These Stocks and Bundles Terms and Conditions were last updated on 1 October, 2026.
IMPORTANT NOTICE
These Stocks and Bundles Terms and Conditions govern your access to and use of CiNKO’s Stocks Services. Please read them carefully before placing any Order. When you buy a stock through the CiNKO Platform, you do not buy or own shares in the company concerned. Instead, you acquire an entitlement to a Stock Token, which is a digital asset issued by a third party and designed to track the economic value of a publicly listed share or fund. Stock Tokens do not give you voting rights or other shareholder rights. The value of Stock Tokens can go down as well as up, and you may get back less than you paid. The Stocks Services are not bank deposits, savings products, brokerage accounts, or principal-protected investments, and are not protected by any government deposit insurance or investor compensation scheme. If you do not understand or do not agree to these terms, you should not use the Stocks Services.
PART 1 - INTRODUCTION AND SCOPE
1.1 About These Stocks Terms
These CiNKO Stocks and Bundles Terms and Conditions (the “Stocks Terms”) govern your access to and use of the Stocks Services available through the CiNKO Platform provided by Digital Finance (Bahamas) Ltd. (“we,” “us,” or “our”), which operates under the CiNKO brand.
These Stocks Terms form part of CiNKO’s General Terms and Conditions (the “General Terms”) and should be read in conjunction with them. Capitalized terms used in these Stocks Terms that are not defined herein have the meanings given to them in the General Terms. In the event of any inconsistency between these Stocks Terms and the General Terms regarding the Stocks Services, these Stocks Terms shall prevail.
By accessing the Stocks Services or placing any Order, you agree to be bound by these Stocks Terms.
1.2 Covered Services
These Stocks Terms govern your access to and use of CiNKO’s Stocks Services, which allow you to:
acquire, hold, and sell Stock Positions through the CiNKO Platform; and
group and manage your Stock Positions together in one or more Bundles.
The Stock Tokens currently available through the Stocks Services, and the specific terms applicable to them, are described in Schedule 1. The terms applicable to Bundles are described in Schedule 2. Each Schedule forms part of these Stocks Terms and sets forth the specific terms, mechanics, fees, and risk disclosures applicable to it.
We may add, modify, or remove Stock Tokens, Token Issuers, or features of the Stocks Services at any time. New or modified Stock Tokens, Token Issuers, or features will be described in a new or updated Schedule to these Stocks Terms, or in service-specific disclosures available through the CiNKO Platform. The addition or removal of a Schedule does not require an amendment to these Stocks Terms.
1.3 Nature of the Stocks Services
The Stocks Services are digital asset services that allow you to use compatible Digital Assets held in your CiNKO Account to acquire Stock Tokens, hold them in our custody, and sell them. Each Stock Token is a digital asset issued by a Token Issuer and designed to provide economic exposure to the price of an Underlying Security, as described in the applicable Schedule.
When you acquire a Stock Position, you do not acquire the Underlying Security or any legal or beneficial interest in it. You do not become a shareholder of the company or fund that issued the Underlying Security, and you have no right to vote, attend shareholder meetings, receive dividends in cash, or participate in corporate actions, except as expressly described in the applicable Schedule.
The Stocks Services are not and do not constitute:
a bank deposit, savings account, or deposit-taking service;
a brokerage or securities account, or the purchase, sale, or holding of shares or other securities in your name;
an investment with guaranteed capital or principal protection;
an investment fund, collective investment scheme, or managed investment product;
a discretionary or advisory portfolio management service;
investment advice, financial advice, or any other form of professional advice; nor
a product with a guaranteed or fixed return of any kind.
The value of your Stock Positions may go down as well as up, and the amount you receive when you sell a Stock Position may be less than the amount you paid. You should carefully read the risk disclosures in Part 5 and the product-specific risk disclosures in the applicable Schedule before placing any Order.
1.4 Our Role
We provide the Stocks Services on an execution-only basis. We make Stock Tokens available to you through the CiNKO Platform, arrange the acquisition and sale of Stock Tokens in accordance with your Orders, hold the Stock Tokens attributable to your Stock Positions in custody, and are responsible for the Stocks Services we provide to you under these Stocks Terms.
Stock Tokens are issued by third-party Token Issuers that are independent of us. The Underlying Securities to which Stock Tokens relate are acquired and held by or on behalf of the relevant Token Issuer through custodians and other service providers appointed by it. We are not responsible for the issuance, backing, operation, or financial soundness of any Token Issuer or its service providers, nor for the performance of any Underlying Security.
We do not select, recommend, or manage Stock Tokens or Bundles for you. Every decision to acquire, hold, or sell a Stock Position, and every decision regarding the composition, allocation, or rebalancing of a Bundle, is made by you alone.
The identity of the Token Issuer and the legal and operational structure applicable to each Stock Token are set forth in the relevant Schedule to these Stocks Terms.
1.5 Eligibility Requirements
You can only access the Stocks Services if:
you hold a verified CiNKO Account in good standing and have met all applicable identity verification and due diligence requirements;
you are not a resident or citizen of, and are not located in, a Restricted Jurisdiction;
you are legally permitted to access the Stocks Services in accordance with the laws and regulations of your country or territory of residence;
you are acquiring Stock Positions for your own account and benefit, and not on behalf of any other person or for Business Use;
you have read and understood the risks associated with Stock Tokens and Bundles, including the risk of receiving less than the amount you paid; and
you meet any additional eligibility requirements that we or the relevant Token Issuer may specify at any time through the CiNKO Platform.
Eligibility may differ between Stock Tokens. A Stock Token may be unavailable to you even if other Stock Tokens are available, where the relevant Token Issuer restricts that Stock Token in your jurisdiction.
The Stocks Services are not available to residents or nationals of any jurisdiction where they constitute an unauthorized securities, investment, brokerage, or deposit-taking activity, or where their availability is otherwise illegal. We may restrict or withdraw access to the Stocks Services, or to any Stock Token, in any jurisdiction at any time without prior notice if we determine that this is necessary to comply with applicable legal or regulatory requirements or the requirements of a Token Issuer.
By accessing the Stocks Services, you represent and warrant that you meet the eligibility requirements and that your participation is lawful in your jurisdiction. You must notify us promptly if you become resident in, or a citizen of, a Restricted Jurisdiction
PART 2 - DEFINITIONS
2.1 Definitions
In these Stocks Terms, the following terms have the meanings set forth below, unless the context requires otherwise:
“Bundle” means a collection of up to ten (10) of your Stock Positions that you create, name, and manage together through the CiNKO Platform, as described in Schedule 2.
“CiNKO Platform” or “Platform” has the meaning set forth in the General Terms.
“Custody Schedule” means Schedule 1 (Custody Schedule) of the General Terms.
“Funding Asset” means the Digital Asset used to pay for Orders to acquire Stock Positions and in which Sale Proceeds are credited, as specified in the applicable Schedule.
“General Terms” means CiNKO’s Terms and Conditions, as amended from time to time, available at https://cinko.io/en/terms-conditions.
“Off-Hours Trading” means trading in a Stock Token outside the regular trading hours of the primary market for the corresponding Underlying Security, where supported by the relevant Token Issuer, as described in the applicable Schedule.
“Order” means an instruction submitted by you through the CiNKO Platform to acquire or sell a Stock Position, including each instruction to acquire or sell a Stock Position that arises from the creation, funding, rebalancing, sale, or deletion of a Bundle.
“Restricted Jurisdiction” means the United States and any other country or territory in which the Stocks Services, or a particular Stock Token, are not available, as determined by us or the relevant Token Issuer from time to time and as reflected on the CiNKO Platform.
“Sale Proceeds” means the amount of the Funding Asset credited to your CiNKO Account upon completion of an Order to sell a Stock Position, after deduction of applicable fees.
“Stock Position” means your entitlement, as recorded in our internal ledger, to a specified quantity (which may be a fraction) of a Stock Token held by us in custody on your behalf.
“Stock Token” means a digital asset issued by a Token Issuer that is designed to track the economic value of an Underlying Security, as identified in the applicable Schedule.
“Stocks Balance” means the balance displayed on the CiNKO Platform that reflects the indicative value of your Stock Positions, including Stock Positions held within Bundles.
“Stocks Services” has the meaning set forth in Section 1.2.
“Token Issuer” means the third-party entity that issues a Stock Token and is responsible for acquiring and holding, or arranging for the holding of, the corresponding Underlying Security, as identified in the applicable Schedule.
“Underlying Security” means the publicly listed share, exchange-traded fund, or other security whose economic value a Stock Token is designed to track.
PART 3 - HOW THE STOCKS SERVICES WORK
3.1 Placing an Order
To acquire a Stock Position, you must access the Stocks section of the CiNKO Platform, select the relevant Stock Token, specify the amount of the Funding Asset you wish to use, and confirm the Order. By confirming an Order, you authorize us to use the specified Digital Assets from your CiNKO Account to acquire the corresponding quantity of the Stock Token on your behalf, in accordance with these Stocks Terms and the applicable Schedule.
Before you confirm an Order, the CiNKO Platform will display the key terms applicable to that Order, including the indicative price, the estimated quantity of the Stock Token, the applicable fees, and whether Off-Hours Trading conditions apply. You are responsible for reviewing this information carefully before confirming your Order.
Orders are executed at the price available from the relevant Token Issuer at the time of execution.
The minimum Order amounts applicable to each Stock Token and to Bundles are set forth in the applicable Schedule. We may modify the minimum Order amounts at any time.
Once you confirm an Order and execution has commenced, the Order is irrevocable. You cannot cancel or modify an Order once it has been submitted. If an Order cannot be completed due to insufficient balance, technical error, compliance review, the unavailability of the Stock Token, rejection by the Token Issuer, or any other operational constraint, the Order may be declined or reversed, and any Digital Assets debited from your CiNKO Account will be returned to it in accordance with the General Terms.
3.2 Pricing
The price at which an Order is executed is determined by the relevant Token Issuer at the time of execution. We do not set or modify that price. The price includes the Token Issuer’s own charges, which are built into the price and are not shown or charged to you as a separate item.
The price displayed on the CiNKO Platform before you confirm an Order is indicative only. The price at which your Order is executed may differ from the indicative price due to market movements, liquidity conditions, volatility, or the time taken to execute the Order (commonly referred to as “slippage”).
The price of a Stock Token may differ from the price of the corresponding Underlying Security on its primary market at the same time. This is more likely outside the regular trading hours of that market, when liquidity may be lower and the difference between buying and selling prices may be wider.
3.3 Fees
In addition to the price of the Stock Token, we charge a transaction fee on each Order, including Orders arising from the creation, funding, rebalancing, sale, or deletion of a Bundle. The transaction fee may comprise a percentage of the Order amount, a fixed amount per Order, or both. The current transaction fee is set out on the CiNKO Platform and in our FAQ at https://help.cinko.io/en/articles/8519789-fees-and-limits, and the fee applicable to each Order is displayed on the CiNKO Platform before you confirm it.
We may change the transaction fee at any time. Changes will be communicated in accordance with Section 5 (Changes to Fees and Limits) of Schedule 2 (Fees Schedule) of the General Terms and will apply only to Orders confirmed after the change takes effect. Schedule 2 (Fees Schedule) of the General Terms must be read in conjunction with these Stocks Terms.
3.4 Selling a Stock Position
You may submit an Order to sell all or part of a Stock Position at any time the relevant Stock Token is available for trading, as described in Section 3.6. When your sale Order is completed, the Sale Proceeds will be credited to your CiNKO Account in the Funding Asset.
The Sale Proceeds will be determined by the price available from the Token Issuer at the time of execution, less applicable fees, and may be less than the amount you paid to acquire the Stock Position. There is no guarantee that you will receive the full amount you paid.
3.5 No Transfer of Stock Tokens
Stock Tokens are made available on a closed-loop basis. Your Stock Positions exist only within the CiNKO Platform and can only be realized by selling them in accordance with Section 3.4. You cannot withdraw Stock Tokens from your CiNKO Account, transfer them to an external wallet or another CiNKO user, deposit Stock Tokens into your CiNKO Account from any external source, or pledge, assign, or otherwise deal with your Stock Positions. Any attempt to do so will have no effect.
These restrictions reflect transfer and eligibility restrictions imposed by the relevant Token Issuer. This means that your ability to exit a Stock Position depends on the trading availability of the relevant Stock Token and the continued operation of the CiNKO Platform.
This Section 3.5 does not prevent the transmission of your Stock Positions or their Sale Proceeds to your estate in accordance with applicable law, and does not limit our rights under Sections 6A and 8.2 of the General Terms.
3.6 Trading Availability
The availability of each Stock Token for trading follows the trading schedule of the relevant Token Issuer, which generally reflects the trading days and hours of the primary market for the corresponding Underlying Security. Certain Stock Tokens may also be available for Off-Hours Trading, as described in the applicable Schedule.
The CiNKO Platform may display an indicator of the current trading session of the primary market for an Underlying Security. This indicator is provided for information only and does not mean that your Order will be executed on, or at the price prevailing on, that market.
We do not operate our own market or matching system for Stock Tokens, and we rely on the trading availability provided by the relevant Token Issuer. When a Stock Token is not available for trading, you will not be able to place Orders to acquire or sell it. The Token Issuer may suspend, delay, or restrict trading in a Stock Token at any time, including during market disruptions, and we are not responsible for any such suspension, delay, or restriction.
3.7 Temporary Transfer of Digital Assets from Custody
When an Order is executed, Digital Assets are transferred from our custody to the relevant Token Issuer, or to a member of our group, in exchange for Stock Tokens (when you acquire a Stock Position) or for the Funding Asset (when you sell a Stock Position). During the period of transfer and execution:
the Digital Assets being transferred are not held in our custody under the General Terms or the Custody Schedule;
our custody of the relevant Digital Assets resumes once the Stock Tokens or the Funding Asset, as applicable, are received into our custody; and
the Digital Assets being transferred may be subject to blockchain network risk, counterparty risk, operational risk, and other risks associated with the Token Issuer and other third-party service providers.
Nothing in these Stocks Terms transfers ownership of your Digital Assets to us, except to the extent strictly necessary to facilitate the execution of your Order.
3.8 Stocks Balance
The Stocks Balance displayed on the CiNKO Platform is for illustrative purposes only. It reflects the estimated current value of your Stock Positions based on the most recent price data available, but may not reflect the exact Sale Proceeds you would receive if you sold your Stock Positions at any given time. The actual Sale Proceeds will be determined at the time of execution in accordance with Section 3.4 and the applicable Schedule.
PART 4 - TOKEN ISSUER, CUSTODY, AND LEGAL STRUCTURE
4.1 Token Issuer
The Stock Tokens offered through the Stocks Services are issued by Token Issuers, each of which is identified in the applicable Schedule. The identity, regulatory status, and legal structure of the Token Issuer for each Stock Token are set forth in the Schedule for that Stock Token. We will update the applicable Schedule to reflect any changes in the Token Issuer.
Token Issuers are independent of us. We do not control, manage, or have supervisory authority over any Token Issuer or any other party involved in the issuance or backing of Stock Tokens.
4.2 Backing and Legal Structure of Stock Tokens
The arrangements under which a Stock Token is backed, including the acquisition and custody of the Underlying Security, any asset segregation mechanisms, and any security or verification arrangements, are specific to the relevant Token Issuer and are described in the applicable Schedule. You should carefully read the applicable Schedule to understand the structural protections and limitations that apply to your Stock Positions.
4.3 Custody of Stock Tokens
The Stock Tokens attributable to your Stock Positions are held by us in custody in accordance with Section 7 (Custody Services) of the General Terms and the Custody Schedule.
Stock Tokens are held on an omnibus basis, together with Stock Tokens attributable to other customers, in one or more shared wallets controlled by us. Your entitlement to each Stock Token is recorded in our internal ledger. By accessing the Stocks Services, you expressly consent to us holding Stock Tokens attributable to your Stock Positions in omnibus custody arrangements, in addition to the consent you have given under Section 7.4A of the General Terms.
Your Stock Positions are your property and are not our assets, as described in Section 7.3 of the General Terms. Your ownership extends to the Stock Tokens recorded in your Stock Positions only, and not to the Underlying Securities to which they relate.
4.4 Limited Recourse
You do not have a direct contractual relationship with, or direct rights against, any Token Issuer or its custodians or other service providers. Any rights relating to the Underlying Securities, and to any security or verification arrangements described in the applicable Schedule, arise under the terms on which the relevant Token Issuer issues Stock Tokens, and are reflected in your Stock Positions only through the value of the Stock Tokens we hold for you.
Your rights against us are limited to our own obligations under these Stocks Terms, including the safekeeping of the Stock Tokens attributable to your Stock Positions and the execution of your Orders. Neither we nor any member of our group guarantees the performance of any Stock Token or Underlying Security, or the obligations of any Token Issuer.
4.5 Token Issuer’s Right to Modify and Token Events
The Token Issuer, as the issuer of the relevant Stock Token, may modify the terms applicable to a Stock Token, or may suspend, discontinue, redeem, or adjust a Stock Token, including in connection with a corporate action affecting the Underlying Security (such as a stock split, merger, delisting, or other reorganization). Corporate actions are reflected in the value or quantity of the relevant Stock Token in accordance with the Token Issuer’s terms, and not through any direct participation by you.
When we receive notification of a material change or event regarding a Stock Token:
we will notify you via the CiNKO Platform as soon as reasonably possible;
where reasonably possible, we will give you an opportunity to sell the affected Stock Positions before the change or event takes effect; and
we will update the applicable Schedule to reflect the amended terms.
If a Stock Token is discontinued or redeemed, any Stock Positions you hold in that Stock Token will be dealt with in accordance with Section 6.2.
If a change is not material - for example, a minor change to trading hours or operating procedures - we may update the applicable Schedule without individual notice.
PART 5 - RISK DISCLOSURE
The risks set forth in this Part 5 apply to all Stock Tokens and Bundles and should be read in conjunction with the general risk disclosures set forth in Section 9 of the General Terms, which also apply to your use of the Stocks Services. Product-specific risk disclosures are set forth in the applicable Schedule. You should read all three carefully before placing any Order.
5.1 No direct ownership of shares
A Stock Token is not a share or other security of the company or fund that issued the Underlying Security. You do not own the Underlying Security, you are not a shareholder, and you have no voting rights, rights to attend shareholder meetings, or rights to participate directly in corporate actions, except as expressly described in the applicable Schedule. Your economic exposure depends on the Token Issuer continuing to issue, back, and redeem the Stock Token in accordance with its terms.
5.2 Market and capital risk
The value of Stock Tokens depends on the price of the corresponding Underlying Securities, which may rise or fall significantly and rapidly, including due to company-specific events, market conditions, and economic or political developments. The Stocks Services do not guarantee the return of the amount you paid. You may lose some or all of the amount you pay for a Stock Position. You should not acquire Stock Positions unless you are prepared to accept this risk. Past performance is not indicative of future results.
5.3 Pricing and tracking risk
A Stock Token is designed to track the economic value of its Underlying Security, but its price may not match the price of the Underlying Security at any given time. Differences may arise from the Token Issuer’s charges built into the price, wider spreads outside regular market hours, lower liquidity, the timing of execution, the reinvestment of dividends net of applicable withholding tax, and the Token Issuer’s handling of corporate actions. The return you receive may therefore differ from the return you would have received by holding the Underlying Security directly.
5.4 Counterparty risk
The Stocks Services involve reliance on third parties, including Token Issuers, their custodians, exchange agents, security and verification agents, and other service providers identified in the applicable Schedule, as well as our own technology and custody service providers. The insolvency, operational failure, or regulatory action affecting any of these parties could adversely affect the value of your Stock Positions or your ability to sell them.
5.5 Liquidity and availability risk
You can only realize the value of a Stock Position by selling it through the CiNKO Platform, and only when the relevant Stock Token is available for trading. Trading in a Stock Token may be unavailable, suspended, or restricted, including outside the trading hours of the Token Issuer, during market disruptions, or when the Token Issuer suspends issuance or redemption. You may therefore be unable to sell a Stock Position at the time or price you want.
5.6 Custody and omnibus risk
Stock Tokens attributable to your Stock Positions are held by us in omnibus custody arrangements and are subject to the custody, operational, and omnibus custody risks described in Sections 9.3 and 9.4 of the General Terms. In the event of our insolvency, the return of your Stock Positions may depend on the accuracy of our records and the application of applicable insolvency laws, and may involve delays or costs.
5.7 Regulatory risk
The legal and regulatory treatment of tokenized securities and related services may change over time and may differ between jurisdictions. Changes in applicable laws, regulations, or regulatory interpretations, or in the jurisdictions in which a Token Issuer makes Stock Tokens available, may affect the availability of the Stocks Services or specific Stock Tokens in one or more jurisdictions. We may be required to modify, suspend, or discontinue the Stocks Services or a Stock Token, or to require the sale of your Stock Positions, to comply with applicable regulatory requirements, with or without prior notice depending on the circumstances.
5.8 Technological and Network Risk
Stock Tokens rely on blockchain networks, smart contracts, and third-party infrastructure that may experience congestion, outages, protocol changes, or security vulnerabilities. These events may delay or prevent the execution of Orders or affect the value of Stock Tokens.
5.9 Lack of government protection
The Stocks Services are not bank deposits or brokerage accounts and are not protected by any government deposit insurance program, insurance scheme, securities investor protection scheme, or investor compensation scheme. In the event of our insolvency or the insolvency of a Token Issuer or any of its service providers, there is no government-backed protection for your Stock Positions.
5.10 Tax risk
Dividends on Underlying Securities may be subject to withholding tax before they are reflected in the value of a Stock Token. The acquisition, holding, and sale of Stock Positions, including through the rebalancing or deletion of a Bundle, may have tax consequences for you. You are responsible for determining and paying any taxes that apply to you, in accordance with Section 8.3 of the General Terms.
5.11 Lack of guidance
We do not provide investment advice, financial advice, tax advice, or any other type of professional advice in connection with the Stocks Services. Nothing in these Stocks Terms, the CiNKO Platform, or any communication from us constitutes a recommendation, solicitation, or endorsement of any Stock Token, Underlying Security, or Bundle composition. You are solely responsible for assessing whether the Stocks Services, any Stock Token, and any Bundle you create are suitable for you, taking into account your own financial situation, risk tolerance, and investment objectives. We recommend that you seek independent professional advice if you have any questions.
PART 6 - SUSPENSION AND TERMINATION OF THE STOCKS SERVICES
6.1 Suspension by us
We may suspend your access to the Stocks Services or to a specific Stock Token, with or without prior notice, when:
required by law or applicable regulatory requirements;
we reasonably believe that the suspension is necessary to protect the security or integrity of the CiNKO Platform or the Stocks Services;
a Token Issuer suspends, restricts, or discontinues a Stock Token, or trading in it;
your CiNKO Account is suspended pursuant to the General Terms; or
we are required to manage legal, regulatory, or risk exposure.
During a suspension, you may be unable to acquire or sell Stock Positions or have otherwise limited access to the Stocks Services.
6.2 Discontinuation of a Stock Token or the Stocks Services
We may discontinue a Stock Token, or the Stocks Services as a whole, at any time for operational, regulatory, or business reasons, including where a Token Issuer discontinues or redeems a Stock Token. When we do so:
we will notify you via the CiNKO Platform as soon as reasonably possible and, where reasonably possible, before the discontinuation date;
you may sell your affected Stock Positions at any time before the discontinuation date, subject to trading availability; and
any affected Stock Positions you still hold on the discontinuation date will be sold on your behalf, or redeemed through the Token Issuer, and the resulting proceeds, less applicable fees, will be credited to your CiNKO Account in the Funding Asset.
The proceeds you receive in these circumstances will depend on the price available at the time of sale or redemption, and may be less than the amount you paid.
6.3 Change in eligibility
If you become resident in, a citizen of, or located in a Restricted Jurisdiction, or otherwise cease to meet the eligibility requirements in Section 1.5, you will no longer be able to acquire Stock Positions. We may also require you to sell your existing Stock Positions within 7 days of our notice to you, after which any remaining Stock Positions may be sold on your behalf and the Sale Proceeds credited to your CiNKO Account.
6.4 Consequences of Account Closure
If your CiNKO Account is closed or terminated pursuant to the General Terms while you hold Stock Positions, your Stock Positions will be sold on your behalf and the Sale Proceeds, less applicable fees, will be credited to your CiNKO Account, to be dealt with in accordance with Section 11.5 of the General Terms. This is subject to applicable law, compliance requirements, and the trading availability of the relevant Stock Tokens.
The sale of your Stock Positions in these circumstances may result in you receiving less than the amount you paid, including a realized loss, depending on the price of the relevant Stock Tokens at the time of sale.
6.5 Survival
The termination of your access to the Stocks Services does not affect any pending Orders, accrued but not yet applied fees, or any other rights or obligations that, by their nature, are intended to survive termination.
PART 7 -GENERAL PROVISIONS
7.1 Liability
We will provide the Stocks Services with reasonable care and skill, in accordance with applicable laws and regulatory requirements and generally accepted industry standards.
To the fullest extent permitted by applicable law, we are not liable for:
losses arising from changes in the price or value of any Stock Token or Underlying Security;
losses arising from the insolvency, operational failure, or regulatory action affecting any Token Issuer, its custodians or other service providers, or any other counterparty;
differences between the indicative price displayed on the CiNKO Platform and the price at which an Order is executed;
the unavailability, suspension, or restriction of trading in any Stock Token, or delays in the execution of Orders caused by blockchain network conditions, Token Issuer operational processes, or other factors beyond our reasonable control;
Sale Proceeds being less than the amount you paid, where this results from market movements or the mechanics of the relevant Stock Token or Bundle, as described in the applicable Schedule; or
any indirect, consequential, or economic losses arising from the Stocks Services.
Our liability to you in connection with the Stocks Services is subject to the limitations set forth in Section 10.3 of the General Terms, which apply to these Stocks Terms. Nothing in these Stocks Terms excludes or limits liability for fraud, willful misconduct, or death or personal injury caused by our negligence.
7.2 Amendments
We may modify these Stocks Terms or any Schedule at any time to reflect changes to the Stocks Services, applicable laws or regulations, a Token Issuer’s terms, or our business operations.
Each Schedule is part of these Stocks Terms but is a separate version. This means that a modification to a Schedule applies only to users who have accepted that Schedule and does not require reacceptance of these Stocks Terms or any other Schedule. A modification to Parts 1 through 7 of these Stocks Terms will require reacceptance by all users of the Stocks Services.
Not all changes will require your active acceptance. A material change is one that alters the transaction fee, the minimum Order amount, the identity of a Token Issuer, the custody arrangements for Stock Tokens, or the rights attached to a Stock Token. When a material modification is made, we will provide you with reasonable notice via the CiNKO Platform and ask you to re-accept the affected document before the modification takes effect. During this notice period, you may sell any affected Stock Positions, subject only to the transaction fee in effect before the modification.
Non-substantive changes - such as additions to the list of available Stock Tokens or minor operational updates to trading hours - may be made by updating the relevant Schedule or the CiNKO Platform and notifying you via the CiNKO Platform, without requiring a new acceptance.
Your continued use of the Stocks Services after any changes take effect constitutes your acceptance of the updated terms. If you do not agree with any changes, you must stop using the Stocks Services and sell your Stock Positions.
7.3 Language and Translation
These Stocks Terms and all documents that form part of the agreement between you and us regarding the Stocks Services are written in English, which is the governing language.
We may make translated versions of these Stocks Terms and other documents or communications related to the Stocks Services available to you through the CiNKO Platform for your convenience. When a translated version is made available:
in the event of any inconsistency, ambiguity, or conflict between the English version and any translated version, the English version shall prevail in all respects;
the translated versions are provided for informational purposes only and do not constitute a separate or independent agreement;
certain terms, words, or expressions used in the translated versions may have a different meaning, connotation, or legal interpretation in the relevant language or jurisdiction than their intended meaning in the English version; and
we do not guarantee that any translated version accurately reflects the meaning, effect, or legal interpretation of the English version.
If you have any questions about the meaning of any provision, please refer to the English version, which is available at all times on the CiNKO Platform.
7.4 Governing Law and Jurisdiction
These Stocks Terms and any dispute or claim arising out of or relating to them or the Stocks Services shall be governed by and construed in accordance with the laws of the Commonwealth of The Bahamas.
The courts of the Commonwealth of The Bahamas shall have exclusive jurisdiction to resolve any dispute or claim arising out of or relating to these Stocks Terms or the Stocks Services, subject to any mandatory rights you may have under applicable law.
7.5 Entire Agreement
These Stocks Terms (comprising Parts 1 through 7), together with the General Terms and the Schedules accepted by you, constitute the entire agreement between you and us regarding the Stocks Services and supersede any prior agreement or understanding relating to the same subject matter.
7.6 Relationship to the General Terms
All provisions of the General Terms apply to your use of the Stocks Services and your CiNKO Account in connection with the Stocks Services, unless these Stocks Terms specifically provide otherwise. In particular, the provisions of the General Terms relating to account security, prohibited activities, compliance obligations, custody, data protection, and claims management apply to the Stocks Services. For clarity, Section 9 (Risk Disclosures) of the General Terms applies to the Stocks Services in addition to, and not in lieu of, the risk disclosures set forth in Part 5 of these Stocks Terms.
The acquisition and sale of Stock Tokens under these Stocks Terms are governed by these Stocks Terms and not by Section 7A (Digital Asset Conversion Services) of the General Terms.
SCHEDULE 1 - Ondo Stocks
Ondo Stocks | Version 1.0 | Effective 1 October, 2026
Tokenized Stocks and ETFs issued by Ondo Global Markets (BVI) Limited
ONDO STOCKS - IMPORTANT INFORMATION
Ondo Stocks are digital tokens designed to track the economic value of publicly listed shares and exchange-traded funds. When you buy an Ondo Stock through CiNKO, you do not own the underlying share or fund and you have no shareholder voting rights. Your capital is at risk. The value of your Stock Positions can go down as well as up, and you may get back less than you paid.
A1.1 Product Description
Ondo Stocks (formerly known as Ondo Global Markets) are Stock Tokens issued by Ondo Global Markets (BVI) Limited (the “Ondo Issuer”). Each Ondo Stock is identified by the ticker of its Underlying Security followed by the suffix “on” - for example, ‘AAPLon’ tracks the economic value of Apple Inc. common stock.
Each Ondo Stock is designed to track the total return of its Underlying Security. This means that dividends paid on the Underlying Security are reinvested into the value of the Ondo Stock, net of applicable withholding tax, rather than paid out to you in cash. Ondo Stocks are designed to be backed by the corresponding Underlying Securities, which are acquired and held by custodians appointed by the Ondo Issuer, as described in A1.4.
Through the CiNKO Platform, you can acquire Ondo Stocks in fractional amounts, hold them in our custody as Stock Positions, and sell them, in accordance with these Stocks Terms.
The Ondo Stocks currently available to you are shown on the CiNKO Platform and may change from time to time in line with the Stocks Terms.
A1.2 Key Product Details
Product Name
Ondo Stocks
Token Issuer
Ondo Global Markets (BVI) Limited
Administrator and Tokenizer
Ondo Finance Inc.
Underlying assets
Publicly listed shares and exchange-traded funds. Ondo Stocks commonly available through the CiNKO Platform include:
AAPLon - Apple Inc.
MSFTon - Microsoft Corporation
NVDAon - NVIDIA Corporation
GOOGLon - Alphabet Inc. (Class A)
AMZNon - Amazon.com, Inc.
TSLAon - Tesla, Inc.
SPCXon - Space Exploration Technologies Corp. (SpaceX) (Class A)
This list is provided for illustration only and is not a complete list of available Ondo Stocks. The Ondo Stocks available to you may change at any time, may vary by jurisdiction, and are shown on the CiNKO Platform. The inclusion of an Ondo Stock in this list or on the CiNKO Platform is not a recommendation or an indication that it is a suitable investment for you.
Custodians of Underlying Securities
Alpaca Securities LLC; BitGo Trust Company, Inc.
Security Agent and Verification Agent
Ankura Trust Company, LLC
Shareholder rights
None - no voting or corporate action participation rights.
Dividends
Reinvested into the value of the Ondo Stock, net of applicable withholding tax
Funding Asset
USDC (displayed on the CiNKO Platform as your USD balance
Minimum Order
USD 20 per individual Ondo Stock (USD 10 per Ondo Stock within a Bundle - see Schedule 2)
Fractional positions
Available
Trading availability
Follows the Ondo Issuer’s trading schedule; Off-Hours Trading available for selected Ondo Stocks only
Transfer out of CiNKO
Not available
Capital protection
None - the value of your Stock Positions may fall, and you may get back less than you paid
Restricted Jurisdictions
United States, United Kingdom, member states of the European Union, and any other jurisdiction shown on the CiNKO Platform.
A1.3 Token Issuer Details
The Token Issuer for Ondo Stocks is Ondo Global Markets (BVI) Limited, a BVI business company incorporated under the laws of the British Virgin Islands. Ondo Finance Inc., a company based in the United States, acts as administrator and tokenizer for Ondo Stocks. Ondo Stocks are acquired from, and sold or redeemed to, the Ondo Issuer by Digital Finance (Bahamas) Ltd. under purchase terms entered into between Digital Finance (Bahamas) Ltd. and the Ondo Issuer. The Ondo Issuer and Ondo Finance Inc. are independent of Digital Finance (Bahamas) Ltd. and are not subject to our direction or control.
A1.4 Backing and Custody Structure
Each Ondo Stock is designed to be backed by the corresponding Underlying Security on a one-to-one basis. When Ondo Stocks are issued, the Ondo Issuer acquires the corresponding Underlying Securities, which are held by Alpaca Securities LLC and BitGo Trust Company, Inc. as custodians, with Alpaca Crypto LLC and BitGo Hong Kong Limited acting as exchange agents. The Ondo Issuer uses a bankruptcy-remote structure designed to keep the Underlying Securities legally separate from the assets of Ondo Finance Inc. Ankura Trust Company, LLC acts as security agent, holding a security interest over the collateral for the benefit of token holders, and as verification agent, independently verifying the collateral.
The Ondo Stocks attributable to your Stock Positions are held by us in custody, on an omnibus basis, as described in Section 4.3. You do not hold Ondo Stocks directly and do not have a direct contractual relationship with, or direct rights against, the Ondo Issuer, its custodians, or Ankura Trust Company, LLC, as described in Section 4.4.
This structure is designed to protect the Underlying Securities from the claims of creditors of the Ondo Issuer’s group. However, no structure is completely risk-free, and the value you are able to realize from your Stock Positions in an insolvency or failure scenario depends on the Ondo Issuer’s arrangements, the accuracy of the relevant records, and the application of applicable insolvency laws.
A1.5 Pricing and Commissions
The price of each Ondo Stock is provided by the Ondo Issuer and is not modified by us. The price includes the Ondo Issuer’s own charges, which are built into the price and are not charged to you separately. Outside the regular trading hours of the primary market for the Underlying Security, prices may be less favorable because liquidity is lower and the difference between buying and selling prices may be wider.
The fee applicable to your Order is displayed on the CiNKO Platform before you confirm it. We do not charge any other fees in connection with Ondo Stocks. For more information on the fees applicable to the Stocks Services, please refer to the CiNKO Platform, our FAQ at https://help.cinko.io/en/articles/8519789-fees-and-limits, or contact our customer service team.
A1.6 Trading Availability
Trading in Ondo Stocks follows the Ondo Issuer’s trading schedule:
Ondo Stocks are generally available for trading during the trading days and hours of the primary market for the Underlying Security.
Selected Ondo Stocks are also available for Off-Hours Trading. Orders in these Ondo Stocks can be priced and executed immediately when the primary market is closed, but prices may be less favorable, as described in A1.5.
Ondo Stocks that are not available for Off-Hours Trading cannot be acquired or sold outside the Ondo Issuer’s regular trading schedule.
The Ondo Issuer may suspend or restrict trading in any Ondo Stock at any time, including during market disruptions or in connection with a corporate action.
The CiNKO Platform indicates which Ondo Stocks are available for Off-Hours Trading and displays the current trading session of the primary market for information only, as described in Section 3.6.
A1.7 Selling and Sale Proceeds
You can submit an Order to sell all or part of a Stock Position in an Ondo Stock at any time the Ondo Stock is available for trading, through the CiNKO Platform. The Sale Proceeds will reflect the price provided by the Ondo Issuer at the time of execution, less the transaction fee described in Section 3.3, and will be credited to your CiNKO Account in the Funding Asset.
Your capital is at risk. The Sale Proceeds may be less than the amount you paid to acquire the Stock Position. The Stocks Balance displayed on the CiNKO Platform is not a guarantee of the Sale Proceeds you will receive.
A1.8 Disclosure of product-specific risks
In addition to the general risk disclosures in Part 5, the following risks are specific to Ondo Stocks:
No shareholder rights: Ondo Stocks do not give you ownership of the Underlying Security or any voting, meeting, or corporate action participation rights. Corporate actions are reflected only through adjustments made by the Ondo Issuer.
Tracking risk: The price of an Ondo Stock may differ from the price of its Underlying Security, including because of the Ondo Issuer’s charges, the reinvestment of dividends net of withholding tax, and the Ondo Issuer’s handling of corporate actions.
Off-Hours Trading risk: Prices for Ondo Stocks traded outside regular market hours may differ significantly from the price of the Underlying Security when the primary market next opens, and spreads may be wider.
Issuer and custodian risk: The value of Ondo Stocks depends on the Ondo Issuer, its custodians, exchange agents, and security and verification agent continuing to operate and to hold and reconcile the Underlying Securities correctly. Operational failure, insolvency, or regulatory action affecting any of these parties could impair the value of your Stock Positions or your ability to sell them.
Availability risk: The Ondo Issuer determines which Ondo Stocks are available and in which jurisdictions. If an Ondo Stock is discontinued or becomes unavailable in your jurisdiction, your Stock Positions may be sold or redeemed in accordance with Part 6, at a time you do not choose.
Withholding tax risk: Dividends on Underlying Securities may be subject to withholding tax at the level of the Ondo Issuer before they are reflected in the value of the Ondo Stock, and you will not be able to reclaim this tax.
Limited Recourse: Your rights are limited to the Ondo Stocks we hold for you in custody. You have no direct rights against the Ondo Issuer or its service providers.
SCHEDULE 2 - Bundles
Bundles | Version 1.0 | Effective 1 October, 2026
User-Created Collections of Stock Positions
BUNDLES - IMPORTANT INFORMATION
A Bundle is a tool that lets you group and manage up to ten of your own Stock Positions together. You choose every Stock Token in a Bundle and the percentage allocated to it. CiNKO does not create, recommend, or manage Bundles, and does not rebalance them for you. A Bundle is not a fund or a separate investment product. Each Stock Position in a Bundle carries the risks set out in Schedule 1, and your capital is at risk.
A2.1 Product Description
Bundles allow you to create a named collection of up to ten (10) Stock Positions, choose the percentage of the Bundle allocated to each Stock Token, and acquire, sell, rebalance, or delete those Stock Positions together through a single instruction on the CiNKO Platform.
A Bundle is a way of organizing and managing your own Stock Positions. It is recorded in our internal ledger as a grouping of individual Stock Positions, each of which is held in our custody in the same way as any other Stock Position. A Bundle does not create any separate token, fund, or legal structure, and does not change the nature of, or the rights attached to, the Stock Positions within it.
The name you give a Bundle must not be misleading, offensive, or in breach of Section 4.5 (Prohibited Activities) of the General Terms.
A2.2 Key Product Details
Feature Name
Bundles
Composition
Up to 10 Stock Tokens, selected by you
Allocation
Percentage allocation for each Stock Token, set by you
Available Stock Tokens
Ondo Stocks (see Schedule 1)
Minimum Order
USD 10 per Stock Token within the Bundle
Fees
Each Stock Token within a Bundle is a separate Order, subject to the transaction fee in Section 3.3
Rebalancing
Manual only - initiated by you
Automatic rebalancing
None
Deletion
Deleting a Bundle sells all Stock Positions in it and credits the Sale Proceeds to your CiNKO Account
Pre-built Bundles
Not offered
Sharing Bundles
Not currently available
Capital protection
None — the value of a Bundle may fall, and you may get back less than you paid
A2.3 Creating and Funding a Bundle
To create a Bundle, you select the Stock Tokens to include, the percentage of the Bundle allocated to each Stock Token, the name of the Bundle, and the total amount of the Funding Asset you wish to use. When you confirm, the total amount is divided between the selected Stock Tokens in the percentages you have chosen, and a separate Order is placed for each Stock Token.
The amount allocated to each Stock Token must be at least the minimum Order amount set out in A2.2. For example, a Bundle containing three Stock Tokens requires a total amount of at least USD 30.
Each Order within a Bundle is executed individually, in accordance with Part 3 and Schedule 1, and Orders may be executed at slightly different times and prices. If one or more Orders cannot be executed -for example, because a Stock Token is not available for trading at the time -the Bundle may be only partly acquired.
A2.4 Changes in Allocation and Rebalancing
The actual percentages of a Bundle will change over time as the prices of the Stock Tokens within it move. For example, a Bundle created as 50% Stock Token A and 50% Stock Token B may later become 60% and 40%. We do not intervene in this process and do not automatically rebalance Bundles.
If you want to restore or change the allocation of a Bundle, you must initiate a rebalance through the CiNKO Platform by selecting new target percentages. When you confirm a rebalance, the Orders required to achieve the new percentages are placed on your behalf, which may involve selling part of some Stock Positions and acquiring more of others. Each acquisition or sale of a Stock Token involved in a rebalance must be at least USD 10.
Each Order placed as part of a rebalance is subject to the transaction fee described in Section 3.3. A rebalance may result in you realizing a gain or loss on the Stock Positions sold, which may have tax consequences for you.
A2.5 Selling or Deleting a Bundle
You may sell all or part of a Bundle at any time the Stock Tokens within it are available for trading. Selling part of a Bundle sells each Stock Position within it in proportion to its current percentage of the Bundle, unless the CiNKO Platform allows you to select otherwise.
If you delete a Bundle, all Stock Positions within that Bundle will be sold and the Sale Proceeds, less applicable fees, will be credited to your CiNKO Account in the Funding Asset. Deletion of a Bundle cannot be reversed once confirmed. If any Stock Token within the Bundle is not available for trading at the time of deletion, the corresponding Stock Position will be sold when that Stock Token next becomes available.
A2.6 Commissions
A Bundle is treated as a set of individual Orders for fee purposes. The transaction fee described in Section 3.3 applies to each Order to acquire or sell a Stock Token within a Bundle, including Orders placed when you create, fund, rebalance, sell, or delete a Bundle.
We do not charge any separate fee for creating, holding, or managing a Bundle. The fees applicable to your Orders are displayed on the CiNKO Platform before you confirm them.
A2.7 Disclosure of product-specific risks
In addition to the general risk disclosures in Part 5 and the risks specific to each Stock Token set out in Schedule 1, the following risks are specific to Bundles:
No advice or management: Bundles are entirely created and managed by you. We do not assess whether the composition of a Bundle is suitable for you, and grouping Stock Positions in a Bundle does not mean they are diversified or that risk is reduced.
Allocation drift: The percentages of a Bundle will change as prices move, and the Bundle will not be rebalanced unless you choose to do so.
Partial execution: Orders within a Bundle are executed individually and may be executed at different times and prices, or not at all if a Stock Token is unavailable, so the Bundle may not exactly reflect the percentages you selected.
Fee impact: Because each Stock Token within a Bundle is a separate Order, the fixed portion of the transaction fee is charged on each one. For smaller Bundles, and for frequent rebalancing, fees will represent a higher proportion of the amount invested.
Deletion and rebalancing: Deleting or rebalancing a Bundle results in the sale of Stock Positions at the prices available at the time, which may result in a realized loss.
ACCEPTANCE
By accepting these Stocks Terms, you confirm that you have read, understood, and accepted Parts 1 through 7 of these Stocks Terms and Schedules 1 and 2. Your acceptance of each Schedule is recorded separately at the time you first access the relevant Stock Tokens or feature. A modification to a Schedule will require only your new acceptance of that Schedule. A modification to Parts 1 through 7 will require your new acceptance of these Stocks Terms.