Specific Terms and Conditions of the Crypto-Asset Custody and Administration Service

Venga provides the Custody and administration Service of Crypto-assets on behalf of the Users. The Custody Service comprises the safeguarding, control, and administration of the Crypto-assets on behalf of the Users, including the safekeeping of the Crypto-assets and their means of access, such as private cryptographic keys, in omnibus distributed ledger addresses controlled by Venga.

1. Venga provides the Custody Service directly, without delegating the custody activity to other crypto-asset service providers, through a hybrid model of hot custody (hot wallet) and cold custody (cold wallet). Venga will maintain a significant percentage of the Users' Crypto-assets in cold custody, limiting the exposure of Crypto-assets in hot custody to what is strictly necessary for daily operations and the fulfillment of withdrawal requests. For operational purposes, technological solutions from specialized third-party providers will be used. Under no circumstances shall such providers hold possession, control, or unilateral access to the Crypto-assets or private keys of the Users.
2. Regarding the custody of Crypto-assets, individualized distributed ledger addresses are not used for each User. Venga is the sole and exclusive holder of the private cryptographic keys that provide access to the Users' Crypto-assets. Users shall not have access to the private keys of the distributed ledger addresses that control and protect the custody-held Crypto-assets. Private keys shall never be accessible in their entirety by any individual, neither by Venga nor by the technological providers, always remaining fragmented and encrypted in secure environments. Each private key is divided into several fragments. Each fragment is stored in a distributed cloud infrastructure, ensuring that the data is not only logically segregated but also protected through physical dispersion against infrastructure failures.
3. Users' Crypto-assets shall be kept separate from Venga's own property, both legally and functionally, in accordance with Article 75, paragraph 7, of the Regulation. To this end, Venga will use omnibus addresses, wallets, or digital wallets distinct from its own, and internal records that will reflect at all times, in an individualized and permanent manner, the balance of each User regarding each type of custody-held Crypto-asset, in their respective Venga Account (as this term is defined in the General Terms). Venga guarantees that, on the distributed ledger, Users' Crypto-assets will be kept separate from Venga's own Crypto-assets, and that Venga's creditors will not be able to assert any right over the custody-held Crypto-assets, including in the event of Venga's insolvency.
4. The User acknowledges and accepts that the User's Crypto-assets held in custody by Venga may be aggregated in omnibus addresses, digital wallets, or wallets together with those of other Users, but always separate from Venga's own Crypto-assets and identified in an individualized manner, with respect to each User, in Venga's internal records, without this affecting, therefore, compliance with the segregation requirements provided for in Article 75.7 of the MiCA Regulation.
5. Venga shall not hold powers of disposal or rights of use over the Users' Crypto-assets, except for the execution of instructions given by them, compliance with legal or regulatory obligations, or in the cases expressly provided for in these Specific Conditions or in any contractual documents signed between Venga and the User. Under no circumstances shall Venga use the Users' Crypto-asset balances for its own operations.
6. The User shall not hold any property right over the specific Crypto-assets deposited with Venga, but rather a property right over an equivalent quantity of Crypto-assets of the same type and quantity as those deposited, according to the balance reflected in the individual position registry maintained by Venga at any given time (the Venga Account). Ownership of the Crypto-assets shall correspond at all times to the User, who shall assume the risk of fluctuation of their market value.

1. Venga has established a custody policy that includes internal rules and procedures to guarantee the safekeeping and control of the custody-held Crypto-assets and their means of access, in accordance with Article 75, paragraph 3, of the Regulation. Said custody policy minimizes the risk of loss of Users' Crypto-assets, or of the rights related to such Crypto-assets, or of their means of access, due to fraud, cyber threats, or negligence.
2. Venga has prepared a summary of its Crypto-asset custody policy, which is available on its website and in the Application. The summary of the custody policy includes information regarding the protection measures for Crypto-assets, access methods, and security systems implemented by Venga.

1. Venga shall maintain a registry of open positions in the name of each User, reflected in the Venga Account, corresponding to the rights of each User over the custody-held Crypto-assets. Buy, sell, and transfer operations of Crypto-assets carried out by the User shall be recorded sequentially in said individual position registry. Every movement made following the User's instructions shall be recorded as soon as possible in the registry, and Venga's internal procedures shall guarantee that every movement affecting the registration of Crypto-assets is reflected in an operation duly recorded in the User's position registry.
2. Venga shall provide the User through their Venga Account, at least once every three (3) months, or when requested by the User, a statement of position of the Crypto-assets registered in their name. Said statement of position shall be provided in a durable electronic format and shall identify the balance of the Venga Account, the Crypto-assets in question, their value, and the buy and sell orders executed and canceled, and the Crypto-asset transfers carried out during the period under consideration. Additionally, Venga shall provide the User as soon as possible with any information regarding operations with Crypto-assets that require a response from the User.
3. The User may check the balance of their Venga Account through the Application. Venga shall inform through the corresponding channels of any relevant change in the custody processes or in the regulatory framework that may affect the User's Crypto-assets.

1. Venga shall facilitate for the User, when applicable, the exercise of the rights inherent to the custody-held Crypto-assets, in accordance with Article 75, paragraph 4, of the Regulation. Every event that may create or modify the rights of the User shall be immediately recorded in the User's position registry. This shall include, where applicable, participation in forks ("forks"), airdrops, network upgrades, or other events that may affect the rights or nature of the Crypto-assets.
2. When changes occur in the underlying distributed ledger technology or any other event that may create or modify the rights of the User, the User shall be entitled to any Crypto-asset or any newly created right on the basis of the User's positions and in a manner proportionate to them, at the time such change or event occurs, unless these Specific Conditions, accepted prior to such change or event, expressly provide otherwise.
3. Notwithstanding, the User acknowledges that the allocation of Crypto-assets derived from forks, airdrops, or other similar events may not be automatic. When the technical nature of the event requires Venga to take active actions to claim, receive, or consolidate the new Crypto-assets on the corresponding distributed ledger network, such actions shall be executed with the greatest possible diligence and promptness, prioritizing in any case the security of the User's assets.
4. Venga shall communicate to the User, through the Application, the occurrence of any event described in the preceding paragraph and the update of their position within a maximum period of twenty-four hours following the update of the registry. Said communication shall include, at a minimum: a description of the event occurred in understandable terms, the date and time of the event, the type and quantity of new Crypto-assets or rights allocated, the updated balance of the User's position, the instructions to dispose of the new assets, and a point of contact for inquiries.
5. When technical circumstances concur that prevent the normal execution of the procedure described in the preceding paragraphs, such as network unavailability, the impossibility of claiming the new Crypto-assets, failure in the registration systems, or any other material incident, Venga shall adopt the necessary provisional measures to preserve the User's rights, which may include the temporary suspension of provisions regarding the affected Crypto-assets. In such cases, Venga shall communicate the situation and the estimated resolution timeframe to the User.
6. When the claim for new Crypto-assets requires interaction with third-party smart contracts or the downloading of additional software, and Venga considers that the technical risks are deemed unacceptable, Venga shall inform the User of the temporary impossibility of making the new Crypto-assets available to them and of the available alternatives, including the possibility of withdrawing their Crypto-assets to an external wallet to exercise such rights autonomously.
7. The User acknowledges that, from the Custody Service, it may not be possible to directly perform certain actions for the exercise of rights linked to the stored Crypto-assets, such as the exercise of voting rights associated with consensus mechanisms of decentralized autonomous organizations (DAOs) or participation in native staking features. In such cases, the User retains the freedom to withdraw their Crypto-assets at any time to exercise these rights autonomously.

Venga implements technical and organizational security measures for the custody of Crypto-assets, including: (a) Technical security measures in relation to hot and cold storage, including the use of antivirus software, firewalls, disk encryption, and cryptographic key encryption; (b) Software and hardware security measures, such as specialized wallet management software and hardware security modules (HSMs); (c) Network security measures, such as firewalls, network isolation, and IP restrictions; (d) Organizational measures, such as change management, key management with multi-signature (multisig) schemes, and employee background checks; (e) Two-factor authentication (2FA) for User operations, via SMS, email, or authentication applications; (f) Advanced and constant monitoring of Users' Crypto-asset balances and periodic balance verification controls to ensure accuracy and detect possible discrepancies.

1. The use of the Custody Service is subject to the payment of the fees, expenses, and charges that Venga establishes at any given time. The fees applicable to the Custody Service shall be communicated to the User through the Application and Venga's website and are subject to the provisions of the General Terms and Conditions of Service.
2. The User agrees to pay fully and punctually all fees, expenses, and charges applicable to the Custody Service.

1. Venga does not own or control the underlying software protocols that govern the distributed ledger of the Crypto-assets. Venga is not responsible for the functioning of the underlying protocols nor does it guarantee the functionality or security of network operations. In particular, underlying protocols may be subject to sudden changes in operating rules (including forks). These changes may significantly affect the availability, value, or functionality of accepted crypto assets.
2. The Crypto-assets accepted by Venga for the Custody Service are subject to the technical limitations of each protocol. Venga reserves the right to limit the operations of certain Crypto-assets and to expand or reduce the list of accepted Crypto-assets.
3. Within the Custody Service, no type of Crypto-asset that incorporates an anonymization function preventing the identification of the Crypto-asset holders and their transaction history shall be accepted.