Terms of Service

Last updated: March 2026

1. Scope of Services

Clavestra Orbital GmbH (“Clavestra,” “we,” “us”) provides federated digital asset custody services to verified business-to-business (B2B) clients. Our services include the secure storage, transfer, and withdrawal of Bitcoin and stablecoins through a multi-guardian federation using threshold cryptography.

Clavestra does not provide investment advice, lending services, exchange services, or retail consumer accounts.

2. Eligibility

Our services are available exclusively to:

  • ✓ Licensed financial service providers
  • ✓ Registered payment processors
  • ✓ Regulated fintech companies
  • ✓ Institutional clients meeting our KYC/AML requirements

All clients must complete our onboarding process, including identity verification, beneficial ownership disclosure, and source of funds documentation before accessing custody services.

3. Client Obligations

By using our services, you agree to:

  • ◆ Provide accurate and complete information during onboarding and maintain up-to-date records
  • ◆ Comply with all applicable laws and regulations in your jurisdiction
  • ◆ Not use our services for money laundering, terrorist financing, sanctions evasion, or any unlawful purpose
  • ◆ Maintain the security of your API credentials and access keys
  • ◆ Notify us immediately of any unauthorized access or security breach

4. Custody Model

Client assets are held in a federated custody model with the following characteristics:

  • ◆ Assets are distributed across multiple independent guardians in different jurisdictions
  • ◆ A threshold of guardians (e.g., 7 of 10) must approve any transaction
  • ◆ No single guardian, including Clavestra, can unilaterally access or move client funds
  • ◆ Client assets are segregated from company operating funds at all times

5. Fees

Fees for custody services are set out in individual client agreements. Fee categories include:

Custody fees: Periodic fees for secure storage of client assets

Transaction fees: Per-transaction fees for deposits and withdrawals

Conversion spread: Applied when clients convert between different digital asset types

All fees are disclosed in writing prior to service activation. We reserve the right to update fee schedules with 30 days written notice.

6. Limitation of Liability

Clavestra shall not be liable for:

  • ◆ Fluctuations in the value of digital assets held in custody
  • ◆ Loss of stablecoin peg by third-party issuers (e.g., Tether, Circle)
  • ◆ Service disruptions caused by force majeure events
  • ◆ Regulatory actions by third-party jurisdictions beyond our control
  • ◆ Losses resulting from client failure to secure their own API credentials

7. Suspension & Termination

We reserve the right to suspend or terminate client access to our services if:

  • ◆ The client fails to meet ongoing KYC/AML requirements
  • ◆ Suspicious activity is detected and cannot be resolved
  • ◆ The client breaches these terms of service
  • ◆ Required by law, regulation, or court order

Upon termination, clients will be provided a reasonable period to withdraw their assets, subject to any legal holds or regulatory requirements.

8. Governing Law

These terms are governed by the laws of Switzerland. Any disputes shall be subject to the exclusive jurisdiction of the courts of Lugano, Canton of Ticino, Switzerland.

9. Amendments

We may update these terms from time to time. Clients will be notified of material changes at least 30 days in advance. Continued use of our services after such notice constitutes acceptance of the updated terms.

10. Contact

For questions about these terms, contact us at:

legal@clavestra.ch