Effective date: October 28, 2025
These Terms and Conditions supplement Coinmetro’s General Terms of Service (the “Terms”, available: https://www.coinmetro.com/terms-of-use) and apply specifically to the “Bundles” product (hereinafter also the “Product”). In case of conflict, these Terms and Conditions prevail for the Product. All capitalised terms have the meaning given in the Terms unless stated otherwise.
1. General
1.1 The “Bundles” product is offered by Coinmetro OÜ, an Estonian company (registry number 14448371), with its principal office at Tartu mnt 84a‑203, Tallinn 10112, Estonia (“Coinmetro”).
1.2 “Bundles” allows Users to purchase and hold predefined bundles of crypto-assets according to thematic or market‑capitalisation groupings (e.g. Top 5, asset-type etc), via a simplified, one‑click interface.
1.3 By using the Product, the User accepts and agrees to these Terms and Conditions, the Terms, and Coinmetro’s Privacy Policy.
2. Product Description & Bundling Mechanics
2.1 Each Bundle is a predefined combination of crypto-assets, selected and weighted by an objective, rules‑based methodology (e.g. based on relative market capitalisation). The specifics of the methodology will be made available via the Product interface.
2.2 Users submit a single order (“Bundle Order”) to buy (or sell) the constituent assets in proportion to that methodology.
2.3 The constituent assets are held directly in the User’s account, not in a pooled or collective vehicle.
3. Rebalancing & Maintenance
3.1 Bundles are rebalanced at scheduled intervals of 30 days from initial purchase to restore the original target weights. The User can make additional purchases or sell part of their Bundle at any time, in which case the Bundle is rebalanced at that time. After such a transaction, a new 30-day period is set for the next auto-rebalance.
3.2 Rebalancing occurs by executing the necessary trades in the underlying assets in the User’s account - sell some overweight assets, buy underweight ones - strictly following the methodology, without discretionary override by Coinmetro.
3.3 If a constituent asset is removed or added (e.g. because it no longer meets eligibility or is delisted), the next rebalance will reflect the changed list. Users will be notified via the Platform post‑rebalance of the new composition.
4. Fees & Costs
4.1 A Bundle maintenance fee (0.1% of Bundle value per rebalance period) will be applied at rebalance.
4.2 Standard trading / SWAP fees and network fees also apply pursuant to the Terms.
4.3 All fees will be shown in the ordering workflow before execution, and once the transaction is completed, are non-refundable.
4.4 For certain Bundles, trade execution spread fees or processing fees may also apply (e.g. card, conversion, network) as disclosed in product detail pages.
5. Control & Execution
5.1 Coinmetro holds no residual interest in crypto-assets in the Bundle.
5.2 All trades (bundles or rebalancing) are execution-only instructions initiated by or pre-authorised by the User - Coinmetro does not exercise portfolio management or discretion.
5.3 Orders will be executed in accordance with Coinmetro’s standard order execution practice and procedures, which aim to achieve the best possible execution in line with market conditions, unless otherwise specified.
6. Nature of the Product & No Advice
6.1 The Product is strictly execution-only - Coinmetro does not provide investment advice, personalised recommendations, or suitability assessments.
6.2 This Product is not an investment fund, not a collective investment scheme, and does not constitute portfolio management under MiFID II or MiCA (or equivalent regimes).
6.3 Performance figures, bundle metrics, and illustrative data are for informational purposes only and are not guarantees of future performance.
6.4 Coinmetro does not engage in efforts to influence the price of any crypto-asset or manipulate market outcomes.
7. Disclaimers, Risks & Regulatory Conditions
- Market Risk: The value of crypto-assets may fluctuate rapidly; Users may lose part or all of their investment.
- Third‑Party Data Reliance: The Product relies on external data (e.g. market capitalisation feeds); accuracy, timeliness, or completeness cannot be guaranteed.
- Regulatory Risk: Bundles are designed to include assets within MiCA’s crypto‑asset scope. If any constituent is later reclassified as a financial instrument, Coinmetro may suspend or delist it.
- Service Suspension / Changes: Coinmetro may amend, suspend, or discontinue the Product, or change bundle definitions, with or without notice, to comply with regulatory or operational needs.
- No Warranty / “As is”: The Product is provided “as available” and without warranties of any kind regarding fitness for purpose, uptime, or accuracy.
- Bundle Integrity: Users can buy or sell only the Bundle as a whole; individual assets within a Bundle cannot be traded separately.
- Limited Diversification: Assets within a Bundle may move in the same direction due to high market correlation; therefore, diversification benefits may be limited.
8. Indemnity & Liability
8.1 The User agrees to indemnify, defend, and hold harmless Coinmetro, its affiliates, officers, employees, agents, and service providers (the “Released Parties”) from any claims, losses, damages, liabilities, or costs (including legal fees) arising from misuse of the Product, violation of these Terms and Conditions, the Terms, or applicable law, or third‑party claims related to the User’s actions or holdings.
8.2 The Released Parties are not liable for losses due to price movements, volatility, or market events; technical failures, system downtime, or network issues; errors, delays or interruptions in data feeds; third‑party platform, network, or blockchain faults; or regulatory changes or forced delistings.
8.3 Liability Cap: Coinmetro’s total liability for any claim or series of related claims arising under these Terms and Conditions shall not exceed the greater of: (i) the total fees paid by the User for the Bundle Product in the 12 months preceding the event; or (ii) the aggregate value of crypto-assets held under Bundles by the User at the time of the event.
9. Communications, Notices & Updates
9.1 All notices under these Terms and Conditions shall be in English.
9.2 Coinmetro may deliver notices via the Platform or email to the User’s registered address. Notices are deemed received when published or successfully sent.
9.3 Coinmetro may revise or update these Bundle Terms and Conditions (or associated methodology) from time to time with or without notice. Continued use of the Product constitutes acceptance of the new terms.
10. Personal Data & Privacy
10.1 Processing of personal data under this Product is governed by the Coinmetro Privacy Policy (available: https://www.coinmetro.com/privacy-policy).
10.2 By using the Product, the User consents to data processing, disclosures, record keeping, and communications necessary for the Product and compliance.
11. Assignment & Legal Relationship
11.1 Coinmetro may assign or transfer its rights or obligations under these Terms and Conditions (or portions thereof) to affiliates or successors without User consent.
11.2 Nothing in these Terms and Conditions shall create or imply a partnership, joint venture, fiduciary, agency, or advisory relationship between Coinmetro and the User.
12. Governing Law & Dispute Resolution
12.1 These Terms and Conditions and any disputes arising hereunder are governed by the laws of the Republic of Estonia.
12.2 Any unresolved dispute shall be submitted to the exclusive jurisdiction of the courts of Estonia.
13. Severability
If any provision of these Terms and Conditions is held invalid or unenforceable, that provision will be severed, and the remainder shall continue in full force and effect.
14. Acknowledgement
By using the Bundles product, the User expressly acknowledges and agrees that:
- the Product is execution-only, not advisory;
- the User bears all risks of market volatility;
- these Terms and Conditions operate together with the Terms and Privacy Policy.