# Terms of Use

## Ledger Enterprise Mobile Application - TERMS OF USE

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You are about to enter Ledger Enterprise Mobile Application software, the data supplied with the software, and any updates or supplements to it to access your Vault Services (“LE Mobile App”). We’re excited for you! Before you get on, Ledger needs you to carefully read, understand and accept our Terms of Use (these “Terms” or this “Agreement”). To access the LE Mobile App, you confirm and agree that you have a Platform as a Service Agreement (“PaaSA”) with us or one of our Affiliates. You also confirm that you have a Ledger Hardware Device.&#x20;

1\. Overview

This Agreement is between your legal entity (“you”, “your”, or “user”) and the following Ledger company, depending on your region and in accordance with your PaaSA with us:

<br>

| Region                                         | Ledger company (“Ledger”, “us”, “our”)                                                                                                                                                                                                                                                           |
| ---------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Asia Pacific                                   | Ledger Technologies SG Pte. Ltd, a private company limited by shares registered under the laws of Singapore having registration number 202003143R and whose registered office is at 9 Raffles Place #26-01, Republic Plaza, Singapore (048619)                                                   |
| United States                                  | Ledger Technologies INC, a company registered under the laws of Delaware  with a registered address located at 838 Walker Rd, Suite 21-2, Dover, DE 19904, County of Kent, United States                                                                                                         |
| Europe, Middle East and Africa / Rest of World | <p>LEDGER, a simplified joint stock company (société par actions simplifiée), whose registered office is located at </p><p>106 rue du Temple 75003 Paris, France, registered with the Trade and Companies Registry (Registre du Commerce et des Sociétés) under number 529 991 119 RCS Paris</p> |

You, the user and us, Ledger are together referred to as the “Parties”.

By clicking “I agree”, “Get started”, or otherwise using any of the Services provided by Ledger or any third party services made available through LE Mobile App, you agree that you have carefully read and accepted all of these Terms which will bind you.&#x20;

IF YOU DO NOT AGREE TO THESE TERMS, CLICK ON THE "REJECT" BUTTON BELOW.

Your use of LE Mobile App is subject to Article 19 (Processing of Customer Personal Data) of your Platform as a Service Agreement with us and the DPA Addendum.&#x20;

\[INSERT AS LINK TO COOKIE POLICY]Use of Software Development Kits (SDKs): Our LE Mobile App may utilize third-party Software Development Kits (SDKs) to provide certain features and functionalities, such as analytics, advertising, social media integration, and crash reporting. These SDKs may collect and process information in accordance with their own privacy policies.

Device Bluetooth Pairing

Access to and use of the LE Mobile App is contingent upon the successful bluetooth pairing of your compatible mobile device (with the LE Mobile App installed) with your Ledger Hardware Device. User authentication and authorization for access to the LE Mobile App, including your designated workspace instance and assigned role, will be solely performed through a Ledger Hardware Device, which, for the avoidance of doubt, currently includes Ledger Stax devices.

Registration

You acknowledge that Ledger does not require you to provide your name and email address in order to complete the registration process for LE Mobile App.

Support for the LE Mobile App and how to tell us about problems

If you want to learn more about the LE Mobile App or the Service, please take a look at our Security Best Practices at Ledger Enterprise [Help Centre](https://help.vault.ledger.com/Content/legal/bestpractices.html).&#x20;

If you have any problems or think the LE Mobile App or the Services are faulty or misdescribed or wish to contact us for any other reason please email our customer service team at <team-tam@ledger.fr> or call us on \[TELEPHONE NUMBER].&#x20;

If we have to contact you, we will do so either by email, by SMS or by pre-paid post, using the contact details you have provided to us in your PaaSA or to your account manager.

In return for your agreeing to comply with these Terms you may:

• download and use the LE Mobile App onto blue-tooth compatible devices actively supporting up to date versions of iOS and Android operating systems to view, use and display the LE Mobile App and the Service on such devices for commercial purposes only. Ledger does not guarantee compatibility with all devices or operating system versions.

• use any documentation and the Security Best Practices to support your permitted use of the LE Mobile App and the Service.

• provided you comply with the terms of your PaaSA with us, receive and use any free supplementary software code or update of the LE Mobile App incorporating "patches" and corrections of errors as we may provide to you.

<br>

BEFORE USING LE MOBILE APP , PLEASE EDUCATE YOURSELF TO MAKE INFORMED DECISIONS. LEDGER DOES NOT PROVIDE FINANCIAL, TAX, OR LEGAL ADVICE. LEDGER DOES NOT CUSTODY, EXCHANGE, SEND, OR RECEIVE DIGITAL ASSETS FOR USERS.  LEDGER DOES NOT ADVISE OR MAKE RECOMMENDATIONS ABOUT ENGAGING IN DIGITAL ASSET TRANSACTIONS OR OPERATIONS. DECISIONS TO ENGAGE IN TRANSACTIONS OR PERFORM OPERATIONS INVOLVING DIGITAL ASSETS SHOULD BE TAKEN ON YOUR OWN OR RELY ON OPINIONS OF YOUR OWN RELIABLE AND QUALIFIED EXPERTS.

### 2. Definitions

The following capitalized terms shall have the meanings described below when used in these Terms, it being specified for the avoidance of doubt that in these definitions, reference to the singular includes a reference to the plural and vice versa, except when clearly inappropriate. Terms used but not specifically defined herein shall have the meanings ascribed to them in your PaaSA with us. In the event of any conflict between these Terms, and your PaaSA, in connection with Vault Services, the terms of your PaaSA shall prevail over these Terms.&#x20;

“Affiliate” means, with respect to any legal entity, any other legal entity controlling, controlled by, or under common control with, such legal entity; it being specified that “control”, “controlling” or “controlled” means the possession, direct or indirect, of the power to direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities, by contract or otherwise.

“Anti-Corruption and Anti-Money Laundering Regulations” means all applicable regulations, laws, rules or guidelines in connection with bribery and corruption, money laundering and counter-terrorist financing issued, administrated or enforced by any relevant Authority.

“Authority” means any competent governmental, administrative, supervisory, regulatory, judicial, disciplinary, authority, agency, commission, board, organisation, court or tribunal of any jurisdiction, whether supranational, national, federal, regional or local and any subdivision, department or branch of any of the foregoing.

“IP Rights” means patents, inventions, trademarks, service marks, trade names, logos, domain names, business names, rights in designs (including registered and unregistered designs and design rights), copyright (including rights in computer software), semiconductor topography rights, database rights and all other intellectual property rights, in each case whether registered or unregistered and including applications for grant of any of the foregoing and all rights or forms of protection having equivalent or similar effect to any of the foregoing which may subsist anywhere in the world now or in the future together with all (a) rights to the grant of and applications for the same and (b) corresponding applications, re-issues, extensions, divisions and continuations of the aforesaid.

“Ledger” or “us”, “we”, “our” means Ledger SAS, and where appropriate, other entities that are part of the Ledger group of companies and which are set out in the table above.

“Ledger Hardware Device” means a secure dedicated device provided by Ledger or Affiliates of Ledger for the purposes of Ledger Enterprise services.

“Representatives” means, in relation to a party, (a) its Affiliates and (b) any director, officer, employee, agent, consultant, shareholder or any other person acting on its behalf (as applicable) of such party or of any of its Affiliates.

“Sanctioned Person” means a person that is targeted by or subject to a Sanction.&#x20;

“Sanctions” means: (a) economic or financial sanctions or trade embargoes imposed, administered or enforced from time to time by (i) the U.S. government and administered by the U.S. State Department, the U.S. Department of Commerce or the U.S. Department of the Treasury’s Office of Foreign Assets Control, (ii) the United Nations Security Council, (iii) the European Union, (iv) France and any other European Union Member state or (v) Her Majesty's Treasury of the United Kingdom; and (b) economic or financial sanctions or trade embargoes imposed, administered or enforced from time to time by or any other relevant sanctions authority.

“Services” mean the services accessible through the Platform (as defined in the PaaSA) consisting of (i) visualizing Assets and Transactions (including past and pending Transactions) linked to Customer’s Accounts, (ii) Limited functions and features connected to your Vault Services, namely initiating, reviewing, approving and rejecting Transactions.&#x20;

“Third Party Services” refers to any Services provided directly to you by third parties such as TRADELINK.&#x20;

“TRADELINK Risk and Security Best Practices” means the set of rules and best practices set forth at the following page: <https://ledger-enterprise-api-portal.redoc.ly/developer-portal/docs/tradelink/best_practices/>&#x20;

### 3. Eligibility

The LE Mobile App is for commercial purposes only and not available for personal use. To be eligible to use the Services in LE Mobile App, you must be at least 18 years old or qualify as an adult in your country of residence. If you are accessing LE Mobile App on behalf of a legal entity, you further represent and warrant that: (a) the legal entity is duly organized and validly existing under the applicable laws of the jurisdiction of its organization; and (b) you are duly authorised by such legal entity to act on its behalf. You can only use the Services if permitted under the laws of your jurisdiction. Please make sure that these Terms are in compliance with all laws, rules, and regulations that apply to you.

3.1 You may not transfer the LE Mobile App to someone else

We are giving you the right to use the LE Mobile App and the Service as set out herein. You acknowledge and agree you may not otherwise transfer the LE Mobile App or the Service to someone else, whether for money, for anything else or for free. If you change any mobile device on which the LE Mobile App is installed, you must remove the LE Mobile App from it.

### 4. Risks and recommendations

You acknowledge that you are fully aware of all applicable laws and technical constraints relating to the proof-of-stake and proof-of-work blockchains, and to the Services. You acknowledge that you have been warned of the following associated risks and advised of the following recommendations:

4.1 Regulatory changes. Blockchain technologies and related services are subject to continuous regulatory changes and scrutiny around the world, including but not limited to anti-money laundering and financial regulations. You acknowledge that LE Mobile App and certain Services, including their availability, could be impacted by one or more regulatory requirements.

4.2 Tax. Transactions or operations in Digital Assets, or more generally Digital Assets events, including but not limited to exchanges, air-drops, forks, and gains arising from staking, may be considered tax events according to the legislations law under which you are subject to taxation. These rules may be unclear or subject to change, and you are therefore encouraged to consult your own tax or accounting adviser before engaging into Digital Assets activities.

4.3 Technology. Users understand that some of the technology supported or made available through the LE Mobile App are new, untested and not provided by Ledger and therefore outside of Ledger’s control. Advances in cryptography, or other technical advances such as the development of quantum computers, could present risks to blockchain networks which could result in the theft or loss of Digital Assets. Other adverse changes in market forces or in the technology, broadly construed, may prevent or compromise Ledger’s performance under these Terms.

4.4 Cybersecurity. Hackers or other groups or organizations may attempt to interfere with LE Mobile App and Ledger’s products and information systems in several ways, including without limitation denial of service attacks, side-channel attacks, spoofing, smurfing, malware attacks, or consensus-based attacks.

4.5 Underlying blockchain protocols. All Transactions created through the Services are confirmed and recorded on blockchain networks. Such networks are decentralized peer-to-peer networks run by independent third parties, which Ledger does not own, control or operate. We have no control over blockchain networks and, therefore, cannot and do not ensure that the Transactions you broadcast on the Services will be confirmed and processed. You acknowledge that we do not store, send, or receive Digital Assets on your behalf and you agree that the Transactions you configure through the Services may fail, or may be substantially delayed by the underlying blockchain networks. On occasions, the blockchain protocol of a given Digital Assets may change, which may have consequences on its key characteristics including but not limited to their availability, name, security, valuation value or the way it operates. Forks entail that forked Digital Assets may be misdirected or replicated. In any such events, Ledger may decide, at its discretion, to suspend support of the impacted Digital Assets for as long as Ledger deems necessary. When it so decides, Ledger will endeavor to give you advance notice, but may not be able to. You should keep yourself apprised of such events and make all necessary arrangements.

4.6 No retrieval of Seeds or Master Seed. Ledger operates non-custodial services, which means that we do not store, nor do we have access to your Digital Assets nor your Master Seed. Ledger does not have access to or store passwords, Seeds, Master Seed, passphrases, transaction history, PIN, or other credentials associated with your use of the Services. You are solely responsible for remembering, storing, and keeping your credentials in a secure location, away from prying eyes. Any third party with knowledge of one or more of your Seeds, Master Seed or PIN can gain control of the Master Seed associated with your Ledger Hardware Device or of the Wrapping Key, and therefore steal your Digital Assets, without any possibility for you or Ledger to retrieve them.

4.7 Keep your credentials safe. When you set your Ledger Hardware Device up, you must: (a) create and remember a strong PIN that you do not use for any other service; (b) protect and keep your Seeds secure and confidential; (c) protect access to your Ledger Hardware Device; To learn more about how to use and secure your Seeds, we recommend that you visit ledger.com and in particular, or visit Ledger’s website and in particular, [this page](https://www.ledger.com/academy/crypto/what-is-a-recovery-phrase), or the “Learn” section in Ledger Enterprise and our support Website [here](https://support.ledger.com/hc/en-us/articles/360005514233?docs=true). The user shall comply with good governance practices for establishing its Rules and implement organizational measures accordingly, notably in order to prevent lock-out in case of insufficient availability of authorised Users or in case of insufficient availability of usable Ledger Hardware Devices in accordance with the Annex 2 to this PAASA – [Security Best Practice of this Agreement](https://help.vault.ledger.com/Content/legal/bestpractices.html).

4.8 Do not trust. Verify. Software integrity, especially when connected to the Internet, is very hard to verify. Ledger’s security model relies on a trusted display. This is why the verification of the information on your Ledger Hardware Device is paramount when using LE Mobile App. Before you approve an operation, you must always double check that the information displayed on your mobile device or desktop screen is correct and matches the information displayed on your Ledger Hardware Device. Upon sending Digital Assets, you are solely responsible for verifying that the recipient address, amount and fees are correct and that they are the same on both your computer or mobile and on your Ledger Hardware Device’s screen. You also acknowledge that using unverified addresses to receive Digital Assets comes at your own risk.

4.9 Learn more about crypto and the risks involved. Before using Ledger Enterprise  or any of Ledger Hardware Devices, it’s important to learn and understand [how to use your Digital Assets and the risks involved](https://www.ledger.com/academy). To help you with that, Ledger recommends that you visit the [Ledger Academy](https://www.ledger.com/academy) before starting your crypto journey.

4.10 No liability. There may be additional risks that we have not foreseen or identified in these Terms. Before you use the LE Mobile App, you are strongly encouraged to carefully assess whether your financial situation and risk tolerance is compatible with such use. For the avoidance of doubt, and notwithstanding the generality of the Limitation of Liability under these Terms, you hereby agree that Ledger shall have no liability for any loss that incurs as a consequence of the risks highlighted in this section and/or your failure to follow the recommendations herein.

### 5. Services and features

<br>

#### 5.1 Services Overview

5.1.1 Description. LE Mobile App, in connection with Ledger Hardware Devices, provides you with a convenient and secure way to manage your Services, access and use Third Party Services, as well as use Seeds derived from your Master Seed.

With LE Mobile App, you can enable your Operators and Administrators using the Services in accordance with Rules to approve or reject Transactions and the following: (including without limitation)

* Allows users to receive notifications when new requests are available
* Update the firmware of your Ledger Hardware Device&#x20;
* Install and uninstall device applications with the Ledger Enterprise Manager
* View the balance of your portfolio of Digital Assets that you hold in self-custody
* View, approve or reject requests and pending requests
* Manage your NFTs
* Learn about Digital Assets, how to secure them and how to use them
* Keep track of cryptocurrency prices in real time
* Access the means to perform operations via our Third Party Services on various blockchain networks in accordance with their respective protocol rules, such as but not limited to:
* * Send and receive Digital Assets to and from users of a dedicated blockchain network
  * Stake your Digital Assets on Proof-Of-Stake networks

5.1.2 Service limitations. You acknowledge that the LE Mobile App is strictly limited in its functions to reviewing, approving or rejecting requests in connection with Transactions that have been initiated . It does not enable users to create transactions or generate new requests within the LE Mobile App and does not provide access to other Ledger Vault functionalities and Vault Services available on the desktop solution Platform.

5.1.3 Services availability. We may change, update or suspend the Services, temporarily or indefinitely, so as to carry out works including, but not limited to: firmware and software updates, maintenance operations, amendments to the servers, bug fixes, etc. We will make reasonable efforts to give you prior notice of any significant disruption of the Services. Ledger does not guarantee the correct functioning of the Services in the event of the installation or use of programs or applications that do not conform to Service specifications and technical standards. Please note that when a Service is unavailable or suspended, you can always recover your Seed using your Master Seed on any compatible Wallet.

5.1.4 Connect with your Ledger Hardware Device. Certain Services may be used without connecting your Ledger Hardware Device (such as access to learning content, monitoring cryptocurrency prices or view the balance of your portfolio) whereas other Services may only be used in connection with your Ledger Hardware Device, including without limitation send, buy, sell, swap and stake services.

#### 5.2 Third Party Services

5.2.1 Third Party Services terms and conditions. LE Mobile App may incorporate, reference and/or provide access to Third Party Services. For instance, buy, sell and crypto to crypto exchange (“swap”) services are Third Party Services. You agree that your use of Third Party Services is subject to separate terms and conditions between you and the third-party identified in LE Mobile App. &#x20;

5.2.2 Availability of the Third Party Services. The availability of each Third Party Service depends on the country from which you are using Ledger Enterprise  and the version - desktop or mobile - of Ledger Enterprise. As a result, Ledger is not responsible for the unavailability of a Third Party Service due to your geographical situation or the device employed to use Ledger Enterprise.&#x20;

5.2.2 No warranty. Ledger is not responsible for the content, accuracy, security, availability, any performance, or failure to perform of the Third Party Services or any issue in relation with the use of Third Party Services. Ledger does not provide any guarantees that access to Third Party Services will not be interrupted or that there will be no delays, failures, errors, omissions, corruption or loss of transmitted information, data or funds, and Ledger shall not be liable for any such Third Party Services. You agree to use the Third Party Services at your own risk. It is your responsibility to review the third party’s terms and policies before using a Third Party Service. Third Party Services may not be available in all languages and may not be appropriate or available for use in any particular location. To the extent you choose to use such Third Party Services, you are solely responsible for compliance with any applicable laws in relation to such use. In addition, Ledger reserves the right to block access to these Third Party Services through Ledger Enterprise  in particular, but not exclusively, in the event of non-compliance with the applicable regulations by the Third Party partner. We retain the exclusive right to suspend, remove, or cancel the availability of any such Third Party Service for any reason and without prior notice.

5.2.3 Personal data. Some Third Party Services may request or require access to your personal data. The processing of such data will be handled in accordance with the relevant Third Party’s privacy policy and best practices. To the extent that (i) you elect to access any Third Party Services, and (ii) it is important for the smooth functioning of the Third Party Service for Ledger or any of its Affiliates to share or transmit your data, you hereby authorise and consent to Ledger or any of its Affiliates sharing only such data as is necessary to ensure the smooth functioning of the relevant Third Party Service.  Some Third Party Services may also request or require access to your personal data.  The processing of such data will be handled in accordance with the relevant third party’s privacy policy and best practices.

5.2.4 Issues with Third Party Services. Third Party Services may not work appropriately with your software or Ledger Hardware Device, and we may not be able to provide support for issues caused by Third Party Services as Ledger does not provide nor operate the Third Party Services. If you have questions or concerns about how a Third Party Service operates, or need support, please contact the relevant third party directly.

5.2.5 Decentralized financial applications. Certain Third Party Services are not operated by identified entities, but can be accessed directly through an interaction between the User’s wallet (whether or not the User uses LE Mobile App or the Ledger Hardware Device) and one or several programs that are solely deployed and accessible on a blockchain network (i.e. “smart contracts”). These Third Party Services allow you to benefit from various services (such as the exchange, lending or borrowing of Digital Assets) without having to provide your personal information to an intermediary. By using these Third Party Services, you agree that their use may not be subject to terms and conditions nor any other kind of contractual relationship with the third party operating such operator of the service. To the extent you choose to use such Third Party Services, you acknowledge that Ledger is not responsible for any issue in relation with the use of such Third Party Services, including any loss of funds.

5.2.6 Fees. The use of certain Third Party Services may be subject to transaction fees and/or other fees charged by such Third Party Services. On top of such fees, Ledger reserves the right to charge you fees for the secured and facilitated access provided by Ledger to use such Third Party Services through the LE Mobile App  (“Ledger Fees”). Ledger Fees may be charged directly to the User or indirectly if already included in the Third Party Fees and paid by the Third Party to Ledger on behalf of the User. In such an event, Ledger will (to the extent practicable) display all applicable fees and any applicable taxes. Cancellation for any Third Party Service is subject to separate applicable terms and conditions provided by third parties for Third Party Services.  Unless otherwise stated in separate terms and conditions, you may have to pay for any complete Third Party Services you received before cancellation.

5.2.7 Transaction Representations. When using LE Mobile App, you represent that all Transactions you or your Affiliates perform:

* comply with applicable Anti-Corruption and Anti-Money Laundering Regulations; and
* are not made to or from any person or public key address that is owned, identified or referable to any person, designated as a “Specially Designated National” by the US Office of Foreign Assets Control, or otherwise subject to any Sanctions or restrictions.
* You acknowledge and authorise Ledger (either directly or through a third party with whom Ledger has a confidentiality agreement) to screen and monitor transaction data to prevent fraud and other suspicious transactions, and in order to comply with applicable law.  This includes conducting screening of persons and public key addresses against various sanctions and politically exposed persons lists, querying information contained in public sources and records, querying information contained in any transaction.&#x20;

### 6. Acceptable Use&#x20;

6.1 User License. As a user of the Services, we grant you a limited, personal, non-commercial, non-exclusive, non-transferable, and revocable license to use the Services. Any use of the Services other than as specifically authorised in these Terms, without our prior written permission, is strictly prohibited and may result in immediate termination of your license to use the Services. We may end your rights to use the LE Mobile App and Services at any time by contacting you if you have broken these Terms in a serious way. If what you have done can be put right we will give you a reasonable opportunity to do so.

6.2 Do no harm. You agree (i) not to distribute any virus or other harmful computer code through Ledger’s systems, (ii) not to use any robot, spider, crawler, scraper or other automated means or interface not provided by us to access the Services or to extract data, (iii) not to provide false, inaccurate, or misleading information, and (iv) not to take any action that may impose an unreasonable or disproportionately large load on our or any of our third party providers’ infrastructure.&#x20;

6.3 Don’t circumvent our security. You agree not to bypass, circumvent, or attempt to bypass or circumvent any measures that we may use to prevent or restrict access to the Services including, without limitation, Ledger Hardware Devices connected to the Services, other accounts, information systems, or networks.

6.4 Don’t break the law. You agree that you will not violate any laws when using the Services. This includes any local, provincial, state, federal, national, or international laws that may apply to you. You agree that you will not use the Services to pay for, support, or otherwise engage in any illegal activities including, but not limited to, fraud, illegal gambling, money laundering, or terrorist activities. You further agree not to encourage or induce any third party to engage in any of the activities prohibited under this section.&#x20;

6.5 Don’t interfere. You agree that, where applicable, you will not use or attempt to use another user’s LE Mobile App login credentials without authorization, or use LE Mobile App in any manner that could interfere with, disrupt, negatively affect, or inhibit other Users from fully enjoying LE Mobile App, or that could damage, disable, overburden or impair the functioning of LE Mobile App in any manner.&#x20;

6.6 External Resources.  In the case you are provided with links to external resources while browsing or using LE Mobile App, use them carefully as they are outside of our control. You acknowledge Ledger cannot be held responsible for any failures or damages caused by a third-party resource.

6.7 Intellectual Property. Ledger respects the intellectual property of others and we ask our Users to do the same.  Ledger and its Affiliates exclusively own all rights, title, and interest in and to LE Mobile App including, but not limited to, (i) associated intellectual property rights and know-how (as well as the look and feel pertaining to LE Mobile App); (ii) all derivative works, improvements or modifications; (iii) all deliverables, material or documentation provided under this Agreement; (iv) all feedback, suggestions, or ideas provided to Ledger and/or its Affiliates relating to LE Mobile App during the term.  Except for the limited license rights explicitly set forth in the Agreement no right, title, or interest in or to the above list is granted or otherwise transferred to a user of LE Mobile App.  All names of the tools developed by Ledger or any member of the Ledger group of companies, and their derivatives shall be and remain the exclusive property of such Ledger companies which may decide to protect the names in any matter that it deems fit including as a brand name, trademark and/or domain name.  The trademarks, service marks and logos of Ledger and others used via LE Mobile App are the property of Ledger and their respective owners. It is strictly prohibited to use these Trademarks without our express written authorisation or those of their owners.

### 7. USE OF LE Mobile App

7.1  You acknowledge that Ledger has no obligation to monitor any transactions and accept that you are responsible for ensuring the compliance of any transactions with applicable law.  This applies notwithstanding any visibility Ledger may have in relation to those transactions, any monitoring that it undertakes for its own purposes, and any other steps it takes pursuant to its own legal obligations or internal policies and procedures.

7.2  In addition to the foregoing, subject to the express prior written consent of Ledger, you may also facilitate and manage access for other third parties for which you act as a “custodian” and you may authorise, under your sole responsibility, a limited number of representatives from such third parties to act as operators for such access.  This section does not create any rights for such third parties, or any obligation on Ledger to such third parties and you acknowledge that Ledger shall have no liability to such third party, however based or caused.

7.3  To the extent you facilitate and start managing access for other third parties for which you act as a “custodian”, it is Your sole responsibility to ensure, and you will procure, that such third parties will comply with substantial terms and conditions of this Agreement governing the use of LE Mobile App, including with no limitation, Security Best Practices. You agree that Ledger does not owe a duty of care to such third parties, and you agree to include this in your documentation with them.&#x20;

7.4  To the extent permitted by applicable law, you shall defend, indemnify and hold harmless Ledger and any of its Affiliates, directors, officers, representatives, employees, and agents from and against any and all losses, claims, demands, liabilities, damages, penalties, fines, taxes, costs and expenses (including without limitation reasonable attorneys’ fees and court costs) arising out of or in connection with (i) any breach by you of any of your obligations under this section 7; (ii) any claim by any third party for any losses or damage suffered by such third party arising out or incurred as a result of or in connection with its use, or inability to use, LE Mobile App, or your role as custodian for such third party, whatever the cause of such loss or damage, unless such third party losses or damages were caused exclusively by Ledger's gross negligence or willful misconduct; (iii) any breach of these Terms or your unauthorised or illegal use of LE Mobile App and any Third Party Services available through LE Mobile App.

7.5  You shall not, and shall not permit others to:

1. make any portion of LE Mobile App available for access by third parties, except as otherwise expressly authorised or provided under this Agreement;&#x20;
2. access or use LE Mobile App for the purpose of developing competing products or services, and/or reverse engineer, decompile, disassemble, copy, or otherwise attempt to derive source code or other trade secrets from or about LE Mobile App or technologies, unless and then only to the extent expressly permitted by applicable law or applicable terms and conditions, without prior written consent from Ledger; and&#x20;
3. interfere with or disrupt the integrity, operation, or performance of LE Mobile App.

7.6 You acknowledge and agree that your access to LE Mobile App and any associated Confidential Information is granted solely for a specific and limited purpose. For the purposes of this section, Confidential Information refers to any information, whether provided through LE Mobile App or related to its activities, including but not limited to financial, marketing, operational, or other non-public information that is not generally known or publicly available. Such information shall be considered confidential and treated as such, either by its nature or by explicit designation.  &#x20;

7.7 You shall not use LE Mobile App or any portion thereof to engage into or support any illegal activity under applicable laws.  You shall indemnify and hold harmless Ledger (to the extent permitted by applicable laws) against all losses and liabilities accruing to Ledger by reason of a breach by you of this Section 7.

### 8. Feedback

We welcome feedback, comments, ideas, and suggestions for improvements to the Services (“Feedback”). You grant to us a non-exclusive, worldwide, perpetual, irrevocable, fully-paid, royalty-free, sublicensable and transferable license under any and all intellectual property rights that you own or control to use, copy, modify, create derivative works based upon and otherwise exploit the Feedback for any purpose.

### 9. Warranties and Disclaimers

9.1 No warranty. Ledger will use a reasonable level of skill and care to ensure that the LE Mobile App can be accessed by you in accordance with the Agreement, but there are no guarantees that access and features will not be interrupted or that there will be no delays, failures, errors, omissions, corruption or loss of transmitted information. The LE Mobile App and its intellectual property are provided “as is” without any warranty of any kind, either express or implied, and in particular without implied warranties of merchantability, reliability, and fitness for a particular purpose.&#x20;

9.2 Limitation of Liability. YOU EXPRESSLY UNDERSTAND AND AGREE THAT LEDGER AND ITS DIRECTORS AND EMPLOYEES SHALL NOT BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING, BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR OTHER INTANGIBLE LOSSES, RESULTING FROM: (I) THE USE OR INABILITY TO USE THE LE MOBILE APP AND OR SERVICES (II) ANY CHANGES MADE TO THE LE MOBILE APP AND OR SERVICES OR ANY SUSPENSION OR CESSATION OF THE LE MOBILE APP AND OR SERVICES OR ANY PART THEREOF; (III) THE UNAUTHORISED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (IV) THE DELETION OF, CORRUPTION OF, OR FAILURE TO STORE AND/OR SEND OR RECEIVE YOUR TRANSMISSIONS OR DATA ON OR THROUGH THE LE MOBILE APP AND OR SERVICES; AND (V) ANY OTHER MATTER RELATING TO THE LE MOBILE APP AND OR SERVICES. SAVE FOR THIRD PARTY SERVICES WHICH ARE NOT OPERATED OR PROVIDED BY LEDGER, THE ABOVE LIMITATIONS DO NOT APPLY IN RESPECT OF LOSS RESULTING FROM (A) LEDGER’S FRAUD, WILFUL MISCONDUCT OR GROSS NEGLIGENCE, WILFUL MISCONDUCT OR FRAUD; OR (B) DEATH OR PERSONAL INJURY.

9.3 Responsibility for assets. You are solely responsible for safeguarding your Digital Assets and Ledger has no duty to you or any user except as otherwise provided under this Agreement.  Ledger will never take custody over any of your Digital Assets.

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### 10. Compliance and Export Control

10.1 Sanctions. Users shall comply, at their own expense, with all laws that apply to or result from their obligations under these Terms. By accessing and using the LE Mobile App, you represent and warrant that you are not on any trade or economic sanctions lists, such as (but not limited to) the UN Security Council Sanctions list, designated as a “Specially Designated National” by OFAC (Office of Foreign Assets Control of the U.S. Treasury Department) or placed on the U.S. Commerce Department’s “Denied Persons List” or the consolidated list of persons, groups and entities subject to financial Sanctions maintained by the European Union. Furthermore, Users are prohibited from using Ledger Enterprise  and Ledger Hardware Devices to engage in transactions prohibited by Sanctions, including Sanctions imposed by the U.S. Treasury Department or the European Commission.

10.2 Territories. Ledger reserves the right to select the markets and jurisdictions where it operates and may restrict or deny access to Services in certain countries, states or territories.

### 11. Term and Termination - Suspension

TERM AND TERMINATION

11.1 The Terms will continue to apply as long as you use LE Mobile App and have an active PaaSA with us.  In its sole discretion, Ledger reserves the right to:

* suspend or terminate (or request applicable third parties to suspend or terminate) your access to LE Mobile App at any time, including in the event of your actual or suspected unauthorised use of LE Mobile App or non-compliance with the Agreement;
* suspend or terminate (or request applicable third parties to suspend or terminate) your access to LE Mobile App and/or Third Party Services, cancel the ability (or request applicable third parties to cancel the ability) to use the LE Mobile App or any Third Party Services made available through LE Mobile App if we notice any activity we believe fraudulent, improper, or unlawful or if we have reason to believe there has been a breach of these Terms;
* suspend or terminate (or request applicable third parties to suspend or terminate) your access to LE Mobile App to comply with applicable laws.

11.2 If you, Ledger or applicable third parties providing Third Party Services suspend or terminate your access to, or use of, LE Mobile App or any services provided by Third Party Services, subject to applicable laws and unless otherwise expressly stated in these Terms, you agree that Ledger shall have no liability or responsibility to you or other third parties. &#x20;

11.3 Sections of these Terms that, either expressly or by nature, must remain in effect even after termination of these Terms, shall survive termination.

### 12. Governing law and jurisdiction

12.1 Governing Law. These Terms, and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws stated in Article 22 of the PaaSA between the Parties, (the "Governing Law  - Jurisdiction Clause"). The provisions of the Governing Law - Jurisdiction Clause of the PaaSA are hereby incorporated by reference and shall apply mutatis mutandis to these Terms.

12.2. Jurisdiction. The parties irrevocably agree that the courts stated in Governing Law Jurisdiction Clause of the PaaSA, shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms or their subject matter or formation (including non-contractual disputes or claims). The provisions of the Governing Law - Jurisdiction Clause of the PaaSA are hereby incorporated by reference and shall apply mutatis mutandis to these Terms.

12.3 Interpretation. For the avoidance of doubt, the intention of this clause 12 of these Terms is that the same body of law and the same exclusive jurisdiction agreed upon by the Parties in the PaaSA for the resolution of disputes arising under that agreement shall equally apply to the interpretation, validity, performance, and enforcement of these Terms.

### 13. General

13.1 Entire Agreement. These Terms constitute the entire and exclusive understanding and agreement between Ledger and you regarding Ledger Enterprise , and supersede and replace any and all prior oral or written understandings or agreements between Ledger and you regarding Ledger Enterprise . If you do not read and accept the Terms in their entirety you should not use or continue using Ledger Services.

13.2 Changes to the Terms. We reserve the right to alter, amend or modify these Terms from time to time, in our sole discretion, due to legislative or regulatory measures, technical developments, any change or improvement of the LE Mobile App or Services including security reinforcement of the LE Mobile App or Services. We will provide you with notice of such changes through Ledger Enterprise  and such changes shall apply immediately upon your acceptance or within one (1) month upon notice of changes at the latest. In any case, if you do not accept the changes, you must cease to use the LE Mobile App or Services.

13.3 Assignment. You may not assign your rights or obligations under these Terms in whole or in part to any third party. You acknowledge and agree that Ledger may assign its rights and obligations under these Terms of Use and, in such context, share or transfer information provided by you while using the LE Mobile App and or Services to a third party.

13.4 Severability. Should any provision of these Terms or part thereof to any extent be or become invalid or unenforceable, such provision shall then be deemed separable from the remaining provisions of these Terms and shall not affect or impair the validity or enforceability of the remaining provisions of these Terms.

13.5 Force Majeure.  Ledger shall not be liable for non-performance or delays in performance that result from causes that are beyond its reasonable control and not attributable to its own acts or omissions, such as acts of God, fire, strikes, embargo, acts of terrorism, acts of government, insurrection or riots, aircraft impact, embargoes, storm, tempest, lightning, flood, drought, earthquake, health epidemics, general outbreak of debilitating disease requirements or regulations of any Authority (including, without limitation, sanctions, travel bans, lockdown measures, trade restrictions and embargoes) or any other similar causes beyond its reasonable control.

13.6 Language.  These Terms may be translated and made available into different languages.  Notwithstanding their translation, you agree that, in the event of a dispute arising out of or relating to these Terms, only the English version of the Terms shall be referred to and prevail.

Last updated 15 May 2025
