Commercial Policy

Commercial Policy

Version 1.0 – October 2024

1. Introduction

The aim of this Commercial Policy (“the Policy”) is to regulate the provision of exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets services (“the Exchange Services”) by Zillion Bits Ltd. (“ZBX” or “the Company”).

The provisions of this Policy have been designed in a manner that ensures clear disclosure of the rights and responsibilities of ZBX and its clients and the effective protection of ZBX and its clients’ rights. 

2. Definitions

‘Exchange of crypto-assets for other crypto-assets’ means the conclusion of purchase or sale contracts concerning crypto-assets with clients for other crypto-assets by using proprietary capital;

‘Exchange of crypto-assets for funds’ means the conclusion of purchase or sale contracts concerning crypto-assets with clients for funds by using proprietary capital.

3. Client Acceptance

ZBX shall make the Exchange Services available to all individual and corporate customers who:

i. have satisfied the customer due diligence procedures;

ii. otherwise satisfy the provisions of the ZBX Client Acceptance Policy; and

iii. have accepted the ZBX Terms of Business.

4. Method of Determining the Price of Crypto-Assets

ZBX shall publish a firm base price of the crypto-assets it proposes to exchange for fiat funds or other crypto-assets. 

The pricing mechanism will be influenced by the following factors:

a) the Risk Rate derived from the risk calibration in accordance with ZBX’s Entity-Wide AML/CFT Business Risk Assessment (BRA), Jurisdictional Risk Assessment (JRA) and Customer Risk Assessment (CRA);

b) the assessment of market forces based on market volatility, scarcity of supply and similar factors; and

c) the assessment of compliance considerations.

The price of crypto-assets in the context of Exchange Services shall adjust dynamically based on the real-time pricing offered by liquidity providers available to ZBX applying a risk premium derived from the above-mentioned factors.

For large-scale over-the-counter (“OTC”) deals pricing can in addition be adjusted based on factors like the volume and size of transactions, the type of client (e.g. individual or corporate), commercial impact, client loyalty and retention considerations, etc. 

5. Finalization of Orders

For an order to be deemed final, the following conditions must be met:

a) the order must be confirmed by the client, which includes review and acceptance of the price at the time of order placement; 

b) any related risk warnings and disclosures must be accepted by clients, if applicable; and

c) any specific conditions must be fulfilled, including minimum transaction amounts or trading limits, if applicable.

Client orders will be locked in and executed at the price displayed at the time the order is deemed final.

6. Trading Fees

The following fees are being charged by ZBX in the context of Exchange Services:

a) Account Activation, Maintenance, and Dormancy Fees;

b) Crypto-to-Crypto Trading Fees;

c) Fiat-To-Crypto Trading Fees;

d) Over-the-counter (OTC) Trading Fees; and

e) Crypto-Asset Withdrawal Fees.

Fees charged by ZBX for completed transactions shall be non-refundable.

ZBX shall publish its Pricing, Costs, and Fees policy as well as the current fees on its website. 

7. Trade Transparency

ZBX shall fully disclose to its clients information about the transactions concluded, including transaction volumes and prices at the time of order placement.