Compliance & Risk Disclosures

AMADEUS Wallet is operated by AMADEUS CASTELLUM AG (registered office: Thurn-und-Taxis-Platz 6, 60313 Frankfurt am Main, Germany), a company incorporated in the Federal Republic of Germany. AMADEUS provides non-custodial crypto-asset services in alignment with:

• Regulation (EU) 2023/1114 on Markets in Crypto-Assets ("MiCA").
• Directive (EU) 2015/849 and successors ("AMLD"), transposed in Germany by the Money Laundering Act (Geldwäschegesetz, GwG).
• Regulation (EU) 2023/1113 on Transfers of Funds and Certain Crypto-Assets ("Travel Rule").
• Regulation (EU) 2016/679 ("GDPR").
• The German Banking Act (KWG) where applicable.

AMADEUS is not a bank, an investment firm, or a licensed exchange. The application is a software interface to public blockchain networks. Where regulated services (e.g. fiat on-ramp) are offered, they are provided by third-party licensed institutions clearly identified within the app.

Warning. Crypto-assets are highly volatile, largely unregulated financial instruments. Their value can rise or fall sharply and can drop to zero. You may lose all of the funds you allocate to crypto-assets. Past performance is not a reliable indicator of future performance. You should not invest more than you can afford to lose.

• Market risk — extreme price volatility, illiquidity, and possible market manipulation.
• Technology risk — protocol bugs, smart-contract vulnerabilities, chain reorganisations, forks, and consensus failures.
• Custody risk — the wallet is non-custodial: loss or disclosure of your seed phrase results in irreversible loss of your funds.
• Counterparty risk — third-party issuers (e.g. stablecoin issuers, staking protocols, on-ramp providers) may fail, freeze redemptions, or become insolvent.
• Transaction risk — on-chain transactions are irreversible. An incorrect address, network, or amount cannot be undone.
• Regulatory risk — the legal treatment of crypto-assets may change, potentially restricting your ability to trade, transfer, or hold specific assets.
• Cyber-security risk — phishing, malware, SIM-swap and social-engineering attacks target crypto users.
• Liquidity risk — some assets may be difficult to sell or swap at a fair price at any given time.
• Tax risk — crypto transactions may generate taxable events in your jurisdiction. You are solely responsible for tax reporting.

Nothing displayed in AMADEUS constitutes investment, financial, tax, legal, or accounting advice, nor a solicitation, recommendation, or offer to buy or sell any crypto-asset. Prices, charts, news feeds, watchlists, ratings, and third-party analyses are provided for informational purposes only. You should consult an independent, qualified professional before making any investment decision.

AMADEUS is not available and must not be used by residents or nationals of, or persons located in, jurisdictions where the Service or the underlying crypto-assets are prohibited or subject to international sanctions, including but not limited to:

• Countries and persons on the consolidated EU sanctions list.
• Countries and persons on the U.S. OFAC SDN list.
• Countries and persons on the UN Security Council sanctions lists.
• Any jurisdiction that has expressly banned the trading, holding, or transfer of the relevant crypto-asset.

Certain features (e.g. staking, leveraged products, fiat on-ramp) may be further restricted depending on your country of residence. Screening is performed at onboarding and continuously during your use of the Service.

As a regulated obliged entity under GwG, AMADEUS applies risk-based customer due diligence:

• Identity verification (ID document + liveness check) at onboarding for services above the non-KYC threshold.
• Enhanced due diligence for higher-risk customers and transactions.
• Continuous transaction monitoring, blockchain analytics, and sanctions/PEP screening.
• Filing of Suspicious Activity Reports (SARs) with the German Financial Intelligence Unit (FIU) where legally required.
• Compliance with the Travel Rule for transfers above the applicable threshold, including collection and transmission of originator and beneficiary information.

Records are retained for 10 years from the end of the business relationship, in accordance with GwG § 8.

The AMADEUS Wallet is non-custodial. Your seed phrase and private keys are generated and encrypted locally on your device. AMADEUS never stores, transmits, or has access to your seed phrase or private keys and cannot recover them if lost. You are the sole custodian of your funds and bear full responsibility for the safekeeping of your credentials.

The Service may integrate third-party providers (blockchains, oracles, KYC vendors, fiat on-ramps, staking protocols, dApps). AMADEUS does not endorse and is not responsible for the acts, omissions, security, or availability of third-party services. Your interaction with any third-party protocol is at your own risk and subject to that party's terms.

All marketing and promotional communications from AMADEUS follow these principles:

• Communications are fair, clear, and not misleading, as required by MiCA Article 66.
• No promise of guaranteed returns, "risk-free" investments, or protection against losses.
• A prominent risk warning is included in every promotional communication that references specific crypto-assets.
• Historical performance data is presented with the disclaimer that past performance is not indicative of future results.
• Marketing to retail customers respects local advertising rules (e.g. UK FCA financial promotion regime, Spanish CNMV requirements, French AMF regime) and is not distributed in jurisdictions where restricted.
• Email, push, and SMS marketing require prior opt-in consent and include a clear unsubscribe mechanism.
• Influencer and affiliate partners must disclose the commercial nature of their communications and comply with our Marketing Code of Conduct.

Complaints may be submitted to complaints@amadeus-wallet.com. We acknowledge complaints within 5 business days and provide a substantive response within 15 business days, extendable to 35 business days in complex cases with an interim update. If you are dissatisfied with our final response, you may refer the matter to the competent German supervisory authority.

AMADEUS maintains a Conflicts of Interest Policy. We do not engage in proprietary trading against our users. Fee arrangements with liquidity providers, on-ramp partners, and staking protocols are disclosed within the app before you confirm a transaction.

Technical and organisational measures include AES-256 encryption at rest, TLS 1.3 in transit, Hardware Security Modules (HSM) for internal key management, 24/7 SIEM monitoring, annual independent penetration testing, and a documented incident response and business continuity plan. See our Security Overview.

You are solely responsible for determining and reporting any tax obligations arising from your use of the Service. AMADEUS may provide export tools (CSV, PDF statements) but does not provide tax advice.

AMADEUS CASTELLUM AG
Thurn-und-Taxis-Platz 6, 60313 Frankfurt am Main, Germany
Compliance: compliance@amadeus-wallet.com
MLRO / AML: mlro@amadeus-wallet.com
Legal: legal@amadeus-wallet.com