TERMS AND CONDITIONS RELAI SERVICES

Last updated June 26, 2025

1. General & Scope

The general terms and conditions herein (the “Terms”) define the rights and obligations between Relai (as defined below) and you (an individual, or an entity acting through an authorized individual, hereinafter the “Client”) in connection with the use of the Mobile App and the Web App as defined below (the “Apps”) to access the Services (as defined below) offered therein.

These Terms are a legally binding agreement (the “Agreement”) between the Client and Relai AG, a company organized and existing under the laws of Switzerland, under company registration number CHE-340.229.036 whose registered office is located at Hardturmstrasse 161, 8005 Zürich (hereinafter “we”, “us”, “our” or “Relai”).

Relai is registered as a Crypto-Asset Services Provider (CASP) with the VQF (Verein zur Qualitätssicherung von Finanzdienstleistungen). The VQF is established at General-Guisan-Strasse 6, CH-6300, Zug. Relai’s registration relates to the provision of services involving crypto-assets. This means Relai provides regulated services when Clients buy or sell Bitcoin via Relai’s infrastructure through the Apps (Mobile or Web) as defined above. Clients use the Relai platform to initiate and complete transactions involving Bitcoin in compliance with applicable AML/CTF and crypto-asset regulations. Relai is also registered with the OAM (Organismo Agenti e Mediatori) in Italy, allowing it to operate legally as a virtual asset service provider (VASP) under Italian regulatory requirements.

Please note that Relai does not issue electronic money or provide fiat payment services; the platform operates exclusively in the context of non-custodial Bitcoin transactions.

In these Terms:

• Applicable Law means the legal, regulatory and administrative provisions, as well as the professional standards applicable to Relai in connection with these Terms.
• Business Client refers to any legal entity, company, partnership, sole proprietorship, foundation, association, or other organizational structure that registers for and uses the services provided under Relai Business for professional or commercial purposes. Business Clients act on behalf of their organization and are subject to enhanced due diligence, including verification of the Authorized Representative(s), ownership structure, and compliance with applicable corporate, financial, and anti-money laundering (AML) regulations.
• Consumer means any natural person who is acting for purposes which are outside his or her trade, business, craft or profession, in accordance with the definition set forth in Article 2(1) of Directive 2011/83/EU of the European Parliament and of the Council. This definition shall apply where relevant under the applicable law.
• Identifiers refers to the personal credentials that allow the Client to access their account or the services provided by the platform (usernames or login IDs, passwords and authentication tokens or codes, such as 2FA codes or API keys if applicable for integrations).
• KYC Process means the process of verifying the identity of a company’s Clients or an individual —“Know Your Customer”—in order to ensure the Client complies with legislation related to the prevention of corruption, money laundering, financial fraud, terrorist financing, and other regulatory obligations to which Relai is subject. For Private’s Client and Business Client a CDD Process —“Customer Due Diligence”— is also required due to the possibility of purchases exceeding the Maximum Threshold. CDD Process refers to the identification and verification process Relai carries out to comply with applicable anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. For individual Clients, this includes collecting and verifying personal identification data and, where required, assessing the source of funds. For Business Clients, the procedure includes verifying the existence and structure of the legal entity, identifying and verifying the identity of its beneficial owners and authorized representatives, and assessing the nature and purpose of the business relationship. Relai conducts these procedures in line with Swiss AML regulations and any applicable European regulatory requirements.
• Maximum Threshold means the highest permissible limit, as determined by Relai, for individual or cumulative bitcoin purchase or sale transactions over a specified time period. This threshold may be subject to internal risk controls, regulatory requirements, or service tier limitations, and exceeding it may require additional verification or may not be allowed.
• Mobile App refers to the mobile application provided by Relai, which allows Clients to easily and securely buy, sell, and store bitcoin in a self-custodial manner.
• Order refers to a request placed by the Client to either purchase Bitcoin using fiat currency (“Purchase Order“) or sell Bitcoin already in their possession for fiat currency (“Sale Order“). Each Order is processed under predefined conditions, in accordance with Relai’s Pricing Policy, and at a price unilaterally determined by Relai; such price is not formed on, nor executed through, any trading venue. The Client cannot modify or customize any specific parameters, including price and processing method.
• Seed refers to the unique recovery phrase (also known as “seed phrase” or “mnemonic phrase”) consisting of a sequence of words (12 or 24) generated during the Wallet creation process. This phrase enables the Client to recover and access their Wallet and to authorize transactions. In the case of non-custodial wallets such as the Wallet created by the Mobile App, the Seed is generated and stored solely on the Client’s device and is never accessible to Relai or any third party.
• Rate refers to the exchange rate at which bitcoin is purchased or sold during a transaction. This is the price or value that Relai offers to the Client at the moment they authorize or initiate a transaction.
• Relai Business refers to the dedicated service offering for legal entities, and companies that wish to buy and manage Bitcoin for business purposes. This service includes enhanced onboarding, tailored compliance procedures, and operational support to meet regulatory and corporate requirements. Relai Business is not intended for personal or retail use.
• Relai Private refers to the individual user account and associated services offered by Relai for non-professional, retail clients. It is designed for personal use only, allowing individuals to buy, sell, and manage Bitcoin in a simple, non-custodial environment via the Mobile App. Clients of Relai Private must act on their own behalf and not for any third party, business, or organization.
• Service(s) means: (i) the purchase or sale of bitcoin against legal tender currency (Euro/EUR); (ii) the access to a non-custodial wallet application, enabling the Client to create and manage a personal bitcoin wallet to retain full control and responsibility for their private keys and funds. In this regard, the Client is informed that Relai is a virtual asset service provider (“VASP”) registered with the VQF and OAM for the purpose of providing the Services on Bitcoin.
• Site refers to Relai’s website (www.relai.app).
• Wallet means the non-custodial bitcoin wallet automatically created on the Client’s mobile device upon installation and first use of the Relai Mobile App. This Wallet is designed to give the Clients full control over their private keys and bitcoin holdings. Relai does not have access to, nor does it store or manage, the Client’s private keys, Seed, or bitcoin at any point. Only the Client has the ability to access and manage the bitcoin held in the Wallet.
• Web App refers to the browser-based application provided by Relai. The platform enables qualified Clients to buy, sell, and manage large volumes of bitcoin securely and efficiently, with tailored features and dedicated support. Like the Mobile App, the Web App offers a non-custodial experience, ensuring that users retain full control over their bitcoin at all times.However, the Web App does not store private keys or enable direct transaction processing, it provides interfaces through which users can initiate operations that are securely processed via the Mobile App or an external wallet.

Relai provides the Services described in these Terms, in particular on the basis of a mandate received by the Clients, and thus operates the Site and the App in compliance with the Applicable Law.

The pricing conditions in force are mentioned in the Pricing Policy.

2. Acceptance and modification of the Terms

Your consent to these Terms is given once you tick the box in the pop-up window which appears upon your first connection and which states that you have read and accepted the Terms. By ticking the box, the Client agrees to be bound by the Terms, as amended and published on the Apps, and to comply with these Terms and all Applicable Laws.

The Terms may be supplemented, where applicable, by technical instructions for use of the Services sold on the Site. In the event of a contradiction, these Terms take precedence over the instructions for use, unless otherwise stated. No special conditions not expressly approved by Relai may prevail over these Terms.

If you do not agree with the Terms, you should refrain from using the Apps and/or the Site. In particular, you acknowledge that you have read and understood the clauses in the Terms relating to Relai’s limitation of liability.

The Terms may be updated by Relai at any time without any prior notice requirement. The current version is published on the Site. You are expected to review such Terms on a regular basis. If you do not agree with any such modification, you should cease using the Services. You agree that any amendments to the Agreement will be communicated to you via email. Your continued access and/or use of the Services, and the Apps following such notification shall constitute an affirmative acknowledgment of the amendments and shall be deemed your acceptance of the revised Agreement.

These Terms are drafted in English and translated to French, German, and Italian. In case of conflict, the English version shall be the binding version.

3. Availability

Relai shall endeavor, as far as possible, to keep the Apps accessible 7 days a week and 24 hours a day. However, access to the Apps and the Site may be temporarily suspended due to technical maintenance, migration or updates, or due to breakdowns or constraints in relation with the operation of the internet. Relai is not liable for any malfunction or inability to access the Apps and the Site attributable to third parties, because of unsuitable equipment of the Client or because of any other circumstances not attributable to Relai (see also what is provided in Article 15. Force Majeure). Subject to the mandatory limits of the law, compensation for direct and indirect damages is excluded.

Although Relai intends to provide accurate and timely information on the Apps and the Site, they may not always be entirely accurate, complete or current and may also include technical inaccuracies or typographical errors. Accordingly, the Client shall verify all information before relying on it. All decisions based on information contained on the Apps and the Site are in the sole responsibility of the Client and Relai shall have no liability for such decisions.

4. Warning

The Client acknowledges and accepts that the Services involve a high-risk asset, which may not be suitable for all individuals. The Clients should ensure they have the financial capacity and expertise to bear these risks, as well as actively monitor their bitcoin (for more details see our Risk Disclosure).

The information provided on the Apps and the Site does not constitute legal, financial, or investment advice, nor is it a recommendation to buy, sell, or trade bitcoin. Relai is not liable for reliance on any statements made or omissions from the provided information. All investment decisions remain solely the responsibility of the Client.

By using the Apps, the Client explicitly warrants that he/she is at least eighteen (18) years old and has legal capacity to contract and that he/she is not barred to use the Apps under any Applicable Law. 

5. Access to the Site, Apps, and Services

Clients are responsible for setting up the IT and telecommunications resources allowing access to the Site and the Apps. Clients are entirely responsible for the correct functioning of their computer equipment, their modem and their telephone line, as well as their Internet connection. Clients will have taken care to ensure that this equipment does not present any problems or viruses and has sufficient security to prevent the risk of a third party obtaining access to data relating to the Services.

Clients will make every effort to preserve this security. Clients will ensure that there is no risk of hostile programs or viruses accessing and disrupting the Site’s computer systems. In particular, Clients will ensure the security of their computer by using and regularly updating anti-virus and anti-spyware software as well as a personal firewall. Clients assume technical risks in particular linked to a power outage, an interruption of connections, a malfunction or even the overload of networks or systems. Furthermore, Customers are aware that they must contact the Internet service provider of choice to access the Internet and the Site. In this context, Clients are aware that it is up to them to select their Internet access provider and to establish the terms of their relationship with the latter. Relai cannot be responsible for the risks relating to Internet access and the risks relating to the remote transmission of data by or to Clients, particularly in the event of a conflict between the Clients and this Internet access provider, in relation to the confidential/personal nature of the data transmitted, the cost of transmission, the maintenance of telephone lines and the Internet network or even service interruptions.

The Services are accessible, subject to the restrictions provided on the Site: (i) to any natural person with full legal capacity to commit to these Terms. The natural person who does not have full legal capacity can only access the Site, the Apps and the Services with the agreement of their legal representative; (ii) to any legal entity acting through a natural person having the legal capacity to contract in the name and on behalf of the legal entity.

Registration is done by completing an online form. Once the form has been completed and validated, the Apps send an email confirming the Client’s request. The Client who has completed the necessary verification steps to have the right to have access to the Services on the Apps is deemed to have entered into a business relationship with Relai and is therefore considered a Client linked by these Terms.

When registering, the Client undertakes to provide accurate and complete data (in particular, with respect to his/her personal information, e-mail address and, if necessary for the purpose of completing the registration, his/her personal telephone number), and is required to complete all mandatory fields appearing in the registration form. The Client will then validate their registration by clicking on the button provided for this purpose. Relai reserves the discretionary right to refuse any request to enter into a business relationship.

The Clients will be responsible for the use of his Identifiers by third parties or for actions or declarations made through his personal account, whether fraudulent or not, and guarantees Relai against any request in this regard. Furthermore, Relai is not responsible in the event of theft of the Clients’ identity. If the latter has reason to believe that a person is fraudulently using the Client’s identification or account, he must immediately inform Relai.

In the event of loss or theft of one of the Identifiers concerning him/her (email or password), the Client is responsible for any harmful consequences of this loss or theft, and must use, as soon as possible, the procedure allowing him/her to modify them. In the event that he/she becomes aware of another person’s access to his/her personal account, the Client will immediately inform Relai by email to the following address: [email protected].

Use of the Site and/or the App which is fraudulent, or which contravenes these Terms, will justify refusing the Clients, at any time, access to their Account as defined below.

6. Purchase and Sale of Bitcoin assets

6.1. General

Relai enables the Client to purchase or sell Bitcoin as a one-time purchase or on a monthly, weekly, or daily basis by placing a recurring order with the Client’s bank. The amount of bitcoin that the Customer intends to purchase on a one-time or recurring basis must be specified in advance by the Customer and must be paid in Swiss francs (CHF) or euros (EUR).

The Service is offered in three different modes: (i) Mobile App is for any individuals who wishes to buy and sell bitcoin, starting from a minimum of fifty euros (50.00 CHF/EUR); (ii) Relai Private is for individuals who wish to buy or sell amounts over the Maximum Threshold with exclusive personal service that will make the experience smooth using the Web App, in addition to the Mobile App; (iii) Relai Business is for legal entities who wish to buy or sell amounts with exclusive personal service and expert guidance that will make the experience smooth using the Web App. Orders from Relai Business can start with a minimum first order of twenty thousand euros (20,000.00 CHF/EUR) and consecutive orders should be a minimum of one thousand euros (1,000.00 CHF/EUR).

Relai enables users to buy and sell bitcoin directly through the Apps in a non-custodial manner. From the moment the Client has successfully completed the registration process and completed the KYC Process, the Client will be assigned a personal profile (the “Account”) to access the Apps. This Account does not constitute a custodial account and does not hold or store any funds or assets on behalf of the Client. The Client agrees not to disclose any information about the Account to any third party. The Client represents that it is solely responsible for maintaining the confidentiality and security of the Account and all Services to which it will have access through the Account. Any breach of the security of the Account must be reported immediately to Relai, who will not be liable in any event for any damages, costs or expenses arising out of or resulting from any breach of security.

Relai reserves the right to request, at any time and at its sole discretion, additional information regarding the Client to enable the proper operation and delivery of the Services. In any case, Relai may suspend the operation of the Account, or proceed to its termination.

To receive or send bitcoin, the Client must provide Relai with addresses that they directly control (non-custodial wallet) or that are held with authorized intermediaries (custodial wallet).

6.2. Service and technical specifications

Relai uses multiple-factor authentication: i) email (proof of email control via OTP); ii) user device finger print (proof of device ownership); iii) a PIN or a face scan of the Client. Once a Client has verified the 3 factors above, the Client is logged in and has 2 options to unlock the app: a) use the phone level touch id or face id; b) use the Keyless pin or face scan.

Relai processes Orders only upon the Client’s explicit request. To do so, the Client must provide specific instructions, detailing i) for Purchase Orders, the amount in fiat currency; and ii) for Sale Orders, the amount they intend to be sold. Orders are processed exclusively under predefined conditions, without any possibility for the Client to customize specific parameters. Prices are set in accordance with the Relai Pricing Policy and are unilaterally determined by Relai at the time of processing.

Relai facilitates the direct sale of bitcoin from its own pre-allocated reserves. Payouts to the Client’s self-custodial wallet are processed in scheduled batches. Depending on blockchain network activity and internal processing schedules, it may take several hours for the bitcoin to arrive in the Client’s wallet.

By placing the Order, the Client confirms under their sole responsibility that: i) the information provided is complete; ii) they have reviewed and understood Appendix230_Risk Disclosure_V2; iii) they have read, understood, deemed appropriate, and accepted the economic terms and fees as specified in the Pricing Policy. Once placed, an Order cannot be revoked or modified by the Customer unless expressly permitted by these Terms.

6.3. Purchase process via Apps

To use the Apps, the Client is required to complete the identification process. Relai reserves the right to determine, on a case-by-case basis and in accordance with Applicable Law and internal risk assessments, whether to accept a Client and which identification information is required. All decisions shall be made based on objective, non-discriminatory criteria, ensuring compliance with regulatory requirements and Relai’s internal policies.

Private clients can place orders through both the Mobile and Web Apps. Business clients may place orders exclusively via the Web App.

Before starting the purchase, the Client, in order to be able to place Bitcoin purchase orders, must join and/or own one of the payment systems accepted by Relai for the use of the Service with the liquidity necessary to proceed with the order. The payment systems accepted by Relai are indicated in the Apps.

The Client can create a one-time or recurring purchase order and can specify the amount in EUR, the frequency, and the target asset (bitcoin) he/she would like to invest in. Clients shall not create a purchase order for less than the minimum amount of CHF/EUR 50.00 (the “Minimum Threshold”). Through the Apps, the Client will receive transfer information to initiate a one-time or recurring order using his/her preferred method of payment. The Client expressly acknowledges and agrees that he/she is solely responsible for entering the correct transfer information. The Client also acknowledges and agrees that the amount of money transferred must exactly correspond with the investment amount indicated in the Apps. Otherwise, Relai will not be able to accept the payment and will refund the amount to the Client; any associated bank fees shall be borne by the Client. Furthermore, the Client must ensure that the bank account used for the transfer matches the account (IBAN) specified in the Apps. If the payment is made from a different IBAN than the one indicated, the deposit will be rejected and refunded. The transaction costs of the bitcoin, which will be transmitted to the Client, are included (see Section 6.8.).

When creating a purchase order the Client agrees to be the sole beneficial owner of the funds he/she intends to use to buy bitcoin. Using our Services via Apps, you confirm that you act on your own behalf as an individual, for your own account, and not on behalf of a legal entity or for the account of anyone other than you.

Relai reserves the right to exclude customers from further purchases at any time in accordance with Applicable law and internal risk assessments. All decisions shall be made based on objective, non-discriminatory criteria, ensuring compliance with regulatory requirements and Relai’s internal policies.

6.4. Price and execution model

6.4.1. Price determination

Relai determines the purchase and sale prices (the “Rates”) offered to Clients entirely at its own discretion, using a proprietary methodology that aggregates external market data and applies Relai’s internal spreads, fees, and risk parameters. The Rates and pricing methodology are indicated in the Pricing Policy available in the App.

6.4.2. Execution model & methodology disclaimer

By placing an Order, the Client acknowledges and accepts that:

(a) Relai acts exclusively as principal and not as broker or agent;

(b) Client Orders are filled directly against Relai’s own inventory and are not routed to or executed on any trading venue or exchange.

Nothing in these Terms shall be construed as an obligation for Relai to apply other methodology that provided in the Pricing Policy or to align its Rates with those observable on external markets.

6.4.3. Suspension of Quotes & Orders

Relai may temporarily suspend the display of firm prices, the application of its pricing methodology, or the acceptance / execution of orders in any of the following situations (“Exceptional Market or Operational Conditions”):

• Market-data outage: none of Relai’s reference venues provide reliable or timely price feeds, or the primary venue used by Relai is suspended.
• Excessive latency in price feeds that exceeds Relai’s predefined tolerance thresholds.
• Periods of extreme volatility or market stress that render the standard spread or methodology inadequate.
• Regulatory intervention: prohibitions, trading halts or other supervisory measures imposed by a competent authority.
• Technological failure or technical unavailability of the Apps or core systems (e.g., maintenance, system overload, force-majeure IT incident) that prevents accurate quote generation or order routing.
• Risk-management suspensions: Relai reaches internal risk limits or is temporarily unable to hedge or otherwise manage its market exposure.

During any such suspension Relai may, at its discretion, (a) defer execution until normal conditions resume or (b) reject the order and refund the Client. Clients will be informed through in-app notification or e-mail as soon as practicable.

6.5. Order Completion and Payment Processing

For One-Time Purchases, the Order (“One-Time Purchase Order”) will remain open for a period of five (5) calendar days from the date of submission. The Client must complete the payment within this period. If the payment is not received within this timeframe, the Order will be automatically canceled, and the Client will be required to submit a new Order to proceed with the One-Time Purchase.

For recurring purchases, the order (“Recurring Purchase Order”) will be finalized upon Relai’s receipt of the corresponding recurring payment. The Recurring Purchase Order will remain active and valid, provided that payment is received within five (5) calendar days from the initial submission and subsequently within the same five (5)-day period following each scheduled due date. For example, if the Client places a Recurring Purchase Order on 2 September, payment must be completed by 7 September and by the 7th of each subsequent month. If payment is not received within this timeframe, the Recurring Purchase Order will be automatically canceled, and the customer will need to submit a new order to continue using the service

The applicable exchange rate shall be determined at the moment when Relai receives the payment in full in the designated bank account. The Client acknowledges that exchange rates may fluctuate between the submission of the Order and the receipt of payment.

If the Client fails to complete the payment within the applicable deadlines mentioned above, the Order will be canceled without liability to Relai. The Client will be required to submit a new Order to initiate the purchase process again.

6.6. Sale process via Apps

The Client may use the Apps to sell bitcoin only if the annual sales amount does not exceed the Maximum Threshold. It remains at the sole discretion of Relai to accept or not accept a Client and the type of information required by Relai for proper identification of the Client.

The sale on Relai takes place exclusively as follows. The Client previously has bitcoin in his/her Wallet. The Client then makes a binding offer to sell bitcoin to Relai. In order to make such a binding offer, the customer must a) fill in all the necessary data on the respective trading screens in a valid and correct manner and b) confirm the “Sell Now” button. The Client is shown an estimate of the expected amount of euros in the sales process. After a successful sale, the Client is shown the exact amount of the sale in his dashboard. The exchange rate for cryptocurrencies is set at the time Relai receives the payment of the Client and can therefore vary significantly from the exchange rate estimated by the Apps. The transaction costs of the bitcoin, which will be transmitted to the Client, are included. Relai will process the sell order within ten (10) business days of receipt of payment and allocate the CHF/EUR to the IBAN of the Client.

When creating a sell order the Client agrees to be the sole beneficial owner of the funds he/she intends to use and to be the sole beneficial owner of the bank account used for the transfer. By selling bitcoin to Relai, you confirm that you act on your own behalf as an individual, for your own account, and not on behalf of a legal entity or for the account of anyone other than you.

Relai reserves the right to exclude Clients from further sales at any time without giving reasons.

6.7. Wallet

On each device (smartphone, tablet, etc.) the Client is installing and using the Mobile App, the Mobile App creates a digital non-custodial wallet enabling the Client to store bitcoin bought through the Mobile App (the “Wallet”). The Wallet is not a “web wallet”. The Client does not create an account or give Relai its bitcoin to hold onto. The Mobile App does not constitute an account where Relai or other third parties serve as financial intermediaries or custodians of the Client’s bitcoin. Relai does not have, at any point in time, access to the Client’s funds. The Client’s private key is generated and stored solely on the Client’s mobile device during the wallet creation process. Your Seed is the master key to your entire wallet. Anyone with access to it can derive all private keys and control your funds. For this reason, your seed phrase must be stored securely and never shared. Relai does not have access to or store any fragments, copies, or encrypted versions of the Client’s private key or Seed. The Wallet is fully non-custodial, ensuring that only the Client has control over and access to their private keys. If the Client loses access to his/her smartphone, the Client expressly acknowledges and agrees that any bitcoin the Client has associated with that Wallet will become inaccessible, unless he/she has created a backup of the Wallet by writing down the Wallet’s private key. The Client expressly acknowledges and agrees that he/she is solely responsible for safekeeping the smartphone and for backing up his/her private key in order to be able to restore his/her bitcoin assets again. In order to ensure the Client’s security and privacy, no sensitive data is ever saved, stored, or transmitted when the Client uses the Wallet. Relai only has access to information that a) has been inserted to the Apps by the Client in the identification process or b) is publicly available on the blockchain. Relai does not hold the bitcoin of the Client. Only the Client itself can access and control its bitcoin. The Client can freely transfer his/her bitcoin from his/her Wallet to another wallet at any time. 

Alternatively, the Client can send the bitcoin directly to an external wallet. In this case, the bitcoin purchase or sale will be sent directly in the external wallet, provided that the destination address has been whitelisted in advance. The processing will take place as soon as the corresponding bank payment settles or the bitcoin arrives in the Relai sell wallet with at least one on-chain confirmation.

The Web App offers the same core functionality as the Mobile App, allowing Clients to buy and sell bitcoin easily and intuitively. It is designed to further simplify the user experience by enabling access from any desktop browser. However, the Web App does not store or access the Client’s Wallet or private keys. The non-custodial Wallet and its associated Seed (recovery phrase) are created and stored exclusively on the Client’s mobile device via the Mobile App. As such, the Seed cannot be displayed or accessed through the Web App. It is the Client’s sole responsibility to securely back up their Seed offline, as it is the only way to recover access to the Wallet and the associated bitcoin in the event of device loss or failure.

6.8. Buy and/or Sell process over the Maximum Threshold by Relai’s Private Clients and Business Clients

Buy and/or sales over the Maximum Threshold are handled for the new first-time Client by Relai’s Private or Business team (the “Relai’s Team“). After accepting the Terms, finishing the CDD Process and completing the first Order, the Client will be able to place an Order above the Maximum Threshold either through the Relai’s Private Team or through the Apps.

Furthermore, a Business Client may complete the KYC process through a natural person who is a duly authorized legal representative using the Relai Mobile App. This individual is registered with Relai solely for identity verification purposes. Buy and sell orders for Business Clients are placed through external wallets that have been whitelisted by Relai, through the AOPP-based verification flow. The Business Client remains fully liable for any transactions processed through such authorized and verified wallets.

6.9. Termination of Use of the App

The Client may at any time, at its sole discretion, terminate the one-time or recurring order with his/her bank or stop using the App, subject to the completion of any order already placed and related payment already processed prior to the termination date. There is no minimum investment term. It is in the sole discretion of the Client whether he/she wants to continue to use the Apps or not. 

Relai may also terminate the possibility for the Client to use the Apps at any time for any reason, at its sole discretion. Such actions may be taken if Relai deems that the Client has breached the Terms in any manner. Additionally, Relai may at any time, at its sole discretion, cease the operation of the service or any part thereof, temporarily or permanently, without giving any prior notice. The Client agrees and acknowledges that Relai does not assume any responsibility or liability with respect to, or in connection with, the termination of the services provided on the Site or with the Apps. 

Any termination does not affect the access of the Client to his/her Wallet. The Client can still freely transfer his/her bitcoin from his/her Wallet to another wallet at any time, or restore the funds associated with the Wallet using the private key.

7. Trade transparency & confirmation

7.1. Pre-trade transparency

Pre-trade Transparency. The information relating to pre-trade transparency obligations is set out in the Pricing Policy available in the Apps.

Recurring Purchase Mandate. By activating a Recurring Purchase or Sale Order, the Client grants Relai a standing mandate to execute successive transactions on the scheduled dates using the best available market price at the time of each execution. The Client acknowledges and accepts that each execution price will vary according to prevailing market conditions and expressly waives any requirement for additional pre‑trade price publication. The execution price, together with fees, will be disclosed in the Post‑Trade Receipt (see Section 6.9).

7.2. Transaction confirmation and statements

Receipt. Relai shall provide the Client, promptly after each executed Order, with a transaction summary that is accessible either within the Mobile App or via Web App. This confirmation shall include the following details: (i) the type of transaction (buy or sell); (ii) the date and time of execution (UTC); (iii) the quantity of bitcoin and corresponding fiat amount; (iv) the execution price per bitcoin (inclusive of all fees); and (v) the total fees or charges applied.

Transaction statement. Relai will make available to the Client, within five (5) business days following the end of each calendar month, a downloadable account statement summarising all transactions carried out during the relevant period, inclusive of cumulative amounts, average execution price, and total fees. The statement shall include cumulative transaction amounts, the exchange price, and total fees applied. It will remain accessible to the Client without time limitation in the secure section of the Mobile App or Web App.

8. No right of Withdrawal – Cancellation

The Client, including Consumers, does not have the right to withdraw from bitcoin purchases or sales made through the Apps. This is in accordance with the Consumer Code, which excludes the right of withdrawal for products or services whose price depends on fluctuations in the financial markets beyond the professional’s control, as is the case here. Such fluctuations can occur during the withdrawal period, making it inapplicable.

The provisions of Article 7.1 above do not affect the Customer’s right to cancel the transfer order with their bank, according to the bank’s terms and conditions, as long as the amount has not yet been credited to Relai. Once the amount is credited, the purchase or sales order becomes irrevocable and cannot be canceled.

9. Client’s Conversion Fee

Each Bitcoin purchase is subject to a fee (the “Conversion Fee“). The applicable Conversion Fee varies based on the transaction size and type, and it may differ from the rates/prices displayed for informational purposes in the App. By authorizing or initiating a transaction, you agree to accept the applicable Rate at that time. Please note that this Rate may differ from the prices or charts shown in the App, which are for informational purposes only. This price data is sourced from one or more Third-Party Service Providers and should not be relied upon as an exact representation of Bitcoin’s actual price.

Relai will not process a transaction if the Conversion Fee and any other associated fees would, together, exceed the value of the Client’s transaction.

In this Conversion Fee, the transaction costs of the bitcoin, which will be transmitted to the Client, as well as a) the brokerage fee of Relai, b) the service fee of Relai c) a margin applied by Relai, from which Relai earns revenue, and d) any fees applied by payment providers, from which payment providers earn revenue, are included.

10. Unauthorized and mistaken transactions

When a bitcoin transaction or euro transaction occurs using your credentials, we will assume that you authorized such a transaction, unless you notify us otherwise. If you believe you did not authorize a particular transaction or or that a transaction was incorrectly carried out, you must contact us as soon as possible using our helpdesk. It is important that you regularly check out your Wallet (as defined in Article 7) and any other wallets accessible through the App (see Article 7, last paragraph) and your transaction history to ensure you notify us as soon as possible of any unauthorized or incorrect transactions. Reporting an unauthorized transaction does not mean Relai will be able to reverse the transaction or reimburse you for the transaction.

In the event that a Client makes a bank transfer to Relai’s account without linking it to a purchase order, or in the case of unauthorized transfer amounts, and Relai is unable to proceed with the purchase, the transferred funds will be promptly returned to the Client. If Relai, even with the assistance of the involved payment institution, is unable to identify the Client or credit the funds back to the original account, Relai will attempt to notify the Client using the contact information available. The funds will be held by Relai for a period of ten (10) years, as required by law. Relai reserves the right to offset any notification costs or other administrative expenses incurred for holding the funds.

11. Claims and fund handling during cessation of Services

In the event of a permanent cessation of Services, including liquidation or operational wind-down, Relai shall implement a formal process to allow Clients to review and submit claims strictly related to any unsettled transactions that may have resulted in a balance owed by Relai.

Clients will be notified in writing (via email and/or in-app notification) of the closure process and will be granted a minimum of sixty (60) calendar days from the date of such notice (the “Claim Period”) to: (i) review any available account information; (ii) submit outstanding claims related to fiat payments that were not processed due to service interruption; and (iii) request the withdrawal or refund of any eligible fiat balances temporarily held and not yet used for cryptocurrency purchase. Claims submitted during the Claim Period shall be reviewed and processed in good faith, fairly and transparently, and in compliance with applicable legal and regulatory requirements.

If a Client fails to submit a Claim or request a refund within the Claim Period, and the total value of the not-yet-processed fiat funds temporarily held is less than fifty euros (50.00 CHF/EUR) such amount shall be deemed abandoned. Abandoned balances under this threshold may be irrevocably forfeited and applied by Relai to cover the administrative, technical, and compliance costs associated with the service termination. No additional notice shall be required, and no claims will be accepted after the expiration of the Claim Period.

For any unclaimed fiat balance exceeding the fifty euro (50.00 EUR), Relai will make reasonable efforts to return the funds to the Client, including: (i) attempting to credit the amount back to the original account or payment method used; (ii) cooperating with the involved payment institution to verify the Client’s identity and payment details; (iii) notifying the Client using the latest available contact information (e.g., email or in-app messages) if automatic reimbursement fails. If Relai, even with the assistance of the involved payment institution, is unable to identify the Client or credit the funds back to the original account, and the Client does not come forward within the Claim Period, such funds may be held in escrow or treated in accordance with applicable unclaimed property or escheatment laws.

After the Claim Period ends, all user interfaces and accounts will be deactivated, and any residual data or transaction history shall be retained or deleted in accordance with the Relai’s record-keeping obligations and applicable data protection laws.

During the cessation period, Relai will provide periodic updates to Clients regarding the status of the process, anticipated timelines, and any changes to procedures affecting their ability to recover eligible funds.

12. Miscellaneous

12.1. Severability

If any term or provision of these Terms is invalid, illegal or unenforceable in any jurisdiction, it will be so held to the minimum extent required by law and such invalidity, illegality or unenforceability shall not affect any other term or provision these terms or invalidate or render unenforceable such term or provision in any other jurisdiction. Upon a determination that any term or provision is invalid, illegal or unenforceable, the parties hereto shall negotiate in good faith to modify these terms to effect the original intent of the parties as closely as possible in order that the transactions contemplated hereby be consummated as originally contemplated to the greatest extent possible.

12.2. Assignment

Relai reserves the right to assign or transfer this Agreement, in whole or in part, to any affiliated entity within the Relai Group, provided that such transfer is conducted in compliance with applicable laws and does not materially affect the rights of the Client under this Agreement. In the event of such assignment or transfer, Relai will notify the Client in advance, and the Client’s continued use of the services following such notification shall constitute acceptance of the assignment. The Client may not assign or transfer any rights or obligations under this Agreement without the prior written consent of Relai.

12.3. Warranties

By using the Apps, the Client warrants that: (a) the Client has obtained sufficient information about bitcoin to make an informed decision to purchase the bitcoin; (b) the Client has carried out an examination as to whether bitcoin meet the Client’s own requirements regarding the Client’s own objectives, risk appetite, experience and/or knowledge; (c) The Client’s purchase of bitcoin complies with Applicable Law in the Client’s jurisdiction; and (d) if the Client is purchasing bitcoin on behalf of any entity (i) such legal entity is duly organized and validly existing under the Applicable Laws of the jurisdiction of its organization, (ii) the Client is duly authorized by such legal entity to act on its behalf and to accept these Terms, and (iii) such entity will be responsible for breach of these Terms by the Client or any other employee or agent of such entity.

13. Intellectual Property rights

Relai is the sole owner of all intellectual property rights related to the Site and the Apps. Any content presently displayed or made available by Relai in the future, such as text, logos, images, music, digital downloads, and data compilations, icons and images (“Materials”) is the property of Relai, its affiliates or its suppliers, and is protected by Swiss and international intellectual property law. Relai’s names and logos are trademarks of Relai. Relai’s trademarks and logos may not be used for products or services that are not respectively manufactured or offered by Relai, or in any way that could cause confusion in the public, or in any way that disparages or discredits Relai.

The use of any such Materials on any other Site or networked computer environment for any other purpose is strictly prohibited; any such unauthorised use may violate copyright, trademark and other applicable laws and could result in criminal or civil penalties. Accordingly, the Client agrees not to reproduce, represent, extract and use in any way any or all of Relai’s trademarks, logos, Apps, Site or Services.

14. Limitation of Liability

TO THE MAXIMUM EXTENT NOT PROHIBITED BY LAW, RELAI AND ITS AFFILIATES SHALL NOT BE LIABLE FOR DAMAGES OF ANY TYPE, WHETHER DIRECT OR INDIRECT, ARISING OUT OF OR IN ANY WAY RELATED TO YOUR USE OR INABILITY TO USE THE SERVICES, INCLUDING BUT NOT LIMITED TO DAMAGES ALLEGEDLY ARISING FROM THE COMPROMISE OR LOSS OF YOUR LOGIN CREDENTIALS OR FUNDS, OR LOSS OF OR INABILITY TO RESTORE ACCESS TO YOUR ACCOUNT OR WALLET, OR FOR MISTAKES, OMISSIONS, INTERRUPTIONS, DELAYS, DEFECTS AND/OR ERRORS IN THE TRANSMISSION OF TRANSACTIONS, THE TRANSMISSION OF A VIRUS ONTO YOUR COMPUTER, UNAUTHORIZED ACCESS (I.E., AS A RESULT OF HACKING OR PIRACY ACTIVITIES) OR ANY OTHER FAILURE OR INADEQUACY ON THE PART OF THE TELECOMMUNICATION OR NETWORK SERVICE PROVIDER, delays or failures in network connectivity, system outages, interruptions, suspensions, technical malfunctions, strikes, labor disputes, acts of terrorism, decisions or actions taken by third-party venues, or obstacles arising from legal provisions or orders issued by authorities, OR FOR DIMINUTION OF VALUE OF BITCOIN.

THE Client IS AWARE THAT RELAI IS NOT MANAGING NOR RESPONSIBLE FOR THE BITCOIN ASSOCIATED BLOCKCHAIN. RELAI SHALL NOT BE LIABLE UNDER ANY CIRCUMSTANCES FOR ANY LOST PROFITS OR ANY SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, OR CONSEQUENTIAL DAMAGES, WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, ARISING OUT OF OR IN CONNECTION WITH AUTHORIZED OR UNAUTHORIZED USE OF THE SERVICES, EVEN IF AN AUTHORIZED REPRESENTATIVE OF RELAI HAS BEEN ADVISED OF OR KNEW OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES.

RELAI MAKES NO WARRANTIES OR REPRESENTATIONS, EXPRESS OR IMPLIED, ABOUT LINKED THIRD PARTY SERVICES, THE THIRD PARTIES THEY ARE OWNED AND OPERATED BY, THE INFORMATION CONTAINED ON THEM, ASSETS AVAILABLE THROUGH THEM, OR THE SUITABILITY, PRIVACY, OR SECURITY OF THEIR PRODUCTS OR SERVICES. YOU ACKNOWLEDGE SOLE RESPONSIBILITY FOR AND ASSUME ALL RISK ARISING FROM YOUR USE OF THIRD-PARTY SERVICES, THIRD-PARTY WEBSITES, APPLICATIONS, OR RESOURCES, INCLUDING RISK OF LOSS FOR ASSETS TRADED THROUGH SUCH THIRD-PARTY SERVICES. RELAI SHALL NOT BE LIABLE UNDER ANY CIRCUMSTANCES FOR DAMAGES ARISING OUT OF OR IN ANY WAY RELATED TO SOFTWARE, PRODUCTS, SERVICES, AND/OR INFORMATION OFFERED OR PROVIDED BY THIRD-PARTIES AND ACCESSED THROUGH THE APP, SITE OR SERVICES.

Some jurisdictions do not allow the limitation of liability for personal injury, or of incidental or consequential damages, so this limitation may not apply to you. In no event shall Relai total liability to you for all damages (other than as may be required by Applicable Law in cases involving personal injury) exceeding the amount of one hundred Euro (CHF/EUR 100.00) or its equivalent in the local currency of the applicable jurisdiction.

15. Compliance with Legal Reporting Obligation

Except in cases of willful misconduct or gross negligence, the Client releases Relai from any liability related to the reporting of information to tax authorities in compliance with the requirements under Legislative Decree No. 100 of July 30, 2020, implementing Directive 2011/16/EU (commonly known as “DAC 6“). This reporting may include details about transactions potentially linked to mechanisms of so-called “aggressive tax planning,” as defined by the applicable regulations, including identifying the relevant taxpayer, providing a detailed description of the cross-border mechanism, and its associated value. The Client further agrees to indemnify Relai from any claims or adverse consequences resulting from the fulfillment of these legal reporting obligations.

16. Force Majeure

We shall not be liable for delays, failure in performance or interruption of service which result directly or indirectly from any cause or condition of Force Majeure beyond our reasonable control. For the purposes of these Terms, ‘Force Majeure’ refers to any event beyond the reasonable control of the parties, which prevents one or both parties from fulfilling their contractual obligations. Such events include, but are not limited to, significant market volatility, act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, pandemic, as well as severe and unforeseeable disruptions to information technology infrastructures caused by external attacks such as Distributed Denial of Service (DDoS) attacks.

17. Data Protection and Security

To provide Services under this Agreement, we are required to collect personal data about you. Under data protection laws, we are considered the “data controller” for the personal data of the Client. For more information on how we use your personal data, please refer to our Privacy Policy available on the Site.

By accepting these Terms, the Client authorizes us to collect, process, and store their personal data for the purpose of delivering Services. This does not affect the rights and obligations of the Client or Relai under applicable data protection laws.

The Client may withdraw their consent by closing their Client Account, which will terminate the agreement between the Client and Relai. If the Client takes this step, we will cease using the Client’s personal data for the purpose of providing Services. However, we may still need to retain certain data to comply with applicable legal or regulatory requirements.

In all cases, Relai will collect, process, and store personal data in compliance with the applicable data protection laws, including the General Data Protection Law (GDPR).

18. Complaints

For any disputes regarding the relationships with Relai, the Client may contact the Relai Support Team using the methods and addresses indicated in the Claim Form (please refer to our FAQ).

If the Client does not receive a response within two (2) months, 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 Swiss Financial Ombudsman in accordance with the Swiss Financial Services Act (“FinSA”). Information on contacting the ombudsman, including contact details, is provided in the Client Complaints Handling Policy, and Relai will cooperate fully with any further procedures as required.

You can download the Claim Form here: DOWNLOAD

19. Applicable Law and Jurisdiction

These Terms and the use of the Website and the App will be governed by, and construed and enforced in accordance with the laws of Switzerland without giving effect to any choice or conflict of law provision or rule. Any dispute arising between the Client and Relai in connection with this Agreement shall fall under the jurisdiction of either the court of the Relai’s registered office or, alternatively, the court of the Relai’s secondary office, where applicable, at the choice of the claimant, with the exclusion of any other jurisdiction. If there is no secondary office, the court of the Relai’s registered office shall have exclusive jurisdiction. If the Client qualifies as a Consumer, the competent court shall be the court of the Client’s place of residence or elected domicile.