Definitions

Bitcoin Store Wallet (Account) – a service within the Platform that enables the purchase, sale, exchange, and storage of crypto-assets, the deposit and withdrawal of EUR, and real-time monitoring of the Client's investment portfolio.

Client – a natural or legal person who uses the Company's Services.

Crypto-asset – a digital representation of value or rights that may be traded digitally, transferred, and used for payment or investment purposes.

Segregated account – a dedicated account or wallet used exclusively for the storage of client assets, held separately from the Company's own funds.

Third-party custodian – a regulated service provider used by the Company for the technical safekeeping of a portion of client crypto-assets.

1. Introduction

This summary of the Crypto-Asset Custody Policy (hereinafter: the Policy) describes how Digital Assets d.o.o. (hereinafter: the Company) safeguards and manages client crypto-assets. The Policy has been prepared in accordance with the requirements of Regulation (EU) 2023/1114 (MiCA) and is available to clients in electronic form.

The Company is an authorised crypto-asset service provider under the supervision of HANFA (the Croatian Financial Services Supervisory Agency).

2. Core Obligations of the Company

The Company undertakes to ensure the following:

• client crypto-assets are at all times held separately from the Company's own crypto-assets
• client crypto-assets are stored in dedicated, segregated accounts
• client crypto-assets are transferred exclusively upon execution of client instructions
• full transparency and a complete audit trail of all transactions are maintained
• client crypto-assets are protected against misuse, fraud, and unauthorised access

3. Crypto-Asset Storage

The Company uses a combined storage model consisting of:

• Hot wallet (online) – a portion of assets is held in online wallets to ensure operational availability and prompt execution of client instructions. Access is secured by multi-factor authentication and encryption.
• Cold wallet (offline) – the majority of client assets are held on offline hardware devices, isolated from the internet, thereby minimising the risk of cyberattacks.

Third-party custody: A portion of client crypto-assets is held with regulated third-party custodians. The primary custodian is Bitstamp Europe S.A. (Luxembourg, supervised by the CSSF), and the reserve custodian is Payward Europe Solutions Limited – Kraken (Dublin, supervised by the Central Bank of Ireland). Both are regulated service providers in accordance with MiCA. The Company retains full legal and operational responsibility towards clients regardless of the use of external custodians.

Client crypto-assets may be held on a pooled basis, together with the crypto-assets of other clients, in shared wallets, subject to the prior consent of the client, which is obtained upon acceptance of the General Terms and Conditions of Business at the time of Account registration. The same model is applied by the regulated third-party custodians used by the Company. Each client's position is recorded separately in the Company's internal records, regardless of the storage method.

Client funds are held by the Company on a pooled basis, subject to the prior consent of the client, which is obtained upon acceptance of the General Terms and Conditions of Business at the time of Account registration. The client is warned of the following risks and the implications of pooled holding:

• operational risk and the risk of record-keeping errors are inherent in the pooled storage model
• a cyberattack on a pooled wallet containing the assets of multiple clients simultaneously may cause a greater extent of damage than an attack on an individual wallet
• a temporary regulatory freeze or court order at the level of a pooled wallet may temporarily prevent all clients whose assets are held in that wallet from accessing their assets.

4. Position Register and Record-Keeping

The Company maintains a position register in the name of each client, reflecting each client's rights to their crypto-assets. Through their Account, the client may at any time view:

• the current crypto-asset balance
• the value of crypto-assets in EUR
• the full transaction history for a selected period.

The Company provides clients with a statement of their positions at least once every three months, as well as upon specific request. The statement is delivered in electronic form and contains the type of crypto-asset, the balance, the value, and an overview of transactions during the relevant period.

5. Order Processing

The client may submit an instruction via the user interface within their Account or in person at a Branch Office. Instructions are executed following verification of the client's identity and the circumstances of the transaction. Deposits of crypto-assets to the Account are processed immediately upon receipt of the requisite number of blockchain confirmations. Withdrawals of crypto-assets are processed no later than the end of the current business day for standard transactions. Crypto-asset withdrawals are irreversible and cannot be cancelled.

6. Asset Protection and Security Measures

Client crypto-assets are protected by the following measures:

• multi-factor authentication (MFA) for all system access
• encryption of private keys and storage in isolated environments
• redundant key access ensures continuity in the event of an unforeseen incident
• automated audit trail of all access and transactions
• daily reconciliation of balances between internal records and custodian accounts
• in the event of the Company's insolvency, client crypto-assets do not form part of the insolvency estate

7. Company Liability

The Company is liable to clients for the loss of crypto-assets or the means of access to crypto-assets that is directly attributable to the Company. In such a case, the Company shall compensate the client with crypto-assets of the same type and quantity; if this is not possible, the Company shall pay the market value of the lost crypto-assets at the time the loss occurred.

The Company is not liable for losses arising from events that are independent of the provision of the Service or the Company's operations, such as issues inherent in the operation of distributed ledger technology that the Company does not control.

In the event of changes to distributed ledger technology or any other event that affects the client's rights, the client is entitled to all crypto-assets or new rights created by such change, in accordance with the client's position at the time the change occurred.

8. Third-Party Custodians

Currently used third-party custodians:

All third-party custodians hold authorisation to operate in accordance with MiCA or the relevant EU regulations. The Company conducts an annual assessment of each custodian. Clients are notified by email at least 15 days in advance of any change of custodian.

9. Contractual Relationship

The contractual relationship for the custody service is established upon acceptance of the General Terms and Conditions of Business at the time of Account registration on the Platform. The General Terms and Conditions of Business are available on the Company's website.

10. Policy Amendments

This Policy is subject to regular review at least once a year, and more frequently if required by changes to the regulatory framework or the Company's business model. All amendments are published on the Company's website.