General Terms and Conditions (T&C)
ZERO Cybernetic Systems & Digital Solutions UG (haftungsbeschränkt)
§ 1 Scope of Application, Contractual Parties
(1) These General Terms and Conditions (hereinafter “T&C”) apply to all orders processed through the online shop website (hereinafter “Shop”) of ZERO Cybernetic Systems & Digital Solutions UG (haftungsbeschränkt), Fidicinstr. 23, 10965 Berlin, Germany (hereinafter “ZERO” or “we”).
(2) A consumer within the meaning of these T&C is any natural person who concludes a legal transaction for purposes that are predominantly outside their trade, business or profession (§ 13 BGB / German Civil Code). An entrepreneur is a natural or legal person or a partnership with legal capacity who, when concluding a legal transaction, is acting in the exercise of their trade, business or profession (§ 14 BGB).
(3) The version of these T&C valid at the time of contract conclusion is decisive.
(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 Products and Services
(1) ZERO offers the following services:
a) Hardware sales: Google Pixel smartphones (models 9a through 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. 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 minutes).
d) Hardware modifications (Mod Stages): Physical removal or deactivation of individual components (microphones, motion/environmental sensors and/or cameras) performed on the customer’s express order on the customer’s own hardware within the workshop model (§ 6). The customer is aware of and expressly requests that the removed functions cease permanently (e.g. no telephony after microphone removal) and that this voids the manufacturer’s warranty and, where applicable, the radio-equipment conformity (CE/RED) of the affected assembly. The components removed per Mod Stage are listed to the customer in the configurator before the order is placed. ZERO does not intervene in any mobile-radio, Wi-Fi or Bluetooth transmit/receive assemblies and does not alter any device identifiers.
e) Bring-Your-Own-Device (BYOD) workshop service: GrapheneOS installation and/or modification on customer-provided hardware.
f) Voucher resale: Authentication vouchers for third-party services (Threema, Mullvad VPN, SMS-Pool). Customer activates own accounts using the accompanying guide.
g) Accessories: Cases, privacy screens, Faraday bags, wired headsets.
h) Privacy consulting: Hourly consultation for individual setups.
(2) All hardware modifications are provided under the workshop model: hardware ownership remains with the customer at all times. ZERO is a workshop service provider, not a manufacturer within the meaning of the German Product Liability Act (ProdHaftG).
(3) GrapheneOS is free open-source software under MIT/Apache license. ZERO is not the developer or maintainer.
§ 3 Contract Formation
(1) The presentation of products in the online shop does not constitute a legally binding offer, but rather an invitation to order (invitatio ad offerendum).
(2) By completing the configurator wizard and clicking “Submit order & receive payment link”, the customer makes a binding offer to conclude a contract.
(3) Contract formation occurs upon receipt of an order confirmation by email. For online prepayment (BTC/XMR/SEPA), the order becomes legally binding only after payment confirmation. For Cash Prepayment or Cash-by-Mail, the order becomes legally binding upon verification of the cash receipt.
(4) The contract language is German. Orders can also be processed in English.
(5) The contract text is stored by ZERO and sent by email to the address provided by the customer after contract formation. The booking number (format ZRO-YYYY-XXXXXX) serves as the unique contract reference.
§ 4 Prices, Payment
(1) All prices in the shop include statutory VAT (19%) pursuant to the German Price Indication Ordinance (PAngV). Shipping costs are added for delivery (zone-dependent, DE €9.90 to Worldwide €299.90), as displayed in the configurator.
(2) Hardware prices are aligned with current market prices for Pixel devices. ZERO reserves the right to adjust prices periodically (typically daily) to reflect market developments. For orders already completed, the price displayed at the time of ordering applies.
(3) Accepted payment methods:
a) Bitcoin (BTC) via BTCPay Server — prepayment, order release after confirmation
b) Monero (XMR) via BTCPay Server — prepayment, order release after 10 confirmations
c) SEPA bank transfer — prepayment, order release upon receipt of funds (1-3 business days)
d) Cash prepayment at workshop appointment — available for pickup or shipping orders. Customer or courier delivers cash to ZERO during the chosen drop-off slot. Service starts only after verification. For amounts of €10,000 or more, identification pursuant to § 10 of the German Anti-Money Laundering Act (GwG) is required (ID presentation, copy).
e) Cash by mail (registered insured letter) — pickup mode only. Customer sends cash by DHL Wertbrief with booking number reference to the ZERO workshop. Max €10,000 per order. Higher amounts require in-person handover with ID or SEPA transfer. Postal cash transmission at customer’s own risk.
(4) The customer may only offset claims against ZERO’s claims if their counterclaim has been legally established or is undisputed. The same applies to the exercise of rights of retention vis-à-vis entrepreneurs.
(5) Anti-money-laundering compliance and cash by mail: ZERO accepts cash only within the statutory framework. For cash payments, the identification obligation under § 10 of the German Money Laundering Act (GwG) applies from a threshold of € 10,000; at or above this threshold ZERO accepts payment exclusively by SEPA transfer or against presentation of ID. Sending cash by mail (para. 3 lit. e) is done solely at the customer’s own risk and responsibility; ZERO recommends the insured DHL registered-value letter and assumes no liability for loss, theft or damage in transit. ZERO is entitled to refuse cash transactions without stating reasons where there are indications of money laundering (§ 261 StGB).
§ 5 Delivery, Shipping, Handover
(1) Shipping options:
a) Berlin pickup (free) — customer picks up in person during workshop appointment or sends a courier of their choice with the booking number (knowledge-based authentication). Pickup slot is released by email link after service completion (24h minimum lead time).
b) DHL shipping — internationally available with tier selection Standard or Express. Shipping prices are country-dependent and displayed in the configurator (zone pricing). Insurance per DHL general terms.
(2) Lead time: 1-10 business days after payment receipt, depending on configuration and country. Exact lead time displayed in configurator.
(3) Tamper-evidence options (paid add-ons):
– Tamper-evident outer packaging with serial number and Signal photo hash (+€15)
– Device security seals with photo documentation (+€10)
– Encrypted PIN Channel: FDE lock before shipping, PIN transmission separately via Signal or PGP-encrypted email (+€25)
(4) For the cash-procurement variant, anonymous procurement of the Pixel device is performed by ZERO at Saturn/MediaMarkt. Shipping or pickup is available at customer’s choice. Surcharge €105 covers buyer compensation, VAT-deduction loss, and cash-trip effort.
(5) BYOD orders (customer brings own hardware): customer selects a drop-off appointment in the wizard and brings the device to the workshop. Pickup slot is released by email link after service completion.
(6) Risk of loss and damage during shipping passes to the consumer customer only upon handover (§ 475 (2) BGB). For entrepreneurs, risk passes upon handover to the shipping service provider.
§ 6 Workshop Model and Ownership
(1) Workshop service orders (Mod Stages, BYOD Flash, BYOD Full Privacy) are provided under the so-called workshop model: ZERO acts as a workshop service provider performing modifications to customer hardware on customer order.
(2) Hardware ownership remains with the customer at all times. In the BYOD case, customer provides the device. In the hardware-purchase case, ownership transfers upon payment verification; modifications are performed on customer-owned hardware.
(3) ZERO assumes no manufacturer liability under ProdHaftG for the performed modifications. ZERO is liable only for defects of the workshop work (solder quality, function testing) pursuant to § 9 of these T&C.
(4) Conformity of modifications: The customer commissions the modification as owner and operator of their own hardware. The customer is aware that a modified device may, after intervention in transmit/receive-relevant assemblies, no longer be operated under its original CE marking (Radio Equipment Act [FuAG] / RED 2014/53/EU). However, ZERO does not remove any antenna or transmit assemblies required for radio operation (mobile, Wi-Fi, Bluetooth), only the sensor, microphone or camera components commissioned by the customer; the device’s radio-equipment conformity is unaffected. ZERO performs no interventions aimed at falsifying evidentiary technical records or device identifiers (§ 269 StGB) and documents every modification truthfully.
§ 7 Cash-Procurement Variant — Data Minimization
(1) When choosing the cash-procurement variant, hardware procurement is performed by ZERO without card trail (cash purchase at MediaMarkt/Saturn). This anonymity refers to the procurement side by ZERO.
(2) ZERO does not collect personal customer identification data within the cash-procurement variant beyond what is strictly necessary for order processing and statutory retention obligations. This complies with the principle of data minimization pursuant to Art. 5(1)(c) GDPR.
(3) Mandatory data collection:
– Email address (for order confirmation, payment link, pickup slot link)
– First name (for salutation and accounting entry — customer can provide any preferred entry)
– Country (for VAT compliance)
Additional data for shipping:
– Last name
– Delivery address (street, postal code, city)
Never collected:
– Date of birth
– ID data (except GwG trigger ≥ €10,000 cash transaction)
– Phone number (only optional for DHL delivery)
(4) ZERO maintains an internal inventory log with serial number and sale date, however without linkage to customer data for cash transactions below the GwG threshold. This data minimization protects customers from data leak risks.
(5) For cash transactions ≥ €10,000 (§ 10 GwG), identification of the contractual party is required. ZERO reserves the right to accept payments above this threshold only via SEPA transfer or with ID presentation.
(6) ZERO reserves the right to refuse cash transactions without stating reasons, in particular in case of indicators for money laundering pursuant to § 261 StGB.
(7) Relationship between data minimization and tax obligations: Where statutory invoicing and retention obligations (in particular § 14 UStG, § 147 AO) mandatorily require the collection of certain data, these prevail over data minimization; in such cases ZERO collects only the legally mandatory information. For small-value invoices up to € 250 (§ 33 UStDV) the designation of the recipient is not required. Above this limit, or where the customer requests an invoice with buyer designation 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 handling is compatible with Art. 5(1)(c) GDPR, as collection remains limited to what is necessary for the respective purpose (performance of contract, legal obligation).
§ 8 Right of Withdrawal for Consumers
(1) Consumers have the right to withdraw from this contract within 14 days without giving any reason. The withdrawal period is 14 days from the day on which the customer, or a third party named by the customer who is not the carrier, has taken physical possession of the goods.
(2) § 356a BGB Withdrawal Button (mandatory from June 19, 2026): Consumers can declare withdrawal via the “Withdrawal” button linked in the shop and order confirmation email.
(3) Consequences of withdrawal: In case of effective withdrawal, ZERO refunds all payments received without undue delay and at the latest within 14 days from the day on which the withdrawal declaration is received. ZERO uses the same payment method for the refund as for the original transaction, unless expressly otherwise agreed.
(4) Exclusion of withdrawal right (§ 312g (2) BGB):
a) For goods manufactured to customer specifications (modification orders, BYOD services) — once workshop work has begun.
b) For hygiene-shipping-seal-broken items.
c) For digital content / voucher codes — once the code has been transmitted to the customer (anonymous vouchers are non-traceable).
(5) Return shipping costs: Customer bears the direct costs of returning the goods, unless ZERO expressly assures otherwise.
(6) Compensation for value loss: Customer must only compensate for value loss of the goods if such value loss is attributable to handling of the goods that is not necessary to examine the nature, characteristics and functioning of the goods.
(7) Sample withdrawal form is included in the order confirmation email and available at /withdrawal-form/.
(8) Withdrawal button (§ 356a BGB): For distance contracts concluded electronically from 19 June 2026, ZERO provides a clearly legible withdrawal button labelled “Withdraw from contract”, linked on the order portal (order-status page) and in the confirmation email. Via a subsequent confirmation page the consumer can declare the withdrawal electronically and submit the information required to identify the contract (including the booking number). ZERO confirms receipt of the withdrawal declaration to the consumer without undue delay on a durable medium.
§ 9 Warranty, Defect Claims
(1) Statutory defect claims pursuant to §§ 434 et seq. BGB apply.
(2) For hardware (Pixel devices without modification):
– Consumer: 24 months warranty
– Entrepreneur: 12 months warranty
– Google original warranty remains unaffected
(3) For modified devices (Mod Stages 1-6, BYOD mods):
– ZERO workshop warranty: 12 months on modification quality (solder quality, function testing)
– Google original warranty expires with modification
– The statutory liability for defects of the workshop service (§§ 634 ff. BGB) remains unaffected; it covers the proper execution of the commissioned modification, but not the functional limitations deliberately commissioned by the customer (e.g. loss of telephony after microphone removal). An impairment that is a direct and exclusive consequence of the expressly requested modification does not constitute a defect.
(4) Defect identification: For defect claims, the original invoice with ZERO inventory number must be presented. For cash-procurement variant, identification is via original invoice with device serial number; alternative buyer identification is not required.
(5) Warranty exclusion:
– Physical damage after handover (drops, water, display breakage)
– Software manipulation by customer (custom ROM swap after handover, bootloader re-lock)
– Self-performed hardware interventions after handover
(6) Repair and replacement delivery: For justified defect claims, ZERO selects between repair or replacement delivery. ZERO may refuse the other type of subsequent performance in case of economic disproportionality.
§ 10 Reservation of Title
(1) The delivered goods remain ZERO’s property until full payment.
(2) For consumers: Customer is obligated to immediately inform ZERO in writing about third-party access to the goods, in particular about attachments.
§ 11 Liability
(1) Limited liability for defects: ZERO is liable for material and legal defects exclusively according to the agreed quality and the provisions in § 9.
(2) Fault: ZERO is liable without limitation for intent and gross negligence as well as under the Product Liability Act.
(3) Slight negligence: ZERO is liable for slight negligence only for breach of essential contractual obligations (cardinal obligations) and limited to the contract-typical, foreseeable damage.
(4) Liability exclusion for cash-procurement variant:
– Loss of anonymous cash shipment during shipping risk (cash-by-mail)
– Loss of booking number by customer (knowledge-based authentication risk)
– ZERO hands devices to ANYONE who can name the correct booking number
(5) Liability exclusion for workshop model:
– Functional impairments from performed hardware modification (e.g. microphone removal → no calls)
– Warranty loss vis-à-vis Google after modification
– Software behavior of third parties (banking apps, provider apps blocking GrapheneOS)
(6) Software liability disclaimer: GrapheneOS, F-Droid apps, Mullvad vouchers etc. are third-party software whose functionality cannot be guaranteed by ZERO.
§ 12 Data Protection
(1) Processing of personal data is conducted in accordance with the separate Privacy Policy at /privacy/.
(2) Principle: ZERO collects only data legally required (data minimization 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, being set up — no third-party transfer).
§ 13 Dispute Resolution, Applicable Law
(1) ZERO is neither willing nor obliged to participate in a dispute resolution procedure before a consumer arbitration board (per VSBG).
(2) Applicable law: German law applies, excluding the UN Convention on Contracts for the International Sale of Goods (CISG). For consumers, this choice of law applies only insofar as 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, statutory jurisdiction applies.
§ 14 Final Provisions
(1) Severability clause: Should individual provisions of these T&C be or become invalid, the remaining provisions remain unaffected. The invalid provision is replaced by the statutory regulation.
(2) Written form: Changes or additions to these T&C require written form. This also applies to the cancellation of this written-form requirement.
(3) Versioning: These T&C are valid in the version dated 2026-05-15. Earlier versions are available upon request.
Appendix A — Sample 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, Germany
Email: contact@zerotrust.is
— I/We () hereby withdraw from the contract concluded by me/us () for the purchase of the following goods () / 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 notification on paper)
— Date
(*) Delete as inapplicable.