Platform Trading Rules

1. INTRODUCTION

These Platform Trading Rules (the “Trading Rules”) set out how Coinmate a.s. (“Coinmate”, the “Company”, “we”, “us” or “our”) operates a trading platform for crypto-assets and processes trading instructions submitted by you (the “client”, “customer”, “you” or “your”) in accordance with Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”).

In the context of the MiCA Regulation, the operation of a crypto-asset trading platform is a regulated service that enables the organized and systematic matching of orders to buy and sell crypto-assets. Through our Platform, we provide a structured and secure market environment where buyers and sellers meet, and where transparent information on price, volume, and other relevant trade data is available. As an operator of a crypto-asset trading platform, we implement effective rules and procedures to ensure market integrity, prevent manipulation, and safeguard the interests of our clients.

These Trading Rules supplement the provisions of the Terms and provide detailed technical information regarding DC trading on our Platform in accordance with the requirements of the MiCA Regulation. By accessing our Platform, you are required to comply with these Trading Rules. The Trading Rules serve to facilitate fair access to the use of our Services.

2. PLATFORM TRADING POLICIES

2.1. EVALUATION OF CRYPTOASSETS

Each DC undergoes an approval process before being listed for trading on the Platform. This includes due diligence focused on the risks of money laundering and terrorist financing, in accordance with EU Directive 2015/849, while complying with all regulatory requirements for the identification and verification of the issuer or project.

Coinmate may refuse to accept certain types of DCs that do not meet the established security and regulatory criteria.

2.2. PARTICIPATION IN TRADING

Coinmate applies objective and non-discriminatory rules for participation in trading on the Platform. Customers must meet reasonable requirements that promote fair and open access to the Platform. These requirements may include identification and verification of the customer’s account prior to trading.

Coinmate establishes firm rules and procedures that support orderly trading and the efficient execution of orders. Coinmate has mechanisms in place to detect market manipulation and abuse, which protect the integrity of the Platform and its users.

2.3. SUSPENSION OF TRADING

In order for a DC to remain available for trading, it must meet minimum liquidity thresholds and certain other requirements. In the event that liquidity or other requirements are not met, Coinmate reserves the right to temporarily suspend or terminate trading in that DC.

Coinmate sets clear conditions under which trading in a specific DC may be suspended, including reasons such as technical issues, disruptions in market conditions, or suspected illegal activities related to that DC.

2.4. SETTLEMENT OF TRANSACTIONS

Coinmate ensures the efficient settlement of transactions for both DCs and FCs. Trade settlement occurs at the moment of entry into Customer accounts, where it is initiated solely within the Company’s internal Position Register (off-chain). No entry is made in the distributed ledger during trade settlement. Internal trade settlement is completed without undue delay after the order is executed, but no later than the end of the business day.

2.5. FEE STRUCTURE

Coinmate maintains a transparent, fair, and non-discriminatory fee structure for Services on the Platform. The fee structure does not encourage trading activities that could disrupt market conditions or promote market manipulation.

2.6. PRICE TRANSPARENCY

Coinmate publishes current buy and sell prices, as well as the volumes and times of transactions executed on the Platform. This data is made available to the public as soon as possible after the transaction is executed.

2.7. RECORD KEEPING

Coinmate retains records of all orders and transactions involving DC for a minimum of five years. These records include all relevant data linking orders to executed transactions. Upon request, Coinmate provides access to these records to the relevant authorities for the purpose of monitoring trading activities on the Platform.

3. TRADING METHODS

3.1. QUICK BUY/SELL

Quick Buy/Sell is the simplest form of trading, allowing for the immediate execution of a trade on the Platform. The trade is based on the current market quote and is executed at a guaranteed price the moment the client confirms the buy or sell. Cryptocurrency markets are volatile, so we temporarily suspend withdrawals and lock in the price for executing the trade. A Quick order carries the risk of settlement at a significantly lower or higher market price.

For less liquid pairs, a warning may appear stating that the price is affected by low liquidity, and the order may be rejected. In extreme cases, order execution may be canceled if the price changes significantly between the time the order is placed and the time it is settled. The client will be notified of this fact and offered a new exchange rate.

3.2. RECURRING BUY

You have the option to set up a standing order with your bank using the bank details we provide when you set up a recurring buy in your user account on the Website, and upon receipt of any FC funds from you via the standing order, we will immediately (within a maximum of 24 hours) purchase the selected DC and credit it to your account held with Coinmate (“Recurring Buy”).

The purchase of DC as part of a Recurring Buy will always be executed by Coinmate in a maximum amount corresponding to the client’s total current available CZK balance in the relevant account, reduced by the fees associated with the purchase, a list of which can be found here. Coinmate will always endeavor to execute a Recurring Buy for the client as quickly as possible after receiving the relevant fiat currency funds, but no later than 24 hours after their receipt, provided the client’s instruction contains all required information. However, Coinmate is not liable for any difference in the value of the relevant DC between the receipt of FC funds and the execution of the trade within the specified period due to the volatility of the cryptocurrency market.

The client may only send funds from a bank account held in the same name as listed on their Coinmate account.

The minimum amount for a Recurring Buy is 50 CZK. The maximum amount for a Recurring Purchase is limited by the current limits for deposits/withdrawals of FC funds in the client’s Coinmate account. Recurring Purchases can only be made in CZK.

If you wish to stop Recurring Purchases, simply cancel the standing order at your bank; if you stop sending additional FC funds to your account for the purpose of making Recurring Purchases, we will not make any Recurring Purchases.

To set up recurring purchases for additional DCs, repeat the above process for each DC separately. Select the desired DC in your Coinmate account and set up a standing order in your online banking in accordance with the instructions provided. The amount and frequency of your Recurring Buy will be affected by how often and in what amounts you send FC from your bank account.

Please note that it is important for the standing order to contain accurate and complete details, which are displayed to the client in their account when creating a new Recurring Buy. Coinmate is not liable for the non-execution of a client’s order if the client fails to provide all required standing order details as specified on the Website when setting up a Recurring Buy or if the order is entered in violation of the Terms for Recurring Buy set forth above.

3.3. ADVANCED TRADING ON THE PLATFORM

Our Platform enables advanced trading based on the interaction of supply and demand (“Advanced Trading Interface”). Prices may vary slightly from other platforms depending on our liquidity and agreements with market makers who help stabilize the exchange rate.

The first asset in a trading pair is the asset you wish to buy or sell. The quoted asset is the second asset in the trading pair, which is used to value the underlying asset. The underlying asset and the quoted asset may be a specific DC or FC. For example, in the BTC-CZK trading pair, BTC is the underlying asset and CZK is the quoted asset.

When a client places an order, that order is subsequently entered into the order book, which contains a list of current orders in the relevant trading pair. An order to buy a specific asset is placed on the buy side of the order book (bid), while an order to sell a specific asset is placed on the sell side of the order book (ask).

3.3.1. Order Types in Advanced Trading

1. Limit

The client sets a maximum price (in the case of a buy) or a minimum price (in the case of a sell) at which they wish to trade the DC. The trade will only be executed if a counter-offer is available on the market at the specified price or at a better (more favorable) price for the client. For this reason, neither the actual execution price nor the execution of the order itself can be guaranteed in advance. The trade may therefore not be settled immediately, or it may not be settled at all.

1. Market

Immediate purchase or sale at the currently available market price. This order is suitable for clients who wish to trade immediately regardless of minor price fluctuations. The client does not specify a price, but only the quantity of DC they wish to trade. A Market order carries the risk of settlement at a significantly lower or higher market price. If there are not enough counter-offers available to execute the trade, we will inform you of this fact.

1. Post Only

An optional feature of the Limit order. This order functions like a Limit order, but with the condition that it will only be filled if a counterparty is available. This order ensures that the trade is executed as a Limit order.

3.3.2 Threshold Values and Protection Against Obviously Erroneous Orders

In accordance with requirements to ensure the proper functioning of the market, Coinmate applies automated checks on submitted orders, which may result in their rejection. The company sets the following:

1. Volume thresholds 

The minimum order size is 50 CZK, and the maximum order size is 30,000,000 CZK. For trading pairs where the base currency is not the CZK, or for orders expressed in units of a cryptoasset, these limits apply as the equivalent value of the cryptoasset calculated based on the current Reference Price at the time the order is placed. Orders exceeding these volume thresholds are automatically rejected by the trading platform.

1. Price Thresholds

The trading platform applies automated price corridors to prevent obviously erroneous orders. In the case of a Market order where the estimated execution price would result in a deviation of more than 10% from the Reference Price, the user is notified of this fact before the order is executed; unless the user explicitly confirms the order, it is automatically canceled (rejected).

The Reference Price means the indicative DC price displayed on the trading platform as the primary reference value, which corresponds to the price of the last successfully settled trade on the given trading pair and falls within the range of the best bid and best ask. The Reference Price does not serve as a binding price for trade execution.

In the event of insufficient market liquidity, trading may be suspended, a price change notification may be issued for the selected pair, or the order may be rejected.

Transactions executed based on Limit, Market, or Post Only orders are processed according to current market conditions, and the user receives a settlement notification with trade details.

A trade order can be canceled until the moment of its partial or full settlement, provided that the conditions of the specific order type allow it (for example, a Quick Buy/Sell cannot be canceled by the customer after the exchange rate has been confirmed).

3.4. AUTOMATIC EXCHANGE SERVICE FROM FC CARD

When using the automatic exchange service from an FC card, FC is automatically exchanged into any DC held in your DC wallet („Automatic Exchange„). You can perform an automatic exchange from FC to DC by providing us with your card details and the amount of FC to be exchanged through us. In such a case, you acknowledge that your bank will be responsible for the FC transfer. Upon confirmation from the Company that the transaction has been authorized, the Company will immediately—no later than 24 hours after authorization—credit the corresponding amount of DC funds to your DC wallet.

All automatic conversions from FC to DC are irreversible and final immediately after you confirm your payment instructions and/or make the payment. Once the instruction is confirmed, you cannot in any way change or cancel your order to complete ongoing or partially executed transactions. You acknowledge that we are not responsible for partially executed transactions or for delays in executing transactions or the inability to execute your transactions due to delays, failures, or interruptions on your part.

If your transaction was not successful or if your payment card does not have sufficient funds, you fully authorize us, at our discretion, either to cancel the Automatic Exchange from FC to DC or to debit your trading account for any amount we deem necessary to complete the Automatic Exchange. Subsequent exchanges or transactions will not be linked to the original credit card transaction.

The client acknowledges that trade confirmation is conditional upon the funds being credited to the Coinmate account. This constitutes a conditional deferral of order execution, whereby the buy order will be executed only after the client’s funds have been credited.

Coinmate reserves the right to cancel the trade if the client’s funds are not credited to the Coinmate account in time to allow for proper settlement of the trade. The client will be informed of the cancellation and may place a new order at the current exchange rate.

4. GENERAL PROVISIONS ON TRADING

We do not guarantee that your orders will be filled, and we may, at our sole discretion, withdraw or cancel an order placed on our market if we deem it non-standard or suspicious for any reason we consider relevant to regulating market transparency and integrity.

If you submit a Limit, Market, or Quick order to execute a trade on our market, we will publish it, and multiple parties may decide to accept the offer at that price. You will not know who these buyers or sellers are. Upon settlement of the trade, you will be able to view a settlement report with details on how your trade was settled.

If you do not have sufficient funds in your account to settle the trade and pay fees, you cannot place an order on the Platform.

After submitting an order and settling the trade via the Platform, it can be canceled until it is executed (in the case of a Quick order, cancellation is not possible by the client after they confirm the offered exchange rate on the Platform, as this moment is considered the execution of the order according to the previous sentence). If part of the order has been filled and the trade has been partially settled, only the unfilled portion of the order and trade may be canceled.