Terms of Use

1. Definitions

The following definitions apply throughout these Terms:

• “Tirnu, we, us or our” means TIRNU GmbH, Grabenstrasse 8, 6300 Zug, Switzerland, registration number CHE-283.006.722.
• “Terms” means these Terms of Use and any amendments that have taken effect in accordance with Section 13.
• “Platform” means the Tirnu website, mobile application and associated interfaces through which Services are made available.
• “User, you or your” means the individual accessing the Platform or registering to use the Services.
• “Account” means your registered account through which you access available Services, submit Instructions and view account information.
• “Services” means the services actually made available to an eligible User through the Platform. References to Planned Services do not establish present availability.
• “Digital Assets” means cryptocurrencies and other blockchain-based tokens supported by the Platform. This term does not imply that an asset is legal tender, a bank deposit or a financial instrument of any particular legal classification.
• “Supported Asset” means a Digital Asset expressly identified as available for a particular function. Trading support does not necessarily include deposits, withdrawals, transfers or Swaps.
• “Supported Network” means a blockchain network expressly identified by the Platform as available for a particular asset and transaction type.
• “Fiat Currency” means a government-issued currency, such as Swiss francs or euros. A token referencing a Fiat Currency remains a Digital Asset and is not itself that Fiat Currency.
• “Wallet Services” means enabled functionality for holding, receiving, transferring or swapping Supported Assets.
• “Custody” means an arrangement under which Digital Assets, or the means of accessing or transferring them, are held or controlled on your behalf by Tirnu or an applicable custody provider, subject to the relevant disclosures and Service-Specific Terms.
• “Instruction” means an order, authorisation or request you submit through the Platform, including a request to purchase, sell, swap or transfer a Supported Asset.
• “Swap” means an exchange of one Supported Asset for another using available Platform functionality.
• “Quote” means a displayed price or exchange rate for a proposed transaction. The transaction interface identifies whether it is indicative or executable and any validity period.
• “Network Fee” means a charge associated with processing a blockchain transaction, separate from Tirnu’s service fees unless expressly stated otherwise.
• “Market Data” means prices, quotations, charts, trading information and related market information displayed through the Platform.
• “Analytical Tools” means research, charting, signals and information-processing tools, including functionality using artificial intelligence.
• “Recurring Investment Instruction” means your authorisation to request purchases of a Supported Asset at specified intervals, where this functionality is enabled.
• “Portfolio Information” means displayed holdings, estimated valuations, transaction history and related account information.
• “Content” means text, data, graphics, Market Data, analytical outputs and other information available through the Platform.
• “Third-Party Provider” means an external provider supporting or delivering a Service, including custody, liquidity, execution, payment, technology and Market Data providers.
• “Planned Services” means features described as Coming Soon, planned or otherwise unavailable, including stock trading, fractional share investing and exchange-traded fund (ETF) trading.
• “Service-Specific Terms” means additional contractual terms expressly identified as applicable to a Service and made available before use. Any intended precedence over these Terms must be stated expressly, subject to mandatory applicable law.
• “Applicable Law” means laws, regulations and binding requirements applicable to the relevant party, activity or transaction.
• “KYC and AML” means know-your-customer verification and anti-money laundering measures, including applicable counter-terrorist-financing and sanctions controls.

2. Eligibility

To use the Tirnu Platform, you must meet the following requirements:

Tirnu may refuse registration or restrict access where eligibility requirements are not met, information is false or incomplete, or access would conflict with applicable obligations. Do not use intermediaries or technical means to circumvent jurisdiction restrictions.

3. Our Services

3.1 Current Scope and Eligibility

Tirnu provides cryptocurrency trading and related Digital Asset Services to eligible Users. Availability depends on your jurisdiction, verification status, Account permissions and applicable legal or operational restrictions.

Only functionality expressly enabled in your Account is available for use. A description in these Terms or elsewhere on the Platform does not establish that a feature is available to every User.

3.2 Cryptocurrency Trading

You may submit Instructions to purchase, sell or exchange Supported Assets. Any reference to more than 50 Digital Assets describes the offering at the relevant time and does not guarantee continued support for any particular asset or minimum number of assets.

Before confirmation, review the asset, amount, Quote, fees and transaction conditions displayed. An indicative Quote may change before execution. Submission of an Instruction does not establish that a transaction has executed; refer to its status and confirmation in your Account.

Execution may depend on liquidity, price movements, limits, verification and system or Third-Party Provider availability. Tirnu does not guarantee execution at an indicative price. The relevant interface and Service-Specific Terms identify Tirnu’s role and any provider involved.

Cancellation is available only if supported for the relevant transaction and before the applicable processing stage. An executed transaction cannot be cancelled solely because market conditions have changed.

3.3 Custody and Wallet Services

Where enabled, Wallet Services support the holding, receipt, transfer and Swap of Supported Assets. Custody may involve Third-Party Providers and is governed by the applicable custody disclosures and Service-Specific Terms.

Before using Custody, you must be provided with the relevant arrangements, including the custody provider’s identity and role, how holdings are recorded, withdrawal conditions and treatment of assets in insolvency. These Terms alone do not establish asset segregation, insurance or a particular insolvency entitlement.

References to institutional custody describe the infrastructure used; they do not imply deposit protection or a guarantee against loss. A displayed balance does not necessarily correspond to an exclusive blockchain address controlled by you.

3.4 Deposits, Withdrawals and Transfers

Use only the Supported Asset and Supported Network identified for the transaction. Verify the destination address, network, amount and any memo, tag or other required identifier before submission. Incorrect or incomplete details, or use of an unsupported network, may cause permanent loss.

Recovery may be technically impossible and is not guaranteed. Where recovery assistance is possible, associated conditions and charges will be disclosed before you accept that assistance.

Transfers may be delayed by network congestion, confirmation requirements, security checks or compliance obligations. Blockchain submission may make a transaction irreversible. Network Fees may apply.

Tirnu may request information about the recipient, beneficial owner, source of funds or purpose of a transaction where necessary to meet applicable obligations.

3.5 Digital Asset Swaps

Where enabled, you may exchange one Supported Asset for another. Each Swap is subject to its displayed Quote, fees, limits and available liquidity. Review the expected amount received before confirming.

A Swap may involve Third-Party Providers or intermediate processing steps. Material execution conditions must be disclosed in the relevant interface or Service-Specific Terms.

3.6 Market Data and Analytical Tools

Where enabled, the Platform provides pricing, charts, signals and AI-assisted Analytical Tools for Supported Assets. Information may originate from Third-Party Providers and may be delayed, incomplete or inaccurate. Real-time labelling does not guarantee instantaneous or uninterrupted updates.

AI outputs can contain errors, omit material facts or reflect outdated information. Verify material information independently. These tools do not authorise discretionary investment decisions on your behalf and do not guarantee outcomes. Section 7 applies.

3.7 Recurring Investments

Where expressly enabled, you may select a Supported Asset, amount and frequency for a Recurring Investment Instruction. You must maintain sufficient available funds. Each purchase is subject to the fees and execution conditions applicable when processed.

The Platform identifies amendment and cancellation procedures and any processing deadline. Cancellation does not reverse an executed transaction. Purchases may fail or be delayed because of insufficient funds, asset unavailability, compliance restrictions or technical issues; monitor your confirmations.

Recurring investing, including dollar-cost averaging, does not remove investment risk or guarantee profit. Recurring investments in stocks or ETFs are not currently available.

3.8 Portfolio Information

The Platform may display Supported Asset holdings, transaction records and indicative valuations. Estimated values can differ from executable prices or withdrawal proceeds because of market movements, spreads, fees, liquidity and update timing.

Portfolio Information is not a tax calculation or certification of an asset’s legal or tax treatment. Current functionality relates to Digital Assets. Consolidated tracking of stocks and ETFs is a Planned Service.

3.9 Stock Trading and Fractional Shares — Coming Soon

Stock trading and fractional share investing are not currently available. Tirnu may introduce selected listed equities and fractional share interests, subject to applicable permissions, provider arrangements and operational readiness.

Before launch, separate disclosures and terms will identify providers, execution, custody, fees and investor rights. For fractional interests, they will explain legal structure, transferability, voting rights, dividends and corporate actions. No stock Instruction can be placed until the Service is expressly made available.

3.10 ETF Trading — Coming Soon

ETF trading is not currently available. Any future offering will be subject to applicable permissions, provider arrangements, eligibility requirements and Service-Specific Terms.

Relevant fund information, execution and custody arrangements, charges and required product disclosures will be provided before you can transact.

3.11 Status of Planned Services

Descriptions of Planned Services are informational and do not constitute an offer to transact in the relevant instruments. Coming Soon does not establish a launch date, guarantee introduction or create an entitlement to access.

Tirnu may revise or discontinue a planned feature. Any launch will be communicated separately and may require acceptance of additional terms.

3.12 Regulatory Scope

Tirnu’s VQF affiliation concerns its obligations under the Swiss anti-money laundering framework. It does not, by itself, authorise banking, securities, fund management or other separately regulated activities.

These Terms do not indicate that FINMA or VQF has approved a Digital Asset, endorsed an investment or guaranteed User assets. Services requiring additional permissions or regulated provider arrangements will be introduced only after the applicable requirements are satisfied.

3.13 Service Restrictions and Changes

Tirnu may restrict or suspend a Service, Supported Asset or Supported Network where reasonably necessary for legal compliance, security, maintenance or material operational risk management.

Where reasonably practicable and legally permitted, Tirnu will notify affected Users and explain available steps, including any withdrawal or conversion arrangements. Actions remain subject to Applicable Law and notice requirements in these Terms.

4. Your Account

4.1 Registration

Register an Account and complete the required verification before accessing restricted Services. Provide accurate, complete and current information and update it when it changes. Registration does not guarantee acceptance or access to every Service.

4.2 Account Security

Take reasonable steps to protect your credentials, devices and Account. You must:

• Use a strong, unique password and keep credentials confidential.
• Enable two-factor authentication where available.
• Notify compliance@tirnu.com promptly if you suspect unauthorised access or activity.
• Do not share access or allow another person to transact through your Account without Tirnu’s express authorisation.

We may restrict access while investigating a security concern. Responsibility for disputed activity will be assessed under Applicable Law and the relevant circumstances; use of credentials alone does not automatically establish that you authorised a transaction.

4.3 One Account Per Person

Only one personal Account is permitted unless Tirnu expressly agrees otherwise. Duplicate Accounts may be restricted while their purpose and ownership are verified.

4.4 Verification and Monitoring

You must provide information reasonably requested to verify identity, beneficial ownership, source of funds, source of wealth or transaction purpose and to support AML and sanctions obligations. Verification may be ongoing. Missing or inadequate information may result in restrictions or closure, subject to Applicable Law.

4.5 Records and Notifications

Review your Account records and report suspected errors promptly with relevant details. Keep contact information current. Reporting procedures do not limit mandatory rights or statutory time limits. Personal information is handled as described in the applicable Privacy Policy.

5. Acceptable Use

5.1 Permitted Use

Use the Platform only for lawful personal Digital Asset transactions and financial management within the Services available to you. Any business use or authorised access by another person requires separate agreement where applicable.

5.2 Prohibited Activities

• Fraud, deception, market manipulation, wash trading or abusive trading practices.
• Money laundering, terrorist financing, sanctions evasion or other unlawful activity.
• Accessing another User’s Account or circumventing eligibility, verification or transaction controls.
• Using unauthorised bots, scripts or automated access, except functionality expressly enabled by Tirnu.
• Interfering with system security, introducing malicious software or extracting source code except where mandatory law permits.
• Infringing intellectual property, privacy or other legal rights.
• Harassing, threatening or abusing Users or staff.

Suspected violations may lead to proportionate restrictions, investigation or termination. Tirnu may report matters to competent authorities where required or permitted by law.

6. Investment Risk

Before transacting, consider your financial circumstances, objectives, ability to bear losses and the following risks:

• Market and liquidity risk: you may be unable to transact at an expected price or when desired.
• Technology and network risk: cyberattacks, software failures, congestion, forks and protocol changes can affect assets and transactions.
• Custody and provider risk: security incidents or provider insolvency may affect access to or recovery of assets; legal treatment depends on the actual custody arrangements.
• Stablecoin risk: a token linked to a currency or other reference can lose its peg or face redemption restrictions.
• Regulatory risk: changes in law or classification may restrict trading, transfers or continued support.
• Protection limitations: Digital Assets are not bank deposits. Do not assume deposit insurance, compensation coverage or insurance applies; any protection must be expressly identified in the applicable disclosures.
• Transfer risk: incorrect addresses or networks and irreversible transactions can cause permanent loss.

Stock and ETF trading are Coming Soon. Product-specific disclosures will apply if those Services are introduced. Seek independent professional advice if you are uncertain whether a transaction is appropriate.

7. No Investment Advice

Market Data, signals, charts and AI-generated outputs provide general information and may be inaccurate or incomplete. They do not create an advisory relationship, constitute a personal recommendation or guarantee investment performance.

Assess material information independently and seek qualified advice where appropriate. Tirnu’s contractual role and that of any Third-Party Provider are determined by the relevant Service-Specific Terms. Describing the Platform as technology does not exclude obligations arising from activities actually performed.

8. Fees & Charges

8.1 Cryptocurrency Trading and Swap Fees

The cryptocurrency fee rates stated in these Terms are:

• Cryptocurrency trading: 0.5% commission on the transaction value.
• Digital Asset Swaps: 0.5% of the transaction value.

The applicable fee and calculation basis must be displayed before confirmation. These commissions do not imply that all additional costs are included. Any spread or conversion charge forming part of the price must also be disclosed.

8.2 Other Charges

Additional charges may include disclosed currency-conversion costs, Network Fees and supported optional processing charges. Where a Network Fee cannot be determined precisely in advance, its estimated amount and calculation method will be identified. No undisclosed optional charge will be imposed merely because it is mentioned as a possibility here.

8.3 Fee Changes

Tirnu will provide at least 30 days’ advance notice of material changes to its service fee rates by email and through the Platform. Market prices and external Network Fees fluctuate and are not fixed Tirnu fee rates. No change applies retrospectively to an executed transaction.

8.4 Taxes

You are responsible for assessing and meeting applicable tax obligations, subject to any withholding or reporting obligations imposed on Tirnu. Portfolio Information does not constitute tax advice. Consult a qualified adviser where necessary.

9. Intellectual Property

Platform Content, software, branding and technology are owned by Tirnu or its licensors. Subject to these Terms, you receive a limited, non-exclusive, non-transferable licence to access the Platform for permitted personal use.

Do not reproduce, distribute, exploit or modify protected materials without permission, except where Applicable Law permits. This clause does not prevent you from retaining your own transaction records or using information as necessary to exercise your legal rights.

Third-party materials remain subject to their owners’ rights and any disclosed licence conditions. Termination of access does not transfer ownership of Platform materials.

10. Limitation of Liability

10.1 Availability and Information

Tirnu does not guarantee uninterrupted operation or error-free informational Content. Network outages, maintenance, provider failures and market disruptions can affect availability. These limitations do not remove duties imposed by Applicable Law or expressly undertaken in Service-Specific Terms.

10.2 Liability

To the extent permitted by Applicable Law, Tirnu is not responsible for losses caused solely by market movements, your investment decisions, or events outside its reasonable control for which it bears no legal responsibility. Limitations concerning informational Content do not excuse a failure to perform contractual obligations where liability cannot lawfully be excluded.

To the extent lawful, liability for indirect or consequential loss, including lost profits or business opportunity, is excluded. Nothing excludes or limits liability for unlawful intent, gross negligence, or any other liability that cannot be excluded under Applicable Law, including mandatory consumer protections.

10.3 Claims Arising from Your Breach

To the extent permitted by law, you may be responsible for reasonable, documented losses and third-party claims caused by your unlawful conduct or breach of these Terms. This does not require you to compensate Tirnu for its own fault or liabilities that cannot lawfully be transferred to you. Any claim must account for causation, mitigation and applicable legal protections.

11. Termination

11.1 Closure by You

You may request Account closure at support@tirnu.com. Pending transactions, outstanding obligations and remaining balances must be addressed before final closure. Tirnu will process closure requests within 10 business days where these matters and required checks have been completed; otherwise it will explain outstanding steps where legally permitted.

11.2 Restrictions or Closure by Tirnu

Tirnu may restrict or close an Account for a material breach, required legal action, reasonable suspicion of unlawful activity, unresolved security concerns or failure to maintain required verification. Immediate action without prior notice may be necessary for legal or security reasons.

Where closure follows a commercial decision to discontinue a Service rather than an urgent legal or security issue, Tirnu will provide reasonable advance notice and instructions for handling remaining assets where practicable.

11.3 Remaining Assets and Records

Closure does not itself transfer ownership of your assets to Tirnu. Subject to legal restrictions, outstanding obligations and necessary checks, Tirnu will provide reasonable assistance to withdraw or otherwise resolve remaining balances. Withdrawal procedures, applicable fees and any technical limitations will be communicated.

Restrictions required by law may prevent immediate release of assets. Transaction records and personal data may be retained for legally required periods. Provisions intended by their nature to survive closure remain applicable.

12. Governing Law & Dispute Resolution

12.1 Governing Law

These Terms are governed by substantive Swiss law, excluding conflict-of-law rules, without prejudice to mandatory protections applicable in your country of residence.

12.2 Complaints and Disputes

Contact compliance@tirnu.com with complaints or disputes, providing sufficient details for investigation. Seeking an informal resolution does not prevent you from exercising legal rights or contacting competent authorities.

Subject to mandatory jurisdiction rules, the courts of Zug, Switzerland, have jurisdiction. Any mandatory right to bring proceedings elsewhere, including consumer rights, remains unaffected.

12.3 Mandatory Rights and Severability

Mandatory Applicable Law prevails over conflicting provisions. If a provision is invalid or unenforceable, the remaining provisions continue to apply to the extent legally possible.

13. Changes to These Terms

Tirnu may amend these Terms to reflect changes in Services, operational arrangements or legal requirements. Material changes will normally be notified at least 30 days before their effective date by email and through the Platform. If binding law requires an earlier change, Tirnu will explain the reason and notify you as soon as legally permitted.

Notices will identify the changes, effective date and available options. Acceptance and any effect of continued use will be determined in accordance with Applicable Law; where express acceptance is required, Tirnu will obtain it.

If you do not accept a change, you may stop using the affected Service and request closure or withdrawal under Section 11. Amendments do not retrospectively alter executed transactions or accrued rights. Launch of a Planned Service may require separate acceptance of Service-Specific Terms.

14. Contact

For questions about these Terms, complaints, security concerns or Account assistance, use the contacts below. Include relevant transaction or Account references, but never send passwords or private keys.