GENERAL TERMS OF USE

of the e-learning training platform

www.route-bitcoin-training.com

INTRODUCTION

These General Terms of Use (hereinafter, the “Terms” or “GTU”) govern access to and use of the online training platform accessible at www.route-crypto-training.net (hereinafter, the “Platform”), provided via technology from Thinkific Labs Inc. (Canada) and managed by MFG Consulting SA, a company incorporated under Swiss law with its registered office at Corso Elvezia 16, 6900 Lugano, Switzerland, represented by Mr. Maurizio Camponovo, email [email protected] (hereinafter the “Company” or the “Provider”).

The Platform offers e-learning training courses focusing, in particular, on crypto-assets, blockchain technology, digital assets, decentralized finance, and related topics (hereinafter, the “Courses” or the “Services”).

These Terms of Use apply to all Users of the Platform and are divided into:

In the event of a conflict between the provisions of Part I and those of Parts II or III, the latter shall prevail.

Access to the Platform and/or the purchase of a Course implies full and unconditional acceptance of these Terms and Conditions, the Privacy Policy, and the Cookie Policy published on the Website.

PART I – GENERAL PROVISIONS

1. Definitions

In these Terms of Use, the following terms have the meanings set forth below:

2. Subject Matter

These Terms of Use govern the Company’s provision of distance learning Services regarding crypto-assets, blockchain, digital assets, and related topics through the Platform.

The Company reserves the right to modify, supplement, or suspend, at any time, the Content, Courses, and features of the Platform, without this giving rise to any right to compensation or refunds, except in cases provided for by mandatory legislation applicable to Consumers.

3. Registration and Account

To access the Services, the User must register on the Platform by providing the requested information, which must be truthful, accurate, and up-to-date. The User is required to promptly notify the Company of any changes to the information provided.

The User is solely responsible for safeguarding their login credentials (username and password) and for all activities carried out through their Account. The transfer, sharing, or granting of use of these credentials to third parties is prohibited. In the event of suspected unauthorized use of the Account, the User must immediately notify the Company.

Registration is reserved for individuals who are at least 18 years of age. The Company reserves the right to refuse, suspend, or close Accounts in the event of a violation of these Terms of Use, suspected fraudulent use, or failure to pay.

4. Conclusion of the Contract

The contract between the User and the Company is concluded when the User, after selecting the desired Course or subscription, completes the online purchase process, expressly accepts these Terms of Use and the Privacy Policy by checking the appropriate boxes, and receives an order confirmation from the Company at the provided email address.

The order confirmation constitutes the Company’s acceptance of the User’s contractual proposal. Before submitting the order, the User has the right to verify and correct the data entered.

The Terms of Use accepted at the time of contract conclusion are stored by the Company in electronic format and are available upon the User’s request.

5. Fees, Billing, and Payment Methods

The fees for Courses and subscriptions are indicated on the Platform at the time of purchase, inclusive of VAT where applicable. The Company reserves the right to modify prices at any time; such modifications do not have retroactive effect on Courses already purchased.

Payment is processed through third-party providers Stripe and PayPal, which act as independent data controllers for payment data (see Privacy Policy). The Company does not store credit/debit card information.

Invoicing is carried out in accordance with applicable tax regulations. The Business User is required to provide correct tax information at the time of purchase.

In the event of non-payment, the Company reserves the right to suspend access to the Course and to take any debt collection measures, without prejudice to compensation for further damages.

6. Access to Courses and License of Use

Upon purchase of a Course, the Company grants the User a personal, non-exclusive, non-transferable, non-assignable, and non-sublicensable license to access the Content for personal or professional training purposes, exclusively through the Platform, for the duration specified at the time of purchase.

The User is expressly prohibited from:

Violation of the above restrictions constitutes a material breach of contract and entitles the Company to immediately suspend access, in addition to compensation for all damages suffered, without prejudice to the right to take civil and criminal action to protect copyrights.

7. Intellectual Property

All Content, including but not limited to text, video, audio, images, graphics, logos, trademarks, software code, and databases, is the exclusive property of the Company or its licensors and is protected by copyright, trademark, and database laws.

No provision of these Terms of Use transfers any intellectual property rights in the Content to the User, except for the limited license of use referred to in Section 6.

Any content uploaded by the User to the Platform (e.g., comments, submissions, forum questions) remains the property of the User, who nevertheless grants the Company a free, non-exclusive, worldwide license, for the time necessary to provide the Services, to use such content for the purposes of the Platform. The User warrants that they hold the necessary rights to the uploaded content and do not infringe upon the rights of third parties.

8. Nature of the Content – Crypto and Financial Services Disclaimer

IMPORTANT WARNING. The Content on the Platform is intended solely for educational, instructional, and informational purposes. It does not constitute financial, investment, tax, legal, or insurance advice in any way, nor does it constitute personalized recommendations or solicitations to invest.

The Company does not provide investment services under the Federal Act on Financial Services (FISG) or the Federal Act on Financial Institutions (FIA), nor does it provide brokerage services under the Anti-Money Laundering Act (AMLA), nor does it provide financial advisory services. The opinions expressed by instructors or in educational materials represent personal assessments for illustrative purposes and do not constitute operational guidance in any way.

Investing in crypto-assets involves high risks, including the risk of total loss of invested capital, high price volatility, liquidity risk, operational risk, fraud risk, and regulatory risk. The User is required to conduct independent assessments, consulting qualified and licensed advisors if necessary, before making any investment decision.

The Company shall in no event be liable for any losses, lost profits, or direct or indirect damages incurred by the User as a result of investment or operational decisions made based—even partially—on the Platform’s Content.

9. Recognition of Continuing Education Credits (IVASS, CONSOB, OCF, and similar)

The Company may issue certificates of course completion that Users may use to fulfill the professional development requirements set forth in industry regulations, specifically:

The Platform’s eligibility to issue certificates valid for the recognition of training hours is based on compliance with the technical requirements of the Learning Management System (LMS) as stipulated by sector regulations (tracking of access and usage, user identification, passing of assessment tests).

Please note that the Company does not operate under a formal accreditation regime with IVASS, CONSOB, or other bodies (as no formal accreditation system exists for training providers), but rather under a self-assessment regime regarding compliance with the technical and content requirements set forth by the regulations. It is the responsibility of the User and/or their employer to verify the eligibility of the certificate for the purposes of their training obligations.

The Company does not guarantee in any way that individual insurance intermediaries, financial advisors, or supervisory bodies will recognize the certificate for their own purposes; any objections raised by the employer or the supervisory authority will not give rise to a right to a refund, without prejudice to the Company’s obligation to provide the Services in a workmanlike manner.

10. Platform Availability and Force Majeure

The Company undertakes to ensure the availability of the Platform with the required professional diligence, but does not guarantee uninterrupted availability. The Platform is provided through Thinkific Labs Inc. and may be subject to interruptions due to routine or emergency maintenance, updates, technical malfunctions, or cyberattacks.

The Company shall not be liable for malfunctions, delays, or suspensions of the Service due to causes not attributable to it, including: unavailability of the Thinkific platform, User connectivity issues, cyberattacks, strikes, natural disasters, regulatory actions, or force majeure events.

11. Limitation of Liability

Except in cases of willful misconduct or gross negligence and as otherwise required by applicable consumer protection laws, the Company’s total liability to the User for any claim related to these Terms of Service shall not exceed the amount of fees actually paid by the User in the 12 months preceding the event giving rise to the claim.

The Company shall not be liable, under any circumstances, for:

12. User Obligations and Warranties

The User warrants that:

13. Suspension and Termination

The Company may immediately suspend access to the Platform, subject to subsequent written confirmation of the termination of the contract, in the event of:

The Company may terminate the contract, upon written notice with 30 days’ advance notice, in the event of termination of the Services, a substantial modification of the offer, or the supervening impossibility of providing the Services.

14. Processing of Personal Data

The processing of the User’s personal data is governed by the Privacy Policy published on the Platform, which constitutes an integral part of these Terms of Use. The User declares that they have read and understood it.

15. Changes to the Terms of Use

The Company reserves the right to modify these Terms of Use at any time. Any changes will be communicated to the User via email and/or by posting on the Website at least 15 days prior to their effective date.

In the event of substantial changes, the Consumer User shall have the right to terminate the contract without penalty within the period specified in the notice. Continued use of the Platform after the changes take effect constitutes acceptance of such changes.

16. Communications

Any communication between the Parties regarding these Terms of Use shall be valid and effective if sent to the email addresses provided at the time of registration (for the User) or published on the Website (for the Company). The User is required to promptly notify the Company of any changes to their contact information.

17. Assignment of the Agreement

The User may not assign the contract, in whole or in part, to third parties, nor may they assign the rights and obligations arising therefrom. The Company may assign the contract to companies within its group or in the event of extraordinary transactions (merger, demerger, sale of the business or a business unit), provided that the User is notified in advance.

18. Severability Clause

The invalidity, nullity, or ineffectiveness of one or more provisions of these Terms of Use shall not affect the validity of the remaining provisions, which shall remain fully effective.

19. Governing Law

These Terms of Use are governed by Swiss law, excluding the rules of private international law. The application of the Vienna Convention on the International Sale of Goods is expressly excluded. For Consumer Users residing in a European Union member state, the application of mandatory consumer protection provisions under the law of the country of habitual residence remains unaffected, pursuant to Article 6 of Regulation (EC) No. 593/2008 (“Rome I”).

PART II – SPECIFIC PROVISIONS FOR CONSUMER USERS (B2C)

The provisions of this Part II apply exclusively to Consumer Users and, in the event of a conflict, prevail over the provisions of Part I.

20. Consumer Protection

The Consumer User benefits from the protections provided by Swiss law regarding distance contracts (Articles 40a–40g CO) and, if resident in a European Union member state, from the mandatory protections provided by the laws of the country of residence, including the Italian Consumer Code (Legislative Decree 206/2005) for Users residing in Italy.

21. Right of Withdrawal

Consumer Users residing in a European Union member state have the right to withdraw from the contract within 14 days of its conclusion, without the need to provide a reason, pursuant to Articles 52 et seq. of the Italian Consumer Code (for residents in Italy) and the corresponding regulations of other EU member states. For Consumer Users residing in Switzerland, the right of withdrawal is governed by Articles 40a–40g of the Swiss Code of Obligations (CO), with a 14-day period.

The standard withdrawal form is available on the Website or may be requested via email. The notice of withdrawal must be sent to the Company’s email address indicated in the introduction.

Exceptions to the right of withdrawal. The right of withdrawal does not apply to contracts for the supply of digital content via non-material media if performance has begun, with the Consumer User’s express consent and acceptance that this entails the loss of the right of withdrawal. Therefore, if the Consumer User expressly requests immediate access to the Course Content and acknowledges the loss of the right of withdrawal, that right may no longer be exercised as of the first actual access to the Content.

Refund procedures will comply with applicable regulations and will be processed using the same payment method used for the original transaction, unless otherwise agreed.

22. Warranty of Conformity

The Consumer User is entitled to the guarantees of conformity provided for by applicable law regarding contracts for the supply of digital content and services. In the event of a lack of conformity, the User may request restoration of conformity, a price reduction, or termination of the contract in the cases provided for by law.

23. Jurisdiction for Consumers

For Consumer Users residing in Italy or another European Union member state, the court of the Consumer’s place of residence or elected domicile has exclusive and mandatory jurisdiction, pursuant to Article 18 of Regulation (EU) No. 1215/2012 (“Brussels I bis”) or—in CH/EU relations—the Lugano Convention of October 30, 2007. For Consumer Users residing in Switzerland, the court of the Consumer’s domicile has jurisdiction pursuant to Art. 32 CPC.

24. Alternative Dispute Resolution (ODR)

Pursuant to Regulation (EU) No. 524/2013, Consumer Users residing in the European Union may access the European Commission’s online dispute resolution (ODR) platform: https://ec.europa.eu/consumers/odr.

PART III – SPECIFIC PROVISIONS FOR BUSINESS / CORPORATE USERS (B2B)

The provisions of this Part III apply exclusively to Business and Corporate Users and, in the event of a conflict, prevail over the provisions of Part I. The protections of the Consumer Code (or Swiss consumer law) do not apply.

25. Conclusion of the Corporate Agreement

Multi-user access to the Platform by a legal entity (company, firm, intermediary, association) is based on a Corporate Agreement separately signed between the Company and the Corporate Customer, which governs:

These Terms of Use apply in addition to the Corporate Agreement; in the event of a conflict, the provisions of the Corporate Agreement shall prevail.

26. Named Licenses and Use by the Corporate Customer

Unless otherwise agreed in writing, the access licenses provided to the Corporate Customer are named and may not be shared among multiple users. The Corporate Customer is responsible for:

27. Confidentiality

The Parties agree to keep confidential any confidential information received from the other Party in connection with the Corporate Agreement, including: commercial, technical, and financial data, know-how, user lists, and usage statistics. The confidentiality obligation remains in effect for 5 years following the termination of the relationship.

28. Service Level Agreement (SLA) and Support

Unless otherwise agreed in the Corporate Agreement, the Company undertakes to ensure Platform availability of at least 99% on a monthly basis, excluding periods of scheduled maintenance and force majeure events. Technical support is provided in Italian on business days from Monday to Friday, from 9:00 AM to 6:00 PM (CET).

29. Liability in B2B Relationships

The protections of the Consumer Code do not apply to relationships between the Company and the Business User. The Company’s liability is limited, except in cases of willful misconduct or gross negligence, to the amount of fees paid by the Corporate Customer in the 12 months preceding the event giving rise to the claim. Indirect, consequential, and damages arising from loss of profits, loss of opportunity, and reputational harm are excluded in all cases.

30. Term, Renewal, and Termination of the Corporate Contract

Unless otherwise agreed, the Corporate Contract has a term of 12 months from the activation date and is tacitly renewed for similar periods unless notice of termination is sent via certified email (PEC) or registered mail with return receipt at least 60 days prior to the expiration date.

Early termination by the Corporate Customer does not entitle the Customer to a refund of fees already paid, unless otherwise agreed in writing. The Company may terminate the Agreement due to the Customer’s breach with 15 days’ notice, without prejudice to the right to immediate termination in the event of material breaches.

31. Jurisdiction for Business Users

For relations between the Company and the Business User, the courts of Lugano (Switzerland) shall have exclusive jurisdiction, unless otherwise agreed in writing.

APPENDIX A – SPECIFIC APPROVAL OF THE CLAUSES

Pursuant to and for the purposes of Articles 1341 and 1342 of the Italian Civil Code (for contracts governed by Italian law), and in accordance with the principles of good faith and contractual transparency (for contracts governed by Swiss law), the User, having specifically and separately reviewed them, expressly approves the following clauses of these Terms of Use: