User Agreement – Coinbox

Last Updated: June 11, 2025

Coinbox Ltd. (hereinafter: "the Company", "Coinbox", or "we") is a virtual currency trading broker operating in Israel under an Expanded Financial Asset Service Provider License from the Capital Markets, Insurance, and Savings Authority. Coinbox provides users with a trading platform to buy and sell virtual currencies, an integrated storage solution allowing users to store their digital assets, and other virtual currency-related services. Coinbox operates in accordance with the laws and regulations applicable to a financial asset service provider in Israel, and is committed to updating its policies and procedures in accordance with industry developments.

By registering 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 case of a problem, and other important information. You must read these terms, along with the documents referenced herein, carefully and contact us if you do not understand anything.

These terms refer to several additional documents which also apply to your use of the Company's services and form an integral part of this agreement:

Our Privacy Policy – details the terms under which we process and retain any personal and financial information (including the retention of information for 7 years as required by law).
Our Risk Warning – a disclosure document detailing important information on potential technological and financial risks when buying, selling, holding, or investing in virtual currencies.

"Digital asset", "virtual asset", or "digital currency" means any digital asset (including virtual currency or commodity) that constitutes a digital representation of value based on a computer network's cryptographic protocol. A supported digital asset is only those assets explicitly listed as available for trading or custody on the Company's trading platform.

1. Information Regarding a Coinbox Account

1.1 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, corporation, legal entity, body, or other organization with the full authority, capacity, and ability to (a) access and use the Company's services; and (b) agree to and comply with these terms.
If you are an individual – you must be at least 18 years old. The use of the services is strictly prohibited for minors.
If you are acting as an employee or representative of a legal entity and signing these terms on its behalf – you must be legally authorized to act on its behalf and bind it for the purpose of entering into these terms.
You are not located in, registered in, residing in, or a citizen of a jurisdiction where access to or use of the Company's services is illegal under applicable law, or a sanctioned country.

1.2 Opening an Account

You must create a Coinbox account to access Coinbox services and the platform. A Coinbox account can be opened as a private user or as a corporate account. To create an account, you must register on the Company's website or app by providing personal details, completing certain verification procedures, and accepting the terms of this agreement. You agree and declare that you will use the services solely for yourself, and not on behalf of any third party. The Company may, at its sole discretion and without obligation to provide reasons, refuse to open an account for you or suspend an existing account.

1.3 Identity Verification (KYC / AML) and Compliance Policy

In accordance with the Prohibition on Money Laundering Law, 5760-2000, and the Company's compliance and enforcement policies, you will be required to undergo "Know Your Customer" (KYC) procedures prior to being granted access to the services:

This procedure is conducted online and includes uploading identifying documents and a facial scan (Liveness Check) via authorized verification providers, as well as providing statements regarding your source of funds and wealth.
Enhanced Due Diligence: We may require you to undergo an enhanced process and submit additional documents (such as bank references) based on your risk level.
The Company strictly prohibits the use of the account under a false identity, impersonation, money laundering activities, terrorist financing, fraud, or ransom payments. Failure to comply with identification requirements will lead to the blocking of the account.

2. Deposits, Withdrawals, and "Same Name" Policy

The Company's compliance policy strictly prohibits receiving funds or assets from third parties, as well as transferring them to third parties (the "Same-Name Policy").

2.1 Fiat Deposits via Bank Transfer or Credit Card

You may deposit fiat currency (such as ILS, USD) strictly from a bank account or credit card registered in your exact name, as verified during the KYC process. The Company will automatically reject and return to the source any deposits originating from an account in another person's name, a company (if it is a private account), or any third party. Deposits are subject to minimum/maximum limits and regulatory checks.

2.2 Digital Asset Deposits via Wallet

You may deposit supported digital assets solely from a digital wallet owned and exclusively controlled by you. You must transfer the assets strictly to the designated blockchain address provided to you on the platform. Every transfer is subject to monitoring and blockchain analytics (KYT - Know Your Transaction). Deposits may be delayed pending the completion of security and anti-money laundering checks. Coinbox is not responsible for the loss of assets transferred on an unsupported network or to an incorrect address.

2.3 Return of Funds / Assets

If funds are deposited before the completion of full identity verification, or if assets are deposited from a wallet classified as high risk or associated with illegal activity, the Company may delay, freeze, or return the funds/assets to their source, minus the Company's expenses and network fees.

2.4 Fiat and Digital Asset Withdrawals

Fiat Withdrawal: Will be executed strictly to a bank account registered in your name only.
Digital Asset Withdrawal (Travel Rule): Will be executed to an external wallet under your control. Under Travel Rule regulations, you may be required to provide additional information about the receiving wallet prior to executing the withdrawal. It is your sole and absolute responsibility to ensure the destination address is accurate and matches the type of asset being transferred. Coinbox will bear no liability for the loss of assets sent to an incorrect address entered by you, and every asset transfer transaction on the blockchain is final and irreversible.

The Company is not responsible for delays arising from congestion on blockchain networks, liquidity providers, or local banks.

2.5 Custody and Internal Ledger Structure

Coinbox manages client assets in technologically centralized wallets (Omnibus/MPC) and uses a segregated internal ledger to record your rights. You do not receive access to private keys. Your assets are not necessarily physically segregated on the blockchain (on-chain) from other clients' assets; rather, they are managed as a contractual right against Coinbox to receive the type and quantity of the asset credited to you in the internal ledger.

3. Fees

The use of the platform and the Company's services (including trading, deposits, or withdrawals) may involve the payment of fees. We reserve the right to determine and update the rates and types of fees from time to time based on market conditions, network costs, and our discretion. To ensure complete transparency, the exact fee applicable to each action (or its method of calculation) will be clearly presented to you within the app or website prior to your confirmation and execution of the transaction. Your confirmation to execute the action constitutes your irrevocable consent to pay the displayed fee.

4. Transactions and Trading

Orders are Non-Cancellable: Market Orders placed on the platform are executed immediately against liquidity providers and cannot be canceled once submitted.
Exchange Rates and Spread: Buy and sell rates are determined based on real-time prices. The final price presented to you includes the Company's fee/spread. Purchasing an asset in a different currency (e.g., buying a USD-denominated asset with ILS) will involve foreign exchange conversion.
Correction of Errors: Coinbox may correct, cancel, or reverse any transaction resulting from a "Manifest Error" of the system (e.g., a bug in price display), and adjust the transaction to the fair market price.
Insufficient Balance: If there is insufficient balance in your account (including to cover operational/network fees), the transaction will be rejected.

5. Supported Digital Assets and Network Events

Limited Support: Coinbox strictly supports only those assets explicitly displayed on the platform. Transferring an unsupported asset to the Company's wallets may lead to its permanent loss with no possibility of recovery.
Forks and Airdrops: Coinbox does not guarantee support for network forks or asset distributions. If you wish to ensure your right to these events, you must withdraw the assets to a private wallet before the record date.
Stablecoins: The Company does not guarantee the retention of value of asset-backed coins (stablecoins) and is not responsible for the quality or existence of the reserves of the issuing entity.

6. Account Security and Cyber Risk Management

In accordance with the Company's cyber risk management policy, we implement stringent security controls, but the responsibility to protect your account also falls on you:

Two-Factor Authentication (2FA): You are required to enable two-factor authentication on your account. This mechanism is critical for protecting the execution of transactions, withdrawals, and settings changes.
Maintaining Confidentiality: You must maintain a strong password and avoid phishing attacks. Coinbox will never ask for your password or your 2FA code outside of the official login screens.
Proactive Account Blocking: In the event of a lost device or suspected breach, you must immediately lock your account via the platform and notify us. We will not be liable for damage resulting from unauthorized access to your device.

7. Account Closure and Data Deletion

We allow users total control over their account and their data.

Proactive Account Deletion: You may close your account at any time (provided there are no outstanding debts or legal freezes on the account) via Settings ← Security ← Delete Account within the platform.
Online Deletion Request: You can submit a request to delete your account without logging into the app via the Data Deletion page.
Deletion Restrictions: Under the Prohibition on Money Laundering Law, transaction data and identification documents are not deleted immediately; rather, they are stored under encryption for a period of up to 7 years (as detailed in the Privacy Policy).
Dormant Account: If your account is inactive (no platform logins) for 90 consecutive days, the system may classify it as a "Dormant Account." It is clarified that the Company never touches, converts, or transfers client assets without an explicit instruction. Your assets will be safely kept exactly as they are, and the classification of the account as dormant requires no further action from you and is intended solely for system and internal control purposes.

8. Suspension, Blocking, and Prohibited Use

Coinbox reserves the right to suspend, restrict, or completely terminate your access to the services, immediately, in the following cases:

Violation of these terms of use or providing false information.
Use of the services for market manipulation (Wash Trading, Pump and Dump), fraud, or any criminal behavior.
Hacking attempts, reverse engineering, or impairing the Company's systems.
Abusive or threatening behavior toward customer service staff.

9. Limitation of Liability and Technological Waiver

No Advice and No Performance Guarantee: The services are provided "AS IS." Coinbox does not provide investment, tax, or legal advice. Trading in digital assets is a volatile activity subject to extreme market risks that could lead to the loss of your funds, and is undertaken at your sole responsibility.
Exemption from Liability for Damages: Coinbox and its custody/liquidity providers will not be liable for any loss or damage (direct or indirect), loss of profits, or delay in trading arising from system downtime, internet outages, cyber-attacks not under its direct control, or the actions of blockchain networks.

10. Taxes and Tax Withholding

The user is responsible for reporting all earnings according to law.

At the same time, Coinbox acts as a withholding authority in accordance with Israeli Tax Authority guidelines. By using the services, you authorize the Company to calculate and withhold tax at source from your activities on the platform.

Auto-Liquidation for Tax: If your tax liability exceeds the available ILS balance in your account, you irrevocably authorize Coinbox to perform an automatic sale of digital assets in your account to cover the required tax liability to be transferred to the Tax Authority.

11. Miscellaneous

Electronic Communication: You agree to receive all regulatory notices and disclosures electronically and/or via phone (including call recording for quality control and service improvement purposes).
Intellectual Property: All intellectual property rights in the platform (designs, logos, source code) belong to Coinbox and no commercial use may be made of them.
Right of Set-off: Coinbox may set off against your account balance (in fiat or digital assets) any debt, fee, chargeback, or payment that you owe the Company.
Force Majeure: Coinbox will not be liable for delays or failures resulting from events beyond its reasonable control, including war, terrorism, natural disasters, strikes, or the collapse of global internet and communication infrastructures.
Assignment: You may not assign or transfer your rights and obligations under this agreement to a third party. Coinbox may assign its rights and obligations to any other entity (e.g., in the event of a merger or acquisition) without requiring your prior consent.
Dispute Resolution: We encourage resolving disputes via customer service at support@coinbox.co.il. If you wish to file a lawsuit, you must send a preliminary "Notice of Claim" in writing.
Law and Jurisdiction: Only the laws of the State of Israel will apply to this agreement. Exclusive jurisdiction over any dispute is given to the competent courts in the Tel Aviv-Yafo district.
Changes to the Agreement: We may update this agreement at any time. Changes will be published on the platform, and your continued use of the services after the update will be deemed acceptance of the new terms.

Confirmation and Consent

By registering, checking the consent box upon opening an account, or by the very use of the platform, you declare and warrant that you have read, understood, and fully and unreservedly agreed to all the provisions of this User Agreement and all its appendices.