Terms of Service

1. Introduction

• Coinbox Ltd. (hereinafter: "the Company" or "Coinbox") is a broker for trading in virtual currencies, operating in Israel under an extended financial asset service licence from the Capital Market, Insurance and Savings Authority (licence no. 71398). Coinbox provides users with a trading platform for buying and selling virtual currencies, an integrated storage solution enabling users to store their digital assets, and further services relating to virtual currencies. Coinbox operates in accordance with the provisions of the law and the regulation applicable to it as a financial asset service provider in Israel.
• When you register to open an account you enter into a legally binding agreement with us. These terms govern your use of the Company's services and explain who we are, how we will provide the services to you, how these terms may be changed or terminated, what to do in the event of a problem, and other important information. You must read these terms, together with the documents referred to in them, carefully, and contact us if there is anything you do not understand.
• These terms refer to a number of additional documents that also apply to your use of the Company's services. These documents include:
• Our Privacy Policy and Cookie Policy, which set out the terms under which we process any personal information we collect about you, or that you provide to us. By using the Coinbox services you understand and consent to this processing, and undertake that all information you provide is accurate and up to date.
• Our Risk Disclosure, which sets out important information on possible risks when buying, selling, holding or investing in virtual currencies.
• The fee schedule on our website.
• Our Accessibility Statement sets out our commitment to making the Company's website and services accessible to people with disabilities. This document explains the technological and organisational adjustments made in order to ensure equal, convenient and independent browsing and use for all users.
• The Cancellation Policy. A purchase or sale of digital assets that has been executed is final and irreversible from the time it is carried out, because its price is derived from market rates that change in real time. The cancellation rights under consumer protection law, the exceptions, and the manner of submitting a cancellation and refund request are set out in full in the Cancellation Policy, which forms an integral part of this agreement.
• "Digital asset" or "virtual asset" or "digital currency" means any digital asset (including a virtual currency or commodity) that constitutes a digital representation of value based on a cryptographic protocol of a computer network". A supported digital currency is only those assets listed as available for trading or custody on the Company's trading platform.

2. Information Regarding a Coinbox Account

Eligibility to Open an Account

To be eligible to register for an account and use the Company's services, you must meet the following conditions:

• Be an individual, a corporation, a legal entity, a body or another organisation having full authority, capacity and ability (1) to access and use the Company's services; and (2) to agree to these terms and to comply with them.
• If you are an individual, you must be at least 18 years old.
• If you are acting as an employee or representative of a legal entity and signing these terms on its behalf, you must be duly authorised to act on its behalf and to bind it for the purpose of entering into these terms.
• You are not located in, registered in, resident in, or (to the extent applicable) a citizen of, or acting within, a jurisdiction in which the use of or access to the Company's services is unlawful under applicable law, or that could cause us or any third party to breach applicable law.

Opening an Account

• You must create a user account in order to obtain access to the Coinbox services and the platform. An account may be opened as a private user, or as a corporate account where the user is a corporation, entity or other organisation.
• To create an account you must register on the Company's website by providing personal details, including but not limited to your full name, email address and password, completing certain verification procedures, and accepting the terms of this agreement. By using the account you agree and declare that you will use the relevant services only for yourself, and not on behalf of any third party. Each customer may register for only one Coinbox account. You are fully responsible for all activity occurring under your account. We may, at our sole discretion, refuse to open an account for you, or suspend or terminate any account (including duplicate accounts), or suspend or terminate trading in certain digital assets in your account or the sending of digital assets from it.

Identity Verification

• You will be required to pass our identity verification procedures before you are permitted to open an account and obtain access to the Coinbox services, whether independently or through a third-party service, by providing certain information about yourself and about every relevant Authorised User. Any information you provide must be complete, accurate and true. You must update the information when it changes. If you notify us that you have changed your country of residence and/or acquired an additional citizenship and provide appropriate documents for this, you agree to be subject to the local terms applicable to you, and you must notify us.
• The Company will carry out identification and verification procedures in respect of the customer's details. This procedure may be carried out online (through an identification services provider) and/or manually. The user consents to the online identification procedure, which includes, among other things, a visual interaction, the uploading of identification documents (such as an identity card or passport) and a photograph of the face (including by video) using advanced verification technologies.
• You authorise us to carry out checks, whether directly or through third parties, that we consider necessary for the purpose of verifying your identity and/or the identity of the Authorised Users, or for the purpose of protecting you and/or us against fraud, money laundering, terrorist financing or other financial crime, and to take any action we see fit in accordance with the results of the checks.
• In carrying out the checks, you acknowledge and understand that your personal information and that of the Authorised Users may be disclosed to identity verification bodies, compliance data registration bodies, fraud prevention bodies or financial crime bodies, and that those bodies may respond to our requests in full. This information may include, among other things: full name, email address, telephone number, identity card number, date of birth, gender, residential address, a copy of an identity card/passport or any other official identifying document, information about your bank account, declarations as to source of funds and source of wealth, the purpose of opening the account and the activity planned in it, and any further information required by the Company for the purpose of meeting regulatory requirements, including the Prohibition on Money Laundering Law, 5760-2000 and the orders made under it.
• We retain your personal information in order to enable your continued use of the Company's services, for as long as this is required for the purpose of realising the relevant purposes described in our Privacy Notice, and as required by law, including for tax and accounting purposes, meeting anti-money laundering requirements, or as notified to you. Please review our Privacy Notice for further information on the collection and use of your personal information in connection with the use and performance of the website and the services.
• Enhanced due diligence: We may require you to undergo an enhanced due diligence process by providing further information about yourself, your business or your Authorised Users, providing further documents, or holding face-to-face meetings with the Company's representatives.
• The Company applies a "Know Your Customer" policy. The scope of the information and documents required may vary according to the customer's risk level, the scope of the activity requested and regulatory requirements. Failure to meet these requirements will entitle the Company to refuse to open an account, to restrict the services or to close an existing account, and the user shall have no claim in this regard.
• By accessing or using the services, you create a personal user account with Coinbox. You declare and undertake that you will not do the following:
• Create an account under a false identity or with false, misleading or inaccurate details, or in the name of another person or entity, or as a trustee or representative for another person or entity without appropriate authorisation.
• Hold an account or use the services if you are prohibited from doing so under any law, regulation, the terms of this agreement or by a decision of Coinbox.
• Use the account or the services to engage in any unlawful activity, including money laundering, terrorist financing, fraud or any other activity prohibited under the laws of the State of Israel or any other relevant law. The Company prohibits the use of its services for the payment of ransom.

3. Deposits and Withdrawals

Deposit by Bank Transfer or Credit Card

You may deposit funds into your account by bank transfer from an account registered in your name or by a credit card registered in your name. Such a deposit may be subject to minimum and/or maximum limits and to further restrictive conditions, at the Company's sole discretion, including regulatory considerations, prevention of money laundering and terrorist financing, and risk management. It is clarified that funds deposited or held on the platform do not bear interest or any other return, unless expressly stated otherwise by the Company. For the deposit or holding of funds, you may be required to pay external clearing company fees in addition to fees determined by the Company, as published on the platform. These fees may change, subject to prior notice as far as possible. Where funds are deposited into the user's account by credit card, activity in those funds and in the digital assets purchased with them will be restricted to trading within the Company's platform only (a "closed garden"). The customer may not withdraw digital assets (cryptocurrencies) purchased in this manner to an external digital wallet. The assets may be realised solely by selling them within the platform and withdrawing the proceeds in fiat funds, subject to all the withdrawal restrictions set out in this agreement.

In the event that a transaction is denied, a transaction-enquiry process is opened with the issuer of the payment method, or a chargeback of any kind is made by the user or the credit card company, the Company may, without prior warning or notice, take any or all of the following actions at its sole discretion: (a) immediately freeze all activity, permissions and balances in the user's account; (b) realise and sell some or all of the digital assets held in the user's account at their market value at the time of realisation, without any obligation to wait for market fluctuations or an increase in value; and (c) set off the sale proceeds against the chargeback amount and against any fee, clearing penalty, legal expense and collection expense incurred by the Company, directly or indirectly, as a result of the denied transaction. The user hereby irrevocably and absolutely waives any claim, demand or action in respect of a loss of value caused by the realisation and set-off of the assets at the time selected by the Company.

Deposit of a Digital Asset from a Private Wallet or from an External Platform

You may deposit supported digital assets into your account on the Coinbox platform. The deposit may be made from a private digital wallet owned by you and under your sole control, or by a transfer from an account or wallet managed on a regulated external platform (such as a crypto exchange) registered in your name. It is clarified that such a transfer from an external platform will be permitted solely from a closed list of exchanges, platforms and authorised bodies that will be published on the Company's website and updated from time to time, in accordance with and subject to the Company's sole discretion. A deposit from any wallet, account or platform that is not under your direct control or in your sole ownership (including one originating from a third party, or from a body not included in the Company's approved list as stated above) requires the express prior written approval of the Company, and is subject to further checks and to the provision of supporting documentation as required. Wallet addresses will be provided by the Company only and on the Company's website only. The deposit is subject to security and compliance checks, including Know Your Transaction checks, source-of-assets checks and internal verification procedures of the Company and of the custody provider. In order to deposit digital assets into your account on the platform, you must send the assets solely to the dedicated blockchain address displayed to you on the platform for the specific type of asset you wish to deposit. The Company will not credit your account, and will bear no liability whatsoever, in the event of a transfer of digital assets that are not supported by the platform, a transfer via a blockchain network that is not supported, or a transfer to an address other than the one provided by the Company. In these cases, the assets may be irreversibly lost. A certain amount of time may be required until final confirmation of the transfer of the digital assets on the relevant blockchain network (for example, a number of confirmations required) before they are credited to your Coinbox account. Coinbox carries out analysis and risk assessment of transactions and wallets involved in transfers of digital assets. Completion of the transaction may be delayed until these checks are concluded.

Return of Funds/Assets

Where identification is not completed: if the user deposited funds or digital assets before the identification and verification procedure was fully completed to the Company's satisfaction, and the Company decides not to approve the account or the operation, the Company may return those funds or digital assets to their source, less any loss, fee or expense incurred by the Company as a result of the non-performance of the services or of transferring them back. Where the digital wallet from which the transfer is made is classified as high risk: if the user deposited digital assets from a wallet classified as high risk, or in a case in which the path of the coins involved unlawful activity or activity classified at a high risk level for money laundering or terrorist financing, the Company may return those funds or digital assets to their source, less any loss, fee or expense incurred by the Company as a result of the non-performance of the services or of transferring them back.

Withdrawals

Before carrying out a withdrawal operation, you may be required to provide further details and documents relating to your activity in the account, to the source of the funds, or to the destination of the withdrawal, for the purpose of meeting regulatory requirements and the Company's risk management policy. It is clarified that the withdrawal will not be completed until all the information and documents required have been provided to the Company's satisfaction and approved.

Withdrawal of Funds Deposited by Credit Card

• It is hereby clarified and agreed that where funds were deposited into the user's account by credit card, the withdrawal of funds (or their equivalent) from the account back to the customer shall, as a rule, be limited to the amount of the original deposit actually made using that card. The customer declares that they are aware that this action derives from legal requirements, the clearing providers' procedures and the Company's risk-management policy. A withdrawal exceeding the original deposit amount, including a withdrawal of trading profits or other credit balances, shall be made solely by bank transfer to a verified bank account registered in the user's name, subject to due-diligence checks and anti-money-laundering standards.

Withdrawal by Bank Transfer

• A withdrawal of fiat funds from your account will be carried out only by submitting a duly made withdrawal request through the platform, and only provided that there is a sufficient credit balance in your account and that the request meets the platform's requirements and the provisions of the law.
• You may be required to pay fees for the withdrawal of funds. The amount of the fees will be published on the platform and may change, subject to prior notice as far as possible.
• The withdrawal operation is subject to the completion of processes by third parties, such as banks. Accordingly, the withdrawal will not be considered final until final approval by those parties and the actual transfer of the funds. Subject to that, the Company will act to complete the operation within a reasonable time, usually up to three business days from its approval of the withdrawal request. The Company gives no undertaking that the third parties will approve the completion of the withdrawal or process it within the expected timeframes. For as long as the bank or the payment party has not processed the withdrawal request, the funds will remain as a credit balance in your account on the platform. The Company will not be liable for a refusal by a bank or a payment party to carry out a transfer or for delays caused by them.
• Receipt of funds at the destination bank and anti-money laundering policy. You acknowledge and understand that the withdrawal of fiat funds from your account to your bank account is subject exclusively to the risk management and anti-money laundering policy of the receiving bank. In cases in which the source of the funds is in digital assets deposited to the platform from external sources (such as foreign exchanges, or private wallets), the bank may apply stricter scrutiny or refuse to receive the funds. Coinbox will make available to you, as far as possible, supporting documents (such as tax reports and network scans, KYT), but bears no liability for a refusal, delay or return of funds by the bank. Any damage, loss or cost caused by the bank's refusal to receive the withdrawn funds shall be borne by you alone.

Withdrawal of a Digital Asset from the Platform

• You may withdraw digital assets to an external digital wallet address that you provide, which must be owned by you and under your sole control. A withdrawal of supported digital assets from your account on the platform will be carried out only by submitting a duly made withdrawal request through the platform, and only if there is a sufficient credit balance of the relevant asset in your account and the request meets the platform's requirements and the provisions of the law.
• It is your full responsibility to ensure that the wallet details you provided are correct and accurate, and that the wallet is suitable for the type of digital asset purchased (for example, a Bitcoin wallet for Bitcoin). Coinbox will bear no liability whatsoever for a transfer of assets to an incorrect or unsuitable wallet address provided by you.
• You may be required to pay fees for the withdrawal of funds, including a blockchain network fee. The amount of the fees will be published on the platform and may change, subject to prior notice as far as possible.
• You may be required to provide further information about the destination of the withdrawal (for example, the wallet holder's details, the purpose of the transfer) or to undergo further verifications, in accordance with the Company's risk management and compliance policy, and with the requirements of the Travel Rule.
• The Company gives no undertaking that the blockchain networks will operate properly or will confirm transactions within the expected timeframe, or that third-party service providers will approve the operations fully and successfully. The Company is not responsible for delays or failures in the blockchain network.
• Where a digital asset is purchased by credit card, activity in that asset will be restricted to trading within the Company's platform only.

4. Holding Funds and Assets in Dedicated Accounts

• The Company declares and undertakes that all fiat funds (shekels and dollars) and digital assets deposited and/or held by it in the user's account will be held by it in trust in dedicated accounts for the customers alone.
• These funds and assets are not the Company's assets and do not form part of its balance sheet, but will be recorded in its books as assets that are absolutely and separately segregated from the Company's own assets ("nostro assets") and for the benefit of the customers alone.
• Fiat funds will be deposited and held solely in separate dedicated accounts opened by the Company at commercial banks in Israel, in accordance with the provisions of the law.
• The virtual assets will be held in omnibus wallets segregated from the Company's assets, while maintaining a rights ledger that ensures full record segregation and grants the customer precise proprietary rights in his assets.
• The customers' digital assets are held in secure custody. The Company uses the services of Fireblocks LTD and Payward Financial, Inc., leading companies in institutional custody technology. Customer assets are held in dedicated custody accounts for the benefit of the customers, completely segregated from the Company's assets.

5. How We Will Contact Each Other

How You Can Contact Us

For further information about Coinbox, you may review the information appearing on our website. If you have questions, comments or complaints, you may contact us through our customer service team at: support@coinbox.co.il.

How We Will Contact You

We will contact you using the contact details you provided to us. This may include contact by email, text message (SMS) or telephone. It is important that you ensure that your contact details are correct and up to date. If your contact details change, you must update us immediately. If you do not do so, we will not be responsible if you do not receive information, notices or other important details from us.

6. Fees

• You agree to pay all the fees applicable in connection with your use of the Coinbox services, as set out on the fee schedule page on our website.
• The user acknowledges and agrees that financial activity by credit card on the platform is ordinary clearing activity involving costs and fees charged by external clearing providers, credit card companies and/or banking corporations. The user shall bear those fees in full, as determined from time to time by the clearing providers and/or as shown to the user in advance in the Company's fee schedule when the operation is carried out. Those fees may be charged and deducted from the deposit or withdrawal amount itself, and apply in addition to and independently of the ordinary activity fees, management fees or trading fees charged by the Company.
• We may update our fees from time to time in accordance with Section 14.3 of these terms.
• Any calculation carried out by Coinbox in connection with the Company's services is final and binding on you, unless it involves a manifest and material error. The calculations will be made in accordance with the calculation method declared for the relevant service, at our good-faith discretion.
• The Company may operate from time to time a "trading tiers" programme granting benefits or reduced service fees according to the scope of the user's activity (such as trading volume in the last 30 days). It is hereby clarified that the Company reserves the full and sole right to determine, change, update, freeze or cancel the trading tiers programme at any time. This right includes, among other things, the power to change the volume thresholds required for each tier, the names of the tiers and the rate of the fees or the benefits derived from each tier, all at its sole discretion and without any need to give advance notice beyond publication on the fee schedule page or in the platform interface. Any change to the trading tier structure will apply immediately, including to trading volumes already accrued by the user prior to the change. It is your sole responsibility to keep informed of the tier and fee structure in force before carrying out any trading operation. Your continued use of the Company's services after an update to the tiers will constitute your full consent to the updated terms, and you shall have no claim in respect of a worsening of terms, loss of status or any loss arising from these changes.

7. Access to Your Coinbox Account

Access

In order to access your Coinbox account, you must, or, where relevant, your Authorised Users must, hold the required equipment (such as a computer or smartphone) and access to the internet. Your Coinbox account may be accessed directly through the platform or by other means of access (including API interfaces) as determined by us. You are permitted to access your Coinbox account only using the Access IDs that we provide to you or to your Authorised Users for these purposes. We may require Multi-Factor Authentication in order to protect your Coinbox account and keep it secure.

Restricting Access by Third Parties

You must ensure that any Coinbox account registered in your name is not used by any person other than you, or, in the case of corporate Coinbox accounts, other than your Authorised Users, in accordance with these terms only.

8. Account and Transaction Information

Your Account History

You may access your account history through the platform. You must review your account history carefully and notify us if you see entries or transactions that you do not recognise or that you believe are incorrect, within fourteen (14) calendar days from the date your account history was delivered or made available.

Errors

We may correct any error in your account history at any time, and we reserve the right to cancel, delete or reverse any transaction that involves or arises from a manifest and material error, or to correct the transaction details so that they reflect what we consider to be the correct or fair details of that transaction. You acknowledge and agree that in the event that you carried out a transaction with improper intent and/or in the event of a manifest and material error, you grant Coinbox authorisation (without any payment, penalty or liability on the part of Coinbox, provided that the action is taken in accordance with applicable law), to carry out one of the following actions:

• Cancel/delete the transaction and treat it as if it had never taken place at all; or
• Correct the price(s) of that transaction (after notice of this is given by Coinbox to you), so that they reflect the current market price at the relevant time, as determined by Coinbox on the basis of an available source for fair market pricing; If Coinbox cancels a transaction in accordance with the rights set out above, it will reverse any transfer of digital assets to or from your Coinbox account that was carried out in connection with that transaction, as if the transaction had never taken place at all. You acknowledge and agree that you bear sole responsibility for your transactions with third parties, to the extent that those engagements arose from or relied on transactions that may be subject to cancellation or correction in accordance with Coinbox's rights under this section.

The Company's Records as Conclusive Evidence

Without derogating from anything stated anywhere else in this agreement, you acknowledge and agree that Coinbox's internal records, as kept and maintained on the Company's servers and in its databases (including the Company's books and internal Ledgers), shall constitute the conclusive, final and exclusive evidence in all matters relating to the state of your account, including but not limited to: balances of digital assets and fiat currencies, the status of transactions, open orders, deposits and withdrawals. In the event of a contradiction or discrepancy between the information displayed to you in the user interface (including in the application or on the website) or any screenshot or other documentation on your part, and the Company's internal records, the Company's internal records are those that shall determine and bind for all intents and purposes. The Company will bear no liability for any damage, loss or claim arising from reliance on an incorrect display, a delay in updating the user interface, a cyberattack or a bug in the system.

Information Sharing

In accordance with these terms or with applicable law, we may be required to share information about your Coinbox account and account history with third parties and with companies affiliated with Coinbox. You acknowledge and agree that we may disclose this information. You may review our Privacy Notice for further information on the manner in which we process your personal information.

9. Use of Your Account

Buy and Sell Orders

Entering a Market Order to Buy or Sell

You must ensure that every buy or sell order you enter is complete and accurate. We are not obliged to verify the accuracy, authenticity or validity of any order, and we will not carry out controls or reject orders on the basis of their being duplicates or appearing to be duplicates. However, if we have any doubt as to the accuracy, authenticity or validity of an order, we may refuse to act on it, reject its execution or request further information about it. Market orders cannot be cancelled, and therefore once a market order has been sent, you or your Authorised Users may not cancel it or withdraw it, unless you have received our written consent to do so. A market order will be considered received by us only when it has been received on our servers. Our record of all orders (including a market order) shall be considered final and binding on you for all intents and purposes.

Execution of Buy or Sell Orders

Upon sending a market order (buy or sell), you or your Authorised Users authorise us to begin executing the transaction in your Coinbox account. Accordingly, we are authorised to credit or debit (or to provide information for clearing purposes to third parties so that they carry out the credit or debit) your digital assets from the Coinbox account in accordance with your order. If you do not have sufficient digital assets or fiat currency in your Coinbox account to carry out the transaction (that is, less than the amount required to close the transaction and pay all the accompanying fees), we may refuse to carry out the transaction. Coinbox may also refuse to act on orders, to the extent permitted under these terms. It is your responsibility to ensure that you have sufficient digital assets or fiat currencies in your account balance.

Orders Pending Execution (such as a Limit Order)

When you enter an order pending future execution (such as a limit transaction), it is your responsibility to ensure that a sufficient balance is maintained in your account for its execution until the time it is actually completed. Should you, after entering the order, carry out other operations in your account (such as currency conversion, withdrawal of funds or the execution of further transactions) that reduce the relevant balance below the amount and quantity required to execute the pending order, the system will cancel the pending order automatically. This is intended to prevent a situation of insufficient cover or the creation of a negative balance in your account.

• The buy and sell rates of the digital assets change frequently and are determined on the basis of the prices received from the Company's liquidity providers in real time. The final price displayed to the user includes the Company's fee.

Price Lock Mechanism

The Company may enable the user, within certain trading operations, to use a "price lock" feature, which makes it possible to fix the buy or sell rate of a digital asset for a limited and predefined time window (hereinafter: the "lock window", such as 10 seconds), independently of the ongoing fluctuations of the market price during that time window. In consideration for the rate-fixing service and the risk involved in market fluctuations, the Company will charge a dedicated fee (as published on the fees page on the website), which will be included in the lock rate displayed to the user or added to the cost of the transaction. It is clarified that the lock rate is valid solely for the duration of the lock window and subject to the records of the Company's servers only. To the extent that the user has not completed the confirmation of the execution of the transaction actively and fully within the lock window, the rate will expire automatically, will be updated in accordance with the market prices current at that time, and will be locked again for a further lock window, and so on. It is the user's sole responsibility to ensure that he completes the confirmation of the operation in good time and within the lock window.

• Without derogating from any other limitation of liability in this agreement, the Company shall not under any circumstances bear any liability whatsoever (and the user waives finally and absolutely any claim or right of action in this regard) for any indirect or consequential damage or "notional loss". This includes that the Company shall not be liable for any claim regarding potential profits missed, loss of a trading opportunity, or the prevention of a loss, arising from a delay in execution, a gap in rates, or the non-execution of a trading order as a result of a technological failure, malfunction, bug, system shutdown or network load, even if the user proves that had the order been executed at its due time or at a particular rate he would have derived a monetary profit from it.
• Purchase of a digital asset denominated in a currency other than the account currency and conversion of dollars to shekels or shekels to dollars. When purchasing a digital asset, if the balances in your account are denominated in a currency other than the currency in which the digital asset is denominated, the Company will convert the transaction amount from the balance in your account into the currency in which the digital asset is denominated in accordance with the continuous rate plus a spread. The user may also carry out a conversion of dollars to shekels or shekels to dollars directly in his account, and in this case too the Company will convert the requested amount from the balance in your account in accordance with the continuous rate plus a spread. The user hereby understands and agrees that the Company shall be entitled to change, update and widen the conversion spreads applied to these conversions at any time, and without prior notice, and he shall have no claim against the Company, in the following cases:
• On days or at hours on which the commercial banks and the local and international foreign exchange markets are closed.
• In the event of the occurrence of exceptional macroeconomic events, security events (including war), geopolitical crises or natural disasters, in particular if these occur at weekends or at times when there is no continuous trading in foreign exchange.

Trading Rules

By accessing the trading platform, you agree to the trading rules set out below

Transactions

Execution of Transactions

The transactions you carry out are brokered by Coinbox. We do not undertake or represent that any transaction will be completed successfully or within a particular period of time.

Unauthorised Transactions

You are responsible for the control and use of your Coinbox account. Therefore, we assume that you or an Authorised User gave every order sent from your Coinbox account, unless we are notified otherwise. It is important to monitor your account history in order to identify unauthorised or suspicious activity and to report it to us as soon as possible. We are not responsible for any claim or damage caused as a result of a transaction carried out following an unauthorised order, unless you reported it to us in accordance with this section, and it is clearly determined in an internal investigation by us that neither you nor an Authorised User gave the order, not even by mistake, negligently, in error or as a result of fraud, and it is also proved that the unauthorised order arose solely from a system failure that is the responsibility of Coinbox.

Retention of Transaction Information

For the purpose of complying with international industry standards for information retention, you agree to permit us (but not to require us) to retain a record of all transaction details throughout the life of your Coinbox account, for as long as this is required for the purposes for which they were collected, or for another period as required under applicable law. Please review our Privacy Policy for further information on the manner of collection and use of information in connection with the use and performance of our website and of the Coinbox services.

Limits on Transactions

Your Coinbox account may be subject to limits regarding:

• The quantity or volume of transactions you are permitted to carry out in connection with your Coinbox account; and/or
• The amount or value of fiat currency or digital assets you are permitted to transfer to or from your Coinbox account. In each case, during a particular period (for example, daily). Any applicable limit will be displayed within your Coinbox account.
• We reserve the right to change at any time, at our sole discretion, any transaction limit applicable to your Coinbox account. You may also be able to request a change to your limits. Any such change will be made at our sole discretion, and will be subject to further conditions that we see fit to apply.

Baskets Programme

• The Company offers a baskets programme that provides convenient access to the purchase of a predefined group of digital currencies (such as the "Big Five basket"). It is hereby expressly clarified that making these baskets available does not constitute, in any form or manner, the provision of investment advice, investment marketing or investment portfolio management, as defined in the Regulation of Investment Advice, Investment Marketing and Investment Portfolio Management Law, 5755-1995. Likewise, the baskets do not constitute a mutual fund or a joint investment, and are not subject to the Joint Investment Trusts Law, 5754-1994. Every operation carried out within the baskets is carried out at the sole and independent discretion of the user.
• The Company reserves the right to update, change, add or remove digital assets from any basket, from time to time, in accordance with parameters determined by it and at its sole discretion. These updates will be reflected in the platform interface, and it is the user's sole responsibility to follow the composition of the basket and its terms before carrying out any operation.
• Any update, change, personal customisation (including the manual addition or removal of assets by the user) or purchase and sale operation of a basket will be carried out solely subject to express instructions and active confirmation by the user through the platform interface and at his sole responsibility.
• It is clarified that the Company does not manage the basket actively on behalf of the user, and does not carry out rebalancing operations or automatic sale and purchase of assets existing in the account following a change in the composition of any basket, unless the user has expressly instructed this. A user's choice to update an existing basket to the composition of a new basket will apply the terms of the new basket solely to future purchases carried out from the date of confirmation onwards.
• A purchase or sale operation of a basket (including closing a basket) constitutes an irrevocable order by the user to carry out actual purchase or sale transactions in the collection of digital assets associated with that basket at that time. These transactions will be executed and priced in accordance with the relevant market prices, and will be subject to the full trading terms, the provisions of this agreement and the Company's regular fee schedule applicable to standalone transactions in digital assets. The Company shall bear no liability for any damage, loss, tax liability or loss of profit arising from changes in the composition of the baskets, from the user's trading decisions or from the manner of operation of the feature on the platform.

Recurring Purchase and Regular Investment

• The Company enables the user to set automatic and recurring orders for the purchase of individual digital assets or asset baskets (hereinafter in this section: the "requested assets"), in predetermined amounts and at predetermined times (hereinafter: "recurring purchase"). It is hereby clarified that the recurring purchase feature constitutes an operational and automatic tool only, activated at the user's request and in accordance with his settings, and it does not involve the provision of investment advice, investment marketing, investment portfolio management or a recommendation as to the merits of any investment.
• Every purchase transaction within a recurring purchase programme will be executed and priced in accordance with the market prices and the commercial terms available to the Company from its liquidity providers at the time of the actual execution of that purchase transaction, and not at the time the order was set by the user. Every recurring purchase transaction will be subject to the Company's regular fee schedule as it may be from time to time. Where the recurring purchase is set for a "basket", the purchase will be carried out in accordance with the composition of the basket in force and approved by the user at that time.
• It is the user's sole responsibility to ensure that at the scheduled time of execution of the recurring purchase there is in his account a liquid and sufficient credit balance (in fiat currency or in the required digital asset) to cover the full amount of the purchase set and all the fees accompanying it. To the extent that at the scheduled time of execution the balance in the account is insufficient, the Company will not carry out the purchase (in whole or in part), and the specific purchase cycle will be skipped or cancelled automatically, without the Company being required to send notice of this to the user. It is clarified that the Company does not grant credit or permit debit balances for the purpose of carrying out these purchases. The Company shall bear no liability for any damage, loss, tax liability or loss of potential profit caused to the user or to a third party as a result of the non-execution of the purchase by reason of insufficient balance.
• Notwithstanding Section 9.5.3 above, the user may set the recurring-purchase and regular-investment operation to be funded by a direct and continuing charge to the credit card linked to the user's account, without first loading a fiat balance into the account. The user's configuration and approval of this operation in the interface constitute an irrevocable authorisation to the Company, or to a clearing and payment-services provider acting on its behalf, to retain the payment-method details and charge the credit card periodically on the dates and in the amounts set and defined by the user. The user declares that they bear sole responsibility for the validity of the credit card to be charged and for the availability of a sufficient credit limit on the charging dates. It is hereby clarified that if the card charge is declined or refused for any reason by the clearing provider, card issuer or card networks, or if the clearing services are suspended for any operational reason, the purchase operation will not be carried out in that cycle. The user shall have no claim, action and/or demand against the Company for the failure to carry out the purchase, including for a loss of potential profits or indirect damage. It is also clarified that purchases made directly by credit card shall be fully subject to the provisions of this agreement restricting the transfer of the assets to the "closed garden" only.
• The user may stop, freeze, cancel or change the recurring purchase settings at any time through the platform interface, without any cost or penalty for the cancellation itself. In order for a cancellation, freeze or change to affect an upcoming purchase cycle, the user must carry out the operation in the platform interface before 10:00 on that date of the recurring purchase. Change or cancellation requests made after that time will apply solely from the following purchase cycle onwards, and the user waives any claim in connection with a charge duly made because a request was submitted late.
• The Company shall be entitled, at its sole and reasonable discretion, not to carry out a recurring purchase in cases in which the requested asset has been suspended from trading, removed from the platform, or in cases of technical malfunctions, system shutdown for maintenance purposes, exceptional load on the communications or blockchain networks, or an event of force majeure. The user agrees that in these cases he shall have no claim, demand or action against the Company for the non-execution of the purchase at its due time or at all.

10. Material Interests and Conflicts of Interest

The Nature of Our Duties

The user understands and agrees that Coinbox acts as a broker and as an operator of a trading platform in digital assets only. The provision of the services by the Company, and the relationship between the user and the Company, do not confer on the Company, its directors or its employees any fiduciary duties, duties of trust or moral duties towards the user, other than the service duties and undertakings expressly set out and required by law in this agreement. The user is aware of and agrees that the Company acts as an intermediary and provides services to a large number of users in parallel, and also cooperates with external providers (such as crypto exchanges and liquidity providers). Within this framework, the Company may charge fees, spreads or various payments from more than one side of a transaction, or receive commercial terms from its providers, and the user hereby gives his full consent to the Company's activity and to its business model as stated.

Affiliate Programmes, Promotions and Referral Rewards

The Company may operate from time to time affiliate programmes, promotions or "refer a friend" programmes (hereinafter: the "referral programme"), under which a user who referred a new user to the platform (hereinafter: the "referring user") may be entitled to a reward, including a reward calculated as a certain percentage of the trading fees paid by the referred user to the Company. By registering on the platform and using the services, you acknowledge and agree that: (a) you are aware of and agree that a third party (the referring user who brought you to the platform, if any) may receive from the Company a monetary or other reward based on your trading fees or activity on the platform; (b) this reward is paid by the Company out of its regular revenues and fees, and it does not derogate from your rights, does not worsen your trading terms and does not increase the amount of the fees set for you; (c) the distribution of this reward does not constitute a conflict of interest on the part of the Company or a breach of a duty of confidentiality or privacy towards you, and you waive absolutely and irrevocably any claim, demand or action against the Company or against the referring user in this regard, including claims regarding infringement of privacy, unjust enrichment or a duty of disclosure.

• Material interests. The user understands and agrees that the Company or anyone on its behalf shall not be obliged: (a) to take into account information in their possession that is of material interest to the Company or to its independent commercial activity; (b) to disclose such information to the user; or (c) to use such information for the user's benefit. In addition, the user acknowledges that from time to time the Company may receive, collect or analyse general information about the market, trading trends and activity volumes in the course of providing the services, and it may use this aggregate and general information in the ordinary course of its business.

11. Supported Digital Assets

Supported Digital Assets

The Coinbox services are available only in respect of supported digital assets, and the list of these may change from time to time. The list of supported digital assets is published on our website. We may remove or suspend digital assets from the list of supported assets, and we will make reasonable commercial efforts to notify you of this in advance. In such a case, you will no longer be able to access the digital assets within the Coinbox services, and you will only be able to withdraw them from your Coinbox account. If digital assets that are not supported remain in your account beyond a period of time notified to you, Coinbox may at its reasonable discretion convert these assets into another type of digital asset that is a stablecoin. Coinbox will notify you in advance of any such conversion, and will enable you to withdraw the digital assets before the conversion, within a reasonable period of time notified to you. We bear no liability whatsoever for an attempt to use a Coinbox account for digital assets that are not supported, or for a conversion to another type of digital asset as described in this section. In addition, we bear no liability or obligation whatsoever in connection with unsupported digital assets sent to a Coinbox account, or supported assets sent to an incompatible wallet address. If you send unsupported digital assets to a Coinbox account, or supported assets to an incompatible wallet address, you will lose those assets. For lost assets, Coinbox may, at its sole discretion, offer to attempt to recover them for you. We may charge fees for a recovery attempt on your behalf, and the fees will be determined at our discretion and made known to you before the recovery attempt is approved. Coinbox does not undertake to recover any amount, and the amount actually recovered may differ from the estimate. Coinbox does not assess and does not guarantee the authenticity, safety or security of unsupported digital assets. You acknowledge and agree that Coinbox is not responsible for any loss caused during the recovery attempt or from the subsequent use of the recovered digital asset.

• For the avoidance of doubt, the mere making available, listing or availability of certain digital assets for trading or custody on the platform does not constitute, and shall in no way be considered, a representation, endorsement, support, expression of opinion or recommendation on the part of the Company regarding the quality, robustness, reliability, economic merit or technological stability of those assets or of the projects and issuers behind them. The user understands and acknowledges that digital assets are exposed to the risk of a full, absolute and rapid loss of value (up to zero value), among other things as a result of market failures, the collapse of projects, technological failures or a lack of liquidity. The sole and full responsibility to carry out independent research and due diligence regarding each digital asset before carrying out any operation in it rests on the user alone, and he waives absolutely any claim that he relied on the Company by reason of the mere availability of the asset for trading.

Forks

We may temporarily suspend Coinbox services in respect of a particular digital asset while we examine whether to support a fork. We are not obliged to support a fork of a digital asset that you hold, even if the version created as a result of the fork is considered the dominant digital asset. If we decide to support a fork, we will publish a public notice of this on our website or by another means of communication that we see fit. You acknowledge that we have no control over or ability to influence the creation or implementation of a fork. We cannot guarantee anything regarding the security, functioning or availability of any digital asset, whether it is the new dominant asset or the original asset. You may not be able to trade the forked assets through the platform, and you may suffer a loss of value in connection with the relevant digital assets.

Airdrops

Coinbox does not guarantee anything regarding the outcome of, or its support for, potential or proposed forks, forked assets or airdrops. Coinbox may, at its sole discretion, decide whether to claim, register or distribute an airdrop or a forked digital asset or any other asset, and also to determine the conditions (including eligibility criteria) that will apply to this. If you wish to participate in a fork or an airdrop, you must withdraw the relevant digital asset to your private wallet in good time.

Backed Digital Assets

From time to time we may support digital assets that declare that they are backed by or pegged to another asset, including but not limited to digital assets, fiat currencies or commodities such as gold or silver ("backed digital assets"). You acknowledge and agree that (a) you have read, understood and accepted all the terms and risks relating to each backed asset before carrying out a transaction in it, and (b) Coinbox is not obliged to purchase, repurchase, or permit the redemption of your backed digital assets under any circumstances. We reserve the right to change, suspend or discontinue any service relating to a backed digital asset at our sole discretion. We make no representation as to whether any backed asset will maintain its value relative to another asset, and we do not guarantee anything regarding the scope or quality of the reserves or the collateral held by the issuer or by any third party.

Governance and Voting

For certain supported digital assets, their protocol may enable holders of the assets to vote on various matters, including matters relating to the governance and operation of the protocol ("voting rights"). Where these assets are held in your account, Coinbox reserves sole and final discretion regarding the exercise of the voting rights. If you wish to exercise your voting rights, you must withdraw your supported digital assets to a private wallet before the relevant date of the vote.

Staking Services

• The user hereby acknowledges and agrees that the Company does not function as a validator node and does not directly operate the validation servers on the various blockchain networks. The safekeeping of the digital assets designated for staking is carried out at a supervised institutional custodian outside Israel, a dedicated deposit corporation operating under supervision in the State of Wyoming in the United States (Payward Financial, Inc., operating under the trade name Kraken Financial; hereinafter: the "custody provider"), while the actual operation of the validator nodes is carried out by another company in the Kraken group. The assets are held at the custody provider in a dedicated account for the benefit of the customers alone, segregated from the assets of the custody provider and from the assets of its other customers. The custody provider has no right, title or ownership in the assets, they are not recorded on its balance sheet, and it may not transfer or pledge them other than on the Company's instruction. Within this account the assets of the Company's customers are held on a pooled basis, without individual segregation on the blockchain, and each customer's right to the quantity and type of the assets is recorded in the Company's books. Notwithstanding the above, the customer is aware that there are risks that may arise from an operational default, economic collapse, bankruptcy, loss of assets or a cyber event in the custody provider's environment.
• The user understands and agrees that digital assets allocated by him to staking programmes will be subject to waiting and lock-up periods defined at the level of the blockchain protocol itself, which are not within the control of the Company or the custody provider. The user declares that he is aware that the time required to release the asset varies from asset to asset and is subject to change from time to time. For some assets the release is immediate, and for others it may take up to 21 days, depending on the network's rules and the load in the exit queue. The current release periods for each asset are displayed on the platform. To the extent that there is a release period, from the time the withdrawal request is broadcast until the actual end of the period the assets are not liquid, no trading, transfer or redemption operation can be carried out in them, and they do not entitle to staking rewards. The Company bears no liability for any loss caused to the user as a result of a fall in the value of the asset, market volatility or the loss of investment opportunities during the lock-up or maturation period.
• The user is aware that the operation of PoS consensus protocols carries exposure to the risk of "network penalties". This penalty is applied automatically by the code against validators that acted contrary to the network's rules, reported conflicting data or experienced hardware failures. Such penalties are set off first against the staking rewards, and in exceptional cases may also result in harm to the principal of the deposited assets. The Company does not guarantee, at any stage, the investment principal and/or any accompanying return. The loss amounts will be attributed pro rata to the customers participating in staking in that asset.
• In accordance with Israeli law, any receipt of a reward as a result of staking activity and/or any operation converting digital currencies on the platform constitutes, as a rule, a taxable event requiring reporting and payment in accordance with the law. The user acknowledges that the Company is obliged to act in accordance with the provisions of the Income Tax Ordinance and the regulations made under it. Accordingly, the Company shall be entitled, in accordance with its legal interpretation of its obligations, to withhold tax at source out of the rewards accrued or out of the redemption funds at the time of withdrawal of the assets, in accordance with the rate of tax prescribed by law for individuals or for a body of persons, unless the user presents to the Company, in good time and in an accepted form, a valid and official certificate from the assessing officer of a full exemption from withholding tax or a certificate of a reduced withholding rate. Notwithstanding the above, the sole legal and economic responsibility for examining tax liabilities, for meeting the independent reporting obligations to the tax authorities and for professional support from a tax adviser remains the responsibility of the user alone.

12. Account Security

Your Responsibility

You are responsible for taking appropriate steps to protect your hardware and data against viruses, malicious software and inappropriate material. Except as required under applicable law, you are responsible for backing up and keeping duplicate copies of any information you store or transmit using the Coinbox services. We are not responsible for any claim or damage caused by your failure to comply with the provisions of this section.

Security Measures

You, and every Authorised User, must at all times maintain adequate security and control over all your Access IDs. You are responsible for taking the required security measures (or for ensuring that your Authorised Users take these measures) in order to protect your Coinbox account and to maintain the confidentiality of your Access IDs, including:

• Full compliance with all our procedures and guidelines;
• Creating a strong password and maintaining the security of your Access IDs;
• Updating the email address and telephone number you provided to us for the purpose of receiving notices and alerts;
• Absolutely refraining from screen or computer sharing or granting remote access to others while you are logged into your Coinbox account;
• Remember that we will never ask you to share a password or a two-factor authentication (2FA) code.
• Logging out of the website or the platform at the end of each use on shared computers.
• Always log in directly to the Company's website in order to check if you have any doubt as to the authenticity of any message. You must keep the security of your email address and your Access IDs against attacks or unauthorised access. You must notify us immediately if you know or have reason to suspect that the security of your email address or that of an Authorised User has been compromised, or if there has been any unauthorised access to your email account or that of the Authorised User.

Monitoring Your Account History

It is important that you monitor your account history on an ongoing basis in order to identify unauthorised or suspicious activity and report it to us as soon as possible. You acknowledge that any security breach may lead to unauthorised access by third parties to your Coinbox account, to the loss or theft of digital assets and/or funds, including in related accounts such as bank accounts or credit cards.

If You Suspect a Security Breach

If you suspect a security breach, including the loss, theft or unauthorised use of his access details, you must:

• Change your password for the login method and ensure that no one else is authorised to access your 2FA method.
• Notify us immediately using the contact details stated on the website and continue to provide accurate and up-to-date information for as long as the security breach continues;
• Follow the "I am worried that my account has been hacked" wizard or any other means that we provide from time to time;
• Take any other action that we reasonably request of you for the purpose of reducing the risk, managing the situation or reporting the security breach. We reserve the right to require, and you agree to provide promptly, any information or document that appears to us to be relevant or necessary for the purpose of dealing with an actual or suspected security breach. You also acknowledge and agree that we may transfer this information to any third party that we see fit for the purpose of investigating or resolving the security breach. The Company may the Company take preventive measures at its sole discretion, including blocking access to the account, halting operations and transfers and/or freezing assets, until the suspicion is removed or until the incident is dealt with

13. Privacy

The Privacy Policy

The collection and use of personal data in connection with these terms, the Coinbox services, the platform or any other website is carried out in accordance with our Privacy Notice (which may be updated from time to time). You acknowledge that we may process personal data relating to you, that you provided to us or that we collected from you in connection with these terms and in accordance with the Privacy Notice. Your personal data will be processed in accordance with the Privacy Notice, and it shall form an integral part of these terms. The user is aware of and acknowledges that the information collected from him and/or about him by the Company or through it, within the framework of and/or for the purpose of providing the services, will be stored and processed in the lawfully secured databases under the Company's control, for the purposes of providing the Company's services, including managing the account, executing orders and operations, and also for the purposes of ongoing communication and sending updates and alerts and/or reports to the customer, managing and operating the Company's services lawfully, for the purpose of analysing and characterising the information in order to streamline and tailor the services, and including for marketing, statistical and direct mailing purposes subject to any law and/or consent as required.

You declare and undertake that:

• You confirm that you have read and understood our Privacy Notice.
• You understand that our business changes on an ongoing basis, and therefore our Privacy Notice will change accordingly. Accordingly, if we provide you from time to time with an updated version of the Privacy Notice, you will read it immediately.

14. Changes to the User Agreement

How and When We May Make Changes

We may make changes to these terms and to any terms and conditions included in them by reference (including product terms) at any time, and your continued use of the Coinbox services will be considered your consent to these changes. Changes to these terms will be published on our website, and may also be communicated to users separately by email, through the application, or by any other means chosen by Coinbox at its discretion. Generally, Coinbox will try to notify users in advance of changes before they come into effect. However, at times we will need to make changes that come into effect immediately, and in such cases we will notify users as soon as possible after the changes come into effect. Circumstances in which changes may come into effect immediately include, for example, and without derogating from the above:

• Where the change is required in order to meet legal and/or regulatory requirements;
• Where the changes are intended to clarify the terms.

When the Changes Come Into Effect

Except where the changes come into effect immediately, any update to the terms will come into effect after we notify users of it. If you do not wish to accept the changes, you may close your Coinbox account in accordance with Section 15.1 of this agreement. Your continued use of the Coinbox services will be considered consent to the updated terms. Copies of the most recent version will always be available on the website.

Changes to Fees

We may also make changes to the fees set out on the fee schedule page on our website, including adding new fees and/or charges. If you do not wish to accept the changes, you may close your Coinbox account in accordance with Section 15.1 of this agreement. Your continued use of the Coinbox services will be considered consent to the updated terms.

15. Closing Your Coinbox Account

Your Right to Close Your Coinbox Account

You may close your Coinbox account at any time by carrying out the account closure procedures determined by us from time to time. You will not be charged any payment for closing your Coinbox account, but you will be required to pay any unpaid amount that you owe us. You authorise us to cancel or suspend any pending transaction at the time of closure, and to deduct from your account any unpaid amount. In certain cases, you will not be able to close your Coinbox account, including where:

• You are attempting to evade an investigation by any competent authority;
• There is a pending transaction or an open claim relating to the account;
• There is an unpaid debit balance in your Coinbox account;
• Your Coinbox account is subject to a freeze, restriction or block.

What Happens When Your Coinbox Account Is Closed

If your Coinbox account is closed, you will be required to withdraw all the digital assets in the account. If you do not withdraw your digital assets, or if you have not logged into the account for a continuous period of 90 days, we will send you a notice of our intention to classify your account as a dormant account.

What Happens When Your Account Becomes Dormant

If you do not respond to a notice under Section 15.2 within 30 days, we may:

• Mark your Coinbox account as a dormant account;
• Convert the digital assets into another type of digital assets. In such a case, we will not be liable for any loss of profit, tax liability or any damage, loss or expense caused to you as a result of the conversion;
• Transfer the dormant account and/or the digital assets in it to any third party (including, but not limited to, a company affiliated with Coinbox, a third-party custodian or a segregated wallet), if it appears to us that this is reasonably required. In such a case, you will have the right to recover your digital assets, subject to meeting reasonable verification requirements determined by us (or by that third party) and to any applicable terms and conditions;
• Adjust the dormant account so that you receive a contractual right of claim in respect of the quantity and type of the digital assets that were in your Coinbox account before it was classified as a dormant account;
• Close the dormant account at any time.

16. Termination, Suspension, Blocking and Restrictions

Our Right

We may at any time change or discontinue, temporarily or permanently, any part or feature of the Coinbox services. In particular, we may:

• Refuse to complete or block, cancel, or, where permitted under applicable law, reverse a transaction that you approved;
• Terminate, suspend or restrict your access to all or part of the Coinbox services;
• Terminate, suspend, close, delay or restrict your access to all or part of your Coinbox accounts;
• Refuse to transfer information or orders to third parties (including third-party wallet operators);
• Take any action that appears to us to be necessary, in each case, immediately and for any reason, including but not limited to where:
• You are not eligible or have ceased to be eligible to use one or more of the Coinbox services;
• We have a reasonable suspicion that:
• The person logged into your account is not you, or that the account has been or will be used for unlawful purposes, fraud or unauthorised use;
• The person logged into your corporate account is not an Authorised User, or that the account has been or will be used for unlawful purposes, fraud or unauthorised use;
• More than one person is using the same Coinbox account, or that the account has been or will be used for unlawful or unauthorised use;
• The information you provided is incorrect, false, out of date or incomplete;
• We have reasonable concerns regarding your financial standing, including:
• If you are an individual and you have been declared bankrupt, are mentally incapacitated, or bankruptcy proceedings have been taken against you;
• If you are acting on behalf of a partnership, and one of the partners has died, become bankrupt or become mentally incapacitated, or steps have been taken to wind up the partnership;
• If you are acting on behalf of a corporation, and it is unable to pay its debts, or insolvency, interim management, receivership or similar proceedings have been taken;
• If you have convened a meeting of creditors or proposed a debt arrangement;
• Pending the provision of information and documents under Section 2;
• Pending enhanced checks under Section 2;
• We consider that applicable law or a competent authority requires us to take action;
• We consider or suspect that:
• You have breached these terms or product terms;
• You have breached representations or undertakings, express or implied, given by you;
• The transaction you carried out is unauthorised, incorrect, fraudulent or unlawful, or that the services or your account are being used in that manner;
• There is a concern of money laundering, terrorist financing, fraud or other crime activity relating to your account or to the Coinbox services;
• Your use of the service is subject to legal proceedings, an investigation or regulation that constitute an increased legal or regulatory risk;
• You owe money to Coinbox that has not yet been settled.
• Emails sent to your address are returned as undeliverable;
• There is a problem in verifying your identity;
• You have taken action to circumvent control mechanisms, including opening a number of accounts without written approval, or abusing promotions;
• In our opinion you are not trading responsibly or you are not suitable to access the services;
• There is any other legal reason requiring this. We will take reasonable steps to notify you where appropriate, but there may be cases in which the law prohibits us from doing so.

Your Acknowledgement

You acknowledge and agree that:

• The examples in Section 16.1 are not exhaustive;
• Our decisions may be based on confidential criteria relating to risk management and security control, and we are not obliged to disclose them to you;
• Aggressive, abusive, threatening behaviour or behaviour that unreasonably burdens our employees is not acceptable, and in serious or repeated cases we may exercise our right to suspend, restrict or terminate your access to the Coinbox services.

What Happens When We Exercise Our Right

When we suspend, halt or restrict your access:

• Open transactions or active orders will be closed by you or by us, according to the circumstances of the case;
• A chargeback from the credit card may cause the immediate suspension of the account;
• In order to release the suspension you will be required to pay the full amount of the chargeback and all other debts;
• You are responsible for any amount you received as a result of a chargeback, and you authorise us to deduct payments from your account without notice.

Unlawful Ownership

If we become aware, or have reasonable cause to believe, that digital assets or fiat currencies in your account are not in your lawful ownership, we may, but are not obliged to, withhold them. The holding will continue until sufficient proof is presented that you are the lawful owner. We do not intervene in or resolve disputes between parties as to ownership.

Access to the Services in Different Countries

Coinbox does not specifically target users in certain countries, and its services may be restricted in part or in full in certain countries. Coinbox reserves the right to change the services available to you. If you are present in a country on the list of prohibited countries, access to the services may be blocked, which may prevent you from trading, monitoring open orders or using the services. You may not attempt to circumvent these restrictions, including by using a VPN to change your IP address.

17. Prohibited Use of the Coinbox Services

In opening a Coinbox account or in carrying out any transaction, and without derogating from any other limitation or restriction set out in these terms, you agree that you and every Authorised User will not do the following:

• Breach these terms or any agreement entered into under or in connection with these terms, including (but not limited to) any product terms;
• Use the Coinbox services in a manner that breaches the terms of use;
• Use the Coinbox services for commercial purposes or for the purposes of resale, including carrying out transactions on behalf of third parties, unless we have given our prior written consent to this;
• Use the services for purposes whose aim, in Coinbox's view, is the artificial control of or influence on the price of any digital asset (market manipulation), including but not limited to "pump and dump", wash trading, self-dealing, "front running", quote stuffing and spoofing or layering, even if they are not prohibited by law;
• Engage in fraudulent activities, or cause us to suspect that you or an Authorised User engaged in fraudulent activity or transactions;
• Provide false, inaccurate or misleading information in connection with your use of the services, or in communications with us, or in any connection with these terms;
• Use deep links, crawlers, bots, spiders or any other automated means or similar manual process to access, copy or monitor any part of the platform;
• Attempt to access any part of the platform without authorisation, or connect to the services or our servers by hacking, password mining or any other unlawful means;
• Test or scan the platform in order to expose vulnerabilities;
• Attempt to track or actually track other users; (5) place an unreasonable load on the systems or networks of the services;
• Disrupt or attempt to disrupt the operation of the services or the transactions;
• Falsify identity details, impersonate or conceal your identity or the source of the messages you send;
• Modify or integrate the platform or any part of it into other software or an application;
• Disassemble, decompile, reverse engineer or attempt to understand the source code or the principles behind the platform;
• Reproduce, copy, store, transfer, transmit, alter or remove copyright notices, sell, rent, lease, sublicense or create derivative works from Coinbox's intellectual property or exploit it in any manner whatsoever;
• Distribute viruses, Trojan horses, worms or other harmful computer code that may harm systems or information;
• Use an anonymous proxy;
• Use a temporary or disposable email address when opening an account;
• Circumvent bot security mechanisms or disrupt the websites or the services;
• Cause us to lose access to the services from internet providers or other partners;
• Create or assert the existence of any lien over fiat currency or digital assets held in your account without our written consent;
• Access or attempt to access the Coinbox services, directly or indirectly, from countries or through persons that Coinbox has classified as "high risk", including but not limited to countries on the list of prohibited countries.

18. Representations and Undertakings

You hereby represent and undertake to us, at all times, as follows:

• All the documents and information you provide to us are true, accurate, complete and up to date in all respects, and may be relied upon in determining your eligibility to access the platform or to use the Coinbox services;
• All the decisions you took in connection with these terms were taken on the basis of your sole discretion and after an independent assessment of your financial resources, your ability and willingness to bear the relevant risks and your financial objectives;
• If you are a corporation, a partner in a partnership or a trustee of a trust:
• The corporation, the partnership or the trust is managed and operates in accordance with applicable law and the incorporation documents or the agreement (such as a partnership or trust deed);
• You will notify us immediately of any change in the composition of the board of directors, the partners, the trustees, the founders or the ultimate beneficiaries, or in any person authorised to act on your Coinbox account;
• You will notify us immediately if the corporation, the partnership or the trust is being wound up, voluntarily or involuntarily;
• You are not a person with limited legal capacity;
• If you are a legal entity, you are duly incorporated, registered and existing under the laws of your jurisdiction, and you have full authority to conduct your business. If you are an individual, you are at least 18 years old;
• Your access to the platform and/or to the Coinbox services, your entry into these terms and their performance, will not cause:
• If you are a corporation, a partner in a partnership or a trustee, a breach or contradiction of your incorporation documents (such as articles of association, a partnership or trust deed);
• A breach of any agreement, document or undertaking to which you are a party or that applies to you or to your assets;
• A breach of a law, judgment, court order, arbitral award or an instruction of any regulatory or governmental authority.

19. Technological Disclaimer

• The Coinbox services and any information provided on the websites and the platform, including the chat services, are provided "as is" and are subject to availability ("as available"), without any representation or warranty, express or implied, to the maximum extent permitted under applicable law. In particular, we disclaim any implied warranty regarding title, merchantability, fitness for a particular purpose and/or non-infringement. We do not undertake or represent that access to the websites, the platform, your Coinbox account, the Coinbox services or any materials contained in them will be continuous, uninterrupted, timely or error-free. This situation may result in an inability to trade on the platform for a certain period of time and even in delays.
• From time to time we may suspend access to your Coinbox account and/or to the Coinbox services for the purposes of scheduled or emergency maintenance. We will make reasonable efforts to ensure that transaction processing is carried out in a timely manner, but we make no representation or undertaking as to the period of time required to complete the processing, since it depends on many factors that are not within our control.
• Although we make reasonable efforts to update the information on the websites and the platform, we do not represent, undertake or guarantee, expressly or impliedly, that the content on the websites and the platform, including information relating to the Coinbox services, is accurate, complete or up to date.
• All the information, articles, guides, system descriptions and examples (including numerical examples, technical scenarios, or fee simulations) published in the "Learning Centre" or anywhere else on the Company's website and on the platform (hereinafter: the "content"), are brought for the purposes of learning, illustration and general explanation of the manner of operation of the system only. The Company does not provide investment advice, and the content does not constitute, and is not to be regarded as, investment advice, investment marketing, financial advice, or a recommendation to carry out any operation, purchase or sale of digital assets. It is clarified that all the numerical examples appearing in the content are based on theoretical and hypothetical data intended to make the system easier to understand, and do not necessarily reflect a real market situation, or a promise of any return or profit. The user declares and acknowledges that every decision to carry out operations on the platform is taken on the basis of his independent and sole discretion alone, and the Company shall bear no liability of any kind for any damage or loss caused as a result of reliance on this content.
• Links to third-party websites (including, without limitation, content, materials and/or information found on those websites) may be provided for your convenience, but are not within our control. You acknowledge and agree that we are not responsible for any part of the content, materials, information or services found on third-party websites that can be accessed through the platform or our websites.
• The platform and the website may display or enable the use of various charts, visual data, indices, oscillators and technical indicators (together: the "visual aids"), including those developed, operated or provided by third parties. The user acknowledges and agrees that: (a) the visual aids and the indicators are displayed for the purposes of general information and illustration only, do not constitute investment advice, a recommendation or a solicitation to carry out an operation, and are not to be relied upon for the purpose of making trading decisions; (b) the Company does not represent, guarantee or undertake that the visual aids or the indicators are accurate, complete, error-free, updated in real time or continuous; (c) the Company shall bear no liability (direct or indirect) for any disruption, delay, malfunction, omission, freeze or error in the display of the charts or the indicators, or for any loss, damage or loss of profit caused to the user or to a third party as a result of reliance on them.
• You are responsible for obtaining the data network connection required for using the Coinbox services. You are also responsible for acquiring and updating the compatible hardware or devices required for the purpose of accessing and using the services and the websites, including their updates. Coinbox does not guarantee that the Coinbox services, or any part of them, will function on particular hardware or devices. The services may be subject to malfunctions and delays arising from the use of the internet and electronic communications.

20. Liability

Limitations of Liability

Neither Coinbox nor any of the parties affiliated with it shall be liable or answerable to you or to any third party for any loss, except where the loss was caused directly and solely as a result of gross negligence, wilful misconduct, actual fraud or a material and continuing breach of an undertaking under these terms on the part of Coinbox.

• Coinbox gives no undertaking or representation regarding the current or future value, the performance, or the integrity of any digital assets. You should know that there are significant risks in holding or trading digital assets. The value of digital assets is highly volatile and may rise or fall significantly, and you may sustain considerable losses. The decision to buy, sell or hold digital assets is at your sole risk.
• The Company may, but does not undertake, to send the user from time to time push notifications, alerts, text messages, or email messages, that include marketing information, advertisements, and also information about market events, rate movements or other updates relating to digital assets (hereinafter: the "market alerts and mailings"). The user declares and acknowledges that the market alerts and mailings are brought to his attention as a discretionary aid only, and they do not constitute in any manner investment advice, investment marketing, financial advice or a recommendation to carry out any operation, purchase or sale of digital assets. The information conveyed in the alerts may be received from third parties, and the Company does not guarantee its accuracy, completeness, or currency. The Company shall bear no liability for any delay, disruption, non-arrival of the message or error in the content of the alert, and the user waives any claim or demand against the Company for reliance on these alerts or for technical malfunctions in sending them. The user may at any time block or disable the receipt of push notifications by changing the settings of his mobile device or the account settings on the platform, and also remove himself from the marketing mailing lists in accordance with the mechanism set out in the Company's Privacy Policy.
• The Company's services may be limited or unavailable at times of high volatility or high activity volumes. This situation may result in restrictions on access to your account or to the services, including an inability to carry out or complete transactions, and also in delays in responses from customer support.
• We recommend consulting a financial, legal or tax adviser regarding your personal situation and considering carefully whether trading in or holding digital assets is suitable for you.
• Notwithstanding any other provision in these terms, you acknowledge and agree that in no event shall we or any party affiliated with Coinbox be liable to you or to any third party for:
• Direct or indirect losses (including loss of profits, business or opportunities), damages or costs, whether in connection with the Coinbox services or not, including but not limited to:
• Any risk mentioned in the Risk Disclosure, as updated from time to time;
• The operation of digital asset protocols, including their functioning, security or availability;
• The question whether backed assets maintain their value relative to another asset, or whether the issuer holds sufficient reserves;
• Acting or refraining from acting in accordance with these terms;
• An inaccuracy, defect or omission in digital asset price data, an error or delay in transmission, or an interruption in this information;
• Scheduled or emergency maintenance that causes an interruption of service;
• Theft of a device that enables access to the services;
• Acts, omissions or breaches of other users or damage from third parties;
• Damage or interruptions as a result of viruses, spyware or other malicious attacks; hardware failures or data loss; technical malfunctions, internet congestion, security breaches or other technological problems;
• A decision to reject an application to open an account;
• Termination, suspension or restriction of access to the services or digital assets, including during an inability to withdraw or trade;
• Limits on transactions in your account;
• Our choice to support or not to support a digital asset;
• A failure to contact you using the contact details you provided;
• The closure of a dormant account;
• A failure to execute a transaction or a delay in completing it;
• A refusal or delay in executing orders;
• A hack of the email account or a security incident;
• Losses caused as a result of the acts of a third party, including fraud or deceit in which Coinbox served only as a technical intermediary;
• Losses as a result of the transfer of assets from the platform at your request;
• Losses arising from issuances or initial offerings or decisions to list or not to list assets on the platform;
• Network events, Forks or Airdrops.
• Any disruption, delay, error or unavailability of the services, including communications disruptions for any reason;
• Any loss of business, profits, anticipated savings or opportunities, or any special, punitive, aggravated, incidental, indirect or consequential losses or damages, whether arising from or connected to our websites, the platform, your Coinbox account, the Coinbox services, these terms, the product terms, the Privacy Notice and/or any other agreement entered into under them or in connection with them or any other matter.
• Any losses or damages that you may sustain as a result of a manifest error and/or in the event of extreme market volatility and/or as a result of the cancellation or change of any transaction, for any reason, whether direct or indirect, special or consequential, including, but not limited to, loss of profits and loss of opportunities, even if Coinbox was aware of the possibility of the said loss or damage being caused, or if it could reasonably have been foreseen that they would be caused.
• We are not responsible for any damage or interruption caused as a result of computer viruses, spyware, Trojan horses, worms or other malicious software that may affect your computer or equipment, or as a result of phishing attacks, impersonation or other attacks. We recommend making regular use of reliable and widely used anti-virus software for scanning and prevention. You should also be aware that SMS and email services are exposed to impersonation and phishing attacks, and extra care must be taken in checking messages purporting to be sent on our behalf. You, and where relevant, the Authorised Users on your behalf, are responsible for all access details, including usernames and passwords, and you must keep your security details safe at all times.

21. Handling Enquiries and Complaints

For the avoidance of doubt, nothing in this section shall deprive you of any mandatory legal right granted to you under applicable law. The Company attaches the utmost importance to providing an appropriate and efficient response to user enquiries. In any case of an objection, allegation, dispute or complaint regarding the services or the operation of the platform (hereinafter: the "enquiry" or the "complaint"), the user undertakes to apply first to the Company in writing through the customer service department at the email address: support@coinbox.co.il. The user must set out in his enquiry the following details: (a) a full description of the substance of the enquiry or the grounds of the complaint; (b) the contact details and the email address linked to his account; and (c) the specific remedy or compensation sought by him, if any. The Company will act to examine the enquiry and provide a response in accordance with its customer handling policy, according to the following timeframes: Acknowledgement of receipt and initial response: will be sent to the user within five (5) business days from the date the enquiry is received in full. A final and reasoned response: will be delivered to the user in writing within thirty (30) business days from the date the enquiry is received. Extension of time in exceptional circumstances: in complex cases requiring in-depth examination, obtaining information from third parties or technology providers, or for other exceptional reasons not within the Company's control, the Company shall be entitled to extend the date of the final response by a further 15 business days, and will give the user notice of this.

22. Governing Law

This agreement, and everything arising from it or connected to it, shall be governed solely by the laws of the State of Israel, without regard to their conflict of laws rules. Exclusive and sole jurisdiction in any dispute, disagreement or claim arising in connection with this agreement, the services or the platform shall be vested in the competent courts of the Tel Aviv-Jaffa District, Israel.

23. Ownership and Intellectual Property

• The services, the platform, the website and all the content appearing in them, including, but not limited to, the Company's name, logos, software, source code, technologies, designs, texts, graphics, images, animations, interfaces, methods of operation, moral rights, documentation, and any other item connected to them (hereinafter: the "intellectual property"), are the exclusive property of Coinbox or of third parties who granted Coinbox a licence to use them.
• Coinbox (or the relevant rights holders, as the case may be) retains all rights, title and interest in the intellectual property, including but not limited to copyright, patents, trademarks, trade names, trade secrets, design rights and any other intellectual property right, whether registered or not.
• This agreement and your use of the services do not grant you any right, licence or ownership in the intellectual property, other than a limited, personal, non-transferable, non-assignable and revocable licence to access and use the services and the platform for the purposes permitted under this agreement alone, and subject to all its terms.
• The name 'קוינבוקס' or 'Coinbox', the logo identified with it, and any other trademark, service mark or branding used by Coinbox in connection with the services, are registered and/or protected trademarks of Coinbox, and no use may be made of them without obtaining Coinbox's prior written approval. Third-party trademarks appearing on the platform are the exclusive property of those parties.

24. General Terms

• Applicable law. You and every Authorised User must comply with all applicable law, licensing requirements and third-party rights (including data privacy laws, and laws for the prevention of money laundering and terrorist financing) in your use of the Coinbox services, your Coinbox account and the platform.
• Notices. We may send notices by email to your email account. It is your responsibility to ensure that the email address is up to date and accurate. A notice shall be deemed received if it was sent to your email address, even if an error message was received regarding a delivery failure.
• You agree and consent to receive electronically (email, SMS messages, application alerts) all the communications (including communications on social networks), agreements, documents, notices and disclosures (together: "communications") that we provide in connection with your Coinbox account and your use of the Coinbox services. The communications include:
• Terms of use and policies that you agree to (for example: the agreement and the privacy policy), including updates to them;
• Account details, history, transaction receipts, confirmations and any other information relating to your account or transactions;
• Legal, regulatory and tax disclosures that we must make available to you;
• Responses to claims or customer service enquiries submitted in connection with your account;
• Official notices, news and promotions. You may withdraw your consent to receiving electronic communications by contacting us at: support@coinbox.co.il. If you withdraw your consent in this manner, Coinbox reserves the right to close your account immediately or to charge you additional fees for sending printed copies.
• You agree that we may record any communication between us, whether electronic, by telephone, by video or in any other manner, in connection with these terms, and that any recording retained by us shall constitute evidence of the communication between you and us. You agree that telephone calls and video calls may be recorded for the purposes of responding to enquiries, complying with applicable law, improving our services and providing customer support.
• Entire agreement. These terms, together with the relevant product terms (which will be published from time to time), constitute the entire agreement between you and us regarding the Coinbox services. Each party acknowledges that it has not relied on any statement, representation, promise or warranty (whether given negligently or not), except as expressly set out in these terms or in the relevant product terms.
• Assignment. You may not assign or transfer any of your rights or obligations under these terms without our prior written approval, which may at times require further information or the carrying out of enhanced due diligence. However, we may assign or transfer any of our rights or obligations under these terms at any time, to any other party, including, but not limited to, in the context of a merger, acquisition or other organisational change involving Coinbox.
• Recording of documentation. You agree that we may record any telephone call, email and chat conversation with you, and also any other type of communication between you and us, including communication used for instructions or for carrying out transactions, and that these recordings may serve as evidence in any legal proceedings relating to the agreement with you. These records shall be our exclusive property.
• Third-party rights. Except in respect of companies affiliated with Coinbox, nothing in these terms shall be construed as granting a legal or equitable right, remedy or claim to any third party that is not a party to this agreement. These terms and all their sections and subsections are intended for the benefit of the parties to them alone, including their successors and their permitted assigns.
• When you instruct Coinbox to transfer or carry out another operation in respect of digital assets, Coinbox will not use specifically identified digital assets in order to carry out your instructions. Subject to these terms, Coinbox will use digital assets in a quantity and of a type identical to those credited to your Coinbox account for the purpose of carrying out your instructions.
• Force majeure. We shall not be liable for any delay or failure in performing the obligations imposed on us under these terms, to the extent that the delay or failure was caused as a result of a force majeure event.
• No waiver. Any delay or forbearance on our part in exercising any right or remedy under these terms shall not be considered a waiver of the future exercise of that right or remedy, or of any other right or remedy under these terms. The rights and remedies provided in these terms are cumulative and are not exclusive of any right or remedy existing under applicable law.
• Set-off. In addition to any legal or other remedy existing under these terms or under law, we may set off any amount that you owe us under these terms or in any other manner. You must pay us all the amounts that you owe us free of any set-off, counterclaim, deduction or withholding of any kind, unless otherwise required under applicable law.
• Taxes. It is your responsibility to determine which taxes apply to payments or additional transactions that are not covered by the system, and to report them where necessary. At the same time, Coinbox acts as a withholding authority in accordance with the directives of the Israel Tax Authority in respect of the trading operations on the platform. Consolidated tax settlement. We calculate in real time the tax liability arising from your trading operations (withholding tax at source). In order to ensure a smooth trading experience without interruptions, the actual tax deduction is carried out on a consolidated basis once a month, or before the withdrawal of digital assets or fiat funds from your account, whichever is earlier. By using the Coinbox services, you irrevocably authorise us to deduct the statutory tax amounts required by law and to transfer them to the Tax Authority. Liquidity and automatic conversion. In the event that the tax liability exceeds the available fiat (shekel) balance in your account at the time of the deduction, you expressly and irrevocably authorise Coinbox to sell part of the supported digital assets in your account at real-time market prices, in order to cover the full tax liability that we are required to report. The identity of the digital assets to be sold will be determined at Coinbox's sole discretion (usually, preferring assets with high liquidity). You acknowledge and agree that execution fees, rate gaps and all the market risks arising from this automatic sale shall be borne by you exclusively, and you shall have no claim regarding losses arising from this course of action. Further information is available in the questions and answers area on our tax page.

Deposits of Digital Assets from External Sources

• As a withholding body and as a financial institution, any digital asset deposited into your account from an external source (a wallet that does not belong to Coinbox) will be considered an asset with no known acquisition cost.
• On the sale of a digital asset deposited from an external source as stated, Coinbox will withhold tax at source at a rate of 30% of the total gross consideration, except in the following cases: a. Presentation of an official certificate from the Tax Authority: to the extent that the user provides and transmits to the Company in good time supporting documentation or a valid and official certificate from the Tax Authority in Israel, expressly directing an exemption from withholding tax at source or a deduction of tax at a different rate, the Company will act in accordance with the directions appearing in that official certificate alone. b. Deposit of USDC: to the extent that the digital asset deposited from an external source is USDC, the cost according to which the tax liability and the withholding at source will be calculated shall be determined according to a fixed value of 2.81 per unit. c. A digital asset transferred and deposited from an account or wallet managed at a supervised Israeli financial body, included in the list of approved bodies published and updated from time to time on the Company's website, and this subject to the provision of supporting documents and evidence and passing a full validation procedure, to the Company's sole and absolute satisfaction. The user is aware of and agrees that for the purpose of carrying out the validation procedure, the transfer of the data or the verification of the documentation as stated, he may be required to install a dedicated software component or an extension on his personal computer or device.
• For the avoidance of doubt, the Company's withholding obligation applies solely to tax events carried out through the Company's platform from the time of the deposit of the assets onwards. The Company does not bear, and shall not bear under any circumstances and in any case, any liability whatsoever for the calculation, deduction, reporting or payment of tax in respect of operations, transactions, conversions or tax events carried out in the deposited assets (including in USDC or in any other asset transferred from a supervised financial body) before they were actually deposited in the user's account at the Company. Full responsibility for lawful reporting and for the payment of any tax applicable in respect of such historical operations and transactions, including trading and conversion operations carried out by the user before purchasing the USDC or transferring it to the Company, rests exclusively, absolutely and unreservedly on the user alone, and he releases the Company from any claim, demand or liability in connection with this.
• Except in the cases set out in Section 24.14.2 above (presentation of an individual certificate from the Tax Authority, sale of USDC, or a transfer from a supervised Israeli financial body that has passed a full validation process), there is no possibility of declaring an independent acquisition cost or providing other trading documentation through the platform's systems. To the extent that the user has proof or documentation of the original purchase price of the deposited assets, it is his responsibility and his right to apply directly to the Tax Authority in Israel for the purpose of submitting an individual application for a tax refund. There is no possibility of declaring an acquisition cost or providing supporting documentation through the platform. To the extent that you have proof of the original purchase price, you may apply directly to the Tax Authority in Israel for the purpose of requesting a tax refund.