Terms of Service

1.1 Scope

These Terms of Service (the “Terms”) govern the contract between you and Coinbar s. r. o. (“Coinbar”) for the crypto-asset services that Coinbar provides through the platform app.coinbar.io.

1.2 Provider

Details of the provider:

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]

Coinbar is a crypto-asset service provider authorised by Národná banka Slovenska (NBS) under Article 59 of Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in crypto-assets (MiCA) (authorisation: [TO BE COMPLETED: NBS authorisation number and date]). You can check the authorisation in the interim register of crypto-asset service providers kept by the European Securities and Markets Authority (ESMA). Coinbar is supervised by NBS.

Coinbar acts honestly, fairly and professionally in the best interests of its clients (Article 66 MiCA) and, before you use a service, gives you information on the service, its costs and its risks.

1.3 Conclusion of the contract

The contract is concluded at a distance, by electronic means: you accept these Terms in the app when you open your account. Coinbar provides the services to you once your identification has been completed (section 3.3).

1.4 Related documents

Before opening an account, please also read the following documents, which complete these Terms:

• Pre-Contractual Information
• Risk Warning
• Fee Schedule
• Complaints Procedure
• Privacy Policy
• Cookie Policy

In these Terms, the following terms have the meanings set out below:

Crypto-asset

A digital representation of a value or of a right that can be transferred and stored electronically using distributed ledger technology or similar technology, within the meaning of MiCA.

E-money token (EMT)

A crypto-asset that purports to maintain a stable value by referencing the value of one official currency, within the meaning of MiCA. On the platform: USDC and EURC.

EURC

An e-money token issued by a third party (Circle), not by Coinbar, and pegged to the euro at 1:1. EURC is a crypto-asset: it is not a euro balance, a bank deposit or a payment account.

Client, you

A natural or legal person who has concluded the contract with Coinbar under these Terms.

Consumer

A client who is a natural person and who, in the contract, acts for purposes outside their trade, business or profession.

Platform

The web application at app.coinbar.io (which can also be installed as a PWA) through which Coinbar provides its services.

Account

Your account on the platform: a private account of a natural person or a business account of a legal person.

Account tier

The level of your account (Tier 1 to Tier 4 or Business), which determines the limits applied to your transactions.

Coinbar Direct

The exchange of crypto-assets for funds or for other crypto-assets in which Coinbar deals on its own account and is your direct counterparty (Article 77 MiCA).

Automatic exchange

The exchange into EURC, at 1:1, of euro that you send to Coinbar by SEPA transfer, carried out on the basis of your prior consent (section 5).

Quote

The firm price at which Coinbar offers to carry out a specific exchange, shown in the app together with its validity period.

Network fee

The fee paid to the operators of a blockchain network for processing a transfer. It is not a Coinbar fee.

Travel Rule

The obligations laid down in 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) to transmit information on the originator and the beneficiary with transfers of crypto-assets.

Self-hosted address

A distributed ledger address that is not held by a crypto-asset service provider (or by a similar provider established outside the EU), for example the address of a wallet that you control yourself.

Business day

Any day other than a Saturday, a Sunday or a public holiday (day of rest) in the Slovak Republic.

NBS

Národná banka Slovenska, the authority competent for Coinbar under MiCA.

MiCA

Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in crypto-assets (MiCA).

3.1 Who can become a client

Only the following may become clients of Coinbar:

• natural persons aged 18 or over who are resident in the Slovak Republic;
• legal persons with their registered office in the Slovak Republic.

Coinbar does not open an account, and may refuse to open one, if you or — for a legal person — its beneficial owners or authorised persons are subject to international sanctions, or if Coinbar cannot complete your identification under the anti-money-laundering rules. You use the services in your own name and for your own account.

3.2 Private and business accounts

Each natural person may hold only one private account. When you register, you choose whether you are opening a private or a business account; you can change this choice until you submit your identity verification.

A legal person uses the services through a separate business account, opened with a separate registration using a different e-mail address and activated after the business identification (KYB) described in section 3.3. Once the identity verification has been submitted, a private account can no longer be changed into a business account; your private account remains as it is.

3.3 Identification (KYC and KYB)

Before providing the services, Coinbar identifies you and verifies your identity under the Slovak rules on protection against money laundering and terrorist financing (zákon č. 297/2008 Z. z. o ochrane pred legalizáciou príjmov z trestnej činnosti a o ochrane pred financovaním terorizmu; the “AML Act”).

If you are a natural person, the identification takes place digitally in the app: you provide your personal data, a photograph of a valid identity document and a selfie.

Using its own software, Coinbar compares the selfie with the identity document and checks that a live person is present (liveness check). This verification is not a certified solution: a failed or inconclusive result never leads to an automatic rejection, but to a manual review by Coinbar’s staff.

If you are a legal person, the business identification (KYB) covers the company’s data, its beneficial owners, the persons authorised to act on its behalf, the purpose of the business relationship and the source of funds; the person who opens the account on behalf of the company is identified as a natural person as described above.

Coinbar screens clients — and, for legal persons, also their beneficial owners and authorised persons — against sanctions lists, lists of politically exposed persons (PEP) and adverse media, using LSEG World-Check One; the screening is repeated on an ongoing and periodic basis throughout the business relationship. Coinbar analyses the crypto-assets you deposit and the addresses you withdraw to using blockchain analytics by Crystal Intelligence.

Coinbar may at any time ask you for additional information or documents, including on the source of your funds, in particular where enhanced due diligence is required (§ 12 of the AML Act). If you do not provide them, Coinbar may restrict the services or refuse to carry out a transaction.

3.4 Account tiers and limits

According to the outcome of your identification, your account is assigned a tier (Tier 1 to Tier 4 or Business). Each tier has limits, which Coinbar applies before a transaction becomes final — also to deposits of e-money tokens and to the automatic exchange. The limits in force for your account are always shown in the app.

The maximum amount of a single exchange is set out in section 6.6.

3.5 Accuracy of data and tax residence

You must provide true, complete and up-to-date information and tell Coinbar without undue delay of any change (for example of your name, address, identity document or tax residence or, for a legal person, of its beneficial owners). Coinbar may ask you to update your identification periodically.

From 1 January 2026 Coinbar collects information on crypto-asset users and their transactions and reports it to the Slovak tax authority (Finančná správa Slovenskej republiky) under the Slovak Act on automatic exchange of information (zákon č. 359/2015 Z. z. o automatickej výmene informácií o finančných účtoch; Directive (EU) 2023/2226, “DAC8”). For this purpose you must provide Coinbar with information on your tax residence.

3.6 Security of access

Access to your account is protected by your password and, where activated, by two-factor authentication (2FA); you confirm withdrawals of crypto-assets with 2FA. Keep your credentials and the device you use for 2FA secure, and tell Coinbar immediately if you suspect that someone else has gained access to them.

4.1 Services provided

Under its authorisation Coinbar provides the following crypto-asset services within the meaning of Article 3(1)(16) MiCA:

4.2 Custody and administration (Article 75 MiCA)

• Coinbar holds and administers your crypto-assets in wallets secured by multi-party computation technology (Fireblocks MPC-CMP): no single person can dispose of them, and transfers above EUR 100,000 are subject to enhanced internal approval.
• Your crypto-assets are held in wallets segregated from Coinbar’s own wallets; technical rules prevent movements from client wallets to Coinbar’s own wallets other than the settlement of exchanges you have confirmed. Coinbar keeps an authoritative register of each client’s positions and reconciles it every day with the custody wallets and the blockchains.
• Most crypto-assets (at least 80%) are kept in cold storage; no more than 20% is kept in hot wallets for day-to-day operations.
• Crypto-assets held for clients are legally segregated from Coinbar’s estate (Article 70(1) and Article 75(7) MiCA), so that Coinbar’s creditors have no recourse to them, in particular in the event of Coinbar’s insolvency. Coinbar does not use your crypto-assets for its own account.
• Coinbar provides you with a statement of your positions at least once every three months and whenever you ask for one (Article 75(3) MiCA). A summary of Coinbar’s custody policy is available on request.
• If a blockchain forks, or new crypto-assets are distributed (airdrop) in respect of crypto-assets you hold, Coinbar detects it, informs you and, in accordance with its custody policy, credits the resulting crypto-assets to you or exercises the related rights for you — never to its own advantage.
• Coinbar’s liability for the loss of crypto-assets is set out in section 12.

4.3 Supported crypto-assets and networks

Coinbar supports the following crypto-assets, each on one network only:

Crypto-assets sent on another network and crypto-assets that Coinbar does not support are not credited automatically (section 7.1).

4.4 E-money tokens (USDC and EURC)

• You can deposit USDC and EURC on the Ethereum network, hold them in custody and exchange them.
• E-money tokens are never withdrawn or transferred out of the platform and cannot be transferred between clients. Coinbar is not their issuer and does not redeem them.
• You can exit a position in e-money tokens only by exchanging it. Residual e-money tokens are returned in kind, under a documented manual procedure, only in exceptional cases: on termination of the contract, in an orderly wind-down of Coinbar’s activities, if exchange is unavailable for a prolonged period, in the event of an issuer event or on the order of an authority (section 10.5).
• EURC is issued by a third party (Circle) and pegged to the euro at 1:1; its value depends on the issuer, and it carries the risk of losing its peg (de-peg). Neither EURC nor any other crypto-asset is protected 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).

4.5 Services Coinbar does not provide

Coinbar does not provide the following services: operation of a trading platform for crypto-assets (Article 76 MiCA), execution of orders for crypto-assets on behalf of clients (Article 78), placing of crypto-assets (Article 79), reception and transmission of orders for crypto-assets on behalf of clients (Article 80), or advice on crypto-assets and portfolio management of crypto-assets (Article 81). Coinbar does not make your crypto-assets available to third parties as a loan, does not use them to validate transactions on blockchain networks and pays no interest or other return on them.

Coinbar gives no investment advice and no personalised recommendations. Prices, charts and other information in the app are not a recommendation to buy or to sell; you take your decisions yourself (see also the Risk Warning).

5.1 Depositing euro

You can send euro to Coinbar by SEPA credit transfer, including SEPA Instant, to the client-funds account operated by Verifo UAB, an electronic money institution established in Lithuania. The account details and your personal payment reference (in the form CB-XXXXXXXX) are shown in the app.

The transfer must come from a payment account held in your name and must carry your personal reference: Coinbar matches the payment to your account by the reference and by the name of the payer. Coinbar does not hold euro for you and does not keep a euro balance or a euro account in your name.

5.2 Prior consent to the automatic exchange

Euro received are exchanged into EURC only on the basis of your prior consent to the automatic exchange. You give the consent in the app, explicitly and separately from these Terms; you can revoke it, and every version of it is recorded.

Before you give it, the consent informs you in particular that:

• the exchange takes place at 1:1, without commission and without spread;
• EURC is an e-money token issued by a third party (Circle), not a euro balance;
• Coinbar holds the EURC in custody for you under Article 75 MiCA;
• you can exit a position in EURC only by exchanging it (section 4.4);
• EURC is not protected by any deposit guarantee scheme;
• EURC carries the risk of its issuer and the risk of losing its peg to the euro (de-peg);
• the automatic exchange is suspended when the circuit breaker is triggered (section 6.7).

5.3 Carrying out the automatic exchange

On the day it receives your euro, and after checks that stop the exchange if they cannot be completed (anti-money-laundering and sanctions checks, the limits of your tier and the status of your identification), Coinbar exchanges the euro into EURC at 1:1 and credits the EURC to your segregated custody position.

While the automatic exchange is suspended, euro received are treated as follows: [TO BE COMPLETED: treatment of euro received while the automatic exchange is suspended].

5.4 Revoking the consent

You may revoke the consent at any time with effect for the future ([TO BE COMPLETED: how the consent is revoked — in the app or through customer support]). Exchanges already carried out are not affected. Euro you send after revoking the consent are not exchanged and are returned under section 5.5.

5.5 Return of euro that are not exchanged

Euro that cannot be exchanged — in particular without a valid consent, after its revocation or where the payment cannot be matched to your account — are returned to the account from which they were sent by the end of the business day following the day of receipt.

Euro held for anti-money-laundering reasons are kept segregated; if they cannot be returned, they are placed with a credit institution in the Slovak Republic within the time limit laid down in Article 70 MiCA.

5.6 Payout in euro

Payout in euro (exchange of EURC into euro and a SEPA transfer to a verified account held in your name) is not yet available; it is planned for a later phase. Until then, you can exit a position in EURC only by exchanging it for another crypto-asset (section 6).

6.1 How Coinbar Direct works

In Coinbar Direct, Coinbar deals on its own account: it buys crypto-assets from you or sells them to you as your direct counterparty, at the firm price of the quote, and settles the exchange from its own inventory. Your exchange request is not passed on to any external trading venue.

Exchanges against the euro are settled in EURC at 1:1, because Coinbar does not hold euro for clients: when you buy, the price is debited from your EURC position; when you sell, the proceeds are credited to your EURC position.

The following pairs are available: BTC/EUR, ETH/EUR, SOL/EUR, XRP/EUR, USDC/EUR and EURC/EUR (1:1); BTC/ETH, BTC/SOL and ETH/SOL; USDC and EURC against BTC, ETH, SOL and XRP. The pairs available at any given time are shown in the app.

6.2 Price

• The reference price (P_ref) is the mid-price of the Kraken order book — (best bid + best ask) / 2 — in real time. Kraken is Coinbar’s only pricing source.
• The price at which you buy is P_ref × (1 + s/2) and the price at which you sell is P_ref × (1 − s/2), where the spread s lies within a band of 1%–2%. The spread is included in the price and is not charged separately.
• Coinbar checks the reference price against CoinMarketCap, LiveCoinWatch and CoinGecko; these sources serve only as a control and are never used as a price.
• EURC/EUR is exchanged at 1:1, without commission, without spread and without a quote validity period.
• This price method and its limits are published under Article 77(2) MiCA.

6.3 Quote

Before you confirm, the quote shows the pair, the quantity, the price, the spread, the commission (standard rate 1.00%, shown separately), the resulting amount, the validity period of the quote — 30 seconds, or 15 seconds in high volatility (a movement of more than 5% in 24 hours) — and the statement that Coinbar is your direct counterparty. If the quote expires, you can request a new one.

6.4 Checks before execution

Before execution Coinbar checks, in particular, anti-money-laundering and sanctions requirements, your balance, your limits, its own inventory and the technical conditions. If any check fails or cannot be completed, the exchange is not executed.

6.5 Finality

Your final confirmation of the quote is binding and final (Article 77(3) MiCA): Coinbar executes the exchange at the price shown at the time of your confirmation, without any subsequent re-pricing, and you cannot cancel a confirmed exchange. The crypto-assets and EURC concerned are credited to or debited from your custody positions.

6.6 Limits

A single exchange by a retail client (private account) may not exceed EUR 15,000. The limits of business clients are set individually after KYB and, where applicable, enhanced due diligence. Larger amounts can be exchanged only as separate transactions, each with its own quote. The limits of your tier also apply (section 3.4).

6.7 Circuit breaker

Coinbar automatically suspends quotes if the Kraken price is unavailable or stale for more than 10 seconds, deviates by more than 1% from the median of the control sources for more than 60 seconds, or moves by more than 5% within 5 minutes. Quotes resume after at least 15 minutes of stable conditions and a successful health check.

If an e-money token loses its peg beyond Coinbar’s risk threshold (de-peg), the pairs involving that token and the automatic exchange are suspended; your positions are not affected.

6.8 Conflicts of interest and transparency

As Coinbar is your counterparty, its interest in an exchange is opposed to yours; the spread and the commission are Coinbar’s remuneration. Coinbar identifies, prevents and manages conflicts of interest in accordance with Article 72 MiCA and applies the published price method to every quote.

Coinbar publishes the prices and volumes of executed exchanges without any information identifying clients (Article 77(4) MiCA).

7.1 Deposits of crypto-assets

• For each crypto-asset the app shows a deposit address dedicated to you (for XRP together with a destination tag). Send only the crypto-asset indicated, and only on the network indicated.
• Coinbar validates the crypto-asset, the network and the address, waits for the finality required by the network and screens the deposit (including under the Travel Rule, section 7.4); it then credits the deposit to your position without undue delay.
• A deposit sent on the wrong network, or of a crypto-asset that Coinbar does not support, is never credited automatically; Coinbar assesses whether it can be recovered manually.
• Coinbar charges no fee for deposits of crypto-assets; the network fee is paid by the sender.

7.2 Withdrawals (transfer service)

You can transfer BTC, ETH, SOL and XRP from your custody position to an address on the respective network; e-money tokens cannot be withdrawn (section 4.4). For a withdrawal:

• you enter the address, the network and, for XRP, the destination tag; an XRP withdrawal without a destination tag is not executed unless you expressly confirm that the destination address does not use one;
• you review a summary, which cannot be skipped, of the amount, the fees and the warning that the transfer is irreversible, and you confirm the withdrawal with two-factor authentication (2FA);
• Coinbar validates the format and checksum of the address, the network and the destination tag and carries out compliance checks (active identification, sanctions, blockchain analytics by Crystal Intelligence, Travel Rule); if a check fails or cannot be completed, the withdrawal is not executed or is put on hold and escalated to Coinbar’s AML Officer;
• the withdrawal is approved internally under the four-eyes principle (with enhanced approval above EUR 100,000), signed with MPC technology and broadcast to the network;
• Coinbar monitors the transfer until finality — indicatively about 60 minutes (6 confirmations) for Bitcoin, about 12–15 minutes (finalised checkpoint) for Ethereum, “finalized” status for Solana and inclusion in a validated ledger (about 3–5 seconds) for the XRP Ledger — and gives you a receipt showing the status of the transfer (broadcast, confirmed, sufficiently irreversible, rejected, returned or suspended).

The network fee is estimated and shown before you confirm and is deducted from the amount transferred. Coinbar transfer fee: [TO BE COMPLETED: Coinbar transfer fee for crypto-asset withdrawals].

7.3 Irreversibility and your responsibility

Transfers on a blockchain are irreversible: once broadcast to the network, Coinbar cannot cancel or recover them. You are responsible for the accuracy of the address, the network and the destination tag you enter; a loss caused by incorrect data you have entered is borne by you, without prejudice to your rights as a consumer that cannot be limited by contract and to Coinbar’s liability for breaches of its own obligations (section 12).

7.4 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.

Coinbar exchanges this information with other providers through NotaBene, using the IVMS101 standard. No fee is charged for collecting the Travel Rule information.

7.5 Holds and rejections

Coinbar may put a deposit or a withdrawal on hold, reject it or make it subject to enhanced due diligence where the anti-money-laundering rules so require (section 10.2). No business function of Coinbar can override such a hold.

Coinbar informs you of all costs before you use a service (Article 66 MiCA). In summary:

The full list of fees is set out in the Fee Schedule. Coinbar changes its fees only in accordance with section 16.

Fee Schedule →

9.1 Your obligations

You undertake in particular to:

• provide true, complete and up-to-date information and documents and update them without undue delay;
• keep your password, your 2FA device and your e-mail account secure, not make them available to anyone and tell Coinbar immediately of their loss, theft or misuse;
• check the address, the network and the destination tag before every withdrawal;
• use the services only for yourself, in your own name and in accordance with the law;
• respect the limits of your account;
• meet your tax obligations yourself — Coinbar gives no tax advice (for Slovak tax residents see in particular the Income Tax Act, zákon č. 595/2003 Z. z. o dani z príjmov);
• read the information Coinbar sends you, including statements of positions, and tell Coinbar without undue delay of any discrepancy.

9.2 Prohibited use

In particular, you must not:

• use the services for money laundering, terrorist financing, the evasion of sanctions or any other unlawful purpose;
• allow another person to use your account, or use another person’s account;
• circumvent the identification, the checks, the limits or the geographic restriction of the services, including by splitting transactions to avoid checks or by concealing your place of residence;
• provide false or misleading information to Coinbar;
• manipulate prices or otherwise engage in abuse of crypto-asset markets;
• access the platform by automated means (bots, scraping) without Coinbar’s consent, or interfere with its security, availability or integrity.

10.1 Suspension and restriction

Coinbar may suspend or restrict, in whole or in part, your access to the platform or to individual services where this is necessary: to comply with the law or an order of an authority; if your identification is incomplete, out of date or cannot be verified; if there is a suspicion of fraud, unauthorised access or a breach of these Terms; when the circuit breaker is triggered (section 6.7); or for maintenance and security reasons. Coinbar informs you of the suspension and its reason unless the law prohibits it.

10.2 Anti-money-laundering holds

Transactions may be held, rejected or made subject to enhanced due diligence. The decision rests with Coinbar’s AML Officer, and no business function can override it. Coinbar reports unusual transactions (neobvyklá obchodná operácia) to the Finančná spravodajská jednotka Prezídia Policajného zboru (the Slovak Financial Intelligence Unit, § 17 of the AML Act) and may not tell you about such a report. Coinbar keeps identification data and the customer due diligence file for five years from the end of the business relationship, and records of individual transactions for five years from the date of the transaction (§ 19 of the AML Act), or longer if the Financial Intelligence Unit so requests.

10.3 Termination by you

You may terminate the contract at any time by notice to Coinbar (section 17); notice period: [TO BE COMPLETED: notice period for termination by the client].

10.4 Termination by Coinbar

Coinbar may terminate the contract by giving notice of [TO BE COMPLETED: notice period for termination by Coinbar]. Coinbar may terminate it with immediate effect if the law or an order of an authority requires it, if Coinbar cannot perform customer due diligence, if you seriously breach these Terms (in particular section 9.2) or if Coinbar loses its authorisation.

10.5 Return of assets on termination

Before the termination takes effect, exchange your crypto-assets or transfer your BTC, ETH, SOL and XRP to an address you control; the usual checks apply (section 7).

E-money tokens (USDC, EURC) cannot be withdrawn: exchange them for another crypto-asset before termination. If any remain on termination, Coinbar returns them to you in kind, under a documented manual procedure, to an address on the Ethereum network that you control and that Coinbar has verified. The same procedure applies in an orderly wind-down of Coinbar’s activities, if exchange is unavailable for a prolonged period, in the event of an issuer event or on the order of an authority.

If, by the time the termination takes effect, you have not said what should be done with your assets: [TO BE COMPLETED: treatment of the assets of a client who gives no instructions by termination].

If you are a consumer, you may withdraw from the contract concluded at a distance within 14 calendar days of its conclusion, without giving any reason and without penalty, under the Slovak rules on consumer protection in distance financial services (zákon č. 311/2025 Z. z. o ochrane spotrebiteľa pri finančných službách na diaľku).

To withdraw, send Coinbar a clear statement before the period expires: [TO BE COMPLETED: channel for the withdrawal notice and model withdrawal form].

The right of withdrawal does not apply to individual exchanges, including those carried out during the withdrawal period, because their price depends on fluctuations in the financial market that are outside Coinbar’s control; exchanges already executed are therefore not reversed.

If you withdraw, the contract ends and your assets are returned as described in section 10.5 ([TO BE COMPLETED: effects of withdrawal and any payment for services provided before withdrawal]).

Independently of the right of withdrawal, you may terminate the contract at any time (section 10.3).

Coinbar is liable for damage caused by a breach of its obligations under the contract or the law, in accordance with Slovak law.

For crypto-assets held in custody, Coinbar is liable for the loss of crypto-assets or of the means of access to them as a result of an incident attributable to Coinbar; this liability is capped at the market value of the crypto-asset lost at the time the loss occurred (Article 75(8) MiCA).

Coinbar is not liable for:

• changes in the prices of crypto-assets and the results of your decisions to buy, sell or hold them;
• the operation of blockchain networks and other third-party infrastructure that Coinbar does not control, including forks, congestion and protocol failures, or events concerning the issuers of e-money tokens;
• losses caused by incorrect data you enter (in particular the address, network or destination tag) or by your breach of these Terms, including the disclosure of your credentials;
• the consequences of a hold, rejection or suspension applied in accordance with the law or these Terms;
• events outside Coinbar’s control that it could not have prevented even by exercising due care.

Nothing in these Terms excludes or limits Coinbar’s liability where the law does not permit it, or your rights as a consumer under mandatory law, in particular under the Civil Code (zákon č. 40/1964 Zb. Občiansky zákonník) and the consumer protection rules (zákon č. 108/2024 Z. z. o ochrane spotrebiteľa).

The platform, its software, design and texts, and the Coinbar marks and logos are protected and belong to Coinbar or its licensors.

For the duration of the contract Coinbar grants you a non-exclusive, non-transferable right to use the platform for the purposes of these Terms. You may not copy, modify, distribute or commercially exploit the platform or its content without Coinbar’s prior written consent.

14.1 Complaints

You can submit a complaint free of charge by e-mail to [email protected] or as described in the complaints procedure (Article 71 MiCA). Coinbar acknowledges receipt without undue delay and decides on the complaint without undue delay and at the latest within two months of receiving it; if this is exceptionally not possible, it tells you the reasons and the date of its decision (Commission Delegated Regulation (EU) 2025/294 on complaints handling by crypto-asset service providers).

Complaints Procedure →

14.2 Submissions to the supervisory authority (NBS)

As a financial consumer, you may also send a submission (podanie) to the supervisory authority, Národná banka Slovenska (NBS), which supervises the protection of financial consumers under the Slovak rules on financial market supervision (zákon č. 747/2004 Z. z. o dohľade nad finančným trhom): electronically via https://podanie.nbs.sk or by post to Národná banka Slovenska, Imricha Karvaša 1, 813 25 Bratislava.

14.3 Alternative dispute resolution

If you are a consumer and Coinbar rejects your complaint or does not reply within 30 days of when you sent it, you may file a proposal for alternative dispute resolution with an ADR body entered in the list kept by the Ministry of Economy of the Slovak Republic (Ministerstvo hospodárstva Slovenskej republiky), under the Slovak rules on alternative dispute resolution of consumer disputes (zákon č. 391/2015 Z. z. o alternatívnom riešení spotrebiteľských sporov). The ADR body competent for Coinbar is: [TO BE COMPLETED: ADR body competent for Coinbar s. r. o.]. The ADR body concludes the proceedings within 90 days.

The Slovak Trade Inspection (Slovenská obchodná inšpekcia, SOI) does not deal with disputes concerning financial services.

14.4 Courts

Your right to go to court is not affected. Disputes are decided by the competent courts of the Slovak Republic under the Code of Civil Contentious Procedure (zákon č. 160/2015 Z. z. Civilný sporový poriadok). If you are a consumer, under Regulation (EU) No 1215/2012 (Brussels I bis) you may also sue Coinbar in the courts of the Member State where you are domiciled, and Coinbar may sue you only in those courts.

The contract and these Terms are governed by the law of the Slovak Republic and by directly applicable European Union law, in particular MiCA and the Transfer of Funds Regulation (section 7.4).

If you are a consumer, the contract is governed in particular by the Civil Code (zákon č. 40/1964 Zb. Občiansky zákonník) and by the consumer protection rules (zákon č. 108/2024 Z. z. o ochrane spotrebiteľa; zákon č. 311/2025 Z. z. o ochrane spotrebiteľa pri finančných službách na diaľku). If you are habitually resident in another State, this choice of law does not deprive you of the protection afforded to you by the mandatory provisions of the law of that State (Regulation (EC) No 593/2008 (Rome I)).

If you are a business client, the contract is governed by the Commercial Code (zákon č. 513/1991 Zb. Obchodný zákonník).

Coinbar may change these Terms, in particular because of changes in the law or in the requirements of the supervisory authority, changes in its services or fees, or for security reasons.

Coinbar informs you of a change by e-mail and in the app at least [TO BE COMPLETED: notice period for changes to the Terms] before it takes effect. Until the change takes effect, you may terminate the contract free of charge; if you do not, the amended Terms apply from the date they take effect.

A change required by law or by an authority may take effect within the period set by that law or authority.

Coinbar communicates with you electronically — through the app and by e-mail to the address registered in your account. You receive statements of positions, receipts and notices of changes in the app or by e-mail; keep your e-mail address up to date.

You can save or print these Terms at any time; the version in force is always published at app.coinbar.io/legal/terms.

You can communicate with Coinbar in Slovak or in English. The contract is concluded in Slovak; the Slovak version of these Terms prevails over their translations.

Coinbar processes your personal data in accordance with the data protection rules (Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR); zákon č. 18/2018 Z. z. o ochrane osobných údajov), as described in the Privacy policy.

Privacy Policy

You can contact Coinbar at:

Company name

Coinbar s. r. o.

Registered office

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

Customer support e-mail

[email protected]

Complaints e-mail

[email protected]

Data protection e-mail

[email protected]

Supervisory authority: Národná banka Slovenska, Imricha Karvaša 1, 813 25 Bratislava (https://nbs.sk).