Ciphering Terms of Service

Effective Date: June 6, 2026

Operator: These Terms of Service ("Terms") are entered into between you ("User", "you", or "your") and Relay ("Relay", "we", "us", or "our"), the company operating the Ciphering platform.

Last Updated: June 6, 2026

1. Acceptance of Terms

By accessing, browsing, or using the Ciphering website, web application, mobile application (including via Capacitor/iOS), AI agent ("Cipher AI"), or any related services (collectively, the "Platform" or "Services"), you agree to be bound by these Terms, our Privacy Policy, and any additional terms that may apply to specific features.

If you do not agree to these Terms, do not use the Platform.

2. Description of the Platform

Ciphering is a non-custodial crypto trading interface and AI-powered assistant focused primarily on the Base blockchain and Ethereum-compatible networks.

Key characteristics:

• Non-custodial by design: You retain full control of your private keys and digital assets at all times. We do not hold, custody, or control your funds, wallets, or private keys.
• Self-custody execution: All on-chain transactions (swaps, approvals, etc.) are constructed on your device or through the interface and must be explicitly signed by you in your own wallet (e.g., MetaMask or other injected wallets).
• AI Assistant ("Cipher AI"): An AI agent powered by models such as Grok (xAI) that can provide market analysis, trade ideas, risk commentary, previews, and tool-assisted suggestions. The AI does not execute trades on your behalf without your explicit confirmation and wallet signature.
• Paper Trading & Live Modes: The Platform offers simulated ("paper") trading and, in certain gated configurations, the ability to execute real on-chain transactions via decentralized protocols (e.g., Uniswap V3 on Base).
• Beta / Experimental Nature: The Platform is in active development. Features, including live execution paths, AI capabilities, and market data, may be incomplete, inaccurate, or change without notice.

Important: Ciphering is not a centralized exchange, broker-dealer, custodian, or investment advisor in its current non-custodial form. Future versions of the product may be offered under different regulatory licenses (see Launch Plan documentation).

3. Eligibility

You may only use the Platform if you:

• Are at least 18 years of age (or the age of majority in your jurisdiction).
• Have full legal capacity and authority to enter into these Terms.
• Are not located in, or a resident of, any jurisdiction where use of the Platform is prohibited or restricted (including but not limited to sanctioned jurisdictions under OFAC, UN, EU, or UK sanctions lists).
• Are not on any sanctions list (OFAC SDN, EU, UK, etc.).
• Understand and accept the high risks associated with cryptocurrency trading and decentralized finance.
• Comply with all applicable laws in your jurisdiction, including tax, securities, and anti-money laundering obligations.

Relay reserves the right to restrict or terminate access for any user at its sole discretion, including for compliance or risk reasons.

4. Your Responsibilities and Acknowledgments

You are solely responsible for:

• The security of your wallet(s), seed phrases, private keys, and devices.
• Reviewing and understanding every transaction before signing it in your wallet.
• All on-chain activity initiated from your connected wallet(s).
• Paying any applicable gas fees, network fees, and taxes arising from your activity.
• Conducting your own research ("DYOR") before making any trading decisions.
• Ensuring that any use of the AI agent or trade previews complies with your personal risk tolerance and local regulations.

You acknowledge that:

• Cryptocurrency trading involves substantial risk of loss, including the potential loss of all capital.
• Smart contract interactions carry technical risks (bugs, exploits, front-running, slippage, failed transactions).
• Market data, quotes, and AI outputs may be delayed, inaccurate, or incomplete.
• Past performance is not indicative of future results.

5. AI Agent and Tool Use — Specific Disclaimers

The Cipher AI agent is a tool, not a financial advisor, portfolio manager, or fiduciary.

• All outputs from the AI (including trade ideas, risk assessments, previews, and recommendations) are for informational and educational purposes only.
• The AI may hallucinate, provide incorrect data, or suggest unsuitable actions.
• We do not guarantee the accuracy, completeness, or suitability of any AI-generated content.
• You, and you alone, are responsible for any trading decisions you make, whether or not they were suggested or previewed by the AI.
• The AI never has authority to move your funds or sign transactions on your behalf.
• Use of voice features (including ElevenLabs integration) does not change these disclaimers.

Never treat AI suggestions as personalized investment advice or a substitute for professional financial, legal, or tax advice.

6. Live On-Chain Trading (When Enabled)

When live trading features are enabled (subject to environment flags, kill switches, and eligibility):

• You are executing real transactions on public blockchains using decentralized protocols (e.g., Uniswap V3, Aerodrome, or other DEXs).
• These transactions are irreversible once confirmed on-chain.
• We may provide previews, route suggestions, or risk warnings, but final responsibility for reviewing all parameters (amounts, slippage, gas, recipient address, etc.) rests with you.
• Certain pairs or features may be restricted or disabled at any time for risk, regulatory, or technical reasons.
• We do not guarantee best execution, lowest fees, or successful transaction settlement.

7. Prohibited Activities

You may not use the Platform to:

• Violate any applicable law, regulation, or sanctions (including money laundering, terrorist financing, fraud, or market manipulation).
• Engage in any activity that could harm the Platform, other users, or third parties.
• Attempt to reverse-engineer, decompile, or extract source code (except as permitted by applicable open-source licenses).
• Use the Platform for any purpose that would require us to be licensed as a money transmitter, broker, dealer, custodian, or investment advisor in any jurisdiction (unless and until we obtain such licenses).
• Provide false or misleading information.
• Use automated means (bots, scrapers) in ways that violate rate limits or these Terms.

8. Intellectual Property

All rights, title, and interest in and to the Platform, including but not limited to the "Ciphering" name and branding, the "Cipher AI" name and persona, the horseman logo and related marks (the "Marks"), software, designs, text, graphics, and documentation, are owned by Relay or its licensors.

You may not use the Marks without our prior written permission, except as permitted by these Terms or applicable law (e.g., nominative fair use).

See the separate Trademark Notice for additional information.

The software components of this project are licensed under the MIT License (see the LICENSE file in the repository).

9. Third-Party Services and Content

The Platform integrates with or relies on various third-party services, including but not limited to:

• Blockchain networks (Base, Ethereum, etc.) and decentralized protocols (Uniswap, Aerodrome, etc.).
• Wallet providers (MetaMask and other injected wallets).
• AI model providers (xAI / Grok).
• Voice synthesis (ElevenLabs).
• Hosting and serverless infrastructure (Netlify).
• Market data providers, indexers, and analytics tools.
• Open-source libraries (ethers.js, lightweight-charts, Zustand, Capacitor, etc.).

We do not control and are not responsible for the availability, accuracy, security, or practices of these third parties. Your use of third-party services is subject to their own terms and privacy policies.

10. No Financial, Legal, or Tax Advice

Nothing on the Platform, in the AI agent outputs, in documentation, or in communications from us constitutes:

• Financial, investment, trading, or portfolio management advice.
• Legal, tax, regulatory, or compliance advice.
• An offer to buy, sell, or hold any digital asset.
• A recommendation regarding any specific transaction or strategy.

You should consult qualified professionals licensed in your jurisdiction before making any financial or trading decisions.

11. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, RELAY, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AND LICENSORS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, LOSS OF DATA, LOSS OF ASSETS, TRADING LOSSES, OR ANY OTHER DAMAGES ARISING OUT OF OR RELATED TO:

• Your use of or inability to use the Platform.
• Any AI-generated content or trade suggestions.
• Any transaction you sign or fail to sign.
• Smart contract risks, blockchain network issues, or third-party service failures.
• Any security incident affecting your wallet or devices.

IN NO EVENT SHALL OUR TOTAL LIABILITY EXCEED THE AMOUNT YOU PAID TO US (IF ANY) IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM, OR USD $100, WHICHEVER IS GREATER.

Some jurisdictions do not allow the exclusion or limitation of certain liabilities. In such cases, the limitations above shall apply to the maximum extent permitted.

12. Indemnification

You agree to indemnify, defend, and hold harmless Relay and its affiliates from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

• Your use of the Platform.
• Any transaction you initiate.
• Your violation of these Terms or applicable law.
• Any content or information you provide.

13. Beta, Modifications, and Availability

The Platform is provided on an "as is" and "as available" basis. We make no warranties regarding uptime, accuracy, or fitness for any particular purpose.

We may modify, suspend, or discontinue any part of the Platform at any time, with or without notice, including disabling live trading features via kill switches or configuration.

14. Termination

We may terminate or suspend your access to the Platform at any time, with or without cause or notice, including for suspected violations of these Terms or legal requirements.

Upon termination, your right to use the Platform ceases immediately. Provisions that by their nature should survive (including disclaimers, limitations of liability, and indemnification) shall survive termination.

15. Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of Denmark, without regard to its conflict of law principles.

Any dispute arising out of or in connection with these Terms or the Platform shall be subject to the exclusive jurisdiction of the competent courts of Denmark, or such other venue as Relay may designate.

You agree that any dispute will be resolved on an individual basis and that you waive any right to participate in a class action or collective proceeding against us.

Notwithstanding the above, nothing in these Terms prevents Relay from seeking injunctive or other equitable relief in any court of competent jurisdiction.

You are responsible for complying with the laws of the jurisdiction in which you reside or from which you access the Platform.

16. Regulatory Status and Future Licensing

The current non-custodial interface is offered as a software tool and information service. It is not a licensed exchange, broker, or custodian.

Relay is a Danish-registered company (CVR: 31961424). As part of its future roadmap, Relay is exploring regulated pathways and potential licensing in additional jurisdictions, including the United Arab Emirates (for example, under VARA for virtual asset activities). Any future regulated services will be offered under the appropriate licensed entity and subject to additional terms, disclosures, and user onboarding requirements (KYC, etc.).

Until such licensing is obtained and announced, users should treat the Platform as an unauthorized, experimental, non-custodial interface.

17. Changes to These Terms

We may update these Terms from time to time. The "Last Updated" date at the top will reflect the most recent changes. Material changes will be communicated via the Platform, email (if you have provided one), or other reasonable means.

Your continued use of the Platform after changes become effective constitutes acceptance of the updated Terms.

18. Contact Information

For questions about these Terms, please contact:

Relay

ceo@ciphering.io

Relay

19. Miscellaneous

• These Terms constitute the entire agreement between you and Relay concerning the Platform.
• If any provision is found unenforceable, the remaining provisions will remain in full force.
• Our failure to enforce any right or provision does not constitute a waiver.
• You may not assign these Terms without our prior written consent.

DISCLAIMER: These Terms are provided as a template based on the current non-custodial nature of the Ciphering Platform. They are not legal advice. Before deploying to production or accepting real user activity (especially live on-chain trading or users in regulated jurisdictions), Relay must have these Terms reviewed and customized by qualified legal counsel in Denmark and any other relevant jurisdictions.

Trade responsibly. You can lose money. Not financial advice.