Terms and Privacy – Lohkovero

Part 1

Service provider details

Service provider: ATP Palvelut (Lohkovero is a service of the sole trader ATP Palvelut)
Business ID: 3656206-4
Legal form: Sole trader (private trader)
Domicile: Espoo, Finland
Address: c/o Aapo Pasma, Syvänsalmenkatu 8 A 37, 02260 Espoo
E-mail: [email protected]
Phone: 046 627 0209
Complaints: Complaints and claims are handled at the same address and the same e-mail as all other correspondence.
VAT: Prices are final, including with respect to VAT: the invoice total is the same as in the price list. Sales are exempt from VAT on the basis of small-scale business (Value Added Tax Act, section 3; the threshold is 20 000 euros per calendar year), so the invoice has no VAT breakdown and no VAT is added to the price. If the threshold is exceeded, VAT liability begins only from the moment it is exceeded, not retroactively — and it does not change prices already agreed.
Prepayment Register: Entered in the Prepayment Register

The sole trader was entered in the Trade Register on 28.9.2026 (Business ID 3656206-4).

Part 2

Pre-contractual information for distance selling

The service is sold as distance selling within the meaning of Chapter 6 of the Finnish Consumer Protection Act: the contract is concluded online or by e-mail without the parties meeting. This information is given to you before the contract is concluded, and you also receive it in writing as an attachment to the offer.

What the service includes

Reconstruction of a private individual's crypto asset transaction history and preparation of tax return material. The exact content of the delivery is defined in the written offer according to the service level. The service is not legal representation and does not include appeals to the administrative court.

Price and payment

The price is fixed, final also with respect to VAT, and is agreed in the written offer before work begins. The price includes everything stated in the offer; separately agreed additional work is charged on an hourly basis at the hourly rate stated in the offer. The invoice is due within 14 days. Late-payment interest is charged in accordance with the Interest Act.

Delivery time

The delivery time is stated in the offer and begins to run once the required material has been received in full. If the material is incomplete, we will let you know, and the delivery time begins when the supplementary material arrives.

Duration of the contract

The contract is a one-off engagement. It ends when the delivery has been handed over and paid for. The service does not include any open-ended commitment or automatically renewing billing.

Right of withdrawal and compensation for work in progress

You have a 14-day right of withdrawal, the terms and exercise of which are described in full in Part 3. If you request that the work begin during the withdrawal period and then withdraw while the work is in progress, you must pay reasonable compensation for the work done up to that point. The basis for calculating the compensation is described in Part 3. If the service is fully performed at your request, the right of withdrawal lapses.

Complaints, customer support and after-sales services

Complaints and claims should be sent to [email protected]. We will respond within 14 days at the latest. The delivery includes a walk-through and answers to questions about the delivery; correcting an error is free of charge. The service comes with no separate guarantee and no fixed-term support agreement — your statutory rights apply without a separate guarantee.

Codes of conduct and dispute resolution

We have not committed to any industry codes of conduct. A dispute may be referred to the Consumer Disputes Board; the procedure is described in Part 7.

Communication costs

Contacting us and dealing with us does not cause you any costs for the use of distance communication beyond the basic rate.

Part 3

Right of withdrawal

As a consumer, you have the right to withdraw from the contract within 14 days without giving a reason. For a service contract, the period begins when the contract is concluded, not upon delivery.

If you want the work to start immediately

The reconstruction work typically takes longer than 14 days, so most customers want it to start immediately. This is possible, but requires two things, which we ask you to confirm in writing when accepting the offer:

You expressly request that performance of the service begin during the withdrawal period.
You are informed that the right of withdrawal lapses once the service has been fully performed at your request.

If you withdraw from the contract after the work has begun but before it is complete, you must pay reasonable compensation for the work done up to that point. The compensation is calculated in proportion to how much of the agreed total performance has been completed, and it cannot exceed the agreed total price. On request, we will tell you what stage the work is at before you make your decision.

To make the compensation predictable rather than open to dispute afterwards, the work is divided into stages and each stage's share of the total price is agreed in advance:

Stage 1 — 30 %: Receipt of material, tracing and confirmation of addresses, integrity check of source material
Stage 2 — 50 %: Normalisation of transactions, FIFO calculation and reconciliation with chain balances
Stage 3 — 20 %: Preparation of the report document and attachments, and a walk-through with you

The compensation is the share of the total price for completed stages, plus the completed portion of the stage in progress. A stage that has not been started is not charged for.

How to withdraw

Send an unequivocal statement to [email protected] before the period expires. You may use the form below, but it is not mandatory — a free-form message is enough. We will refund any payments already made without delay and no later than 14 days after receiving your notice, using the same means of payment you used, unless expressly agreed otherwise — less the reasonable compensation referred to above. You will not incur any costs as a result of the refund.

WITHDRAWAL FORM (Complete and return this form only if you wish to withdraw from the contract. Use of the form is not mandatory.) To: ATP Palvelut c/o Aapo Pasma, Syvänsalmenkatu 8 A 37, 02260 Espoo [email protected] I/We hereby give notice that I/we withdraw from my/our contract for the provision of the following service: Service / offer number: _______________________________ Ordered on: ___________________________________________ Name of consumer: _____________________________________ Address of consumer: __________________________________ E-mail: _______________________________________________ Signature of consumer: ________________________________ (only if this form is notified on paper) Date: _________________________________________________

Part 4

Terms of Service

Formation of the contract

The engagement is formed when you accept the written offer. The offer defines the service level, content, price, delivery time and the material on which the work is based. The free diagnosis is not a contract and does not bind either party to anything.

What the report is based on

The report is prepared from the material you provide and from the public blockchain data that can be found on the basis of the addresses you give and the addresses traced from them. You are responsible for ensuring that the material you provide is correct and as complete as possible and that the wallet addresses you confirm are yours. If transactions are missing from the material, this will show in the calculation — but we cannot know about a source that you have not mentioned and that tracing does not find.

Source list and your confirmation

Before delivery you receive a source list (appendix 0 of the report): every exchange account, wallet address and chain whose data has been used in the calculation, together with an exception list of transactions whose treatment required interpretation or where information was missing. You confirm the source list in writing, for example by email. By confirming it you declare that the list contains all the places where you have held or traded crypto assets during the tax years concerned, and that the wallets marked as yours are yours.

We are not liable for an error or damage to the extent that it results from

the material you provided being incorrect, edited or incomplete, for example a transaction export covering only part of the history,
an exchange, wallet, chain or way of trading (for example OTC, peer-to-peer or cash trades, gifts or lost keys) not being disclosed, where tracing could not find it from the material you provided,
you confirming as yours an address that is not yours, or not confirming an address that is,
you entering information to the Tax Administration that differs from the report, or disregarding the report's recommendations.

If a source comes to light later, we update the report. The update is free of charge if the source should already have been found from the material you provided. Otherwise it is additional work, priced in advance.

In situations open to interpretation, such as staking rewards, liquidity pools or bridges, we present the alternative treatments with their justifications and mark which one follows the Tax Administration's guidance. You choose the treatment before delivery, and the choice is recorded in the source list (appendix 0) and the methodology statement. If you do not choose, we use the treatment that follows the Tax Administration's guidance. If the Tax Administration reaches a different interpretation, this is not an error in the report when the choice has been documented and justified.

What the service is not

The service is not tax or legal advice on an individual case, but the production of calculations and material. The calculation principles and legal references are documented so that you can check them yourself or have them checked.
We do not represent you, do not deal with the Tax Administration on your behalf, and do not prepare your tax return, claim for adjustment (oikaisuvaatimus) or response to a request for clarification. You receive the calculation and methodology statement, with which you do these yourself or hand them to a tax adviser of your choice.
Final taxation is decided by the Finnish Tax Administration (Verohallinto). We do not guarantee any particular tax outcome, nor that the Tax Administration will not raise questions.

How the work is done

Tracing, reconciliation and calculation are done with AI assistance using Anthropic's Claude model, and every report is checked before delivery. The AI receives only the transactions, wallet addresses and the engagement number, never your name, contact details or personal identity code. We use Anthropic's Claude service with the use of material for model training switched off. Anthropic retains conversations for up to 30 days under its own terms. We ask for your consent to this on the order form.

Liability

We are responsible for the work being carried out professionally and with the agreed content. If there is an error in the delivery, we will correct it free of charge without undue delay. If the error is not corrected within a reasonable time, you are entitled to a price reduction and, in the case of a material error, to terminate the contract.

If our negligence causes you damage, we are liable for it in accordance with the law. Tax that you would have been obliged to pay in any case is not damage; damage means, for example, a tax increase, late-payment interest or additional correction costs caused by an error. Check the summary of the calculation before using the figures in your tax return, and tell us if any figure differs from what you expected. We are liable for the performance of our subcontractors as for our own.

Business customers. If you order the service as a business, for example as an accounting firm on behalf of your client, our liability is limited to the price of the order and we are not liable for indirect damage. The limitation does not apply to damage caused intentionally or through gross negligence.

The limits of our liability arise from what we have promised to do, not from a limitation of liability clause. The section "What the service is not" above defines our obligation of performance, and the section "What the report is based on" defines the material from which the work is done. The section "Source list and your confirmation" sets out when an error results from the material provided rather than from our work. We are not responsible for the Tax Administration's decision.

Ownership and use of material

The material you provide remains yours. The finished report and its attachments are yours to use freely, including when you hand them over to the Tax Administration or a third party. The tools, models and methods used in the calculation remain with the service provider.

Suspension of work

If the case turns out to be substantially more demanding than estimated, we will suspend the work and present options — we will not charge for the excess without a separate agreement. If you do not accept any of the options, we will invoice the work done up to that point at the hourly rate and hand over the unfinished material to you.

Part 5

Privacy notice

Information provided to the data subject in accordance with Articles 13 and 14 of the General Data Protection Regulation (EU 2016/679).

Data controller

Data controller: ATP Palvelut, 3656206-4
Contact details: [email protected], c/o Aapo Pasma, Syvänsalmenkatu 8 A 37, 02260 Espoo
Data protection officer: No data protection officer has been appointed. The nature and scale of the business do not require one. For data protection matters, contact the address above.

What data we process

Contact details: name, e-mail address, phone number and address for invoicing.
Exchange transaction exports: trade, transfer, deposit and withdrawal transactions with timestamps, currencies and amounts used, fees, and transaction and account identifiers issued by the service provider.
Wallet addresses and blockchain data: the public addresses you give, addresses found during tracing and your confirmation of them, and the public transaction history of these addresses.
Engagement details: offer, calculations, delivered report, invoices and payments.
Communications: e-mails and other contacts relating to the engagement.

We do not process special categories of personal data within the meaning of Article 9 of the General Data Protection Regulation. We do not carry out automated decision-making or profiling. Nor do we record any criminal-law assessments in the material — we calculate figures, we do not characterise actions.

Is providing the data mandatory

Providing the data is not a statutory obligation, but it is a prerequisite for performing the contract. Without exchange transaction exports and at least one address per chain, the report cannot be prepared and the engagement cannot be accepted. If you do not confirm which of the addresses found during tracing are yours, the calculation will remain incomplete and we will state this in the report.

What the data is used for and on what basis

Providing the service: Contract and steps taken prior to entering into a contract (Art. 6(1)(b)). This also covers the free diagnosis, as it is carried out at your request to prepare a possible contract.
Accounting and invoicing: Legal obligation (Art. 6(1)(c)), Accounting Act.
Traceability of the delivery: Legitimate interest (Art. 6(1)(f)): the ability to show afterwards what the calculation was based on if the Tax Administration or the customer raises questions.

Where the data comes from

From you: contact details, exchange transaction exports and wallet addresses.
From public blockchain data: the transaction history of the addresses you give and the addresses traced from it. This information is public and can be read by anyone without permission; we obtain nothing from it that is not already available to everyone.
From market data providers: historical prices of crypto assets for valuation. These are not personal data.

Transaction counterparties

When we trace your addresses on the blockchain, the material inevitably also includes counterparties' addresses: parties to whom you have sent funds or from whom you have received them. Most of these are exchanges, protocols and other legal persons, but some may be natural persons. In that case we also process their personal data.

We cannot inform them: we only have a public address, no name or contact details, and a privacy notice cannot be sent to an address. We therefore rely on Article 14(5)(b) of the General Data Protection Regulation, under which the obligation to inform may be derogated from where the provision of the information proves impossible. The same provision requires safeguards, and they are:

This notice is public and also describes the processing as regards counterparties — it is the publicly available information referred to in the provision.
Minimisation: we trace only to the extent required to calculate the disposals. We do not cluster counterparties, nor do we find out who the addresses belong to.
Limited retention: counterparty data is retained only as part of the verifiability of the calculation, with the same retention periods as the other material of the engagement, and only at the level of the transaction identifier.
No onward disclosure for any other purpose. In the report submitted to the Tax Administration, a counterparty is identified by transaction identifier insofar as the verifiability of the calculation requires it.

If you are a counterparty to a transaction and want to know whether your address is processed in our material, please contact us. We can only respond if you specify the address.

To whom data is disclosed

We do not sell or disclose your data to third parties for marketing purposes. We use the following data processors, with whom we have a data processing agreement:

Tally (Tally BV, Belgium) — form and receipt of material. Form data is stored within the EU.
Zoho (Zoho Corporation B.V., EU data centre) — e-mail.
Cloudflare, Inc. (United States; certified under the EU–US Data Privacy Framework) — website delivery, protection and DNS. Cloudflare processes the visitor's IP address in order to relay and protect traffic. The website's visitor statistics run on Cloudflare's service (database in the EU) and are described under Cookies.
Accounting service as regards invoicing and accounting records.

In addition, data is passed to the following services, which are not our processors but process the data under their own terms:

Anthropic (Anthropic PBC, United States), Claude AI service — tracing and calculation. Only transactions, wallet addresses and the engagement number are passed to Anthropic, never names, contact details or personal identity codes. Model training is switched off, and Anthropic retains the data for up to 30 days. The transfer is based on your explicit consent, given on the order form.
Blockchain APIs and explorers (for example Blockscout, Solscan and RPC providers) — retrieval of public transaction history. Only public wallet addresses and transaction identifiers are passed to them, never names or contact details. Some of these services operate outside the EU.

Data is also disclosed to authorities where required by law.

Transfers outside the EU and EEA

Your contact details are not transferred outside the EU or EEA. There are three transfers. Anthropic processes transaction data and wallet addresses, without names or contact details, in the United States. Public addresses and transaction identifiers are passed to blockchain APIs. Cloudflare may process the visitor's IP address outside the EEA. The transfer to Anthropic is based on your explicit consent (Article 49(1)(a) GDPR). The level of data protection in the United States may differ from that in the EU, which is why names and contact details are never passed to Anthropic. Other transfers are based on the European Commission's decision on the EU–US Data Privacy Framework where the recipient is certified, and otherwise on the European Commission's standard contractual clauses. Should any other service we use change in this respect, the transfer would be based on the European Commission's standard contractual clauses and we will state this in this notice.

How long data is retained

Diagnosis material: Deleted immediately at your request and otherwise within three months at the latest, if the diagnosis does not lead to an engagement.
Engagement material: One year from handover of the delivery. During that time the basis of the calculation is available if the Tax Administration requests further clarification. After that the material is deleted; the finished report and its appendices remain with you.
Accounting records: Vouchers and correspondence concerning business transactions for six years from the end of the calendar year in which the financial period ends; financial statements and books of account for ten years from the end of the financial period (Accounting Act, Chapter 2, Section 10).
Counterparty data: As for engagement material, but only at the level of the transaction identifier and only to the extent required for the verifiability of the calculation.
Enquiries: Two years from the last contact, if they are not related to an engagement.

How data is protected

Material is received over an encrypted connection. We do not ask you to send transaction exports as unencrypted e-mail attachments.
We never ask for or accept recovery phrases, private keys, passwords or exchange credentials. A public address cannot be used to move funds or log in to anything.
Material is stored within the EU, access is restricted and protected, and unnecessary material is deleted in accordance with the retention periods.

Your rights

To know what data about you is being processed, and to obtain a copy of it.
To request the rectification of inaccurate data or the completion of incomplete data.
To request the erasure of data when there is no longer a basis for processing.
To request restriction of processing, or to object to processing based on legitimate interest.
To receive the data you have provided in a machine-readable format for transfer to another service provider.
To lodge a complaint with a supervisory authority. In Finland this is the Office of the Data Protection Ombudsman, tietosuoja.fi.

Requests should be sent by e-mail. We respond within one month. We may need to verify your identity before carrying out the request. Some data may not be deleted if the law requires it to be retained — in that case we will tell you what it concerns.

Part 6

Cookies

The website does not use tracking or advertising cookies, and its operation does not require cookie consent.

If we introduce a service that uses cookies, we will ask for consent and describe the cookies in this section before introducing it.

Cookieless visitor statistics. We measure use of the website with our own service, without cookies and without browser storage. We record the page address, the referring site's domain, country, device type, and use of buttons such as the price estimator, opening the form and the thank-you page shown after the form is sent. IP addresses are not stored. Visits on the same day are linked with an identifier derived from the IP address and browser details using a random key that changes daily. The key is destroyed, so visits cannot be linked across days and the IP address cannot be recovered from the identifier. The data is used solely to improve the website, is not disclosed to others, and is deleted after about 13 months. If your browser sends a Do Not Track or Global Privacy Control signal, your visit is not measured. The legal basis is legitimate interest: monitoring how the website works.

The form service through which material is received may set its own functional cookies on its form page. These are described in that service's own notice.

Part 7

Applicable law and dispute resolution

The agreement is governed by Finnish law. Disagreements are to be resolved primarily through negotiation — contact us and we will go through the matter.

If no solution is found, as a consumer you have the right to refer the matter to the Consumer Disputes Board (kuluttajariita.fi). Before taking the matter to the Board, contact the Consumer Advisory Service (kkv.fi). The matter can also be taken to the district court of your place of residence.