Terms and Conditions

These Terms and Conditions (hereinafter – “Terms”) govern the access to and use of the website and the crypto-asset services provided by Veront international s.r.o., a company incorporated under Czech law, with its registered office at Olšanská 2898/4h, Žižkov, 130 00 Praha 3, identification number
22194665 (hereinafter – “the Company”). The Company intends to be authorised by the Czech National Bank (hereinafter – “CNB”) as a crypto-asset service provider under Regulation (EU) 2023/1114 on markets in crypto-assets (hereinafter – “MiCA”), together with Czech implementing legislation including Act No 31/2025 Coll. on the digitalisation of the financial market (hereinafter – “the Digital Finance Act”).

The Company will not present itself as authorised or provide any activity requiring prior authorisation until the CNB grants such authorisation. Upon authorisation the Company will be supervised by the CNB and included in the CNB’s public register of crypto-asset service providers.

1. Scope of Services

The Company will provide only those services authorised and defined under MiCA, specifically: (i) execution of orders on behalf of clients, (ii) providing transfer services for crypto-assets on behalf of clients, (iii) providing custody and administration of crypto-assets on behalf of clients, (iv) exchange of crypto-assets for funds, and (v) exchange of crypto-assets for other crypto-assets. The Company will identify clearly on its website and in its communications which of these services are being used at any time.

2. Contractual Relationship

The relationship between the Company and any natural or legal person using the Services (hereinafter – “Client”) is governed by these Terms together with all service-specific documents referenced herein, including but not limited to the Execution Policy, Custody and Safeguarding Disclosure, Transfer and Exchange Procedures, Complaints Handling Policy, Conflicts of Interest Policy, and Privacy Notice. 

3. Onboarding, Eligibility and Verification

Every Client has the right to register on the Company’s platform. After registering, every Client must complete the onboarding process, which includes customer due diligence in accordance with Czech and EU anti-money-laundering and counter-terrorist-financing rules and screening against international sanctions lists. The Client must provide accurate and up-to-date information and notify the Company of any change without delay. The Company may refuse to open or maintain an account if doing so would contravene law or internal risk criteria.

4. Execution of Orders on Behalf of Clients

The Company executes orders for crypto-assets on behalf of Clients in accordance with its internal Execution Policy. This section summarises the key principles of that policy and forms part of the contractual relationship between the Company and the Client.

Before any order is executed, each Client receives clear and comprehensive information explaining how the Company handles orders, including the factors that determine execution quality such as price, costs, speed, likelihood of execution and settlement, order size, and the custody conditions of the crypto-assets involved. The Client must provide prior consent to the Execution Policy through a legally valid method, which may include electronic confirmation or a signed agreement. The Company maintains verifiable records of such consent.

The Company takes all reasonable steps to achieve the best possible result when executing Client orders, considering a range of factors including price, costs, speed, likelihood of execution and settlement, size, nature, and other relevant aspects. For retail Clients, total consideration (price plus costs) normally carries the greatest weight unless a specific instruction is given. Where a Client issues a specific instruction, that instruction may affect the Company’s ability to achieve the best possible outcome. The Company ensures that Clients are clearly informed of such implications before execution.

Orders are executed through trading platforms and execution venues that have been selected according to objective criteria, including liquidity, price competitiveness, operational reliability, security, and regulatory compliance. The Company maintains and reviews an up-to-date list of these platforms, available upon request. No remuneration, discounts, or non-monetary benefits are accepted from any trading platform in return for routing Client orders, ensuring that execution decisions remain fully independent.

Where an order may be executed outside a trading platform, the Company will inform the Client of this possibility in advance and obtain express consent before proceeding. Such execution will occur only when it serves the Client’s best interest.

The Company continuously monitors the quality of its order execution to ensure adherence to best-execution standards. Monitoring includes real-time tracking of execution metrics, periodic audits, and comparative analysis of venue performance. If deficiencies are identified, corrective measures are promptly implemented, which may include reassessing trading venues, improving internal procedures, or enhancing staff training. Clients are informed where execution deficiencies materially affect their orders.

To prevent conflicts of interest and misuse of order information, the Company enforces strict internal controls. Access to Client order data is limited to authorised personnel, and employees are prohibited from using such information for personal gain or disclosing it to third parties. All order data are processed through secure, encrypted communication channels, and employee activities related to order execution are subject to continuous monitoring and compliance oversight.

Clients may request a detailed execution report from the Company providing the venue, time, price, and other factors influencing execution. Such reports are verified internally before release to ensure accuracy and transparency.

5. Transfer Services for Crypto-Assets

The Company provides transfer services for crypto-assets on behalf of Clients. A transfer consists of the initiation and execution of an on-chain movement of a Client’s crypto-assets from a wallet or account under the Client’s control to a beneficiary wallet or account designated by the Client, or the receipt of a corresponding inbound transfer for the benefit of the Client. The service is available for supported networks and asset types as announced on the Website. Support may vary over time to reflect security, liquidity and regulatory considerations. The Company does not guarantee support for any specific network, token standard or smart-contract functionality and may decline or suspend support where justified by risk, legal or operational grounds. 

Before initiating a transfer the Client must provide accurate beneficiary details, including the correct network, wallet address and any mandatory payment reference, tag or memo. The Client bears the risk of loss arising from inaccurate or incomplete instructions, including the use of an incorrect network or incompatible address format. The Company may, but is not obliged to, implement address-whitelisting or other controls that require additional confirmation before a first-time beneficiary can be used. Transfers are generally irreversible once confirmed on the relevant distributed ledger, and settlement may be probabilistic. The Client acknowledges that confirmation times, fees and finality depend on network conditions outside the Company’s control. 

The Company carries out pre-execution checks to verify the Client’s right to dispose of the assets, to confirm that sufficient balances are available, and to ensure that the transfer complies with legal and regulatory obligations, including sanctions screening and anti-money laundering and counter-terrorist financing controls. Where applicable, information required by the travel-rule framework is collected, transmitted and retained. The Company applies real-time transaction monitoring and may require additional information or supporting documents. A transfer may be delayed, suspended or rejected if required to comply with law, to address security or fraud concerns, or to protect Client assets. The Client will be informed of a rejection or suspension and of any steps necessary to resume processing where permitted by law. 

The Company selects the network path and technical parameters for execution with regard to security, reliability and timeliness. Where more than one network is supported for a given asset, the Company will follow the network selected by the Client in the instruction, subject to feasibility and compliance checks. For certain assets or service configurations the Company may use multi-signature, multi-party computation or similar safeguards and may operate hot, warm and cold storage tiers to balance security and timely processing. The Company maintains internal controls that separate initiation, verification and release functions and records all movements for reconciliation. 

Before the Client confirms a transfer the Company provides clear pre-transaction information in a durable medium, including the asset and amount, the network selected, an estimate of blockchain fees payable to third parties, and any service charge applied by the Company. Blockchain fees are passed through without markup and may change until the transaction is broadcast. Where a transfer cannot be executed at the disclosed cost due to network conditions, the Client will be prompted to confirm an updated estimate or to cancel. After execution the Client receives electronic confirmation with the transaction identifier, time of execution, asset and amount moved, the value date, and a breakdown of charges. The Company provides timely access to transfer history through the Client interface. 

The Company may from time to time enable transfer-optimisation features for supported networks, including batching or layer-two rails, where these improve speed or cost without compromising security. The availability of such features depends on external conditions and may be withdrawn at the Company’s discretion. The Company does not assume responsibility for delays or failures attributable to distributed-ledger congestion, validator behaviour, mempool dynamics or protocol-level events, provided the Company has acted with due skill and care. 

The Client must not use the transfer service for unlawful purposes and must ensure that beneficiary wallets are lawfully controlled and technically capable of receiving the assets on the specified network. The Company may place temporary holds, daily limits or velocity controls on transfers to manage operational and financial crime risk. If a transfer is returned by a third party or otherwise fails after broadcast, the Company will credit or return the relevant amount to the Client as soon as reasonably practicable, net of any non-recoverable network fees. Where a transfer has been routed to a wrong or non-supported address due to Client error, recovery is not guaranteed. Any recovery attempt will be on a best-efforts basis and may incur reasonable costs disclosed to the Client in advance. 

Nothing in this section limits statutory rights. The Company is responsible to the Client for losses directly caused by the Company’s negligence, wilful misconduct or breach of these Terms. The Company is not responsible for indirect or consequential loss, for network-level fees charged by third parties, or for losses arising from protocol failures or third-party custody outside the Company’s control, provided the Company has implemented and applied reasonable organisational and technical measures consistent with these Terms. 

Fees applicable to transfer services are disclosed on the Website and before each transaction and may include a service charge and blockchain fees payable to network participants. The Client remains responsible for any taxes arising from a transfer. The Company does not provide tax advice. Service availability, supported networks and applicable limits are published on the Website and may be updated to reflect security, regulatory or operational requirements.

6. Custody and Administration of Crypto-Assets

The service covers the safekeeping of Clients’ crypto-assets, the maintenance and protection of the means of access to those assets, and, where applicable, the performance of administrative actions connected to them. The Company performs these activities with due skill, care and diligence and in strict compliance with its obligations of segregation, protection, and transparency.

All crypto-assets belonging to Clients are segregated from the Company’s own holdings and from the holdings of other Clients. Segregation is implemented both legally and operationally. The Company maintains accurate, up-to-date records that identify the quantity, type, blockchain network, and wallet designation of each Client’s crypto-assets. These records are reconciled against blockchain data and internal ledgers on a recurring basis to ensure precision and to detect any discrepancy.

Custodied assets are stored using a multi-layered wallet structure consisting of hot, warm, and cold storage tiers. Allocation between tiers is determined by security, liquidity and operational factors. Private keys and equivalent credentials are generated, stored, and used under strict multi-layer access control, with segregation of duties, multi-factor authentication, and cryptographic protection. Every key operation is subject to logging, verification, and periodic review by authorised personnel. The Company’s custody infrastructure is designed to ensure continuity, integrity, and recoverability of all Client assets.

Clients retain full legal ownership of their crypto-assets held in custody. The Company holds these assets solely for safekeeping and administration and has no right of use, lien, or disposal. Client assets cannot be pledged, rehypothecated, or otherwise encumbered by the Company. Any use of Client assets for purposes other than safekeeping requires the Client’s explicit written consent and must comply with all legal requirements.

The Company applies an internal control system ensuring that every crypto-asset held in custody is linked to a unique Client identifier and that each movement of assets is verified and authorised by at least two designated officers. The custody system operates on the principle of separation between initiation, verification, and execution functions. Regular reconciliation procedures are performed daily for active wallets and periodically for long-term storage, with prompt investigation and correction of any inconsistency.

Where the Company delegates part of its safekeeping duties to an external sub-custodian, it does so only after performing comprehensive due diligence covering the sub-custodian’s technical competence, financial standing, governance framework, and regulatory compliance. The Company remains fully responsible to Clients for any act or omission of such sub-custodian. The identity and jurisdiction of any appointed sub-custodian are disclosed to Clients in a durable medium before delegation takes effect.

The Company maintains a detailed business continuity and disaster recovery plan covering all custody operations, including contingency procedures for loss or compromise of private keys. Secure, encrypted backups of critical data and key material are kept in separate, geographically distributed facilities within the European Union. The plan provides for controlled restoration of access to Client assets under the supervision of the management body and in coordination with the Czech National Bank if required.

In addition to safekeeping, the Company may provide administration services, which include the facilitation of Client participation in events or benefits linked to the held crypto-assets, such as staking, airdrops or governance votes, when legally and technically feasible. These activities are carried out only with the Client’s explicit consent and in a manner that preserves segregation and security. Details of supported administrative functions and applicable terms are available on the Website.

In the event of the Company’s insolvency, all Client crypto-assets are excluded from the insolvency estate. The Company’s records and segregation framework are designed to allow for prompt identification and restitution of Client assets. The Company will cooperate fully with insolvency administrators and the supervisory authority to ensure that Clients can recover their assets without undue delay.

The Company maintains adequate insurance coverage for custody operations, providing protection against risks such as theft, cyber incidents, or loss of private keys due to operational failure. The existence and scope of insurance do not limit the Company’s statutory liability but supplement its financial capacity to compensate Clients for eligible losses.

The Company is liable to the Client for the loss of any crypto-asset or the means of access to such assets resulting from negligence, wilful misconduct, or breach of these Terms by the Company or any sub-custodian. The Company is not liable for losses arising from blockchain malfunctions, consensus failures, or protocol-level events outside its control, provided that it has exercised due skill and care and maintained reasonable organisational and technical safeguards consistent with these Terms.

7. Exchange of Crypto-Assets for Funds and for Other Crypto-Assets

The Company provides exchange services that allow Clients to convert crypto-assets into fiat currency or to exchange one crypto-asset for another. These services are provided under the Company’s authorisation as a crypto-asset service provider and are governed by these Terms, MiCA, and Czech law.

When requesting an exchange, the Client instructs the Company to execute a transaction at the price and on the conditions displayed through the Company’s platform at the time of confirmation. The price quoted represents the rate offered by the Company for immediate settlement and includes all applicable service charges unless otherwise stated.

The Company acts honestly, fairly, and in the best interests of its Clients when arranging or executing exchanges. All transactions are settled as promptly as possible after the Client’s instruction has been verified, provided that the necessary funds or crypto-assets are available and that legal and technical conditions permit settlement.

Prices and available pairs are displayed transparently on the Website. The rates offered reflect prevailing market conditions but may vary according to liquidity, network congestion, or other external factors beyond the Company’s control. The Company does not guarantee the continued availability of any exchange pair and may temporarily restrict or suspend an exchange service if required for legal, regulatory, operational, or security reasons.

Before confirming an exchange, the Client receives clear information regarding the applicable rate, the amount of each asset to be exchanged, and any fees or charges. Once confirmed, the Client’s order becomes binding and cannot be revoked after execution has commenced. The Client acknowledges that blockchain transactions are generally irreversible once validated.

All fiat transactions are processed through payment service providers or credit institutions authorised within the European Union. The Company segregates Client fiat funds from its own assets in accordance with applicable law. For crypto-to-crypto exchanges, the Company executes transactions directly on the relevant network and records each transaction for reconciliation and audit purposes.

The Company may temporarily delay or refuse to execute an exchange instruction where necessary to comply with law, to prevent fraud or market abuse, or to protect Client assets during periods of exceptional market instability. The Client will be notified of such action unless disclosure is prohibited by law or regulatory direction.

Fees and charges for exchange services are published on the Website and displayed prior to order confirmation. Fees may vary according to asset type, transaction size, and prevailing network conditions. The Client remains responsible for any third-party network or payment-service fees and for any taxes arising from the transaction.

The Company is responsible for losses directly caused by its negligence, wilful misconduct, or breach of these Terms. It is not responsible for losses arising from external events such as market volatility, third-party system failures, or blockchain-level disruptions, provided that the Company has acted with due skill and care.

By using the exchange service, the Client acknowledges and accepts the risks inherent in crypto-asset transactions, including price volatility, liquidity risk, and the potential for rapid market changes. The Company does not provide investment advice or guarantees regarding the future value of any crypto-asset.

8. Fees, Costs and Taxes

The Client is responsible for all fees, costs and charges arising from the use of the Company’s services. The applicable fees are published on the Website and may be updated at the Company’s discretion. The version in force at the time of a transaction applies.

The Company does not charge fees for the opening, maintenance or closure of wallets. For exchanges between crypto-assets, a 0.75 percent commission applies to the transaction value. For conversions between crypto-assets and fiat currency, a 0.3 percent commission applies. These transactions are processed exclusively through SEPA-compliant bank transfers. Transfers involving the exchange of one crypto-asset for another without fiat involvement are subject to a 0.3 percent fee. Transactions executed on the Company’s peer-to-peer (P2P) platform are subject to a 0.1 percent commission. Where a P2P transaction includes a fiat component processed through a SEPA bank transfer, an additional 25 CZK fee applies. Network, payment-service or banking fees charged by third parties are borne by the Client and passed through at cost. The Company may amend its fees or introduce new ones at any time. Changes take effect upon publication on the Website.

All fees become due immediately upon execution of the relevant transaction and are deducted automatically from the amount involved. Fees are non-refundable unless the Company cancels the transaction before execution.

The Client bears any taxes, duties or other public charges arising from their transactions. The Company does not provide tax advice.

9. Risk Disclosure

High risk of loss. Trading and holding crypto-assets involves significant risk. Prices are highly volatile and you may lose the entire amount invested. Past performance is not a reliable indicator of future results. Protections typical of securities or bank products may not apply to crypto-assets or to the platforms where you buy, sell, borrow, lend, or stake them. 

No guarantee of value or redemption. Most crypto-assets are not legal tender and are not backed by a central bank or guaranteed by any public authority. They are generally outside deposit guarantee or investor compensation schemes. “Stable” tokens can lose their peg and redemptions may be delayed, restricted, or unavailable. 

Technology and custody risks. Use of crypto-assets entails operational and cybersecurity risks, including loss or theft of private keys, wallet or smart-contract failures, irreversible transfers sent to the wrong address, network congestion, forks or protocol changes, and outages at wallet providers, trading venues, or custody providers. Self-custody mistakes can be permanent and irrecoverable. 

Market and liquidity risks. Crypto markets can experience sharp intraday movements, thin liquidity, and disorderly trading. Prices may be impacted by market manipulation, fraud, or failures at trading venues. Certain products (for example, margin or derivatives) introduce additional risks such as liquidation if collateral becomes insufficient. 

Regulatory status and protections. Under the Markets in Crypto-Assets Regulation (MiCA), firms must provide information that is fair, clear, and not misleading and warn clients about risks. MiCA protections apply only where services are provided by EU-authorised entities and do not extend to unregulated products or to services from unauthorised or non-EU firms. Consumers should not assume that authorisation for some services implies the same protections for all products offered on the same platform. 

Czech Republic consumer guidance. The Czech National Bank highlights risks associated with offers to the public under MiCA, including volatility, information asymmetry, and the absence of guarantees, and urges careful review of disclosures before investing. 

Taxes and suitability. Transactions in crypto-assets may be taxable. You are responsible for understanding and meeting your tax obligations. Crypto-assets are not suitable for everyone: only invest money you can afford to lose and ensure you understand how the product works and the specific risks before transacting. Nothing on this website constitutes investment, legal, or tax advice. 

How to protect yourself. Check whether the provider is authorised in the EU (Veront is currently in the process of obtaining an European license), read risk disclosures and (where applicable) the relevant white paper, use secure wallet practices, enable strong authentication, and be alert to promotions that could be misleading about the scope of regulatory protections.

10. Conflicts of Interest

A conflict of interest arises where the Company’s interests, or the interests of any person connected with the Company, may diverge from the Client’s interests, where one Client could be favored over another, where the Company carries on the same business as a Client, or where the Company receives a monetary or non-monetary benefit from a third party in connection with a service. Conflicts may also occur between Clients competing for a scarce opportunity. Both categories fall within the scope of this chapter.

The Company gives priority to prevention. Services are designed so that sensitive information and decision making are separated where appropriate, access is restricted to personnel who need it, and any staff member who may be conflicted is reassigned away from the relevant engagement. If a listing, placement, market making, lending, staking or validator activity presents a foreseeable conflict, the Company implements structural measures before launch or does not proceed. Where prevention cannot neutralise the risk without prejudice to the Client’s interests, the Company may decline or cease the engagement.

The Company applies management measures where a conflict cannot be fully prevented. Information barriers are reinforced, execution models are adjusted, timing or blackout windows are used where relevant, books are rebalanced and responsibilities are reassigned so that no party is unfairly advantaged. Front-running and any misuse of Client information are prohibited. Where liquidity is scarce, the Company applies neutral and pre-defined allocation and routing rules and keeps complete records to demonstrate equal treatment.

Disclosure is used only to address residual risk after prevention and management. If a remaining conflict could still be relevant to the Client’s decision, the Company will provide an electronic notice before the Client decides whether to proceed. The notice will describe the nature and source of the conflict, the mitigation already applied, the residual risk and the available options. Language will be clear and comprehensible for non-experts. If residual risk cannot be reduced to a level consistent with the Client’s best interests, the Company will not proceed.

Where a conflict materialises or controls fail, the Company acts promptly. The affected activity is paused, relevant records and evidence are secured, impact on Clients is assessed and appropriate remedies are applied without undue delay. Remedies may include unwinding or correcting transactions where permitted, re-performance on neutral terms, fee waivers or refunds, price adjustments to a documented benchmark, compensation where justified, priority execution where appropriate and organisational changes to prevent recurrence. Where disclosure is required, it is provided before the Client makes any further decision that could be affected and the Client’s acknowledgement is recorded.

Client choices are respected. A Client may request further information about a disclosure, may refuse to proceed with a conflicted service and may raise concerns at any time through the contact channels on the Website. On request, the Company will provide an electronic copy of its Conflicts of Interest Management Policy, subject to limited redactions for security-sensitive controls and personal data.

Conflicts governance is active. The management body approves and oversees the conflicts framework and bears ultimate responsibility for it. Day-to-day operation is led by the person responsible for conflicts management. The Company tests the effectiveness of its controls, maintains a central register of conflicts cases and reviews the policy at least annually. Public disclosure on the Website is updated when services or risks change.

The Company provides contact details for conflicts matters on the Website. The Company will acknowledge receipt of queries or concerns, explain next steps and keep the Client informed until resolution.

11. Complaints Handling

Clients may submit complaints by email to [info@veront.com], via the web form on the Company’s website, or by post. Complaints are acknowledged without undue delay, investigated impartially, and resolved within a reasonable period. The Company will inform the Client of the outcome and of available escalation mechanisms, including out-of-court resolution where applicable under Czech law. Complaints data are analysed regularly to identify systemic issues and improve service quality.

12. Data Protection

The Company processes personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Czech data-protection law. The Privacy Notice available on the website describes the purposes of processing, lawful bases, retention periods, data-subject rights and contact details of the data-protection officer. Processing necessary for contract performance and for legal compliance is mandatory.

13. Termination

The Company may suspend or terminate Services where required by law, for security reasons, or due to a Client’s breach of these Terms. The Client may terminate the relationship at any time after settling outstanding obligations. Upon termination the Company will return to the Client all crypto-assets and funds lawfully belonging to them, subject to legal holds, security interests and technical feasibility.

14. Liability

The Company is liable to Clients for losses resulting from negligence, wilful misconduct or breach of statutory duty, including loss of crypto-assets or of means of access attributable to it or to its delegated custodian. The Company is not liable for losses arising from market fluctuations, blockchain malfunctions, acts of public authorities or force-majeure events that are beyond its control, provided it has taken reasonable steps to mitigate such effects.

15. Amendments

The Company may amend these Terms to reflect legal, regulatory or operational changes. Clients will be notified via e-mail and through their personal profile before the amendments take effect unless immediate change is necessary to comply with law or maintain security. Continued use of services after the effective date constitutes acceptance of the amended Terms.

16. Governing Law and Jurisdiction

These Terms are governed by the laws of the Czech Republic. Disputes will be subject to the jurisdiction of the courts of Prague, without prejudice to any mandatory rights of consumer Clients to bring proceedings in their state of residence. The contractual language is Czech.

17. Contact and Regulatory Information

The Company can be contacted at its registered office K Červenému dvoru 3269/25a, Prague, 130 00, by email at info@veront.com, or by telephone at +420 725 731 110. Information about its authorisation status and supervisory authority will be published on the website after authorisation together with a link to the CNB register of crypto-asset service providers.