Terms of Service

This page explains your and our rights and responsibilities regarding the services we provide through our website and mobile app. Please read these Terms of Service carefully before using our services. To help you better understand these Terms, we provide simplified explanations in highlighted boxes throughout the document. While these summaries are helpful guides, the full legal text always takes precedence if there are any differences. All communications are prepared in plain and understandable language as required by EU regulations.

All communications, including these Terms, our Website, mobile application, emails, and any promotional materials, are prepared in accordance with the EU Markets in Crypto-Assets Regulation (MiCA).

• All marketing and promotional materials shall be fair, clear, and not misleading.
• All promotional statements shall be consistent with these Terms of Service and the Risk Disclosures.
• Kriptomat does not provide investment advice. All information, including marketing content, is general in nature and must not be interpreted as a personal recommendation.

ACCEPTANCE OF TERMS OF SERVICE

These Terms of Service (“Terms”) represent the agreement between you (the “Client”) and FintechX OÜ (“Kriptomat”) and govern your use of our Services. By using our website, registering for the Kriptomat Account, using a mobile application, or any other services, products, or any other data or materials available through our website www.kriptomat.io (“Website”) or mobile application (“Services”), it is considered you agree with these Terms of Service, acknowledge them,  and you are entering into a business relationship with us. 

The term “we”, “Kriptomat platform”, “us”, and “our” refers to Kriptomat. Depending upon the context, “Kriptomat” may also refer to the services, products, Website, content, or other materials provided by Kriptomat. The terms “you”, “user”, “client”, and “Website visitor” refer to you as a user of our services. 

These Terms incorporate the Privacy Policy and Risk Disclosure and Warning on Crypto Assets and Appendices, as well as any other policies published on the Website referring to these Terms. By accepting these Terms, you agree with and accept all such notices and policies published on the Website.

IN CASE YOU DO NOT AGREE TO THESE TERMS OF SERVICE, DO NOT ACCESS THIS WEBSITE AND DO NOT USE OUR SERVICES.

By clicking “I agree with the Terms of Service and the Privacy Policy”, you confirm that you have read, understood, and accept these Terms, which then become a legally binding agreement between you and us. 

Kriptomat reserves the right to change, add, or remove parts of these Terms at any time and at its sole discretion. We will inform you of the changes in advance through your Account or via Email notification. It is your responsibility to familiarise yourself with the amended Terms. Your continued use of Services following the entry into force of amended Terms shall constitute and be interpreted as your acceptance of the changes, and your subsequent use of Services will be subject to the amended Terms.

These Terms include appendices that are an integral part of these Terms, in particular, applicable to our specific product and services. It is considered that you consent to them by accepting these Terms. 

The version of the Terms is indicated in the last section of the Terms.

If you have any questions or comments, please contact us at [email protected]. You agree that your feedback may be used to improve and/or modify our Website and Services without any limitation or obligation for any payment, and you grant us a non-exclusive, perpetual, worldwide free-of-charge license to use your feedback and suggestions for improving our services, while retaining any moral rights you may have in such feedback.

ABOUT KRIPTOMAT AND OUR SERVICES 

FintechX OÜ is an Estonian private limited company, having its statutory seat at Osmussaare 8, 13811  Tallinn, Estonia, company number 14424637, and provides services under the Kriptomat trademark. Kriptomat owns the domain www.kriptomat.io and is a platform for buying, trading, investing, and custody of crypto assets.  

We encourage you to learn about crypto regulation, which aims to ensure companies provide services following the best standards and earn your trust. You can find complete, up-to-date information about our company, licenses, and registrations on our Impressum page. Never settle for less. You should at all times know who you are doing business with and to whom you trust your assets.

LICENCE AND REGISTRATIONS

Kriptomat is currently authorised as a Virtual Asset Service Provider (VASP) under Estonian law and supervised by the Estonian Financial Intelligence Unit (FIU). With the entry into force of the EU Markets in Crypto-Assets Regulation (MiCA), VASP authorisations will transition to Crypto-Asset Service Provider (CASP) licences. Kriptomat has initiated the authorisation process under MiCA to ensure a smooth transition. Until the CASP licence is granted, Kriptomat continues to operate under its valid Estonian VASP licence and other registrations in the EU, as listed below.

Our Services are provided based on our primary termless licence, issued by the Estonian Ministry of Finance, Financial Intelligence Unit (“FIU”), No. FVT000310

(LINK TO PUBLIC REGISTRY) , for the provision of the following services:

• Providing services for exchanging crypto assets against a fiat currency;
• Providing services for exchanging crypto assets against other crypto assets;
• Providing a crypto asset wallet service;
• Providing a crypto asset transfer service.

The Company is subject to the supervision of the Estonian Financial Intelligence Unit based on Estonian Anti-Money Laundering and other regulations. 

Kriptomat also holds several secondary registrations for providing the crypto asset services listed above in the following countries and with regulating bodies as indicated below:

• Greece, Hellenic Capital Market Commission – Registered provider of exchange services between virtual currencies and fiat currencies and Custodian wallet provider, entry into the registry 25th May 2021.  
• Spain, CNMV – National Securities Market Commission- Registered Virtual Assets Service Provider, registration number D718 – Bank Of Spain registry, entry in the registry 21st October 2022.
• Poland, Tax Administration Chamber – Registered Virtual Assets Service Provider. Registration number RDWW-408, Virtual Currency Business Register,  entry in the registry 9th August 2022.
• Croatia, HANFA, Croatian Financial Services Supervisory Agency – included in the registry of companies from EU member states that submitted a notification to Hanfa about the provision of services related to virtual currencies in the territory of the Republic of Croatia. Entry in the registry, 18th July 2023. 
• France, Autorité des marchés financiers (AMF) – Registered 5th September 2023, registration number E2023-095.  

Kriptomat is registered as a Digital Asset Service Provider by the Autorité des marchés financiers (AMF) with the approval of the Autorité de Contrôle Prudentiel et de Résolution (ACPR).

The following services are available to French clients:

• Digital assets custody 
• Purchase/sale of digital assets for fiat and vice versa 
• Trading of digital assets against other digital assets
• KritpoEarn 
• Intelligent Portfolios

Services not specifically listed above are not available to French clients.

Other specifics applicable solely to French clients: 

• LIABILITY FOR OUTSOURCED SERVICES – Our services also include some services provided by third parties (outsourced services). We take full responsibility for the services we provide through outsourcing as if we were providing the services directly ourselves, subject to limitations from the previous paragraph. When we outsource services, we take full responsibility for ensuring the same level of quality and commitment as if we were providing them ourselves.
• DOUBLE VERIFICATION REQUIREMENT – Upon onboarding, you are required to verify your identity through our Know-Your-Client (“KYC”) verification process and make a bank deposit in the minimum amount as identified in the interface. Please note that you cannot use our services until the double verification is successfully performed. After a successful KYC verification and receiving your bank deposit, you may start using our services. 

CROSS-BORDER SERVICES

Kriptomat is licensed as a Virtual Asset Service Provider (VASP) in Estonia and is registered or notified with competent authorities in several other EU Member States, as listed above.

The EU Markets in Crypto-Assets Regulation (MiCA) entered into force on 29 June 2023. The provisions applicable to Crypto-Asset Service Providers (CASPs) apply from 30 December 2024. As an existing VASP authorised in Estonia, Kriptomat benefits from the transitional grandfathering period until 31 July 2026 and continues to provide services under its valid Estonian VASP licence and other EU registrations, until CASP authorisation is granted by the competent authority.

Once Kriptomat receives CASP authorisation under MiCA, services will be provided on an EU-wide basis under a single licence, through the passporting regime available to CASPs.

OTHER SERVICES

Besides our regulated services, we offer other services and products as shown on our Platform. We do not exchange crypto-assets that qualify as financial instruments under MiCA, applicable Estonian law, or EU financial services legislation. We only facilitate transactions in crypto-assets that fall within our regulatory authorisations. Kriptomat reserves the right to immediately suspend or terminate access to any service that may require additional regulatory authorizations.

To be clear, we do not offer financial investment services. No information, service, or product on our Platform constitutes investment advice and must not be interpreted as such.

Kriptomat is not a payment institution and does not provide financial payment services. Any fiat deposited to our bank account and shown in your Account will be considered a prepayment. Fiat shown in your Account after selling crypto assets will be available for withdrawal to your bank account. The same applies when you exchange different crypto assets. The crypto-assets in your Kriptomat account are held by us as custodian on your behalf, segregated from our own assets, and protected in accordance with MiCA Article 82 safeguarding requirements. These assets remain your property and represent our obligation to you, executable through transaction orders. 

The Company facilitates all fiat transactions through authorized electronic money institutions, specialized financial institutions, and/or payment service providers, with which it has special arrangements.

TRANSLATION OF OUR SERVICES 

To guarantee that our Services are fully understood and accessible, parts of our Services have been translated. We may add or remove supported languages at any time, at our discretion. English is our official language. If there are discrepancies between the English version and any other language, the English version is the correct one. For all formal communications (for example, with banks or the  authorities), English must be used.

Some sections of the Website or Service may not be translated and may only be available in English. Translations demonstrate our commitment to client care and fraud prevention, ensuring that you understand who we are, and the nature and purpose of our Services.

You are responsible for ensuring that you understand our Services, notifications, and all other communications from us. While we provide translations as a convenience, we cannot be held liable for any misunderstandings, losses, or damages arising from translation issues or language barriers. If you do not understand our Services or their potential consequences, you must not use them. This limitation of liability does not affect your mandatory rights under applicable consumer protection laws.

To help your experience in visiting our Website and/or using our Services safely, we use translations into several languages as we happily use the advantage of the translation tools. Yet, we remain an Estonian crypto company, so consider this when entering into a business relationship with us.

Important Notice: 

Subpages in different languages ​​represent only translations of the Website www.kriptomat.io and not individual domains. The translations of the Website are intended solely to help with understanding the content of Services and a mere translation shall in no case represent an active solicitation. By enabling translated Services we wish to increase the security and awareness of the clients (for more information please refer to the Fraud Prevention section), however, the clients must be and are considered to be explicitly aware that by accepting these Terms and by using Services, they enter into a contractual relationship with an Estonian company, and the contractual relationship is regulated in accordance with the Estonian legislation, and further subject to countries in which we hold VASP registrations. 

Outside of markets where we are licenced or hold VASP registration, we might not be permitted to actively solicit our Services. You represent and warrant that regardless of the translation and language used to communicate, you chose to access and use our Services on your initiative and not as a result of our solicitation and/or promotion.

RESTRICTIONS ON THE SERVICES AVAILABILITY 

Depending on your country of residence, statutory seat, or place of incorporation, you may be restricted or prohibited from using some or all the functions of our Services. Our Services are to be used solely by clients, natural or legal persons, who are residents, are incorporated, or have their real seat in jurisdictions where crypto-asset services are permitted. We reserve the right to immediately suspend or terminate access to our Services if we determine that you are accessing them from a restricted jurisdiction or in violation of applicable laws. We shall not be liable for any losses arising from such restrictions or terminations when implemented in compliance with regulatory requirements. You are responsible for following those rules and the laws of your country of residence and/or country from which you access our Services. More information about the availability of our Services and restricted or prohibited areas is available at the following link: https://kriptomat.io/global/

For security or technical reasons, certain crypto assets may not be transferred outside the Kriptomat Account.

Certain functionalities of specific crypto assets may be limited. In the process of listing crypto assets, Kriptomat is following its internal listing policy and safety requirements, regulations, and good market standards. Therefore, some crypto assets may only have a buy and sell option, without the option to transfer them outside your Kriptomat Wallet. You will be notified about this before placing a buy/sell order and will have to agree with it beforehand.

PRIVACY AND DATA PROTECTION

FintechX OÜ acts as the data controller of your personal data within the meaning of the EU General Data Protection Regulation (GDPR).

We process your personal data on the following lawful bases:

• Contract (Art. 6(1)(b) GDPR): to provide our services to you.
• Legal obligation (Art. 6(1)(c) GDPR): to comply with AML/KYC requirements, tax reporting, and other regulatory obligations.
• Legitimate interests (Art. 6(1)(f) GDPR): to prevent fraud, ensure the security of our services, and improve our operations.
• Consent (Art. 6(1)(a) GDPR): where required for marketing communications or optional features, which you may withdraw at any time.

We do not intentionally process special categories of personal data (Art. 9 GDPR). Where biometric or identity verification data is processed for compliance purposes, this will be limited to what is strictly necessary and subject to appropriate safeguards.

Some compliance-related decisions may be based on automated processing (e.g., transaction monitoring or fraud detection). Where such automated decisions produce legal effects or significantly affect you, you have the right to request human intervention, express your point of view, and contest the decision.

We retain your personal data only for as long as necessary to fulfil the purposes described above, and in particular for at least five (5) years after the end of the business relationship, in line with Estonian AML legislation.

Where we transfer personal data outside the European Economic Area, such transfers are safeguarded by adequacy decisions or by the use of Standard Contractual Clauses (SCCs) approved by the European Commission. You can obtain a copy of these safeguards by contacting our DPO. We conduct and document transfer impact assessments for all international data transfers in accordance with applicable laws and regulations, including GDPR and relevant European Data Protection Board guidance. For transfers to countries without an adequacy decision, we implement supplementary technical safeguards including encryption, access restrictions, and pseudonymisation in line with the Schrems II ruling. We maintain the right to update our transfer mechanisms as required by evolving regulatory requirements or judicial decisions. Any such changes will be communicated to you in accordance with our Privacy Policy.

You have the following rights under GDPR:

• Right of access to your personal data;
• Right to rectification of inaccurate or incomplete data;
• Right to erasure (“right to be forgotten”);
• Right to restriction of processing;
• Right to data portability;
• Right to object to processing based on legitimate interests;
• Right not to be subject to a decision based solely on automated processing, including profiling.
  

You may exercise these rights by contacting our Data Protection Officer at [email protected]. You also have the right to lodge a complaint with your local data protection authority or with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at https://www.aki.ee. 

For further details, please refer to our full Privacy Policy at https://kriptomat.io/privacy-policy/

CREATING KRIPTOMAT ACCOUNT

Step 1: Registration  

You can create a Kriptomat Account by registering on our platform by providing your email, and full name and creating a password of your choice. Registration is also possible through Google and/or Apple accounts. All information and instructions regarding the registration process are available on the registration page. For more information please visit the tutorial page How to Open a Kriptomat Account. 

By creating your Kriptomat Account, you represent, warrant and verify that:

• You fully understand and accept these Terms;
• You fully understand and accept our Privacy Policy;
• You have read and understood the Risk disclosure and Warning on Crypto assets
• You are a minimum of 18 years of age;
• In case you are applying for a legal entity, you are its legal representative or are duly authorized to act on behalf and in the name of the legal entity; 
• You have the full legal capacity to accept these Terms and enter into a business relationship with us;
• The purpose of entering into a relationship with us is to use crypto-related services for yourself and you are not under control or instructed to use our services by third parties;
• You are a resident of a country where crypto assets are not prohibited or restricted;
• In the case of a legal entity, you represent an entity that is incorporated or has a real seat in a country where crypto assets are not prohibited or restricted; 
• Our formal language is English. 

Two-Factor Authentication 

During the setup of your account, you are required to set up two-factor authentication (2FA). You can get more information about the 2FA in the article “What is two-factor authentication?”. 

Step 2: Verification of Your Identity 

The verification process is also known as the Know-Your-Client process. Identity verification is a mandatory step and is required by regulatory obligations applicable to us, commencing from KYC rules, anti-money laundering, and combating the financing of terrorism, fraud, and other financial crime prevention. We will guide you through the verification process of the application. For more information please read KYC / AML / CTF POLICY and Privacy Policy. 

Until we successfully verify your identity you will not be able to use your Account and or Services. The validation of your account is subject to our assessment of compliance with regulatory requirements and risk management policies, which are detailed in our Risk Management Policy available on our website. Such actions may be taken without prior notice where necessary for legal compliance or risk management purposes. You are obliged to provide us with true and accurate information. Should we discover any attempt to provide falsified information, we might submit a report to the competent authority. Furthermore, you are obliged to inform us in case of a change concerning such information. Upon the expiry of your identity documentation, we will request to provide us with valid documentation. 

Kriptomat Account 

Each user is allowed one verified Kriptomat Account, which displays their fiat and crypto asset balances. The Account is not a fiat money account; the fiat balance only reflects the amount of fiat money available for purchasing crypto assets or for withdrawal to the user’s bank account and/or card.

All prices on the Kriptomat platform and fiat transaction orders are only supported in euros (EUR).

The Account interface will display any additional fiat currencies that become available for fiat deposits.

You can exchange any cryptocurrency asset on the Kriptomat platform for ETH, BTC, or USDC (crypto asset pair trading). We may remove any crypto asset pairs at any time. The exchange value is displayed when placing an order, but the final value isn’t determined until the order is processed. This is because the value of the crypto asset may change during the transfer execution time.

Funding Your Account 

Fiat funding

You can fund your Account by transferring fiat via a bank transfer, a credit/debit card payment, or using other available payment options (Skrill, Paypal, and others). If using a credit card or other payment methods other than bank transfer, you can make a purchase in your currency and the conversion into EUR currency will be automatically made by the payment processor subject to possible additional cost on your behalf. 

The list of supported countries is available on our Website, the section Supported counties with listed funding and withdrawal options. 

When making a credit card deposit, you guarantee to us that you own the credit card or that you are authorized to use it. If we suspect that the used credit card is not yours, then this can result in us freezing your assets and restricting your account. Suspicious transactions may be reported to the law enforcement authorities.

The purchase may be subject to the minimum purchase amount as defined in your Account interface. 

Our bank account details and payment options are available in the Account interface under the deposit section displaying the available methods of deposit. When making a deposit please include your personal reference number because it serves as your payment identifier and significantly helps to process your deposit quicker. 

You will receive a notification when the transaction has been successfully processed and the fiat balance is available on your account. We will credit the amount received (the “Fiat Account Balance”) to your Account, displayed under Fiat balance. The Fiat Account Balance is equivalent to the Fiat amount Kriptomat received from you, deducted for the fee as indicated in the interface. 

All transactions are subject to AML & CFT checks.  

Fiat deposits are usually completed in a few hours or minutes. However, it can take a longer time subject to the banking processing systems. We have no control over the banking processing of the deposit, and we cannot guarantee a minimum time to receive the deposit. We cannot be held responsible for any damages related to your deposits. 

Deposits and withdrawals are subject to certain fees and limitations, displayed in your Account interface. For more information please refer to the Fees and Limits section. 

Crypto funding

You can also fund your Account by transferring crypto assets to blockchain wallet addresses which are controlled by Kriptomat (“Wallets”) in the course of our custodial services. When we receive your crypto deposit, the amount is displayed in your Wallet as crypto balance, whereas your assets are transferred into our custody, namely secure cold storage.  

To make our services as convenient for you as possible, we are constantly updating and adding new payment methods and features. Please always refer to information in the Account interface as the information there is up-to-date and valid.

You can make deposits from your different accounts and credit cards, subject to   AML & CTF-related limitations. You also represent and warrant that you are not on any trade or economic sanctions lists, such as the United Nations Security Council Sanctions List or other administrative law enforcement agencies. 

Rejected Deposit 

Your fiat deposit might be rejected on our side or the bank’s side.

We will reject the deposit and return the asset to the sender if the deposit was made by a third party. Your family and friends are also considered third parties, except in cases where you have a joint bank account. We reserve the right to charge refund process expenses and make a deduction from the third-party deposit.

We may also reject the deposit for other reasons subject to our unilateral decision, for example, and not exclusive to an indication of certain risk factors, performing a service on behalf of someone else, or an indication of third-party interference. 

What if Your Bank Rejects the Deposit? 

If your bank rejects the processing of your deposit on your account there are two most common reasons: 

• the bank does not allow transactions with crypto-related companies, either due to internal policy decisions or based on such instruction from the national banking authority in the form of a general crypto ban, or 
• the bank disables the transaction with us due to their internal risk indicators or fraud suspicion. 

We put a serious fight against fraud, however, there is a small percentage of cases where we cannot prevent fraud, mostly in situations when the clients enable full remote access and control of their user accounts to fraudulent brokers, when clients provide us with false information or situations related to credit card misuse. If the client makes a complaint to the bank or if the enforcement authority makes an official inquiry, some banks might put our bank account on the so-called “black list”, and transactions to listed bank accounts on the “black list” are automatically rejected. That is the reason why, in some cases, you will see a notice that the “transaction was declined due to fraud suspicion” or a similar notice. That is because your bank wants to protect you and we respect that. 

In no case does the bank deposit rejection demonstrate the illegitimacy of our company. Having a bank deposit rejected is a bad user experience and is not consistent with our client focus principle, but we understand that the bank only wants to protect its clients. Kindly note that we are unaware of any issue with the bank until we receive a notification from you on the deposit rejection. Once we become aware of the issues with the bank, we will reach out to the bank and provide a comprehensive introduction to our business, so that they can verify our business. We encourage you, and we would highly appreciate it if you notify us in case you have any issues with sending a deposit through your bank. We will then further coordinate with the bank to ensure that you will be able to transact with us smoothly.

Please send us the information about any issues you have concerning transactions with our company to our support team at [email protected]. 

Withdrawal Orders – Fiat 

The bank accounts from which we received your fiat deposits are considered verified if the name of the bank account owner matches your name (verified Kriptomat account). 

Please note that you can only make withdrawals to your verified bank accounts; withdrawals to other bank accounts are not possible. 

You can make a withdrawal to your credit card account as well, in which case you are obliged and you guarantee to us that the credit card is yours. You can only make a withdrawal to a credit card account you have previously used and saved for purchase/deposit. 

Withdrawal Orders – Crypto 

You can withdraw (send) your crypto assets to a crypto wallet of your choice. All transfers are at your sole discretion and sole responsibility. Be careful to always enter the wallet address to which you wish to transfer your crypto assets.

We shall in no event be responsible for the transfer of your crypto assets outside your Kriptomat account.

CRYPTO-ASSET TRANSFER SERVICES

This section explains how crypto transfers work on Kriptomat, including how you send crypto to another wallet and what happens after you confirm a transfer. Crypto transfers are made directly on the blockchain and are usually irreversible, so it is important to double-check recipient details and be alert to scams. Kriptomat executes transfers on your instructions, shows fees before you confirm, and lets you track the transaction status in your account. It also explains when transfers may be delayed or refused, how fees are charged, and when Kriptomat is responsible if something goes wrong.

This section forms an integral part of the Kriptomat Terms of Service and governs the provision of crypto-asset transfer services by Kriptomat in accordance with Regulation (EU) 2023/1114 (MiCA), including Article 82(1). By accepting the Terms of Service, the user agrees to the terms applicable to crypto-asset transfer services.

The user may withdraw from these services by closing their Kriptomat account. Such closure does not affect transfers that have already been initiated or executed prior to termination.

General description of the service

Crypto transfer service means on-chain transfer of a selected crypto asset from one blockchain address to another on a blockchain supporting the asset of choice, which is similar to transferring funds from one account to another account. Unlike a bank transfer, crypto transfers are generally irreversible, so a user should make sure that input details are correct and should always verify details with the intended recipient. Given the generally irreversible nature of transactions, users should pay special attention to risks related to fraud and scams, which can be found in the relevant section of these Terms and Conditions.

Users interact through accounts on the web or mobile platform, while Kriptomat manages on‑chain addresses. Kriptomat holds custodial wallet private keys and executes only on‑chain transfers on client instructions, while attaching legally required originator and beneficiary  information and safeguarding user assets according to MiCA and the EU Transfer of Funds Regulation. Internal transfers between users of Kriptomat are also processed on‑chain. No off-chain transfers are supported by Kriptomat.

When a user initiates a transfer, the user selects appropriate inputs, such as selecting the crypto asset, selecting one of the supported blockchains, enters recipient address and travel rule details, whereas Kriptomat signs it using securely stored private keys, and broadcasts it to the relevant blockchain network. The system tracks transaction status on‑chain (pending, confirmed, failed, replaced) and updates the customer’s transaction history once the transaction reaches the required confirmation depth. Transaction status is displayed to the Client in near real time in the transaction history section of the Client’s account.

Screening tools and analytics are applied at the address and transaction level, and transfers that intersect with high‑risk on‑chain entities can be delayed, blocked, or escalated for manual review.

Crypto-Asset Transfer Instructions

Through Kriptomat’s web or mobile interface, the client specifies the crypto asset, the amount, and the destination address, as well as recipient details. Transfer Instruction Form presented to the user informs in real time of the relevant blockchains supported for the transfer of the selected crypto asset.

For a transfer to be properly initiated and executed, the client must provide complete and accurate information as requested in the transfer form, including recipient details and any legally required originator or beneficiary information. First-time withdrawals to a newly added address are subject to additional verification.

Kriptomat may refuse to act on, or may delay, any instruction that is incomplete, appears erroneous, fails authentication, or raises legal, regulatory, or fraud‑prevention concerns, and may request additional confirmations before execution.

The ability to withdraw or amend a transfer instruction is extremely limited for any blockchain network. Once the client has provided final confirmation, the transaction is broadcasted to the relevant blockchain network and instruction generally becomes irrevocable. Client may request cancellation of a crypto transfer instruction, but Kriptomat cannot guarantee cancellation or recall of the transfer, unless the broadcast to the relevant network was rejected by the network, is pending due to technical issues or is pending manual review due to incomplete information or legal, regulatory, or fraud‑prevention concerns. For incoming crypto deposits, even though settlement times may vary depending on the network – any crypto-asset deposit reflected in your personal account with status “succsessful” is considered irreversible by the originator, regardless of number of confirmations on blockchain (DLT). Successful crypto-asset deposits are notified via e-mail.

Execution and cut-off times

Instruction is considered received after final confirmation by the user. Relevant records of the instruction, including time stamp and its status are available in the web and mobile interface of Kriptomat. 

Fully compliant transfers are processed immediately upon acceptance and broadcasted to the relevant blockchain network shortly after the receipt of the instruction, subject to technical and network conditions. Blockchain confirmations occur on a 24/7 basis. 

Transfers that are escalated to manual review due to incomplete information or legal, regulatory, or fraud‑prevention concerns, will be processed within 1 hour of receipt of satisfactory additional information from the user during business hours (09:00–17:00 CET on business days). 

For transactions triggering manual review referred to above, cut-off time for same-day execution is 16:30 CET on business days and transactions falling under manual review after the cut-off will be processed the following business day. 

The transfer execution status updates to “Completed” once the crypto-asset transfer is successfully broadcasted to the network, and a “transaction hash” is logged in the transaction history detail allowing the user to monitor transaction status in real time using relevant blockchain explorers. For each crypto-asset and supported DLT network, the reasonably estimated time and/or number of block confirmations required for a transfer to be considered irreversible (or sufficiently irreversible in the case of probabilistic settlement) is determined based on the technical characteristics of the relevant network. 

Users will be notified of any technical delays in execution not related to manual review via e-mail and/or push notifications. Notifications will be sent to the users without undue delay, upon discovery of the technical issue causing the delay of execution, latest within 24 hours of discovery. Notification will indicate reason for the delay, types of transactions affected, expected resolution time and communication channel for obtaining additional information.

Error handling

If the transaction broadcast fails, depending on the reason – it will be automatically retried or paused and flagged for manual investigation. 

For each status change, the client will receive a status update (e.g., “transfer completed”, “transfer pending” or “transfer failed”). Live monitoring of the blockchain confirmation status is possible through a link in the transfer history section. 

If a transaction is rejected, returned or suspended, the user will be informed of the reason via e-mail and/or app notification, as well as about remedies where applicable (e.g. missing, insufficient or incorrect beneficiary details).

Crypto Transfer Fees

All applicable fees are disclosed transparently prior to transfer instruction confirmation by the user, including:

• fixed service fees as defined in the Fees and Trading Limits Policy, if any
• any variable blockchain network (miner) fees, if any
• applicable dynamic charges, which are calculated in real time, if any.

Where exact amounts cannot be known in advance (e.g., miner fees), estimated fees are displayed, and the final fee is confirmed after transaction execution.

Where the user does not agree with displayed fees or crypto transfer service conditions, the user shall terminate the process and shall not proceed with the transfer instruction confirmation.

Crypto Transfer Service Liability

Users will be notified of suspected security or fraud threats and of any relevant delayed transactions via e‑mail promptly upon discovery. Kriptomat applies its best efforts to combat fraud and protect its users, but it is ultimately users own responsibility to be prudent and act with reasonable care, including:

• Carefully verify the recipient’s identity and wallet address before authorising any crypto transfer, as blockchain transactions are generally irreversible and misdirected funds may be permanently lost. 
• Exercise heightened caution when responding to unsolicited investment offers, requests to move funds, or third‑party instructions received via social media, messaging apps, phone, or e‑mail, and independently confirm that any such request is legitimate.
• Protect their login credentials and authentication codes, and ensure that no third party can access their devices or accounts, as any transaction initiated using valid credentials shall be deemed authorised by the user.
• Regularly review account activity and promptly report any suspected unauthorised or fraudulent transaction to Company and, where applicable, to law‑enforcement or other competent authorities.

Kriptomat assumes liability for unauthorised transfers or transfers executed by Kiptomat not in accordance with the user instructions, and users are entitled to refund for such qualifying incidents.

Liability arising from user fraud, user negligence or user intentional attempts to misuse and/or manipulate Kriptomat systems are explicitly excluded. 

Claims must be submitted without undue delay, in accordance with Complaint Handling Policy, either through e-mail [email protected], support chat, or dedicated complaints channel https://kriptomat.io/submit-a-complaint/. For fraud related cases a dedicated channel is available: https://kriptomat.io/fraud-report/  

The Company will investigate user claims and respond within 15 calendar days. The response shall contain resolution and its reasoning, as well as alternative dispute resolution ways for cases where the user is not satisfied with the outcome of investigation.

To the extent permitted by applicable law, Kriptomat liability for execution of crypto transfer service shall always be limited to refunding the incorrectly executed transfer or unauthorised transfer, and shall exclude any liability for indirect, incidental or consequential losses.

SUSPENDING OR RESTRICTING YOUR ACCOUNT FUNCTIONALITIES 

Subject to our internal AML and security measures, regulatory requirements, and risk management policies, we may immediately and without prior notice temporarily or permanently restrict, suspend, or terminate your Account access or any functionality thereof. This includes situations where we reasonably suspect unauthorized access, fraud, regulatory violations, market manipulation, or other violations of our Terms or applicable law. 

Based on your Account profile, provided answers, your transaction analysis, and other information received from you or third parties, we may–based on our sole discretion–decide to restrict one or more of the following functionalities within your Account:

• Crypto asset withdrawals to external wallets
• Fiat to crypto asset exchange transactions
• Crypto asset exchange to fiat transactions 
• Crypto to crypto exchange transactions
• Credit card withdrawals
• Fiat withdrawal 
• Crypto asset deposit
• KriptoEarn
• Intelligent portfolio
• Vault
• Credit card deposit
• Instant deposit (SEPA)
• Credit card withdrawal.

Although the most common reason for such restrictions is to ensure your safety due to the risk of potential fraud, there are other reasons as well.

The temporary suspension of certain functionalities may also be due to a pending transaction review or account review. For more information, visit our support article. 

Disabling certain Account features is our sole right and we reserve the right to unilaterally decide on such Account actions. If you decide to exchange crypto assets back to fiat due to the disabled withdrawal option, this constitutes a new transaction. In no case are we responsible for further transaction fees, nor for any possible loss of value (no refund policy).

CUSTODY AND ADMINISTRATION OF CRYPTO ASSETS 

Kriptomat holds your crypto-assets and fiat funds in custody with the highest level of security and in accordance with the EU Markets in Crypto-Assets Regulation (MiCAR).

Kriptomat provides custody and administration of crypto-assets on behalf of clients in accordance with Regulation (EU) 2023/1114 (MiCA), including Article 75. By accepting these Terms, the client enters into an agreement with Kriptomat governing the holding, administration, and safeguarding of crypto-assets.

Segregation of Assets
All client assets are held separately from Kriptomat’s own funds and are clearly identified in our records and accounts. Your assets are legally segregated and will not form part of Kriptomat’s estate in the event of insolvency.

No Use Without Consent – Transaction and Asset Management
Kriptomat will not use, lend, pledge, or rehypothecate your assets for its own account or for the benefit of third parties without your explicit prior consent. Kriptomat provides custodial services by holding and administering crypto-assets and fiat funds on behalf of clients, executing on-chain transfers only upon client instruction, and maintaining records of client holdings.

When a client initiates a transaction, including the transfer of assets into or out of their Kriptomat account, the transaction is processed in accordance with defined internal controls. These controls include verification of client instructions, appropriate authorisation steps, and the use of secure systems and communication channels to reduce the risk of unauthorised access or fraudulent activity.

All asset movements are recorded promptly in Kriptomat’s internal systems, ensuring that client balances and holdings accurately reflect executed transactions. This enables ongoing reconciliation and monitoring and helps minimise the risk of inconsistencies between client instructions and the execution of asset transfers.

Safekeeping Obligations
Kriptomat applies organisational and technical security measures, including multi-signature controls, wallet segregation, access controls, and monitoring systems, to safeguard client assets.Client crypto-assets are safeguarded using industry-standard security practices, including multi-signature technology and has implemented measures based on ISO27001:2022 Information Security standard. Assets are held using a combination of hot and cold wallets, with the majority of long-term holdings secured in cold storage due to its higher level of security. 

Fiat funds are held in segregated accounts with authorised credit institutions, payment service and liquidity service providers.

Reporting and Transparency

Kriptomat provides clients with clear and timely information about their crypto-asset holdings through secure web and mobile interfaces. Clients can view account balances, transaction history, and asset movements in near real time and access historical data at any time. 

Liability
Kriptomat is liable for the safekeeping of your assets, except where loss results from external events beyond our reasonable control (e.g., force majeure, systemic blockchain failure).

We carefully select our financial payment service and liquidity providers. If a financial payment service provider or crypto liquidity provider becomes insolvent and/or enters into bankruptcy proceedings, your rights to claim compensation will be subject to the specific circumstances, but we cannot guarantee that you will be able to claim compensation directly in your name.

Kriptomat will always take all reasonable steps to recover and, where applicable, compensate you for any loss of assets caused by our failure to comply with our custody obligations.

Fees

Kriptomat does not charge fees for custody of Crypto assets.

ORDER PLACEMENT AND NO ORDER CANCELLATION POLICY

We will execute your order immediately. Please be careful when placing an exchange order. Once initiated, it is not possible to cancel or change it. Should you wish to make a reverse transaction (e.g. you purchase fiat for BTC and wish to cancel the order and reverse the assets to fiat), that is not possible. You can only make another exchange order from crypto to fiat.Due to the technical nature of our services, there is no refund option!  In case you initiate a refund request with your bank and we deduct that you already sent the purchased crypto to a crypto wallet outside our system, or the refund is unjustified for other reasons, we may request an administrative fee to cover the expenses we incurred with processing the refund claim. Finally, we reserve the option to deduct such a fee from your account value.

You will receive the purchased crypto asset into your wallet instantly (within a few minutes), subject to network conditions, liquidity availability, and technical factors beyond our control. We do not guarantee specific execution times and are not liable for delays or failures caused by blockchain network congestion, technical issues, force majeure events, or third-party service provider outages. In case of significant service disruption, we will notify you in accordance with our Service Availability Policy and MiCA Article 68 obligations. In case you do not receive your crypto assets within 24 hours, please contact our support: [email protected]. 

You are fully responsible for your transactions. Any mistakes, errors, or defects in the course of any transaction, either resulting in partial or total loss of your crypto assets, are attributable solely to you. While you are responsible for providing correct transaction details, we remain liable for losses caused by our own negligence, willful misconduct, or breach of our obligations under these Terms or applicable law. Our liability for your losses resulting from your own actions is excluded to the extent permitted by law. 

RECURRING BUY/INVESTMENT ORDER 

As part of our Services, you can set a continuous payment plan for recurring purchases.

Our Recurring Buy option provides you with an option to schedule regular order(s) for future purchases of crypto assets or investments in intelligent portfolios. By setting up a recurring purchase plan of crypto assets, you authorize us to initiate recurring electronic payments in accordance with your Recurring Buy Order Plan and corresponding payment methods as made available by us and chosen by you. Multiple Recurring Buy Orders for different crypto assets may be set in accordance with limits as set with these Terms. 

To activate recurring crypto asset purchases you are required to activate your Kriptomat Recurring Buy Order functionality by setting your Recurring Buy Order Plan on our platform. Your Recurring Buy Order Plan consists of a selected crypto asset of your choice, your corresponding payment method (credit card, fiat balance), the selected value of Recurring Buy Orders, payment period selection (weekly, bi-weekly, or monthly), and day of Buy. Your Recurring Buy will occur in identical, periodic instalments and based on your period selection as defined in your Recurring Buy Order Plan. You may cancel or edit the Recurring Buy Order at any time. We reserve the right to cancel or decline a Recurring Buy Order at any time without stating the reasons. We may at any time terminate the Recurring Buy Order as a service by providing a notice to you.  

The Recurring Buy option may include certain limitations pertaining to (1) Recurring Buy Order Plans being limited to a certain maximum number; (2) the minimum and maximum value of individual Recurring Buy Order per month; (3) the daily limits (aggregate value of all Recurring Buy Orders per day); (4) the monthly limits (aggregate value of all Recurring Orders per month); (5) payment options, and (6) any other limits as set in the Recurring Buy Order settings. The limit settings are dynamic and may be unilaterally changed by us from time to time. The limits as outlined in the system are applicable. 

In case your bank or credit card issuer is unable to process any payment to us, or you do not have sufficient fiat assets deposited in your Account, we will consider this as a delayed order transaction, followed by additional order attempts within the following 25 (twenty-five) days with automatic client notification of the pending order status. If additional transaction attempts are also not successful, the Recurring Buy Order will be automatically terminated and you will receive the cancellation notification. We may charge you for any cost or remedies we incur as a result. 

Authorization to initiate recurring electronic payments in accordance with your Recurring Buy Order Plan on your behalf will remain in full force and effect until you change or cancel your Recurring Order Plan in plan settings or until you provide us with written notice of termination sent to [email protected]. You are required to notify in writing of any changes in your bank account information. Third-party credit cards are not allowed and we will decline any Recurring Buy service in all cases where the owner of the credit card will not match the client.

CLOSING KRIPTOMAT ACCOUNT AND ADMINISTRATIVE FEE

You closing your Account: You may close your account at any time by choosing the closing option within your Kriptomat Account, Account information section, or placing an Account closing order to client Support, subject to an account balance of 0.00 euros, and following the settlement of any pending transactions. 

Closing your Account by us: We may close or limit your Account on notice and at our sole discretion. We can close, limit, suspend, or freeze your Account partially or completely for the following reasons: 

• Suspicious activities related to your Account, indicating possible relation to illicit activities such as fraud, money laundering, financing terrorism, and weapons of mass destruction financing;
• Attempts to gain unauthorised access to the Website and/or circumvent security features of our Service;
• Violations of these Terms;
• Upon the request of law enforcement or other competent authorities;
• Using our services in a way that is inconsistent with our rules and the purpose of our services;
• Other circumstances that invoke necessary measures for legal compliance and safety;
• Failure to comply with security protocols and use of our services in a manner that is inconsistent with good information security practices, and which may lead to misuse of our services by the user or third parties;
• Using our services through third parties (e.g. by installing remote access);
• Technical reasons;
• Any attempt to gain unauthorised access to our Website or Accounts of our users either by yourself or by assisting third parties, including disclosing information them about our security measures;
• in case of non-payment of outstanding obligations to us;
• in case of inappropriate behaviour and inappropriate offensive or violent communication with us.

At the time of the Account closing, the value of your fiat and crypto balance needs to be zero, meaning any remaining fiat or crypto assets will need to be transferred to your bank account or external crypto wallets. A small deposit from your bank account for verification purposes might be needed in case you did not make any previous deposits from the bank to which you wish to make a withdrawal. This is required to verify that the bank account is yours. If needed, our support team will gladly help you with the offboarding process.

We will provide you with sufficient time to empty your Kriptomat account. If you do not transfer your crypto assets to external wallets within the agreed time frame and their value exceeds 25 EUR, we will convert them to EUR at the prevailing market rate and transfer the proceeds to your designated bank account, deducting only reasonable conversion fees which will be disclosed to you in advance. If we do not have your bank account information, we will place your fiat into escrow and notify you with further instructions. Please note that certain fees may be charged for escrow services.

If, at the time of account closure, the total value of your remaining assets is less than 25 EUR, Kriptomat may apply an administrative fee equal to the value of those assets to cover the costs of processing the closure and related banking or operational expenses. This means that balances below 25 EUR may not be returned to you upon closure of your account. For transparency, this fee is not a penalty but a cost-recovery measure, reflecting the minimum expense incurred by Kriptomat in processing account closures.

By closing your account, additional processing and bank costs may be imposed on your behalf. Such costs will be reasonable and proportionate to the actual expenses incurred by Kriptomat in processing your account closure.

After Closing your Kriptomat Account we will retain your personal data that we obtained from you during the onboarding process, data on your activities within your Account, and any other data obtained from you during our relationship for the period in accordance with the AML regulations. More about the deletion of your personal data is available in our Privacy Policy. 

You will be responsible for any obligations towards us and any fees incurred before the Account closing. 

Kriptomat may suspend, limit, or terminate your account at any time and at our sole discretion, upon notice to you by e-mail or other communication channels, particularly in cases where: (a) we suspect or detect unauthorized or fraudulent use of your account or security credentials; (b) we reasonably believe you have breached these Terms; (c) we are required to do so by law, regulatory authority, or court order; (d) you pose an unacceptable regulatory or fraud risk; (e) you provide any false, incomplete, inaccurate, or misleading information; or (f) we detect technical or security risks to our platform. While we will endeavor to provide advance notice where possible, immediate suspension may occur in cases of suspected fraud or security risks. You may appeal any such decision through our Complaint Handling Procedure. Subject to applicable law and MiCA requirements, Kriptomat will not be liable to you for any losses incurred in connection with a good faith suspension, limitation, or termination of your account.

PROCEDURE IN CASE OF USER’S DEATH OR LOSING ITS LEGAL CAPACITY 

In case of a user’s death, we will deactivate the Account immediately after receiving notification of the death. Authorization, if previously existent,  for a deceased person is not valid, therefore we inform about the status of the Account only based on a request by the lawyer of the deceased user’s heirs with a demonstrated legal interest, or based on a court request. We will transfer the assets of the deceased, if they exist,  in accordance with the final court decision on inheritance. The Account of a deceased person will not be transferred to the heirs as the Account will be closed, and the assets will be transferred to the account as instructed in the court decision or other formal order, in which case we will provide instructions on the transfer. 

In case we are notified of a case of losing the legal capacity of our user, we will only allow access to the Account to the authorized person based on the court or other competent authority’s final decision. 

For more information and instruction please contact our support team at [email protected] and they will be happy to assist you. 

SERVICE FEES AND EXCHANGE RATES 

We operate on the basis of fees exclusively and we do not issue any invoices similar to the banking services system. 

We charge fees when you use our service to buy, sell, exchange, send crypto assets as well as other transactional fees.. Fees are calculated at the time you place your order and may be determined by a combination of factors, like your selected payment method, the order value, market conditions, order type, and/or your transaction history.

Fees are displayed in the transaction preview screen before you submit your transaction and may differ for similar transactions. By completing an order, you are agreeing to pay the applicable fees for that transaction. For more information on the fees please visit the Fees and Limits section on our Website. 

We may change the fee models at any given time, but you will always receive valid information on the fee minimum at the time when placing an order and before your confirmation of the order. 

We may also start charging fees on free services such as crypto custody or introduce new fees for new products. We will release an announcement or put up a notice on a respective page before any such changes or modifications are made effective. 

We may charge an administration fee upon returning funds to your bank account in specific circumstances, including but not limited to: refund claims, rejected transactions due to suspicious account activity, or established correlation between fraud and your account. Processing each refund and/or chargeback incurs certain expenses for us, so we reserve the right to charge administrative fees to cover such expenses.

EXCHANGE RATES 

Each purchase or sale of crypto assets is also subject to the exchange rate for the given transaction. The exchange rate means the price of a crypto asset in fiat currency (crypto-to-fiat transactions) and the price of a crypto asset to another crypto asset (crypto-to-crypto transactions) as stated in the interface when placing the order. The exchange rate is stated either as a “Buy Price” or as a “Sell Price”, which is the price at which you may buy or sell crypto assets, respectively. 

You explicitly acknowledge that the buy price exchange rate may differ from the sell price exchange rate at any given time and that we might add a margin or “spread” to the quoted exchange rate. You agree to accept the exchange rate (including added margin or “spread”) when you authorise the transaction. Fees for Services are not included in the exchange rate and are charged separately. 

We do not guarantee the availability of any exchange rate nor do we guarantee that you will be able to buy or sell your crypto asset on the market at any particular price or time. 

You hereby explicitly agree that we have the right to deduct the fees directly from your Account. Fees will be deducted at the time of the completion of each transaction.

RISKS 

Not all crypto-assets and crypto-asset services are equal nor are they regulated in the same way (if at all). While a new regulation known as MiCA (the Markets in Crypto-Assets Regulation) is now in place in the EU and regulates activities involving certain crypto-assets, most crypto-assets typically remain volatile and highly risky. As such, they may not be suitable for all consumers as a form of investment, payment or exchange. Depending on the type of crypto-asset and the provider you might face higher risks and may have only limited or no consumer protection rights (e.g. access to comprehensive information, transparent complaints-handling procedures.). This is especially the case if you use or invest in crypto-assets/cryptoasset services offered by firms established outside the EU, and by providers not regulated under MiCA. Make sure you are sufficiently knowledgeable about the crypto market and crypto assets, and that you can make informed decisions. You should carefully read this risk section, including Risks Disclosure and Warning on Crypto assets available at https://kriptomat.io/risks-of-trading-virtual-assets/. Be very cautious and keep in mind that we hold no responsibility for any loss related to the loss of value of crypto assets regardless of the reason. At all times mind your financial condition.

Risks Related to Crypto Assets:

• High Risk of Loss
  Crypto-assets are highly volatile and speculative. Their value may change rapidly and you may lose the entire amount invested. You should never invest money you cannot afford to lose. What this means for you: Only invest what you can afford to lose completely. The crypto market can be extremely unpredictable, and there are no guarantees of returns.
• No Guarantees or Protection Schemes
  Crypto-assets are not legal tender and are not backed by any government or central bank. They are not covered by deposit guarantee schemes (such as the EU Deposit Guarantee Scheme) or investor compensation schemes.
• Technology and Operational Risks
  Transactions in crypto-assets are irreversible. Cyber-attacks, hacking, blockchain forks, protocol failures, and technical disruptions may result in the permanent loss of your assets. Kriptomat is not liable for losses from such risks, except where required by law.
• Regulatory and Legal Risks
  The regulatory framework for crypto-assets is evolving. Future changes in laws or supervisory practices may affect your ability to use our services or the value of your crypto-assets.
• Fraud and Scam Risks
  Crypto-assets are targeted by fraudsters. You are responsible for safeguarding your account credentials and ensuring that you transact only through Kriptomat’s official website and mobile application. Kriptomat will never ask for your password or remote access to your device. For more information please visit our Fraud Prevention Awareness Note.
• Suitability
  Crypto-asset services may not be suitable for all investors. You should understand how crypto-assets work and carefully assess your financial situation and risk tolerance. If in doubt, seek independent financial advice.

Risks Related to Fraud and Scams 

Crypto assets are very popular among fraudsters and there are many methods that fraudsters use to prey on their victims. At Kriptomat, your safety is paramount to us. Fraud prevention is managed by a special fraud prevention task force managing the internal Fraud Management Program. Within the program, we carefully monitor and explore cases of fraud, and evaluate the effectiveness of our preventive measures, which we improve and upgrade based on regular assessments. For more information please visit https://kriptomat.io/fraud-prevention/. You must understand that without your cooperation, i.e. prudently following our instructions and safety protocols, the effectiveness of all our measures will be significantly reduced. We shall in no case bear any responsibility for your actions or omission, and we disclaim any liability for damages.

TRADEMARKS, COPYRIGHTS, AND OTHER INTELLECTUAL PROPERTY RIGHTS 

You can use our Services for your own needs, but we do not allow any exploitation beyond your personal use in accordance with the purpose of our Services.

Unless otherwise indicated by us, all copyright and other intellectual property rights in all content and other materials contained on the Website or in connection with the Services, including Kriptomat logotype, images, icons, texts, graphics, and all designs, slogans, products, or service names, databases, information, data software, corporate identity, sound, video, and other files (collectively: “Materials”) are the intellectual property of Kriptomat or our licensor or suppliers/partners and are protected by applicable copyright, trademark, and other applicable laws. You may view, print, or download a copy of Materials solely for your personal, informational, and non-commercial use, subject to the copyright and other proprietary notices. You may not copy, reproduce, republish, modify, imitate, collect, distribute, transmit, scrap, distribute, or use our Materials without our prior explicit written permission. 

Kriptomat grants you a limited, nonexclusive, non-sublicensable, and non-transferable licence, subject to these Terms, to access and use the Materials, solely for approved purposes as permitted by Kriptomat. All rights not expressly granted in these Terms are reserved solely for the benefit of Kriptomat. The licence granted under this Section shall automatically terminate or suspend upon the termination of your access to the Services.

Infringement of our intellectual property rights will result in legal action to the fullest extent permissible by law. Unauthorised use, reproduction, modification, or distribution of our Materials not explicitly permitted in these Terms is strictly prohibited and may lead to civil and criminal penalties. We vigilantly protect our intellectual property rights and will actively pursue legal remedies to address violations, including seeking damages, injunctive relief, and recovery of legal fees and costs incurred in enforcing our rights.

APPROPRIATE USE OF OUR SERVICES

You are fully responsible for any materials and information you provide to us in the scope of using our Services. 

You acknowledge and confirm that you will comply with all applicable laws and regulations and not use our Services for any purpose that is illegal, unlawful, unethical or inconsistent, and/or contrary to these Terms and the purpose for which the Services were created.

Kriptomat reserves the right to investigate all violations of these Terms, threats, and unauthorised use of the Services and will act accordingly and in a manner that is considered appropriate, including, among other things, reporting on the suspicion of illegal activities to the competent law enforcement authorities, the regulator or other authorised third parties. If necessary and bound by the law, we will disclose all the relevant information to the above-stated authorities, including personal names, emails, IP addresses, etc. You also acknowledge that you will not perform any activities that would, at our discretion, constitute or represent a disproportionate and excessive burden on our Services and infrastructure.

PROHIBITED USES

When using Kriptomat’s Services, you agree that you will not, directly or indirectly:

• Illegal Activities
  • Use the Services for money laundering, terrorist financing, fraud, or any other unlawful purpose.
  • Use the Services in violation of international sanctions, embargoes, or restrictions imposed by the European Union, United Nations, U.S. Office of Foreign Assets Control (OFAC), Estonian Financial Intelligence Unit (FIU), or other competent authorities.
• Market Abuse
  • Engage in market manipulation, including but not limited to pump-and-dump schemes, wash trading, spoofing, layering, or other abusive trading practices.
  • Spread false or misleading information in connection with crypto-assets traded on Kriptomat.
• Misuse of Services
  • Circumvent, attempt to circumvent, or assist others in circumventing Kriptomat’s security measures.
  • Use bots, automated scripts, or other technological tools to disrupt or overload the Services.
  • Open or operate accounts on behalf of third parties without disclosure and Kriptomat’s prior consent.
• Unlawful Asset Transfers
  • Send or receive crypto-assets to/from wallets associated with darknet markets, mixers/tumblers, or otherwise flagged high-risk services.
  • Deposit or withdraw funds on behalf of third parties, except in cases of verified joint accounts.
• Other Prohibited Behaviour
  • Impersonate another person or misrepresent your identity.
    Engage in abusive, offensive, or violent communication with Kriptomat staff.
  • Use the Services in a manner inconsistent with these Terms of Service, good market practice, or applicable law.
    

Kriptomat reserves the right to suspend or terminate your Account, freeze assets, and report suspicious activity to competent authorities if you are found to be, or reasonably suspected of being, in breach of these prohibitions.

ANTI-MONEY LAUNDERING REGULATORY REQUIREMENTS 

We may be asking several questions regarding your transactions and your identity. We nurture a culture of compliance and do our best to provide a reliable and regulatory-compliant environment, and to achieve this goal we need your participation and tolerance. Even though no one likes to receive questions about their personal financial matters, the benefit is that you can be sure we follow regulations and that we care about the safety of the assets and the safety of the financial market in general.

We are a licenced crypto asset service provider subjected to strict Estonian AML rules and supervised by a competent financial authority. In all markets where we hold registration, we are also subjected to local AML regulations and supervised by local financial authorities. 

For security measures, we will not disclose any information regarding our internal AML and fraud prevention measures, but we are informing you that we are monitoring your Account activities as part of our regulatory monitoring obligation and that we have a regulatory reporting obligation to report all suspicious activity to competent financial authorities.

In the course of our cooperation, we will be asking you about your identity, transaction background, cooperating with third parties, ownership of the wallets and source of your money or crypto funds, the purpose of your cooperation with us, and some other information. 

You should always provide us with factual, comprehensive, and accurate information. You should respect and follow these Terms as well as our other rules, instructions, and guidelines at all times when using our Services. You are obliged to act truly and transparently when completing the KYC procedure. 

You shall not, by any means, use Kriptomat to endanger national security or the security of people.

More information about our Know-Your-client and Know-Your-Business processes is available on the following link : https://help.kriptomat.io/en/articles/1985939-what-is-kyc-and-why-do-i-need-to-complete-it.

ONGOING MONITORING 

During our cooperation, we will be monitoring your account activities subject to anti-money laundering, terrorist financing, account security and fraud prevention.  

In certain cases, to ensure your safety, we may apply additional checks to eliminate the doubt of the possible account takeover or influence of third parties to open an account with us, or on your transactions, including their purpose. Among other things, we will specifically investigate cooperation with financial advisors/brokers. One of the measures is the ID confirmation photo (or IDCP) requirement requesting you provide an ID selfie photo with a hand-written statement that your cooperation with us is based on your initiative, that you are fully aware of the transaction consequences,  and that you are not under the influence of any third party. We may also require additional information regarding the destination wallet. Please make sure that you provide us with accurate information and that you do not withhold any information on the purpose of the withdrawal and any links with third parties. 

We know our questions and requirements may not be perceived as a pleasant user experience, but we ask for your understanding and trust in our experience as we only want to make sure that you are safe and that our platform is not misused. If you do not cooperate, our security protocols are heavily impaired, so we ask you to cooperate and participate in building a safe and reliable place for building your crypto portfolio.

DISCLOSURES TO THE AUTHORITIES 

We may share or disclose your Personal Information with law enforcement, data protection authorities, government officials, authorized financial institutions, and other authorities when it is:

• required by law;
• compelled by court order, or other legal procedure;
• reasonably believed by Kriptomat that disclosure is necessary to prevent physical harm or financial loss;
• necessary to report suspected illegal activity and disclosure is justified respectively; or
• necessary to investigate violations of our Terms of Service or Privacy Policy.

We will disclose all the relevant information to the above-stated authorities, including information obtained during the verification process, IP address, transaction history, etc. Any circumstances identified among your transactions that are unusual or suspicious or some characteristics point to fraud relation, dark web relation, money laundering, terrorist financing, or any other illicit activity, we will inform you about and disclose such information to the relevant authorities.   

For more information, please contact us at: [email protected].

SERVICE LEVEL GUARANTEE

We will do our best, but undesired events can happen and you should consider this before entering into a business relationship with us. You may suffer temporary unavailability of Kriptomat services in case of technical maintenance. Such events can be monitored on our status page.

Our Services are provided in accordance with best-effort standards and there is no guarantee that there will be no delays, errors, failures, omissions, or other impairments of the system or the loss of the transmitted data or other information. 

We will do our best to ensure our Services meet your availability expectations, however, we give no guarantee of any kind, either express or implied, that the Services will be available uninterrupted at all times.

While we make every effort to ensure the continuity, speed, and security of the Services, we are unable to completely foresee and hedge every legal, technological, and other possible risks. In accordance with Article 68 of Regulation (EU) 2023/1114 (MiCA), Kriptomat will employ commercially reasonable efforts to ensure the availability, continuity, and security of our Services. While we strive to provide uninterrupted access, you acknowledge that certain events may temporarily affect availability, including but not limited to system maintenance, security enhancements, technical issues, market volatility, or factors outside our reasonable control.

We will take reasonable measures to minimise disruptions and, where possible, provide prior notice of planned outages. In case of unplanned interruptions, we will work diligently to restore Services as quickly as possible.

Despite these efforts, you acknowledge and accept that:

• temporary unavailability or delays may occur;
• certain circumstances, including force majeure, hacker attacks, denial-of-service attacks, third-party service failures, or other events beyond Kriptomat’s reasonable control, may impact the Services.

We have taken all reasonable measures to ensure the accuracy of the information on the Website, however, Kriptomat does not guarantee the accuracy, suitability, reliability, completeness, performance, and/or fitness for the purpose of the content of any Services available through the Website, and will not accept liability for any loss or damage that may arise directly or indirectly from the content or your inability to access our Website, nor shall be responsible for any delay or failure of the transmission or the receipt of any instruction or notifications sent through our platform.

In such cases, Kriptomat will not be liable for losses directly resulting from these events, provided we have applied reasonable care, security measures, and business continuity processes.

YOUR RESPONSIBILITY TO FOLLOW SECURITY MEASURES 

You agree to safeguard the security of your Account and crypto assets within your account. We hold no responsibility for your actions and omissions that lead to impairment of the security of your Account, including and specifically resulting in losing your assets. We specifically warn you that using remote access tools (such as AnyDesk, TeamViewer) to access your Account is strictly prohibited and there is an extremely high correlation between enabling access to your Account to third parties and fraud. If you need any help with using our app, always ask our support team to assist you!

You as the user are solely responsible for managing and maintaining the security of your login credentials and any other forms of authentication, and you understand and acknowledge that we are not responsible (and you will not hold us responsible) for any unauthorized access to and or use of your login credentials and/or Account (“Unauthorized Access”). We reserve the right to suspend, freeze, or restrict access to your account and/or Services, including freezing part or all of your assets, where: (i) required by law, regulation or government request, (ii) we reasonably suspect fraud, money laundering, market manipulation or other violations of applicable laws, (iii) your account shows unusual or high-risk activity patterns, (iv) we need to comply with our Risk Management Policy or regulatory obligations, or (v) technical or security risks require such action. Any such restrictions will be proportionate to the identified risks. Kriptomat shall “unfreeze” the frozen account when the conditions to do so are met and there is no risk of any kind for us and you.

We reserve the right to determine whether to unfreeze partially or wholly when we receive your request to unfreeze. You hereby acknowledge the request to unfreeze the account may not be accepted, and before unfreezing the account, you shall cooperate with us on identity verification or other relevant requirements, in particular establishment of third-party involvement in s and provide, including but not limited to, identity information, identity card, passport, other valid identity documents and other documents or information required by us.

LIABILITY, EXCLUSION OF ANY WARRANTIES AND GUARANTEES 

Our liability is limited to the maximum extent possible following the law. In particular, you are fully responsible for all actions or omissions on your side. Further, we are not responsible for any loss commencing from hacking, cyber attack, exploited system vulnerability, theft of crypto assets, or any other attack resulting in the loss, unavailability, or destruction of your crypto assets (altogether “cyber attacks”) or delisting of a crypto asset. We also cannot be held responsible for any damage or loss for reasons on the side of third parties. We select our third-party service providers carefully and responsibly, but in case the risk materializes, you must understand we do not hold any responsibility for damage resulting from third-party providers. Please make sure you read Risk of Trading Crypto Assets carefully!

You shall bear any and all loss resulting in your own fault or error, including but not limited to unprompted operation or transaction, untimely trading operations, leakage of passwords, cracked passwords or private keys (if any), and/or the invasion of your computer by a third person.

In the event of a potential loophole in the trading rules or system based on which you are unjustly enriched, we will contact you to recover the gains. You must effectively cooperate, otherwise, we will take actions, including, but not limited to, restrictions on Account transactions, freezing account funds, legal enforcement, and other recourse measures. We reserve the right for the amount of unjustified enrichment to be deducted from your Account balance if available. In the event you will not cooperate, we may also charge you with administrative recovery fees. 

We are not liable for any direct, indirect, punitive, incidental, consequential, or other damages or loss of data, profits, goodwill or reputation, personal injury, or any other damage resulting from (i) your access and use of our Services, (ii) your inability to use the Services (iii) any information or content contained on our Website, (iv) your information or material provided to us. The exclusion of liability applies regardless of whether the damage was caused by a breach of contract, liability for damages, negligence, and strict liability or otherwise. 

Unless expressly provided in these Terms, we do not make any representations and exclude any warranties, expressed or implied, to the fullest extent possible under the applicable law regarding the relevance, reliability, availability, timeliness, and accuracy of the Services and Website information, the content of the Website and links to third party websites on our Website. Our Services, Website, information, and content on it, are provided without any warranty of any kind. 

The information we provide on the Website may be inaccurate or have typographical errors and we shall not be liable for such errors.

Our liability is limited to the maximum extent permitted by law. In particular, we are not liable for any loss or damage resulting from cyber attacks, third-party failures, or your own acts or omissions, as described above.  

To the extent permitted by law, we exclude liability for indirect, consequential, punitive, incidental, or special damages, including loss of profit, goodwill, or data. Nothing in these Terms shall limit or exclude our liability in cases of deliberate fraud, gross negligence, death or personal injury, or where such limitation is otherwise prohibited by applicable law.

FORKS AND AIRDROPS

In case of a fork, deposits and withdrawals may be halted, and may remain unavailable until further notice. We will notify you via the notification system and/or emails before halting the transactions. You will be notified by email when the deposits and withdrawals of the crypto assets are again available. 

What this means for you: A fork is a technical change in how a cryptocurrency works. When this happens, we may need to temporarily stop deposits and withdrawals to ensure your assets remain safe. We will always try to inform you before this happens and let you know when services resume.

We cannot guarantee the functionality, security, or availability of updates, upgrades, or modifications to underlying blockchain protocols, as these are outside our control. In accordance with MiCA Article 68, we specifically disclose that: (i) we cannot control or influence blockchain protocols, (ii) technical changes to protocols may affect your crypto assets’ value or functionality, and (iii) we are not responsible for losses resulting from protocol changes outside our control, provided we have exercised reasonable care in managing associated risks. By accepting these Terms you acknowledge the risk associated with forks, that is changes in operating rules. Further, you also acknowledge the risk of airdrops. Both forks and airdrops may affect the value and other characteristics of the crypto asset. 

In accordance with best-effort standards, we will notify you about the upcoming forks and/or airdrops and their impact on our Services, and how we will manage them within our system. You must understand that we might have a different approach from other service providers. 

Upon the occurrence of the fork or airdrop, please make sure you carefully follow our notifications and understand the implications they might have on your crypto portfolio. We will not be responsible for any loss you may suffer from such events, and in particular, we do not guarantee we will support the fork or airdrop.

COMPLAINT RESOLUTION 

We understand you may be dissatisfied with our services. Kriptomat maintains a standardised complaints procedure in line with the EU Markets in Crypto-Assets Regulation (MiCA). You can find more information on the dedicated complaints pahe HERE 

Clients may submit complaints in writing through the following channels:

• Complaints web form  – https://kriptomat.io/submit-a-complaint/form/ 
• E-Mail: You can download and fill in the formal form of complaint, and send it to our email: [email protected] 
• Post: You can download and fill in the formal form of complaint, print it out, sign it, and send it by post to our registered address: FintechX OÜ, Osmussaare 8, 13811 Tallinn, Estonia.
• For fraud-related issues: [email protected]  or https://kriptomat.io/fraud-report 
• You will receive a confirmation of receipt of your complaint within 10 business days.
• Kriptomat will provide you with a final response within 15 calendar days of receiving your complaint.
• In exceptional cases where a full response cannot be provided within 15 calendar days, we will send you a holding reply stating the reasons for the delay and indicating the date by which you can expect a final response, which will be no later than 30 business days from the date of receipt.

Complaints are processed free of charge.

We may contact you for additional information and supporting documentation to resolve your complaint. Your cooperation is essential to ensure timely resolution.

Alternative Dispute Resolution (ADR)
If you are not satisfied with our response, you may refer your complaint to an independent alternative dispute resolution (ADR) body in Estonia or in your country of residence within the European Union. Information about relevant ADR entities is available at:  https://ec.europa.eu/consumers/odr. These dispute resolution options are available at no additional cost to you and do not affect your right to initiate legal proceedings.

CLIENT COMMUNICATION AND SUPPORT

Kriptomat places strong emphasis on clear, timely, and secure communication with its clients in relation to all account services. Clients can contact Kriptomat through multiple support channels, including:

• in-app support chat 
• a dedicated support email [email protected]
• Complaint web form: https://kriptomat.io/submit-a-complaint/form/ 
• Fraud notification form: https://kriptomat.io/fraud-report/ 
• Physical document submission: FintechX OÜ, Osmussaare 8, 13811 Tallinn, Estonia

Kriptomat does not:

• offer phone support,
• use remote desktop to assist users,
• offer physical face to face support,
• offer support on social media channels (facebook, X, etc),
• offer support via instant messaging apps (telegram, whatsapp, etc)
• Offer investment advice.

This way Kriptomat is ensuring assistance is secure and readily available when needed. All communication channels are operated through secure systems designed to protect client information.

Clients are provided with regular and transparent information regarding their account and asset holdings, including transaction confirmations, status updates, and relevant changes to services or regulatory requirements that may affect their assets. 

In addition to routine communications, Kriptomat’s customer support team is available to assist with account-related questions, transactions, custody matters, and transfer inquiries, ensuring clients receive appropriate support throughout their use of the platform.

TAX OBLIGATIONS

You are solely responsible for determining any tax obligations that may arise from using our Services and investing in crypto assets. We do not bear any responsibility for the identification, calculation, reporting, or payment of taxes on your behalf.

Given the complexity and evolving nature of tax regulations pertaining to crypto assets, we strongly recommend that you consult with a qualified tax professional. A tax advisor can provide tailored advice and guidance based on your individual circumstances, ensuring compliance with the applicable tax laws in your jurisdiction. This consultation is particularly important as tax laws vary significantly across different countries and are subject to change.

Remember, failing to accurately report cryptocurrency transactions can result in significant legal and financial penalties. It is therefore imperative to understand and adhere to your tax obligations.

INDEMNITY 

To the full extent permitted by applicable law, you hereby agree to indemnify our partners against direct damages and reasonable costs arising from: (i) your breach of these Terms, (ii) illegal use of the Services, or (iii) infringement of third-party rights. This indemnification obligation shall be limited to damages that are foreseeable and directly caused by your actions.

JURISDICTION AND APPLICABLE LAW 

These terms and conditions shall be subject to the jurisdiction and interpretation of the law of the Republic of Estonia.  In case of a dispute, parties shall solve disputes in an extrajudicial way – users of the Services agree to a mediation procedure according to the Estonian law, before taking the case before the court. Should the dispute not be settled in the mediation procedure, then the Harju County court shall have exclusive jurisdiction to solve it. This shall not, however, limit the rights of consumers to file complaints or seek assistance with consumer protection authorities or other competent bodies in their country of residence, in accordance with applicable EU consumer protection law.

CONFLICTS OF INTEREST

Kriptomat is committed to conducting its business in a fair and transparent manner and to acting in the best interests of its clients. In accordance with the requirements of the EU Markets in Crypto-Assets Regulation (MiCA) and applicable Estonian law, we maintain and implement a Conflicts of Interest Policy designed to identify, prevent, manage, and disclose situations where the interests of Kriptomat, its employees, or its partners may conflict with those of our clients.

We take appropriate organisational and administrative measures to prevent such conflicts from adversely affecting our clients. These measures include, among others:

• separating activities that may create conflicts of interest;
• restricting personal trading by employees in certain circumstances;
• ensuring fair execution of client orders and equal treatment of clients;
• disclosing any fees, commissions, or benefits received from third parties.

If, despite these measures, a conflict of interest cannot be effectively avoided, Kriptomat will disclose the nature of the conflict to the client in a clear and timely manner before providing the relevant service.

You may review our full Conflicts of Interest Policy at the following link: https://kriptomat.io/prevention-and-management-of-conflicts-of-interest-policy

MISCELLANEOUS 

These Terms, along with the Privacy Policy, Cookie Policy, and other related documents, govern the legal relationship between you and us regarding the use of our Services.

If either party does not exercise a right under these Terms, it does not waive that right or any other rights.

We are not liable for failure to fulfil our obligations under these Terms or any damages related to our Services if the failure or damage is due to reasons beyond our reasonable control, including force majeure, hacker attacks, or mechanical, electrical, or communication issues.

If any provision of these Terms is unenforceable or invalid, it will be limited or eliminated to the minimum extent necessary for the Terms to remain in force.

We may transfer or assign our rights and obligations under these Terms to a third party without your consent, provided such transfer does not diminish your rights under these Terms or applicable law. You will be informed of any transfer via email or other communication channels. You may not assign your rights under these Terms to anyone else.

We reserve the right to modify, suspend, or discontinue any part of our Services at any time, with or without notice. This may include adding or removing features, functionalities, or content. We will not be liable to you or any third party for any such changes.

These Terms are effective immediately upon your acceptance during registration and remain in effect until you close your Kriptomat Account and stop using our Services.

ANNEXES

KriptoEarn Staking Services 

Kriptomat Intelligent Portfolios

Last update, 9th of January 2026