Non-Custodial & Risk Disclosure

Last Updated: September 11, 2026

1. Introduction

This Non-Custodial & Risk Disclosure (“Disclosure”) explains important characteristics and risks associated with the use of Coinsnap software, including Merchant payment functionality, the Coinsnap Wallet, Point-of-Sale functionality, APIs, plugins, integrations and related technologies.

Coinsnap is a brand operated by:

Onlineshop24 DOO
Ljubimira Ivkovica Suce 75
11453 Sopot (Ducina)
Serbia

Registration Number / Matični broj: 21579041
Tax ID / PIB: 111945856

Coinsnap provides software and technical infrastructure.

Coinsnap’s standard Merchant payment functionality is designed so that Bitcoin can be paid directly from the Payer to a wallet selected by the Merchant without Coinsnap taking custody of the Bitcoin.

Use of Bitcoin, self-custodial wallets, the Lightning Network and related technologies involves risks. Users should understand these risks before using Coinsnap.

This Disclosure should be read together with the Coinsnap Terms of Service, Privacy Policy, Cookie Policy and, where applicable, Data Processing Addendum.

If there is any conflict between this Disclosure and the Coinsnap Terms of Service regarding contractual rights or obligations, the Terms of Service prevail.

2. Nature of Coinsnap

Coinsnap provides software and technology for using and accepting Bitcoin.

For Merchants, Coinsnap may provide functionality such as:

• Bitcoin and Lightning payment requests;
• QR codes and payment pages;
• payment links and payment buttons;
• Point-of-Sale functionality;
• integrations for online shops;
• plugins;
• APIs and webhooks;
• transaction detection;
• payment status information;
• transaction attribution and reconciliation;
• reporting and accounting exports;
• wallet integrations; and
• technical integrations with independent Third-Party Providers.

Coinsnap may also provide self-custodial wallet software that enables Users to send and receive Bitcoin.

Coinsnap does not provide its standard Merchant service as a custodial account, cryptocurrency exchange, brokerage service, bank account or fiat settlement service.

3. Standard Direct-to-Merchant Payment Model

For a standard self-custodial Merchant payment, the payment flow is:

Payer’s Wallet → Bitcoin / Lightning Network → Merchant-selected Wallet

The Merchant uses Coinsnap software to create or present a payment request.

The Payer decides whether to make the payment and initiates and authorises the transaction using the Payer’s own wallet.

Bitcoin is transferred through the Bitcoin or Lightning Network directly to the wallet destination selected by the Merchant.

Coinsnap software detects the resulting payment and provides technical information to the Merchant, such as payment status and the association between the payment and the relevant order or invoice.

Coinsnap does not receive, hold or take possession of the Bitcoin at any stage of the standard self-custodial payment flow.

Coinsnap does not take ownership of the Bitcoin payment.

Coinsnap provides the software layer used to create and monitor the payment request and to connect the resulting payment information with the Merchant’s business systems.

4. Coinsnap Does Not Control the Payer’s Payment Decision

A Bitcoin payment is initiated by the Payer.

Coinsnap does not independently decide whether the Payer should make a payment and does not independently authorise a payment on behalf of the Payer.

The Payer is responsible for checking the payment request before authorising a transaction, including:

• the payment amount;
• the payment destination;
• the requested currency or Bitcoin amount;
• any displayed Merchant information; and
• any applicable network fees.

Once a Bitcoin transaction has been authorised and transmitted to the relevant network, Coinsnap cannot guarantee that it can be cancelled or reversed.

5. No Custody of Merchant Payments

Coinsnap does not take custody of Bitcoin received by a Merchant as part of the standard self-custodial payment service.

In particular, Coinsnap does not, as part of that service:

• hold a Merchant’s Bitcoin balance in a custodial account;
• receive or take possession of Bitcoin Payments intended for the Merchant;
• control when the Merchant may transfer Bitcoin;
• freeze a Merchant’s Bitcoin balance;
• use Merchant Bitcoin for Coinsnap’s own purposes;
• maintain pooled Merchant Bitcoin balances; or
• exercise unilateral control over a Merchant’s Bitcoin.

The Merchant remains responsible for the wallet destination selected for receiving Bitcoin.

6. Merchant-Controlled Wallet Destinations

Depending on the Coinsnap configuration, a Merchant may receive Bitcoin using:

• the Coinsnap self-custodial Wallet;
• another self-custodial Bitcoin wallet;
• an on-chain wallet configured through appropriate wallet information such as an extended public key;
• a Lightning wallet or Lightning Address; or
• another supported Merchant-selected wallet configuration.

The Merchant is responsible for ensuring that the configured receiving destination is correct and appropriate for its intended use.

Coinsnap is not responsible for Bitcoin sent to an incorrect destination supplied or configured by the Merchant.

Because Bitcoin transactions may be irreversible, an incorrect wallet address, Lightning destination, wallet configuration or other payment destination can result in permanent loss of funds.

7. Extended Public Keys and Wallet Configuration

Where a Merchant uses an extended public key or similar wallet information to receive on-chain Bitcoin, the Merchant is responsible for providing the correct information.

An extended public key generally enables the derivation or observation of receiving addresses but does not itself provide authority to spend Bitcoin.

However, disclosure of extended public key information may have privacy implications because it may allow transactions and addresses associated with that wallet structure to be analysed.

Merchants should protect wallet information according to the security recommendations of their wallet provider.

8. Coinsnap Wallet and Self-Custody

The Coinsnap Wallet is designed as a self-custodial wallet.

In a self-custodial wallet, the User remains responsible for controlling access to the Bitcoin.

The User, rather than Coinsnap acting as a custodian, is responsible for protecting the credentials and recovery information required to access or restore the wallet.

Coinsnap does not maintain a custodial account balance that the User must request Coinsnap to release.

Transactions from the self-custodial Coinsnap Wallet are initiated and authorised by the wallet User.

Coinsnap does not independently decide to transfer a User’s Bitcoin on the User’s behalf.

The availability of the Coinsnap Wallet does not change Coinsnap’s role in Merchant payments and does not make Coinsnap the custodian of Bitcoin received by a Merchant.

9. Private Keys and Recovery Information

Users of a self-custodial wallet are responsible for securing:

• private keys;
• recovery phrases or seed words;
• wallet backups;
• mobile devices;
• passwords;
• device authentication; and
• any other information capable of restoring or accessing the wallet.

Coinsnap is not a custodial recovery service.

Loss or compromise of wallet recovery information may result in permanent loss or theft of Bitcoin.

Users should never disclose a recovery phrase or private key to persons claiming to be Coinsnap support.

Coinsnap support does not require a User’s recovery phrase or private key in order to provide normal support.

10. Backup and Recovery Functionality

The Coinsnap Wallet may provide optional backup or recovery functionality.

The specific backup or recovery method may depend on the Wallet version, operating system and functionality selected by the User.

Where third-party storage or device services are used as part of an optional backup or recovery function, Users may also be exposed to risks associated with those services and accounts.

Users remain responsible for securing access to their devices, accounts, backup information and recovery information.

The availability of a backup or recovery function does not remove the User’s responsibility for ensuring that the wallet can be recovered.

Users should follow the current Coinsnap Wallet documentation applicable to the Wallet version they use.

11. Loss of Wallet Access

Self-custody provides Users with control over their Bitcoin but also places responsibility for access and recovery on the User.

Depending on the wallet and configuration, loss of:

• a device;
• recovery information;
• authentication credentials;
• backup access; or
• other required recovery information

may result in permanent loss of access to Bitcoin.

Coinsnap cannot guarantee recovery of a self-custodial wallet where the necessary recovery information has been lost.

12. Bitcoin Transaction Irreversibility

Bitcoin transactions are generally not reversible in the way that traditional card payments may be reversed or charged back.

Once a transaction has been validly authorised and transmitted, Coinsnap cannot simply cancel it.

Users must therefore verify transaction details before authorising a payment.

Merchants remain responsible for their refund policy and for issuing refunds relating to their own goods or services.

Where a refund is made from a self-custodial wallet, the Merchant is responsible for verifying the refund destination and amount before authorising the transaction.

13. Bitcoin Network Risks

Bitcoin operates on decentralised network infrastructure that is not controlled by Coinsnap.

Risks may include:

• network congestion;
• variable transaction fees;
• delayed confirmations;
• blockchain reorganisations;
• protocol changes;
• software vulnerabilities;
• infrastructure failures;
• connectivity problems;
• denial-of-service attacks;
• malicious actors;
• incompatible software;
• forks; and
• other technical events.

Coinsnap cannot control the operation of the Bitcoin network and cannot guarantee a particular transaction confirmation time.

14. Lightning Network and Other Supported Payment Technologies

Coinsnap may use or support the Lightning Network and other Bitcoin-related payment technologies.

These technologies may have risks different from ordinary Bitcoin on-chain transactions.

Depending on the technology and payment route, risks may include:

• routing failures;
• insufficient liquidity;
• unavailable routes;
• temporary service interruption;
• payment timeouts;
• node or infrastructure failures;
• implementation defects;
• protocol changes; and
• dependency on third-party infrastructure.

A payment request being generated does not guarantee that every wallet will be able to complete the payment successfully.

Coinsnap does not control the entire Bitcoin or Lightning infrastructure used to transmit a transaction.

15. Payment Detection and Confirmation

Coinsnap provides software that detects payment information and communicates payment status to the Merchant.

Payment detection and payment status depend on technical information available from Bitcoin, Lightning or other supported infrastructure.

Delays, network failures or third-party infrastructure problems may result in a payment being detected later than expected or payment status information being temporarily unavailable.

Merchants should configure their operational processes according to the level of payment confirmation appropriate for their business.

Coinsnap does not guarantee that a particular payment status eliminates all technical or commercial risk.

16. Public Nature of Bitcoin Transactions

Bitcoin on-chain transactions are recorded on a public blockchain.

Public information may include:

• Bitcoin addresses;
• transaction identifiers;
• amounts;
• timestamps; and
• transaction relationships.

Bitcoin is generally pseudonymous rather than inherently anonymous.

Blockchain analytics and other information may enable third parties to associate particular transactions or addresses with a person or business.

Coinsnap cannot modify or delete information validly recorded on the Bitcoin blockchain.

Merchants and Payers should consider the privacy characteristics of Bitcoin when using on-chain payments.

17. Payment and Customer Information

Coinsnap does not require identification of the Payer merely to detect a standard self-custodial Bitcoin payment.

Coinsnap does not store the Payer’s IP address as part of the standard Bitcoin or Lightning payment transaction record.

A Merchant may, however, choose to associate customer or Payer information with a payment for purposes such as:

• order attribution;
• invoicing;
• reporting;
• accounting;
• customer service; or
• an optional Third-Party Provider integration.

The Merchant is responsible for deciding what information it collects from its customers and for complying with privacy and other laws applicable to that processing.

Where Coinsnap processes Personal Data on behalf of the Merchant, the Coinsnap Data Processing Addendum may apply.

Additional information regarding data processing is provided in the Coinsnap Privacy Policy.

18. Bitcoin Price and Exchange-Rate Risk

The value of Bitcoin may change substantially over short periods.

Where a Merchant prices goods or services in a fiat currency, Coinsnap may calculate a corresponding Bitcoin amount using available exchange-rate information.

This calculation does not mean that Coinsnap buys or sells Bitcoin.

Exchange-rate sources may:

• differ from one another;
• update at different times;
• become temporarily unavailable;
• experience errors; or
• differ from the rate obtainable on an exchange or through a Third-Party Provider.

Coinsnap does not guarantee the future value of Bitcoin or that a Merchant will be able to exchange Bitcoin at the rate displayed when a payment request was created.

Merchants bear the economic risk associated with holding Bitcoin they receive.

19. Third-Party Conversion and Bank Settlement

A Merchant may choose an optional independent Third-Party Provider for functionality such as:

• Bitcoin-to-fiat conversion;
• exchange services;
• brokerage services;
• settlement to a bank account; or
• other financial services.

These financial services are not provided by Coinsnap.

Where a Merchant selects such a service, the payment, conversion or settlement flow may differ from the standard direct-to-Merchant self-custodial flow described in this Disclosure.

The relevant Third-Party Provider determines how its service operates.

The Merchant may enter into a separate contractual relationship with that provider.

Depending on the service, the Third-Party Provider may be responsible for:

• receiving assets as part of its own service;
• conversion;
• exchange execution;
• fiat settlement;
• bank payout;
• KYC or KYB procedures;
• AML procedures;
• sanctions screening; and
• other regulatory requirements applicable to its service.

Coinsnap may provide the technical integration through which the Merchant connects to or uses the Third-Party Provider.

Coinsnap does not itself perform the regulated financial service merely because Coinsnap provides the technical integration.

20. Information Required by Third-Party Providers

A Third-Party Provider may require information about the Merchant or Payer in order to comply with laws or regulatory obligations applicable to that provider.

Such requirements are determined by the Third-Party Provider and are not independently imposed by Coinsnap as a condition of a standard self-custodial Bitcoin payment.

Where supported by the integration and instructed by the Merchant, Coinsnap may technically transmit information supplied by the Merchant to the selected Third-Party Provider.

The Third-Party Provider is responsible for its own:

• compliance procedures;
• acceptance decisions;
• customer due diligence;
• KYC or KYB requirements;
• AML requirements;
• sanctions screening;
• transaction monitoring;
• banking requirements;
• account restrictions; and
• regulatory obligations.

A Third-Party Provider may refuse, delay, restrict or terminate its service independently of Coinsnap.

21. Third-Party Service Risks

Coinsnap software may rely on or integrate third-party technologies or services.

Depending on the product used, these may include:

• Bitcoin network infrastructure;
• Lightning infrastructure;
• wallet infrastructure;
• blockchain information services;
• cloud infrastructure;
• mobile operating systems;
• application stores;
• notification services;
• market data providers; and
• financial service providers selected by the Merchant.

Coinsnap does not control independent third-party services.

Failures or changes affecting those providers may result in:

• temporary service interruption;
• delayed payment detection;
• unavailable functionality;
• routing problems;
• data delays;
• compatibility issues; or
• discontinuation of a particular integration.

Coinsnap may replace, modify or discontinue integrations where necessary for security, reliability, technical compatibility or legal reasons.

22. Merchant Operational Responsibility

Merchants remain responsible for their own commercial operations.

This includes decisions regarding:

• when goods or services are delivered;
• which payment status is sufficient for fulfilment;
• refunds;
• pricing;
• invoices;
• accounting;
• taxes;
• customer support;
• consumer protection;
• privacy disclosures; and
• compliance obligations applicable to the Merchant’s business.

Coinsnap does not become a party to the transaction between the Merchant and the Payer merely because its software is used to create, display, detect or reconcile the Bitcoin payment.

23. Regulatory and Legal Risk

Laws and regulations relating to Bitcoin, crypto-assets, self-custodial wallets and related technologies differ between jurisdictions and may change.

The legality or regulatory treatment of a particular activity may depend on factors including:

• the country in which a Merchant operates;
• the location of its customers;
• the Merchant’s business activity;
• the payment flow used;
• whether assets are held or controlled by an intermediary;
• whether conversion or settlement services are used; and
• the nature of any Third-Party Provider involved.

Coinsnap’s standard Merchant service is designed as non-custodial software and technical infrastructure.

Coinsnap does not provide its standard Merchant service as a bank, cryptocurrency exchange, broker, custodial wallet provider or fiat settlement provider and does not represent itself as a MiCAR-authorised Crypto-Asset Service Provider.

Where Coinsnap determines that a functionality would require regulatory authorisation that Coinsnap does not hold, Coinsnap may:

• not offer the functionality;
• restrict its availability;
• modify or redesign the technical workflow;
• discontinue the functionality; or
• provide access through an appropriate independent Third-Party Provider.

Coinsnap may make such changes in order to preserve the intended separation between Coinsnap’s software services and regulated financial or crypto-asset services.

Nothing in the availability of Coinsnap software constitutes a representation that a Merchant’s use of Bitcoin is lawful or unregulated in every jurisdiction.

Merchants remain responsible for understanding and complying with the rules applicable to their own business.

24. No Financial, Investment, Tax or Legal Advice

Coinsnap provides software and technical information.

Coinsnap does not provide:

• investment advice;
• trading advice;
• financial advice;
• tax advice;
• accounting advice; or
• legal advice.

Information made available by Coinsnap should not be interpreted as a recommendation to buy, sell or hold Bitcoin.

Users remain responsible for obtaining their own professional advice where necessary.

25. Software and Cybersecurity Risks

Software may contain defects, vulnerabilities or compatibility problems.

Risks associated with using Coinsnap or related systems may include:

• application errors;
• software bugs;
• incompatible devices;
• operating-system changes;
• malware;
• compromised devices;
• phishing;
• credential theft;
• unauthorised account access;
• network attacks;
• third-party software vulnerabilities; and
• data or configuration errors.

Users should:

• keep devices and software updated;
• use secure authentication;
• protect account credentials;
• verify wallet addresses and payment destinations;
• protect recovery information; and
• obtain software only from trusted sources.

Users should treat unexpected requests for seed phrases, private keys or account credentials as potentially fraudulent.

Coinsnap support does not require a User to disclose a seed phrase or private key.

26. Service Availability

Coinsnap aims to provide reliable software but cannot guarantee uninterrupted availability.

Services may be affected by:

• maintenance;
• software updates;
• infrastructure outages;
• internet failures;
• Bitcoin network conditions;
• Lightning Network conditions;
• third-party failures;
• cybersecurity incidents;
• force majeure; or
• events outside Coinsnap’s reasonable control.

A Merchant should consider appropriate contingency procedures where continuous Bitcoin payment acceptance is important to its business.

27. No Guarantee Against Loss

Self-custody removes the need for Coinsnap to hold a User’s Bitcoin but places significant responsibility on the wallet owner.

Coinsnap cannot guarantee protection against losses caused by circumstances outside Coinsnap’s control, including:

• loss of recovery information;
• incorrect payment destinations;
• compromised devices;
• disclosure of private keys;
• fraudulent instructions;
• Bitcoin price movements;
• network conditions;
• irreversible transactions; or
• failures of independent Third-Party Providers.

The allocation and limitation of legal liability between the User and Coinsnap is governed by the Coinsnap Terms of Service and applicable law.

28. Changes in Technology or Regulation

Bitcoin and related technologies continue to develop.

Coinsnap may change its software where necessary because of:

• Bitcoin protocol developments;
• Lightning Network developments;
• changes to supported technologies;
• security requirements;
• technical infrastructure changes;
• changes to Third-Party Providers; or
• legal or regulatory developments.

Coinsnap may remove, restrict or redesign a feature where necessary to preserve the intended non-custodial software model or to avoid providing a service that would require regulatory authorisation Coinsnap does not hold.

29. User Acknowledgement

By using Coinsnap, Users acknowledge that they understand that:

• Coinsnap’s standard Merchant payment service is designed as non-custodial software and technical infrastructure;
• the Payer initiates and authorises the Bitcoin payment;
• Bitcoin is transferred directly to the Merchant-selected wallet destination in the standard self-custodial payment model;
• Coinsnap does not receive, hold or take possession of the Bitcoin in the standard self-custodial payment flow;
• Coinsnap does not hold the Merchant’s Bitcoin as a custodian;
• self-custody places responsibility for wallet security and recovery on the wallet owner;
• Bitcoin transactions may be irreversible;
• Bitcoin and Lightning technologies involve technical and financial risks;
• optional financial services may be provided by independent Third-Party Providers;
• Coinsnap may modify or discontinue functionality where necessary to preserve its non-custodial software model or comply with applicable law; and
• applicable laws may differ depending on the User, Merchant, jurisdiction and functionality used.

Users should not use Coinsnap or Bitcoin functionality they do not understand.

30. Contact

Questions regarding this Disclosure may be sent to:

Coinsnap / Onlineshop24 DOO
Ljubimira Ivkovica Suce 75
11453 Sopot (Ducina)
Serbia

Email: support@coinsnap.io
Website: https://coinsnap.io