Supplemental Terms and Conditions Cashback

These Supplemental Terms and Conditions (“Supplemental Terms”) govern the Cashback programme (the “Programme”) offered by Xapo Bank to eligible customers and are in addition to, and should be read together with, the Xapo Bank General Terms & Conditions and the Xapo Visa Card Terms or Mastercard Xapo Card Terms (as applicable).  In these Supplemental Terms, “we”, “us” and “our” mean Xapo Bank, and “you” and “your” mean the Cardholder (as defined in clause 1.1).

In these Supplemental Terms, “USD Account” means the US Dollar account titled “USD Account” held with Xapo Bank and “BTC Account” means the Bitcoin wallet held with Xapo VASP Limited. Capitalised terms not defined in these Supplemental Terms have the meanings given to them in the Xapo Terms & Conditions or the Xapo Visa Card Terms or Mastercard Xapo Card Terms (as applicable).

By holding an eligible Xapo debit card, you agree to be bound by these Supplemental Terms.

1. Eligibility

1.1 This Programme is open to all paid members who hold an active Xapo debit card issued by Xapo Bank (“Cardholders”).

1.2 There is no minimum USD Account balance or minimum card tenure to take part. However, how much Cashback you can earn depends on your Average USD Balance (see clause 3).

1.3 No application, enrolment or opt-in step is required. Eligible Cardholders are included in the Programme automatically.

1.4 We may exclude you from the Programme (so that you do not earn Cashback) if your account is under review, restricted or dormant, if you are in a jurisdiction where we cannot offer the Programme or if you hold a product type that is not eligible.

2. Cashback Reward

2.1 As an eligible Cardholder, you earn cashback paid in Bitcoin (“Cashback”) at a rate of 2% of  your Cashback Allowance (see clause 3). Cashback is calculated in USD and paid in Bitcoin (see clause 3.14).

2.2 There are no tiers, tokens, promotional step-downs, or deposit tests applicable to the Cashback rate.

3. Cashback Allowance and Qualifying Transactions

3.1 Your Cashback Allowance is the maximum amount of card spending in a calendar month that is eligible to earn Cashback. On the first day of each calendar month we set your Cashback Allowance for that month using the following formula:

Cashback Allowance = Average USD Balance x Allowance Percentage

where: (a) “Average USD Balance” means the average of your USD Account balance at the end of each day (UTC) during the previous calendar month; and (b) “Allowance Percentage” means 20%, as we may change it under clause 3.5.

For example: if your Average USD Balance is $5,000, your Cashback Allowance is $5,000 x 20% = $1,000. You earn Cashback on up to $1,000 of spending that month, so the most you can earn that month is $20 Cashback (paid it Bitcoin).

3.2 Only the money in your USD Account counts towards your Cashback Allowance. Your USD Savings Account, Bitcoin balances, investment balances and other assets do not count. If you convert Bitcoin, stablecoins or other assets into USD in your USD Account, that money counts from the end of the day on which it is in your USD Account.

3.3 Your Cashback Allowance is fixed for the whole month. If your USD Account balance goes up or down during the month, your Cashback Allowance for that month does not change. Instead, it affects the following month’s Cashback Allowance. On the first day of each calendar month we recalculate your Cashback Allowance using your Average USD Balance for the month just ended. For example if you add money to your USD Account on 20 March, your March Cashback Allowance stays the same, but the extra money raises your March average and so your April Cashback Allowance.

3.4 You cannot roll unused Cashback Allowance over to future months. If it is not used in the month, it is lost.

3.5 The Allowance Percentage is currently 20%. We may change it by giving you at least 30 days’ written notice. A change will apply from the first day of the month after the notice period ends, and will not affect Cashback you have already earned or your Cashback Allowance for the current month.

3.6 A “Qualifying Transaction” is a purchase made with your Xapo debit card, in-store or online, that: (a) is authorised on your card; (b) is not an Excluded Transaction (see clause 3.9); and (c) is otherwise eligible for Cashback under the Xapo Visa Card Terms or Mastercard Xapo Card Terms (as applicable).

3.7 Cashback is estimated when a purchase is authorised and finalised when it clears. (a) Authorisation. When a merchant asks us to approve a purchase (authorisation), we check how much of your Cashback Allowance you have left for that month (“Remaining Allowance”). We set aside the amount of the purchase that is within the Remaining Allowance, fix the Bitcoin exchange rate, and show the Cashback as “Estimated”. (b) Clearing. When the purchase clears (settles), we calculate the final Cashback under clause 3.10. We pay it on the first day of the month after the purchase clears (see clause 5.1). (c) Which month it counts towards. A purchase uses the Cashback Allowance of the month in which it was authorised, even if it clears in the next month. It never uses the next month’s Cashback Allowance. (d) All your Xapo debit cards share one Cashback Allowance. There is no minimum purchase value.

3.8 Your Cashback Allowance is the only limit on how much Cashback you can earn in a month: the most you can earn is 2% of your Cashback Allowance. There are no other monthly caps or limits.

3.9 The following are “Excluded Transactions”. They do not earn Cashback and do not use any of your Cashback Allowance: (a) transactions made with a merchant whose Merchant Category Code (the code card networks assign to a merchant to identify its type of business) is for gambling, quasi-cash, brokerage, tax, government, insurance and charity transactions; (b) ATM withdrawals or other cash withdrawals; (c) money transfers or peer-to-peer payments; and (d) any other transaction types excluded from Cashback under the Xapo Visa Card Terms or Mastercard Xapo Card Terms (as applicable).

Xapo Bank reserves the right to amend this list by giving notice under clause 8.1.

3.10 Authorisation and clearing.

Before the purchase clears. (a) If the merchant increases or reduces the authorised amount,, we recalculate the Estimated Cashback against your Remaining Allowance for that month. (b) If the purchase is cancelled, reversed or expired, it earns no Cashback and the amount we set aside goes back to that month’s Cashback Allowance.

When the purchase clears. (c) We calculate the final Cashback on the cleared amount, using the Bitcoin exchange rate fixed at authorisation. (d) Cleared for less: Cashback is reduced and the unused amount we set aside goes back to that month’s Cashback Allowance. (e) Cleared for more: Cashback increases only if the Cashback Allowance for the month of authorisation still has an unused amount that is not used or set aside for other purchases. (f) Only partly covered at authorisation: If only part of the purchase fitted within your Remaining Allowance when it was authorised, and Cashback Allowance in that month has since been released, we may use it to increase the Cashback, up to 2% of the cleared amount.

After the purchase clears. (g) Once a purchase has cleared, its Cashback is final and will not be recalculated, except for refunds (clause 3.12) and fraud or misuse (clause 7). (h) Settled without authorisation (a “forced settlement”): we calculate Cashback when we process a settlement, against your Remaining Allowance for that month and the Bitcoin exchange rate at that time.

3.11 We will show the following in the Xapo app: (a) your Cashback Allowance for the current month; (b) how much of it you have used and your Remaining Allowance; (c) the Cashback you have earned so far and the date it will be paid; and (d) for each Qualifying Transaction, how much Cashback it earned (or is expected to earn, if Estimated).We may also show an estimate of next month’s Cashback Allowance. Any estimate is labelled as an estimate and is not guaranteed.

3.12 Refunds. If a purchase that earned Cashback is refunded in whole or in part, and we can link the refund to that purchase: (a) we reverse the Cashback on the refunded part. This is recorded as negative Cashback and deducted from your future Cashback payments; if it cannot be deducted, we may recover it from your other accounts (BTC Wallet, BTC Savings, USD Wallet, USD Savings and BTC Vault). (b) If the refund is made in the same calendar month as the purchase, we also give back the refunded share of the Cashback Allowance the purchase used, so you can spend it again that month. (c) If the refund is made in a later month, only the Cashback is reversed; your Cashback Allowance for that month does not change. (d) If a refund cannot be linked to a purchase that earned Cashback, it has no effect on your Cashback or your Cashback Allowance.

3.13 New Cardholders: If you join after the Effective Date, your first Cashback Allowance is set on the first of the month after the month you join. It is calculated using your average USD Account balance for the month you joined, with the days before you joined counted as $0. This means you will not earn Cashback in the month you join, and your first Cashback Allowance may be smaller than later ones.

3.14 We calculate Cashback in USD and convert it into Bitcoin at the Bitcoin exchange rate when the purchase is authorised (or, for a forced settlement, when it is processed). The Estimated amount shown is normally the amount you will be paid, but it can change if the final purchase amount differs or as set out in clause 3.10.

4. Programme Period

4.1 This Programme takes effect from 9th November 2026 (the “Effective Date”) and will continue until varied, suspended, or discontinued by Xapo Bank in accordance with clause 8.

5. Payment of Cashback

5.1 On the first day of each month we pay the Cashback credited to you in the previous month (that is, on purchases that cleared during the prior month). If a purchase is authorised in one month but clears in the next, the Cashback counts towards the month of authorisation (see clause 3.7) but is paid on the first day of the month after it clears. For example, a purchase authorised on 31 January that clears on 2 February counts towards January but is paid on 1 March.

5.2 Cashback is paid automatically; no claim, redemption step, or action by the Cardholder is required.

5.3 If your account is closed, or we have told you we are going to close it, any Cashback you have earned but we have not yet paid will be paid to you in Bitcoin straight away, instead of on the first day of the next month. We will not pay it if we are entitled to withhold it under clause 7, or if we are required by law or regulation not to release it (for example, because of sanctions or suspected money laundering or terrorist financing).

6. Disputes

6.1 If you have a question or dispute about your Cashback, please tell us through our usual customer support channels. We will assess it using the rules in these Supplemental Terms. In particular, Cashback is estimated when a purchase is authorised and finalised when it clears, as set out in clauses 3.7 and 3.10. This does not affect your right to complain under our complaints procedure or any of your legal rights.

6.2 We already hold records of your USD Account balance and transactions and will use them to check any disputed calculation. We may ask you for further documents or information if we reasonably need them to verify it.

7. Fraud and Misuse

7.1 If we reasonably believe that you have engaged in fraud, misuse or any attempt to manipulate or abuse this Programme, we may take action under this clause. This includes (without limitation) artificially inflating, cycling or temporarily topping up your USD Account balance to increase your Cashback Allowance or Cashback otherwise than through genuine spending or saving. Adding money to your USD Account is not misuse in itself. In these cases we may: (a) disqualify you from this Programme; (b) withhold or cancel any Cashback; and (c) recover any Cashback already paid.

7.2 For clarity, none of the following, of itself, constitutes fraud or misuse of this Programme, and none will result in the withholding, cancellation, or recovery of Cashback already earned: (a) a Cardholder’s Average USD Balance falling below the level needed to support their recent level of card spend, which affects only the Cardholder’s ability to earn Cashback on spend going forward and will not result in the loss of Cashback already earned; and (b) ordinary fluctuations in a Cardholder’s USD Account balance arising from genuine day-to-day account activity.

8. General Provisions

8.1 We may amend, suspend or discontinue this Programme (including the Cashback rate, the Allowance Percentage and the Excluded Transactions) by giving you at least 30 days’ notice, unless a shorter period is needed to comply with law or regulation or to protect against fraud, misuse or financial crime. Cashback you have already earned on Qualifying Transactions before a change takes effect will not be affected, except as set out in clauses 3.12 (Refunds) and 7.

8.2 The Programme is personal to you and cannot be transferred. Cashback cannot be exchanged for cash, other than by being paid to you in Bitcoin as set out in these Supplemental Terms.

8.3 In the event of any inconsistency between these Supplemental Terms and the Xapo Visa Card Terms or Mastercard Xapo Card Terms (as applicable), these Supplemental Terms will prevail, but only to the extent necessary to govern this Programme.

8.4 You are responsible for any tax that applies to Cashback you receive. We do not provide tax advice.

8.5 These Supplemental Terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with Gibraltar Law. Each party irrevocably agrees that the courts of Gibraltar shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these or its subject matter or formation.