General Terms and Conditions (T&C)
ZERO Cybernetic Systems & Digital Solutions UG (haftungsbeschränkt)
§ 1 Scope, contracting party
(1) These General Terms and Conditions (hereinafter “T&C”) apply to all orders processed via the website of the online shop (hereinafter “Shop”) of ZERO Cybernetic Systems & Digital Solutions UG (haftungsbeschränkt), Fidicinstr. 23, 10965 Berlin (hereinafter “ZERO” or “we”).
(2) A consumer within the meaning of these T&C is any natural person who enters into a legal transaction for purposes that can predominantly be attributed neither to their commercial nor to their independent professional activity (§ 13 BGB [German Civil Code]). An entrepreneur is a natural or legal person or a partnership with legal capacity who, when entering into a legal transaction, acts in the exercise of their commercial or independent professional activity (§ 14 BGB).
(3) The version of the T&C valid at the time the contract is concluded is authoritative.
(4) Deviating, conflicting or supplementary general terms and conditions of the customer shall not become part of the contract unless ZERO expressly agrees to their validity in writing.
§ 2 Range of services
(1) ZERO offers the following services:
a) Hardware sales: Google Pixel smartphones (models 9a to 10 Pro Fold) with pre-installed GrapheneOS.
b) Workshop service tier “GrapheneOS Only” (Tier 1): Pixel hardware + GrapheneOS flash + full-disk encryption (FDE) + empty default profile. The customer configures apps and profiles themselves.
c) Workshop service tier “Full Privacy” (Tier 2): Tier 1 plus multi-profile architecture, VPN killswitch configuration, anti-forensic tools, FOSS wallet pre-configuration, FOSS app bundle installation and workshop handover (60 min).
d) Hardware modifications (Mod Stages): Physical removal or deactivation of individual components (microphones, motion/environmental sensors and/or cameras) on hardware owned by the customer, carried out on the customer’s express instruction within the framework of the workshop model (§ 6). The customer is aware, and expressly wishes, that the removed functions cease permanently (e.g. no telephony after removal of the microphone) and that the manufacturer’s warranty and, where applicable, the radio equipment conformity (CE/RED) of the affected assembly are thereby lost. The components removed in each Mod Stage are listed to the customer in the configurator before the order is placed. ZERO does not carry out any interventions on transmitting/receiving assemblies relevant to mobile radio, Wi-Fi or Bluetooth and does not make any changes to device identifiers.
e) Workshop service for Bring Your Own Device (BYOD): GrapheneOS installation and/or modification on hardware provided by the customer.
f) Voucher resale: Authentication vouchers for third-party services (Threema, Mullvad VPN, SMS pool). The customer activates their own accounts themselves using the enclosed guide.
g) Accessories: Cases, privacy screens, Faraday bags, wired headsets.
h) Privacy consulting: Consulting on individual setups, billed by the hour.
(2) All hardware modifications are performed in accordance with the workshop model: ownership of the hardware remains with the customer at all times. ZERO is a workshop service provider, not a manufacturer within the meaning of the ProdHaftG (German Product Liability Act).
(3) GrapheneOS is free open-source software under the MIT/Apache licence. ZERO is not its developer or maintainer.
§ 3 Conclusion of contract
(1) The presentation of the products in the online shop does not constitute a legally binding offer but an invitation to place an order (invitatio ad offerendum).
(2) By completing the configurator wizard and clicking “Submit order & get pay link”, the customer submits a binding offer to conclude a contract.
(3) The contract is concluded upon receipt of an order confirmation by email. In the case of online prepayment (BTC/SEPA), the order is triggered with legally binding effect only after receipt of payment. In the case of cash prepayment or cash by post, the order becomes legally binding once the receipt has been booked.
(4) The language of the contract is German. Orders may also be processed in English.
(5) The text of the contract is stored by ZERO and sent by email to the address provided by the customer after the contract has been concluded. The booking number (format ZRO-YYYY-XXXXXX) serves as the unique contract reference.
§ 4 Prices, payment
(1) All prices in the Shop include statutory value added tax (19% VAT) in accordance with the PAngV (German Price Indication Ordinance). In the case of shipping, the shipping costs stated in the configurator are charged in addition (depending on zone, DE €9.90 to Worldwide €299.90).
(2) Hardware prices are based on current market prices for Pixel devices. ZERO reserves the right to adjust prices at regular intervals (typically daily) to market developments. For orders already concluded, the price displayed at the time of ordering applies.
(3) Accepted payment methods:
a) Bitcoin (BTC) via BTCPay Server — prepayment, order triggered after confirmation
b) Monero (XMR) — in preparation; currently not available as a payment method
c) SEPA bank transfer — prepayment, order triggered after receipt of funds (1-3 working days)
d) Cash prepayment at the workshop appointment — possible for pickup or shipping orders. The customer or a messenger hands over the cash to ZERO in the selected drop-off slot. The service starts only once the payment has been booked. For amounts of €10,000 or more, identification pursuant to § 10 GwG (German Anti-Money Laundering Act) is required (presentation of identity document, copy).
e) Cash by post (insured-value letter) — only in pickup mode. The customer sends cash by DHL Wertbrief (insured-value letter), marked with the booking number, to the ZERO workshop. Max. €10,000 per order. Higher amounts require handover in person with presentation of an identity document, or a SEPA bank transfer. Sending by post is at the customer’s own risk.
(4) The customer may only set off claims if the counterclaim has been finally established by a court or is undisputed. The same applies to the assertion of rights of retention vis-à-vis entrepreneurs.
(5) Anti-money laundering compliance and sending cash: ZERO accepts cash only within the framework of the statutory requirements. For cash payments, the identification obligation under § 10 GwG applies from a threshold of €10,000; from this threshold, ZERO accepts payments exclusively by SEPA bank transfer or against presentation of an identity document. Cash is sent by post (para. 3 lit. e) exclusively at the customer’s own risk and own responsibility; ZERO recommends the insured DHL Wertbrief and accepts no liability for loss, theft or damage in the post. ZERO is entitled to refuse cash transactions without giving reasons where there are indications of money laundering (§ 261 StGB).
§ 5 Delivery, shipping, handover
(1) Shipping options:
a) Berlin pickup (free of charge) — the customer collects in person at the workshop appointment or sends a courier of their choice with the booking number (knowledge-based authentication). The pickup slot is released by email link after completion of the service (24h notice).
b) DHL shipping — available internationally with a choice of Standard or Express tier. Shipping prices are shown by country in the configurator (zone pricing). Insurance in accordance with the DHL general terms and conditions.
(2) Delivery time: 1-10 working days after receipt of payment, depending on configuration and country. The exact delivery time is shown in the configurator.
(3) Tamper-evidence options (subject to a charge):
– Tamper-evident outer packaging with serial number and Signal photo hash (+€15)
– Device security seal with photo documentation (+€10)
– Encrypted PIN channel: FDE lock before shipping, PIN transmitted separately via Signal or PGP-encrypted email (+€25)
(4) In the cash-purchase variant, the anonymous procurement of the Pixel device is carried out by ZERO at Saturn/MediaMarkt. Shipping or pickup is possible at the customer’s choice. The surcharge of €105 covers the buyer’s pay, the loss of input tax and the cost of the cash trip.
(5) BYOD orders (the customer brings their own hardware): the customer selects a drop-off appointment in the wizard and brings the device to the workshop. The pickup slot is released by email link after completion of the service.
(6) For consumers, the risk of loss in shipping and the transport risk pass to the customer only upon handover to the customer (§ 475 para. 2 BGB). For entrepreneurs, the risk passes upon handover to the shipping service provider.
(7) Cash drop-off appointment (cash payment on site), cancellation compensation: If the customer chooses cash payment with personal handover as the payment method, they book a workshop appointment (cash drop-off appointment) in the configurator; this appointment is at the same time the time of payment. For the agreed time, ZERO keeps the workshop available exclusively for the customer. The appointment can be rescheduled free of charge via the order link up to 24 hours before it begins. If the customer cancels the appointment less than 24 hours before it begins or does not attend (no-show), ZERO charges a flat-rate cancellation compensation of € 50.00 for the time kept available in vain. The customer retains the right to prove that no damage was incurred at all or that the damage is substantially lower than the flat rate (§ 309 no. 5 lit. b BGB). A new appointment can be arranged once the cancellation compensation has been settled. This cancellation compensation does not apply to the extent that the customer is not responsible for the short-notice cancellation or the non-attendance.
(8) Pickup appointment and consulting appointment, rescheduling and cancellation compensation: For the pickup appointment (para. 1 lit. a) and for Privacy Consulting appointments (§ 2 lit. h), ZERO reserves the agreed time exclusively for the customer. The customer can move both appointments free of charge via the order link up to 24 hours before they start. If the customer reschedules an appointment less than 24 hours before it starts, cancels it within that period or does not attend (no-show), ZERO charges a flat cancellation compensation of 50,00 € for the time held in vain. The customer retains the right to prove that no damage was incurred at all or that the damage is substantially lower than the flat rate (§ 309 no. 5 lit. b BGB). The cancellation compensation does not apply to the extent that the customer is not responsible for the short-notice rescheduling, the cancellation or the non-attendance; it likewise does not apply if ZERO moves or cancels the appointment. Before a short-notice rescheduling, the customer expressly confirms the cancellation compensation in the order link; without this confirmation no new appointment is offered. For the pickup appointment, the cancellation compensation is payable in cash at the new pickup appointment. For the consulting appointment, the new appointment takes place once the cancellation compensation has been settled; it can be paid in cash on site, in cryptocurrency via the order link or by bank transfer. Each further short-notice rescheduling triggers the cancellation compensation anew.
§ 6 Workshop model and ownership
(1) Workshop service orders (Mod Stages, BYOD flash, BYOD Full Privacy) are performed within the framework of the so-called workshop model: ZERO is a workshop service provider that carries out modifications to customer hardware on the customer’s behalf.
(2) Ownership of the hardware remains with the customer at all times. In the BYOD case, the customer brings the device. In the hardware purchase case, ownership passes to the customer once the payment has been booked; modifications are carried out on hardware owned by the customer.
(3) ZERO assumes no manufacturer’s liability within the meaning of the ProdHaftG for the modifications carried out. ZERO is liable only for defects in the workshop work (soldering quality, functional testing) in accordance with § 9 of these T&C.
(4) Conformity of the modifications: The customer commissions the modification as the owner and operator of their own hardware. The customer is aware that, after intervention in assemblies relevant to transmission/reception, a modified device may under certain circumstances no longer be operated under the original CE marking (Funkanlagengesetz [FuAG, German Radio Equipment Act] / RED 2014/53/EU). However, ZERO does not remove any antenna or transmitting assemblies required for radio operation (mobile radio, Wi-Fi, Bluetooth), but exclusively the sensor, microphone or camera components commissioned by the customer; the radio equipment conformity of the device remains unaffected by this. ZERO does not carry out any interventions aimed at the falsification of technical records relevant as evidence or of device identifiers (§ 269 StGB), and documents every modification carried out truthfully.
§ 7 Cash-purchase variant — data minimisation
(1) If the cash-purchase variant is chosen, the hardware is procured by ZERO without a card trail (cash purchase at MediaMarkt/Saturn). This anonymity relates to the procurement side by ZERO.
(2) In the cash-purchase variant, ZERO collects no personal buyer data for identification purposes beyond what is strictly necessary for order processing and statutory retention obligations. This corresponds to the principle of data minimisation pursuant to Art. 5 para. 1 lit. c GDPR.
(3) Mandatory data collection:
– Email address (for order confirmation, pay link, pickup slot link)
– First name (for salutation, accounting entry — the customer may provide any name)
– Country (for mandatory VAT information)
Additionally for shipping:
– Last name
– Delivery address (street, postcode, city)
Never collected:
– Date of birth
– Identity document data (except where the GwG is triggered by a cash transaction ≥ €10,000)
– Telephone number (except optionally for DHL delivery)
(4) ZERO keeps an internal stock record with serial number and date of sale, but without any link to customer data for cash transactions below the GwG threshold. This data minimisation protects customers against data leak risks.
(5) For cash transactions ≥ €10,000 (§ 10 GwG), identification of the contracting party is required. ZERO reserves the right to accept payments from this threshold only by SEPA bank transfer or with presentation of an identity document.
(6) ZERO reserves the right to refuse cash transactions without giving reasons, in particular where there are indications of money laundering pursuant to § 261 StGB.
(7) Relationship between data minimisation and tax obligations: Insofar as statutory invoicing and retention obligations (in particular § 14 UStG, § 147 AO) mandatorily require the collection of certain data, these take precedence over data minimisation; in this case, ZERO collects only the information that is mandatory by law. For small-amount invoices up to €250 (§ 33 UStDV), it is not necessary to state the recipient of the service. Above this limit, or if the customer requests an invoice naming the buyer for the purpose of input tax deduction, the billing address provided by the customer in the configurator is used. The customer determines the scope of the data collected through their own entries. This practice is compatible with Art. 5 para. 1 lit. c GDPR, as the collection remains limited to what is necessary for the respective purpose (performance of the contract, legal obligation).
§ 8 Right of withdrawal for consumers
(1) Consumers have the right to withdraw from the contract within fourteen days without giving any reason. The withdrawal period is fourteen days from the day on which the customer, or a third party named by the customer who is not the carrier, has taken possession of the goods.
(2) § 356a BGB withdrawal button (mandatory from 19.06.2026): Consumers can declare their withdrawal via the “Withdrawal” button linked in the Shop under the order confirmation email.
(3) Consequences of withdrawal: In the event of an effective withdrawal, ZERO reimburses all payments received without undue delay and at the latest within 14 days from the day on which the notice of withdrawal was received. For the reimbursement, ZERO uses the same means of payment as in the original transaction, unless expressly agreed otherwise.
(4) Exclusion of the right of withdrawal (§ 312g para. 2 BGB):
a) For goods manufactured to customer specification (modification orders, BYOD services) — as soon as the workshop work has begun.
b) Where a hygiene shipping seal has been broken.
c) For digital content / voucher codes — as soon as the code has been transmitted to the customer (anonymous vouchers cannot be traced back).
(5) Return costs: The customer bears the direct costs of returning the goods, unless ZERO expressly promises otherwise.
(6) Compensation for loss in value: The customer is only liable for any loss in value of the goods if this loss in value is attributable to handling of the goods that was not necessary to examine the nature, characteristics and functioning of the goods.
(7) The model withdrawal form is sent with the order confirmation email and is also available at /widerruf/.
(8) Withdrawal button (§ 356a BGB): For distance contracts concluded in electronic commerce from 19.06.2026, ZERO provides a clearly legible withdrawal button labelled “Withdraw from contract”, which is linked in the order portal (order status page) and in the confirmation email. Via a subsequent confirmation page, the consumer can declare the withdrawal electronically and in doing so transmit the information required to identify the contract (including the booking number). ZERO confirms receipt of the notice of withdrawal to the consumer without undue delay on a durable medium.
(9) Services (consulting, support, workshop services): For contracts for the provision of services, the withdrawal period begins on the day the contract is concluded. If the customer expressly requests that ZERO begin performance before the withdrawal period expires and then withdraws, the customer owes value compensation for the share of the service provided up to receipt of the withdrawal (§ 357 (8) BGB). The right of withdrawal expires once ZERO has fully performed the service and only began performance after the customer expressly consented and confirmed their awareness of losing the right of withdrawal upon full performance (§ 356 (4) BGB). The cancellation compensation under § 5 (7) and (8) remains unaffected: it is not triggered by a withdrawal, and paying it does not limit the right of withdrawal.
§ 9 Warranty, claims for defects
(1) The statutory claims for defects pursuant to §§ 434 et seq. BGB apply.
(2) For hardware (Pixel devices without modification):
– Consumers: 24 months’ warranty
– Entrepreneurs: 12 months’ warranty
– Google’s original warranty remains unaffected
(3) For modified devices (Mod Stages 1-6, BYOD mods):
– ZERO workshop warranty: 12 months on modification quality (soldering quality, functional testing)
– Google’s original warranty expires upon modification
– The statutory liability for defects in respect of the workshop service (§§ 634 et seq. BGB) remains unaffected; it extends to the proper execution of the commissioned modification, but not to the functional restrictions deliberately commissioned by the customer (e.g. loss of telephony after removal of the microphone). An impairment that is the direct and exclusive consequence of the expressly requested modification does not constitute a defect.
(4) Identification for defect claims: For claims for defects, the original invoice bearing the ZERO inventory number must be presented. In the cash-purchase variant, identification is made via the original invoice bearing the device serial number; no alternative identification of the buyer is required.
(5) Exclusion of warranty:
– Physical damage after handover (drop, water, broken display)
– Software manipulation by the customer (switching to a custom ROM after handover, bootloader re-lock)
– Hardware interventions carried out by the customer after handover
(6) Repair and replacement delivery: In the case of justified claims for defects, ZERO chooses between repair and replacement delivery. If it would be economically disproportionate, ZERO may refuse the other type of subsequent performance.
§ 10 Retention of title
(1) The goods delivered remain the property of ZERO until payment has been made in full.
(2) The following applies to consumers: the customer is obliged to inform ZERO in writing without undue delay of any third-party access to the goods, in particular of any seizures.
§ 11 Liability
(1) Limited liability for defects: ZERO is liable for material defects and defects of title exclusively in accordance with the agreed quality and the provisions of § 9.
(2) Fault: ZERO is liable without limitation for intent and gross negligence as well as under the Produkthaftungsgesetz (Product Liability Act).
(3) Slight negligence: In the case of slight negligence, ZERO is liable only for breach of material contractual obligations (cardinal obligations) and limited to the foreseeable damage typical of the contract.
(4) Exclusion of liability in the cash-purchase variant:
– Loss of the anonymous cash consignment in the course of the shipping risk (cash by mail)
– Loss of the booking number by the customer (knowledge-based authentication risk)
– ZERO hands over devices to ANYONE who can state the correct booking number
(5) Exclusion of liability under the workshop model:
– Functional impairments caused by the hardware modification carried out (e.g. microphone removal → no calls)
– Loss of warranty vis-à-vis Google after modification
– Behaviour of third-party software (banking apps, carrier apps that block GrapheneOS)
(6) Software liability disclaimer: GrapheneOS, F-Droid apps, Mullvad vouchers etc. are third-party software whose functionality ZERO cannot guarantee.
§ 12 Data protection
(1) Personal data is processed in accordance with the separate privacy policy at /datenschutz/.
(2) Principle: ZERO collects only data that is legally required (data minimisation, Art. 5 GDPR).
(3) Processors: 1984 ehf. (hosting, Iceland/EEA), Proton AG (Switzerland, email mailboxes), Hetzner Online GmbH (encrypted off-site backups, DE), BTCPay Server (self-hosted — no transfer to third parties).
§ 13 Dispute resolution, applicable law
(1) ZERO is neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board (pursuant to the VSBG).
(2) Applicable law: German law applies, to the exclusion of the UN Convention on Contracts for the International Sale of Goods (CISG). For consumers, this choice of law applies only insofar as it is not contrary to mandatory consumer protection provisions of the state in which the customer has their habitual residence.
(3) Place of jurisdiction: For disputes between ZERO and entrepreneurs, the place of jurisdiction is Berlin. For consumers, the statutory place of jurisdiction applies.
§ 14 Final provisions
(1) Severability clause: Should individual provisions of these T&C be or become invalid, the remaining provisions shall remain unaffected. The invalid provision shall be replaced by the statutory provision.
(2) Written form: Amendments or additions to these T&C require written form. This also applies to the waiver of this written-form requirement.
(3) Versioning: These T&C are valid in the version dated 2026-09-26. Earlier versions can be viewed on request.
Annex A — Model withdrawal form
If you wish to withdraw from the contract, please complete this form and return it to:
ZERO Cybernetic Systems & Digital Solutions UG (haftungsbeschränkt)
Fidicinstr. 23, 10965 Berlin
Email: contact@zerotrust.is
— I/We () hereby withdraw from the contract concluded by me/us () for the purchase of the following goods () / the provision of the following service ()
— Ordered on () / received on ()
— Booking number (ZRO-…)
— Name of consumer(s)
— Address of consumer(s)
— Signature of consumer(s) (only if this form is notified on paper)
— Date
(*) Delete as appropriate.