General terms and legal information for DeFi-MC users

Contracting parties: NORRIS-systems UG (haftungsbeschränkt) – hereinafter the “provider” – and the user of the DeFi Marketing Center – hereinafter the “user”.

I. General terms and conditions (GTC) for DeFi-MC users

1. Preamble and subject matter

The provider operates the DeFi Marketing Center (DeFi-MC), a technical infrastructure based on the Xoto framework. DeFi-MC supports partners organisationally and in marketing – reach, content creation, and connection to common online channels.

The agreed scope of services includes in particular tools for search engine optimisation (SEO), AI-assisted text creation, GEO-marketing features, and interfaces and storage for social-media auto-posting, as described in the relevant product or plan.

Important notice: The provider is not a financial services institution and does not offer DeFi-MC as a licensable investment intermediary service. In particular, DeFi-MC does not provide investment advice, individual investment recommendations, portfolio management, or banking or payment services.

2. Mail hub and account setup

The provider may set up email accounts for the user in a technically supported or automated way (“registration mailboxes” or comparable system mailboxes). These serve mainly as a technical interface for registration and verification with third parties (e.g. social networks, search or business profiles) where this is necessary for the booked features.

After the respective setup steps, captured credentials and technical parameters are stored securely in line with good practice (e.g. encryption of sensitive fields, role-restricted access). The user accesses the information visible to them via the personal dashboard or comparable interfaces within the permission model.

When setting up social media profiles and similar accounts, the provider acts as a technical service provider for the agreed fee (e.g. setup fee). The profiles, accounts, and contractual relationships with platform operators (e.g. Meta, X, LinkedIn, Google) remain in the user’s legal and discretionary control unless expressly agreed otherwise. The user remains responsible for complying with each platform’s terms of use.

3. Content and community networking

Unless otherwise agreed in writing, content produced exclusively for the user by DeFi-MC’s AI and editorial tools is intended for the user’s economic and copyright interests, subject to mandatory rules (e.g. non-waivable statutory rights).

DeFi-MC’s concept includes holistic networking of the partner community (including sensible linking and backlink structures while avoiding competition- and SEO-harmful duplicate content). For that purpose, the user grants the community a limited right of joint use where it serves the shared visibility and growth of the community and does not infringe third-party rights or individual agreements of the user.

The user may use their own attributed texts and assets extensively across platforms, subject to obligations from platform APIs, trade marks, or special agreements.

4. Limitation of liability and risk information

Investment advice / securities: DeFi-MC does not provide investment advice or securities services. The user is independently responsible (e.g. as an independent DeFi or information partner) for ensuring that their published materials and public presence comply with applicable law – including, where relevant, the German Banking Act (KWG), the Securities Institutions Act (WpIG), and other market and consumer rules.

Technology and protocol risk: The user understands that DeFi applications often rely on smart contracts and third-party protocols. The provider is not liable for losses from bugs in third-party code, severe market dislocations, failure of bridges or oracle services, or total loss of digital assets, except where mandatory liability law applies.

Disclosure to end clients: Where the user acts as a market participant themselves, they undertake to inform end clients and prospects truthfully and without misleading them about risks and legal frameworks of the traditional financial system (including resolution regimes such as the German Recovery and Resolution Act – Sanierungs- und Abwicklungsgesetz, SAG – and life insurance risks such as benefit reductions if the insurer becomes distressed under Section 314 of the German Insurance Supervision Act – VAG –, each as amended).

II. Orientation guide for independent DeFi partners (checklist)

Topic: Legally sound marketing communication

To communicate responsibly and avoid unintentionally entering licensable advice or grey areas, use the following dos and don’ts as a working aid. This is not legal advice and is not exhaustive.

✅ What is generally acceptable (education, technology, general information)

• General education on systemic risk and deposit protection: You may explain factually that banking stress can trigger regulatory measures and that, in extreme cases, resolution regimes (such as under SAG) can affect access to deposits or their restructuring – without scaremongering or impermissible promises.
• Reference to VAG Section 314: You may explain in neutral terms that if a life insurer is in distress, benefits can be reduced while contract duties on the customer may continue – without steering to specific products.
• Decentralisation and self-custody: You may factually present the benefits of self-custody of keys or assets versus third-party custody, without guarantees of return or safety.
• Technical training: You may show how to use the DeFi-MC dashboard and tools to improve reach, structure, and editorial quality – without individual investment instructions.
• Transparency on fees: You should disclose setup, recurring, or third-party costs clearly and that DeFi-MC does not collect hidden “investment fees” for a personalised single investment.

❌ What to avoid (typical liability and supervisory risks)

• Individual investment advice: Avoid lines such as “I recommend you put €500 into this coin today” or comparable personalised buy/sell recommendations without a licence.
• Client money and custody: Do not take money from end clients to “invest” or manage for them. Interaction with protocols and wallets should remain with the end client unless a separate licensable structure exists.
• Impermissible guarantees and return promises: Do not use “guaranteed”, “safe”, “fixed interest”, or similar absolutes. If needed, use factual wording such as “historical yields”, “protocol rewards”, or “subject to high volatility”, and mention total loss risk.
• Misleading claims and greenwashing: Do not claim unproven regulatory “approvals” for protocols or “risk-free” DeFi.
• Duplicate content: Use DeFi-MC editorial and variation tools to keep content unique. Search engines penalise mass duplication; you also reduce competition-law friction within the community.
• Hiding risk notices: Do not omit clear risk information (volatility, smart-contract risk, regulatory change) when presenting digital assets.

This overview is for orientation of DeFi-MC users. For specific legal questions, consult qualified counsel.