-Party Provider, unless expressly stated otherwise.

No responsibility for Third-Party Providers. Mainframe does not control, operate or guarantee the performance, availability, security, solvency or reliability of any Third-Party Provider or its services.

To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- acts or omissions of Third-Party Providers;
- failures, delays or errors in their systems; or
- your access to or use of Third-Party Services.

Changes to Third-Party Providers and services. Mainframe may, at any time and without prior notice:
- add, remove or replace any Third-Party Provider; or
- modify, restrict or discontinue access to any Third-Party Services.

Mainframe shall not be liable for any Loss resulting from such changes or from the unavailability of any Third-Party Provider.

Termination of integrations. If Mainframe ceases integration with a Third-Party Provider, access to the relevant services through the Platform will be discontinued.

You remain solely responsible for managing any Client Assets, balances or positions held with such Third-Party Provider in accordance with its terms.

No endorsement or advice. The availability of any Third-Party Provider or service on the Platform does not constitute:
- any endorsement or recommendation;
- any investment, financial, legal or tax advice; or
- any representation that such provider or service is suitable for your individual circumstances.

You are solely responsible for conducting your own assessment of any Third-Party Provider and the risks associated with its use.

FIAT AND PAYMENT SERVICES

No banking or deposit-taking activity. Mainframe is not a bank and does not accept deposits from the public.

Mainframe does not act as a bank or licensed payment institution and does not provide payment services in its own name.

All fiat-related services are provided through independent Third-Party Providers.

Fiat account structure. Fiat funds may be held with third-party banking or payment institutions (including providers such as BCB Group or similar institutions) in accounts opened in the name of Mainframe and designated internally for client fund purposes.

Mainframe maintains internal records identifying fiat balances attributable to each Client.

Fiat funds held in accounts opened in the name of Mainframe are not bank accounts of the Client and may not benefit from depositor protection available to direct bank customers.

Such accounts may constitute pooled or omnibus accounts and do not create a direct claim of the Client against the banking provider.

The Client bears the credit risk of the relevant banking provider.

This structure does not constitute deposit-taking activity by Mainframe and is implemented solely for operational and settlement purposes in connection with Third-Party Providers.

Mainframe does not use fiat funds for its own account, does not pay interest on such funds and holds them solely for operational settlement and client-attribution purposes in connection with Platform Services.

Relationship with banking providers. Your use of fiat-related services is subject to the terms and conditions of the relevant Third-Party Provider.

The Client may not have a direct contractual relationship with the relevant banking or payment provider solely by virtue of using the Platform, unless explicitly established otherwise.

Third-party risk. The Client bears risks attributable to the relevant banking or payment provider, including, without limitation:
- insolvency or financial failure;
- regulatory intervention, freezing or account restrictions;
- delays, failures or reversals of payments; and
- operational or technical disruptions.

This allocation of risk does not apply to the extent that a Loss is directly caused by Mainframe’s wilful misconduct or gross negligence.

Mainframe may restrict, block or delay access to fiat funds where required by law, regulatory obligations or Third-Party Provider requirements.

No liability for payment services. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- acts or omissions of banks or payment service providers;
- delays, failures or restrictions in fiat transfers; or
- insolvency or regulatory actions affecting such providers.

No deposit protection or insurance. Unless expressly stated otherwise in writing, no deposit insurance, depositor protection scheme or equivalent protection applies to fiat funds accessible through the Platform. Clients expressly acknowledge that they may lose all fiat funds held through such structure in the event of insolvency of the banking provider.

Operational limitations. You acknowledge that fiat transactions may be subject to:
- banking hours and cut-off times;
- compliance checks and regulatory restrictions; and
- delays outside the control of Mainframe.

Changes to providers. Mainframe may change, replace or discontinue the use of any banking or payment provider at any time without prior notice.

Mainframe shall not be liable for any Loss resulting from such changes or from the unavailability of any provider.

CUSTODY AND CLIENT ASSETS

Client Assets (Digital Assets). Digital Assets forming part of Client Assets are held or recorded through Third-Party Providers, including wallet infrastructure providers, custody technology providers, exchanges and other service providers.

Mainframe does not act as a legal custodian of Digital Assets. Digital Assets are operated through Third-Party Provider infrastructure and subject to their legal and operational frameworks.

Mainframe does not acquire beneficial ownership of Digital Assets.

Mainframe does not hold private keys directly. Any ability to initiate or facilitate transfers is limited to the technical permissions, approval workflows and controls available within Third-Party Provider infrastructure and is exercised only on Client Instruction or where required by applicable law, regulatory obligations, compliance requirements or Third-Party Provider rules.

Any interaction with Digital Assets is performed through infrastructure provided by Third-Party Providers and initiated solely based on Client Instructions.

Private key management and transaction execution are performed within Third-Party Provider infrastructure.

Client Assets (Fiat Funds). Fiat funds forming part of Client Assets are subject to the structure described in Clause 7 (Fiat and Payment Services).

For the avoidance of doubt, such fiat funds may be held in accounts opened in the name of Mainframe with third-party banking or payment providers and internally attributed to Clients.

Ownership and title. As between Mainframe and the Client, Mainframe does not acquire beneficial ownership of Client Assets. The legal treatment of Client Assets held with or through Third-Party Providers depends on the applicable provider terms and account structure.

No deposit or fiduciary relationship. Nothing in these Terms creates a bank account, deposit, fiduciary deposit, loan, trust, escrow or similar relationship between the Client and Mainframe.

Segregation and record-keeping. Mainframe implements reasonable organisational and record-keeping measures to distinguish Client Assets from its own assets.

Client Assets may be held on a segregated, omnibus or hybrid basis depending on the relevant Third-Party Provider, service or transaction type.

Third-party risk. Client Assets remain subject to the legal, operational, insolvency, cybersecurity, regulatory and technical risks of the relevant Third-Party Providers.

Mainframe does not guarantee the solvency, performance, security or availability of any Third-Party Provider.

Client Assets may not be bankruptcy-remote from Third-Party Providers, including banks, exchanges, OTC counterparties or infrastructure providers.

Access and restrictions. The Client may access and use its Client Assets through the Platform, subject to technical, operational, compliance and Third-Party Provider limitations.

Mainframe may restrict, block, suspend or delay access to Client Assets where required for compliance, regulatory, security, technical, legal, operational or Third-Party Provider reasons.

No rehypothecation. Mainframe will not rehypothecate, lend, pledge or otherwise use Client Assets for its own account unless expressly agreed with the Client.

No insurance or protection. Unless expressly stated otherwise in writing, Client Assets are not covered by insurance, deposit protection, investor compensation schemes or any equivalent protection.

Service continuity and recovery. In the event of failure, insolvency or unavailability of a Third-Party Provider, access to Client Assets may be delayed, restricted or unavailable.

Mainframe does not guarantee recovery, availability or uninterrupted access to Client Assets in such circumstances.

FEES AND CHARGES

Mainframe fees. In consideration for the provision of Platform Services, you agree to pay fees to Mainframe (the Fees), as displayed on the Platform prior to submission of any Instruction.

Mainframe Fees relate solely to Platform Services and do not constitute consideration for any Third-Party Services.

Third-party fees. You acknowledge that Third-Party Providers may charge additional fees, commissions, spreads or network costs in connection with Third-Party Services.

Such fees are determined, charged and retained independently by the relevant Third-Party Provider and are outside the control of Mainframe.

Conflicts of interest and rebates. Mainframe may receive and retain fees, rebates, commissions, spreads or other financial or non-financial benefits from Third-Party Providers in connection with services accessed through the Platform.

The Client expressly acknowledges and consents to such arrangements and agrees that Mainframe may retain such benefits for its own account.

Such arrangements create inherent conflicts of interest.

Fee disclosure and acceptance. Applicable Mainframe Fees will be presented to you prior to submission of an Instruction.

By submitting an Instruction, you confirm your acceptance of all applicable Fees.

Availability of funds. You are responsible for ensuring that sufficient Client Assets are available with the relevant Third-Party Provider to cover:
- Mainframe Fees; and
- any applicable Third-Party Provider fees.

Failure to maintain sufficient balance may result in rejection or non-execution of an Instruction.

Fee collection and deduction. Where technically supported and legally permissible, Mainframe may deduct, set off or cause to be deducted any Fees or amounts due from Client Assets.

Such deduction is performed solely for the purpose of fee settlement and does not transfer ownership of Client Assets to Mainframe.

Any deduction of unpaid Fees from Client Assets will be performed only where technically available, legally permissible and properly recorded in Mainframe’s systems.

Fee validity. Any fee quotation displayed on the Platform is time-limited and may be recalculated if not accepted within the indicated period.

Changes to Fees. Mainframe may amend its Fees at any time.

Updated Fees will be made available on the Platform and will apply to future Instructions.

No liability for third-party fees. Mainframe shall not be liable for any changes to, or application of, fees by Third-Party Providers, including any Loss resulting therefrom.

Taxes. Mainframe Fees are exclusive of any applicable taxes, duties or charges, if any.

You are solely responsible for determining and fulfilling any tax obligations arising from your use of the Platform, including transactions, holdings, gains or losses.

DIGITAL ASSET PROTOCOL RISKS

No control over protocols. Digital Assets operate on distributed ledger protocols, including blockchain networks and smart contracts, which are typically open-source and not controlled by Mainframe.

Mainframe does not own, control, operate or maintain such protocols and assumes no responsibility for their functionality, security, availability or legality.

Protocol risks. You acknowledge and accept that Digital Asset protocols may:
- change, be modified or cease to operate;
- contain bugs, vulnerabilities or design flaws;
- be subject to cyberattacks, exploits or network disruptions; and
- result in partial or total loss of Digital Assets.

Forks, airdrops and network events. Protocols may undergo changes in operating rules, including forks, airdrops, upgrades or other network events.

Support for such events is determined by Third-Party Providers and, where applicable, by Mainframe at its sole discretion.

You have no entitlement to any forked asset, airdrop, staking reward, governance right or other protocol-derived benefit unless such benefit is supported and made available through the Platform.

Mainframe assumes no liability in respect of unsupported protocol changes or their consequences.

Third-party dependency. Support for Digital Assets and protocol events is dependent on Third-Party Providers, including exchanges, custodial infrastructure providers and liquidity providers.

Mainframe does not guarantee that any Digital Asset, protocol feature, fork, airdrop or network functionality will be supported or available.

No liability for protocol layer. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- operation or failure of any Digital Asset protocol;
- smart contract execution or failure;
- forks, airdrops or network changes; or
- any interaction with decentralised systems.

Counterparty and venue risk. You acknowledge that transactions involving centralised exchanges (CEXs), decentralised exchanges (DEXs), OTC counterparties, liquidity providers and DeFi protocols involve counterparty risk, liquidity risk, execution risk, settlement risk and may result in partial or total loss.

DeFi and smart contract risk. Interactions with decentralised finance (DeFi) protocols may involve additional risks, including but not limited to:
- smart contract vulnerabilities or exploits;
- oracle manipulation or failure;
- front-running, miner extractable value (MEV) or transaction reordering;
- liquidity pool imbalance or impermanent loss; and
- governance attacks or protocol-level manipulation.

Mainframe does not assess, monitor or guarantee the safety, reliability or performance of any DeFi protocol.

Client responsibility. You are solely responsible for understanding the technical, operational and economic risks associated with Digital Assets, protocols and Third-Party Services.

You acknowledge that you have sufficient knowledge and experience to assess such risks or have obtained independent advice where necessary.

Combined Risk Exposure. The Client acknowledges that the use of the Platform involves combined risks arising from Digital Asset markets, Third-Party Providers, infrastructure providers, regulatory actions and technological systems, any of which may result in partial or total loss of Client Assets.

AML/CTF, SANCTIONS, AND REGULATORY CONTROLS

Regulatory framework. Mainframe operates as a financial intermediary within the meaning of the Swiss Anti-Money Laundering Act (AMLA) and is subject to applicable AML/CTF laws, sanctions regimes and regulatory requirements.

Mainframe is a member of VQF, a self-regulatory organisation recognised and supervised by FINMA for AMLA purposes.

Onboarding and verification. Access to the Platform is conditional upon successful completion of all onboarding, identification and verification procedures, including KYC/AML checks, to the satisfaction of Mainframe.

Mainframe may, at any time and on an ongoing basis, require additional information, documentation or enhanced due diligence measures.

Ongoing monitoring. Mainframe may monitor Client activity on an ongoing basis, including transactions, behavior and risk indicators, for the purposes of detecting suspicious or unlawful activity and ensuring compliance with applicable laws and internal policies.

Client obligations. You represent and warrant that:
- your funds and Digital Assets are not derived from unlawful activity;
- you will not use the Platform for money laundering, terrorist financing, sanctions evasion or any other illegal purpose; and
- you will promptly notify Mainframe if you become aware of any suspicious or unlawful activity in connection with your Account.

Regulatory actions and restrictions. Mainframe may, at its sole discretion and without prior notice, take any action it considers necessary or appropriate to comply with applicable laws, regulations, sanctions requirements or internal risk policies, including without limitation:
- refuse, suspend or terminate access to the Platform;
- delay, block, reject or refuse to transmit Instructions;
- restrict withdrawals or access to Client Assets;
- freeze, hold, segregate or otherwise restrict assets or balances;
- request additional information or documentation; and/or
- report any activity to competent authorities.

Such actions may be taken immediately and without prior notice to the Client.

Sanctions and restricted jurisdictions. You must not:
- be subject to any applicable sanctions; or
- access or use the Platform from any Restricted Jurisdiction.

Mainframe may restrict, suspend or terminate access to the Platform in any jurisdiction at its sole discretion and without prior notice.

Information sharing. You authorise Mainframe to share your information with:
- regulators, supervisory authorities and law enforcement;
- financial institutions and Third-Party Providers; and
- service providers involved in compliance processes.

Such disclosure may be made without prior notice to or further consent from the Client where permitted or required by law, regulation, competent authority request, Third-Party Provider requirements or Mainframe’s internal compliance policies.

Mainframe may be legally prohibited from informing the Client of any report, investigation, restriction, freeze, block or suspicious activity assessment, including where such notification would constitute unlawful tipping-off under applicable law.

Such disclosures may include full transaction history, identity data and supporting documentation where required for compliance purposes.

Third-party compliance dependency. Mainframe may be required to comply with AML/CTF, sanctions and compliance requirements imposed by Third-Party Providers, including banks, exchanges, custodial infrastructure providers and liquidity providers.

Mainframe may take any action necessary to comply with such requirements, including restricting access, delaying or blocking Instructions or freezing assets.

No liability for regulatory actions. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from any action taken in good faith to comply with applicable laws, regulations, sanctions regimes, Third-Party Provider requirements or internal compliance policies.

SECURITY AND ACCOUNT ACCESS

Client responsibility. You are solely responsible for maintaining the confidentiality and security of your Account credentials, including usernames, passwords, authentication codes, and any other access information.

Use of Account. All Instructions and actions performed through your Account shall be deemed to have been authorised by you.

Mainframe may rely on completed authentication procedures and is not required to perform additional verification for each Instruction, unless required by applicable law or internal compliance procedures.

Unauthorised access. You are responsible for any use of your Account, whether authorised or unauthorised, except to the extent required under mandatory applicable law.

Security measures. Mainframe may implement security measures, including two-factor authentication (2FA) or other authentication mechanisms.

Such measures are intended to enhance security but do not guarantee prevention of unauthorised access, fraud or security breaches.

Client obligations in case of breach. You must:
- promptly notify Mainframe of any actual or suspected security breach; and
- take all reasonable steps to mitigate its impact, including securing your credentials and systems.

Platform security. Mainframe applies reasonable technical and organisational measures to protect the Platform and Client data.

However, Mainframe does not guarantee that the Platform will be uninterrupted, secure or free from errors, malware or vulnerabilities.

The Client acknowledges that the Platform is dependent on third-party infrastructure and may be unavailable, delayed or degraded at any time.

Third-party and external risks. Mainframe shall not be liable for any Loss arising from:
- security failures of Third-Party Providers;
- vulnerabilities in external systems, networks or software; or
- malware, cyberattacks or unauthorised access beyond Mainframe’s reasonable control.

Limitation of liability for security events. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from:
- compromise of Client credentials;
- unauthorised access to the Account; or
- delays or failures in security systems.

Incident response and notification. In the event of a material security incident affecting the Platform or Client data, Mainframe will assess its obligations under applicable law and will notify affected Clients, regulators or competent authorities where required under applicable data protection, cybersecurity, AML/CTF or other mandatory laws.

LIMITATION OF LIABILITY

Basis of liability. Mainframe shall be liable only for Losses directly caused by its own wilful misconduct or gross negligence, to the extent required under applicable law.

To the maximum extent permitted by applicable law, Mainframe shall not be liable for any other Loss.

Exclusion of liability. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any:
(a) indirect, incidental, special, punitive, or consequential Loss;
(b) loss of profits, revenue, business opportunity, or anticipated savings;
(c) trading losses, including losses arising from market movements or failure to execute any transaction;
(d) loss, corruption, or inaccuracy of data; or
(e) reputational damage or loss of goodwill.

Third-party and external risks. Mainframe shall not be liable for any Loss arising from or in connection with:
(a) acts or omissions of any Third-Party Provider;
(b) insolvency, failure or unavailability of any Third-Party Provider;
(c) failures, delays or disruptions of external systems, networks or infrastructure;
(d) Digital Assets, blockchain protocols, smart contracts or decentralised systems;
(e) execution, non-execution, rejection or delay of any Instruction by a Third-Party Provider;
(f) Force Majeure Events; or
(g) any action taken by Mainframe in good faith for compliance, regulatory, legal, security or risk management purposes.

Client actions and Instructions. Mainframe shall not be liable for any Loss arising from:
- Instructions submitted through the Account;
- unauthorised access to the Account; or
- any error or omission in Instructions provided by the Client.

Platform provided “as is”. The Platform and all related services are provided on an “as is” and “as available” basis.

Mainframe makes no representation or warranty, whether express or implied, including as to:
- fitness for a particular purpose;
- accuracy, completeness or reliability;
- uninterrupted or error-free operation; or
- security, availability or performance.

Liability cap. Subject to Clause 13.7, to the maximum extent permitted by applicable law, the total aggregate liability of Mainframe arising out of or in connection with these Terms shall not exceed the total Fees paid by the Client to Mainframe in the twelve (12) months preceding the event giving rise to the claim, or CHF 10,000, whichever is higher.

Mandatory law carve-out. Nothing in these Terms excludes or limits liability to the extent such exclusion or limitation is not permitted under applicable law, including liability for:
- fraud or fraudulent misrepresentation;
- wilful misconduct; or
- gross negligence.

Service changes. Mainframe may modify, suspend, or discontinue any part of the Platform at any time without liability.

External resources. The Platform may contain links to or integrations with third-party websites or services. Mainframe is not responsible for the content, availability or accuracy of such external resources.

INDEMNITY AND CLIENT LIABILITY

Indemnity. You agree to indemnify, defend and hold harmless Mainframe, its affiliates and their respective directors, officers, employees and agents from and against any and all Loss arising out of or in connection with:
(a) your use of the Platform or any Third-Party Services;
(b) any breach of these Terms;
(c) any Instruction submitted through your Account;
(d) your violation of any applicable law, regulation or sanctions regime;
(e) any breach of AML/CTF, sanctions, tax, fraud prevention or source-of-funds representations;
(f) your interaction with any Third-Party Provider, including any transactions, losses or disputes arising therefrom; or
(g) any claim brought by a third party in connection with your actions or omissions.

Third-party claims and reimbursement. Where Mainframe becomes subject to any claim, investigation, regulatory request or proceeding as a result of your actions or omissions, you shall promptly indemnify and fully reimburse Mainframe for all resulting Loss, including legal fees, investigation costs and settlement amounts.

Such reimbursement obligation shall apply on demand, subject to mandatory applicable law and any finally determined defences available to the Client, and shall not require prior judicial determination to the extent permitted by applicable law.

Cooperation and information. You agree to provide all information, documentation and assistance reasonably requested by Mainframe in connection with any investigation, claim, audit or regulatory requirement.

Failure to provide such information may result in suspension or restriction of access to the Platform.

Fraud and unlawful activity. Where Mainframe reasonably suspects fraud, unlawful activity or breach of these Terms, it may take any action it deems appropriate, including requesting information, restricting access or reporting to authorities.

You agree to comply with such requests and acknowledge that failure to do so may result in immediate suspension or termination of your Account.

Survival and independence. The indemnity obligations under this Clause shall survive termination of these Terms and shall be independent of any limitation of liability set out in these Terms, to the extent permitted by applicable law.

DATA PROTECTION AND INFORMATION USE

Privacy Policy. The collection, use, storage, and processing of personal data by Mainframe are governed by the Privacy Policy, which forms an integral part of these Terms.

Data processing for service provision. You acknowledge and agree that Mainframe may process your personal and transactional data to:
- provide access to the Platform;
- facilitate interaction with Third-Party Providers; and
- perform onboarding, verification, and ongoing compliance checks.

Mainframe acts as controller for onboarding, AML/KYC, account, transaction and compliance data. Certain Third-Party Providers may act as independent controllers or processors depending on their role.

Regulatory and compliance use. Mainframe may process, retain and disclose your data where necessary to comply with AML/CTF laws, sanctions regimes, regulatory obligations and requests from competent authorities.

Such processing and disclosure may occur without prior notice where required or permitted by applicable law.

Data sharing with third parties. You acknowledge and agree that your data may be shared with:
- banks and payment institutions (e.g., fiat service providers);
- custodial infrastructure providers;
- exchanges, OTC counterparties, and other Third-Party Providers;
- KYC/AML service providers (e.g., identity verification providers); and
- regulatory or governmental authorities.

This may include, without limitation, service providers such as SumSub, Fireblocks, BCB Group, exchanges, OTC counterparties, cloud infrastructure providers and other operational or compliance partners.

Cross-border data transfers. Client data may be transferred to and processed in jurisdictions outside Switzerland or the European Economic Area only where permitted under applicable data protection law and subject to appropriate safeguards where required, including contractual or other legally recognised transfer mechanisms.

Where required, Mainframe may rely on the Federal Council adequacy list, standard contractual clauses, contractual safeguards, statutory exemptions or other mechanisms recognised under Swiss data protection law.

Data retention. Mainframe retains KYC, KYB, AML, transaction and related compliance records for at least ten (10) years, or such longer period as required under applicable law.

Other data may be retained for as long as necessary for legal, regulatory, operational, evidentiary or legitimate business purposes.

System testing and security. Mainframe may use anonymised or pseudonymised data, and where necessary copies of data, for system testing, security monitoring and infrastructure resilience purposes.

Third-party data processing. Third-Party Providers process data under their own legal terms and privacy policies. Mainframe does not control and is not responsible for the processing of data by such Third-Party Providers.

Priority of regulatory disclosures. In the event of any conflict between data protection obligations and obligations under AML/CTF, sanctions or regulatory requirements, Mainframe’s obligations to comply with such regulatory requirements shall prevail to the extent permitted by applicable law.

SUSPENSION, RESTRICTIONS AND REGULATORY ACTIONS

Right to suspend or restrict access. Mainframe may, at its sole discretion and without prior notice, suspend, restrict or limit your access to the Platform where:
(a) your use of the Platform violates or may violate applicable law, including AML/CTF or sanctions requirements;
(b) continued provision of the Platform may expose Mainframe to legal, regulatory or reputational risk;
(c) you breach these Terms or any applicable policies;
(d) you fail to meet ongoing eligibility or compliance requirements;
(e) you become subject to insolvency, bankruptcy or similar proceedings; or
(f) it is necessary to ensure the security, integrity or proper functioning of the Platform.

Such measures may be applied immediately and without prior notice where deemed necessary by Mainframe.

Measures. In such cases, Mainframe may, without limitation:
- suspend your Account;
- restrict or block access to the Platform;
- delay, reject or refuse to transmit Instructions;
- restrict access to Third-Party Services;
- restrict, suspend or delay access to Client Assets, balances or transactions; and/or
- take any other action deemed necessary for compliance, security or risk management purposes.

Regulatory and compliance actions. Mainframe may take any action required or deemed appropriate to comply with applicable laws, regulations, sanctions regimes, regulatory requests or Third-Party Provider requirements, including freezing, holding or restricting access to Client Assets or Accounts.

Client notification. Where permitted, Mainframe may notify you of any suspension, restriction, freeze, block or termination.

Mainframe shall not be obliged to provide prior notice or reasons, particularly where such disclosure may conflict with legal, regulatory, law enforcement or internal risk management requirements.

Effect of suspension. During any period of suspension or restriction:
- access to the Platform may be limited or disabled;
- Instructions may not be accepted, transmitted or executed; and
- access to Client Assets or balances may be restricted, delayed or unavailable.

No liability. To the maximum extent permitted by applicable law, Mainframe shall not be liable for any Loss arising from any suspension, restriction, freeze, block, termination of access or related action taken in good faith.

Client obligation to notify. You shall promptly notify Mainframe if you become aware of any circumstances that may affect your eligibility, compliance or lawful use of the Platform.

INTELLECTUAL PROPERTY

Ownership. All intellectual property rights in and to the Platform, including its software, infrastructure, APIs, databases, design, content and all related materials (the IP), are owned by Mainframe or its licensors.

Nothing in these Terms shall operate to transfer any intellectual property rights to the Client.

Limited licence. Subject to compliance with these Terms, Mainframe grants you a limited, non-exclusive, non-transferable, non-sublicensable and revocable licence to access and use the Platform solely for its intended purpose.

This licence does not include any right to access underlying source code, algorithms, architecture or non-public interfaces of the Platform.

Restrictions. You shall not, without prior written consent of Mainframe:
- copy, reproduce, modify or create derivative works of the Platform;
- reverse engineer, decompile or attempt to extract source code;
- access or use the Platform in a manner that competes with or replicates the Platform or any of its functionalities;
- use the Platform for commercial exploitation beyond its intended use;
- scrape, extract or systematically collect data from the Platform;
- use automated tools, bots, crawlers or similar technologies without authorisation;
- interfere with, disrupt or attempt to gain unauthorised access to the Platform or its underlying systems; or
- infringe any intellectual property rights of Mainframe or any third party.

No transfer of rights. Nothing in these Terms shall be construed as transferring any intellectual property rights to you.

All rights not expressly granted are reserved by Mainframe.

Third-party intellectual property. The Platform may include intellectual property belonging to Third-Party Providers.

Such intellectual property is used under licence or integration arrangements and remains the property of the respective Third-Party Providers.

Your use of such intellectual property may be subject to the terms and conditions of the relevant Third-Party Providers.

Feedback. If you provide any feedback, suggestions or ideas relating to the Platform, you grant Mainframe a perpetual, irrevocable, worldwide, royalty-free, transferable and sublicensable right to use, modify and implement such feedback without restriction or compensation.

Data and usage rights. Mainframe may collect and use anonymised, aggregated or statistical data derived from the use of the Platform for analytics, performance improvement, security, compliance and business purposes.

Such data shall not identify the Client directly.

TERM AND TERMINATION

Term. These Terms shall commence upon your acceptance and remain in effect until terminated in accordance with this Clause.

Termination by the Client. You may request closure of your Account at any time through the Platform.

Mainframe may process such request within a reasonable period, subject to:
- completion of any pending obligations;
- settlement of any outstanding Fees; and
- compliance with applicable legal and regulatory requirements.

Termination by Mainframe. Mainframe may terminate these Terms and/or your access to the Platform at any time, with or without notice, including in accordance with Clause 16 or where continued provision of the Platform is no longer feasible for legal, regulatory, operational or risk management reasons.

Effect of termination. Upon termination:
- your access to the Platform will be disabled;
- Instructions may no longer be accepted or transmitted; and
- access to certain functionalities or services may be restricted or discontinued.

You remain solely responsible for managing any Client Assets, balances or positions held with Third-Party Providers.

Mainframe does not control or manage Client Assets and shall not be responsible for any actions required by the Client following termination.

Termination shall not affect any outstanding Fees, pending Instructions, regulatory holds, compliance reviews, reporting obligations or restrictions imposed by applicable law, Third-Party Providers or competent authorities.

Data retention. Notwithstanding termination, Mainframe may retain Client data to the extent required by applicable law, including AML/CTF obligations, and for legitimate business purposes.

Survival. Any provisions of these Terms which by their nature should survive termination shall remain in full force and effect, including, without limitation:
- limitation of liability;
- indemnity obligations;
- data protection and regulatory compliance; and
- any accrued rights or obligations.

No obligation to disclose reasons. Mainframe shall not be obliged to disclose the reasons for any suspension, restriction, freeze, block or termination where such disclosure would conflict with legal, regulatory, law enforcement or internal risk management requirements.

COMMUNICATIONS, SUPPORT, AND CONTACT

Electronic communications. You agree that Mainframe may communicate with you via electronic means, including email and through the Platform.

Such communications may include, without limitation, operational messages, regulatory notices, security alerts, updates to the Platform and amendments to these Terms.

Legal effect of communications. Any notice, communication or information provided by Mainframe via email or through the Platform shall be deemed received at the time it is sent, unless a delivery failure notice is received.

Electronic communications shall have the same legal effect as written communications.

Client contact details. You are responsible for maintaining accurate and up-to-date contact information, including your email address.

Mainframe shall not be responsible for any Loss arising from your failure to maintain accurate contact details.

Support and enquiries. If you have any questions, feedback or complaints, you may contact Mainframe using the contact details provided on the Platform.

Mainframe may, but is not obliged to, provide support services and does not guarantee response times or resolution of enquiries.

Contact information. Current contact details of Mainframe are made available on the Platform and may be updated from time to time.

Notices to Mainframe may be sent to: compliance@mainframe.finance, or such other contact details as may be communicated by Mainframe from time to time.

NO ADVICE AND TAX

No advice. No information, content or materials provided through the Platform constitute investment, financial, legal or tax advice, or a recommendation to buy, sell or transact in any Digital Asset or financial instrument.

Mainframe does not provide advisory, portfolio management or discretionary services.

Independent decisions. You are solely responsible for any decision to engage in transactions involving Digital Assets or Third-Party Services.

You acknowledge that you act on your own initiative and at your own risk and that you have sufficient knowledge and experience to assess such transactions or have obtained independent professional advice where necessary.

No reliance. You agree that you do not rely on any information provided by Mainframe as advice or as a basis for any investment or transaction decision.

Tax responsibility. You are solely responsible for determining, reporting and fulfilling any tax obligations arising from your use of the Platform or any Third-Party Services, including transactions, holdings, gains or losses.

Mainframe does not provide tax advice and makes no representation regarding the tax treatment of any transaction.

GENERAL PROVISIONS

Entire agreement. These Terms, together with any documents incorporated by reference (including the Annexes), constitute the entire agreement between you and Mainframe and supersede any prior agreements, understandings or representations.

Severability. If any provision of these Terms is found to be invalid, illegal or unenforceable, such provision shall be enforced to the maximum extent permissible and the remaining provisions shall remain in full force and effect.

Assignment. Mainframe may assign, transfer or otherwise dispose of its rights and obligations under these Terms, in whole or in part, at any time without restriction.

You may not assign, transfer or otherwise dispose of your rights or obligations without the prior written consent of Mainframe.

No waiver. Failure or delay by Mainframe to exercise any right, power or remedy shall not constitute a waiver of such right, power or remedy, nor shall any single or partial exercise prevent further exercise of that or any other right.

Amendments. Material changes will be notified by email, Platform notification or other appropriate means where required by applicable law or where Mainframe reasonably considers the change material.

Third-party rights. Except as expressly provided, no person other than the parties to these Terms shall have any right to enforce any provision of these Terms.

Language. These Terms may be made available in multiple languages. In the event of any inconsistency, the English version shall prevail.

GOVERNING LAW AND JURISDICTION

Governing law. These Terms and any non-contractual obligations arising out of or in connection with them shall be governed by the laws of Switzerland.

Jurisdiction. The courts of Zug, Switzerland shall have exclusive jurisdiction to resolve any disputes arising out of or in connection with these Terms. The place of performance shall be Zug, Switzerland, subject to mandatory consumer protection rules where applicable.

No class actions. To the extent permitted by applicable law and subject to mandatory applicable law, any claims shall be brought on an individual basis and not as part of any class or collective action.

Swiss-regulated institutional brokerage infrastructure for professionals managing digital asset capital. One account replaces fragmented vendor stack that institutional desks have historically assembled alone.

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© 2026 Mainframe Finance AG, Switzerland

Mainframe Finance AG (CHE-472.429.137) is a financial intermediary affiliated with VQF (membership number 101314), a self-regulatory organization recognized by FINMA under the Swiss Anti-Money Laundering Act (AMLA). Mainframe is not a bank under Swiss Banking Act and does not hold a banking license. Services described on this website are directed at professional and institutional clients within meaning of Swiss Financial Services Act (FinSA). Information presented does not constitute financial advice, investment recommendation or solicitation to enter into financial transactions. Digital assets are subject to significant price volatility and total loss of capital. Past performance does not indicate future results. Regulatory treatment of digital assets varies across jurisdictions and may change. Clients are responsible for assessing suitability of services against own circumstances and consulting independent legal, tax and financial advisors before engaging.

Swiss-regulated institutional brokerage infrastructure for professionals managing digital asset capital. One account replaces fragmented vendor stack that institutional desks have historically assembled alone.

Subscribe

English

© 2026 Mainframe Finance AG, Switzerland

Mainframe Finance AG (CHE-472.429.137) is a financial intermediary affiliated with VQF (membership number 101314), a self-regulatory organization recognized by FINMA under the Swiss Anti-Money Laundering Act (AMLA). Mainframe is not a bank under Swiss Banking Act and does not hold a banking license. Services described on this website are directed at professional and institutional clients within meaning of Swiss Financial Services Act (FinSA). Information presented does not constitute financial advice, investment recommendation or solicitation to enter into financial transactions. Digital assets are subject to significant price volatility and total loss of capital. Past performance does not indicate future results. Regulatory treatment of digital assets varies across jurisdictions and may change. Clients are responsible for assessing suitability of services against own circumstances and consulting independent legal, tax and financial advisors before engaging.

Swiss-regulated institutional brokerage infrastructure for professionals managing digital asset capital. One account replaces fragmented vendor stack that institutional desks have historically assembled alone.

Subscribe

English

© 2026 Mainframe Finance AG, Switzerland

Mainframe Finance AG (CHE-472.429.137) is a financial intermediary affiliated with VQF (membership number 101314), a self-regulatory organization recognized by FINMA under the Swiss Anti-Money Laundering Act (AMLA). Mainframe is not a bank under Swiss Banking Act and does not hold a banking license. Services described on this website are directed at professional and institutional clients within meaning of Swiss Financial Services Act (FinSA). Information presented does not constitute financial advice, investment recommendation or solicitation to enter into financial transactions. Digital assets are subject to significant price volatility and total loss of capital. Past performance does not indicate future results. Regulatory treatment of digital assets varies across jurisdictions and may change. Clients are responsible for assessing suitability of services against own circumstances and consulting independent legal, tax and financial advisors before engaging.

Swiss-regulated institutional brokerage infrastructure for professionals managing digital asset capital. One account replaces fragmented vendor stack that institutional desks have historically assembled alone.

Subscribe

English

© 2026 Mainframe Finance AG, Switzerland

Mainframe Finance AG (CHE-472.429.137) is a financial intermediary affiliated with VQF (membership number 101314), a self-regulatory organization recognized by FINMA under the Swiss Anti-Money Laundering Act (AMLA). Mainframe is not a bank under Swiss Banking Act and does not hold a banking license. Services described on this website are directed at professional and institutional clients within meaning of Swiss Financial Services Act (FinSA). Information presented does not constitute financial advice, investment recommendation or solicitation to enter into financial transactions. Digital assets are subject to significant price volatility and total loss of capital. Past performance does not indicate future results. Regulatory treatment of digital assets varies across jurisdictions and may change. Clients are responsible for assessing suitability of services against own circumstances and consulting independent legal, tax and financial advisors before engaging.