Terms and Conditions for the provision of Bull Bitcoin Services in Europe

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For terms and conditions related to the Bull Bitcoin wallet, please visit https://wallet.bullbitcoin.com/terms

1. Introduction and Definitions

1.1 These Terms and Conditions ("Terms") govern the use of Bull Bitcoin exchange services provided by Leonod SARL ("we," "us," "our," or "Bull Bitcoin"), a company organized and existing under the law of France, under company registration registered with the Trade and Companies Register of Lyon under number (SIRET) 849 566 559 00019, whose having its registered office is located at 15 Place Jules Ferry, 69006 Lyon, France. We are in the process of applying for full authorization as a Crypto-Asset Service Provider (CASP) under the Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114). Users can verify our status on the AMF register at https://www.regafi.fr or ESMA's public register (once available). For inquiries or complaints related to supervision, contact the AMF at https://www.amf-france.org/en/contact-us.

Our services are exclusively available to individuals who are residents of European Union member states (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden) for regulatory and tax purposes.

Residents of the United States, United Kingdom, and other jurisdictions where our MiCA authorization does not apply are strictly prohibited from accessing or using our services, regardless of their citizenship or how the request is initiated.

By using our Services, you confirm that you are not a resident of a prohibited jurisdiction and that you will immediately cease use if your residency status changes.

Bull Bitcoin is not an issuer of electronic money and does not offer fiat payment services. It operates exclusively for self-custodial bitcoin purchases and sales.

Capitalised terms used in these Terms (or defined elsewhere herein) shall have the meanings set out below, unless otherwise specified.

1.2 "User," "you," or "your" refers to any individual or entity using our Services.

1.3 "Bitcoin" refers to the cryptocurrency known as bitcoin (BTC), and may include transactions performed using the Bitcoin Network, or the Lightning Network.

1.4 "Fiat currency" refers to government-issued currency that is designated as legal tender in its country of issuance, specifically Euros (EUR) for our services.

1.5 "Service(s)" refers exclusively to the exchange of bitcoin for euros and euros for bitcoin, as described in Article 3 (Services Description). Users are required to: (a) provide a bitcoin wallet address under their sole control to receive purchased bitcoin; and (b) send bitcoin from their own wallet when selling.

1.6 "Buy Limit Order" refers to a standing offer by Bull Bitcoin to sell Bitcoin from its own inventory to the User at a specified price condition. When the User creates a Buy Limit Order, they express interest in purchasing Bitcoin if and when the Index Price reaches or falls below a specified threshold price ("Limit Price"). Upon satisfaction of this price condition, Bull Bitcoin may, at its sole discretion and acting as principal, conclude a sale of Bitcoin to the User from Bull Bitcoin's proprietary inventory at the then-prevailing Bull Bitcoin Quote.

1.7 "Index Price" refers to the Bitcoin price displayed on the Bull Bitcoin homepage at https://app.bullbitcoin.com. The Index Price is a benchmark used to calculate the final fixed price.

1.8 "Mempool" means the pool of unconfirmed bitcoin transactions awaiting inclusion in a block on the Bitcoin blockchain.

1.9 "On-Chain Confirmation" means the inclusion of a bitcoin transaction in a block on the Bitcoin blockchain, verified by the network's consensus mechanism.

1.10 "Prepayment Ledger" means the accounting record maintained by Bull Bitcoin to track Fiat currency amounts prepaid by Users as advance consideration for committed Bitcoin purchase transactions from Bull Bitcoin's proprietary inventory.

1.11 "AML/CFT" means anti-money laundering and contrast financing of terrorism.

2. Acceptance of Terms

2.1 By accessing, browsing, or using any of our Services, downloading and using the Wallet or the app, or creating an Account with us, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy, which is incorporated by reference.

2.2 If you do not agree to these Terms, you must immediately discontinue use of our Services.

2.3 We reserve the right to modify these Terms from time to time. We will distinguish between: (a) "Minor Modifications" such as technical updates, clarifications, or changes that do not affect your rights or obligations; and (b) "Material Modifications, such as changes affecting pricing, core service features, data processing, liability, or your fundamental rights.

For Minor Modifications, we will update the "Last Modified" date at the top of these Terms and post the updated version on our website. Continued use of the Service after such updates constitutes acceptance. For Material Modifications: (a) we will provide you with clear notice via email to your registered address at least thirty (30) days before the modifications take effect; (b) the notice will clearly identify the changes and their effective date; (c) you may reject the modifications by terminating your account at any time before the effective date, without penalty or termination fees; (d) if you do not terminate your account before the effective date, continued use of the Service will constitute acceptance of the modified Terms.

2.4 You may review the current version of these Terms at any time at https://www.bullbitcoin.com/terms-eu. Previous versions are available upon request.

3. Services Description

3.1 Bull Bitcoin offers two primary Services:

Buy Bitcoin: the exchange of fiat currency (EUR) for Bitcoin, whereby Bull Bitcoin, acting as a principal, sells Bitcoin to the User at a firm Bull Bitcoin Quote and ensures delivery of the purchased Bitcoin to the User's wallet.
Sell Bitcoin: the exchange of Bitcoin for fiat currency (EUR), whereby Bull Bitcoin, acting as a principal, purchases Bitcoin from the User at a firm Bull Bitcoin Quote and ensures delivery of the corresponding fiat currency amount to the User's specified fiat account.

3.2 Bull Bitcoin acts exclusively as principal and sole counterparty in all Bitcoin exchange transactions. We buy and sell Bitcoin using our own proprietary capital and inventory. All transactions are bilateral agreements between Bull Bitcoin and the User. We do not act as intermediary, agent, or broker between third parties, nor do we route, match, or execute transactions on behalf of Users on trading venues or against external liquidity providers. Each transaction represents a direct sale from Bull Bitcoin to the User (for Buy transactions) or a direct purchase from the User by Bull Bitcoin (for Sell transactions).

3.3 Bull Bitcoin does not offer Bitcoin custody services. We do not hold, secure, or manage Users' bitcoins or fiat funds on their behalf. All Services are non-custodial, with Users retaining full control of their assets.

3.4 Fiat funds are received or sent solely as consideration for the Bitcoin exchange between the User and Bull Bitcoin acting as counterparty. Bull Bitcoin does not process or route payment and does not manage User's funds. Accordingly, Bull Bitcoin does not provide payment services within the meaning of EU law.

3.5 User's Prepayment Ledger exists only to facilitate pending Buy or Sell Bitcoin transactions. They are non-interest-bearing operational balances and do not constitute bank accounts or e-money accounts.

3.6 Bull Bitcoin determines and publishes the pricing methodology for all transactions in accordance with Article 77(2) of Regulation (EU) 2023/1114 (MiCA) (please refer to Pricing Policy (public version TBC)). Each exchange transaction is concluded at a firm Bull Bitcoin Quote determined independently by Bull Bitcoin. The Bull Bitcoin Quote is calculated using Bull Bitcoin's internal Index Price as a reference benchmark, plus an applicable spread as disclosed at https://www.bullbitcoin.com/rates.

3.6.1 The Index Price displayed at https://app.bullbitcoin.com serves solely as an indicative reference point. It does not constitute an offer to buy or sell, and does not bind Bull Bitcoin. The authoritative price for any transaction is the Bull Bitcoin Quote presented to the User for acceptance at the moment of transaction confirmation.

3.6.2 For conditional transactions (including Buy Limit Orders per Article 8, Dollar Cost Averaging per Article 9, and Autobuy per Article 10), Bull Bitcoin's obligation to sell Bitcoin arises only upon satisfaction of the specified condition. At that moment, Bull Bitcoin determines the applicable Bull Bitcoin Quote based on the then-current Index Price and applicable spread. Bull Bitcoin then affects a sale of Bitcoin from its own inventory to the User at that Quote. These are principal transactions in which Bull Bitcoin sells from its own holdings, not executions of pre-existing orders on behalf of the User.

3.6.3 In all cases, Bull Bitcoin acts as principal seller (for User purchases) or principal buyer (for User sales), using its proprietary capital to acquire or deliver Bitcoin. The timing of conditional transactions is determined by external conditions (price thresholds, deposit receipt, or scheduled intervals), but the decision to complete each transaction remains with Bull Bitcoin acting in its capacity as counterparty, not as agent or intermediary.

4. Account Registration and Management

4.1 To use our Services, you must create an account and provide accurate, complete, and up-to-date information as requested during the registration process, including for AML/CFT purposes.

4.2 Users are responsible for creating a strong password and maintaining security and control of any and all devices, IDs, personal identification numbers, passwords, hints, API keys or any other codes that Clients use to access their Account (together, the "Credentials"). Bull Bitcoin will never under any circumstances ask you for your passwords, 2-factor authentication codes, private keys, or any form of Credentials. BB assumes no responsibility for any loss that the User may sustain due to compromised Credentials due to no fault or default of Bull Bitcoin.

4.3 You agree to immediately notify Bull Bitcoin of any unauthorized use of your account or any other breach of security.

4.4 Bull Bitcoin reserves the right to refuse registration, suspend, or terminate accounts at our discretion, particularly if we suspect violations of these Terms or applicable laws.

5. EUR Purchase Ledger

5.1 Bull Bitcoin records Fiat currency prepayments from Users exclusively as advance payment for specific Bitcoin purchase transactions. In particular, Fiat currency amounts transferred by Users represent purchase commitments and are reflected in the User's Prepayment Ledger exclusively as: (a) pre-payment for Bitcoin purchases that the User intends to make; or (b) proceeds from Bitcoin sales that the User has completed with Bull Bitcoin. Users may withdraw EUR from their account balance to their own registered bank account only to cancel unused prepayment for Bitcoin purchases that the User no longer intends to execute.

5.2 The EUR Purchase Ledger is not a payment account, savings account, or general-purpose wallet. It exists exclusively to facilitate the User's Bitcoin exchange transactions with Bull Bitcoin as described in Article 3.

5.3 Users are prohibited from:

requesting withdrawal of prepayments to any bank account other than their own registered account;
maintaining prepayments in their Ledger for purposes other than completing a committed Bitcoin purchase;
Using prepayment amounts for any purpose other than purchasing Bitcoin from Bull Bitcoin.

5.4 EUR Purchase Ledger does not constitute a bank account, trust account, or payment service provider account.

5.5 When adding funds to a Bull Bitcoin account balance, users must send funds exclusively from their own bank account via SEPA or Instant SEPA. Funds from unregistered or foreign bank accounts may be denied and refunded, subject to applicable fees.

5.6 Bull Bitcoin may temporarily restrict access to the account balance if we believe the User is in breach of these terms and conditions, or if we believe the user's account has been compromised, or if we believe the user is the victim of attempted fraud, or if we are compelled to do so by law.

5.7 By activating the DCA service, Users explicitly: (a) commit to a series of scheduled Bitcoin purchase transactions from Bull Bitcoin's proprietary inventory at predetermined intervals; (b) pre-fund these committed purchases by maintaining EUR prepayment in their ledger equal to the aggregate purchase price of scheduled transactions; (c) authorize Bull Bitcoin to execute each scheduled sale of Bitcoin from its inventory to the User at the agreed intervals, with payment automatically debited from the User's Prepayment Ledger; (d) acknowledge that each DCA transaction constitutes an independent sale of Bitcoin by Bull Bitcoin to the User, not a payment instruction or standing order. The Prepayment Ledger serves as prepaid consideration for the recurring sales, not as a payment account from which Bull Bitcoin executes payment instructions.

5.8 By enabling the Autobuy feature, Users explicitly authorize that any incoming Fiat currency deposit to their Prepayment Ledger will automatically trigger a Buy Bitcoin order. Users who wish to add prepayment without immediate purchase must disable Autobuy before initiating the transfer.

6. Buy Bitcoin Service Rules

6.1 The Buy Bitcoin service constitutes a sale agreement whereby Bull Bitcoin, acting as principal, sells and delivers Bitcoin from its own inventory to the User. Bull Bitcoin delivers the specified amount of Bitcoin to the address, or Lightning Network invoice provided by the User, in exchange for the agreed-upon amount of fiat currency (EUR). The User acquires Bitcoin directly from Bull Bitcoin as seller; no intermediaries or third-party liquidity providers are involved.

6.2 You must provide a Bitcoin address from a self-hosted wallet under your full and exclusive control. Providing addresses belonging to third parties is strictly prohibited.

6.3 Before confirming a transaction, Bull Bitcoin presents you with a firm offer displaying: (a) the total EUR/BTC amount required; (b) the Bitcoin/EUR exchange rate (Bull Bitcoin Quote); and (c) the amount of Bitcoin we will sell to you. The offer remains firm for five (5) minutes from the time it is displayed. You must explicitly accept this offer for the sale to be concluded. Upon your acceptance, Bull Bitcoin sells the Bitcoin to you at the quoted rate and delivers from its inventory. The transaction details, including final price, exchange rate, and fees, are recorded in your transaction history.

6.4 You are solely responsible for the accuracy of the provided Wallets information and the security of your Wallets.

6.5 All Bitcoin sales are final and non-refundable. The Bitcoin exchange rate is guaranteed upon confirmation of purchase and cannot be altered.

6.6 The price of Bitcoin quoted by Bull Bitcoin includes a spread of around 2%. Rates displayed on the homepage or at https://www.bullbitcoin.com/rates are indicative only. The rates and fees shown to you for confirmation are authoritative.

6.7 Bitcoin payout transactions may be batched and scheduled. You may opt for express on-chain withdrawal, where estimated network fees are deducted from the Bitcoin delivered.

6.8 Bull Bitcoin is not liable for transaction confirmation delays and provides no guarantee of quick confirmations, except as per service levels.

6.9 For Lightning Network purchases, Bull Bitcoin cannot guarantee successful payment due to potential network or wallet issues. You are responsible for ensuring your Lightning Network wallet can receive payments from Bull Bitcoin.

6.10 Bitcoin purchased via a Buy Order will be delivered using the method selected by you, subject to the following restrictions (all amounts in satoshis):

Lightning Network (LN): Minimum 1,000, maximum 25,000,000.
On-chain Bitcoin (BTC): Minimum 100,000, no maximum.

7. Sell Bitcoin Service Rules

7.1 The Sell Bitcoin Service constitutes a purchase agreement whereby Bull Bitcoin, acting as principal, purchases Bitcoin from the User for Bull Bitcoin's own account in exchange for an agreed-upon amount of fiat currency (EUR), to be delivered according to the User's payment instructions. The User sells Bitcoin directly to Bull Bitcoin as buyer; no intermediaries or third-party liquidity providers are involved.

7.2 You may instruct Bull Bitcoin to alternately:

record the fiat currency payment in its Prepayment Ledger;
send the fiat currency payment to your own bank account via SEPA/Instant SEPA;
send the fiat currency payment to a third party bank account via SEPA/Instant SEPA.

7.3 When you initiate a Sell Bitcoin transaction, Bull Bitcoin will generate a price quote that includes: (a) the Bitcoin/Euro exchange rate; (b) the amount of Bitcoin you will sell; (c) the total amount in Euros you will receive; (d) the applicable fees; and (e) a unique Bitcoin address for sending payment.

7.4 Before confirming a transaction, you will be shown the amount of Bitcoin you will sell, the effective Bitcoin/Euro exchange rate, and the total amount in Euros you will receive. The quoted price is guaranteed for a period of five minutes from the time it is displayed. You must explicitly accept these terms for the transaction to proceed. Once accepted, the transaction is carried out at the agreed-upon rate, and the corresponding fee is applied as displayed at the time of confirmation. When the execution is complete, you can view all transaction details, including the final price, exchange rate, and any applicable fees, in your transaction history.

7.5 The exchange rate quoted in Article 7.3(a) is locked upon detection of your bitcoin payment in the Mempool. The transaction becomes final and the euro payment is processed once your bitcoin transfer receives one (1) on-chain confirmation. You must send the exact Bitcoin amount from the specified address within the quote validity period. Bull Bitcoin will not send fiat currency payments until confirmation.

7.6 Ownership of Bitcoin shall be transferred to Bull Bitcoin upon confirmation of the Bitcoin transaction on the Network.

7.7 Every sale of Bitcoin to Bull Bitcoin is final and non-refundable.

7.8 You are strictly prohibited from canceling unconfirmed transactions sent to Bull Bitcoin through any mechanism, including RBF or double spending. Violations may result in financial penalties and account restrictions.

7.9 The price of Bitcoin quoted by Bull Bitcoin includes a spread of around 2%. Rates displayed on the homepage or at https://www.bullbitcoin.com/rates are indicative only. The rates and fees shown to you for confirmation are authoritative.

8. Buy Limit Order

8.1 A Buy Limit Order represents a conditional purchase commitment by the User to buy Bitcoin from Bull Bitcoin when specific price conditions are satisfied. By placing a Buy Limit Order, the User makes a binding offer to purchase Bitcoin from Bull Bitcoin's proprietary inventory at Bull Bitcoin's prevailing Quote when the Index Price reaches or falls below the User-specified Limit Price. When the price condition is satisfied, Bull Bitcoin may, acting as principal seller, accept the User's offer and execute a sale of Bitcoin to the User at the then-current Bull Bitcoin Quote. Bull Bitcoin determines this Quote independently based on the Index Price at that moment plus applicable spread, in accordance with Article 3.6. Completion of the sale requires: (a) sufficient prepayment amounts in the User's Prepayment Ledger to cover the purchase price; and (b) availability of Bitcoin in Bull Bitcoin's inventory.

Bull Bitcoin does not guarantee completion of any conditional sale due to factors including market volatility, inventory availability, technical issues, or insufficient User Prepayment balance.

8.2 When the User creates a Buy Limit Order, they authorize Bull Bitcoin to effect a conditional sale of Bitcoin to them if and when the specified price condition is satisfied. Upon satisfaction of the price condition, Bull Bitcoin performs a principal sale of Bitcoin to the User from Bull Bitcoin's inventory. The sale is concluded at the Bull Bitcoin Quote applicable at that moment, determined in accordance with Article 3.6. Each executed Limit Order constitutes an independent principal-to-principal commodity sale governed by the same terms applicable to standard Bitcoin purchases under Article 6, including delivery methods, minimum/maximum amounts, and pricing methodology.

8.3 You may have up to five (5) active Buy Limit Orders at any time.

8.4 Buy Limit Orders expire one (1) year from placement unless executed or canceled earlier.

8.5 Active Buy Limit Orders cannot be modified. To change the limit price or amount, you must cancel the order and create a new one.

8.6 If your EUR Prepayment Ledger is insufficient to cover the full order amount at execution, Bull Bitcoin will automatically execute a partial sale for the maximum available balance. The remaining portion of the order will be cancelled immediately. You will receive notification showing: (a) the amount actually sold; (b) the execution price applied; and (c) the cancellation of the unfilled quantity.

8.7 Buy Limit Orders are subject to the same limitations regarding delivery methods as Buy Orders. If the selected delivery method does not comply with these restrictions, the order will be canceled.

8.8 You may cancel an active Buy Limit Order at any time before execution via your Bull Bitcoin account. Creation/cancellation is free.

8.9 We may cancel any Buy Limit Order due to non-compliance with these Terms, technical errors, or at our discretion.

8.10 Bull Bitcoin will notify you by email when a conditional sale pursuant to a Buy Limit Order is completed.

9. Dollar Cost Averaging (DCA) Rules

9.1 The Dollar Cost Averaging (DCA) service enables Users to commit a series of recurring Bitcoin purchases from Bull Bitcoin's proprietary inventory at scheduled intervals (hourly, daily, weekly, or monthly). By activating DCA, the User commits to purchase a fixed EUR-equivalent amount of Bitcoin from Bull Bitcoin at each scheduled interval and pre-funds these committed purchases by maintaining EUR prepayment in their Prepayment Ledger. At each scheduled interval, Bull Bitcoin, acting as principal seller, executes a sale of Bitcoin from its proprietary inventory to the User at the then-prevailing Bull Bitcoin Quote. The prepayment amount corresponding to the purchase price is applied as consideration for that specific sale.

9.2 Each DCA transaction constitutes an independent principal-to-principal sale of Bitcoin from Bull Bitcoin to the User. At each scheduled interval, Bull Bitcoin: (a) determines the applicable Bull Bitcoin Quote at that moment in accordance with Article 3.6; (b) applies the scheduled EUR amount from the User's prepayment ledger as purchase consideration for the sale; (c) sells the corresponding BTC amount from Bull Bitcoin's proprietary inventory to the User; (d) delivers the purchased BTC to the User's designated wallet in accordance with Article 6. Each DCA installment is a separate bilateral commodity sale transaction, not a payment transaction or payment service. The prepayment amount applied represents the purchase price paid by the User to Bull Bitcoin for Bitcoin sold from Bull Bitcoin's inventory, not funds held in a payment account or e-money transferred on behalf of the User.

9.3 The User is responsible for maintaining sufficient Prepayment Ledger to cover each scheduled Bitcoin purchase. If the User's Prepayment Ledger is insufficient when a scheduled interval occurs, Bull Bitcoin will execute a partial sale corresponding to the available prepayment amount only.

9.4 If the User's Prepayment Ledger is insufficient to cover a scheduled DCA purchase, the DCA plan will be cancelled automatically. Following cancellation, any remaining EUR prepayment may be: (a) withdrawn to the User's registered bank account; or (b) applied to other Bitcoin purchases in accordance with Article 5. To resume DCA purchases after automatic cancellation, the User must reactivate the DCA plan and ensure adequate prepayment balance.

9.5 Bull Bitcoin does not guarantee completion of all scheduled DCA sales or strict adherence to the specified schedule due to:

(a) insufficient prepayment balance in the User's Prepayment Ledger;
(b) unavailability of Bitcoin in Bull Bitcoin's proprietary inventory;
(c) technical system malfunctions or scheduled maintenance;
(d) force majeure events or circumstances beyond Bull Bitcoin's reasonable control;
(e) market conditions affecting Bull Bitcoin's ability to execute sales from its inventory.

9.6 Bull Bitcoin is not liable for any delays, missed purchases, partial executions, or failure to achieve the User's intended investment outcomes through the DCA plan, except as provided in Article 12.

9.7 Users may cancel or modify their DCA plan at any time via their Bull Bitcoin account interface, subject to completion of any transactions already in process at the time of cancellation.

9.8 DCA purchases are subject to the same delivery method restrictions as immediate Bitcoin purchases under Article 6.10 and the same exchange rate determination methodology as specified in Article 6.

10. Autobuy Feature

10.1 The Autobuy feature enables Users to configure their service settings such that any EUR transfer to Bull Bitcoin automatically constitutes a binding commitment to immediately purchase Bitcoin from Bull Bitcoin's proprietary inventory. When Autobuy is enabled in the User's service configuration, each incoming EUR transfer is treated as prepayment for an immediate Bitcoin purchase at the Bull Bitcoin Quote prevailing at the moment the transfer is confirmed. By enabling Autobuy, the User makes a standing conditional offer to purchase Bitcoin: each EUR amount transferred while Autobuy is active represents a separate, immediate purchase commitment. Bull Bitcoin, acting as principal seller, accepts each such offer and executes a sale of Bitcoin from its proprietary inventory to the User at the applicable Bull Bitcoin Quote.

10.2 Each Autobuy transaction constitutes an independent principal-to-principal sale of Bitcoin from Bull Bitcoin to the User. Upon confirmation of an incoming EUR transfer while Autobuy is enabled, Bull Bitcoin: (a) determines the applicable Bull Bitcoin Quote at that moment, based on the Index Price plus applicable spread disclosed in Article 6.6; (b) accepts the User's purchase commitment for the transferred amount; (c) sells the corresponding Bitcoin amount from Bull Bitcoin's proprietary inventory to the User; (d) applies the transferred EUR amount as purchase consideration for the sale; (e) delivers the purchased Bitcoin to the User's designated wallet in accordance with Article 6. Bull Bitcoin acts as principal seller in each Autobuy transaction, not as a payment service provider executing payment instructions on behalf of the User.

10.3 When Autobuy is enabled, any EUR transfer to Bull Bitcoin automatically triggers an immediate Bitcoin purchase from Bull Bitcoin's inventory. The sale occurs immediately upon confirmation of the incoming transfer, at the Bull Bitcoin Quote applicable at that moment. Each Autobuy sale is governed by the same terms and conditions applicable to immediate Bitcoin purchases under Article 6, including pricing methodology, delivery methods, and minimum/maximum transaction amounts.

10.4 Bull Bitcoin does not guarantee completion of Autobuy sales due to:

(a) Unavailability of Bitcoin in Bull Bitcoin's proprietary inventory;
(b) Technical system malfunctions or scheduled maintenance;
(c) Network delays in receiving or confirming incoming transfers;
(d) Transferred amount below minimum transaction requirements specified in Article 6;
(e) Non-compliance with delivery method restrictions specified in Article 6.10.

10.5 Bull Bitcoin is not liable for any delays, failures to execute, or losses resulting from completed or uncompleted Autobuy sales, except as required under Article 12.

10.6 Users are responsible for ensuring that their Bitcoin delivery method preferences (on-chain or Lightning Network) configured via the User Account interface comply with the restrictions specified in Article 6.10. If the configured delivery method does not comply with these restrictions at the time of an Autobuy sale, Bull Bitcoin may be unable to complete the sale. In such case, the transferred EUR amount will be recorded in the User's Prepayment Ledger (accessible via the User Account interface) and must be either: (a) applied to other Bitcoin purchases with compliant delivery methods; or (b) withdrawn to the User's registered bank account within a reasonable timeframe in accordance with Article 5. The Prepayment Ledger does not constitute a payment account, e-money account, or custody service. EUR amounts recorded in the Prepayment Ledger represent prepayment for committed Bitcoin purchases only, not funds held for general payment purposes.

10.7 Users may enable, disable, or modify the Autobuy feature at any time by accessing the platform via their User Account, subject to completion of any sales already in process at the time of modification.

10.8 Autobuy sales are subject to the same pricing methodology as immediate Bitcoin purchases specified in Article 6 and the same delivery method restrictions specified in Article 6.10.

10.9 By enabling the Autobuy feature, Users explicitly acknowledge and agree that: (a) each EUR transfer to Bull Bitcoin while Autobuy is enabled constitutes a binding commitment to immediately purchase Bitcoin from Bull Bitcoin's proprietary inventory at the prevailing Bull Bitcoin Quote; (b) each such transfer represents prepayment for an immediate Bitcoin purchase, not a deposit into a payment account or e-money account; (c) Bull Bitcoin will apply the transferred amount as purchase consideration for Bitcoin sold from Bull Bitcoin's inventory to the User; (d) each Autobuy transaction constitutes an independent principal-to-principal commodity sale, not a payment service, payment initiation service, or standing payment instruction as defined in Directive (EU) 2015/2366 (PSD2); (e) Users may disable Autobuy at any time via the User Account interface to prevent automatic Bitcoin purchases upon future transfers.

11. Know Your Customer (KYC) and Compliance

11.1 Users must submit personal information required for "know your client" and anti-money laundering verifications before using Bull Bitcoin services.

11.2 Bull Bitcoin reserves the right to:

Prevent users from using services
Request additional information
Restrict or terminate accounts

if we suspect violations of these Terms, applicable laws, or if provided information is inaccurate or suspicious. We may assign risk categories and monitor for suspicious patterns.

11.3 You are responsible for the accuracy and completeness of your personal information, including but not limited to email address, telephone number, name, address, date of birth, identity documents, and proof of residence documents.

11.4 Periodic reviews and updates may be required to ensure compliance with Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures, in line with EU AML Directives and MiCA Recital 77.

11.5 Bull Bitcoin is committed to complying with all applicable local, state, national, and international laws, including anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. We update systems to detect/report suspicious activity and assist authorities with audit trails.

12. Limitation of Liability

12.1 To the fullest extent permitted by applicable law, Bull Bitcoin and its affiliates, officers, directors, employees, and agents disclaim all warranties, express or implied, in connection with the Services and your use thereof, except as required under MiCA.

12.2 Notwithstanding the above, pursuant to MiCA Article 37(10), Bull Bitcoin shall be liable for any losses resulting from ICT incidents, operational failures, or errors attributable to us, our staff, or third parties we engage, including compensation for direct damages. We maintain professional indemnity insurance to cover such liabilities.

12.3 Bull Bitcoin shall not be liable for any indirect, incidental, special, consequential, or exemplary damages, including but not limited to damages for loss of profits, goodwill, use, data, or other intangible losses, resulting from:

The use or inability to use the Services (except as per 12.2)
Unauthorized access to or alteration of your transmissions or data
Statements or conduct of any third party on the Services
Any other matter relating to the Services

12.4 You expressly understand and agree that your use of the Services is at your sole risk. The Services are provided on an "AS IS" and "AS AVAILABLE" basis, subject to our operational resilience commitments (§14).

12.5 Bull Bitcoin is not responsible for:

User errors, such as incorrect Bitcoin addresses
Fluctuations in Bitcoin value or potential losses
Losses due to user error, such as forgotten passwords or failed device backups
Any damages resulting from events beyond our control, including but not limited to acts of God, natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, accidents, network infrastructure failures, strikes, or shortages of transportation facilities, fuel, energy, labor, or materials (force majeure, §23.1).

12.6 Bull Bitcoin relies on certain third-party service providers that perform essential technical or operational functions for the provisions of the Services (including, for example, cloud hosting, payment and banking partners, bitcoin infrastructure provider, and security service providers). Although Bull Bitcoin selects such providers with due care, Bull Bitcoin does not control their system or operations. Bull Bitcoin shall not be liable for any loss, damage, delay, inability to execute an order, or other impact on the Services that result from any interruption, failure or malfunction of such third-party providers, provided that Bull Bitcoin has taken reasonable steps to select and monitor such providers. Nothing in this clause excludes Bull Bitcoin's liability where such loss results from Bull Bitcoin's own fraud, gross negligence, or breach of its statutory obligations under applicable law, including MiCA and consumer protections rules.

13. No right of withdrawal

13.1 The User, including Consumer, does not have the right to withdraw from bitcoin purchases or sales made through Bull Bitcoin. This exclusion is provided for under Article L221-28, 13° of the French Code de la consommation, which excludes the right of withdrawal for financial services whose price depends on fluctuations in the financial markets that the professional cannot control and which may occur during the withdrawal period. This provision does not affect the User's right to revoke a payment transfer order with their bank in accordance with the bank's terms and conditions, provided that the funds have not yet been credited to Bull Bitcoin's account. Once the transfer amount is credited to Bull Bitcoin, the purchase or sale order becomes binding and irrevocable.

14. Incident Reporting and Redress

14.1 In accordance with MiCA Article 47(3), we provide a free, transparent complaints handling process. You may submit complaints via support@bullbitcoin.com or our app, using the methods and addresses indicated in the Claim Form. We acknowledge receipt within 5 business days and resolve within 30 days, providing reasoned decisions. If the User doesn't receive a response within the term, or if the response is not fully or partially favorable to the Client, or if the acceptance of the complaint has not been implemented, the Client may refer the matter to the AMF Mediator (https://www.amf-france.org/fr/le-mediateur) as provided in the Complaint Management Policy. This right applies to all disputes arising from Services provided by Bull Bitcoin and cannot be waived. The ADR procedure does not preclude the User's right to judicial remedies, according to the Article 20 of these Terms.

14.2 For incidents (e.g., system outages, errors), we notify affected users within 24 hours via the app, including details, impact, and resolution timeline.

15. Operational Resilience and Continuity

15.1 We implement appropriate technical and organizational measures to ensure the continuous and reliable operation of our Services, including business continuity and disaster recovery procedures.

15.2 We may temporarily suspend or limit access to the Services for scheduled maintenance. Where reasonably practicable, we will provide at least 48 hours' advance notice via the App and conduct maintenance during off-peak hours.

15.3 In the event of unscheduled service disruptions, we will:

notify affected users as soon as reasonably possible;
provide regular updates on the status and expected resolution timeline; and
work to restore Services in accordance with the severity of the incident.

15.4 Given the non-custodial nature of our Services, where we do not hold or control your funds or crypto-assets:

we are not liable for losses arising from service unavailability, delays, or disruptions beyond our reasonable control (including force majeure, third-party infrastructure failures, network congestion, or market volatility);
where disruptions are attributable to our fault, our liability is limited as set out in Section [12] of these Terms;
we are not liable for indirect losses, including loss of profit or trading opportunities resulting from service unavailability.

16. Fraud and scam disclaimer

16.1 As part of our regulatory obligations, we implement ongoing transaction monitoring and due diligence measures designed to detect and prevent money laundering and fraudulent activity. However, we cannot guarantee detection of all fraudulent schemes, particularly those involving social engineering or deception by third parties.

16.2 You acknowledge that: a) Bitcoin transactions are irreversible once confirmed on the blockchain. We cannot reverse, cancel, or recover transactions after execution; b) You are solely responsible for verifying the accuracy of recipient addresses and the legitimacy of any third party to whom you send funds, and c) we do not endorse, verify, or guarantee any investment opportunity, person, or entity you may interact with outside our Services.

16.3 We may suspend, freeze, or refuse to execute transactions if we detect suspicious activity or reasonably believe a transaction may be fraudulent. Such measures are taken in accordance with our AML/CFT Policy and may result in temporary service restrictions.

16.4 To protect against fraud, you should:

a) never share your account credentials, passwords, or verification codes with anyone, including individuals claiming to represent Bull Bitcoin;
b) be highly skeptical of unsolicited investment opportunities promising guaranteed or high returns;
c) verify independently any claims made by third parties before sending funds; and
d) do not allow others to remotely access your device or direct your use of our Services.

16.5 If you believe you have been the victim of fraud or a scam:

Contact our customer support immediately at support@bullbitcoin.com;
File a report with local law enforcement authorities.

We will cooperate with law enforcement investigations within our technical and legal capabilities, but cannot guarantee recovery of funds due to the irreversible nature of blockchain transactions.

16.6 Our liability for losses resulting from third-party fraud is limited as set out in Section 12. We are not liable for losses arising from your voluntary transfer of funds to third parties, regardless of the circumstances, except where we failed to comply with our statutory obligations under AML/CFT or MiCA regulations.

17. Prohibited Use

17.1 You are strictly prohibited from:

Using Bull Bitcoin services for any illegal or unauthorized purpose
Creating or operating multiple accounts
Providing false or misleading information
Impersonating or misrepresenting affiliation with any person or entity
Attempting to circumvent any security measures or restrictions
Engaging in any activity that interferes with or disrupts the Services
Using the Services for money laundering, terrorist financing, or other criminal activities
Attempting to manipulate or exploit the Services or exchange rates
Transferring funds to or from entities known for fraudulent behavior
Interacting with loan providers demanding cash or Bitcoin collateral
Engaging in any activities associated with scams or malicious intentions

17.2 The Services are not available to persons or entities located in, resident in, or subject to the jurisdiction of:

(a) EU/UN Sanctioned Countries: Belarus, Central African Republic, Democratic People's Republic of Korea (North Korea), Iran, Libya, Myanmar (Burma), Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, Zimbabwe, Ukraine (Crimea, Donetsk, and Luhansk regions)

(b) FATF High-Risk Jurisdictions (as updated from time to time): Currently includes: Democratic People's Republic of Korea, Iran, Myanmar.

(c) Other Restricted Jurisdictions: United States (due to licensing requirements), United Kingdom (due to regulatory requirements)

17.3 You represent and warrant that you are not located in, resident in, or subject to the jurisdiction of any Restricted Jurisdiction. We implement automated and manual checks to verify compliance, including IP address detection and identity verification.

17.4 We may update the list of Restricted Jurisdictions due to changes in sanctions regimes, regulatory requirements, or risk assessment. We will provide 30 days' notice before adding a jurisdiction (except where immediate action is required by law or regulation), during which affected users may withdraw funds subject to compliance procedures.

17.5 If we discover you are accessing Services from a Restricted Jurisdiction:

Your account will be suspended immediately;
You will be notified and given an opportunity to provide evidence you are not subject to the restriction;
If the restriction applies, you will be given reasonable time (minimum 30 days, unless legally prohibited) to withdraw funds, subject to completion of enhanced due diligence and compliance with applicable sanctions laws.

18. Intellectual Property Rights

18.1 We own all the intellectual property in Bull Bitcoin's products and Services (for example, the content in Bull Bitcoin's app and on Bull Bitcoin's website, Bull Bitcoin's logo and card designs, text, graphics, pictures, information, data, software, sound files, other files, content and materials, and the selection and arrangement thereof (collectively, "Bull Bitcoin Materials") are the property of Bull Bitcoin or our licensors our suppliers, and are protected by French and international property right laws). Subject to your compliance at all times with these Terms, we hereby grant you a limited, revocable, nonexclusive and non-sublicensable licence to access and use, solely on the Services, the Bull Bitcoin Materials for your personal use of the Services. Such licence is subject to these Terms and does not permit (a) any resale of the Bull Bitcoin Materials; (b) the distribution, public performance or public display of any Bull Bitcoin Materials; (c) modifying or otherwise making any derivative uses of the Bull Bitcoin Materials, or any portion thereof; or (d) any use of the Bull Bitcoin Materials other than for their intended purposes. The licence granted under this Article will automatically terminate if we suspend or terminate your access to the Services. All rights not expressly granted to you under these Terms are reserved to Bull Bitcoin or our applicable licensor(s) or supplier(s), as applicable. The User shall not reverse-engineer any of Bull Bitcoin's Materials or any of Bull Bitcoin's, our licensors' or suppliers' products (that is, reproduce them after a detailed examination of their construction or composition).

18.2 Trademarks. "Bull Bitcoin", the Bull Bitcoin logo, and any other Bull Bitcoin product or service names, logos or slogans that may appear on our Services are trademarks of Bull Bitcoin, and may not be copied, imitated or used, in whole or in part, without our prior written permission. In addition, the look and feel of our Services, including all page headers, custom graphics, button icons and scripts, is the property of Bull Bitcoin and may not be copied, imitated or used, in whole or in part, without our prior written permission. All other trademarks, registered trademarks, product names and company names or logos mentioned or displayed through our Services are the property of their respective owners. Reference to any products, services, processes or other information, by name, trademark, manufacturer, supplier or otherwise does not constitute or imply endorsement, sponsorship or recommendation by us.

19. Indemnification (Business Clients Only)

19.1 If you are acting as a business or professional user (not a Consumer), you agree to indemnify and hold harmless Bull Bitcoin and its officers, directors, employees, and agents from any third-party claims, damages, and expenses (including reasonable legal costs) directly arising from:

(a) Your provision of false, fraudulent, or misleading information during registration or KYC/AML verification, where such information results in regulatory sanctions or fines imposed on us;
(b) Your use of the Services in violation of applicable laws or these Terms, where such violation causes direct harm to us or third parties;
(c) Your infringement of third-party intellectual property rights, privacy rights, or other legal rights through your use of the Services;
(d) Claims by third parties arising from your intentional misconduct or gross negligence in using the Services.

19.2 This indemnity does not apply to claims arising from:

Our breach of these Terms or applicable law;
Our negligence or willful misconduct;
Failures of our systems, security, or operational processes;
Our violation of data protection or AML/CFT obligations.

19.3 We will promptly notify you of any claim subject to indemnification and provide you with a reasonable opportunity to defend such claim at your expense. We reserve the right to assume control of the defense if we determine our interests require it.

19.4 If you are a Consumer (as defined under the French Code de la consommation), this Section 18 does not apply to you. Your liability is limited to direct damages caused by your intentional misconduct or fraud, as determined by applicable law.

20. Taxation

Bull Bitcoin does not make any tax declarations on behalf of its customers. It is the responsibility of the Customer which, if any, taxes apply to the trades or transactions the User completes via the Services, and it is the User's responsibility to report and remit the correct tax to the appropriate tax authority, and to take all necessary and compulsory steps to pay taxes in accordance with the applicable legislation. You agree that Bull Bitcoin is not responsible for determining whether taxes apply to your trades or for collecting, reporting, withholding or remitting any taxes arising from any trades or transactions.

21. Governing Law and Dispute Resolution

21.1 These Terms are governed by and construed in accordance with the laws of France.

(a) Internal Complaints: Any dispute should first be submitted to our internal complaints handling procedure as described in Section 13. (b) Mediation: If you are not satisfied with our response, you may refer the matter to the AMF Mediator (Médiateur de l'AMF) free of charge at: https://www.amf-france.org/fr/le-mediateur. Mediation is voluntary but encouraged as a cost-effective means of resolving disputes.
(c) Arbitration (Optional): Following the above steps, both parties may agree in writing to submit the dispute to arbitration under the rules of Paris Chamber of Commerce. Any such agreement must be made after the dispute has arisen and is entirely voluntary.

21.2

(a) For Consumers: Without prejudice to your right to use the AMF Mediator, you may bring legal proceedings in either: The courts of your place of residence; or The competent courts of Paris, France (our registered office). We may only bring proceedings against you in the courts of your place of residence.

(b) For Business Clients: Subject to mandatory provisions of French law, disputes shall be submitted to the exclusive jurisdiction of the competent courts of Paris, France, unless otherwise agreed in writing.

21.3 All dispute resolution proceedings, whether mediation, arbitration (if agreed), or judicial proceedings, shall be conducted in French, unless all parties agree otherwise in writing.

22. Processing personal information

To provide services under this agreement we need to collect information about you. Under data protection law, we are what is known as the 'data controller' of the Client's personal information. For more information about how we use the Client's personal information, see Bull Bitcoin's Privacy Policy. By entering into this agreement the Client is giving us permission to gather, process and store the Client's personal information for the purpose of providing Bull Bitcoin's services to you. This doesn't affect any rights and obligations the Client or we have under data protection law. The Client can withdraw the Client's permission by closing the Client's account, which will end the agreement between the Client and us. If the Client does this, we'll stop using the Client's information for the purpose of providing Bull Bitcoin's services, but we may need to keep the Client's information for other legal reasons. In any case, Bull Bitcoin will always collect, process and store your personal data in compliance with the French Data Protection Act and the General Data Protection Regulation ("GDPR").

23. Severability

If any provision of these Terms is found to be unenforceable or invalid under any applicable law, such unenforceability or invalidity shall not render these Terms unenforceable or invalid as a whole, and such provisions shall be deleted without affecting the remaining provisions herein.

24. Entire Agreement

These Terms, together with the Privacy Policy and any other legal notices published by Bull Bitcoin on the Services, shall constitute the entire agreement between you and Leonod SARL concerning the Services.

25. Contact Information

If you have any questions about these Terms, please contact us at: contact@bullbitcoin.com.

By using Bull Bitcoin services, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions.

26. Law Enforcement Requests

Bull Bitcoin will respond to law enforcement requests from authorized law enforcement officials with proof of authority. The guide below explains how authorized law enforcement officials can contact Bull Bitcoin to request customer information.

Law enforcement inquiries provided to Bull Bitcoin should contain the relevant information to the request, including the details of the law enforcement agency, the related case officer or representative to contact, details of information requested, as well as a way in which Bull Bitcoin can authenticate the request being made as genuine.

The request should contain information that will help Bull Bitcoin identify the user or transaction for which the information is being sought. This could include Public Address, Transaction ID, IP Address, and Time & Date of suspicious activity.

Law enforcement inquiries can also include an attachment of any documentation that may be applicable or otherwise related to the request for information. These could include, but are not limited to, subpoenas, court orders, or search warrants.

27. Exchange Rates, Fees, and Transaction Limits

27.1 Bull Bitcoin displays its exchange rates, transaction fees, transaction minimums, transaction maximums, and estimated transaction processing times publicly at https://www.bullbitcoin.com/rates for the convenience of its users, for the sake of transparency and to provide information to the end user that may help them make a general assessment of our services.

27.2 Rates displayed on the homepage or at https://www.bullbitcoin.com/rates are indicative only. The rates and fees shown to you for confirmation are authoritative.

27.3 Funding and withdrawal fees are those displayed at https://www.bullbitcoin.com/rates and are authoritative.

27.4 The mention of "no fee" for certain services does not imply that Bull Bitcoin does not generate revenue. The mention reflects no extra processing fee on top of the buy/sell price (spread).

27.5 Transaction maximums publicly available at https://www.bullbitcoin.com/rates are subject to your identity verification levels and imply that your account has full identity verification. Transaction maximums may be significantly lower, or not available at all, if your identity verification is incomplete. Transaction maximums may be unique and customized for each user. If there is a discrepancy between the transaction maximums displayed at https://www.bullbitcoin.com/rates and the transaction maximums that apply to a specific user's account, the transaction maximum that applies to the user's account will prevail.

27.6 Transaction maximums may be subject to your own bank or payment processor. Transaction maximums listed at https://www.bullbitcoin.com/rates are the maximums that Bull Bitcoin will accept from you. Your bank or payment processor may impose its own maximums.

27.7 The fee applied to Express on-chain Bitcoin withdrawals is not collected by Bull Bitcoin. It is collected by Bitcoin miners. The feerate used for the transaction is always the priority feerate according to mempool.space. The feerate is accepted or rejected by the user at their sole discretion. The user understands and agrees that Bull Bitcoin has no control over the Bitcoin network fees.

27.8 Bull Bitcoin may impose additional transaction fees, at its sole discretion, on transactions sent by users to Bull Bitcoin whose amounts are below the minimum visible at https://www.bullbitcoin.com/rates.

27.9 The processing times displayed publicly at https://www.bullbitcoin.com/rates are meant to provide a general assessment of typical processing times and delays associated with particular transaction types. They do not constitute a guarantee or service-level agreement by Bull Bitcoin. Processing delays can be caused by multiple factors outside of its control. Bull Bitcoin will always attempt to process transactions on a best-effort basis, in line with our operational resilience commitments.

28. Amendments

28.1 Bull Bitcoin reserves the right to modify these Terms at any time, at our sole discretion. Any changes will be effective immediately upon posting on our website.

28.2 Your continued use of our Services after such changes constitutes your acceptance of the new Terms. If you do not agree to the modified Terms, you must discontinue using our Services.

28.3 We will make reasonable efforts to notify users of material changes to the Terms, but it is your responsibility to review these Terms periodically.