APPENDIX: Information on Transfer Services

Version: 1.0, Last updated: 10.07.2025 

What You Should Know Before Using Crypto-Asset Transfers with Smart Valor 

This summary highlights the key information clients should understand before initiating a crypto-asset transfer using Smart Valor’s platform. It supports transparency, compliance, and your informed decision-making. 

Fees You May Incur 

Smart Valor charges a flat withdrawal fee per asset. The exact amount is shown before you confirm any transfer. You can find the complete fee list here.

Note: Blockchain network fees (e.g., Ethereum gas fees, Bitcoin miner fees) are not shown and may apply depending on network conditions. 

Important: Transfers Are Irreversible 

Once your transaction is submitted to the blockchain, it cannot be canceled, reversed, or refunded. 

Before confirming your transfer: 

Double-check the recipient wallet address 

Make sure the network matches the selected asset 

Remember: Transfers to unsupported or incorrect addresses may result in the permanent loss of funds 

You will see this warning before every transfer: 

“Please make sure your transaction details are correct. Blockchain technology makes this transaction impossible to refund or cancel.” 

Need Help? Contact Support 

If you have questions, technical issues, or suspect unauthorized activity, contact our support team: 

Email: support@smartvalor.com 

Live Chat: Available on smartvalor.com 

Help Center / FAQ: smartvalor.com/en/faq 

Support requests are handled securely via a dedicated customer support system and may require identity verification for sensitive matters. 

Full Terms & Procedures 

You can find detailed information about transfer rules, risks, timelines, and your rights in the full Appendix: Information of Transfer Services, starting from the next page. 

We recommend reading the full appendix before using the transfer functionality. 

APPENDIX: Information of Transfer Services 

This appendix has been developed in accordance with Article 82 of Regulation (EU) 2023/1114 (MiCAR), as well as applicable Regulatory Technical Standards (RTS 60/62) and guidance from ESMA Guideline ESMA35-1872330276-2032. 

It describes the internal procedures, ICT systems, and human resources SMART VALOR uses to ensure that crypto-asset transfers are executed securely, promptly, and with resilience against operational disruptions or cyber risks. These safeguards support SMART VALOR’s obligation to protect clients and maintain continuous service availability. 

Aim: 

The following guidelines were issued by Smart Valor AG (“Smart Valor”) with the aim of establishing coherent, efficient, and effective supervisory practices, as well as ensuring a uniform and consistent application of the provisions of Article 82 of Regulation (EU) 2023/1114 on Markets in Crypto Assets (MiCA). The purpose of this section is, in particular, to specify the regulatory requirements applicable to Smart Valor as a provider of crypto-asset services, insofar as Smart Valor offers crypto-asset transfer services on behalf of clients. The focus lies on the development, implementation, and ongoing review of effective procedures and strategies aimed at safeguarding investor interests. This includes, in particular, the protection of client rights in connection with the execution of transactions, as well as ensuring transparency, traceability, and legal compliance across all related processes. 

We would like to point out that the content of this appendix may partially overlap with the content of the Smart Valor Terms and Conditions. In the event of any inconsistency between this appendix and the general Terms and Conditions, the provisions of this appendix shall prevail with regard to crypto-asset transfer services. 

Content of the agreement in relation to transfer services: 

Transfer Service 

SMART VALOR provides secure, efficient, and transparent crypto-asset transfer services, facilitating the movement of cryptocurrencies and digital assets between client-designated wallets or addresses upon the client’s explicit instructions. 

Security System 

SMART VALOR implements layered security defenses using the following systems, but not limited to: 

Identity Provider Service (IdP) 

Provides secure, passwordless authentication for the Smart Valor platform users. Stytch enforces adaptive Multi-Factor Authentication (MFA), monitors for anomalous login patterns (e.g., IP and device fingerprint mismatches), and supports session expiration policies. All authentication events and identity anomalies are logged and reviewed in coordination with incident triage workflows. 

Web Application Firewall (WAF) 
Serves as the first line of defense for the trading platform’s web traffic. It blocks OWASP Top 10 vulnerabilities (e.g., SQL injection, XSS), rate-limits traffic during DDoS attempts, and filters automated bots. Cloudflare’s managed rulesets are regularly updated, and custom rules are implemented based on application-specific threat models.  

SAST, DAST and SCA 

SAST scans an application's static source code to find security flaws before runtime, while DAST tests the running application from an external, attacker-like perspective to identify vulnerabilities in its operational state. Complementing these, SCA analyzes all third-party and open-source components to uncover known vulnerabilities and potential licensing issues within the software supply chain. 

Fees 

Smart Valor applies following fees: 

Deposit fees - Cryptocurrency deposits are free of charge. 

Withdraw fees - Withdrawals to external wallets require specific fee amounts in order for the transaction to be processed. These fees are specially selected to ensure the fastest processing times on the blockchain. When withdrawing funds, the withdrawal form provides information on the amount of the fee. Below is a table that contains all fees for every currency clients can withdraw. 

Reference to the Applicable Law 

These Terms and Conditions shall be governed by and construed in accordance with the laws of the Principality of Liechtenstein, in particular the Liechtenstein Blockchain Act (TVTG) of 3 October 2019, as well as applicable European Union legislation, including the Markets in Crypto-Assets Regulation (MiCAR – Regulation (EU) 2023/1114) and the related technical standards issued by the European Securities and Markets Authority (ESMA). 

General Provisions on Strategies and Procedures for the Transfer of Crypto Assets 

Duty to Inform 

Smart Valor ensures that clients receive this Appendix to the Terms and Conditions promptly and in electronic format (e.g., as downloadable PDF documents) before entering into any service agreement. The Appendix includes all relevant information and terms applicable to crypto-asset transfer services, presented clearly, comprehensively, and in easily understandable language. 

The information to be disclosed to the client shall, at a minimum, include the following: 

The name of the crypto-asset service provider: Smart Valor AG 

The address of its head office: Birkenweg 6, 9490 Vaduz, Liechtenstein 

The email address: talk@smartvalor.com 

The name of the national competent authority in charge of supervising SmartValor's activities: Liechtenstein Financial Market Authority (FMA), Landstrasse 109, P.O. Box 279, 9490 Vaduz, Liechtenstein 

Additionally, the following information (Chapters 3.2 – 3.11) will be disclosed through the client information as outlined in section 3.1. 

Key Characteristics of the Crypto-Asset Transfer Services 

Smart Valor provides crypto-asset transfer services that enable users to send and receive digital assets securely and transparently via supported blockchain networks. The main features of these services include: 

3.2.1 Type of service:  

Smart Valor provides only external transfers (to blockchain-based wallet addresses not hosted by Smart Valor). The service includes wallet-to-wallet transfers on supported networks and custodial-to-non-custodial asset movements. 

3.2.2 Transaction Initiation and Execution 

Users can initiate transfer orders via the Smart Valor web platform (accessible from both desktop and mobile browsers) or mobile application. Upon initiation, transactions are verified, signed, and submitted to the blockchain for execution. Internal transfers within the platform are not allowed. External transfers are processed according to the relevant blockchain network conditions and compliance checks, including those required under the Crypto Travel Rule. 

3.2.3 Destination Address (Recipient) 

For each external transfer, users are required to provide the recipient’s wallet address. Smart Valor supports only one designated blockchain network per crypto-asset, and this network is clearly indicated in the withdrawal interface at the time of the transaction. 

Where applicable, users may also be required to enter additional information, such as a memo, destination tag, or similar identifier, to complete the transfer correctly. All such requirements, including the supported network and any additional fields, are clearly communicated to users within the withdrawal form before the transaction is initiated. Because each crypto-asset is linked to a specific blockchain, users cannot select an alternative network (e.g., switching between ERC-20, TRON, or BNB Chain). The provided withdrawal address must be fully compatible with the predefined blockchain network supported by Smart Valor for the selected asset. 

It is the user’s sole responsibility to ensure that the wallet address and any required supplementary information are accurate and network-compatible. Transfers to unsupported or incorrect addresses are not permitted and may result in the irreversible loss of funds, for which Smart Valor accepts no liability. 

3.2.4 Availability and Processing Time 

Transfer services are available 24/7, subject to scheduled maintenance or downtime notices. External transfers are typically processed within a few minutes; however, blockchain confirmation times may vary based on network congestion and the selected asset. 

3.2.5 Fees and Charges 

Applicable transfer fees include: 

Smart Valor service fees, which are fixed per asset and cover the network (gas) fees required to process the transaction on the blockchain. 

No separate blockchain network fees are charged to the client. 

A detailed fee structure is available in Chapter 2.3 Fees of this document or at: https://smartvalor.com/en/faq/withdraw-crypto?question=3. 

All fees are displayed transparently at the time of transaction. 

3.2.6 Security Measures 

SMART VALOR implements stringent Secure Customer Authentication (SCA) protocols aligned with MiCA requirements. Authentication involves multi-factor authentication (MFA), integrating at least two independent authentication factors from: 

Knowledge (password)  

Possession (smartphone-based authenticator apps, security tokens)  

Inherence (biometric identifiers such as fingerprint or facial recognition) 

Additionally, SMART VALOR employs continuous monitoring mechanisms to detect unusual login attempts, suspicious activities, and potential security breaches.  Сustomers receive email notifications for every login attempt, whether successful or not. After five unsuccessful login attempts, account access is automatically blocked, and following a password change, customer withdrawals are temporarily suspended for 72 hours, enhancing overall account security. All authentication measures are regularly audited and updated according to evolving security standards and regulatory guidance to ensure full compliance with MiCA regulations and customer security expectations. 

Smart Valor enforces industry-grade security protocols to protect transfer operations: 

Know Your Customer (KYC) and Anti-Money Laundering (AML) screening 

Two-Factor Authentication (2FA) for user logins and withdrawals 

End-to-end encryption of sensitive data and transactions 

Security features include: 

Real-time login alerts 

Automatic account lockout after five failed attempts 

72-hour withdrawal hold after password changes 

Continuous transaction monitoring and fraud detection 

All authentication and security protocols are reviewed and updated regularly to comply with evolving regulatory standards and best practices. 

3.2.7 GDPR Compliance 

SMART VALOR has implemented comprehensive technical and organizational measures to ensure the security of client data and transactions, fully complying with the General Data Protection Regulation (GDPR). 

3.2.8 Roles and Oversight Responsibilities 

SMART VALOR's crypto-asset transfer operations are supported by a clearly defined governance structure: 

The Operations Team oversees day-to-day transfer processing, withdrawal monitoring, and liquidity handling. 

The Compliance Team is responsible for AML/CTF screening, Travel Rule data validation, and regulatory reporting. 

The Engineering Team manages the technical infrastructure behind the transfer system, including connectivity to wallet infrastructure, blockchain nodes, and security controls (e.g., 2FA, WAF, SAST/DAST). 

These roles are supported by defined escalation paths and review cycles to ensure operational reliability, regulatory compliance, and risk mitigation in line with MiCAR and the Liechtenstein Blockchain Act (TVTG). 

3.2.9 Business Continuity and Cyber Resilience 

SMART VALOR maintains a Business Continuity and Disaster Recovery Plan for all core services, including crypto-asset transfers. Key elements include: 

Redundant infrastructure and fallback servers to maintain critical operations during outages; 

Real-time monitoring of blockchain connectivity, compliance API calls, and wallet operations; 

Auto-halt protocols if price feeds, AML systems, or security checks become unstable; 

Recovery time objectives (RTOs) and documented manual override procedures for severe disruptions. 

Cybersecurity protections include: 

Layered security using 2FA, biometric access, and device/session verification; 

Continuous security testing (SAST, DAST), vulnerability scans, and patch management; 

A Web Application Firewall (WAF) and bot protection provided by Cloudflare; 

Encryption of sensitive data in storage and transit. 

These measures are reviewed annually and tested as part of regular IT security audits and risk assessments in accordance with DORA, GDPR, and MiCAR Article 82. 

3.2.10 Legal Framework and Supervisory Authority 

Smart Valor’s crypto-asset transfer services are provided under the regulatory framework of the Markets in Crypto-Assets Regulation (Regulation EU 2023/1114). Smart Valor AG is regulated and supervised by the: 

Liechtenstein Financial Market Authority (FMA) 

Landstrasse 109, P.O. Box 279 

9490 Vaduz, Liechtenstein 

Website: https://www.fma-li.li 

Description of the Process and Procedure 

The initiation or authorization of a crypto-asset transfer shall be carried out through a defined and secure process within the SmartValor platform. To maintain compliance with AML regulations, only users who have successfully completed the Know Your Customer (KYC) verification process are permitted to access and use the transfer functionality. 

 Clients must follow the steps outlined below to initiate or approve a transfer: 

3.3.1 User Verification and Authentication 

Access to the transfer function is restricted to users who have fully completed the KYC process, including identity verification, as required by applicable law. 

Once verified, users must log in to the platform using their Smart Valor credentials. 

Secure login requires Two-Factor Authentication (2FA), combining password entry with a secondary verification factor (e.g., authenticator app or biometric check). 

3.3.2 Transfer Initiation 

Navigate to the “My Wallet” section of the SMART VALOR website. 

Select the desired crypto-asset. 

External transfer (to an external wallet address). 

Input the following required information: 

Transfer amount 

External wallet address  

Additional comments (not obligatory) 

Blockchain/network selection should not be done as SMART VALOR supports only one blockchain option for every currency. The supported chain is clearly communicated to users within the withdrawal form.  

3.3.3 Summary Review and Confirmation 

A transaction summary screen will display: 

Asset and amount that is being transferred 

Smart Valor fees 

Current available balance 

Balance that will be left after the transfer 

Users must review the transaction details and confirm by: 

Clicking “I confirm that I have read and confirmed information above” 

The information above includes the following warning: ‘’Please make sure your transaction details are correct. Blockchain technology makes this transaction impossible to refund or cancel.’’ 

Provide Travel Rule information about the recipient in the next step (if prompted). 

Entering their 2FA code (if prompted) 

3.3.4 Transfer Authorization and Consent 

Confirmation constitutes explicit and irrevocable consent to execute the crypto-asset transfer. 

For certain transactions (e.g., high-value, first-time address use, or flagged transfers), Smart Valor may request additional user actions: 

Email confirmation 

Enhanced due diligence 

Temporary withdrawal lock or internal escalation 

3.3.5 Execution and Blockchain Submission 

After authorization, the transfer is: 

Subject to final internal review (compliance or security check) 

Digitally signed and submitted to the appropriate blockchain 

Clients can monitor transaction status and blockchain confirmations via the ‘’Deposit’’ or “Withdrawal” section of ‘’My Wallet’’. 

3.3.6 Notifications and Records 

A confirmation email is sent to the client once the transaction has been initiated and broadcast to the blockchain. 

A detailed record of the transaction, including blockchain hash and timestamp, is available in the client account and is retained for a minimum of 10 years, in line with regulatory standards. 

Revocation of Instruction or Consent 

This section details the procedure for revoking an existing instruction or consent regarding a crypto-asset transfer. Clients must follow the steps outlined below and provide all required information to ensure the revocation is properly initiated and executed. 

Once a crypto-asset transfer instruction is submitted on the Smart Valor platform and successfully confirmed, it is generally irrevocable, due to the technical and final nature of blockchain transactions. However, in limited cases, such as for pending transactions that have not yet been broadcast to the blockchain, Smart Valor may allow the revocation of a transfer instruction, provided specific conditions are met. 

Clients who wish to revoke an instruction or consent to a transfer must adhere to the following procedure: 

3.4.1 Revocation Eligibility and Timing 

Revocation is only possible if the transaction has not yet been processed or submitted to the blockchain network. Requests must be submitted immediately after transfer initiation. Once broadcast to the blockchain, transactions are permanent and non-reversible. 

3.4.2 Submission of Revocation Request 

To request revocation, clients must: 

Contact Smart Valor Customer Support through the secure in-platform chat or via registered email (support@smartvalor.com) 

Provide the following mandatory information: 

Full name and registered email 

Amount and asset of transfer initiation 

Date and time of transfer initiation 

Reason for revocation request 

3.4.3 Authentication and Verification 

The client will be asked to verify their identity through a short video call.  

Smart Valor reserves the right to deny the revocation if the authentication process fails or if the transaction is already committed to the blockchain. 

3.4.4 Confirmation and Processing 

Once authenticated, Smart Valor will assess whether the transaction can still be halted. If revocation is possible, the transaction will be marked as cancelled, and the client will receive a written confirmation via email. If the transaction is already irreversible, the client will be informed accordingly and provided with blockchain confirmation details. 

3.4.5 Important Notice 

Smart Valor cannot guarantee the success of revocation requests for blockchain-based transfers. Clients are strongly advised to double-check all transaction details, particularly recipient wallet addresses, before confirming any transfer. 

Smart Valor is not liable for losses resulting from client errors, delayed revocation requests, or network-level finality. 

 Conditions for refusing a crypto-asset transfer instruction 

Smart Valor reserves the right to refuse the execution of any crypto-asset transfer instruction in full or in part where such action is necessary to comply with applicable laws, mitigate risks, or uphold platform integrity and user security. Transfer instructions may be declined under the following circumstances:  

3.5.1 Third-Party Transfers Are Prohibited 

Smart Valor strictly prohibits transfers to wallets or accounts not owned by the verified account holder. Transfers must only be made to external wallets beneficially owned by the client. Therefore, Smart Valor may reject any instruction where: 

There is evidence or strong suspicion that the recipient address belongs to a third party. 

The beneficial owner of the destination wallet does not match the verified identity of the client initiating the transfer. 

The user refuses or fails to provide proof of ownership for the destination wallet upon request. 

3.5.2 Transfer to High-Risk or Non-Compliant Exchanges 

Smart Valor may refuse transfer instructions directed to: 

Non-KYC or anonymous exchanges, or 

Platforms rated as “High Risk” under Smart Valor’s internal risk assessment (e.g., flagged by blockchain analytics tools such as Coinfirm, Chainalysis, or similar). 

Such transfers may expose Smart Valor to AML/CTF and reputational risk, and may conflict with obligations under MiCA, the Liechtenstein Due Diligence Act (SPG), and FATF standards. In these cases, clients may be asked to reroute the withdrawal to a personal, self-hosted wallet under their own control. 

3.5.3 Indicators of Criminal or Illicit Activity 

A transfer may also be declined if: 

The transaction is flagged by internal monitoring systems as high-risk due to suspicious volume, frequency, or counterparties. 

There is evidence or reasonable suspicion that the transaction is connected to criminal activity, including fraud, sanctions evasion, money laundering, or terrorist financing. 

The recipient address has been associated with illicit behavior or is listed on watchlists from reputable sources (e.g., law enforcement, blockchain monitoring services). 

3.5.4 Non-Compliance with Security or Regulatory Requirements 

Smart Valor may suspend or refuse transfers if: 

The client has not passed or has failed to update KYC/AML requirements. 

The transfer amount or behavior triggers enhanced due diligence and the client fails to respond or provide adequate information. 

There are technical issues or security flags, such as login anomalies or account integrity risks. 

3.5.5 Legal, Technical, or Operational Constraints 

Transfer instructions may also be refused if: 

There is a regulatory restriction or court order affecting the user’s account or the target address. 

The transaction exceeds withdrawal or compliance thresholds, and verification cannot be completed in time. 

3.5.6 Client Notification 

Where feasible, Smart Valor will notify the client of the refusal and, if legally permitted, provide the reason for the decision. In some cases, such as suspicion of criminal activity or required reporting to authorities, notification may be withheld in accordance with anti-money laundering and anti-tipping-off obligations. 

Timing Procedure and Supported DLT Networks 

3.6 1 Procedure Description and Timing: 

All crypto-asset transfer instructions on the Smart Valor platform are processed through the specific blockchain network designated for each asset (e.g., Bitcoin, Ethereum, Solana). The processing time depends not only on internal verification steps but also on the performance and characteristics of the respective blockchain. 

The official receipt time of a transfer instruction is recorded at the moment the client has completed all of the following:  

Submits a valid transfer request via the platform or mobile device, 

Confirms the transaction (e.g., by clicking "“I confirm that I have read and confirmed information above”"), 

Successfully submits the Travel Rule information, and 

Successfully passes 2-Factor Authentication (2FA). 

There is no fixed cut-off time, as transfers can be initiated 24/7. However, the following factors may delay execution: 

Transfers submitted during platform maintenance windows, 

Transfers subject to additional compliance or security review, and 

High network congestion or blockchain-specific issues 

Each supported blockchain has its own confirmation requirements and block generation speed. As a result, transfer processing times may vary depending on the selected crypto-asset. For example: 

ERC-20 tokens (Ethereum): typically processed within 30 minutes to 2 hours, depending on network congestion and gas fee priority 

Bitcoin (BTC): may take 30 minutes to 1 hour, depending on block confirmation speed 

Litecoin (LTC), Bitcoin Cash (BCH): generally faster, often completed in 15-30 minutes 

XRP, XLM, EOS, and SOL: are typically confirmed within a few minutes 

Please note that the above timeframes are estimates and may vary based on current network conditions. 

Smart Valor continuously monitors transfer activity and aims to complete all valid requests as promptly as possible, while ensuring full compliance with applicable security and regulatory requirements. 

3.6.2 Supported DLT Network(s) for Each Crypto-Asset: 

Smart Valor supports external crypto-asset transfers across multiple blockchain networks, depending on the specific asset. The following networks are currently supported: 

Bitcoin (BTC) - Bitcoin network 

Ethereum (ETH) - Ethereum network 

Bitcoin Cash (BCH) - Bitcoin Cash network 

Litecoin (LTC) - Litecoin network 

Ripple (XRP) - XRP Ledger 

Stellar (XLM) - Stellar network 

EOS (EOS) - EOS network 

Solana (SOL) - Solana network 

Cardano (ADA) - Cardano Blockchain 

Dash (DASH) - Dash Blockchain 

Polkadot (DOT) - Polkadot (native network) 

NEAR Protocol (NEAR) - NEAR (native network) 

Optimism (OP) - Optimism Layer 2 (EVM-compatible) 

Algorand (ALGO) - Algorand (native network) 

ERC-20 Tokens - Ethereum (ERC-20 standard), including: USDT, USDC, BNB (ERC-20), DAI, AAVE, UNI, VALOR, LINK, MATIC, AVAX, MANA, YFI, BAT, COMP, ENJ, ZRX, 1INCH, AXS, CRV, KNC, MKR, PAXG, RARE, SAND, SNX 

Important: Clients must ensure they provide a wallet address that matches the correct blockchain network for the selected asset. For example, ERC-20 tokens require an Ethereum-compatible address (0x…), while BTC, LTC, or SOL must be sent to their respective native network addresses. 

Providing an address on an unsupported or incorrect network may result in the irreversible loss of funds, for which Smart Valor bears no liability. 

3.6.3 Irreversibility Estimate 

Transactions on blockchain networks are irreversible once they are broadcast and included in a block. From that moment on, they are part of the distributed ledger and cannot be canceled, recalled, or reversed, regardless of the number of confirmations. 

However, if a transaction has not yet been broadcast to the network (i.e., it is still in internal processing within Smart Valor's system), there may be a brief window in which the transaction can be canceled. Once the transaction is submitted to the network, it is out of Smart Valor’s control. 

Because most blockchain networks operate under probabilistic settlement, the certainty of finality increases with each additional block confirmation. For operational and risk management purposes, Smart Valor applies internal thresholds to determine when a transfer is considered sufficiently irreversible. 

Below is an overview of the typical confirmation thresholds and expected timeframes for each supported network: 

These thresholds represent Smart Valor's internal standards for treating transactions as final. They reflect a balance between blockchain settlement certainty and practical risk mitigation. 

Maximum Execution Time 

Smart Valor will execute crypto-asset transfer instructions within a maximum period of 24 hours from the time the instruction is successfully received and authenticated, provided that all compliance and security checks are passed. 

For a full description of applicable timeframes, influencing factors, and how execution time is calculated, please refer to Chapter 4.1 Execution Times and Cut-Offs.  

Communication Methods and Technical Requirements 

The following communication channels, technical requirements, and information delivery methods are established in accordance with Article 82(1) of the Markets in Crypto-Assets Regulation (MiCA) and reflect the terms agreed upon between Smart Valor and its clients for all matters related to crypto-asset transfer services. 

3.8.1 Communication Tools and Technical Requirements: 

SMART VALOR ensures secure, efficient, and MiCA-compliant communication channels to protect customer assets, maintain data integrity, and uphold user privacy. 

The following communication methods are provided: 

FAQ Section - Customers can access a comprehensive FAQ page (https://smartvalor.com/en/faq) addressing common inquiries and troubleshooting guidelines. 

Email and Support Ticket System - Clients may contact SMART VALOR via the official support email (support@smartvalor.com). Emails are automatically converted into support tickets within Freshdesk, a dedicated helpdesk system. Support agents are assigned to tickets, with automated service-level agreements ensuring timely initial responses and resolutions. All sensitive or critical requests, such as account access issues (including two-factor authentication resets or email address changes), require the client to re-verify their account through identity verification, involving a passport and video identification via the integrated KYC system. 

Live Chat on Website - SMART VALOR provides a real-time online chat feature directly on the website. If support agents are available, inquiries are addressed promptly. If agents are offline, customers receive a corresponding notification and messages that were left in chat automatically become Freshdesk tickets, ensuring follow-up communication within SLA. 

Customer Settings Management - Customers can independently manage basic settings within their accounts, including address, password changes, two-factor authentication (2FA), and biometric access. This facilitates quick resolution of common tasks without direct support intervention. 

Investment Level Requests - For changes to investment levels, customers submit requests along with required information through the designated section on the platform. SMART VALOR receives notifications internally (via Slack), promptly reviews submitted information, and contacts customers via email. These interactions also generate corresponding Freshdesk tickets to ensure traceability and effective follow-up. 

Customer Feedback - After each resolved ticket, customers are encouraged to provide feedback on their interactions and the quality of support received, promoting continuous improvement of SMART VALOR’s customer service processes. 

Official Social Channels - SMART VALOR uses Telegram (https://t.me/smartvalor_official), Twitter (@smartvalorinc), LinkedIn (https://www.linkedin.com/company/smartvalor), and Facebook (https://www.facebook.com/smartvalorinc) exclusively for general announcements and updates. These channels do not handle sensitive or contract-specific communication, however, clients can reach out to admins or send a message. All customer communications are routed from social media to SMART VALOR's email and integrated support ticketing system, ensuring seamless tracking, timely response, and comprehensive issue resolution. 

Smart Valor provides access to its platform via secure web-based applications and native mobile applications compatible with both iOS and Android operating systems. To ensure seamless and secure usage of our services, client devices and software must meet the following technical requirements: 

Web Application: 

Devices should run the latest or recent versions of supported web browsers including Chrome, Firefox, and Safari. 

JavaScript must be enabled. 

Secure and stable internet connection (HTTPS protocol). 

Adequate antivirus and firewall protection to ensure security and data integrity. 

Mobile Applications (iOS and Android): 

Devices should run the latest or recent versions of iOS or Android operating systems, ensuring compatibility and security. 

Mobile devices must support secure network protocols and have access to stable and secure internet connectivity. 

Regular updates of the Smart Valor AG mobile application are required to maintain compliance and security standards. 

These technical requirements are established in compliance with Article 82(1) of the Markets in Crypto-assets (MiCA) Regulation to guarantee the security, operational integrity, and availability of our services to all clients. 

3.8.2 Method and Frequency of Information Provision: 

Clients will receive automatic email notifications from Smart Valor each time a crypto-asset transfer is: 

Initiated on the Smart Valor platform, and 

Successfully processed on the blockchain. 

In addition to email updates, clients may log in to their Smart Valor account at any time to access detailed information about all past and pending transfers. Each transaction is clearly labeled as: 

"Pending" - if it is still being processed or awaiting blockchain confirmation 

"Completed" - once it has been finalized and recorded on the blockchain 

Smart Valor does not issue weekly summaries; however, the transaction history and real-time status updates are always available through the user dashboard. 

3.8.3 Language(s) of the Agreement and Communication: 

The official language of the Terms and Conditions, user agreements, and all legally binding documentation provided by Smart Valor is English. 

However, customer support communication is available in both English and German. Clients may contact the Smart Valor Support Team and receive assistance in either language, depending on their preference. 

Secure Notification Procedure for Suspected or Actual Fraud and Security Threats 

Smart Valor has implemented an automated and secure notification process to promptly inform clients of any suspected or confirmed fraud, unauthorized access, or changes to sensitive account information. This process is designed to ensure rapid awareness, user verification, and incident response. 

3.9.1 What Constitutes a Security Threat or Fraudulent Activity? 

Clients will be automatically notified in cases including, but not limited to: 

Unauthorized login attempts from unrecognized devices or IP addresses 

Changes to sensitive account data, such as: 

Password updates 

Two-Factor Authentication (2FA) changes 

Linked email address changes 

Suspicious withdrawal activity or unusual behavior flagged by internal monitoring tools 

These events trigger automated security alerts, even if the system is still in the process of determining their risk level. 

3.9.2 Notification Channel  

All security-related communications are sent exclusively via the client’s registered email address. This email channel is encrypted and protected, and no sensitive information (such as passwords or full authentication codes) is ever included in plain text. 

Smart Valor does not use SMS or in-app notifications for fraud alerts or security threats. 

Automated Email Content and Client Actions  

The automated security email will contain: 

A brief description of the detected event (e.g., “We detected a login from a new device.”) 

The timestamp and IP/geolocation of the activity 

A question asking whether the client initiated this action 

A clear call-to-action, such as:  

“If this was not you, please contact our Customer Support team immediately.” 

“If you initiated this change, no further action is required.” 

These emails are system-generated and delivered instantly upon triggering events. 

3.9.3 Urgent Escalation Procedure  

In rare high-risk cases where Smart Valor has reason to believe the client no longer has access to their email, or the situation demands immediate personal verification (e.g., suspected account takeover or compromised credentials), Smart Valor will reset the client’s identity verification status, effectively blocking all financial activity on the account. In parallel, Smart Valor may attempt to contact the client through the following means: 

Calling the registered mobile number, and/or 

Requesting a video call to confirm the identity of the account holder. 

These escalation steps are only used when email contact has failed or when the risk level justifies direct contact. 

3.9.4 Delivery Verification and Response Tracking  

Smart Valor’s system tracks: 

Email delivery status 

Whether the email has been opened or bounced 

Whether the client has responded or contacted Support 

If no response is received within 24 hours, the alert is escalated to compliance/security operations and the account will be temporarily blocked to prevent any further activity until the issue is resolved. Clients are advised to ensure their registered email is always up to date, and to regularly monitor their inbox (including spam folders) for security-related notifications from Smart Valor. 

Reporting and Liability for Unauthorized or Incorrect Transfers 

Smart Valor is committed to safeguarding client assets and ensuring transparency and accountability in the event of any issues with crypto-asset transfers. This section outlines the procedure for reporting unauthorized or incorrectly executed transfers, the responsibilities of the client, and the conditions under which Smart Valor may or may not assume liability. 

3.10.1 Reporting Means and Channels 
Clients must report any unauthorized, incorrectly initiated, or incorrectly executed crypto-asset transfers without undue delay using one of the following official communication channels: 

Email: support@smartvalor.com 

Live chat (during support hours): Available on the Smart Valor website 

All communication must be made using the client’s registered email address 

3.10.2 Reporting Deadline 
To ensure proper review and eligibility for consideration, the client must report the issue to Smart Valor: 

No later than 30 calendar days from the date the transfer was executed, or 

Within 5 business days of the client becoming aware of the issue - whichever occurs earlier. 

Reports received after this period may be deemed invalid, and Smart Valor may decline to investigate or provide any assistance. 

3.10.3 Required Information from the Client 
When submitting a report, the client must provide the following information: 

Full name and registered email address 

Asset and amount 

Transaction ID or Hash 

Date and time of the transaction 

Description of the issue, including suspected error or unauthorized activity 

Supporting documentation, such as screenshots, blockchain explorer links, or correspondence (if available) 

Incomplete or unverifiable reports may result in delays or rejection of the complaint. 

3.10.4 Liability 
Smart Valor does not accept liability for client-initiated errors, including incorrect wallet addresses, unsupported network selections, or third-party transfers. All crypto-asset transfers are final once submitted to the blockchain, and clients are required to confirm transaction details during the transfer process. 

For full details on Smart Valor’s liability exclusions and conditions, please refer to Chapter 6 of this document, Liability. 

3.10.5 Maximum Liability Amount 
In line with the above, Smart Valor's liability for unauthorized or incorrectly executed transfers is zero (0) in cases where: 

The client confirmed the transfer via standard authentication flow, or 

The error was caused by the client’s own actions or omissions 

Smart Valor will only consider exceptional cases for review where internal platform error or fraud directly attributable to Smart Valor systems is proven. 

Clients are strongly advised to carefully verify all transaction details before confirming a transfer and to notify Smart Valor immediately in the event of any concerns. 

Termination & Procedure 

In the context of Smart Valor, termination of the agreement related to the provision of crypto-asset transfer services refers to the closure of the client’s entire account. Clients cannot selectively terminate individual services (such as transfer services) while continuing to use others (e.g., custody). Account closure automatically ends access to all related services, including crypto-asset transfers. 

3.11.1 Right to Terminate 

Clients have the right to terminate their agreement and close their account at any time, without any minimum contract period or prior notice required. 

3.11.2 How to Submit a Termination Request 

Account closure can be initiated in one of the following ways: 

Directly through the Smart Valor platform, using the available account deletion feature in the user settings; or 

By contacting Customer Support via: 

Email: support@smartvalor.com 

Live chat: available on the Smart Valor website or platform 

Clients must clearly state their intention to delete or close their account and confirm their identity via registered contact information. 

3.11.3 Notice Period and Effective Date 

There is no mandatory notice period. Once a valid termination request is received and confirmed, Smart Valor will process the account closure immediately or within a reasonable timeframe, usually within 2-3 business days. 

3.11.4 Confirmation of Termination 

The client will receive an email confirmation once the account has been successfully closed and the termination of services is complete. Any remaining balance must be withdrawn before closure. If necessary, Smart Valor may request additional identity verification before finalizing the process, to ensure secure termination. 

Access to Agreement and Information 

Smart Valor ensures that the client can access or receive the agreement, as defined in Article 82(1) of the MiCA Regulation, along with the information specified in Chapter 3 of these Terms, in electronic format at any time during the entire term of the agreement, upon request. 

Smart Valor also undertakes to inform the client in a timely manner and prior to entry into force of any intended changes to the information specified in Chapter 3. 

In line with regulatory best practices and ESMA Guideline 1 Point 16, Smart Valor further ensures that, at the time of presenting a copy of the draft contract under Article 82(1) MiCA, it is able to provide: 

Relevant information about the functioning of crypto-asset transfers, including procedural steps, supported blockchain networks, and security measures; 

A description of key risks associated with crypto-asset transfers (e.g., irreversibility, third-party wallet compatibility, network congestion); and 

Clear, accessible material to help clients understand their rights and obligations under the agreement. 

Educational content and explanations are made available through Smart Valor’s platform, support documentation, and customer service channels to ensure that clients are empowered to make informed decisions.  

In the event of an operational incident, technical failure, or cybersecurity threat affecting transfer services, SMART VALOR has implemented contingency protocols to preserve service continuity. Where necessary, affected clients will be informed via email and/or platform notifications, along with instructions for remediation, status tracking, or manual support options. 

The official language of the Terms and Conditions and all legally binding documentation is English. However, customer support is available in both English and German, and SMART VALOR ensures that all key concepts, such as risks, fees, and transaction conditions, are communicated clearly and accessibly through platform prompts, FAQs, and support documentation. 

Duty to inform 

Smart Valor ensures, through a standardized warning message displayed in the withdrawal window, that after the client initiates a crypto-asset transfer instruction but before the transaction is executed, the client is provided with the following essential information: 

3.13.1 Irreversibility Warning 

A clear and standardized warning is presented to all users: 

“Please make sure your transaction details are correct. Blockchain technology makes this transaction impossible to refund or cancel.” 

This message informs clients that: 

Once the transaction is submitted to the blockchain network, it becomes technically irreversible. 

No changes, cancellations, or refunds are possible after execution. 

Clients are responsible for verifying all transaction details, including wallet address, amount, and any memo or tag, before confirming the transaction. 

For blockchain networks operating under probabilistic settlement models (such as Ethereum and Bitcoin), Smart Valor defines internal thresholds for when a transaction is considered sufficiently final. These thresholds are based on the consensus algorithm and block confirmation speed of each DLT network. (See “Irreversibility Estimate” section for details.) 

3.13.2 Fee Disclosure 

Prior to final confirmation, Smart Valor displays a clear summary of the service fees it charges for the crypto-asset transfer. A flat service fee is applied by Smart Valor, and the specific fees for each supported asset are detailed in Section 2.3 Fees of this document. 

Note: Blockchain network fees (such as gas fees on Ethereum or miner fees on Bitcoin) are not displayed to the client, as they are dynamic, determined by the relevant DLT network, and not controlled by Smart Valor. 

Only the fees explicitly charged by Smart Valor are shown in the withdrawal interface before the client confirms the transaction. 

These measures are implemented through Smart Valor’s platform interface using automated tools that require the client to review the transaction details and explicitly confirm them by: 

Clicking “I confirm that I have read and confirmed the information above” before the transfer is processed. 

This procedure ensures compliance with applicable regulatory requirements and safeguards the client by supporting informed, deliberate decision-making prior to the execution of any crypto-asset transfer. 

The strategies and procedures outlined above (in Section 3) ensure that no transfer is initiated or executed without meeting the obligations set out in the Transfer of Funds Regulation (TOFR), particularly Article 14. These include the obligation to provide the client, after execution of each crypto-asset transfer, with the following information: 

The names of the Originator and Beneficiary 

The Distributed-Ledger address or account number of both the Originator and the Beneficiary 

A unique reference to identify the specific transfer 

The amount and type of crypto-assets transferred or received 

The value date for the debit or credit of the transaction 

The fees and commissions charged, including a breakdown, where applicable 

These disclosures guarantee transparency and traceability, and support Smart Valor’s ongoing compliance with regulatory requirements under TOFR and MiCA. 

Smart Valor will provide the information from this document in electronic format free of charge, provided that it is not supplied more frequently than once per month.  

In the event that a crypto-asset transfer is rejected, returned, or suspended, Smart Valor has established automated and manual procedures to ensure that the client is promptly informed through the following channels: 

Email notification sent to the client’s registered email address 

Support follow-up through Smart Valor’s customer support system, if further clarification or action is needed 

The notification includes the following information: 

The reason for the rejection, return, or suspension (e.g., regulatory block, invalid recipient address, internal security flag) 

If applicable, instructions or steps to remedy the issue (e.g., providing a new address, redoing identity verification) 

The amount of any fees or commissions already incurred, if any 

A statement on any refund options, including whether funds will be automatically returned to the client’s wallet or if further verification is needed 

These measures are supported through internal tools integrated with compliance monitoring, blockchain analytics, and Smart Valor’s ticketing system to ensure transparency and client support. 

Execution times and cut-off times 

Smart Valor provides crypto-asset transfer services on a continuous basis (24/7). There are no fixed cut-off times; however, the receipt time of a transfer instruction is formally defined as the moment the client completes all of the following steps: 

Submits a valid transfer request via the Smart Valor platform 

Confirms the transaction by clicking “I confirm that I have read and confirmed the information above” 

Completes required Travel Rule information (if applicable) 

Successfully passes Two-Factor Authentication (2FA) 

Once these steps are completed, the instruction is considered received and ready for execution. 

Maximum Execution Deadline 

Smart Valor will execute crypto-asset transfer instructions within a maximum of 24 hours from the time the instruction is received and authenticated, unless delayed due to the factors listed below. 

Factors That May Affect Execution Time 

The following conditions may cause temporary delays within the 24-hour window: 

Network congestion on the blockchain, resulting in slower confirmation or higher fees 

Pending compliance or security reviews, including enhanced due diligence 

Invalid or incompatible wallet addresses requiring manual verification 

Scheduled maintenance or technical disruptions on the platform 

Security-related account restrictions, such as withdrawal holds after a password reset 

Smart Valor continuously monitors these variables and aims to process all transfers as promptly as possible. 

Client Notifications 

Clients will be notified via email and/or their Smart Valor account dashboard: 

When a transfer is successfully initiated and the transaction is broadcast to the blockchain 

Once the transaction has been confirmed 

These steps ensure clear, traceable communication throughout the transfer process. 

Irreversibility Timeframes by DLT Network 

Each blockchain network has a different settlement speed and confirmation requirement before a transaction is considered final and irreversible. Smart Valor uses internal thresholds to assess sufficient finality for risk management purposes. 

A detailed table of confirmation counts and estimated settlement times per supported network (e.g., Ethereum, Bitcoin, Solana) is provided in Section 3.11 Irreversibility Estimate. 

Rejection or suspension of an instruction to transfer crypto assets or to return transferred crypto assets 

Smart Valor applies a risk-based approach in determining whether a transfer will be executed, suspended, or rejected, in accordance with TOFR, MiCA, and the EBA Guidelines on preventing abuse of transfers for money laundering or terrorist financing. 

Key triggers that may result in rejection, reversal, or suspension include: 

Transfers to wallets or exchanges classified as High Risk by blockchain analytics providers 

Mismatch between the client initiating the transfer and the declared beneficiary (recipient of the funds) 

Clients flagged for enhanced due diligence, pending risk review 

Failed KYC/AML verification 

Attempted use of unsupported networks or currencies 

Incomplete or invalid beneficiary data submitted under the Travel Rule, which may result in delayed or blocked outbound transfers. Smart Valor uses a dedicated Travel Rule compliance solution to support these requirements in line with TOFR Article 14 and EBA guidance. 

All decisions are logged and reviewed through Smart Valor’s compliance tools and internal workflows. Clients are notified of the outcome and, where legally permitted, provided with the reason for the decision and, if applicable, instructions for resolving the issue. 

Note: Reversals are only possible for transactions that have not yet been submitted to the blockchain. Once broadcast, transactions are technically irreversible, in line with MiCA settlement principles. 

Smart Valor continuously evaluates and updates its transaction screening and wallet risk profiling protocols to ensure regulatory compliance and prevent abuse of the platform. 

Liability 

Smart Valor applies a strict standard for client responsibility in the execution of transfers. Crypto-asset transfers are irreversible once submitted to the blockchain, and Smart Valor exercises multiple safeguards to ensure client awareness and intent, including: 

Mandatory confirmation prompts 

Display of recipient wallet address 

Requirement to re-enter 2FA credentials before submission 

Accordingly, Smart Valor accepts no liability for losses or incorrect transfers resulting from: 

Client error, such as entering a wrong or incompatible wallet address 

Failure to verify the recipient address or transfer details during confirmation 

Transfers to unsupported networks or third-party platforms 

Negligence in securing login credentials, passwords, or 2FA devices 

Late or unsubstantiated reporting 

Smart Valor is not obligated to reverse, refund, or recover misdirected funds under any of these conditions. 

Smart Valor will only consider exceptional cases for review where internal platform error or fraud directly attributable to Smart Valor systems is proven.