Document Requiring User Agreement (Written
Explanation of Crypto Asset Trading)August 28, 2024

bitFlyer, Inc.

1

This English translation is provided for convenience purposes only. The Japanese version of thisdocument shall be regarded as the official version. In the event of a dispute, the Japanese
language version shall prevail.
This written explanation is a document requiring user agreement in accordance with Articles 21
and 22 of the Cabinet Office Ordinance on Crypto Asset Exchange Services as well as selfimposed regulations from the Japan Crypto Asset Trading Association.
The crypto assets handled by bitFlyer, Inc. (hereafter “the Company”) are different from the fiat
currencies of Japan and other countries. The value of crypto assets is not guaranteed by anestablished party.

Company Profile
bitFlyer, Inc.
9-7-1 Akasaka, Minato-ku, Tokyo 107-6230
Registered Crypto Asset Exchange Operator (Registration No. 00003, issued by the Director of
the Kanto Local Finance Bureau)

Trading Activity
1. Buy/Sell:
These services are where customers buy or sell directly to and from the Company throughover-the-counter trading. The Company takes the following measures in order to ensurethat a fair and stable price for each crypto asset can be offered to customers.
1.1. For crypto assets handled on bitFlyer Lightning Spot: A unique price is derived from the
spot price on bitFlyer Lightning and prices transmitted by multiple crypto asset
exchanges.
1.2. For crypto assets not handled on bitFlyer Lightning Spot: A unique price is derived fromprices on other crypto asset exchanges.
2. Exchange, bitFlyer Lightning:
The Exchange and bitFlyer Lighting are provided by the Company mainly as a platform formatching sell orders and buy orders for crypto assets through competitive trading toconclude purchase and sales of crypto assets or the exchange of crypto assets for othercrypto assets. The parties placing these orders include not only customers, but also ourinternal proprietary trading department and our group companies (including our parent
company and companies that have the same parent company as our company). When anorder placed by a customer is matched with an order in the opposite direction placed by the
proprietary trading department of the Company, the Company acts as the counterparty to
the customer to conclude a purchase or sale of crypto assets or an exchange of crypto assets
for other crypto assets between the customer and the Company. If an order placed by acustomer is matched with an opposite order placed by another customer or the groupcompany, the company will act as an intermediary between the customer and the otherparty placing the order to conclude the purchase or sale of crypto assets or the exchange of
crypto assets for other crypto assets. The purpose of placing orders to buy, sell, or exchange
crypto assets held by the Company's group companies for investment purposes, to provide

2liquidity to the exchanges and bitFlyer Lightning's order book, and for arbitrage trading in
anticipation of a decrease in the gap between the trading price of bitFlyer Crypto CFD andthe trading price of bitFlyer Lightning, the reference price of bitFlyer Crypto CFD.
Arbitrage trading is one example. The purpose of the Company's proprietary trading
department and the Company's group companies placing orders on Exchange or bitFlyer
Lightning to buy, sell, or exchange crypto assets (including, but not limited to, the sale ofcrypto assets that the Company received as compensation from contract sales partners andtransferred to the group companies) for other crypto assets, are to adjust the amount ofcrypto assets held by the Company in its proprietary accounts, to provide liquidity to
Exchange and bitFlyer Lightning's order books, as well as arbitrage trading in the eventthat the trading price of bitFlyer Crypto CFD diverges from the trading price of bitFlyer
Lightning, which is the reference, with the expectation that the divergence will decrease.
The company’s proprietary trading department uses both algorithm-based automated orderplacement and trader-determined manual order placement. In both cases, the Company
shall not perform front-running*, use customers’ trading information, prioritize theprocessing of the Company’s orders, prioritize the Company’s orders in the event of any
system malfunction, or any other form of inappropriate trading.
*Front-running refers to the act of an operator using customers’ order information in orderto place an order before other customers’ orders are placed. The Company shall endeavor tominimize the number of crypto asset positions held and the length of time for crypto asset
positions held by the Company in order to prevent conflicts of interest with customers.
The prices of trades are determined by the principle auction trading. The principle ofauction trading is the principle of prioritizing price (buyers aim for the lowest price whilesellers aim for the highest price, limit orders have a designated price, market orders do nothave a designated price) and the principle of prioritizing time (orders that were placed firstare prioritized over other orders for the same price).

Policy for Receiving orders and Processing Executions
Currencies and Currency Pairs
Buy/SellCurrency

Unit

Bitcoin

BTC

Ether (Ethereum)

ETH

Ethereum Classic

ETC

Litecoin

LTC

Bitcoin Cash

BCH

3

Monacoin

MONA

Lisk

LSK

Ripple (XRP)

XRP

Basic Attention Token

BAT

Stellar Lumens

XLM

NEM

XEM

Tezos

XTZ

Polkadot

DOT

Chainlink

LINK

Symbol

XYM

Polygon

MATIC

Maker

MKR

Zipangcoin

ZPG

Flare

FLR

Shiba Inu

SHIB

Palette TokenPLTThe Sandbox

SAND

Decentraland

MANA

Axie Infinity

AXS

Immutable

IMX

ApeCoin

APE

Chiliz

CHZ

Dai

DAI

4

Render TokenRNDRThe Graph

GRT

Avalanche

AVAX

Dogecoin

DOGE

Zipangcoin Platinum

ZPGPT

Zipangcoin Silver

ZPGAG

Mask Network

MASK

Exchange
Currency Pair

Unit

BTC/JPYBTC

ELF/JPY

ELF

Lightning Spot
Currency Pair

Unit

BTC/JPY

BTC

ETH/BTC

ETH

BCH/BTC

BCH

ETH/JPYETH

XRP/JPYXRP

XLM/JPY

XLM

MONA/JPY

MONA

Order Size
The minimum and maximum order sizes are subject to change due to circumstances such as
fluctuations in market prices. The current information on order sizes can be found here
(https://bitflyer.com/en-jp/faq/4-27).
Measures to Prevent Sudden Fluctuations in Trade Prices5

In the event of sudden price changes or changes in the status of other crypto asset exchanges
that impacts the ability to receive valid and stable prices or if the prices transmitted from crypto
asset exchanges significantly diverge from the market, the Company may suspend pricetransmissions. After the price transmission has been suspended, once the Company has judgedthat it has become possible to continuously receive a stable price to display on the crypto asset
exchange which does not significantly diverge from the market price, price transmission shallresume. To prevent sudden price changes, bitFlyer Lightning and the Exchange have a circuit
breaker system. A circuit breaker temporarily suspends trading in order to prevent erroneousorder placement.
The circuit breaker system is summarized below.
Activation Conditions

The placement of an order which causes the market priceto fall outside of the price fluctuation threshold

Circuit Breaker Reference Price

The last traded price from 10 minutes priorPrice Fluctuation Threshold

20% above or below the circuit breaker reference priceSuspension Period

About 5 minutes

Resumption Procedure

Trading will resume by the Itayose method after thesuspension period has elapsed*When trading resumes, bitFlyer ’s proprietary trading
department may employ the Itayose method to holdpositions for the purpose of hedging price fluctuation risks
or for arbitrage trading. In such instances, the price andquantity desired by the proprietary trading department
will be reflected on the order book and displayed in thesame manner as orders from other customers.

*Orders may be placed and cancelled while trading is temporarily suspended.
*If there have been no trades for 10 minutes, the reference price remains at its most recent value.
*The single price determined by the Itayose method is taken as the circuit breaker reference
price for the duration of the 10 minute period following the resumption of trading.
*When trading is temporarily suspended due to circuit breaker activation and the single pricedetermined by the Itayose method falls outside of the price fluctuation threshold, another periodof suspension will immediately follow without resumption of trading. The reference price of thisnew period will be the price at which the price fluctuation threshold was exceeded.
*There may be situations where the Company does not apply the circuit breaker if the Company
determines that, in consideration of trading conditions, applying a temporary suspension to
trading is not appropriate.
*The Company will make a determination as to whether to temporarily suspend trading on eachoccasion that the circuit breaker activation conditions are met. There may be a time difference
between the satisfaction of those conditions and the commencement of a suspension.
*If the regularly scheduled maintenance time starts while the circuit breaker is activated, thecircuit breaker Itayose process will take priority over the maintenance period.
*The circuit breaker system is not guaranteed to activate for every order made in error. Pleaserefer to the outline above for the activation conditions.
*Any opportunity losses, including those due to the introduction of the circuit breaker system,
are under no circumstances the responsibility of the Company.
The Itayose method searches for a price by sequentially matching buy and sell orders using theprescribed priority while making quantitative matches, and then makes purchases and sales using asingle price. The order of priority is as follows.

6

Sell order
1: Market orders 2: lowest price limit order
Buy order
1: Market orders 2: highest price limit order
If there are multiple limit orders at the same price, the orders will be executed in the order they
were placed. All market orders placed before the single-price auction (Itayose method) is
determined (including orders placed prior to scheduled maintenance) will be considered to havebeen placed at the same time.
Trading Rules
Buy/Sell
Crypto assets can be bought and sold. To place an order, input the desired amount of crypto asset
to purchase or sell into the Company’s trading user interface. Crypto asset purchases and sales
have predetermined minimum and maximum order sizes. The units available for purchase andsale for each currency is as follows.
Bitcoin purchase and sale unit

0.00000001 BTC (= 1 Satoshi)

Altcoin purchase and sale units

Ethereum: 0.00000001 ETH
Ethereum Classic: 0.00000001 ETC
Litecoin: 0.00000001 LTC
Bitcoin Cash: 0.00000001 BCH
Monacoin: 0.00000001 MONA
Lisk: 0.00000001 LSK
Ripple (XRP): 0.000001 XRP
Basic Attention Token: 0.00000001 BAT
Stellar Lumens: 0.0000001 XLM
NEM: 0.000001 XEM
Tezos: 0.000001 XTZPolkadot: 0.00000001 DOT

7

Chainlink: 0.00000001 LINK
Symbol: 0.000001 XYMPolygon: 0.00000001 MATIC
Maker: 0.00000001 MKR
Zipangcoin: 0.0001 ZPG

Flare: 0.000001FLR
Shiba Inu: 0.00000001 SHIB
Palette Token: 0.00000001 PLT

The Sandbox: 0.00000001 SAND

Decentraland: 0.00000001 MANA

Axie Infinity: 0.00000001 AXS

Immutable: 0.00000001 IMX

ApeCoin: 0.00000001 APE

Chiliz: 0.00000001 CHZ

Dai: 0.00000001 DAI

Render Token: 0.00000001 RNDRThe Graph: 0.00000001 GRT

Avalanche: 0.00000001 AVAX

8

Dogecoin: 0.00000001 DOGE

Zipangcoin Platinum: 0.000001 ZPGPT

Zipangcoin Silver: 0.000001 ZPGAG

Mask Network: 0.00000001 MASK

Exchange and Lightning Spot
Exchange

Lightning Spot

Hours of operation

24 hours/day, 365 days/year*Excludes periodic and irregular maintenance periods. Moreinformation can be found here (https://bitflyer.com/en-jp/faq/9-25).
*Periodic maintenance is performed daily between 4:00 and 4:10
AM (JST). Maintenance times are subject to change.

Order designation

Please ensure that orders placed through either the Company’s
online trading interface or bitFlyer Lightning API are placed
during the hours of operation and meet all necessary
requirements to be placed.
* The time required for order instructions may differ between the
Company’s designated trading interface and bitFlyer LightningAPI.

New orders

Orders to buy or sell crypto assets or trade one crypto asset foranother crypto asset

Order types

IFD
OCO
IFDOCO
Please reference About
bitFlyer Lightning Special
Orders below for more
information

Execution parameters

Market order
Limit orderMarket order
Limit order
Stop order
Stop limit order
Please reference About bitFlyer
Lightning Special Orders
below for more information

9Period of validity forlimit orders

Orders are valid for 30 days. (This is not the case if you use
bitFlyer Lightning API and set an expiration date shorter than 30
days.)
Orders may be canceled due to service updates, etc.

Order cancellation

Limit orders can be cancelled until they are executed. Market
orders can not be cancelled.

Order revision

Orders can not be revised. Please cancel the order and then place a
new one.

* If there is a possibility that a Registered User's order may self-trade with another order of thesame user that has already been received by the Company (meaning a case where the conditions
match and execution may occur), the Registered User may not place such an order.

10

About bitFlyer Lightning Orders
Order types

IFD: An abbreviation of “IF Done”, If two orders are made at the same time
and the first one is filled, then the second order is automatically placed.
OCO: An abbreviation of “One-Cancels-the-Other”, when two orders are madeat the same time and one is completed, the other side is automaticallycancelled.
IFDOCO: A combination of IFD and OCO, After an IFD order is filled, theOCO order is automatically placed.

Execution
parameters

Market order: This is where an order is placed with no price specified,emphasizing the filling of the order above other parameters. A buy orderwithout limit will be filled with the lowest available offer at that time. A sellorder without limit will be filled with the highest available offer at that time.
Price limit order: A price limit order is an order placed to be filled at the pricespecified. With a buy order with price limit, the order will not be filled unlessa price below that specified is found. For a sell order with price limit, theorder will not be filled unless a price above that specified is found.
Stop order: A stop order is a market order without limit that incorporates thefollowing parameters: If the price reaches above the trigger price, buy; and if
the price drops below the trigger price, sell.
Stop limit order: If the price reaches above the trigger price, buy; and if theprice drops below the trigger price, sell.
Notes on the difference between stop orders and stop limit orders
The difference between the above two order types is that, for stop orders, once
the trigger price is reached, a market order without limit is placed. A stop
limit order, by contrast, is when a price limit order is placed once the trigger
price is reached. With a stop limit order, an order will never be filled at a
price more unfavorable than the one specified in the price limit. However, due
to price fluctuations, the order may not be filled.
Trailing stop order: A trailing stop order is where the trigger price for a stoporder is automatically calibrated based on price fluctuations.
*Please note that the IFD (the second order), stop orders, stop limit orders
and trailing stop orders will not be placed or executed in the case of a margin
shortage when actually trying to place an order. Please understand thatshould any special orders be triggered just before service is suspended(includes maintenance), there is the possibility that they will be executed
once the service resumes. If the service resumes under the Itayose method,the order will use the corresponding Itayose method.

Executionamountparameters

Good Til Canceled (GTC): A Good Til Canceled order is one where the orderremains in effect until it is either filled or cancelled.
Immediate or Cancel (IOC): With an Immediate or Cancel order, all or part ofthe order is immediately filled if a match is found for the price indicated or
better. Orders that fail to fill are canceled in their entirety.
Fill or Kill (FOK): This refers to when the order is cancelled if the volume is
not immediately executed (filled) in its entirety.

11*Please note that the same execution parameters will be applied to thesecond order when you place IFO or IFDOCO.

Response to Planned Hard Forks and New Crypto Assets That Originate in Hard
Forks
1. Method of reporting to users
In the event that a crypto asset handled by the Company is scheduled to undergo a largescale update where backward and forward compatibility will be lost (“hard fork”), theCompany shall report the Company’s response to the hard fork, including the beginningand end of temporary suspensions of services related to the corresponding crypto asset, tocustomers on the Company’s website, through email, and other communication channels
that the Company deems appropriate. Additionally, if the corresponding crypto asset isthe underlying asset in leverage trading or if the corresponding leverage trade is linked
to a crypto asset index, the communication channels above will be used.
2. Service suspension measures for when a hard fork occurs
In the event of a hard fork, the Company may suspend purchases, sales, deposits,
withdrawals, etc. for a period of time determined by the Company. The Company shallconsider when to make and lift a temporary suspension of services based on acomprehensive assessment of the risks of losing mutual compatibility, retroactive
invalidation of trades, large declines in price, etc. Additionally, withdrawals of fiat
currency and crypto assets will be unavailable during the suspension period andavailable once service resumes. In the event that any customers incur losses due to pricemovement, etc. during the suspension period, the Company shall bear no responsibility
for the corresponding losses incurred.
3. Granting a new crypto asset that originates in a hard fork to customers
The Company shall decide whether or not to handle any new crypto assets originating ina hard fork or the crypto asset that underwent the hard fork itself. As a result, theCompany may choose not to grant any new crypto assets, and the Company is not
responsible for any losses incurred by customers by not granting any new crypto assets.
4. Fees required for granting new crypto assets
In order to cover the costs incurred in building the necessary systems for operations,
measures for customer protection, etc. required for the new crypto asset the Company
may collect a fee from customers when granting a new crypto asset.
5. Response guidelines for planned hard forks and new crypto assets resulting from hardforks
The response guidelines for planned hard forks with a possibility for a blockchain

12

divergence, and new crypto assets resulting from a hard fork can be found here
(https://bitflyer.com/en-jp/guidelines-hard-forks).

Overview of Crypto Asset Handling
1. Crypto assets are not a legal tender.
2. Buying and selling crypto assets and exchanging them for other crypto assets can resultin losses due to fluctuations in the price of those crypto assets. It is possible that the priceof crypto assets falls due to changes in the balance of supply and demand, price trends,
trends in legal currency and other markets, changes in other factors related to the crypto
asset, etc.
3. Crypto assets can only be used to pay for goods or services with the consent of the person
receiving payment.
4. The crypto assets handled by the company are not guaranteed in value by any particularcountry or person.
The Company handles the following crypto assets.
●

Bitcoin
Bitcoin is a crypto asset. Bitcoin is not issued by a central bank or any specificorganization. Bitcoin has an upper limit to the amount that can be issued. The practicalvalue held by Bitcoin is derived from the trust placed in it by people. Blockchain
technology, a distributed ledger that uses encryption technology, is used to store andtransfer values.

●

Ethereum
Ethereum is the name of a platform. The unit of crypto asset used on the platform isETH. Ethereum adopts Proof of Stake (PoS), where the network administrators, calledvalidators, have mining rights based on the staked Ethereum they possess. Validators
return fees to users when they succeed in mining.

●

Ethereum Classic
Ethereum Classic is a blockchain divergence from Ethereum which serves as a platform
for building distributed applications (DApps) and smart contracts. Ethereum Classic
differs from Ethereum in that there is no upper limit for issuance, and Ethereum Classic
has a defined reduction period. The unit of crypto asset for Ethereum Classic is ETC.

●

Bitcoin Cash
Bitcoin Cash is a crypto asset that originated in a blockchain divergence (hard fork) from
Bitcoin. Bitcoin Cash was created to solve Bitcoin’s scalability problem by increasing thesize of blocks. Bitcoin Cash implemented a technology called 0 approval transactions
which can consider transactions approved even if no minors have done so.。

●MonacoinMonacoin is a crypto asset that originates in Japan. The Monacoin Project, whichdeveloped the Monacoin Program, is not involved in issuing or managing the coins. The
Monacoin network is developed and maintained by client programs.

●

Litecoin
Litecoin is a crypto asset. Litecoin was developed to deal with the issues of long approvaltimes and scalability faced by Bitcoin. The upper limit of Litecoin to be issued is 4 times
as much as Bitcoin.

●

Lisk

13

Lisk is a platform for building decentralized applications (DApps). In May 2024, Lisk
migrated from its own blockchain network to the Ethereum network. With this migration
Lisk was converted into an ERC-20 token, making it more compatible with the Ethereum
ecosystem and enabling low-cost, high-speed transaction processing. Lisk continuously
aims to provide a more efficient and secure DApp platform.
Notes on LSK transfers
This crypto asset uses the Ethereum network and Lisk's own layer 2 blockchain(Optimism Superchain).
We only accept the transfer of ERC-20 tokens on the Ethereum network for this crypto
asset, and do not accept any other networks.
When transferring the relevant crypto assets from our company to an external party orfrom an external party to our company, please select "ERC-20" for the destination wallet.
If you select any other network, the transfer may fail and your crypto assets may bepermanently lost, so please confirm that the wallet network is set as Ethereum network.
●

XRP
Ripple (XRP) is a crypto asset. The role of Ripple is to serve as a bridge for performing
transfers of fiat currency when making remittances between financial institutions. By
using Ripple (XRP) instead of a fiat currency, financial institutions can transfer money
quickly at a low cost.

●

Basic Attention Token（BAT）
Basic Attention Token is a new type of crypto asset that changes the relationship between
publishers, advertisers, and users. Basic Attention Token is realized as contracts on the
Ethereum blockchain, and was developed in tandem with the Brave web browser thatblocks unwanted ads and trackers.

●

Stellar Lumens（XLM）
Stellar Lumens is a crypto asset and distributed ledger developed by the Stellar
Development Foundation. The goal of Stellar Lumens is to make financial services
accessible to more people by creating a global payment system that is affordable and easy
to use.

●NEM（XEM）
NEM is a crypto asset developed for the New Economy Movement network. The goal of
NEM is to establish a new economic framework based on the principles ofdecentralization, economic freedom, and equality, rather than the existing frameworks
managed by countries and governments.

●

Tezos（XTZ）
Tezos is a blockchain platform that supports smart contracts and decentralized
applications. The goal is to use unique technology to create social, political, and economic
innovations on a global scale.

●

Polkadot（DOT）
Polkadot is a blockchain project that allows for the interconnection of multiple different
blockchains. It was founded by the Web3 Foundation, which aims to develop a
decentralized web.In addition to the central Relay Chain, Polkadot uses multiple parallel
blockchains, called parachains, to provide interoperability that allows for the exchange ofvarious types of data and value.

●

Chainlink（LINK）

14

Chainlink is a decentralized service that connects various data in the real world withsmart contracts on the Ethereum blockchain.Chainlink aims to create an environment
where all smart contracts can use the provided data secured. LINK is a token that is paid
as a reward to the node operators of the network that provides this decentralized service.
●

Symbol（XYM）
Symbol is an open source blockchain platform developed based on NEM. The native token
circulating on the Symbol network is XYM.As an enterprise blockchain designed
specifically for the use by corporations and government agencies, its features include
interoperability through linking with existing corporate systems and processes, as well as
many built-in functions.

●

Polygon（MATIC）
Polygon is a side chain created to supplement the Ethereum blockchain and solve
scalability problems including soaring fees and slow processing speeds.
The Polygon chain has a bridge function that allows the transfer of funds between otherblockchains like Ethereum, and money can be sent on a unique chain for a relatively low
fee.
Polygon can also be used as utility tokens in fields like blockchain games, NFTs, andDApps.

●

Maker（MKR）
Maker is the governance token managed by the MakerDAO project, which is responsiblefor issuing the cryptocurrency, DAI.
Users can issue DAI as collateral for a variety of Ethereum-based crypto assets, and there
are DApps that use DAI.
Maker holders are also able to vote for a variety of operational decisions.

●Zipangcoin（ZPG）
Zipangcoin is a crypto asset issued by Mitsui & Co. Digital Commodities, Ltd. 1 ZPG aims
to have a value equivalent to 1 gram of physical gold and generally track the price ofphysical gold.
Due to its mechanism for price formation and value preservation, this crypto asset holds
asset and investment traits similar to those of physical gold.
As a crypto asset, Zipangcoin enables small-scale transactions at a lower cost and serves
as a reliable, convenient asset management and inflation hedging asset.
Zipangcoin (ZPG) uses the proprietary private blockchain Miyabi developed by bitFlyer
Blockchain, Inc. as its underlying system.
bitFlyer Blockchain Inc. is the wholly owned subsidiary of bitFlyer Holdings, Inc., theparent company of bitFlyer Inc. Based on this reciprocal relationship, companies
belonging to the bitFlyer Group, including the crypto asset exchange operator bitFlyer
Inc. may continue to receive support from Mitsui & Co. Digital Commodities, Ltd. andDigital Asset Markets, Inc. with respect to Zipangcoin (ZPG).
Regarding Disclosure of the Actual Collateral Status of Zipangcoin
Information regarding the actual collateral status of Zipangcoin is regularly disclosed andpublished by the issuer. For more information, please refer to the issuer's website(https://www.mitsuidc.com/news).

●

Flare（FLR）
Flare is a crypto asset supported by Ripple and is designed to implement smart contracts
on XRP ledger. It is developed to interoperate with various blockchains under thephilosophy of "Connect Everything”. The function called State Connector enables the
secure acquisition of various blockchain states. FAssets provides a smart contract15

executable environment for those crypto assets without smart contracts. Also, Layer Cakecan be used to improve the security and speed of bridging between different blockchain
networks.
●

Shiba Inu（SHIB）
Shiba Inu (SHIB) is one of many meme coins derived from the famous joke coin
DogeCoin.
It is a token created from the idea of "What would happen if the operation of a crypto
asset project was 100% community-driven?".
Since its launch, the community has spearheaded NFT issuance, metaverse construction,
Layer 2 development, and various other projects.
It has a wide variety of use cases, not only as a remittance, but also gives users the rightto vote for the governance, and the payment method within Dapps.

●

Palette Token（PLT）
Palette Token (PLT) is a project whose purpose is to solve the problem of high fees on
public chains and copyright issues in handling NFT contents.
It was launched for use on the proprietary consortium platform called Palette Chain,
which is specialized in the entertainment sector such as GameFi and NFT. Furthermore,users can also earn rewards by staking their tokens on the palette chain.
HashPalette Inc., the issuer of the PLT, has announced its plan to conduct an IEO withus as consignment distributors. The bitFlyer Group companies, including bitFlyer Inc.,
the crypto asset exchange may receive support from HashPalette Inc. for promotional
campaign expenses related to the Palette Token.

●

The Sandbox（SAND）
The Sandbox is a metaverse platform utilizing blockchain technology. Users are free tocreate and own the content using the tools provided by the platform. The platform also
sells a virtual asset called LAND, and some of the companies that own LAND regularly
hold game events within their respective areas. The SAND, which refers to the crypto
asset used on the platform, is used for trading user-generated content and staking.
Moreover, it will be used as a governance token in the future.

●

Decentraland（MANA）
Decentraland is a decentralized platform within the virtual reality space (metaverse).
Users can use the crypto asset MANA to trade LAND, a virtual real estate andwearables, virtual clothing assets. Users are able to create content on their LAND and
can interact with other users.
Decentraland is operated by the community as a decentralized autonomous organization(DAO), allowing any user who owns assets like MANA or LAND to participate ingovernance voting concerning the DAO.

●

Axie Infinity（AXS）
Axie Infinity is a play-to-earn gaming project where players earn income by engaging inbattles and adventures using digital pets called Axies, which are NFT characters ownedby the players. Breeding Axies allows the creation of new characters with different
appearances and skills, enabling the production of powerful or cute Axies for trading in
the NFT marketplace. Holders of this crypto asset are eligible to participate in platformgovernance voting, receive rewards through staking, and engage in various use casessuch as participating in LAND sales.

16Notes on AXS Price Fluctuations
Unlike other crypto assets, Axie Infinity is only used within the Axie Infinity game, so its
price may fluctuate depending on the popularity of the game and other related factors.
Notes on the Protection of AXS User Assets
In the event that we deem it difficult to provide service for the crypto asset from theperspective of user asset protection due to changes in social conditions, usage conditions,or legal changes to "Play to Earn," we may consider and implement temporary suspension
or discontinuation of the service.
●

Immutable（IMX）
Immutable is a crypto asset primarily intended for use in fields such as gaming, art, andentertainment. It enables fast on-chain solutions through utilizing Ethereum Layer 2
platforms, e.g. facilitating large-scale issuance and trading of NFTs while eliminating
fees.
The platform represents one of Ethereum's solutions to the scalability problem,
leveraging zero-knowledge proof and using Layer 2 technology and has achieved cost
reduction, speed enhancement, and decreased energy consumption.

●

ELF Token（ELF）
ELF Token is a crypto asset used in THE LAND ELF Crossing (hereafter "THE LAND"),
an NFT farming game released by HashPalette Inc. and issued on the PaletteChain. ELF
Tokens can be earned by participating in tournaments and other events, or selling items
acquired in the game after converting them to NFTs.
With ELF Tokens, players can purchase land NFTs called LAND and item NFTs in thegame. Staking ELF Tokens (the act of depositing tokens for a certain period of time)within the service provided by HashPalette Inc. unlocks special features that allow
players to progress more comfortably through THE LAND.
Staking as a service is not provided by bitFlyer.
HashPalette Inc. will buy back ELF Tokens at irregular intervals, funded by proceedsfrom in-app purchases.
Notes on ELF Token Transfers
This crypto asset uses the Palette Chain and Ethereum networks.
We only accept the transfer on the Palette Chain for this crypto asset and do not accept
any other networks.
When transferring the relevant crypto assets from our company to an external party orfrom an external party to our company, please select "Palette Chain" for the destination
wallet. If you select any other network than Palette Chain, the transfer may fail and yourcrypto assets may be permanently lost, so please confirm that the wallet network is set as
Palette Chain.
Notes on ELF Token Price Fluctuations
Unlike other crypto assets, ELF Tokens are only used within THE LAND game, so its
price may fluctuate depending on the popularity of the game and other related factors.
Notes on the Protection of ELF Token User Assets
In the event that we deem it difficult to provide service for the crypto asset from theperspective of user asset protection due to changes in social conditions, usage conditions,or legal changes to "Play to Earn," we may consider and implement temporary suspension
or discontinuation of the service.

17

●

ApeCoin（APE）
ApeCoin is a project based on the "Bored Ape Yacht Club" NFTs copyrighted by Yuga
Labs aimed at supporting “the decentralized communities pivotal to web3”. The crypto
asset APE will be utilized for settlement within the ecosystem, games, events andcommercial transactions.
Moreover, ApeCoin is managed by a community named ApeCoin DAO, where the token
functions as a governance token to vote on the decision making.
Notes on the Yuga Labs Class Action Lawsuit
Yuga Labs is currently involved in a class action lawsuit over NFTs related to the Bored
Ape Yacht Club (BAYC). Please be aware of the potential impact of the ruling in thislawsuit on the ApeCoin project.
In the event that we deem it difficult to provide the service in terms of user asset
protection due to changes in social conditions and usage conditions, we may consider andimplement a temporary suspension or discontinuation of the service.
*August 21, 2024●

Chiliz（CHZ）
Chiliz is a project to issue official fan tokens in partnership with various sports clubs,
including F1 and eSports, as well as professional soccer clubs.
By purchasing fan tokens using the corresponding crypto asset CHZ, fans can participatein events organized by the sports club. Additionally, fans can get involved in the
management of the club by participating in governance voting.
Chiliz facilitates interaction between fans and clubs and aims to build new forms of
relationships based on trust.
Notes on CHZ price fluctuations
Some of the fan tokens that can be issued and acquired within Socios.com are currently
tradable on crypto exchanges outside of Socios.com, so it is possible that they may betreated as crypto assets rather than fan tokens in the future. If these fan tokens become
recognized as crypto assets, the change could affect the price of CHZ.

●

Dai（DAI）
Dai is a crypto asset operating on the Ethereum blockchain. It aims for a value of 1 DAI =1 USD, backed by various crypto assets including ETH. Issuance and price stabilizationof DAI is conducted through smart contracts developed and operated by MakerDAO, adecentralized autonomous organization.
This crypto asset serves a wide range of use cases in decentralized applications, enablingvalue storage, exchange, investment, borrowing and lending.

●Render Token（RNDR）
Render Token is a crypto asset used on the Render Network, a decentralized cloud
rendering service. The Render Network is a platform that allows users to monetize GPU
computing power that is necessary for graphic and video production by sharing excess
computing power among users.
RNDR can be used for payments within the platform's services and for governance voting
regarding project operation policies.
Regarding Render Token program node availability and how to provide rendering power
How to check node availability:

18

You can check the latest information about the operational status of the nodes runningon the Render Network and the rendering power provided by the nodes on the service
page when you actually use the service.
How to provide rendering power:
To contribute GPU computing power, you must join a specific group called a "Tier(https://know.rendernetwork.com/getting-started/how-to-get-started/select-rndr-tier)”. By
joining this group, GPU power providers can provide their GPU power and receive
RNDRs as a reward for their contribution to the Render Network ecosystem.
Notes on the Sending of Render Tokens (RNDR)
Please note that the referenced crypto asset is RNDR on the Ethereum network and isdifferent from RENDER on the Solana network.
We only accept the sending of RNDR (ERC-20) on the Ethereum network for this crypto
asset, and do not accept RENDER (Solana network).
When transferring the relevant crypto assets from our company to an external party,
please select "ERC-20" for the destination wallet. If you select any other network, thetransfer may fail and your crypto assets may be permanently lost, so please confirm thatthe wallet network is set as Ethereum network.
●

The Graph（GRT）
The Graph is a decentralized data query protocol aimed at simplifying and enhancing
efficiency of decentralized applications (DApps) and smart contract development.
The Graph can be utilized as a fee for developers to retrieve data from the blockchain, as
rewards for holders who stake the Graph and for governance voting in operational
decisions.
Issuance and Burning of the Graph
The initial token supply of the Graph is 10 billion GRT, with an annual target of 3% newissuance.
On top of that, multiple burning mechanisms are in place to adjust the Graph supply.
Approximately 1% of the GRT supply will be burned annually and it is expected that thepercentage will increase as network activity continues to grow.
For more information on issuance and burning, please visit the following page.
https://thegraph.com/docs/en/tokenomics/#token-supply-burning--issuance●

Avalanche（AVAX）
Avalanche utilizes its unique consensus algorithm employing a Proof of Stake (PoS)
mechanism to achieve high scalability and interoperability. The Avalanche platform ishighly compatible with Ethereum, making it also DApps-friendly.
Being a native token on the Avalanche network, Avalanche serves various purposes suchas staking, paying fees within the ecosystem and participating in governance voting.

●

Dogecoin（DOGE）
Dogecoin is a crypto asset developed in 2013 based on Litecoin technology with a logo
featuring a Shiba Inu motif known as the “Doge”, a popular internet meme. Initially,
Dogecoin was released without a clear vision or purpose. However, the project community
gradually expanded and is using it as a payment method in numerous internet shops, fordonations etc.
Mechanics of Dogecoin issuanceDogecoin mining is performed every minute and one block is generated every minute.
During block generation, newly issued assets are granted to miners as a reward for19mining according to the following schedule.
Since there is no upper limit to the number of crypto assets that can be issued, there is nolimit to the number of issuances.
*As of 2024/8/21
Dogecoin mining reward
Number of Blocks（in DOGE）
1–99,999
0–1,000,000
100,000–144,999
0–500,000
145,000–199,999
250,000
200,000–299,999
125,000
300,000–399,999
62,500400,000–499,999
31,250500,000–599,999
15,625600,000+
10,000*Reference: https://github.com/dogecoin/dogecoin/blob/master/doc/FAQ.md●

Zipangcoin Platinum（ZPGPT）
Zipangcoin Platinum is a crypto asset issued by Mitsui & Co. Digital Commodities, Ltd. 1
ZPGPT aims to have a value equivalent to 1 gram of physical platinum and generally
track the price of physical platinum.
Due to its mechanism for price formation and value preservation, this crypto asset holds
asset and investment traits similar to those of physical platinum.
As a crypto asset, Zipangcoin Platinum enables small-scale transactions at a lower costand serves as a reliable, convenient asset management and inflation hedging asset. Like
Zipangcoin (ZPG), Zipangcoin Platinum uses the proprietary private blockchain Miyabi
developed by bitFlyer Blockchain, Inc. as its underlying system.
bitFlyer Blockchain Inc. is the wholly owned subsidiary of bitFlyer Holdings, Inc., theparent company of bitFlyer Inc. Based on this reciprocal relationship, companies
belonging to the bitFlyer Group, including the crypto asset exchange operator bitFlyer
Inc. may continue to receive support from Mitsui & Co. Digital Commodities, Ltd. andDigital Asset Markets, Inc. with respect to Zipangcoin Platinum (ZPGPT).
Regarding Disclosure of the Actual Collateral Status of Zipangcoin Platinum
Information regarding the actual collateral status of Zipangcoin Platinum is regularly
disclosed and published by the issuer. For more information, please refer to the issuer's
website (https://www.mitsuidc.com/news).

●

Zipangcoin Silver（ZPGAG）
Zipangcoin Silver is a crypto asset issued by Mitsui & Co. Digital Commodities, Ltd. 1
ZPGAG aims to have a value equivalent to 1 gram of physical silver and generally track
the price of physical silver.
Due to its mechanism for price formation and value preservation, this crypto asset holds
asset and investment traits similar to those of physical silver.
As a crypto asset, Zipangcoin Silver enables small-scale transactions at a lower cost andserves as a reliable, convenient asset management and inflation hedging asset.
Like Zipangcoin (ZPG), Zipangcoin Silver uses the proprietary private blockchain Miyabi
developed by bitFlyer Blockchain, Inc. as its underlying system.
bitFlyer Blockchain Inc. is the wholly owned subsidiary of bitFlyer Holdings, Inc., theparent company of bitFlyer Inc. Based on this reciprocal relationship, companies
belonging to the bitFlyer Group, including the crypto asset exchange operator bitFlyer
Inc. may continue to receive support from Mitsui & Co. Digital Commodities, Ltd. andDigital Asset Markets Inc. with respect to Zipangcoin Silver (ZPGAG).

20

Regarding Disclosure of the Actual Collateral Status of Zipangcoin Silver
Information regarding the actual collateral status of Zipangcoin Silver is regularly
disclosed and published by the issuer. For more information, please refer to the issuer's
website (https://www.mitsuidc.com/news).
●

Mask Network（MASK）
Mask Network is a browser extension that enables the trading of crypto assets and theuse of decentralized applications (DApps) on social media platforms. It aims to add
blockchain functionality to social media sites like X (formerly Twitter) and Facebook
while protecting user privacy. What makes it unique is that the extension provides endto-end encryption and allows users to send and receive crypto assets, access decentralized
finance (DeFi), and trade NFTs all directly within social media. The associatedgovernance token MASK can be used for governance voting related to the operation anddecision-making of Mask Networks decentralized autonomous organization (DAO)
project.
Decentralized file storage feature
The decentralized file storage feature of MASK Network does not rely on a central server,
and distributes data security and privacy protection across multiple nodes, making it
difficult to tamper with or modify files.
Please note that the decentralized file storage feature may lose its value if it is used in a
way that violates public order or in a way that is considered socially problematic. It isthen also possible that it is disabled in the future.

*The Company endeavors to provide accurate information on this page, but the Company does
not guarantee that the information is complete, up to date, or accurate. The Company does notendorse any specific crypto asset.

Risks
Please ensure that you have thoroughly studied the risks and the structure of trading in advanceand trade at your own responsibility.
The following are examples of risks that may lead to potential losses.
1. Price Fluctuation Risks
The principal is not guaranteed in crypto asset exchange transactions and there is apossibility of losses due to price fluctuations in the crypto asset of the transaction as wellas other price fluctuations. Note that unexpected or specific events, including, but notlimited to, changes to the balance of supply and/or demand, changing prices ofcommodities, fiat currencies, or other markets, natural disasters, wars; changes to laws,
regulations, statutes, and governments, and changes to crypto assets may cause drastic
price fluctuations of crypto assets. The price may even fall to zero.
2. Business Hours Risks
In situations such as when system maintenance is underway, crypto asset exchangetransactions and their associated requests can not be carried out. During these times,
there is the risk of market prices fluctuating significantly.
3. Crypto Asset Network Risks
Crypto assets are electronically recorded and may be lost during transfer across the21network. Crypto asset transactions (transaction confirmation on blockchains) will be held
for a certain period of time until an adequate amount of trade confirmations have been
received. There is also a risk of losses being incurred if any serious problems occur during
the transfer process. There are also risks of crypto assets being lost or prices decreasing
due to cyber attacks, etc.
4. System Risks
As a result of causes that include, but are not limited to, damage to thetelecommunications networks, systems, and equipment used by the Company andcustomers, damage to a connection, natural disasters such as earthquakes, lightning, andfires, or cyber attacks, etc., the electronic trading system may be rendered unusable
temporarily, and transmission of customer orders may be delayed, deleted, or fail toprocess, resulting in invalidation or completion in an unintended manner. Note that in
the event of electronic trading system failure, all or part of the Service, including theexecution of trades may be suspended or restricted by the Company.
Login or other information (including, but is not limited to, email addresses, login IDs,
API keys, passwords, API secrets, private keys, authentication codes, personal
identification numbers (PIN), and the same when referred to by other names) used toelectronically authenticate on the electronic trading system that it is stolen, intercepted,
or otherwise leaked, may result in damages or losses to customers in the event that it isused maliciously by a third party.
If sudden market fluctuations occur, price information may be delayed which would
result in a discrepancy between the displayed price on the digital trading system and theactual market price. The Company is not responsible for any losses incurred by customers
or third parties
5. Risk of Slippage
When placing a market order, or a special order that contains a market order, there may
be a difference between the price displayed on the trade interface and the actual
execution price. The corresponding price difference (slippage) that occurs due to the time
taken in the communication between the customer’s device and the Company’s systems or
the time taken for processing order executions may result in an advantageous price or adisadvantageous price.
6. Risks of The Company's Bankruptcy, Etc.
There is a risk that the Company will be unable to continue doing business due toreasons such as changes in the external environment. In the unlikely event that theCompany is unable to continue doing business, bankruptcy procedures (which include
dealing with customer assets) will be carried out in accordance with applicable laws (theBankruptcy Act, the Companies Act, the Corporate Reorganization Act, the Civil
Rehabilitation Act, etc.). The fiat currency currencies and crypto assets deposited to us by22

the Company’s customers are stored separately and managed separately from theCompany’s own assets.

User Assets
1. Management Method for Asset Segregation
1.1. Method for Managing Entrusted Money
Users’ assets are stored and managed in separate accounts clearly separated from theCompany's own monetary assets. The Company shall store deposited money in
Sumitomo Mitsui Banking Corporation and SBI Clearing Trust Co., Ltd.
1.2. Management Method for Deposited Crypto Assets
Please reference “2. Methods for Managing User Assets” below.
2. Methods for Managing User Assets
2.1. Methods for managing user assets
The Company manages its data so that crypto assets held by us and crypto assets heldby each customer can be distinguished immediately.
All of our customers’ assets for each crypto asset the Company lists are stored inseparately managed cold wallets. The Company also manages a portion of crypto
assets with multi-sig.
2.1.1. Cold Wallets
Cold wallets are wallets that store the private key for crypto assets, and are kept
offline, in an environment that is not connected to the Internet. The Company’s cold
wallets are protected by multiple physical security measures and a 24-hour
surveillance system for extra protection. The management of each crypto asset
handled in cold wallets is a standard prescribed by the Company. In addition to cold
wallets, private keys are always stored in an encrypted state so that even if a private
key were to be leaked, it would be impossible to be used by a third party.
2.1.2. Multisig (Multiple-signature Wallet)
Multisig technology requires multiple private keys to authorize remittance. Multisig
technology can be used to create highly secure wallets. With the proper configurationof multisig, even if a private key, the most important piece of data, were to be leaked,
it would still be impossible to move the corresponding crypto asset without the otherrequired key(s). In general, it is significantly difficult for an attacker to penetrate
two or more highly secure platforms at the same time.
2.2. Equipment, personnel, and methodology required for the secure management of user
assets The Company shall maintain the necessary equipment, and sufficient personnel
to operate the equipment, for moving the fiat currencies and crypto assets that are23

user assets. Additionally, the Company shall establish strict internal regulations on
the procedures involving private keys required to move crypto assets.

Fees, etc.
Fees and other charges to be paid by registered users, as well as the calculation methods, are as
follows.
The necessary fees are purchase and sales fees, JPY withdrawal fees, bank transfer fees
(specified by each financial institution), Quick Deposit fees, crypto asset withdrawal fees, andother fees. For details, please refer to https://bitflyer.com/en-jp/s/commission.

Account Creation Fee

Free

Account Maintenance
Fee

Free

Bitcoin and Altcoin
Trading Fees

Exchange (BTC/JPY)

Execution amount x 0.01 ~0.15% (Base unit: BTC)

Lightning Spot (BTC/JPY)
Buy/Sell Bitcoin

Free(The price at which thecustomer can buy or sell will
be quoted by adding or
subtracting the spread to orfrom the middle market
price.)

Exchange (ELF/JPY)

Execution amount x 0.2%
(Base unit: ELF)

Lightning Spot（ETH/JPY）

Execution amount x 0.01% ~0.15% (Unit varies byaltcoin)Lightning Spot（XRP/JPY）
Lightning Spot（XLM/JPY）
Lightning Spot（MONA/JPY）
Lightning Spot（ETH/BTC）
Lightning Spot（BCH/BTC）
Buy/Sell Ethereum

Execution amount x 0.2%
(Base unit: Differs for eachaltcoin)Free

24

Buy/Sell Ethereum Classic
Buy/Sell Litecoin
Buy/Sell Bitcoin Cash
Buy/Sell Monacoin
Buy/Sell Lisk
Buy/Sell Ripple (XRP)
Buy/Sell Basic Attention Token (BAT)
Buy/Sell Stellar Lumens (XLM)
Buy/Sell NEM (XEM)
Buy/Sell Tezos (XTZ)
Buy/Sell Polkadot (DOT)
Buy/Sell Chainlink (LINK)
Buy/Sell Symbol (XYM)
Buy/Sell Polygon (MATIC)
Buy/Sell Maker (MKR)
Buy/Sell Zipangcoin (ZPG)
Buy/Sell Flare (FLR)
Buy/Sell Shiba Inu (SHIB)
Buy/Sell Palette Token (PLT)
Buy/Sell The Sandbox (SAND)

25(The price at which thecustomer can buy or sell will
be quoted by adding or
subtracting the spread to orfrom the middle market
price.)

Buy/Sell Decentraland (MANA)
Buy/Sell Axie Infinity (AXS)
Buy/Sell Immutable (IMX)Buy/Sell ApeCoin (APE)
Buy/Sell Chiliz (CHZ)
Buy/Sell Dai (DAI)
Buy/Sell Render Token (RNDR)
Buy/Sell The Graph (GRT)
Buy/Sell Avalanche (AVAX)
Buy/Sell Dogecoin (DOGE)
Buy/Sell Zipangcoin Platinum (ZPGPT)
Buy/Sell Zipangcoin Silver (ZPGAG)
Buy/Sell Mask Network (MASK)

26

Exchange Fee
Past 30 day volume

Exchange / Lightning Spot (excludes ETH/BTC andBCH/BTC)

Less than 100,000 JPY

0.15%

100,000 - Less than 200,000 JPY

0.14%

200,000 - Less than 500,000 JPY

0.13%

500,000 - Less than 1 million JPY

0.12%

1 million - Less than 2 million JPY

0.11%

2 million - Less than 5 million JPY

0.10%

5 million - Less than 10 million JPY

0.09%

10 million - Less than 20 million JPY

0.07%

20 million - Less than 50 million JPY

0.05%

50 million - Less than 100 million JPY

0.03%

100 million - Less than 500 million JPY

0.02%

500 million or more JPY

0.01%*The customer’s Bitcoin and altcoin trading fee rate is calculated daily between 0:00 and 00:10
AM.
*Measured total trade volume includes trades from Bitcoin Buy/Sell, Exchange, Lightning Spot
(excludes ETH/BTC and BCH/BTC) and bitFlyer Crypto CFD.
*Fees may be negotiated based on volume and trade frequency.

Complaints and Consultation
For more information on transactions and services, please contact us here.
● Contact page: https://bitflyer.com/en-jp/contactpage●

Email: info@bitflyer.com●

Address: Midtown Tower 30F, 9-7-1 Akasaka, Minato-ku, Tokyo 107-6230 bitFlyer, Inc.

●

Call Center:
Complaints: 03-6434-7624
Regarding restricted transactions, unauthorised logins and fraud damage: 03-6434-7957
General Inquiries: 03-6434-5864○

The call center is open weekdays from 9:30 to 17:30 (JST)○Only available in Japanese○

These phone numbers are not toll-free27○Outside of the hours of operation, please make inquiries through the Company’s
contact form (https://bitflyer.com/en-jp/contactpage). The Company will respondby email.

Dispute Resolution Measures
The Tokyo Bar Association's Dispute Resolution Center, the Dai-ichi Tokyo Bar Association's
Arbitration Center, and the Daini Tokyo Bar Association's Arbitration and Mediation Center are
all available for resolving disputes between the Company and customers of the Company. The
Japan Virtual and Crypto Asset Exchange Association (Name will change to the Japan Crypto
Asset Trading Association as of May 1, 2020)’s complaint form may also be used.
Inquiries and Support

Contact Information

Japan Crypto Asset Trading Association

Kawakita Memorial Building 4F, Ichibancho 18,
Chiyoda-ku, Tokyo 102-0082, Japan
Tel: 03-3222-1061

Tokyo Bar AssociationDispute Resolution
Center

1-1-3 Kasumigaseki, Chiyoda-ku, Tokyo 100-0013,
Japan
Tel: 03-3581-0031

Dai-ichi Tokyo Bar Association ADR
Center

1-1-3 Kasumigaseki, Chiyoda-ku, Tokyo 100-0013,
Japan
Tel: 03-3595-8588

Dai-ni Tokyo Bar Association ADR Center

1-1-3 Kasumigaseki, Chiyoda-ku, Tokyo 100-0013,
Japan
Tel: 03-3581-2249

Certified Association for Payment Service Providers MembershipJapan Crypto Asset Trading Association

About the Contract
Parties who wish to use the Company's services as they relate to crypto asset exchange mustregister for these services. Once user registration is complete, it remains valid until the date on
which that user’s registration is cancelled. If you would like to have your user registration
cancelled, please notify us using the inquiry form (https://bitflyer.com/en-jp/contactpage) found on
the Company's website.

Other
1. Methods for Depositing Fiat Currency and Crypto Assets
When depositing JPY to be used for the Company’s services, please make deposits bymaking a bank transfer to the account in your name at the financial institution
designated by the Company. When depositing crypto assets to be used for the Company’s
services, please transfer it to the crypto asset address designated by the Company. For
deposits of either JPY or crypto assets, the amount is not deposited at the point in time at28

which the customer has finished the transfer procedure, but rather at the point in time atwhich the Company has confirmed and received the amount.
2. Asset Status and Trade Report
To confirm the status of your deposited assets or your trading history, log in and view
“My Assets” or the “Trade Report.”
3. Storage of Login Information
It is the customer’s own responsibility to set, manage, and store their login information.
Please do not use the same password on other services or passwords that are easy toguess. The Company requires two-factor authorization for when “sending crypto assets orusing bitWire”, “registering an external crypto asset address”, and “making JPY
withdrawals.” but we sincerely recommend also enabling two-factor authentication for“when logging in”, You can change your security settings from the “Settings” menu after
logging in.
4. Other
The Terms of Use stipulate items that must be observed by customers during use of theCompany’s services as well as the relationships of rights and obligations between the
Company and between all customers. We ask that you take time to carefully read overthese terms.

[Enacted on April 1, 2017][Amended on July 18, 2017][Amended on October 30, 2017][Amended on January 25, 2018][Amended on February 8, 2018][Amended on June 9, 2018][Amended on August 10, 2018][Amended on August 31, 2018][Amended on October 31, 2018][Amended on May 28, 2019][Amended on November 29, 2019][Amended on January 31, 2020][Amended on April 20, 2020][Amended on August 6, 2020][Amended on November 26, 2020][Amended on December 8, 2020][Amended on March 3, 2021][Amended on April 1,2021][Amended on June 29, 2021][Amended on December 14, 2021][Amended on February 25, 2022][Amended on March 24, 2022][Amended on June 17, 2022][Amended on August 2, 2022][Amended on December 21, 2022][Amended on January 23, 2023][Amended on February 1, 2023][Amended on February 10, 2023]

29

[Amended on March 29, 2023][Amended on June 21, 2023][Amended on June 26, 2023][Amended on July 27, 2023][Amended on December 30, 2023][Amended on February 5, 2024][Amended on February 9, 2024][Amended on February 15, 2024][Amended on February 19, 2024][Amended on February 26, 2024][Amended on February 29, 2024][Amended on March 15, 2024][Amended on April 4, 2024][Amended on August 9, 2024][Amended on August 23, 2024][Amended on August 28, 2024]30