Transfer Rules

1. INTRODUCTION

These rules for the transfer of client cryptoassets (“Transfer Rules”) set forth how Coinmate a.s. (hereinafter “we,” “us,” “our,” „Coinmate„) handles a transfer order for a client’s cryptoassets (hereinafter „your,“ „you„, “client”, “customer”) in accordance with the Markets in Crypto-Assets Regulation (EU) 2023/1114, Article 82 (hereinafter „MiCA„).

These Transfer Rules supplement the provisions of Article 8 of the Terms and provide detailed technical information on DC transfers in accordance with the requirements of the MiCA Regulation. By using the Transfer Service, you agree to these Transfer Rules.

1.1. DESCRIPTION OF TRANSFER SERVICES

Coinmate provides Transfer Services via supported distributed ledger technologies („DLT„) and between Coinmate accounts. These services include:

Blockchain Transfer:

Sending DC from Coinmate wallets to external wallets („Withdrawals„)
Receiving DC from external wallets to Coinmate wallets („Deposits„)

1.2. TECHNICAL STRUCTURE OF WALLETS

To manage client funds, Coinmate uses a wallet system based on the following principles:

a) Deposit addresses:

Each user and each sub-account has a dedicated Deposit address for each supported DC;
These addresses are used to identify to whom the Deposited funds should be credited;
For Bitcoin, we use our own wallet, from which we assign a unique Deposit address to each user;

b) Omnibus wallets:

Upon receipt, most cryptocurrencies (except Bitcoin) are immediately forwarded to a shared omnibus wallet
Withdrawals are sent from the omnibus wallet
With Bitcoin, funds are not immediately transferred to an omnibus wallet; withdrawal transactions are constructed from available inputs

c) Blockchain records:

All DC transfers, including transfers between Coinmate clients, are recorded on the relevant blockchain
This approach ensures maximum transparency and auditability of all transactions
Every change in DC ownership is therefore transparently recorded in the distributed ledger

2. REQUIRED INFORMATION FOR TRANSFERS

When submitting a cryptoasset Withdrawal order, the customer must provide the following information:

About the sender: first and last name (or name), the sender’s cryptoasset address, registered office/residence address including country (or date and place of birth, or customer account number, or national identification number), or LEI or equivalent, if applicable.
About the recipient: first and last name (or name), address of the recipient’s crypto assets.
Amount and type of crypto-assets.

This information is transmitted securely to the recipient’s provider prior to or concurrently with the transfer, no later than before the order is submitted to the blockchain.

3. TECHNICAL INFORMATION

3.1. WITHDRAWAL PROCESS ON THE BLOCKCHAIN

You may make Withdrawals from your account at any time, unless we inform you otherwise prior to the conclusion of a partial trade regarding the specific DC being purchased. In particular, for less liquid currency pairs, you may be informed of a temporary restriction on Withdrawals of the DC you are purchasing. However, such a temporary restriction on DC Withdrawals does not in any way affect the client’s ability to trade with the given DC.

You can select a DC as follows:

Log in to your Platform
Select the desired cryptocurrency on the cryptocurrency tab and click „Withdraw„
Enter the required information as specified in Section 2 of this document
Enter the amount to be sent
Confirm the accuracy of the information provided and agree to the fees

Once a Withdrawal request is submitted, it is considered final and cannot be canceled.

Coinmate supports Withdrawals only for selected DCs, and the availability of Withdrawals may change over time. Some DCs may be available for Withdrawal during a certain period, while later they may be temporarily or permanently restricted, and vice versa. You will be informed about supported DCs via our Platform.

3.2 RESTRICTIONS ON TRANSFERS OF CERTAIN DCs

Coinmate may temporarily or permanently restrict the Deposit or Withdrawal of certain DCs; it will do so primarily (but not exclusively) for technical or regulatory reasons, and you will always be notified of this fact as soon as possible. For regulatory reasons, Coinmate does not allow transfers of the USDC (USD Coin) stablecoin from a client’s wallet held with Coinmate to third parties. The Company also does not allow transfers of USDC from third parties to a client’s wallet held with Coinmate.

Coinmate restricts automatic Deposits and Withdrawals for cryptoassets in the Exchange Service (clearly marked in the Platform interface as cryptoassets with restricted transfers or manual Withdrawal). For these cryptoassets, a specific manual Withdrawal procedure applies upon the client’s request, as described in Section 4.1 of the Custody Rules. The list of these cryptoassets is subject to change depending on the current technical support provided by the Company and its partners.

3.3 GROUNDS FOR REJECTING TRANSFER INSTRUCTIONS

Coinmate may reject DC Deposit instructions in the following cases:

The Deposited DC is not supported by Coinmate
The DC is sent via an unsupported blockchain network
The Deposit is sent to an invalid or inactive address
The Deposit fails internal security checks
The Deposit fails on the blockchain network
Coinmate has not received the required information in accordance with EU Regulation 2023/1113 (Travel Rule)

Coinmate may reject DC Withdrawal requests in the following cases:

The recipient’s wallet address is invalid, inactive, or incompatible with the selected blockchain network
The Withdrawal exceeds Coinmate’s risk tolerance
The Withdrawal is below the minimum Withdrawal amount for the given DC
The Withdrawal exceeds the maximum recommended Withdrawal amount
Insufficient information has been provided
We have reasonable suspicion of illegal activity

Coinmate reserves the right to suspend a Withdrawal if insufficient information is provided or if we have reasonable suspicion of illegal activity. If a transaction is rejected, you will be notified.

Coinmate does not allow clients to make Withdrawals exceeding 1,000 EUR to a non-hosted wallet that is not owned by the client requesting the crypto asset Withdrawal.

In the cases mentioned above, particularly if the Client sends a cryptocurrency that Coinmate does not support or uses an unsupported blockchain network, Coinmate may, without the Client having any legal claim to such performance, offer assistance in attempting to recover these funds (hereinafter “Crypto Recovery”).

To initiate this process, the client is required to contact Customer Support and provide all necessary information, including the address for the return of funds, which must be on a blockchain supported by us. The Crypto Recovery service is subject to an administrative fee in accordance with the current price list, available here. Coinmate reserves the right to deduct this fee from the amount being returned. Coinmate is not liable for the failure of the Crypto Recovery process due to technical or other reasons beyond its control, nor for any loss of value of the funds during this process.

3.4 CREDITING TIME AND TRANSACTION COMPLETION

Withdrawal instructions are processed as follows:

Coinmate receives the instruction immediately after the user submits it
Coinmate performs internal checks before sending the transaction to the relevant blockchain
In some cases, Coinmate may batch Withdrawal requests into a single transaction to improve efficiency
The transfer is executed no later than 3 hours from the time the transfer instruction is received, with the exception of cryptoassets in Exchange Service, where the deadlines and manual process specified in Section 4.1 of the Custody Rules apply. This timeframe includes all internal checks and batching (which may cause a delay of up to 20 minutes before submission to the blockchain) as well as waiting for the required number of confirmations on the DLT network.

Deposit instructions are processed as follows:

The user receives a unique Deposit address for each supported DC
After sending funds to this address, Coinmate identifies the transaction as belonging to the given client
For all DCs (except Bitcoin), the funds are then transferred to an omnibus wallet
Coinmate performs internal checks before processing the Deposit to the user’s account

The execution of a Deposit or Withdrawal instruction may be delayed due to suspected fraudulent activity or a temporary technical outage of Deposit and Withdrawal services.

Transfers between Coinmate accounts are also executed via blockchain transactions. This means that even when transferring cryptocurrencies between two Coinmate clients, an entry is made on the blockchain, ensuring maximum transparency and full compliance with regulatory requirements. These transactions are subject to the same conditions as standard blockchain transactions, including the confirmation times of the relevant blockchain, and may involve associated fees.

Before confirming a transfer, the customer is notified via the Platform when the transfer of crypto assets will become irreversible. At the same time, the customer is shown an overview of all fees associated with the transfer.

3.5 SUPPORTED DLT TECHNOLOGIES

The supported blockchain networks for each DC are displayed when initiating a Withdrawal or Deposit for that DC. Available networks appear in the dropdown menu above the Withdrawal Address field.

The client is responsible for verifying the compatibility of the transfer request with the listed networks. Coinmate is not liable for losses caused by selecting the wrong blockchain network.

3.6 TRANSFER PROCESSING TIME

Transfers are usually completed within a few minutes, depending on:

Confirmation times on the relevant DC’s blockchain
Coinmate’s internal compliance checks
The type of DC being transferred and its specific characteristics

This applies to all types of transfers—external Withdrawals, Deposits, and transfers between Coinmate clients—as all these operations are executed via blockchain entries.

Delays may occur due to:

Network congestion
Additional verification requirements
Technical issues related to the blockchain
The need to batch transactions to optimize fees

3.7 BLOCKCHAIN CONFIRMATION REQUIREMENTS

Confirmation thresholds vary by blockchain network and specific DC. These are always displayed to the user before the transfer is executed.

3.8 FEES, COSTS, AND DEDUCTIONS

Fees may be charged in connection with the use of DC transfer services. You will be required to pay all fees incurred by us in connection with the DC transfer. You can find the current fee schedule for DC transfers here. Since blockchain fees change over time, you will always be informed of the total fee after entering the target Withdrawal amount, before you submit the Withdrawal request.

3.9 INFORMATION ABOUT TRANSACTIONS ON THE BLOCKCHAIN

You can check the status of your Withdrawal via the link to the relevant block explorer listed in the transaction details. This link provides real-time updates after the transaction is sent to the blockchain.

3.10 COMMUNICATION WITH COINMATE

Communication regarding DC transfers may take place: (i) Through the form available on the Company’s website under the Contact section: https://coinmate.io/cs/support (ii) Via the form in the Support Interface available under the Customer Support button (https://coinmate.io/cs/customer-support) (iii) By letter to the Company’s registered office at: Pernerova 697/35, Karlín, 186 00 Prague 8, clearly marked “Complaint”

3.10 DETECTION OF FRAUDULENT TRANSACTIONS

Coinmate will immediately notify clients of any suspected or actual fraudulent activity or security threats via a notification through the Support Interface and/or email. Upon detecting suspicious activity, Coinmate will suspend the transaction and request additional information.

Users shall report suspicious activity to Coinmate via the Support Interface.

4. UNAUTHORIZED AND INCORRECTLY EXECUTED TRANSFERS

4.1 REPORTING

The customer is required to report an unauthorized or incorrectly executed transfer without undue delay via the Support Interface, providing the transfer identification, a description of the problem, and any available supporting documentation.

4.2 INVESTIGATION AND PROCEDURAL TIMELINES

Coinmate will immediately initiate an investigation and confirm receipt of the report within 24 hours. The results of the investigation will be communicated to the customer within 10 business days. The investigation includes verifying the transfer authorization, reviewing the transaction in the systems, and determining the current status of the transfer (unprocessed, processed, being confirmed on the blockchain, completed).

4.3 REMEDIAL SCENARIOS

Based on the results of the investigation, Coinmate will proceed as follows:

Unprocessed transfer: Coinmate will immediately stop and cancel the transfer; the crypto assets remain in the customer’s account.
Processed but unconfirmed transfer: Coinmate will attempt to stop the transfer using technical means; if this fails, the procedure described in the following point will be followed.
Confirmed transfer: Coinmate will contact the recipient’s provider (if identifiable) to request cooperation in returning the funds. If a return is not technically possible, Coinmate will assess the claim for compensation based on the results of the investigation.

Coinmate is liable if an unauthorized or incorrectly executed transfer occurred as a result of a breach of Coinmate’s obligations. Coinmate bears no liability if an unauthorized or incorrectly executed transfer occurred as a result of a breach of these Terms (including annexes) by the customer, or due to the customer’s negligence (for example, but not limited to, in the case of a phishing attack, vishing attack, etc.).

For incorrectly executed transfers on the part of Coinmate, liability shall be determined in accordance with applicable laws. Liability limits are capped at the value of the transferred DC.

4.4 COMMUNICATION

Coinmate will keep the customer informed of the status of the investigation, the reasons for the rejection, return, or suspension of the transfer, and any applicable fees via the Support Interface.