Draft notice. This document is a current working draft and is undergoing professional legal review. Some details (registered entity, governing-law forum, regulatory licensing) are placeholders pending lawyer sign-off. We will publish the final version before any material change to your agreement.

Terms of Service

Bitblock Markets

Last revised: 2026-06-28 (DRAFT — pending legal review)

Notice. This document is a working draft prepared for legal review. It is not yet in force. Please consult your engaged counsel before publishing.

1. Acceptance of these Terms

By creating an account on, or otherwise accessing, the Bitblock Markets investment platform (the "Platform"), operated by Bitblock Markets [legal entity name], a company registered in the United Arab Emirates under registration number [number] ("Bitblock Markets", "we", "us", or "our"), you ("Client", "you") agree to be bound by these Terms of Service ("Terms"). If you do not accept these Terms in full, you must not access or use the Platform.

These Terms should be read together with our Privacy Policy and the Investor Agreement you execute prior to your first deposit. In the event of conflict, the Investor Agreement prevails as to the commercial terms of your investment, and these Terms prevail as to platform use.

2. About Bitblock Markets

Bitblock Markets is an asset-management firm headquartered in Dubai, United Arab Emirates, with a regional operating office in Nairobi, Kenya. We provide structured investment products to qualifying individuals through the Platform. Our services include:

Account opening and identity verification
Acceptance of cryptocurrency deposits in supported assets
Discretionary capital allocation across asset classes (foreign exchange, cryptocurrency, equities, indices, commodities)
Monthly profit distributions under a fixed twelve (12)-month engagement term
A referral programme that compensates existing Clients for introducing new investors

Regulatory licensing details, where applicable, will be displayed on our website and updated as our authorisations are issued.

3. Eligibility

To open and maintain an account on the Platform you must:

Be at least eighteen (18) years of age and have full legal capacity in your home jurisdiction
Not be a citizen or resident of any jurisdiction subject to comprehensive international sanctions (including but not limited to those imposed by the United Nations, the United Arab Emirates, the United States Office of Foreign Assets Control, the European Union, or the United Kingdom)
Not be a U.S. Person within the meaning of Regulation S of the U.S. Securities Act of 1933, unless explicitly accepted by us in writing
Have full legal authority to enter into binding agreements
Successfully complete our identity-verification (KYC) and source-of-funds review process

We reserve the right to refuse service, suspend an account, or terminate an Investor Agreement at our sole discretion where we reasonably believe it is necessary to do so for compliance, regulatory, security, or reputational reasons.

4. Account registration and security

When you register an account you agree to:

Provide accurate, current and complete information about yourself and update it promptly should it change
Use a strong password and keep your credentials confidential
Enable two-factor authentication where available
Notify us immediately at notices@bitblockmarkets.com if you suspect any unauthorised access to your account

You are responsible for all activity that occurs under your account. We are not liable for losses arising from compromised credentials where the compromise resulted from your act or omission, including but not limited to sharing your password or failing to enable two-factor authentication.

5. Identity verification (KYC) and anti-money laundering

In compliance with applicable anti-money-laundering ("AML") and counter-terrorist-financing laws of the United Arab Emirates, the Republic of Kenya, and other jurisdictions where we operate, you agree to:

Submit a current government-issued identity document (national ID or passport), proof of address, and a recent selfie photograph
Provide additional information or supporting documents at our reasonable request, including in relation to source of funds
Re-verify periodically as required by law or our internal compliance procedures
Promptly notify us of any change to your residency, nationality, or politically-exposed-person status

We may freeze, suspend, or terminate your account where we are unable to verify your identity or where you fail to respond to compliance enquiries. We may also report transactions to the appropriate regulator, financial-intelligence unit or law-enforcement body where we are required to do so.

6. The Investor Agreement

Investment on the Platform is governed by a separate written Investor Agreement that you and Bitblock Markets execute prior to your first deposit. The Investor Agreement sets out, among other things:

Your investment amount in United States Dollars and the Kenyan Shilling equivalent
The twelve (12)-month engagement term and the schedule of monthly distributions
The firm's structured monthly return target of ten percent (10%) of invested capital, which is not a guarantee (see Section 12)
The cadence of payouts (anniversary of activation, plus one (1) business day, with month-end fallback)
The return of principal together with the twelfth and final monthly distribution
The conditions under which the Investor Agreement may be renewed or terminated, including the early-termination provisions in clauses 4 and 5 of the Investor Agreement

These Terms supplement, and do not replace, the Investor Agreement.

7. Deposits

Investments are funded by cryptocurrency deposits in USDT, USDC, BTC, or ETH on the networks supported on the Platform. The exact pay amount, including network fees and processor service fees, is disclosed on the deposit screen prior to address generation. You agree that:

You will send only the asset and on the network specified by the Platform for that deposit. Funds sent to an incorrect address or via an unsupported network may be permanently lost and we accept no responsibility for such losses.
Deposit addresses are valid for the time period displayed on the Platform. We may extend or refresh the validity period at our discretion.
Once received and confirmed on chain, deposited funds are custodied by Bitblock Markets on your behalf during the engagement term.
Bitblock Markets is not a bank and your deposit is not a bank deposit. Your funds are not protected by any deposit-insurance scheme.

You are responsible for the security of any wallet or exchange from which you initiate a deposit.

8. Distributions and withdrawals

Monthly distributions are made according to the schedule set out in your Investor Agreement and are paid to the payout method you nominate in your account settings (cryptocurrency, M-Pesa, or bank transfer). You agree to:

Keep your payout details current and accurate
Re-verify a change to your payout method using your account password
Accept that distributions may be delayed by up to forty-eight (48) hours from the scheduled date where additional verification or compliance review is required

Your principal is returned together with the twelfth and final monthly distribution. Where you have elected to terminate the Investor Agreement before the end of its term, distributions are governed by the termination provisions in clauses 4 and 5 of that agreement (see Section 10 below).

9. Referral programme

Every registered Client receives a six-character referral code, which they may share with prospective new investors. When a person you refer (a "Referred Investor"):

opens an account on the Platform using your code,
completes KYC and signs an Investor Agreement,
funds the agreement, and
their contract becomes active,

you earn a one-time direct bonus of five percent (5%) of the Referred Investor's initial investment, credited instantly to your referral balance. You also earn an ongoing monthly profit-share bonus of ten percent (10%) of each monthly distribution received by the Referred Investor for the duration of their twelve (12)-month engagement.

Referral earnings may be withdrawn from your referral balance at any time, subject to a 24-48 hour processing window and any KYC re-verification we reasonably require.

Termination of your own Investor Agreement — whether by you or by Bitblock Markets — immediately ends your right to accrue further referral bonuses, including from any Referred Investors who continue to be active on the Platform. Amounts credited before the termination remain available to withdraw.

We may amend or suspend the referral programme at any time. Material changes will be communicated under Section 18.

10. Termination of the Investor Agreement

Either party may terminate an Investor Agreement by giving the other party one (1) month's written notice through the Platform.

Where the Client terminates within the first three (3) months of the engagement, an early-termination penalty equal to thirty percent (30%) of the initial capital applies, as set out in clause 5 of the Investor Agreement. After three months, no penalty applies.
Where Bitblock Markets terminates, no early-termination penalty applies regardless of the date of termination. The Client receives full return of principal together with any unpaid earnings due during the notice period.

All due amounts, including earned profits in accordance with the Investor Agreement, are disbursed to the Client at the end of the notice period.

11. Suspension of service

We may suspend your access to the Platform, freeze your account, or terminate the Investor Agreement immediately without notice where we reasonably believe that you have:

Materially breached these Terms or the Investor Agreement
Engaged in fraudulent, abusive, or illegal conduct
Provided false or misleading identity information
Acted in a way that poses a regulatory, security, or reputational risk to the firm

We will use commercially reasonable efforts to notify you of the action and its reason as soon as it is appropriate to do so. Where the suspension is later determined not to be justified, your account will be reinstated and any directly resulting losses borne to the extent required by applicable law.

12. Risk disclosure

You acknowledge and accept the following statements before investing on the Platform:

Investing carries risk. The value of investments can fluctuate and you may receive less than the amount originally invested. You should not invest more than you can afford to lose.
The 10% monthly target is not a guarantee. It represents the firm's discretionary trading objective for the strategies you allocate to. Actual returns depend on market conditions, the disciplined execution of those strategies, and other factors outside the firm's control. Past performance is not indicative of future results.
Bitblock Markets is not a bank. Your investment is not a deposit and is not protected by any deposit-insurance or similar scheme.
Cryptocurrency risk. Cryptocurrency deposits are subject to network risk, exchange-rate volatility, and irreversible-transaction risk. Sending funds to an incorrect address, on an unsupported network, or to a sanctioned counterparty may result in permanent loss for which we are not responsible.
Tax responsibility. You are responsible for assessing and discharging any tax liability arising from your participation on the Platform in your home jurisdiction. Bitblock Markets does not provide tax advice.
Regulatory risk. The regulatory environment for digital assets and alternative investment products is evolving in both the United Arab Emirates and the Republic of Kenya. We may be required to change the structure, availability, or terms of our products at short notice in response to regulatory developments.

13. Prohibited uses

You must not, and must not permit any other person on your behalf to:

Use the Platform to launder money, finance terrorism, or otherwise breach any AML, sanctions or counter-terrorist-financing law in any relevant jurisdiction
Provide false, misleading, or impersonated identity information
Attempt to access another Client's account or any non-public part of the Platform's infrastructure
Use automated means (scrapers, bots, scripts) to interact with the Platform other than as expressly permitted in writing
Misrepresent the Platform's products in public communications or social media in a way that is misleading or that creates the impression of an endorsement we have not given
Resell, sublicense, or otherwise commercialise access to the Platform without our prior written agreement

14. Intellectual property

All trademarks, logos, software, copy, page layouts and other intellectual property displayed on the Platform are owned by, or licensed to, Bitblock Markets. Nothing in these Terms grants you any right, title or interest in such intellectual property except for the limited, non-exclusive, non-transferable, revocable right to access and use the Platform for its intended purpose.

You retain ownership of any content you upload, but grant us a worldwide, royalty-free licence to host, process and display such content to the extent strictly necessary to operate the Platform and meet our regulatory obligations.

15. Disclaimers

The Platform is provided "as is" and "as available". To the maximum extent permitted by applicable law, we disclaim all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, accuracy, and non-infringement. We do not warrant that the Platform will be uninterrupted, error-free, secure against every conceivable attack, or free of viruses or other harmful components.

Information displayed on the Platform — including market commentary, weekly reports, and projected returns — is provided for informational purposes only and does not constitute investment advice or a recommendation.

16. Limitation of liability

To the maximum extent permitted by applicable law, in no event shall Bitblock Markets, its officers, directors, employees, partners, suppliers, or affiliates be liable for any indirect, incidental, special, consequential, punitive, or exemplary damages — including but not limited to loss of profits, data, goodwill, or other intangible losses — arising out of or in connection with your use of the Platform.

Our aggregate liability to you for any direct losses arising under these Terms shall not exceed the amount of your initial investment less any distributions you have received before the date the liability arose.

Nothing in this Section excludes or limits liability for fraud, fraudulent misrepresentation, gross negligence, death or personal injury caused by negligence, or any other liability that cannot lawfully be excluded.

17. Indemnification

You agree to indemnify and hold harmless Bitblock Markets, its officers, directors, employees, and affiliates from any claim, demand, loss, liability, or expense (including reasonable legal fees) arising out of or in connection with:

Your breach of these Terms or the Investor Agreement
Your violation of any applicable law or regulation
Your infringement of any third-party right (including intellectual-property, privacy, or contract rights)
Any inaccurate or misleading information you have provided to us

18. Modifications to these Terms

We may amend these Terms from time to time. Material changes will be notified to you by email and via in-platform notification at least thirty (30) days before they take effect. Non-material changes (typographical corrections, clarifications, contact-detail updates) may be made without advance notice.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the amended Terms. If you do not accept the amended Terms, your sole remedy is to terminate your Investor Agreement in accordance with Section 10.

19. Governing law and dispute resolution

These Terms are governed by the laws of the United Arab Emirates [Dubai International Financial Centre / Abu Dhabi Global Market / mainland — to be confirmed by counsel], without giving effect to conflicts-of-law principles.

Any dispute, controversy or claim arising out of or relating to these Terms, the Platform, or the Investor Agreement shall first be addressed through good-faith negotiations between the parties. If the dispute is not resolved within fifteen (15) business days, it shall be referred to and finally resolved by binding arbitration administered by the [DIFC-LCIA / Dubai International Arbitration Centre / appropriate centre — to be confirmed], seated in Dubai, conducted in the English language, in accordance with the prevailing arbitration rules of the chosen centre. The arbitration award shall be final and binding on the parties.

Where required by mandatory consumer-protection legislation in the Client's country of residence (including but not limited to the Republic of Kenya), the Client may invoke local statutory dispute-resolution mechanisms as an alternative.

20. Force majeure

Neither party is liable for failure or delay in performance to the extent caused by acts of war, civil disturbance, natural disaster, pandemic, labour strike, governmental action, regulatory order, internet or banking infrastructure failure, or any other event beyond the affected party's reasonable control. The affected party will use commercially reasonable efforts to resume performance as soon as practicable and will notify the other party in writing of the event.

21. Notices

Notices to Bitblock Markets under these Terms shall be sent to notices@bitblockmarkets.com, with a copy to our registered office at [Dubai address — to be confirmed]. Notices to you will be sent to the email address registered on your account and delivered as in-platform notifications.

22. Severability

If any provision of these Terms is held by a court or arbitrator of competent jurisdiction to be invalid, illegal, or unenforceable, that provision shall be deemed severed from these Terms and the remaining provisions shall continue in full force and effect.

23. Assignment

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign or transfer our rights and obligations to a successor in interest or to an affiliate without your consent, provided the assignee agrees to be bound by these Terms.

24. Entire agreement

These Terms, together with the Investor Agreement and the Privacy Policy, constitute the entire agreement between you and Bitblock Markets with respect to the Platform and supersede all prior or contemporaneous agreements, understandings, and communications, whether written or oral.

25. Contact

Questions about these Terms?

Bitblock Markets

Email: notices@bitblockmarkets.com

Registered office: [Dubai address — to be confirmed]

Regional office (Kenya): [Nairobi address — to be confirmed]

By accessing the Platform, you confirm that you have read, understood, and agree to be bound by these Terms.