Risk Warning

1. Important warning

Coinbar s. r. o. ("Coinbar") is a crypto-asset service provider supervised by Národná banka Slovenska (NBS). It provides custody and administration of crypto-assets on behalf of clients, exchange of crypto-assets for funds or for other crypto-assets on its own account ("Coinbar Direct") and transfer services for crypto-assets on behalf of clients. Before you use these services, keep the following in mind:

• You can lose all the money you use to buy crypto-assets. Only use money you can afford to lose entirely.

• Crypto-assets are not covered by the Deposit Protection Fund (Fond ochrany vkladov; zákon č. 118/1996 Z. z. o ochrane vkladov) or by the Investment Guarantee Fund (Garančný fond investícií; zákon č. 566/2001 Z. z. o cenných papieroch a investičných službách). This also applies to the e-money tokens USDC and EURC.

• Coinbar's authorisation under MiCA does not mean that crypto-assets are safe or that their value is protected. Crypto-assets are not legal tender, and no central bank or public authority guarantees their value.

• The value of crypto-assets can fall sharply within a very short time, even to zero. Past performance is not a reliable indicator of future results.

• Coinbar does not give investment advice or personalised recommendations. Every decision to buy, sell, hold or transfer crypto-assets is yours alone.

Read the pre-contractual information, the Fee Schedule and this risk warning before every exchange. The price, the spread, the commission and the resulting amount are shown on every quote before you confirm it.

Pre-Contractual InformationFee Schedule

2. Market risk

Crypto-asset prices are highly volatile and can change significantly within minutes. Factors that can move them include:

• supply and demand, speculation and the behaviour of large holders;
• statements and decisions of regulators, governments and central banks;
• events on the underlying networks, such as outages, forks, protocol changes or security incidents;
• general economic conditions, interest rates and movements in other financial markets.

3. Liquidity and suspension risk

• Coinbar as the only counterparty. Coinbar is the only counterparty to every exchange (exchange on own account, Coinbar Direct, Art. 77 MiCA): it buys from you or sells to you from its own inventory and does not route your request to other trading venues. You can therefore exchange through Coinbar only when Coinbar provides a quote, and only for the pairs it offers.
• Automatic suspension of quotes (circuit breaker). Coinbar automatically suspends its quotes when the reference price is not reliable: when Kraken is unavailable or its data are more than 10 seconds old, when the Kraken price deviates by more than 1% from the median of the control sources (CoinMarketCap, LiveCoinWatch, CoinGecko) for more than 60 seconds, or when the price moves by more than 5% within 5 minutes. Quoting resumes only after at least 15 minutes of stable conditions and a technical check. During a suspension you cannot exchange, and prices can change significantly in the meantime.
• Checks before every exchange. Before every exchange Coinbar checks, among other things, anti-money-laundering and sanctions requirements, your available balance, your limits and its own inventory, and runs technical checks. If any check fails, the exchange is not executed.
• Limits. A retail client can exchange at most EUR 15,000 in a single transaction; business clients have individual limits set after the verification of the company. The limits of your account tier are shown in the app. A larger amount can only be exchanged as separate transactions, each with its own quote and price.
• Suspension of services. Coinbar may also suspend or restrict its services for security reasons, during maintenance, on a decision of a competent authority or when the conditions for providing a service are not met. Your crypto-assets remain in custody during a suspension, but you may be unable to exchange or withdraw them while it lasts.

4. E-money tokens USDC and EURC

USDC and EURC are e-money tokens (EMT) within the meaning of MiCA. They are issued by Circle, a third party independent of Coinbar: USDC references the US dollar and EURC the euro, each at a ratio of 1:1. Coinbar is not the issuer, does not guarantee the peg and does not redeem the tokens. Holding an e-money token involves in particular the following risks:

5. Risks specific to each crypto-asset

Coinbar supports each crypto-asset only on the network indicated below. Crypto-assets sent on any other network, or tokens other than those listed, are not credited automatically: a recovery, where technically possible at all, is manual, can take a long time and is not guaranteed.

6. Transfer risks

Coinbar transfers crypto-assets on your behalf (Art. 82 MiCA). Transfers on a blockchain carry the following risks:

• Irreversibility. A blockchain transfer cannot be reversed. Once it has been broadcast, Coinbar cannot cancel or recall it, and crypto-assets sent to a wrong address are usually lost for good.
• Your responsibility for the details. Check the address, the network and, for XRP, the destination tag before you confirm. Coinbar validates the format of the address and the network, but it cannot verify that the address belongs to the person you intend to pay.
• Finality times. A transfer is considered sufficiently irreversible after 6 confirmations on Bitcoin (about 60 minutes), a finalized checkpoint on Ethereum (about 12–15 minutes), the "finalized" status on Solana and a validated ledger on the XRP Ledger (about 3–5 seconds). Congestion can extend these times.
• Network fees. The network fee is estimated and shown before you confirm and is deducted from the amount sent; network fees vary with the conditions on the network.
• Deposits. Send each crypto-asset only to the dedicated address shown in the app for that crypto-asset and network. Incoming transfers are credited after network finality and after screening; a deposit sent on the wrong network is never credited automatically.

Travel Rule

Transfers of crypto-assets are subject to Regulation (EU) 2023/1113 of the European Parliament and of the Council on information accompanying transfers of funds and certain crypto-assets (Transfer of Funds Regulation) (the "Travel Rule"): with every transfer to or from another crypto-asset service provider Coinbar transmits the required information on the originator and the beneficiary, without a minimum amount. The additional information you are asked to provide in the app (beneficiary details and, for a self-hosted address, confirmation that you own or control it) depends on the threshold in force under Coinbar's anti-money-laundering policy, which may apply to every transfer. Before you confirm a withdrawal, the app tells you whether this information is required.

Compliance checks and holds

Every withdrawal requires multi-factor authentication (MFA), passes compliance checks (active identity verification, sanctions screening, blockchain analytics by Crystal Intelligence, Travel Rule) and needs an internal approval. A transfer can be put on hold, delayed or rejected, or require additional information (enhanced due diligence); such a hold cannot be bypassed. The law may prohibit Coinbar from telling you the reason for a hold.

7. Custody risks

Coinbar holds your crypto-assets in custody (Art. 75 MiCA) in wallets based on multi-party computation (MPC), using technology provided by Fireblocks. Coinbar keeps a register of the positions of each client and reconciles it daily with the wallets and the blockchain. The main risks are:

• Insolvency of Coinbar. Crypto-assets held for clients are kept in vaults separate from Coinbar's own wallets and are legally segregated from Coinbar's estate (Art. 70(1) and Art. 75(7) MiCA), so that Coinbar's creditors have no recourse to them. Even so, if Coinbar becomes insolvent, the return of your crypto-assets may be delayed by the proceedings.
• Limit of liability. Coinbar is liable to you for the loss of your crypto-assets or of the means of access to them resulting from an incident attributable to Coinbar; its liability is capped at the market value of the crypto-asset lost at the time the loss occurred (Art. 75(8) MiCA). Losses caused by events that Coinbar does not control, such as a problem inherent in the operation of a network, may not be compensated.
• Cyber and operational risk. Transactions are signed with MPC by a quorum (no single person can move the assets), at least 80% of the assets are held in cold storage, and movements from client vaults to Coinbar's own wallets are blocked by technical rules. These measures reduce but do not eliminate the risk of cyber attacks, failures of the technology provider, internal errors or fraud.
• Dependence on third parties. Custody depends on the technology provider Fireblocks and on the underlying networks; a failure on their side can make your crypto-assets temporarily unavailable.
• Forks and airdrops. Coinbar detects them, informs you and credits the resulting crypto-assets to you or exercises the related rights on your behalf, never to its own advantage. A crypto-asset created by a fork or an airdrop may have little or no value and may not be offered for exchange.
• Statements. You receive a statement of your positions at least every three months and on request (Art. 75(3) MiCA). Check it and report any discrepancy to Coinbar without delay. A summary of the custody policy is available on request.

8. Technology and operational risks

Crypto-assets rely on technologies that carry risks of their own:

• Forks and protocol changes. A network can split into two chains (fork) or change its rules; this can affect the value, the transferability or the support of a crypto-asset.
• Defects and attacks. Software bugs, attacks on the consensus mechanism of a network (for example by an actor controlling most of its computing power or stake) or vulnerabilities in the smart contracts of ERC-20 tokens can cause losses or interruptions.
• Network congestion. Congestion and outages of networks can delay deposits and withdrawals and increase network fees.
• Outages at Coinbar or its providers. The app, the pricing source Kraken, the custody technology Fireblocks, the cloud infrastructure or internet connectivity can be unavailable. During such periods you may be unable to exchange, deposit or withdraw.
• Human error. Human error and internal fraud cannot be ruled out entirely, despite internal controls such as the four-eyes principle.

Coinbar manages its information and communication technology (ICT) risks under Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA): it applies ICT risk-management, incident-management, testing and third-party-risk measures. These measures reduce operational risk but cannot eliminate it.

9. Regulatory and tax risks

• The legal framework for crypto-assets is still developing. Changes in EU or Slovak law, in the guidance of the European supervisory authorities or of NBS, or measures taken by an authority may restrict or end the offer of certain crypto-assets or services, or change the way they are provided.
• A crypto-asset may have to be suspended or removed from the offer, for example if it no longer meets legal requirements or if the issuer of an e-money token loses its authorisation.
• Coinbar's services are offered only to natural persons aged 18 or over resident in Slovakia and to legal persons with their registered office in Slovakia. A change of residence or registered office may lead to restrictions of the services.

Taxes

• Gains from crypto-assets may be subject to tax. Coinbar does not give tax advice; you are responsible for your own tax obligations (for Slovak tax residents in particular under the Slovak Income Tax Act, zákon č. 595/2003 Z. z. o dani z príjmov). Tax rules may change.
• From 1 January 2026 Coinbar collects data on its clients and their crypto-asset transactions and reports them to the Slovak Financial Administration (Finančná správa SR) under zákon č. 359/2015 Z. z. o automatickej výmene informácií o finančných účtoch, which transposes Directive (EU) 2023/2226 ("DAC8"). You must provide your tax residence information.

10. Fraud, scams and security

Fraudsters exploit the popularity of crypto-assets. Protect yourself:

• Offers too good to be true. Be wary of offers that promise guaranteed or unusually high returns, of "recovery" services for lost crypto-assets and of people you have only met online who urge you to invest.
• Phishing. Before you sign in, check that you are using the official Coinbar app or website. Do not open links or attachments in unexpected messages.
• Passwords and MFA codes. Coinbar never asks for your password, whether by e-mail, phone, chat or social media. Never share your multi-factor authentication (MFA) codes with anyone, including anyone who says they are from Coinbar; enter them only in the app when you sign in or confirm an operation yourself.
• Impersonation. Fraudsters may pretend to be Coinbar, a public authority or a well-known person. Coinbar never asks you to move your crypto-assets to a "safe" address. If in doubt, contact Coinbar only through the app or at [email protected].
• Protect your device and account. Use a strong password that you use nowhere else, keep your device and the app up to date and do not let anyone else use your account. Report any suspected unauthorised access to Coinbar immediately.
• No way back. Crypto-assets sent to a fraudster can almost never be recovered, because blockchain transfers are irreversible.

11. No leverage, no derivatives, no staking or lending

12. Complaints

Complaints Procedure

13. Regulatory references

This risk warning is based in particular on:

• Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in crypto-assets (MiCA), in particular Art. 66 (information to clients, including risks), Arts 70 and 75 (custody and segregation), Art. 77 (exchange) and Art. 82 (transfer services);
• Regulation (EU) 2023/1113 of the European Parliament and of the Council on information accompanying transfers of funds and certain crypto-assets (Transfer of Funds Regulation) (the "Travel Rule");
• Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA);
• Commission Delegated Regulation (EU) 2025/294 on complaints handling by crypto-asset service providers;
• zákon č. 297/2008 Z. z. o ochrane pred legalizáciou príjmov z trestnej činnosti a o ochrane pred financovaním terorizmu (Slovak anti-money-laundering act);
• zákon č. 747/2004 Z. z. o dohľade nad finančným trhom (supervision by NBS);
• zákon č. 118/1996 Z. z. o ochrane vkladov and zákon č. 566/2001 Z. z. o cenných papieroch a investičných službách (protection schemes that do not cover crypto-assets);
• zákon č. 359/2015 Z. z. o automatickej výmene informácií o finančných účtoch (DAC8 reporting).

Coinbar's authorisation ([TO BE COMPLETED: NBS authorisation number and date]) can be checked in the interim MiCA register published by the European Securities and Markets Authority (ESMA).

14. Contact

For questions about this Risk Warning, please contact Coinbar:

Company name

Coinbar s. r. o.

Legal form

limited liability company (spoločnosť s ručením obmedzeným)

Commercial register entry

IČO 57 695 415 — Mestský súd Bratislava III, Oddiel: Sro, vložka č. 200646/B

Registered office

Krajná 17137/7C, 821 04 Bratislava-Ružinov, Slovakia

Competent authority

Národná banka Slovenska (NBS), Imricha Karvaša 1, 813 25 Bratislava

MiCA authorisation

[TO BE COMPLETED: NBS authorisation number and date]

LEI

[TO BE COMPLETED: company LEI]

Customer support e-mail

[email protected]

Complaints e-mail

[email protected]