4 mar, 2026

Terms and Conditions

GENERAL PROVISIONS
These Terms of Use (the “Terms”) are issued by Connectee OÜ, a private limited liability company incorporated in the Republic of Estonia (legal entity code: 14891451), with its registered address: Narva mnt. 7, 10117 Tallinn, Estonia. In these Terms, Connectee OÜ is referred to as “Connectee”, “we”, “us” or “our”.
Connectee operates under the brand name Connectee, including through its official website https://connectee.io (the “Website”). All legal and regulatory documents, updates and communications with users are maintained exclusively through the Website.
These Terms constitute a legally binding agreement between you (the “User”, “you” or “your”) and Connectee. By accessing or using any of our Services, as defined below, you acknowledge that you have read, understood and accepted these Terms together with all accompanying disclosures and policies, including but not limited to the Conflicts of Interest Policy, the Complaints Handling Policy, the Fee Schedule, the Privacy Policy, the Commercial Policy, the Segregation of Client Crypto Assets and funds, the Crypto Custody policy, the Crypto-Assets Risk Disclosure, as amended from time to time (together the “Disclosures”).
Connectee does not offer Crypto-assets to the public or seek admission of Crypto-assets to trading on a trading platform. Connectee also does not provide trading, investment, portfolio management or financial advisory services.
You should be aware that the value of Crypto-assets can fluctuate significantly and that there is a substantial risk of losing the entire value of your holdings. By using our Services, you acknowledge and agree that you are aware of the risks associated with transactions in Crypto-assets and will not engage in such transactions beyond your financial capacity and risk tolerance. You also agree that you are solely responsible for all decisions relating to your use of the Services and that you assume full risk of loss unless otherwise provided in these Terms. You are strongly encouraged to seek independent legal, tax and financial advice before engaging in any activity involving Crypto-assets.
Connectee will disclose the information to You in a clear, accurate, and transparent manner, and it will be updated at least monthly. Nothing in these Terms or in the services constitutes, or should be construed as, financial, investment, legal or tax advice.
By clicking “I agree”, “I accept”, “Start” or a similar acknowledgement when prompted, you confirm that you have read, understood and accepted these Terms and the Disclosures. If you do not agree, you must not access or use the Services
These Terms are subject to mandatory legal provisions applicable in your country of residence. Use of certain features may be governed by additional terms and conditions (including those of our partners), which you agree to by using such features.

DEFINITIONS
  1. In these Terms of Use, the following terms shall have the meanings set out below:
Account” means a user account created and maintained with Connectee, which enables you to access and use the Services in accordance with these Terms.
“Abandoned Account” means an Account with a positive Balance due to the Client that meets all of the following conditions: (a) there has been no Qualifying Activity on the Account for a continuous period of twelve (12) months (or a longer/shorter period if required by Applicable Law); and (b) after the period in (a), Connectee has sent at least two (2) notices to the Client’s registered contact details (including in-Account messaging and email) requesting activity and/or confirmation of contact details, and within thirty (30) days from the last notice the Client has either not responded or such communications have been undeliverable, and/or the Client has failed to complete any requested KYC/KYB re-verification within thirty (30) days; and (c) the Account is not subject to a legal hold, court/authority order, sanctions restriction, chargeback/dispute, fraud investigation or any other regulatory constraint that would prevent classification as Abandoned. Where Applicable Law prescribes different dormancy periods, notification steps or unclaimed-property rules, those requirements prevail, and Connectee will apply this definition to the extent permitted by law.
“Qualifying Activity” means a client initiated action on the Account, including: a deposit, withdrawal, on-chain transfer or receipt; placement or execution of a spot exchange order; a transaction using a partner-issued card or a Connectee enabled POS device linked to the Account; or a successful sign-in followed by a confirmation/update of contact details or security credentials. System-generated entries (including fee accruals, interest/airdrop credits, reconciliations or compliance checks) do not constitute Qualifying Activity.
“Balance” means the net amount of eligible Crypto-assets standing to the credit of the Account, less any holds, liens, chargebacks, fees, or other amounts due and payable by the Client under these Terms.
Applicable Law” means any applicable statutes, regulations, regulatory requirements, directives, guidelines, notices, rulings or mandatory codes of conduct issued by any governmental, regulatory or self-regulatory authority having jurisdiction over Connectee or the Services.
Connectee” means Connectee, a private limited liability company incorporated in the Republic of Estonia (registry code 14891451), having its registered office at Narva mnt. 7, 10117 Tallinn, Estonia Estonia.
Exchange Rate” means the exchange rate applied by Connectee for converting between Funds and Crypto-assets, or between different Crypto-assets, taking into account prevailing market conditions, liquidity providers, acquisition costs and operational factors. The Exchange Rate may change at any time, including after an Order has been placed, and may affect the final amount received.
Crypto-asset” means a digital representation of value or rights that is able to be transferred and stored electronically using distributed ledger technology or similar technology.
Custody and administration of Crypto-assets means the safekeeping or controlling, on behalf of clients, of Crypto-assets or of the means of access to such Crypto-assets, where applicable in the form of private cryptographic keys, as defined in Article 3(1)(17) of MiCA.
"Deposit Address" means the unique blockchain address assigned to your Wallet within your Account, through which incoming Crypto-asset transactions are credited to your Account. This address is distinct from Connectee's internal settlement addresses used to execute outgoing transfers.
“Dormant Account” means a client account in which there has been no login, transaction, communication, or any other form of activity for a continuous period of twelve (12) months. Any subsequent client action (such as logging in, updating details, or initiating a transaction) resets the account status back to “Active.” The Company reserves the right to restrict functionality, apply maintenance fees, or initiate account closure procedures for Dormant Accounts, in line with applicable laws, regulatory obligations, and these Terms of Use.
Exchange of Crypto-assets for funds” means the conclusion of purchase or sale contracts concerning Crypto-assets with clients for funds by using proprietary capital, as defined in Article 3(1)(19) of MiCA.
Exchange of Crypto-assets for other Crypto-assets” means the conclusion of purchase or sale contracts concerning crypto-assets with clients for other Crypto-assets by using proprietary capital, as defined in Article 3(1)(20) of MiCA.
Execution of orders for Crypto-assets on behalf of clients” means entering into agreements to buy or sell one or more Crypto-assets on behalf of clients, as defined in Article 3(1)(21) of MiCA.
Funds” has the meaning set out in Article 4(25) of Directive (EU) 2015/2366.
KYC” or “Know Your Customer” means the onboarding and verification procedures carried out by Connectee to establish and verify the identity of Users, in compliance with Applicable Law and Connectee’s internal compliance policies.
KYT” or “Know Your Transaction” means the ongoing monitoring of User transactions to detect suspicious or prohibited activity, in compliance with anti-money laundering and counter-terrorism (the “AML/CTF”) financing regulations.
“Order” means any instruction submitted by you through the Website or other approved channels to purchase, sell, deposit, withdraw or otherwise transact in Crypto-assets using the Services.
Partner” means any third-party service provider or business partner engaged by Connectee in connection with the provision of the Services.
Providing transfer services for Crypto-assets on behalf of clients” means the transfer, on behalf of a client, of Crypto-assets from one distributed ledger address or account to another, as defined in Article 3(1)(26) of MiCA.
“Services” means the Crypto-asset services and additional services provided by Connectee as described in Section 3 of these Terms.
“Safeguarded Funds” means Funds credited in your favour and held exclusively by EU-licensed payment/e-money institution partners in segregated safeguarding accounts under PSD2/EMD, pending settlement to your designated bank account in accordance with these Terms.
“Safeguarded Crypto-asset” means Crypto-assets that are held by Connectee on behalf of its clients and are subject to specific safeguarding obligations in accordance with applicable laws and regulations. Crypto-assets are maintained separately from Connectee own assets and are protected to ensure their return to clients in the event of insolvency or other adverse events. Connectee implements appropriate technical and organizational measures to ensure the security, confidentiality, and integrity of Crypto-assets at all times.
User or client” means any natural or legal person who meets Connectee’s eligibility criteria, accepts these Terms, Disclosures and accesses or uses the Services.
Wallet” means a custodial digital wallet provided by Connectee which enables Users to store, receive and transfer supported Crypto-assets.
Wallet Services means the custody and administration of Crypto-assets and related Services provided by Connectee in connection with a Wallet. Capitalised terms used but not defined in these Terms shall have the meaning given to them elsewhere in these Terms or in the Disclosures or in the Supplementary Terms.

SERVICES
Scope of services
Connectee seeks to obtain authorisation to provide certain Crypto-asset services under the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) (“MiCA”). Subject to such authorisation, these Services consist of:
  1. Custody and Administration of Crypto-assets on behalf of clients;
  2. Exchange of Crypto-assets for Funds;
  3. Exchange of Crypto-assets for other Crypto-assets;
  4. Providing Transfer Services for Crypto-assets on behalf of clients.

The availability of the Services is subject to Connectee’s regulatory status in the relevant jurisdiction. Certain Services may be temporarily unavailable in Estonia and provided via an affiliated EU entity during the suspension period.

Additional services
In addition to the MiCA-regulated Services (subject to authorisation), Connectee intends to provide the following additional services (Schedule 1): Point-of-Sale (POS) terminals enabling businesses to accept payments in Crypto-assets (but not in Funds). Connectee will facilitate the provisioning of Point-of-Sale (POS) Terminals that enable businesses to accept payments in supported Crypto-assets at physical retail locations or in mobile (“on-the-go”) environments. The hardware of such terminals is sourced from independent third-party manufacturers, while Connectee provides the crypto-acceptance software layer that enables transaction processing and settlement in Crypto-assets. Connectee does not itself issue, sell, or maintain POS hardware and shall not be liable for any hardware malfunctions, defects, or interruptions in service resulting from third-party equipment.

Wallet services
Connectee provides custodial Wallet Services, which allow Users to store, receive and transfer supported Crypto-assets. Wallet Services are operated in accordance with Applicable Law and MiCA requirements, including the safeguarding of Users’ assets, segregation from Connectee’s own assets and the implementation of security measures designed to protect the means of access to Crypto-assets.

Orders
Users may place Orders through the Website or other approved channels to purchase, sell, deposit, withdraw, or otherwise transact in Crypto-assets. The submission, execution, amendment, and cancellation of Orders are governed by the rules set out in Section 8. Connectee reserves the right to refuse or cancel any Order that does not comply with these Terms or Applicable Law.

Limitation of Services
Connectee does not offer Crypto-assets to the public, does not seek admission of Crypto-assets to trading on a trading platform and does not provide trading, investment, portfolio management or financial advisory services. Nothing in the Services constitutes investment advice, legal advice, tax advice or any other form of regulated financial service outside the scope of Connectee’s MiCA authorisation.

Service availability
Connectee will make reasonable efforts to ensure that the Services are available on a continuous basis. However, availability may be interrupted by maintenance, security updates, system failures or circumstances beyond Connectee’s control. Connectee may suspend or restrict access to the Services where required by Applicable Law or these Terms.

ELIGIBILITY AND ONBOARDING
To use the Services, you must meet Connectee’s eligibility requirements and complete the onboarding process in accordance with Applicable Law. The Services are not available to everyone and Connectee reserves the right to accept or refuse Users at its discretion, subject to regulatory requirements.
When applying for an Account, you must provide accurate, complete and up-to-date information about yourself (or, where applicable, about your company or organisation) and keep this information updated at all times. Connectee may request documents or additional information at any stage of the relationship to verify your identity, the source of Funds or the purpose of a transaction.
As part of the onboarding process, Connectee will conduct KYC checks and apply ongoing KYT monitoring. During these checks may be required to provide personal information and documentation, such as your name, date of birth, personal identification number, government issued identification, citizenship, residential address, contact details, corporate registration details, beneficial ownership information and other documents necessary for verification according to Applicable law and Connectee’s internal policies. Connectee may also request updated documents during your use of the Services. Connectee may rely on external service providers, databases or screening tools to perform these checks and by accepting these Terms you consent to such use.
In connection with the migration of Users to another entity within the Connectee operational setup during a regulatory transition period, Users acknowledge that additional verification, re-onboarding, or updated information may be required by the receiving entity in accordance with its applicable regulatory and AML/CTF obligations.
By providing this information, you authorise Connectee to collect, use, store and share it in accordance with our Privacy Policy, including retention for up to eight (8) years after termination of the relationship or longer if required by Applicable Law. You further authorise Connectee to carry out necessary investigations directly or through third-party service providers, credit bureaus or government authorities to verify your identity, prevent fraud and comply with AML/CTF obligations.
By registering an Account and using the Services, you represent and warrant that the following statements are true at the time of registration and will remain true for as long as you use the Services:
  1. You are at least eighteen (18) years old, or otherwise of legal age to form a binding contract under Applicable Law;
  2. You have full legal capacity and the necessary authority to enter into these Terms. If you act on behalf of a legal entity, you confirm that you are duly authorised to bind that entity.
  3. You have not previously been suspended or removed from using the Services and you are not attempting to register or use the Services under a different identity.
  4. You are not based, located, or residing in a country or territory that is subject to international sanctions, embargoes or other restrictions, including any jurisdiction listed on Connectee’s restricted or prohibited countries list.
  5. You are not a citizen or resident of the United States of America, and you are not accessing the Services from any location within the United States.
  6. You are not a Politically Exposed Person (PEP), a family member of a PEP, or a close associate of a PEP, unless Connectee has explicitly approved your status through enhanced due diligence.
  7. Your use of the Services does not and will not violate any Applicable Law.
  8. You are not subject to any economic or financial sanctions and your name does not appear on any restricted persons list, including (i) the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List, (ii) sanctions lists issued or adopted by the European Union or the Republic of Estonia, or (iii) any applicable United Nations or United Kingdom sanctions list.
Connectee reserves the right to request additional information or documentation to verify your eligibility and to refuse, suspend or terminate access to the Services if any of the above representations are or become untrue. Connectee may also update its list of restricted or prohibited jurisdictions from time to time. It is your responsibility to review such updates, which will be published on the Website.
Your access to and continued use of the Services is conditional upon the successful completion of Connectee’s onboarding and verification procedures and on your ongoing compliance with these Terms and Applicable Law.

USER RIGHTS AND OBLIGATIONS
When using the Services, you must act honestly, fairly and in accordance with these Terms and Applicable Law. You are responsible for not engaging in activities that violate national or international sanctions imposed by Estonia, the European Union, or other competent authorities.
You may only access and use the Services in your own name and for your own benefit, or, if applicable, on behalf of a legal entity that you are duly authorised to represent. You must not use another person’s identity or allow others to use your Account.
You must ensure that all information and documents you provide to Connectee are accurate, complete and up to date. If your information changes, you must update it promptly. Connectee may request additional information at any time to comply with its legal and regulatory obligations. Failure to provide such information may result in suspension or termination of your Account.
You are responsible for keeping your Account credentials (including usernames, passwords and two-factor authentication codes) secure and confidential. Connectee requires the use of two-factor authentication (2FA) for access to the Services and/or for sensitive actions. You must not share your login details or 2FA devices with anyone.
Security and authentication measures
To protect Accounts, data and transactions, Connectee implements commercially reasonable technical and organisational measures, which may be updated from time to time, including encryption in transit and at rest, mandatory 2FA, role-based access and least-privilege controls, session management and automatic time-outs, audit logging and monitoring, daily integrity-checked backups to preserve data accuracy, and 24/7 monitoring with incident response. We also run vulnerability management and other security controls in line with Applicable Law and industry standards. While we take these measures, no system is infallible; you remain responsible for the security of your devices, networks and credentials.
If you suspect that your Account or credentials have been compromised, you must notify Connectee immediately. You remain responsible for all activity carried out using your Account until Connectee has confirmed receipt of such notice. Connectee may, where necessary, freeze, restrict or require re-verification of your Account to protect you and the platform. Connectee is not liable for losses arising from unauthorised access due to your failure to protect your credentials.
By using the Services, you agree that:
  1. you will follow Connectee’s security and authentication procedures;
  2. you will notify Connectee immediately of any unauthorised use of your Account; and
  3. Connectee may investigate suspected breaches of these Terms and take appropriate action, including freezing or limiting access to your Account, cancelling Orders, reporting to authorities or removing unlawful content.
You must use the Services only for lawful purposes and in accordance with these Terms. Connectee may suspend, freeze or cancel your access if it believes the Services are being misused, accessed by an unauthorised person or used in violation of Applicable Law.
You are responsible for all activity carried out through your Account, whether authorised by you or not. Connectee is not responsible for losses caused by your failure to comply with these obligations.

PROHIBITED USE
You may only use the Services for lawful purposes and in accordance with these Terms. Any use of the Services that is illegal, abusive, fraudulent or contrary to Applicable Law is strictly prohibited. Connectee may suspend, restrict or terminate your access to the Services if it reasonably suspects that you have engaged in Prohibited Use or if it is required to do so by Applicable Law or a competent authority.

Restricted jurisdictions
Connectee does not provide Services to individuals or entities that are located, incorporated or otherwise established in jurisdictions subject to international sanctions or considered high-risk from a compliance, regulatory or reputational perspective.
Users from the following jurisdictions are strictly prohibited from accessing or using the Services, including account creation, transactional activity or business engagement:
  1. Africa: Algeria, Angola, Benin, Burundi, Central African Republic, Chad, Democratic Republic of the Congo (DRC), Djibouti, Equatorial Guinea, Eritrea, Eswatini, Ethiopia, Gabon, Guinea-Bissau, Liberia, Libya, Mali, Madagascar, Mauritania, Morocco, Mozambique, Namibia, Niger, Nigeria, Republic of the Congo, Rwanda, Sao Tome and Principe, Sierra Leone, Somalia, South Sudan, Sudan, Tanzania, Togo, Uganda, Zambia, Zimbabwe;
  2. Asia: Afghanistan, Bahrain, Bangladesh, Cambodia, China, Gaza Strip, India, Iran, Iraq, Jordan, Kuwait, Lao People’s Democratic Republic, Lebanon, Macao SAR, Myanmar, Nepal, North Korea, Oman, Pakistan, Philippines, Syria, Timor-Leste, Turkmenistan, Vietnam, West Bank, Yemen.
  3. Europe: Belarus, Bosnia and Herzegovina, Hungary, Kosovo, North Macedonia, Russian Federation, Ukraine (Occupied Territories: Crimea, Sevastopol, parts of Donetsk, Luhansk, Kherson, and Zaporizhzhia regions), Transnistria.
  4. North America and the Caribbean: Barbados, Cayman Islands, Cuba, Guatemala, Haiti, Honduras, Nicaragua, Puerto Rico, Trinidad and Tobago, Turks and Caicos Islands, United States of America, Virgin Islands (British and U.S.).
  5. South America: Bolivia, Colombia, Ecuador, Guyana, Paraguay, Peru, Suriname, Uruguay, Venezuela.
  6. Oceania: American Samoa, Guam, Kiribati, Marshall Islands, Micronesia, Northern Mariana Islands, Papua New Guinea, Samoa, Solomon Islands, Vanuatu, Wallis and Futuna.
Connectee may update its list of restricted jurisdictions from time to time in response to regulatory developments or internal risk assessments. The updated list will be published on the Website.
  1. Prohibited business activities
The following business types or activities are strictly prohibited from accessing or using the Services:
High-Risk and Unlicensed Financial Services
  • Unlicensed financial institutions (banks, remittance, MSBs, currency exchange houses (casa de cambio), MVTS, Forex, Binary options platforms)
  • Pawnbroking and pledge-based lending institutions
  • Ponzi schemes, pyramid structures, Multi-Level Marketing (MLM) scams, Matrix programs
  • Payment platforms operating from offshore jurisdictions (unlicensed)
  • Crowdfunding platforms (if not registered or transparent)
  • Debt-related services: collection, restructuring, factoring, credit repair
  • Unregistered non-EU/EEA charities, non-profits, or funds
  • Visa or immigration services vulnerable to abuse
  • Residency-/citizenship-by-investment programs (high misuse risk)
  • Unregulated Trust Companies
Crypto Asset-Related High-Risk Activity
  • Mixers, tumblers, or crypto anonymization services
  • Platforms or services used for ransomware or cybercrime funding
  • Crypto asset platforms with no licensing or regulatory clarity (DEXs, mixers)
  • NFT marketplaces (unregulated or used for wash trading)
  • DAO structures without legal personality or accountability
  • Freelancers/influencers receiving anonymous or crypto payments
  • Carbon credits (if unverifiable or unregulated)
Illegal or Prohibited Goods/Services
  • Narcotics, synthetic drugs, drug paraphernalia, pharmaceutical production/trade (with unverified supply chain)
  • Smart drugs, nootropics, pseudo-pharmaceuticals, unlicensed supplements
  • Weapons, defence, semi-military software or services
  • Trade or storage of hazardous chemicals
  • Precious metals or jewellery trade (especially if from conflict areas)
  • Cultural/archaeological artefacts (sculptures, statues, antiques, collector items), historical or religious items, ivory, protected species
  • Wildlife trade or endangered species (with unclear origin)
  • Alcohol or tobacco (if unlicensed or from high-risk countries)
  • Logging, quarrying, extractive industries (solid, liquid, gas)
  • Drift net fishing in the marine environment
  • Dual-Use goods (source)
Human Exploitation and Sexual Abuse
  • Child pornography, pornographic or sexual content involving coercion, minors, trafficking, or non-consensual publication, revenge porn
  • Human exploitation activities (including trafficking, smuggling, organ trade, sex exploitation)
  • Escort, Prostitution services
  • Services related to mail-order brides or matchmaking abroad
  • Dating platforms with anonymity risks
Environmental, Cultural and Ethical Risks
  • Cash-intensive businesses (car washes, nightclubs, scrap yards)
  • Scrap metal trade
  • Real estate with no clear source of funds (SoF)
  • Importers of second-hand vehicles (cash-based + SoF uncertainty)
  • Art dealing, auctions, penny bidding platforms
  • Prize Draws, Gift Cards, Scratch cards
  • Offline gambling forms (horse racing, bingo, sports betting)
  • Unlicensed online gambling, iGaming, betting (casino, poker, lotteries, etc.)
  • Unethical gift/influence practices
  • Bribery (giving or receiving gifts that could be interpreted as undue influence)
Technology, Cybercrime and Data Misuse
  • Abusing confidential or material, non-public information
  • Circumvention/encryption devices used for regulatory evasion
  • Virtual SIM card or spoofing service providers
  • AI systems with Unacceptable Risk (source)
  • Identity fraud, document forgery, fake profiles, fake IDs, fake government profiles or deep fakes
  • Informal value transfer services (hawala, hundi)
  • Escrow services (unlicensed)
  • Counterfeit goods, smuggling
  • Trade in human body parts or pathogens
  • Trade in radioactive or nuclear materials
Connectee may suspend, restrict or terminate your access to the Services if you are found to be associated with any restricted jurisdiction or prohibited business activity listed above.

OUR RIGHTS AND LIMITATION OF LIABILITY
Connectee may, at its discretion, modify, suspend or discontinue any part of the Services at any time if this is necessary for business, operational, legal or regulatory reasons. It may also restrict, freeze, or terminate your access to the Services if you fail to comply with these Terms, with Applicable Law, or with compliance requirements. Connectee further reserves the right to refuse to process or execute any Order if it reasonably believes that the Order is suspicious, unlawful, contrary to these Terms or may expose Connectee to regulatory, financial or reputational risk. In such circumstances, Connectee may freeze or block Funds or Crypto-assets in accordance with Applicable Law or the instructions of competent authorities.
You acknowledge that Connectee does not provide investment, financial, tax or legal advice. Connectee does not provide portfolio management, brokerage or trading services and nothing in the Services or on the Website should be considered as a recommendation to buy, sell or hold any particular Crypto-asset. You remain solely responsible for your decisions and assume all risks associated with the use of the Services.
To the fullest extent permitted by Applicable Law, the Services and any related materials are provided strictly on an “as is” and “as available” basis. Connectee disclaims all warranties of any kind, whether express or implied, including merchantability, fitness for a particular purpose, title, non-infringement, or warranties arising from course of dealing or usage. Connectee does not warrant that the Services, the Website or related content will be accurate, complete, reliable, current, secure, uninterrupted, error-free or free from harmful code. Connectee also does not guarantee that any Order will be executed, accepted, recorded or remain open. You acknowledge and agree that Connectee shall not be liable for losses caused by inaccurate or delayed data, errors in transmission, interruptions from scheduled or unscheduled maintenance, blockchain network delays, forks or protocol changes, actions or omissions of other Users, illegal actions of third parties or other events beyond Connectee’s reasonable control.
To the maximum extent permitted by Applicable Law, Connectee, its affiliates and their respective directors, officers, employees, contractors and agents shall not be liable for any indirect, incidental, special, punitive or consequential losses, including (without limitation) loss of profits, revenue, goodwill, business opportunity or data, whether arising in contract, tort (including negligence), breach of statutory duty or otherwise. Subject to the paragraph below, Connectee’s aggregate liability arising out of or in connection with these Terms or the Services shall not exceed the total fees paid by you to Connectee in the twelve (12) months immediately preceding the event giving rise to the claim. For transactions rejected by Connectee’s compliance controls, Connectee’s liability is limited to the refund of any fees charged by Connectee for that rejected transaction (if any).
Nothing in these Terms excludes or limits liability for: (i) fraud, wilful misconduct or gross negligence; (ii) death or personal injury caused by negligence; (iii) breach of confidentiality or data-protection obligations to the extent such liability cannot be limited under Applicable Law; (iv) misappropriation of, or failure to segregate, client assets due to Connectee’s wilful misconduct or gross negligence; or (v) any other liability that cannot be excluded or limited by Applicable Law. If you are a consumer, your statutory rights are not affected.
You agree to indemnify and hold harmless Connectee, its affiliates, contractors, licensors and their respective directors, officers, employees and agents against any claims, investigations, proceedings, damages, penalties or expenses (including reasonable legal fees) arising out of or in connection with your use of the Services, your breach of these Terms or your violation of any law, regulation or third-party rights, except to the extent caused by Connectee’s fraud, wilful misconduct or gross negligence. Connectee retains the right to control the defence and settlement of any claim for which indemnification is owed and may decide in its sole discretion whether to settle such claim and on what terms.

ORDERS AND TRANSACTIONS
Orders are instructions you submit through the Website or other approved channels to purchase, sell, deposit, withdraw or otherwise transact in Crypto-assets using the Services. By submitting an Order, you authorise Connectee to process it in accordance with these Terms and subject to Applicable Law.
All Orders are subject to operational capabilities, system availability and Connectee’s compliance checks. Once you confirm an Order, Connectee will begin processing without undue delay. The actual execution time may vary depending on blockchain network congestion, market conditions, liquidity availability, third-party service providers or internal compliance procedures, Force Majeure or system maintenance events.
Blockchain based transactions are irreversible once confirmed and network delays, forks or protocol changes may affect execution time or outcomes. Connectee shall make public the price, volume, and time of transactions executed in respect of crypto-assets traded on its platform as close to real-time as is technically possible, in accordance with Article 76(10) of the MiCA Regulation. While Connectee strives to ensure timely execution and transparency, execution times and data publication may be affected by network congestion or other technical factors. Accordingly, Connectee does not guarantee continuous real-time execution or disclosure and shall not be held liable for delays, failures, or losses arising from circumstances beyond its reasonable control.
An Order is deemed completed when one of the following has occurred:
  1. the purchased Crypto-assets have been delivered to your designated Wallet;
  2. the equivalent amount in Funds has been transferred to your verified payment account; or
  3. the Order status is shown as “Completed” within your Account interface.
You are responsible for monitoring the status of your Orders and ensuring that you provide accurate wallet addresses, account details and transaction instructions at the time of submission.
Once submitted and confirmed, Orders are always final and binding. Once such an Order has been confirmed, it cannot be amended or revoked, even if it is still pending execution on the blockchain.
If you wish to request a revocation or amendment, you must immediately contact Connectee via the support channels listed on the Website and provide a clear explanation and any required documentation. Connectee may, at its sole discretion, decide whether to allow the request. If the Order has already been processed, submitted to the blockchain or rendered irreversible, the request will be denied. In cases where an amendment or revocation is exceptionally permitted, additional administrative fees may apply and further verification may be required. Orders to sell Crypto-assets for Funds are always final and cannot be revoked once confirmed.
Refunds are only considered in cases of a proven technical or operational error directly attributable to Connectee. Completed Orders, including blockchain transactions, are final and non-refundable. Refunds will not be issued if incorrect wallet addresses or incomplete details were provided by you, or where suspicious activity is detected.
If Connectee approves a refund, it will be processed only to the original payment source used, never to third-party accounts. Refunds may be subject to administrative fees and will be calculated using the prevailing Exchange Rate at the time of processing. Refunds may also take up to ten (10) business days to settle, depending on your bank or blockchain network.
Chargebacks should not be used as a substitute for direct communication with Connectee. If you initiate a chargeback, Connectee reserves the right to suspend your Account and provide evidence of completed Orders to your financial institution. Connectee may restrict your access to Wallet Services while a chargeback is being investigated.
Connectee applies a minimum transaction threshold for Orders. The current threshold is ten (10) Euros or the equivalent in another supported currency. Orders below this minimum will not be processed. Connectee may adjust the minimum amount at any time, and the applicable threshold will be displayed on the Website or in the Order interface before you submit an Order. It is your responsibility to ensure that any Order meets the minimum requirement.
Connectee may refuse to execute an Order if it reasonably believes that it is suspicious, fraudulent, contrary to these Terms or may expose Connectee to legal, regulatory or reputational risk. Connectee may also delay or block Orders if required by Applicable Law or a competent authority.
The Service Provider reserves the right to restrict, suspend or limit transactions, including deposits and exchanges, where required by Applicable Law, regulatory requirements, entity migration processes, or the temporary suspension of operations in a specific jurisdiction. During such periods, Users may be limited to withdrawal-only functionality.

CUSTODY AND SAFEGUARDING
Connectee provides custodial Wallet Services, which enable you to store, receive and transfer supported Crypto-assets. By using Wallet Services, you authorise Connectee to hold and safeguard your Crypto-assets on your behalf, in accordance with Applicable Law on the safeguarding of client assets.
Connectee will exercise due skill, care and diligence in safeguarding your Crypto-assets. Assets held in custody are kept separate from Connectee’s own assets and are recorded in accounts and records clearly identifying them as belonging to Users. Connectee will not use your Crypto-assets for its own account, lend them out or otherwise dispose of them, except where you have expressly authorised a transfer or withdrawal through the Services.
Your Wallet is custodial in nature. Connectee holds the private cryptographic keys required to access your Crypto-assets. While Connectee implements strict security measures, including encryption, multi-signature protocols and secure storage arrangements, you acknowledge that no system is infallible and that there are inherent risks in holding Crypto-assets in custodial form.
You are responsible for providing accurate Wallet addresses and transaction instructions. Connectee is not liable for losses arising from transfers to incorrect, incompatible, or non-existent addresses provided by you or for unsupported tokens sent to your Wallet. Blockchain based transactions are irreversible and Connectee cannot recover assets once they have been transferred to a third-party address.
When processing outgoing transfers, transactions may be executed from Connectee's internal settlement addresses — operational blockchain addresses managed as part of Connectee's custody infrastructure. These addresses are distinct from your Deposit Address as shown in your Account. Your Deposit Address is the only address through which incoming transactions are credited to your Account. You should not send funds to any address identified from blockchain transaction records relating to Connectee's outgoing transfers. Connectee shall not be responsible for funds sent to internal settlement addresses that are not designated as deposit addresses within the client’s Account. Clients are responsible for ensuring that funds are transferred only to deposit addresses provided within their Account. Where technically feasible, Connectee will use commercially reasonable efforts to recover and return such funds; however, recovery may require additional processing time and cannot be guaranteed in all circumstances.
Connectee may rely on third-party service providers to assist in custody, settlement or safekeeping.
When processing outgoing transfers, transactions may be executed from internal settlement addresses managed by Connectee as part of its custody infrastructure. These addresses are distinct from your personal deposit address displayed in your Account. Your deposit address, as shown in your Account, is the only address through which incoming transactions will be credited to your Account.
Connectee is not liable for funds sent to internal settlement addresses obtained from blockchain transaction records or transaction history. Where technically feasible, Connectee will use commercially reasonable efforts to recover and return such funds; however, recovery is a manual and complex process and may take up to 20 business days or longer depending on the circumstances, including network conditions, security procedures, and third-party dependencies. Recovery is not guaranteed and Connectee does not commit to any specific timeframe. If so, Connectee will take reasonable steps to ensure that such providers meet applicable regulatory and security standards.
Funds and safeguarding via licensed partners. Connectee does not accept deposits or safeguard client Funds on its own account. Where a transaction involves funds (e.g., an exchange to EUR), the Funds leg is provided exclusively by EU-licensed payment/e-money institutions. Any Funds standing to your credit are held by such partners in segregated safeguarded accounts under PSD2/EMD rules. Subject to Applicable Law and any outstanding obligations, Connectee will instruct the partner to return such Funds upon your request or upon termination of the Services. In practice, Connectee does not hold client fiat itself, but keeps transaction and balance records in our system. When You requests a withdrawal or account termination involving fiat Funds, Connectee performs the following steps:
9.1. Verification – The client’s identity, account status, and any pending obligations (e.g., open orders, chargebacks, or compliance holds) are reviewed by the Compliance and Finance teams.
9.2. Instruction to Partner – Once cleared, Connectee sends a formal payment instruction via the partner’s API or secure communication channel (as per the EMI/PSP’s operational protocol), identifying:
  1. The client’s verified IBAN or account details;
  2. The total fiat amount due;
  3. The transaction reference and supporting audit record.
9.3. Settlement Confirmation – The EMI/PSP executes the transfer directly to the client and provides a settlement confirmation. Connectee records this confirmation in the client’s account and updates internal ledgers accordingly.
9.4. Audit Trail – All such instructions are logged in Connectee’s transaction management system and retained in accordance with PSD2/EMD safeguarding recordkeeping requirements.
In the event of Connectee’s insolvency, Safeguarded Crypto-assets by Connectee are intended to remain segregated from Connectee’s estate, subject to Applicable Law and administration costs. Funds (where applicable) are safeguarded by EU-licensed partners and are subject to the partner’s safeguarding and insolvency regime under Applicable Law.
Connectee may impose limits on deposits, withdrawals or transfers for operational, security or compliance reasons. Any such limits will be displayed on the Website or communicated to you directly.

RISKS AND DISCLOSURES
Using the Services and dealing with Crypto-assets involves significant risks. By accessing and using the Services, you confirm that you understand and accept these risks. You should carefully consider your financial situation and risk tolerance before using Crypto-assets or the Services.
The value of Crypto-assets is highly volatile. Prices may change rapidly and without warning and the value of your holdings may decrease significantly or even become worthless. Past performance of any Crypto-asset is not a reliable indicator of future results.
Crypto-assets are not legal tender and are not backed by any government or central bank. They are not covered by deposit protection or investor compensation schemes in the European Union, Estonia or any other jurisdiction.
Transactions in Crypto-assets are irreversible once confirmed on the blockchain. If you provide an incorrect Wallet address or other inaccurate details, your assets may be permanently lost. Connectee cannot recover Crypto-assets transferred to incompatible or non-existent addresses.
There are technological risks associated with Crypto-assets. These include cybersecurity threats, fraud, hacking, malware and vulnerabilities in smart contracts or blockchain protocols. Network congestion, forks or changes in the underlying technology may delay or disrupt transactions.
Custody of Crypto-assets also involves risks. While Connectee applies strict security and segregation measures, no system is completely secure. There is a risk of loss arising from technical failures, operational issues, insolvency of third-party custodians or other events beyond Connectee’s reasonable control.
Regulatory and legal risks also apply. The laws and regulations governing Crypto-assets are evolving and may change unexpectedly. New restrictions, reporting obligations or bans could affect the availability, legality or value of the Services and Crypto-assets.
You should not use the Services or hold Crypto-assets unless you can bear the risk of full loss. You are strongly encouraged to obtain independent legal, tax and financial advice before using the Services.
Safeguarded Funds held by EMI/PSP Partners are protected by segregation rules under PSD2/EMD.

FEES
Connectee charges fees for the use of the Services. The applicable fees are set out in the Fee Schedule, which is published on the Website and updated from time to time. By using the Services, you agree to pay all fees associated with your transactions in accordance with the Fee Schedule in effect at the time of the transaction.
All applicable charges, commissions and other potential costs are disclosed to you before you confirm a transaction. The Fee Schedule includes details of service fees, transaction fees for deposits, withdrawals and exchanges, as well as any third-party fees that may apply. It also specifies when and how fees will be deducted from your Account or from the amounts transferred in connection with your Orders.
Connectee may apply a Exchange Rate to determine the value between Funds and Crypto-assets, or between different Crypto-assets. The Exchange Rate takes into account market prices, liquidity, acquisition costs and operational factors. It may differ from rates available on public exchanges and may change between the time an Order is placed and the time it is executed.
If your Account holds a positive Balance but remains inactive for twelve (12) consecutive months, Connectee may apply a Dormant Account fee as indicated in the Fee Schedule. Prior to charging a fee, we will make reasonable efforts to contact you using your registered contact details. Dormant/Abandoned status, related fees, restoration mechanics and potential closure are governed by Section 11A (Dormant and Abandoned Accounts).
In addition to Connectee’s fees, your transactions may be subject to external costs, including blockchain network fees or charges imposed by third-party payment service providers or banks. These costs are outside Connectee’s control and remain your responsibility.
All fees and charges will be shown to you prior to confirmation of a transaction. By confirming the transaction, you accept the fees as disclosed. Fees are generally deducted from the amount of Funds or Crypto-assets you receive, unless otherwise specified.
Connectee may amend its fees from time to time. Changes will be published on the Website and, where required by Applicable Law, notified to you in advance. Continued use of the Services after the effective date of a fee change constitutes your acceptance of the updated fees.
It is your responsibility to review the Fee Schedule regularly and ensure that you understand the fees that apply to your transactions. If you do not agree with any fee, you should not use the Services.
Settlement to bank accounts may be subject to payout fees or partner charges as set out in the Fee Schedule; any such fees are disclosed prior to confirmation.

11A. Dormant and Abandoned Accounts
Dormant Accounts. An Account becomes Dormant if there is no Qualifying Activity for a continuous period of twelve (12) months. While an Account is Dormant, we may apply a Dormant Account fee of EUR 100 (one hundred euros) per calendar month or the equivalent in another supported currency. This fee will be deducted from the Account Balance on a monthly basis until the Balance reaches zero or the Account is restored to Active status. The fee is non-refundable and will be applied only after we have provided at least two (2) prior notices to the Client. If you do not take action within thirty (30) days of the last attempted contact, Connectee may begin applying the Dormant Account fee until the balance is fully depleted. Once the Account balance reaches zero, the Account may be permanently closed. All collected Dormant Account fees are transferred into a dedicated internal account to cover potential refund claims.
Abandoned Accounts. A Dormant Account may be classified as Abandoned if the Client remains unresponsive to notifications and required verification requests. We may apply a monthly Abandoned Account fee and deduct any reasonable costs incurred by us in managing the Abandoned Account. The amount and any applicable cap for the Abandoned Account fee are set out in the Fee Schedule.Schedule. The Abandoned Account fee and such costs will be deducted from the Account Balance.
Restoration. A Dormant or Abandoned Account will be restored to Active status once the Client performs a Qualifying Activity and, where requested, updates contact details and/or completes KYC/KYB re-verification. Fees and/or costs already deducted prior to restoration are non-refundable, but no further Dormant/Abandoned fees will accrue from the date of restoration.
Legal Precedence. Where Applicable Law prescribes different dormancy periods, notification steps, fee limitations or unclaimed-property/escheat requirements, such requirements prevail. We will not levy Dormant/Abandoned fees where prohibited. Where required, we may transfer remaining eligible Funds/crypto-assets to a competent public authority or otherwise handle them as mandated by law.
Notices under this Section will be sent in accordance with the Section 17 of the Terms. If messages are undeliverable due to outdated contact details or Client’s mailbox settings, the notice shall be deemed delivered when we have used the contact details last provided by the Client.
Accounts subject to a legal hold, court/authority order, sanctions restriction, chargeback/dispute, fraud investigation or other binding regulatory constraint will not be classified as Abandoned and will be handled in line with Applicable Law and these Terms (including our rights to suspend, restrict or terminate).


DATA PROTECTION AND PRIVACY
Connectee processes personal data in accordance with Regulation (EU) 2016/679 (the “GDPR”), the Law on Legal Protection of Personal Data of the Republic of Estonia and other Applicable Law.
When you apply for an Account or use the Services, Connectee may collect and process personal information including your name, date of birth, personal identification number, citizenship, residential address, contact details, corporate registration and beneficial ownership information, government issued identification and transaction data. This information is necessary to provide the Services, to comply with legal and regulatory obligations.
Connectee also processes information relating to your use of the Services, including wallet addresses, deposit and withdrawal details, transaction history and exchange activity. This data is used to operate and maintain the Wallet Services and exchange functions, to prevent fraud and abuse and to comply with Applicable Law.
Your personal data may be shared with third-party service providers acting on behalf of Connectee, such as identity verification providers, custodians, payment processors and compliance screening partners. Connectee may also disclose information to competent authorities, regulators or law enforcement agencies where required by law.
Personal data will be retained for as long as you maintain an Account with Connectee and for up to eight (8) years after the end of the relationship, or longer where required by law.
You have the right to request access to your personal data, rectification or erasure of inaccurate data, restriction of processing, portability of your data and to object to certain forms of processing, as provided under the GDPR. You also have the right to lodge a complaint with the State Data Protection Inspectorate in Estonia (https://vdai.lrv.lt/en/)
Connectee applies appropriate technical and organisational measures to ensure the confidentiality, integrity and security of your personal data. While Connectee takes reasonable steps to protect information, you acknowledge that no system can be guaranteed to be fully secure.
Further details on how Connectee processes and protects your personal data are set out in the Privacy Policy, which forms part of these Terms.
During periods of regulatory transition or entity migration, personal data may be jointly controlled by Connectee and CONNECTEE OÜ, in accordance with Article 26 of the GDPR, as further described in the Privacy Policy.
COMPLAINTS AND DISPUTE RESOLUTION
Connectee has established a Complaints Handling Policy under Applicable acts.
If you wish to submit a complaint, you may do so free of charge using the contact details provided on the Website and as indicated in the Complaints Handling Policy. Complaints will be handled fairly, promptly and in line with Connectee’s internal procedures.
Further details on how complaints are received, assessed and resolved are set out in the Complaints Handling Procedure.
This procedure does not affect your right to escalate the matter to the Bank of Estonia or to pursue judicial remedies available under governing law.

TERMINATION
You may terminate your relationship with Connectee at any time by closing your Account and discontinuing use of the Services. Account closure requests must be submitted through the channels indicated on the Website. You may submit a closure request via the in-Account “Close Account” function or by emailing support@connectee.io from your registered email address. Termination by you shall not affect the validity of any transactions already executed, nor shall it release you from any obligations incurred prior to termination.
Connectee may suspend, restrict or terminate your access to the Services at its discretion, subject to Applicable Law, including where:
  1. you breach these Terms or fail to comply with Applicable Law;
  2. your eligibility status changes and you no longer meet the requirements set out in Section 4;
  3. Connectee reasonably suspects that your Account is being used for unlawful, fraudulent or prohibited purposes;
  4. you are located in or associated with a jurisdiction subject to sanctions, restrictions or prohibited business activities listed in Section 6; or
  5. Connectee is required to do so by law, regulation or the order of a competent authority.
Upon termination, Connectee will take reasonable steps to return any remaining eligible Funds or Crypto-assets to you, subject to Applicable Law, including AML/CTF financing requirements.
You may be required to provide updated information or documents before any withdrawal can be processed. Connectee may withhold, freeze or deduct amounts where necessary to comply with legal obligations, enforce these Terms or cover any fees, charges or liabilities owed.
Termination of your Account shall not affect provisions of these Terms which, by their nature, are intended to survive termination, including but not limited to those relating to liability, indemnification, data protection, governing law and dispute resolution.
Connectee shall not be liable for any losses or damages resulting from the suspension or termination of your access to the Services, provided such action is taken in accordance with these Terms and Applicable Law.
Closure of Abandoned Accounts and related fees are governed by Section 11A (Dormant and Abandoned Accounts).

AMENDMENTS TO THE TERMS
Connectee may amend or supplement these Terms from time to time to reflect changes in its business, technology, regulatory requirements or other relevant circumstances. The most recent version of the Terms will always be available on the Website.
Unless otherwise required by Applicable Law or by an order of a regulator or court, amendments shall take effect no earlier than thirty (30) days after publication on the Website. You will be deemed to have accepted the revised Terms if you continue to access or use the Services after this notice period.
In certain circumstances, changes may take effect immediately without prior notice, including where they:
  1. are required to comply with Applicable Law, regulatory requirements, or decisions of competent authorities;
  2. correct errors or clarify provisions without adversely affecting your rights;
  3. update contact details or references; or
  4. otherwise make the Terms more favourable to you.
Connectee may notify you of amendments by email or other appropriate means, but you are responsible for reviewing the Website regularly for the latest version. If you do not agree to any amendment, without incurring any penalties or additional Fees. If the client continues using Connectee services after the 30-day notice period, Connectee will consider that the client have accepted the amendments, and they will apply to the client from the effective date specified in the notice.
Previous versions of the Terms will be retained by Connectee and may be made available upon request.

EVENT OF DEATH
In the event of your death, the representative of your estate or other authorised legal successor must notify Connectee in writing without undue delay. Connectee may require supporting documentation, such as a death certificate, proof of authority and any inheritance or estate tax documents, before taking action in respect of the Account.
Upon receipt of proper notification and documentation, Connectee will suspend the Account, cancel any pending Orders, and take measures to safeguard the assets held. Connectee may, at its discretion, restrict transactions or retain a portion of the assets in the Account if necessary to protect against potential liabilities, claims or tax obligations.

Connectee may close the Account and transfer the remaining assets to the authorised representative of the estate in accordance with Applicable Law. The estate shall remain liable for any outstanding obligations, fees or losses arising from the Account, including transactions initiated before Connectee received notice of death.
Until Connectee receives valid notice and documentation, it may continue to process transactions in accordance with these Terms and Connectee shall not be liable for any losses incurred as a result.

COMMUNICATION AND NOTICES
All communications between you and Connectee relating to your Account or the Services will be conducted in English, unless otherwise required by Applicable Law. Any translation provided is for convenience only and in case of inconsistency the English version shall prevail.
The primary way Connectee will communicate with you is electronically. This means that important information, including updates to these Terms, confirmations of transactions or notices regarding your Account, will be provided through the Website and in-Account messaging, or sent to the email address you have registered with Connectee.
By opening an Account and using the Services, you agree to receive such communications electronically. You are responsible for keeping your contact details, including your email address and phone number, accurate and up to date. Connectee will not be liable if you miss an important communication because you failed to update your information or did not check your messages.
Communications will be considered delivered once they are made available on the Website or sent to your registered email address, regardless of whether you have read them.
Where a Estonian translation is provided for regulatory or client-communication purposes, in case of inconsistency the English version shall prevail, unless Applicable Law requires otherwise.

GOVERNING LAW AND JURISDICTION
These Terms and any dispute or claim arising out of or in connection with them, including any non-contractual obligations, shall be governed by and construed in accordance with the laws of the Republic of Estonia.
The courts of Estonia shall have exclusive jurisdiction to settle any dispute or claim arising from or relating to these Terms, your Account or your use of the Services, without prejudice to any rights you may have under Applicable Law to bring a claim in the courts of your place of residence.
Nothing in this section limits Connectee’s right to initiate proceedings against you in any other jurisdiction where you may be subject to legal action, particularly for the enforcement of judgments or to seek urgent interim relief.

MISCELLANEOUS
If any provision of these Terms is found to be invalid, illegal or unenforceable by a competent authority, the remaining provisions shall remain valid and enforceable.
Failure or delay by Connectee in exercising any right or remedy under these Terms shall not constitute a waiver of that right or remedy. Any single or partial exercise of a right or remedy shall not prevent further exercise of that or any other right or remedy.
These Terms constitute the entire agreement between you and Connectee regarding the Services and supersede any prior discussions, agreements or understandings between you and Connectee in relation to the same subject matter.
The headings in these Terms are for convenience only and shall not affect their interpretation. Words in the singular shall include the plural and vice versa, unless the context requires otherwise. References to “including” or “such as” shall mean “including without limitation.”

CONTACT INFORMATION
If you have any questions about these Terms or the Services, you may contact Connectee using the details below:
Connectee
Address: Narva mnt. 7, 10117 Tallinn, Estonia.
Email: office@connectee.io

Connectee will use the contact details you provide in your Account for all official communications unless otherwise required by Applicable Law.
Connectee OÜ is a regulated VASP with license number FVT000019 issued on May 20, 2020 by the Estonian Financial Intelligence Unit

Estonia, Tallinn, Kesklinna linnaosa,
Narva mnt 7, 10117

Company Registration Number:
[ 14891451 ]