Regulations for the defence of clients of BITCOINFORME S.L.

One of Bit2Me's main strategic objectives is to establish a lasting and mutually satisfactory relationship with its customers. The achievement of this objective requires, among other actions, reaching a high level of quality in the provision of services that meets the aspirations of the clientele.

The application of the customer defense regulation is a basic element to improve the quality of Bit2Me's products and services.

The Customer Service is an internal service that will have sufficient autonomy so that its decisions cannot be affected by conflicts of interest and will have the material and human resources that allow it to adopt an adequate and quick resolution.

This Regulation contains the following information:

• Information on the free-of-charge nature of filing complaints or claims by customers
• A description of how to file claims, including:
  • Information that claims can be filed using the form attached in Annex II.
  • The type of information that must be included by the Customer in the claim;
  • The channel and department to which the claims must be addressed;
  • The languages in which a claim can be filed.
• The conditions for admitting claims;
• The processes for managing a claim;
• The time limits for managing a claim.

Index:

• 1. GENERAL PROVISIONS
  • 1.1 Purpose
  • 1.2 Scope of application
  • 1.3 Definitions
  • 1.4 Approval and adherence to the Regulation.
  • 1.5 Dissemination
  • 2. CUSTOMER SERVICE
  • 2.1 Configuration
  • 2.2 Head of Customer Service
  • 2.3 Incompatibility and ineligibility
  • 2.4 Appointment and termination
  • 2.5 Conflicts of interest
  • 2.6 Obligations of the departments
• 3. PROCEDURE FOR THE PROCESSING OF CLAIMS
  • 3.1 Scope of the procedure
  • 3.2 Deadline for filing claims
  • 3.3. Filing of claims
  • 3.4 Form and content of claims
  • 3.5 Deadline for resolving the claim
  • 3.6 Correction of deficiencies
  • 3.7 Rejection of a claim
  • 3.8 Processing
  • 3.9 Acknowledgment and withdrawal
  • 3.10 Finalization and notification
  • 3.11. Effects of the resolution
  • 3.12. Custody of files
• 4. OTHER ASPECTS
  • 4.1 Annual report
  • 4.2 Relationship with the Supervisors' Complaints Services
• ANNEX I – Adhering entities
• ANNEX II – Form for filing claims with the CS

1. GENERAL PROVISIONS

1.1 Purpose

The purpose of this Regulation is to regulate the rules of internal regime and the operation of the Customer Service of BITCOINFORME, PSC, S.L., hereinafter Bit2Me, and of the entities of the Bit2Me Group that adhere to this Regulation, as well as the procedure for processing claims and complaints from customers that they may file, related to their legally recognized interests and rights.

This Regulation has been prepared in compliance with the provisions of the following applicable regulations:

• Regulation (EU) 2023/1114 of the European Parliament and of the Council of May 31, 2023, on crypto-asset markets ("MiCA") 
• Delegated Regulation (EU) 2025/294 of the Commission of October 1, 2024, supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the requirements, templates, and procedures for the handling of claims by crypto-asset service providers.
• Order EHA/2899/2011, of October 28, on transparency and customer protection of banking services.
• Law 7/2017, of November 2, which incorporates into the Spanish legal system Directive 2013/11/EU of the European Parliament and of the Council, of May 21, 2013, on alternative dispute resolution in consumer matters. 

1.2 Scope of application

The Customer Service is responsible, in accordance with the powers and procedure established in this Regulation, for handling and resolving complaints and claims from customers, both natural and legal persons, Spanish or foreign, provided that such complaints and claims refer to their legally recognized interests and rights, whether they arise from contracts, from the regulations on transparency and customer protection, or from good financial practices and, in the area of crypto-assets, in particular, from the principle of equity.

Complaints and claims that are not covered by the preceding paragraph are not within the competence of the Customer Service and, in particular, those arising from:

a) The relationships of the entities with their shareholders and their employees as such.

b) The relationships of the companies subject to this Regulation with their suppliers

on matters related to their commercial relationship.

c) The provision of services or products carried out by Group entities that are not adhering to the Regulation.

d) Complaints or claims made by those who are not considered customers or customer representatives.

e) Claims that refer only to products or services provided by third-party entities, in which the relationship of the Bit2Me customer is established directly with the third-party company through specific terms and conditions.

f) Complaints or claims whose knowledge falls within the competence of administrative, arbitration, or judicial bodies, or are pending resolution or litigation.

g) Those complaints or claims that raise disputes about facts whose proof can only be made in a judicial proceeding or whose resolution necessarily requires the valuation of experts with specialized knowledge in a technical matter unrelated to the regulations on transparency and customer protection or good practices and uses

financial.

h) Complaints or claims that refer to the discretionary commercial powers of the subject entities, such as the decision to enter into or not enter into operations, contracts, or services with a specific person, the content of their agreements and conditions.

1.3 Definitions

The following terms will have the meaning established below in this Regulation:

1. Customers or users: Natural or legal persons, Spanish or foreign, who meet the condition of being a user of any of the services provided by the entities of the Bit2Me Group adhering to this Regulation, provided that these services are considered financial or crypto-asset services.

2. Services: The services subject to this Regulation will be those provided by an entity of the Bit2Me Group that are of a financial or crypto-asset nature. 

3. Complaint: Any statement of dissatisfaction from customers presented to the Technical Support, Sales, or another internal department other than the Customer Service will be considered a complaint. All internal departments are responsible for working preventively and resolving customer dissatisfaction, so that the customer does not need to file a claim with the Customer Service.

4. Claim: Any statement of dissatisfaction from customers presented to the Customer Service regarding the provision of one or more regulated services.

5. Bit2Me Group: BITCOINFORME, PSC, S.L. and the entities integrated into its Group that adhere to this Regulation.

6. Technical support: Service responsible for receiving customer contacts and acting to resolve doubts, requests, incidents, and complaints, with the support of internal departments, so that the customer does not need to file a claim.

7. CS: The Customer Service. An independent department from the business and commercial areas, responsible for resolving claims and managing and promoting the continuous improvement of all complaints and claims.

8. Supervisors' Complaints Services: Refers to the complaints services attached to the National Securities Market Commission, which, in accordance with their scope of competence, handle complaints and claims filed by users of the Services.

Although sometimes the terms complaint and claim may be used interchangeably in general communication, for the purposes of this procedure they will be understood in accordance with the definitions established in the preceding sections

1.4 Approval and adherence to the Regulation.

This Regulation has been approved by a resolution of the Board of Directors of BITCOINFORME, PSC, S.L.

Entities of the Bit2Me Group belonging to one of the following categories may adhere to this Regulation:

a) Investment services firms; and b) any other entity that provides financial or other services to end customers, provided that a regulatory provision does not prevent their adherence.

Adherence must be made by a resolution of the Board of Directors of the respective entities. Said resolution must contain the express and specific acceptance of the head of the Customer Service designated by the Board of Directors of Bit2Me. 

Any variations of the heads of the Customer Service (terminations and new designations) will be approved by a resolution of the Board of Directors of Bit2Me, subject to the provisions of this Regulation, and will be assumed by the adhering entities. Said variations will be communicated to the Complaints Services of the supervisors, the CNMV, and the other supervisory authorities that correspond due to the activity carried out by Bit2Me and the adhering entities. Likewise, the Boards of Directors of the adhering entities will individually approve any variations of the heads of the Customer Service. 

Modifications to this Regulation will be approved by a resolution of the Board of Directors of Bit2Me and will be assumed by the adhering entities, which must approve them by council. Said modifications will be submitted for verification by the CNMV.

The failure to assume the agreements provided in the preceding sections will imply the unlinking of the affected entity from the regime established in this Regulation, being empowered to establish the Customer Service it considers in accordance with the regulations in force at any time.

An updated list of the adhering entities will be attached as an annex to this Regulation.

1.5 Dissemination

Bit2Me will make the following information available to customers and the general public on its websites and those of the adhering entities of the group:

1. The existence of a Customer Service with an indication of its electronic and postal address.

2. The obligation to handle and resolve claims filed by its Customers free of charge and within the deadlines described in this regulation.

3. The reference to the Complaints Service of the National Securities Market Commission, with an indication of its postal and electronic address for the event that Customers consider it necessary to resort to it, including an express mention of the need to exhaust the Customer Service channel in order to file complaints and claims with them.

4. The existence of this Regulation.

2. CUSTOMER SERVICE

2.1 Configuration

The Customer Service is an internal body and department of Bit2Me, separated from commercial and operational services, whose function is to resolve claims within its competence autonomously and avoiding any conflict of interest, in accordance with the provisions of this Regulation, as well as to promote continuous improvement with regard to complaints and claims.

Bit2Me will provide the Service with adequate human, material, technical, and organizational means for the fulfillment of its functions. In particular, it will adopt the necessary actions so that the personnel assigned to it have an adequate knowledge of the regulations on transparency and protection of the customer of financial services.

Bit2Me will adopt the appropriate measures to ensure that the procedures provided for the transmission of the information at all times required by the Customer Service to the rest of the organization's departments respond to the principles of speed, security, efficiency, and coordination.

2.2 Head of Customer Service

Bit2Me will appoint a head of Customer Service (hereinafter, the "Head of Customer Service" or the "Head") to ensure the correct management of complaints and claims in accordance with the provisions of the regulations to which this Regulation is subject. The entities adhering to this Regulation will designate the same Head through their Boards of Directors. 

The head of the Service must be a person with commercial and professional honorability, and with adequate knowledge and experience to perform their functions.

For these purposes, commercial and professional honorability is present in those who have observed a personal trajectory of respect for commercial laws or others that regulate economic activity and business life, as well as good commercial, financial, or crypto-asset practices.

Those persons who have a criminal record, are being prosecuted, or have had an order for the opening of an oral trial issued for any crime cannot be elected to the position of Head of Customer Service.

The head of the Customer Service will participate in the processes of approval, monitoring, and control of new products, within the framework of the Group's product governance policy, providing their experience on claims and their knowledge of the supervisors' criteria.

The resolutions of the Customer Service will be binding for Bit2Me, but not for the claimant.

2.3 Incompatibility and ineligibility

The following may not be heads of the Service:

• Those who have failed and are not rehabilitated from bankruptcy proceedings.
• Those who are disqualified or suspended, criminally or administratively, from holding public office or from managing or directing entities.
• Those who have a criminal record for crimes against property, money laundering, against the socioeconomic order, against the Public Treasury, or Social Security.
• Those who have been sanctioned for committing administrative infractions derived from the regulations applicable to the exercise of the activity of credit institutions, insurance activity, the regulations applicable to the securities market, crypto-assets, the prevention of money laundering, the financing of terrorism, and consumer protection, as well as for any other type of serious or very serious administrative infraction.
• Those who perform functions directly related to Bit2Me's commercial or operational services.
• Those who hold political positions or carry out any other activities that could have public relevance or that could in any way affect the public image of the Customer Service.

2.4 Appointment and termination

The Head will be appointed by resolution of the Board of Directors of each entity of the Bit2Me Group for an indefinite period and may be dismissed by a motivated resolution of the same body, based on the following reasons:

• Loss of the requirements established for their eligibility.
• Suspension or termination of the employment relationship with Bit2Me.
• Being investigated in the criminal field for any fact related to infractions or crimes against property, money laundering, against the socioeconomic order, against the Public Treasury, or Social Security;
• Notoriously negligent performance of their function or any other serious cause.
• Due to death or subsequent incapacity.
• By express resignation.
• At any time, by a motivated decision of the Board of Directors of Bit2Me, provided that this is issued exclusively due to the concurrence of serious and justified causes.
• For incurring in any of the causes of ineligibility or incompatibility provided for in this Regulation.

The appointment and termination of the Head will be communicated by Bit2Me to the Complaints Services of the supervisors and to the National Securities Market Commission.

In the event that the position becomes vacant for any reason, the person who replaces them will be appointed in accordance with the legal and/or statutory regulations in force.

The termination and subsequent appointment of a new Head of Customer Service will not suspend the deadline for resolving a complaint or claim.

The termination and subsequent appointment of a new Head of Customer Service will not suspend the deadline for resolving a complaint or claim.

2.5 Conflicts of interest

In those claims or complaints in which the Head has a personal interest that produces or could produce a conflict of interest, the Head will refrain from participating in the processing and resolution of the complaint or claim, and their instruction and resolution will correspond to the person who holds the position of greatest relevance in the Customer Service after the Head.

Likewise, when any of the members of the Customer Service has a personal interest that produces or could produce a conflict of interest, they will refrain from participating in the processing and proposed resolution.

2.6 Obligations of the departments

Although the Customer Service, like its head, will be separate from the other commercial or operational services of its organization, all departments of Bit2Me and entities adhering to this Regulation must collaborate with the Customer Service, whenever requested, in everything that favors the best exercise of its functions and, especially, provide it with all the information requested by it on matters within its competence and in relation to the issues submitted for its consideration.

3. PROCEDURE FOR THE PROCESSING OF CLAIMS

3.1 Scope of the procedure

The operational, sales, and technical support departments are responsible for resolving the doubts, incidents, and complaints submitted by customers so that they do not become a claim to the Customer Service.

The procedure provided for in this chapter will be applicable to the processing of claims whose knowledge is attributed to the Customer Service.

3.2 Deadline for filing claims

Customers may file claims at any time from the time they become aware of the reason for the claim until a maximum period of 1 year has passed from the date of the facts causing it.

3.3. Filing of claims

In the event that a complaint or incident is not resolved by the responsible department or when the customer is not satisfied with the resolution, they may open a claim file with the Customer Service immediately.

All Customers will have the right to file claims with the Customer Service free of charge, regarding the products and services offered by the entity.

The claim files may be opened in the languages used by the crypto-asset service provider to market its services or communicate with customers and the official languages of the member state of origin and of the host member states that are also official languages of the Union.

Claims may be filed by the customer or by representation, by electronic means or by mail, as informed on the company's website. 

In any case, a written acknowledgment of receipt must be issued, stating the following for the purpose of calculating said period: 

• the department responsible for its management, contact email to which customers can address any query related to their claim;
• the date of receipt of the claim and a reference to the resolution timeline;
• a copy of the claim filed by the customer, when they use electronic means for its submission.

The claim will be filed only once by the interested party, without the need for it to be repeated before different bodies of the entity.

Once the claim is received by the Customer Service, the file will be opened.

3.4 Form and content of claims

The procedure will be initiated by submitting a written document that must contain:

• Name, surnames, and address of the interested party and, where applicable, duly accredited; identity document or passport number for natural persons and data referring to a public register for legal entities. In the event that it is done through a representative, the representation must be proven by any means permitted by law.
• Reason for the claim, with clear specification of the issues on which a decision is requested and, where applicable, the amount claimed. 
• Product or service where the incidents that are the subject of the complaint or claim occurred. 
• That the claimant is not aware that the matter of the claim is being processed through an administrative, arbitration, or judicial procedure.
• Place, date, and acceptance of the processing of their data in the legal terms of data protection.
• The documentary evidence in their possession that supports their claim.

The claim may be filed using the form attached in Annex II. 

3.5 Deadline for resolving the claim

• The Customer Service must issue a decision within a maximum period of 2 months. Exceptionally, this period may be extended when, for reasons beyond the Service's control, it is impossible to provide a response within the established period, provided that the Service communicates the reasons for the delay to the customer and specifies the period in which the customer will receive a definitive response.

• The deadlines for the management of claims will begin to run from the date of filing the claim with the CS in the case of the electronic channel and from the date of delivery of the letter in the case of the postal route and will not include the period used by the customer to provide missing information for the admission of the claim.

3.6 Correction of deficiencies

If the identity of the claimant is not sufficiently accredited, or if the facts of the claim cannot be clearly established, the signatory will be required to complete the submitted documentation within a period of fourteen (14) calendar days, with the warning that if they do not do so, the claim will be filed without further processing. However, the failure to correct the errors within the established period can never be interpreted as a waiver by the claimant of their right to re-file the claim.

The period used by the claimant to correct the errors referred to in the previous paragraph will not be included in the calculation of the deadline for resolving the claim.

3.7 Rejection of a claim

The admission of claims may only be rejected in the following cases:

• When essential data for processing that cannot be corrected are omitted, including cases where the reason for the claim is not specified.
• When it is intended to process as a claim, appeals, or different actions whose knowledge is the competence of administrative, arbitration, or judicial bodies, or the same is pending resolution or litigation, or the matter has already been resolved in those instances.
• When the facts, reasons, and request in which the issues of the claim are specified do not refer to specific operations or do not conform to the scope of application of this Regulation.
• When the claims are intentionally and manifestly aimed at preventing, hindering, or delaying the exercise of any right of Bit2Me against the customer.
• When claims are filed that reiterate previous claims already resolved, presented by the same customer in relation to the same facts.
• When the deadline for filing claims established in this Regulation has expired.
• If the content of the claim is insulting.
• When simultaneous processing of a claim and an administrative, arbitration, or judicial procedure on the same matter is known, the first one must be refrained from being processed. 

When the claim is deemed inadmissible for processing, it will be made known to the interested party by a reasoned decision, giving them a period of ten (10) calendar days to present their allegations. When the interested party has responded and the causes for rejection are maintained, the final decision adopted will be communicated to them.

3.8 Processing

The Customer Service may gather during the processing of the files, both from the claimant and from the different departments and services of the affected entity, any data, clarifications, reports, or elements of proof that they consider relevant to adopt their decision. All of this must be carried out diligently by the departments in order to allow a decision to be reached within the established deadlines.

Bit2Me will adopt the appropriate measures to ensure that the procedures provided for the transmission of the information at all times required by the Customer Service to the rest of the departments of Bit2Me or adhering entities, respond to the principles of speed, security, efficiency, and coordination. The departments and services will respond to the requests within the non-extendable period of five (5) days.

3.9 Acknowledgment and withdrawal

Prior to the resolution, the Customer Service may do everything necessary to try to reach an amicable agreement between the parties which, if reached, will be binding for both parties.

If, in light of the claim, Bit2Me or the adhering entities rectify their situation with the claimant to their satisfaction, it must be justified with documentation and the claim may be filed without further processing.  

Interested parties may withdraw their claims at any time. The withdrawal will lead to the immediate finalization of the procedure with regard to the relationship with the interested party.

3.10 Finalization and notification

The file must be finalized by a resolution issued within the corresponding period from the date of filing the claim with the Customer Service, in the specific channel enabled for this purpose.

The resolution will always be motivated and will contain clear conclusions about the request made in each claim, based on the contractual clauses, the applicable regulations on transparency and customer protection, as well as good financial practices and uses.

In the event that the resolution deviates from the criteria expressed in similar previous files, the reasons that justify it must be provided.

The resolution will be notified to the interested parties within a period of ten (10) calendar days from its date of issue, by email or by regular mail if the claimant so designates.

The resolution must expressly mention the right of the claimant to resort to the Supervisors' Complaints Service that corresponds in case of disagreement with the result of the decision. 

The resolution will be made in the language in which the claimant has filed their claim, provided that it is a language referred to in paragraph 3.3, third paragraph.

The customer may resort to the CNMV's Complaints Service, provided that any of the following situations occur:

• for having elapsed 2 months without the Customer Service having resolved their complaint or claim, or
• for not being in agreement with the resolution issued by the Customer Service.

The customer will have a maximum of one (1) year from the date on which the entity's Customer Service Department issued its resolution or, in the absence thereof, from the date on which it should have been resolved, to resort to the CNMV's Complaints Service, which will resolve in the manner and within the period that it has established at any time.

3.11. Effects of the resolution

• For the customer: The claimant will not be obliged to accept the resolution issued by the Customer Service, being able to initiate administrative actions or exercise the judicial actions they deem appropriate.
• For Bit2Me: The resolution issued by the Customer Service, favorable to the claimant, will be binding on Bit2Me.

Once the resolution is accepted, Bit2Me will execute it within the period defined in the response to the customer. This period may change depending on the object of the claim and the means to correct it. The deadline for execution will be counted from the day that Bit2Me is notified of the claimant's acceptance.

3.12. Custody of files

Claimants will have the right to be informed about the status of the files in which they are a party, to the return of the original documents they have provided, and to obtain a copy or duplicate of these and of the communications sent to them by the Customer Service.

The information related to the files and their content will not be disclosed or provided to third parties without the consent of the interested parties, except by a request from a judicial or administrative authority, and without prejudice to the fact that statistical data and the criteria contained in the decisions may be made public, maintaining the appropriate confidentiality with regard to the intervening parties.

4. OTHER ASPECTS

4.1 Annual report

Within the first quarter of each year, the Customer Service will present to the Board of Directors of BITCOINFORME, PSC, S.L. and of the entities adhering to this Regulation an explanatory report on the development of its function during the preceding year, which must have the following minimum content:

• Statistical summary of the claims handled, with information on their number, admission for processing and reasons for rejection, motives, and issues raised in the claims, and amounts and affected amounts.
• Summary of the decisions issued, indicating whether they are favorable or unfavorable to the claimant.
• General criteria contained in the decisions.
• Recommendations or suggestions derived from its experience, with a view to a better achievement of the purposes that inform its actions.

At least a summary of the report will be included in the annual report of Bit2Me and of each of the entities adhering to this Regulation.

4.2 Relationship with the Supervisors' Complaints Services

The requirements that the Supervisors' Complaints Services may make in the exercise of their functions to any of the entities subject to this Regulation will be handled by the Customer Service or by the person designated by its head, within the deadlines that they determine, in accordance with the provisions of their regulations.

ANNEX I – Adhering entities

In accordance with the provisions of article 3, the following entities of the Bit2Me Group have adhered to this Regulation:

• BITCOINFORME, PSC, S.L

ANNEX II – Form for filing claims with the CS

1.a. Information regarding the claimant

1.b. Contact information (if different from that provided in point a))

2.a Information about the legal representative (if applicable) (a power of attorney or other official document as proof of the representative's appointment, which must be provided in an annex to this form)

2.b. Contact information (if different from that provided in point 2.a):

3. Information regarding the claim

3.a. Provide a complete reference to the product, service, or agreement to which the claim relates, including the operations carried out, the type of currency, quote, reference number, etc. 

3.a Description of the reason for the claim. Include documents that support the facts mentioned)

3.c Date(s) of the events that motivated the claim

3.d Description of the damages, losses, or harms caused (if applicable)

3.e Other comments or relevant information (if applicable)

I declare that I am not aware that this matter is being processed through an administrative or judicial procedure (mandatory)

In (place) on (date)

Signature

CLAIMANT / LEGAL REPRESENTATIVE OF THE CLAIMANT

Documentation provided (check the corresponding box)