Terms of Service

Version 1.0 - Effective June 20, 2025

I. INTRODUCTION

These Terms of Service ("Terms") govern your access to and use of the On-Ramp, Off-Ramp, and Non-Custodial Platform services ("Services") provided by Compose Finance Sp. z o.o. ("Compose Poland") and Compose Finance Ltd ("Compose UK") (collectively, "Compose," "we," "our," or "us"). By using our Services, you agree to be legally bound by these Terms. If you do not agree, do not use the Services.

II. DEFINITIONS

For the purposes of these Terms:

Affiliate: Any entity that has ownership, control, or common ownership with another party.
AML: Anti-Money Laundering laws, regulations, and procedures.
Blockchain: A distributed ledger where records of digital asset transactions are maintained.
Smart Contract: A self-executing program stored on a blockchain that automatically carries out the actions encoded in it once predetermined conditions are met; transactions resulting from a Smart Contract are trackable and irreversible.
DeFi: Short for decentralized finance — an umbrella term for peer-to-peer financial services that run on public blockchains by means of smart contracts, allowing users to lend, borrow, trade, or earn yield without traditional intermediaries.
Protocol: A set of rules and Smart Contract code that governs how participants in a blockchain network interact; in the DeFi context, Protocols enable permissionless financial functions such as lending, trading, or liquidity provision.
Digital Asset: A digital representation of value, such as cryptocurrency, that uses encryption techniques for generation and transfer.
Fiat: Official government-issued currency (e.g., EUR).
KYC: Know Your Customer procedures for verifying the identity of clients and assessing risks.
Non-Custodial Platform: A platform that enables users to interact directly with DeFi protocols from their own wallets, without Compose holding or managing digital assets.

III. ABOUT COMPOSE FINANCE

Who we are:

Compose Finance Sp. z o.o. is a company incorporated in Poland (Company No. 5214081197), with its registered office at 22B Bartycka lok. 21A, 00-716 Warszawa, Poland. Compose Finance Ltd (UK) develops and manages the Compose.finance non-custodial platform.

Regulatory status:

Compose Finance Sp. z o.o. is registered in the Polish Register on Virtual Currencies Business Activity (Cryptocurrencies Register) under number RDWW – 1471.

IV. SERVICES PROVIDED

Compose offers the following Services:

On-Ramp: Purchase Digital Assets using Fiat currency (provided by Compose Poland).

Off-Ramp: Sell Digital Assets for Fiat currency (provided by Compose Poland).

Non-Custodial DeFi Platform: Access DeFi protocols directly from your self-custodied wallet (developed and managed by Compose UK).

V. ELIGIBILITY

You may use our Services if you:

Are at least 18 years old;
Satisfy all due diligence, KYC, and AML requirements;
Are not legally prohibited from using the Services in your jurisdiction;
Are neither a resident nor a citizen of any jurisdiction subject to US, UK, or EU sanctions, nor are you personally sanctioned by these entities (including but not limited to Iran, North Korea, Sudan, Syria, Cuba, Russia).

VI. COMPLIANCE AND VERIFICATION

To comply with applicable AML and KYC regulations, Compose must collect and retain specific information about you, which may include government-issued identification and supporting documents. We may use third-party providers for verification and may be required to report suspicious activity to authorities. You must provide accurate and up-to-date information and promptly notify us of any changes.

VII. HOW OUR SERVICES WORK

1. On-Ramp (Buying Digital Assets)

Select the type and quantity of Digital Assets to purchase.
Review the purchase price in Fiat, the conversion rate, and any associated fees before proceeding.
Provide your wallet address.
Complete payment using your chosen Fiat payment method.
Upon payment confirmation, Digital Assets are sent to your designated wallet address.

2. Off-Ramp (Selling Digital Assets)

Select the quantity of Digital Assets to sell and specify the Fiat currency to receive.
Review the conversion rate and any applicable fees before proceeding.
Provide your bank account information.
Send the specified Digital Assets to the wallet address provided by Compose.
Upon confirmation of receipt, Fiat is transferred to your nominated bank account.

3. Non-Custodial DeFi Platform

Access supported DeFi protocols directly from your self-cusodied wallet within the Compose platform.
Compose does not hold, manage, or take custody of your Digital Assets at any time.

VIII. IMPORTANT INFORMATION REGARDING DIGITAL ASSETS

The value of Digital Assets is highly volatile and subject to market risks. You should carefully consider whether buying, selling, or using Digital Assets is suitable for you. Transactions on the Blockchain are irreversible, and you are solely responsible for safeguarding your private keys and wallet credentials.

IX. USER RESPONSIBILITIES

You are responsible for:

Ensuring the accuracy of payment amounts, Digital Asset quantities, wallet addresses, and bank details;
Verifying all transaction information before submission, as Blockchain transactions are irreversible;
Safeguarding your private keys and credentials;
Complying with all applicable laws and regulations.

Compose is not liable for losses resulting from incorrect information, irreversible transactions, or third-party service failures.

X. ACCEPTABLE-USE & PROHIBITED ACTIVITIES

You agree not to:

Use the Services for any unlawful purpose, including money-laundering, sanctions evasion, market manipulation, or terrorist financing.
Upload or transmit malware, conduct denial-of-service attacks, or scrape our platform with robots or spiders.
Violate intellectual-property rights, privacy rights, or publicity rights of others.
Attempt to gain unauthorised access to our systems or other users' wallets.
Use the Services in a way that could damage, disable, or overburden our infrastructure.

We may suspend or terminate your access immediately if we reasonably believe you are engaged in any prohibited activity.

XI. DEFI & SMART-CONTRACT RISK DISCLOSURE

Third-Party Protocols & Oracles: When you interact with DeFi protocols through our interface, transactions execute on blockchains and smart contracts we do not control. We are not responsible for the security, accuracy, or availability of those protocols or any oracle price feeds.
Code Exploits & Upgrades: Smart contracts may contain bugs, be upgraded without notice, or be shut down. Exploits can lead to partial or total loss of Digital Assets.
Network Fees & Slippage: You may be required to pay all on-chain network fees. Transactions may fail or execute at different prices due to slippage, MEV, or network congestion.
Forks & Airdrops: We may choose not to support assets created by chain splits, token migrations, or airdrops.

XII. YIELD / STAKING DISCLAIMER & NO-ADVICE NOTICE

Yield rates displayed in the interface are variable, may change rapidly, and are not guaranteed. All information we provide is for general reference only and does not constitute investment or financial advice. You should consult a qualified adviser before making any investment decision.

XIII. DATA PROTECTION, PRIVACY & COOKIES

We process personal data in accordance with our Privacy Policy (see link in footer). Our website uses authentication cookies hardened with HTTPONLY and secure attributes. By continuing to use the Services you consent to this processing.

XIV. INTELLECTUAL PROPERTY

All platform content is owned by Compose or its licensors.

User Licence to Compose – By submitting feedback or materials to us, you grant Compose a worldwide, royalty-free, perpetual licence to use, modify, and sub-license that content for any purpose.

XV. FEES AND TAXES

All applicable fees are disclosed before you confirm any transaction. You are solely responsible for any taxes arising from your use of our Services. Compose is not responsible for determining or reporting your tax obligations.

XVI. MODIFICATION OR TERMINATION OF DEFI ACCESS

We may disable, restrict, or remove access to any specific DeFi protocol or asset without closing your entire account (e.g., after a hack, exploit, or regulatory notice). We will endeavour to give reasonable notice unless immediate action is required to protect users or comply with law.

XVII. ELECTRONIC COMMUNICATIONS CONSENT

You consent to receive contracts, notices, statements, and other communications from us electronically (email, in-app display, or website posting) and agree electronic signatures have the same legal effect as wet signatures.

XVIII. SECURITY & VULNERABILITY DISCLOSURE

We operate an open vulnerability-disclosure programme. Please report suspected security issues to [email protected]; good-faith researchers will not be pursued under computer-misuse laws if they adhere to our coordinated-disclosure rules.

XIX. COMPLAINT HANDLING & DISPUTE RESOLUTION

Internal Process: Submit complaints to [email protected]. We acknowledge receipt within 5 business days and aim to issue a final response within 60 days.
Escalation: If you are unsatisfied, you may escalate to the competent Polish court or, by mutual agreement, to WIPO mediation followed by expedited arbitration as per the model clause in Section 10 of the WIPO FinTech guidelines.
Governing Law: Polish law governs these Terms.

XX. TERMINATION OF SERVICES

These Terms remain in effect until terminated by either you or us. We may suspend or terminate your access to the Services at any time for reasons including breach of these Terms, legal requirements, or at our discretion. If your account is terminated, we will return any remaining assets or funds unless prohibited by law. Certain provisions, including those regarding liability and intellectual property, will survive termination.

XXI. LIABILITY AND INDEMNIFICATION

Compose is not liable for:

Losses that are not reasonably foreseeable, including indirect or consequential losses;
Loss of data, funds, Digital Assets, or losses due to price fluctuations, inaccuracies in price information, or the unavailability of Digital Assets;
Force Majeure events or losses resulting from circumstances outside of our reasonable control, including actions or omissions of third parties such as exchanges, token issuers, or wallet providers.

Our liability cannot be excluded for fraud, death, or personal injury caused by negligence, or anything that cannot be excluded by law. Our liability for any claim under these Terms is limited to the fees paid by you in the 12 months preceding the claim.

You agree to indemnify and hold Compose and its Affiliates, as well as their employees, managers, officers, directors, partners, and shareholders, harmless from any losses, damages, suits, expenses, or other liabilities of any kind, including legal fees, incurred in connection with your use of the Services, your breach of these Terms, violation of any law or regulation, or any act or omission by you or anyone acting on your behalf while using the Services.

XXII. WARRANTY DISCLAIMER

Compose Services are provided "as is" and "as available" without any warranty. To the extent allowed by applicable law, all express or implied conditions, representations, and warranties, including but not limited to those of merchantability, fitness for a particular purpose, satisfactory quality, and non-infringement, are disclaimed.

XXIII. CHANGES TO THESE TERMS & NOTICE MECHANISM

We may amend these Terms to reflect service or legal changes. Material amendments will be communicated by email and/or prominent in-app notice at least 14 days before they take effect, unless earlier implementation is required by law. Continued use of the Services after the effective date constitutes acceptance.

XXIV. OTHER PROVISIONS

These Terms constitute the entire agreement between you and Compose regarding the use of our Services.
No third party has rights under these Terms.
If any provision is found to be unenforceable, the remainder remains in effect.
Our failure to enforce any provision does not waive our right to do so later.
These Terms are governed by the laws of the Republic of Poland.

XXV. CONTACT INFORMATION

If you have any questions or concerns regarding these Terms, please contact us at:

Email: [email protected]