NO-SOLICITATION - LEGAL NOTICE

THIS LEGAL NOTICE INFORMS YOU OF WHERE WE PROVIDE OUR SERVICES FROM, WHO OUR REGULATOR IS, WHAT PERMISSIONS WE HAVE IN PLACE TO SERVE OUR CUSTOMERS, THE ENTITIES THROUGH WHICH WE SERVE OUR CUSTOMERS AND THE BASIS AND LIMITATIONS ON WHICH WE PROVIDE OUR SERVICES.

YOU ARE REQUIRED TO READ AND ACCEPT THE CONTENT OF THIS LEGAL NOTICE WHENEVER IT APPEARS TO YOU. BY ACCEPTING THE CONTENT OF THIS LEGAL NOTICE YOU WILL BE CONFIRMING THAT YOU HAVE FULLY READ AND UNDERSTOOD ITS CONTENT AND ALL OF ITS LEGAL IMPLICATIONS.

YOU SHOULD NOT AGREE TO ACCEPT THE CONTENT OF THIS LEGAL NOTICE OR PROCEED WITH REQUESTING OUR SERVICES IF YOU HAVE ANY DOUBT OR DO NOT FULLY UNDERSTAND THIS LEGAL NOTICE OR ANY PART OF IT. WHERE YOU HAVE ANY DOUBT YOU MUST NOT CONTINUE ANY FURTHER

1. ABOUT US

1.1We serve our customers from Gibraltar through three regulated entities:

a) Xapo Bank Limited (“Xapo Bank”), a company incorporated and registered under the laws of Gibraltar with Company No. 111928; and

b) Xapo VASP Limited (“Xapo VASP”), a company registered and incorporated in Gibraltar with company No. 118088.

c) Xapo Credit Limited ("Xapo Credit"), a company registered and incorporated in Gibraltar with company No. 124075

1.2The registered office of all entities is 2 Irish Town, Gibraltar, GX11 1AA.

1.3Our place of business is Xapo HQ, One Grand Casemates Square, Gibraltar, GX11 1AA.

1.4Our fiat services are provided by Xapo Bank and our crypto services are provided by Xapo VASP.

2. OUR REGULATOR AND PERMISSIONS

2.1Both Xapo Bank and Xapo VASP are regulated by theGibraltar Financial Services Commission(“GFSC”).

2.2Xapo Bank is regulated under the Financial Services Act 2019 as a ‘credit institution’ underPermission No. 23171.

2.3Xapo VASP Limited is regulated under the Financial Services Act 2019 as a ‘DLT institution’ underPermission No. 26061.

3. DEPOSIT PROTECTION

3.1Deposits held with Xapo Bank are covered by theGibraltar Deposit Guarantee Scheme(“GDGS”).

3.2Eligible depositors are covered up to GBP 120,000.00 per depositor, irrespective of the number of accounts or the currencies (if applicable) these are held in at the bank that has failed.

3.3The GDGS does not regulate us or other banks, this is carried out by the GFSC. The GFSC is the Competent Authority and has been appointed as the Resolution Authority. The Financial Services Resolution and Compensation Committee (“FSRCC”) is the designated authority, who administers the GDGS. Only the GFSC, as the regulator, or the Courts can decide if a bank is unable to repay its deposits. The GDGS cannot make this decision.

3.4For more information about the GDGS, including amounts covered and eligibility, you can visitGDGS website. You can find out more on our GDGSDepositor Information Sheet.

4. NO-SOLICITATION

4.1Our website and other publicly available material and information on our services is provided for information purposes only and does not constitute a recommendation, offer or solicitation to enter into any contract or agreement with us for our services.

4.2You acknowledge that your arrival to and use of our website and any of our mobile applications and other platforms and any requests on your part for information or to obtain our services are wholly unsolicited and are made entirely out of your own initiative without any prior direct communication from us.

5. CHANGES TO OUR PRODUCT AND SERVICES

5.1 You acknowledge and accept that the products and services we offer may evolve over time after you have opened an account with us. This may include the introduction of new products and services aligned with the general concepts of our business offering, as well as updates or enhancements to our existing offerings.

5.2 We may inform you of such changes to ensure you are aware of updates or new features. These communications are provided for information purposes only and should not be interpreted as direct solicitations or invitations from us to use or engage with the updates or new products.

5.3 Your further acknowledge and accept that your use of our services at all times is wholly unsolicited and entirely out of your own initiative despite any such communication from us.

5.4 You accept and acknowledge that you will receive these communications unless you have expressly opted out, except when we are obliged to inform you by our regulators or applicable law.

6. RESTRICTED ACCESS

6.1The information contained in our website and other publicly available material is not directed at you if Xapo is prohibited by any law of any jurisdiction from making such information available to you and is not intended for any use that would be contrary to local law or regulation.

6.2None of the services referred to in our website and other publicly available material are available in any jurisdiction where such activity is prohibited.Persons who are resident outside Gibraltar should consult their professional advisers or local regulator to satisfy themselves of local regulatory requirements.

6.3In particular, no offer or invitation is made to any US persons (being residents of the United States of America or partnerships or corporations organised under the laws of the United States of America or any state, territory or possession thereof), who are excluded from the services offered by us.

7. CONTACTING US

If you have any questions, issues, or complaints, you can always contact our Customer Support team via our website. Unless otherwise stated our FAQs do not form part of any agreement between us and shall not affect the content or interpretation of this Legal Notice.

8. WHICH LAWS APPLY?

8.1This Legal Notice, our services and any dispute or claim (including non-contractual disputes or claims) arising from this Legal Notice and our services are governed by and construed in accordance with Gibraltar Law.

8.2The courts of Gibraltar shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this Legal Notice or its subject matter or formation and our services.