Terms of Use
March 15, 2024

bitFlyer, Inc.

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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.

The Terms of Use (hereinafter referred to as the “Terms”) set forth the mattersto be observed by the Registered Users as well as the rights and obligations of
bitFlyer, Inc. (hereinafter referred to as the “Company”) and the RegisteredUsers with respect to the use of the sale or purchase of Crypto Assets, Over-thecounter Derivatives of Crypto Asset Transactions and other related services
provided by the Company. Every user desiring to register for the services will be
required to read through the entire text of the Terms carefully before agreeing
thereto.

Article 1 Scope of Application
1. The Terms shall define the rights and obligations of the Company and the RegisteredUsers (as defined in Article 2), and shall apply to any relationship between the Company
and the Registered Users with respect to the use of the Service (as defined in Article 2).
2. The rules and regulations concerning the Service which may be posted by the Company
on the Website (as defined in Article 2) from time to time shall constitute part of theTerms.

Article 2 Definitions
For the purposes of the Terms, the following terms shall have the meanings ascribed to them asfollows:
1. “Intellectual Property Rights" refers to copyrights, patents, utility model rights,
trademark rights, all rights to data (including transaction price data retrievable via
APIs), documents, databases, websites, graphics, software, applications, programs, andcode (including but not limited to chat posts, the contents of Company emails, etc.), whichhave been developed or provided by the Company or an affiliate of the Company, as wellas any other intellectual property rights including, without limitation, the rights toacquire these rights or to file an application for the registration of any of such rights.
2. “Website” refers to the website on the Internet operated by the Company with the domainof bitflyer.jp, bitflyer.com, bitflyer.org or bitflyer.net, irrespective of device, including,
without limitation, the new website in cases where the domain or contents of the Website
are changed.
3. “Applicant” refers to the “Applicant” defined in Article 3.
4. “Registration Information” refers to the “Registration Information” defined in Article 3.
5. “Registered User” refers to an individual or a corporation who is registered as a user of
the Service in accordance with the provisions of Article 3.
6. The "Service" refers to the crypto asset purchase and sales service provided by theCompany called Buy/Sell Bitcoin and Buy/Sell Altcoins (hereinafter, collectively"Buy/Sell"), bitFlyer Lightning (including the Exchange). The Service provides a place tobuy and sell crypto assets between Registered Users, a service to conduct over-thecounter derivatives of crypto asset transactions between Registered Users and theCompany, and other related services (if the name or content of the Service is changed forany reason, the Service after the change is included).
7. “Service Agreement” refers to the agreement to be executed between the Company and2the Registered User pursuant to Article 3.3 with respect to the use of the Service under
the provisions of the Terms.
8. “Crypto Assets" refers to crypto assets handled by the Company, and “Over-the-counter
Derivatives of Crypto Asset Transactions" refers to index forward transactions as definedin Article 2.22.2 of the Financial Instruments and Exchange Act, which are traded
between Registered Users and the Company with reference to crypto assets specified by
the Company.
9. An “Insider” refers to anyone who meets the following criteria.
1. Issuers and managers of crypto assets handled by the Company and issuers andmanagers of reference crypto assets for Over-the-counter Derivatives of Crypto
Asset Transactions conducted by the Company
2. A company affiliated with a person described in 1
3. A major shareholder of those described in 1 and/or 2
4. An executive of those described in 1 and/or 2
5. Person who qualified for 4 within the last 1 year
6. Spouse of or someone living in the same home as a person described in 4
7. Executive or employee of 1 and/or 2
8. Major shareholders, executives, or employees of a Crypto Assets operator as wellas major shareholders, executives, or employees of Financial Instruments
Business operator engaging in Over-the-counter Derivatives of Crypto Asset
Transactions
10. "Crypto Asset Information" refers to crypto assets (including crypto asset indices; thesame shall apply hereinafter) that the Company currently handles or intends to handle,
or that the Company specifies or intends to specify as underlying assets for Over-thecounter Derivatives of Crypto Asset Transactions. The Company and other crypto asset
handling business operators that have not been disclosed regarding crypto assets or
crypto asset-related financial indicators (regardless of whether registered or not, thosethat engage in crypto asset-related transactions including Over-the-counter Derivativesof Crypto Asset Transactions as a business. The same shall apply hereinafter) and
important information related to insiders as defined in the preceding clause, such astransaction decisions related to the crypto assets of the Company’s users or Over-thecounter Derivatives of Crypto Asset Transactions that refer to the crypto assets (type,
number and price of crypto assets to be traded, whether to trade or exchange, the method
and timing, or the content and timing of over-the-counter derivative transactions related
to crypto-assets. means information that is accepted.

Article 3 Registration
1. Any person who desires to use the Service (hereinafter referred to as the “Applicant”)
may apply to the Company for registration as a user of the Service by agreeing to abideby the Terms and providing the Company with the information required by the Company(hereinafter referred to as the “Registration Information”) in a manner specified by theCompany.
2. The Applicant represents and warrants that he/she was not in the past, is not in thepresent, and will not in the future be any of the following:
1. Anti-social forces (hereafter defined as criminal organizations, criminalorganization members, semi-criminal organization members, companies related
to criminal organizations, corporate extortionists, political racketeers, organizedcrime syndicates, and/or other similar entities); or
2. Involved in anti-social forces in any manner including, but not limited to,cooperation or engagement in the maintenance, operation, and/or management ofanti-social forces through funding or any other method.
3. The acceptance or rejection of applications for the registration will be determined by theCompany in accordance with the criteria established by the Company. The registration of
an Applicant as a Registered User shall be deemed to have been completed when the
Company issues to the Applicant a notice stating that the application has been accepted.

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The Company is not obligated to disclose details regarding the application review process,even in the event that the Applicant was rejected. Furthermore, regardless of acceptanceor rejection of registration, the Company is under no obligation to return documents, etc.
received from the Applicant.
4. The completion of the registration under Article 3.3 constitutes the execution of theService Agreement between the Registered User and the Company with respect to theuse of the Service in accordance with the provisions of the Terms, whereby the RegisteredUser shall be entitled to use the Service in such a manner as specified by the Company
from the date of the completion of the registration.
5. The Company may reject the Applicant's registration if:
1. Registration Information submitted to the Company contains, in whole or part,
false or erroneous statements or omissions;2. the Applicant is a minor, an adult ward, a person under curatorship or a person
under assistance, or voluntary guardianship is commenced through theappointment of a voluntary guardianship supervisor;
3. the Company determines that the Applicant is or was in the past 5 years amember of anti-social forces, or the Company determines that the Applicant is or
was in the past 5 years associated with or involved in anti-social forces in any
manner such as cooperating or engaging in maintenance, operation, managementof anti-social forces through funding or any other method;
4. the Company determines that the Applicant is committing or has committed anyof the acts entailed in Articles 8 or 12;
5. the Applicant resides in a country or region where the Service is not being
provided, or in the event that the Applicant meets certain conditions outlined at
the Company's discretion;
6. the Company determines that the Applicant may possibly be a specified

United States person as designated in the Statement (FATCA statement)of Mutual Cooperation and Understanding between the U.S. Departmentof the Treasury and the Authorities of Japan to Improve International
Tax Compliance and to Facilitate Implementation of FATCA;or
7. the Company otherwise determines that the registration would be inappropriate.

Article 4 Changes in Registration Information
1. In the event of any change in the Registration Information, the Registered User shallpromptly notify the Company of such change in accordance with the procedure specified
by the Company and submit to the Company the required information.
2. The Registered User shall, without fail, notify the Company in writing if he/she is or
becomes a PEP (politically exposed person) or relative of a PEP.
3. The Registered User shall, without fail, notify the Company in the event that assistance,
curatorship, or guardianship has been or will be commenced by a family court trial, orthat voluntary guardianship has been or will be commenced through the appointment of
a voluntary guardianship supervisor by a family court trial.
4. The Company is not responsible for damages incurred by the Registered User in theevent that the Registered User neglects or delays reporting the changes detailed in
Article 4.1 and Article 4.2.

Article 5 Management of Password and User ID
1. The Registered User shall be fully responsible for the settings, security and safekeepingof their password (hereafter defined as including but not limited to login password, API
secret, private keys, authentication codes, PINs, etc.) and user ID (hereafter including
but not limited to their login ID, account ID, API key, etc.) and the Registered User shallnot cause or permit any third party to use the password or user ID nor shall he/she loan,
assign, or cause to be owned in the name of another person or to be sold or purchase thepassword or user ID or otherwise cause the password or user ID to be an object of any

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activity similar to the foregoing.
2. Use of the Service by a third party with the Registered User's password and user ID isdeemed as use of the Service by the Registered User. The Registered User is responsiblefor damages incurred in the event that the Registered User’s password or user ID aremismanaged, wrongfully or improperly used, leaked, used by a third party, stolen, etc.
(regardless of whether the Registered User himself/herself entered the information, theCompany confirms that the password and user ID match for use of the Service (forexample, if the Registered User’s email was hacked and the same User ID and Password
are used for other services)); the Company is not responsible. Excludes cases where theCompany makes a specific exception.
3. In cases where the password or user ID are found to be stolen or used by a third party,
the Registered User shall immediately notify the Company to that effect and follow the
instructions provided by the Company.

Article 6 Fees and Payment Methods
1. When using the Service, the Registered User shall pay fees and other service charges
separately determined by the Company.
2. In the event that the Registered User fails to pay the required fees, the Registered User
shall pay to the Company 14.6% per annum of the unpaid amount as default interest.
3. Registered Users who do not reside in Japan may be charged an additional fee
separately, specified by the Company.
4. If the Registered User does not pay the necessary payment or fees by the due datespecified by the Company and the obligation of the Registered User to the Company
remains, the Company shall be able to offset the obligation or any claim the RegisteredUser has to the Company or any other claim without prior notice, regardless of thedeadline of the claim. In doing so, the Company may, at any time and without priornotice, cancel payout of the Registered User's money or Crypto Asset, cancel orders,dispose of holding assets, settle the open interest by countertrading for Over-the-counter
Derivatives of Crypto Asset Transactions, exchange currency at the Company's arbitrary
rate, etc. as judged necessary by the Company. The Company is not responsible for any
losses, etc. caused by offsetting and/or this process.
5. In the event of an offset as described in the preceding clause, the Company shall decide,at the Company’s own discretion, the credit liability interest, calculation of the penalty,
period and date of executing the offset, interest rate, tariffs, and foreign currency or
Crypto Asset exchange rates. In the event that the Registered User’s offset is unable tofulfill all obligations, the Company may allocate the available offset as the Company
deems appropriate.

Article 7 Use of the Service
1. During the period of valid registration as a Registered User, the Registered User shallhave the right to use the Service in such a manner as directed by the Company inaccordance with, and within the scope of, the Terms. Upon use of this Service, theRegistered User confirms that he/she has carefully read and reviewed the terms andconditions of the Terms as well as the written explanations and information regarding
risks provided on the Company's website, and the Applicant confirms that he/sheunderstands the contents (including the purchase/sale of Crypto Assets), the workings,
and the risks related to using this Service.
2. The Registered User shall, at their own cost and responsibility, prepare and maintaincomputers, software and other devices, and telecommunication lines and othercommunication environments which are necessary to use the Service.
3. The Registered User shall, at their own cost and responsibility, prepare and maintainsecurity systems suitable for the Registered User’s environment for use of the Service to
avoid computer virus attacks, unauthorized access, information leakage, etc.
4. As part of the Service, the following terms and conditions shall apply to Buy/Sell.
1. Registered Users may submit orders to buy or sell crypto assets in accordance5with the method determined by the Company. The prices at which crypto assets
are purchased and sold shall be determined by the method prescribed by theCompany, and Registered Users shall not raise any objections in this regard. The
Company does not promise or guarantee the conclusion of the purchase and saleof crypto assets to Registered Users.
2. When the price is determined in accordance with the preceding clause, a contract
for the purchase and sale of crypto assets shall be deemed to have been executed
between the Registered User and the Company. Registered Users agree inadvance to be bound by the terms and conditions of the corresponding contract
once formed, and may not withdraw thereafter.
5. The following are the terms and conditions applied to purchases and sales on bitFlyer
Lightning.
1. The buying and selling of crypto assets on bitFlyer Lightning is primarily a place
to match Registered Users who want to sell crypto assets (hereinafter referred to
as “Sellers”) and Registered Users who want to buy crypto assets (hereinafterreferred to as “Buyers”). The information is provided by the Company (in somecases, the Company may be a party to the transaction). The Company mediates
the sale and purchase of crypto assets between Registered Users, but does notpromise or guarantee that the sale of crypto assets will be completed to theRegistered Users.
2. The Seller and the Buyer may place the order of sales of Crypto Assets in such amanner as directed by the Company. The price of the purchase and sale shall be
determined to be the price agreed between the Seller and the Buyer, and theCompany shall not be responsible for the agreed price.
3. The sales agreement of Crypto Assets between the Seller and the Buyer shall bedeemed to be entered into when the price is agreed between both parties. The
Registered User shall agree in advance to be bound by the terms and conditions
as of the effective time of the sales agreement, and not to cancel thereafter.
4. If there is a possibility that a Registered User's order may self-trade with anotherorder of the same user that has already been received by the Company (meaninga case where the conditions match and execution may occur), the Registered User
may not place such an order.
6. As part of the Service, the following terms and conditions shall apply to Over-the-counter
Derivatives of Crypto Asset Transactions on bitFlyer Lightning:
1. Over-the-counter Derivatives of Crypto Asset Transactions on bitFlyer Lightning
are conducted through the execution of Over-the-counter Derivatives of Crypto
Asset Transactions contracts between Registered Users and the Company in anegotiated transaction. The Company shall execute Over-the-counter Derivativesof Crypto Asset Transactions with Registered Users only within the range of thevolume that the Company can execute, but the Company does not promise or
guarantee the execution of Over-the-counter Derivatives of Crypto Asset
Transactions to Registered Users.
2. Registered Users may present orders for Over-the-counter Derivatives of Crypto
Asset Transactions in accordance with the method determined by the Company.
The Company will offer the total of the volume of orders in the opposite direction
received from another registered user and the volume required by the departmentthat conducts proprietary trading within the Company as the volume at each
price that the Company can accept for Over-the-counter Derivatives of Crypto
Asset Transactions with a Registered User. The Company shall not engage inOver-the-counter Derivatives of Crypto Asset Transactions with Registered Usersin excess of the volume presented to Registered Users.
3. A contract for Over-the-counter Derivatives of Crypto Asset Transactions shall bedeemed to have been concluded between a Registered User and the Company
when the conditions regarding the price and volume presented by the Registered6

User and the Company are met. The Registered User agrees in advance that theRegistered User is bound by the terms and conditions of the contract at the time
the contract is formed, and that the contract cannot be withdrawn thereafter.
4. If there is a possibility that a Registered User's order may self-trade with anotherorder of the same user that has already been received by the Company (meaninga case where the conditions match and execution may occur), the Registered User
may not place such an order.
5. The volume and open interest (positions) that Registered Users are allowed to
trade are within the limits set by the Company, and the Company shall not
execute orders that exceed such limits. The Company shall not execute ordersthat would result in a shortage of margin for Registered Users. The Company
may give notice to a Registered User who has an excessive amount of open
positions relative to the volume of orders received from other Registered Users,
requesting the user to reduce the volume of open positions to the extent requestedby the Company. Upon receipt of such notice, the Registered User shall reduce
the amount of open positions by the deadline requested by the Company.
7.

As part of the Service, the margin deposit requirements for Over-the-counter
Derivatives of Crypto Asset Transactions in bitFlyer Lightning are as follows:

1. When conducting Over-the-counter Derivatives of Crypto Asset Transactions with
the Company, Registered Users shall make a margin deposit with the Company
in an amount determined by the Company in a manner determined by theCompany in order to secure all customer obligations to the Company arising from
Over-the-counter Derivatives of Crypto Asset Transactions. Registered Users may
use crypto assets held by the corresponding Registered User and deposited with
the Company as margin. In this case, the valuation of such crypto assets shall be
determined by the Company, and the Company may change the valuation method
without notice.
2. If an Over-the-counter Derivatives of Crypto Asset Transactions generates profit
or loss, the Company may add the profit on deposited margin (hereafter,
including Crypto Assets deposited as a substitution for the margin) or deduct theloss from the deposited margin, without prior notification to the relevant
Registered User.
3. A Registered User shall always maintain an amount of margin at least equal to
the level of the amount of margin to be maintained for the Registered User'stransactions as determined by the Company during the period from thecommencement of new transactions to the settlement of such transactions.
4. The Company may reasonably change the margin maintenance rate inaccordance with changes in economic conditions or revision of Laws andRegulations, etc. When the margin maintenance rate is changed, the changed
margin maintenance rate shall be applied to the margin of open interest(positions) of Registered Users.
5. In addition to the preceding subclauses, the handling of margins for Over-thecounter Derivatives of Crypto Asset Transactions shall be in accordance with theCompany's rules.
8. As part of the Services, the terms and conditions for sell out transactions related to Overthe-counter Derivatives of Crypto Asset Transactions on bitFlyer Lightning are as
follows:
1. When a Registered User's open interest (position) falls under the criteria set by
the Company as sell out rules, the Company may, at the Company’s discretion
and without notice to the Registered User, reverse the transaction on thecustomer’s account. In such a case, the Company shall execute sell outtransactions only within the range of the volume at each price that the Company
has presented as the volume at which Over-the-counter Derivatives of Crypto

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Asset Transactions can be executed. In such a case, the Company shall not beheld liable for failing to immediately execute sell out transactions when sell out
rules are triggered.
2. The Company shall not be held responsible for any losses incurred as a result of
countersales in accordance with the preceding subclause, even if such losses
exceed the price range set in the sell out rules.
3. The sell out rules may be changed at the discretion of the Company.
9. The usage conditions concerning the deposit of money or Crypto Assets and thewithdrawal of money or Crypto Assets from Registered Users' accounts are as follows:
1. The Registered User shall be entitled to deposit money or Crypto Assets into theiraccount in a manner prescribed by the Company.Money or Crypto Assets will beconsidered deposited only after the Company has confirmed its receipt, not uponcompletion of transfer or other procedures taken by the Registered User. In
addition, the Registered User is responsible for any transfers and/or deposits oflegal currencies, Crypto Assets, tokens and/or other formats not supported by theCompany ("Unsupported Currency"), and deposits of Crypto Assets made to an
address that differs from the one allocated by the Company without prior consent
from the Company. In the event that an Unsupported Currency is sent to theRegistered User's account or a Crypto Asset is deposited to an address that differsfrom the one allocated by the Company, the Company does not bear the
responsibility to make a return to the Registered User, and, in the event of a
return, the Company may collect handling fees. The withdrawal, depositing, andreturning of Unsupported Currency or depositing Crypto Assets to an addressthat differs from the one allocated by the Company carries the risk of loss ofassets. The Company is not responsible for damages incurred by Registered Users
due to the above.
2. In response to the Registered User's request, the Company shall withdraw moneyfrom the Registered User's account or withdraw Crypto Assets according to themethod prescribed by the Company. The Registered User may request thewithdrawal of crypto assets after agreeing to the requirements determined by the
Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange andForeign Trade Act, and any other relevant laws and regulations. The RegisteredUser designates a withdrawal destination at their own risk, and when the
Company withdraws money or Crypto Assets in accordance with the instructionsof the Registered User, the Company is not responsible for the money or Crypto
Assets and is not responsible for the accuracy and validity of the destination
information provided by the Registered User. If the Registered User is a businessthat handles personal information as defined in Article 2.5 of the Act on theProtection of Personal Information, the Company must obtain approval from therecipient of the crypto assets to receive notification of the name and address of
the recipient in advance of sending the crypto assets. The Company shall requestthat the corresponding crypto assets be sent after approval and the recipient's
name and sender's crypto asset address are reported to the Company.
3. When a Registered User makes a request for sending crypto assets to a declared
recipient on another crypto asset exchange operator, in accordance with the Act
on Prevention of Transfer of Criminal Proceeds and self-regulations from theJapan Virtual and Crypto asset Exchange Association that were formulated tocomply with the international requests from the FATF Recommendations,
Guidance and Interpretive Note, the Registered User's personal data including,but not limited to, full name, address or customer identification number, sender'scrypto asset address, and recipient's crypto asset address shall be reported to thecorresponding crypto asset exchange operator with the intention of preventing
terrorists and other criminals from freely using crypto asset transfer systems as

8well as trace any instances of such use. The Company shall obtain and store theprovided personal data. The Registered User must agree to provide thecorresponding personal data to other crypto asset exchange operators.
4. If the registered user does not agree to the previous clause, the Company will not
send the corresponding crypto asset. The Company is not responsible for any
losses incurred in such a case.
5. Regardless of the previous item, in the event of theft of the Company’s assets orassets under the custody of the Company by hacking or other methods, should theCompany determine that the specific Crypto Asset is difficult to restore, theCompany may, by means of the Company’s choosing, restore a converted amountof money or other Crypto Asset.
6. Even when the Company has performed the sending or receiving of Crypto Assets
for the Registered User's account pursuant to the previous items, in the eventthat the Registered User’s sending or receiving of Crypto Assets transaction iscanceled on the corresponding blockchain, the Company may cancel the sametransaction for the Registered User’s account.
7. In the event of a chain split by a hard fork, etc., other change in the structure of a
Crypto Asset, or air drop, etc., the Company may form or not form measures at
the Company’s discretion. The Company is not obligated to credit the newly
created Crypto Asset to Registered Users, and if the Company does credit theRegistered Users, the Company may charge processing expenses to theRegistered Users. The Company is not responsible in the event that a RegisteredUser or a third party incurs losses or damages as a result of the defects,
alteration, or lack of measures or changes in the measures taken by theCompany.
10. The Company may, upon obtaining an agreement (includes comprehensive agreements),
borrow Crypto Assets from the Registered Users without collateral.
11. The Company may, in order to improve convenience and service quality, implement
experimental measures to the Service, and the Registered Users agree to cooperate to areasonable extent.

Article 8 Prohibited Activities
1. The Registered User shall be prohibited from engaging in any of the following activities
with respect to the use of the Service:
1. to perform any act which would infringe any Intellectual Property Rights or
portrait rights of the Company, other users of the Service or other third parties(including any act which raises such infringement directly or indirectly);
2. to take part in the unauthorized commercial use or reproduction of any and all
intellectual property, copyrights, names and likenesses that the Company holds
the rights to;
3. to perform any act which would infringe any privacy rights, credits, or otherrights or interests of the Company, affiliated companies, others related to theCompany, other users of the Service or other third parties (including any act
which raises such infringement directly or indirectly);
4. to conduct criminal acts including, but not limited to, fraudulent activity,
establishing or soliciting for pyramid schemes, etc., purchases and/or sales ofillegal goods and/or services, transferring profits gained from illegal acts or using
the Service to perform these acts.
5. to perform an act associated with a criminal act, or an act against public orderand good morals;
6. to gamble (including online casinos, the same applies below), regardless ofcountry or region, or sending or receiving Crypto Assets to or from persons who
conduct or organize gambling (including affiliate advertisements), or any act thatencourages or facilitates these activities.
7. to transmit information related to relations between people;
8. to advertise to or solicit other Registered Users and/or other third parties (except

9where permitted by the Company)
9. to perform any act which violates any law or regulation, or the internal rules ofan entity of which the Company or the Registered User is a member;
10. to engage in or attempt the duplicate assignment of Crypto Assets;
11. to transmit information containing computer viruses or other harmful computer
programs or to destroy or obstruct the system, server, network, or other functions
managed by the Company, or to perform any act that places an unnecessarily
excessive burden on any of the aforementioned items;
12. to exploit errors, bugs, security loopholes, or other defects found in any of thesystems, servers, or networks related to the Service or managed by the Company;
13. to modify information which can be used for the purpose of the Service;
14. to transmit through the Service data the volume of which is larger than the sizeof data specified by the Company;
15. to use API or other programs not offered by the Company to use the Service
outside of the intentions of the Company’s system design, or have an influence onother systems of the Company or other Registered Users;
16. to perform any act which is likely to interfere with the operation of the Service by
the Company, (including, but not limited to) failure to reduce the volume of open
positions in Over-the-counter Derivatives of Crypto Asset Transactions by thedeadline requested by the Company, despite receiving a notice from the Company
requesting the reduction of the volume of open interest in Over-the-counter
Derivatives of Crypto Asset Transactions..
17. to deliberately steal the assets of Registered Users, the Company, or affiliatedcompanies, through replay attacks, etc.;
18. to disseminate rumors or non-factual information, or to commit an act of fraud,
extortion or blackmail, that may defame the reputation of the Company;
19. to create multiple accounts by the same person;
20. to engage in the sharing of an account with multiple persons, to permit a third
party other than the Registered User to use the account, to conspire with otherregistered users to commit any of the acts listed in any of the items of thisparagraph, or any transactions associated with these acts;
21. to open or attempt to open an account using a false name, another person’s name,or any name other than one’s own real name, trade under such circumstances, orprovide partially or wholly false information as the account’s registeredinformation;
22. to provide services (including, but not limited to, the purchases, sales, trades,
transfers or payments of Crypto Assets and the distribution of price information)that are the same or similar to the Service to third parties based on information,etc. obtained through use of the Service or other users of the Service (including,but not limited to, acting as an agent to perform trades for third parties and/or
using the Service to trade for third parties); to use such information, etc. obtained
through the Service for commercial purposes such as providing services, goods,
etc. to third parties (including using the Service to receive Crypto Assets aspayment for sale or issuance of Crypto Assets or tokens that are sold or issued by
the Registered User or a third party, from an unspecified large number of third
parties); and/or to allow subsidiaries or other third parties to engage in any of theaforementioned acts; except for cases in which prior written consent has been
received from the Company for the situations in this item;
23. to have a third party make monetary deposits into the Registered User’s account,or make monetary withdrawals from the Registered User’s account to a third
party’s account (except where specifically permitted by the Company in advance)
24. to make deposits and withdrawals seemingly unrelated to the use of the Service,repeated orders in a short period, repetitively sending Crypto Assets to the same
receiver within a short period, etc., or usage of the Service that the Company
deems to be inappropriate or suspicious.
25. to perform any of the following actions with the intent of altering the prices of
Crypto Assets or Crypto Asset trades (includes Over-the-counter Derivatives of
Crypto Asset Transactions and Crypto Asset indices):101. Disseminating facts with no logical basis in which the disseminator does
not does not have direct experience or recognition to an unspecified large
number of people
2. Using means to mislead other people into fraudulent acts; unnecessarily
using speech or actions that agitate a passion for speculation in otherpeople3. Using assault or intimidation
26. to perform any of the following acts with the intent of artificially manipulating, or
causing fluctuations in, the price of Crypto Assets and Over-the-counter
Derivatives of Crypto Asset Transactions:
1. Purposely misleading other people into transferring their rights over
Crypto Asset related trading; disguising trades that are not performed
with the intent of exchanging money
2. Colluding with a third party with the intent of misleading other people on
Crypto Asset related trades
3. Performing actual Crypto Asset trades with the intention of misleading
other people into seeing trading the corresponding Crypto Asset as
prosperous for the purpose of enticing other people into Crypto Asset
trades
4. Intentional market manipulation performed by oneself or with anotherparty with the intent of causing the indicated price of the Crypto Asset tofluctuate, or intentionally disseminating information on important items
that is fraudulent or promotes a misunderstanding in order to enticeother people into Crypto Asset related trades
5. All acts detailed in Article 185, Clause 22, Subclause 1, Article 185,
Clause 23, Subclause 1, Article 185, Clause 24, Subclauses 1 and 2 of the
Financial Instruments and Exchange Act
27. to perform Crypto Asset related trades using information on Crypto Assets gainedby one’s status as an insider
28. to perform the following acts related to losses incurred by the Registered User inthe course of trading conducted by the User
1. to demand a promise for warranty for loss or profit from us or a third
party prior to the occurrence of a relevant loss, etc.
2. to demand a promise for property interest to compensate for losses or to
add to profits from us or a third party after the occurrence of a relevant
loss, etc.
3. to demand, or causing a third party to demand, property interest tocompensate for losses or to add to profits from us or a third party after theoccurrence of a relevant loss, etc.
29. to perform any other acts determined by the Company to be inappropriate.
2. In cases where the Company determines that any act of the Registered User falls or is
likely to fall under any of the items of Article 8.1, the Company may, at its sole discretion,
delete all or part of such information transmitted by the Registered User, suspend orcancel the account of the Registered User or, in addition to the process specified in Article
6.4, confiscate money or Crypto Assets owned by the Registered User without any priornotice to such Registered User. In such case, the Company shall not be obligated toreturn any documents, etc., received from the Registered User. The Company is not
responsible for any damages incurred by the Registered User as a result of any action
taken by the Company pursuant to Article 8.2.
3. The Company is not responsible for any damages incurred by the Registered User in theevent that the Registered User performs any of the acts outlined in Article 8.1. In theevent that the Registered User performs any of the acts outlined in Article 8.1, any
damages incurred by the Company are the responsibility of the Registered User.

Article 9 Discontinuation or Suspension of the Service
1. In the event of any of the following circumstances, the Company shall reserve the right topermanently discontinue or temporarily suspend all or part of the use of the Service for11all or some users without prior notice to the Registered User:
1. When the Company conducts scheduled or unscheduled inspections ormaintenance of the computer systems relating to the Service;
2. When a computer or telecommunications network ceases to operate or function asa result of an accident;
3. When the operation of the Service becomes difficult due to fire, power failure,natural disaster, war, political change, strikes, changes in laws or regulations,etc., sudden changes in the state of fiat or Crypto Assets or any other cause offorce majeure;
4. When the Company’s assets or assets under the Company’s custody are stolen byhacking or other methods;
5. When troubles occur in the pricing system or any other system necessary for theprovision of the Service;
6. When the Company inspects for unauthorized use, violations of the Terms, etc.;
7. When the Company determines that it is necessary to conduct investigations
based on laws or government regulations, internal regulations by industry
organizations to which the Company or the Registered User belongs, or theCompany's internal rules;
8. When the Company determines or suspects that any money or Crypto Assets in
the Registered User's account is related to profits gained through crime;
9. When the liquidity of a Crypto Asset significantly declines;
10. When the Company decides to cease handling of a Crypto Asset or other related
services in whole or in part based on the results of a hard fork that causes a chain
split or changes to a Crypto Asset, etc;
11. When the Company deems that provision of the Service cannot continue due tochanges in laws, policy, social conditions, etc.; or
12. When for, any other reason, the Company determines that the discontinuation orsuspension is necessary.
2. The Company may, at its own discretion, terminate the provision of the Service. In thiscase, the Company shall give prior notice to the Registered User.
3. The Company may terminate the provision of the Service depending on the inventory
status of the Crypto Asset of the Company without any prior notice to the RegisteredUser.
4. The Company is not responsible for any damages incurred by the Registered User as aresult of any action taken by the Company in accordance with this Article.

Article 10 Warning for Downloading, etc.
In cases where at the commencement of or during the use of the Service the Registered User
installs software or programs from the Website into their computers by way of downloading orother means, the Registered User shall exercise due care in order to prevent the loss or alterationof the information held by it, or any fault or damage to their equipment. The Company shall not
be responsible or liable for such loss or damage incurred by the Registered User.

Article 11 Ownership and Intellectual Property Rights
1. All ownership rights and Intellectual Property Rights in and to the Service and theWebsite shall vest in the Company or its licensors, and the use of the Service permitted
through the registration under the Terms shall not be construed as granting any licensewith respect to the Website or the Service under any Intellectual Property Rights held by
the Company or its licensors. The Registered User shall not, for any reason, perform any
act which would infringe any Intellectual Property Rights of the Company or its licensors,
including, without limitation, disassembling, decompiling, or reverse engineering.
2. The Registered Users shall grant to the Company the non-exclusive, sublicensable androyalty-free license to copy, reproduce, modify or otherwise use in all forms the texts,
graphics, videos and other data uploaded or transmitted in the Website or the Service by

12the Registered User.

Article 12 Account Cancellation
1. The Company may temporarily suspend the use of the Service by the Registered User orcancel the registration of the Registered User without any prior notice if:

2.

3.

4.
5.

1. the Registered User violates any provision of the Terms or the Company
determines that there is such a risk;
2. the Registration Information is found to contain false information;
3. the Registered User uses or attempts to use the Service for such purposes or insuch a manner as would cause damage to the Company, other Registered Usersor other third parties, or the Company determines that there is such a possibility
based on inquiries, reports or statements, etc. from public agencies, selfregulatory organizations, and/or other third parties;
4. the Registered User interferes with the operation of the Service by any means;
5. payment by the Registered User is suspended, or the Registered User becomesinsolvent, or an application for a proceeding for bankruptcy, civil rehabilitation,
corporate reorganization, special liquidation, or other similar proceedings isinstituted with respect to the Registered User;
6. the Registered User is penalized for dishonoring a check or promissory note,
whether self-issued or underwritten, or if the Registered User faces a suspensionof transactions and/or other equivalent penalty at a clearing house;
7. a petition is filed against the Registered User for seizure, provisional seizure,
temporary injunction, judicial enforcement or a forced auction;
8. necessary payments, fees, etc. are not paid by the date specified by the Company;
9. the Registered User becomes subject to the procedures for tax delinquency;
10. the Registered User dies;
11. assistance, curatorship, or guardianship has been or will be commenced for theRegistered User by a family court trial, or voluntary guardianship has been or
will be commenced through the appointment of a voluntary guardianshipsupervisor by a family court trial, and the Company deems that it is difficult for
the Registered User to continue the use of the Service;
12. the Registered User has not used the Service for a period of three (3) months or
more, and has not responded to any communication from the Company;
13. the Registered User does not respond to any inquiries (unless an appropriate
reason can be given) from the Company regarding Registered Information or useof the Service;
14. the Registered User falls under any of items of Article 3.5 or the Company
determines that there is a risk that the Registered Users falls under them;
15. the Registered User communicates with the Company or the Company’s
employees through means of telephone, fax, email, messenger or othercommunication tools in an overbearing manner, or uses direct violence, excessive
slander, threats, or other conduct commonly held as inappropriate;
16. the Company is required or requested to do so by public agencies, self-regulatoryorganizations, etc.; or
17. the Company determines for any reason that the continuation of the registrationof the Registered User would be inappropriate.
In cases where the Registered User falls under any of items of Article 12.1, any and allmonetary debt of the Registered User to the Company shall become forthwith due andpayable, and the Registered User shall immediately pay such monetary debt.
The Company shall not be responsible or liable for any damage incurred by theRegistered User as a result of any action taken by the Company in accordance with theprovisions of this Article.
The Registered User may cancel their registration as a Registered User by notifying theCompany in accordance with the procedures specified by the Company.
In the event of any of the events detailed in Clause 1, or in the event of a cancellation ofregistration, the Company may, without prior notice to or consent of the Registered User,

13

sell or otherwise dispose of all or part of the crypto assets in the Registered User's
account at the Registered User's own calculation and at the Company’s discretion, andsettle the remaining open interest in Over-the-counter Derivatives of Crypto Asset
Transactions that are conducted by depositing margin. Any costs incurred in this caseshall be borne by the Registered User.
6. When canceling the Registered User’s account, if the Registered User has insufficient
funds or other liabilities, the Registered User must pay immediately. If the RegisteredUser’s bank account is registered and approved, and the amount in the Registered User’s
account has a balance that exceeds the withdrawal fees, the amount of money will bewithdrawn from the Registered User’s registered bank account less the corresponding
withdrawal fees.
7. Regardless of Article 12.5 and 12.6, if the money, Crypto Assets, etc., held by theRegistered User is used for transferring profits gained through criminal activity, related
to criminal actions, or under suspicion of connection to criminal activity, the Company
will not return the corresponding Registered User’s money, Crypto Assets, etc., andconfiscation or other necessary measures pursuant to Article 8.2 shall be enforced.
8. In the event that a Registered User must fulfill an obligation to the Company due to thearrival of a deadline, forfeiture of the benefit of a deadline, or any other reason, theCompany may set off the obligation against the Registered User's claim and any otherclaims related to the transaction at any time without prior notice to the Registered User,
regardless of the deadline for such claim. In such cases, the offsetting shall be handled inaccordance with the provisions of Article 6.
9. If a Registered User fails to perform the corresponding Registered User’s obligations to
the Company by the time limit specified by the Company. The Company may, without
notice, demand, etc., and without following legal procedures, dispose of the collateralpledged by the Registered User to the Company at the Company’s option on the accountof the Registered User, and appropriate the amount remaining after deducting various
expenses from the acquisition thereof to the payment of the obligation, regardless of thelegal order. If there is any remaining debt as a result of such appropriation, thecorresponding debt shall be repaid immediately.
10. In the event that a Registered User fails to fulfill the corresponding Registered User’s
obligations to the Company in connection with transactions with the Company, theCompany may dispose of the Registered User's margin in the Company's possession, andall such cases shall be handled in accordance with the preceding clause.
11. If a Registered User fails to perform the corresponding Registered User’s obligations to
the Company in connection with the transaction, the Company may, at the Company's
request, charge the Registered User a late payment fee from the day following the due
date until the day of performance. The provisions of Article 6 shall apply to thecalculation method of the late payment charge.

Article 13 Disclaimer and Limitation of Liability
1. The Company makes no warranty and does not assume any liability, including, without
limitation, warranty against defects with respect to the sale or purchase of Crypto Assets,
over-the-counter Derivatives of Crypto Asset Transactions, other related services, or thevalue, function, stability, availability and usage of Crypto Assets. Except as expressly
provided for in the Terms, the Company makes no other warranties to the RegisteredUser even in cases where the Registered User has acquired from the Company, directly or
indirectly, any information concerning the Service or other Registered Users.
2. The Company provides services for the purchase and sale of crypto assets, services toprovide a venue for trading crypto assets among Registered Users, and services for theCompany to respond to Registered Users' Over-the-counter Derivatives of Crypto Asset
Transactions on a relative basis, and is not obligated to fulfill Registered Users' orders.
Therefore, even if a Registered User's order is not executed, or a sales contract between
Registered Users or between a Registered User and the Company is invalid, canceled,terminated, or any other event that prevents the execution or validity of the contract, theCompany shall not be responsible for compensating the Registered User for any damages
incurred.The Company is not responsible if, as a result of an input error and/or other14

such actions by the Registered User; the breakdown or failure of transmission and/or
system equipment of the Registered User, the Company, or a third party; a system error
or other issues in operational status; a natural disaster; a cyberattack; or any othercause, the Company suspends or restricts all or part of the Service, the Registered User's
orders becomes invalid, an unintentional execution results or no execution is made,execution of the Registered User's order is delayed, or an unintentional order is executed.
The Registered User assumes responsibility when using the Service and the Company's
website.
3. The Registered User shall investigate at their own expense and responsibility todetermine whether or not their use of the Service will violate any law or regulation
applicable to the Registered User or the internal rules of the entity of which theRegistered User is a member, and the Company makes no warranty that the use of theService by the Registered User will comply with the laws and regulations applicable to
the Registered User and the internal rules of the entity of which the Registered User is amember.
4. The Registered User shall, with their full responsibility, treat and resolve alltransactions, communications, disputes, etc. in connection with the Service or theWebsite which arise between the Registered User and other Registered Users or otherthird parties, and the Company is not responsible for these actions.
5. The Registered User is deemed to have consented that a transaction may not complete as
intended due to the type of order, market conditions, or other factors. The Company
waives all liability for damages sustained by a Registered User or any third party
through the results of a transaction.
6. The Company is not responsible for any damages incurred due to the suspension,
discontinuation, unavailability or modification of the Service caused by the Company,
deletion or loss of any message or information from the Registered User, cancellation of
the registration of the Registered User, loss of data or failure of or damage to equipment
through the use of the Service, or any other damage incurred by the Registered User inconnection with the Service.
7. Even if the Website contains links to and from other websites on the Internet, theCompany is not responsible for any websites other than the Website or any information
obtained therefrom.
8. The Company shall be able to arbitrarily carry out regulations or restrictions ontransactions in the interest of laws, cabinet orders, regulations, ordinances, government
directives, official notices, bylaws, guidelines or other rules (collectively, the “Law”),
security, or to prevent/investigate irregular/illegal transactions, etc., and the Company is
not responsible for any losses or damages caused directly or indirectly by doing so.
9. If the Company rationally decides for any reason, such as system anomaly, that thedisplayed price is an error or abnormal value (for example, it significantly diverges fromprevailing market prices or is based on unfair price formation) the offer price can beinvalidated and the Registered User's agreement based on the displayed price can becancelled. The Company is not responsible for any directly or indirectly resulting loss ordamages.
10. The Company shall not be responsible or liable for any damage incurred by theRegistered User caused by future amendments of the Law regarding Crypto Assets orover-the-counter Derivatives of Crypto Asset Transactions or future amendments ofapplicable taxation systems including the same for consumption tax.
11. If future amendments of the Law regarding Crypto Assets and over-the-counter
Derivatives of Crypto Asset Transactions or applicable taxation systems including thesame for consumption tax has a retroactive effect, the Company shall not be responsible
for any damages incurred by the Registered User caused by any such retroactive effect.

Article 14 Resolution of Disputes and Indemnity
1. The Registered User shall indemnify and hold harmless the Company from and against
any damage incurred by the Company as a result of any breach by the Registered User ofany provision of the Terms or resulting in connection with the use by the Registered Userof the Service.

15

2. The Company is not responsible for damages incurred by the Registered User inconnection with the Service.
3. The exemptions to responsibility of the Company for damages including Article 14.2 shallbe effective only to the extent permitted by the Consumer Contract Act and otherapplicable laws and ordinances. Additionally, in the event that the Company can not be
exempt from responsibility for damages under the Consumer Contract Law or otherapplicable laws and ordinances, unless there was willful or gross negligence on the
Company’s part, the Company is only responsible for an amount equal to the total
amount of the actual fees incurred in using the Service during one month before thecause of the damage has occurred.

Article 15 Confidentiality
1. For the purposes of the Terms, “Confidential Information” refers to any and all
information related to technology, business, operation, finance, organization, etc. of theCompany which may be provided or disclosed by the Company to, or come to theknowledge of, the Registered User in connection with the Terms or the Service in writing,orally or in storage media, etc., but excluding information (1) which is generally available
to the public or known to the Registered User at the time when the information isprovided or disclosed by the Company to or comes to the knowledge of the RegisteredUser; (2) which becomes publicly known through publication or otherwise without fault of
the Registered User after the information is provided or disclosed by the Company to orcomes to the knowledge of the Registered User; (3) which the Registered User has
lawfully acquired without any obligation of confidentiality from a third party authorized
to provide or disclose the information; (4) which the Registered User has developed
independently of the Confidential Information, or (5) which is confirmed by the Company
in writing to be excluded from the obligation of confidentiality.
2. The Registered User shall use the Confidential Information of the Company solely for the
purpose of using the Service hereunder, and shall not provide, disclose or divulge theConfidential Information of the Company to any third party without the Company’s priorwritten consent.
3. Notwithstanding the provision of Article 15.2, the Registered User may disclose theConfidential Information of the Company when such disclosure is required by law or by
an order, requirement or request of a court or governmental authority; provided,
however, that such order, requirement or request shall be promptly notified to theCompany by the Registered User.
4. At any time upon request of the Company, the Registered User shall promptly return to
the Company or destroy the Confidential Information of the Company and the documents
or other storage media containing or including the Confidential Information along withall reproductions thereof in accordance with the instructions of the Company.

Article 16 Effective Term
The Service Agreement shall become effective on the date of the completion of the registration
pursuant to Article 3 in respect of the Registered User, and remain in force and effect between
the Company and the Registered User until the termination of the registration during theprovision of the Service.

Article 17 Amendment and Changes to Terms, etc.
1. The Company reserves the right to make amendments or changes to the contents of theService without restriction.
2. The Company reserves the right to make amendments or changes to the Terms(including, without limitation, the rules and regulations concerning the Service which
may be posted on the Website; the same shall apply hereinafter in this Article). In theevent of any amendment or change to the Terms, the Company shall notify theRegistered User of the Terms being amended and/or changed, the details of theamendments and/or changes to the Terms, a before and after comparison of the16amendments and/or changes, and the date of enactment for the amendments and/orchanges. If the Registered User uses the Service, or fails to take steps to cancel theregistration within the time specified by the Company after the notice set forth above, theRegistered User shall be deemed to have agreed to such amendments and changes madeto the Terms.
3. If any modification of the Terms of Use restricts the existing rights of Registered Users or
imposes new obligations on Registered Users, the company shall notify Registered Usersof such modification at a time determined by the Company before the modification takes
effect, and the Company may request that Registered Users agree to the modification
notwithstanding the preceding subclause. In such a case, the Registered User shall bedeemed to have consented to the changes. In such cases, if a Registered User does notagree to the changes within the period of time specified by the Company, the Company
may restrict the Registered User's use of the Service.

Article 18 Notice
1. Any inquiries with respect to the Service or other communications or notices from theRegistered Users to the Company, or the notices concerning any amendment to theTerms or other communications or notices from the Company to the Registered User shallbe made in accordance with the procedures specified by the Company.
2. Pursuant to Article 18.1, when the Company sends reports to customers by email or
publication on the Website, the report is effective as of the time that the email was sent
and/or published on the Website. When the Company sends a notification by mail to thecustomer’s home address or office, the notification is effective at the time that the mailwas sent.
3. In the event that any notices do not reach the customer or arrive late due to a change inthe customer’s address, absence, or any reason that can not be attributed to theCompany, the notices will be considered to have arrived at the originally anticipatedtime.
4. Cancellation of Registered Users shall be made in accordance with the Terms.

Article 19 Assignment of Terms
1. The Registered User shall not assign, transfer, grant security interests on or otherwise
dispose of their status under the Service Agreement or rights or obligations under theTerms without the prior written consent of the Company.
2. In cases where the Company has assigned business regarding the Service to a third
party, the Company may, as part of such assignment of business, assign to the thirdparty assignee all or part of its status under the Service Agreement, its rights andobligations under the Terms, and the Registration Information and other information
relating to the Registered User, and the Registered User hereby agrees to suchassignment in advance. For the purposes of this Article, the assignment of businessreferred to above shall include, in addition to the usual form of assignment of business,
split of the Company or any other form of restructuring of the Company which would
result in a transfer of the business.

Article 20 Severability
If any provision of the Terms or part thereof is held to be invalid or unenforceable under theConsumer Contract Law of Japan or other laws or regulations, the remaining provisions hereof
shall remain in full force and effect, and the Company and the Registered User shall endeavor toagree to an amendment thereof to the extent necessary to make such invalid or unenforceable
provision or part thereof legally operative in order to achieve the same purpose and same legal
and economic effect as originally contemplated by such invalid or unenforceable provision or part
thereof.

Article 21 Survival of Provisions

17

The provisions of Articles 5.2, 6 (to the extent that the Fee is unpaid), 8.2, 9.4, 10, 11, 12.2, 12.3,
5 through 7, 13 through 15, and 19 through 22 shall survive the expiration or termination of theTerms and remain in full force and effect; provide, however, that Article 15 shall survive only forthree (3) years from the expiration or termination of the Terms.

Article 22 Governing Law and Jurisdiction
The Terms shall be governed by the laws of Japan. Any and all disputes arising out of or inconnection with the Terms shall be submitted to the exclusive jurisdiction of the Tokyo District
Court in the first instance.

Article 23 Resolution Through Discussion
Any matters not provided for in the Terms or those giving rise to any doubts with respect to theinterpretation of the Terms shall be promptly resolved through good faith discussions between
the Company and the Registered User.
[Enacted on April 26, 2014][Amended on August 25, 2015][Amended on November 6, 2017][Amended on December 19, 2018][Amended on May 28, 2019][Amended on February 26, 2020][Amended on April 20, 2020][Amended on November 10, 2021][Amended on March 28, 2022][Amended on October 1, 2022][Amended on July 27, 2023][Amended on March 15, 2024]18