Non-Discriminatory Commercial Policy

PURPOSE
1. Bitflow Lab s.r.o. offers the following crypto-asset services, as defined in Article 3(16) of Regulation (EU) 2023/1114 (MiCA):
  1. Custody and administration of crypto-assets on behalf of clients;
  2. Exchange of funds (fiat) for crypto-assets;
  3. Exchange of crypto-assets for other crypto-assets.
2. This Policy is established to:
  1. Ensure a non-discriminatory commercial framework;
  2. Define onboarding and servicing criteria;
  3. Describe price methodology and service availability;
  4. Fulfill transparency and fair-treatment obligations under MiCA.
3. Bitflow Lab commits to safeguarding client assets separately from its own holdings, ensuring robust security for key management, not using client assets without explicit consent, and allowing clients to access or withdraw their assets at any time under normal conditions.
4. Clients retain full legal ownership of their assets. The Company does not acquire proprietary rights over client-held crypto-assets.
REVERSE SOLICITATION
1. Bitflow Lab s.r.o. strictly adheres to the principle of non-solicitation in jurisdictions where it does not hold regulatory authorisation to provide crypto-asset services. The Company does not engage in direct or indirect marketing, advertising, or promotional campaigns targeting clients in such jurisdictions. Services are provided exclusively under the reverse solicitation regime, whereby a prospective client initiates the business relationship entirely on their own initiative, without any prior contact, inducement, or prompting by the Company or its representatives.
2. To ensure compliance with this principle, the Company implements advanced geo-blocking and IP-filtering technologies to restrict website access and service availability in unauthorised jurisdictions. The Company also refrains from using language-specific SEO optimisation, sponsored content, affiliate marketing, or third-party influencers in non-permitted regions. Any marketing materials or communications are carefully reviewed to ensure that they do not constitute solicitation in restricted countries.
3. Upon receiving a service request that may qualify as reverse solicitation, the Company performs enhanced verification to assess the unsolicited nature of the contact. This includes:
  1. Requiring the client to submit a signed acknowledgment confirming that the relationship was initiated independently;
  2. Maintaining internal records of communication chronology and IP addresses;
  3. Ensuring no previous marketing or promotional engagement exists;
  4. Verifying the client’s location through documentation and technical tools.
4. Clients onboarded via reverse solicitation are subject to the same compliance standards as all other users. This includes full AML/CFT onboarding, identity verification, risk scoring, and ongoing transaction monitoring, as required under MiCA, the EU AML framework, and the Company’s internal policies. Reverse solicitation does not limit the Company’s right to refuse or terminate services if legal or regulatory grounds arise during or after onboarding.
TYPES OF CLIENTS
1. Bitflow Lab provides services to both natural persons and legal entities who have successfully completed the Company’s onboarding procedures, which include customer due diligence (CDD), identity verification, beneficial ownership disclosure (where applicable), and acceptance of the Terms of Use, Privacy Policy, and this Commercial Policy.
2. The Company applies a risk-based approach in its client acceptance procedures. Services are denied to applicants who:
  1. Fail or refuse to complete the required AML/KYC checks;
  2. Are residents of or incorporated in jurisdictions subject to international sanctions or listed on the Company’s internal high-risk jurisdiction list;
  3. Have previously violated the Company’s Terms of Use, fraud prevention policies, or attempted circumvention of geo-restrictions;
  4. Pose an unmanageable ML/TF or reputational risk, as determined by the Compliance Officer.
3. Bitflow Lab reserves the right to segment clients into service categories or tiers based on transparent and objective factors, such as:
  1. Trading volume and transaction frequency;
  2. Jurisdictional risk rating;
  3. Compliance and behavioral history;
  4. Service usage level and financial contribution.
  5. Client classification does not affect the non-discriminatory nature of service provision but may influence access to premium features, API bandwidth, transaction limits, or custom support levels.
AVAILABILITY AND PRICING OF SERVICES
1. Bitflow Lab’s platform is designed for 24/7 service delivery, offering continuous access to custody and exchange functionalities under normal market and system conditions. However, the Company reserves the right to temporarily suspend or limit specific services in the event of:
  1. Maintenance activities or scheduled upgrades;
  2. Blockchain protocol changes (forks, upgrades, airdrops);
  3. Liquidity disruptions from third-party providers;
  4. Regulatory notices or injunctions;
  5. Detected security threats, fraud, or technical anomalies.
  6. All suspensions are executed in a transparent and proportionate manner, and clients are notified where possible.
2. The Company guarantees equal opportunity for clients who meet its onboarding and compliance standards. No preference, discrimination, or differential treatment is applied based on race, nationality, gender, political opinion, or other personal attributes.
3. However, risk-based service adjustments may apply, such as:
  1. Limiting access to high-risk jurisdictions;
  2. Adjusting trading limits based on transaction history;
  3. Applying higher scrutiny for clients with complex ownership structures.
  4. These restrictions are not discriminatory but are imposed solely for regulatory, operational, or risk mitigation reasons.
4. Bitflow Lab applies a real-time, data-driven pricing model that aggregates rates from major liquidity providers. Prices for each transaction are calculated based on:
  1. External market data feeds;
  2. Bid/ask spreads and order book depth;
  3. Volatility indicators;
  4. Client transaction size and direction;
  5. Token-specific liquidity parameters;
  6. Associated blockchain network fees.
  The Company ensures that pricing decisions are made using automated, auditable algorithms and are not influenced by client identity or status.
5. Pursuant to Article 6(2)(e) of Delegated Regulation 2025/305, the Company explains how trading volume and market volatility affect price formation:
  1. When a client initiates a large transaction relative to the market's available liquidity, the system may apply dynamic slippage margins to account for execution impact. The larger the order, the more it may deviate from the mid-market rate due to its influence on the available depth.
  2. During periods of rapid price fluctuation, spreads widen to reflect the increased risk of slippage or loss. The system automatically recalibrates rates more frequently and shortens the validity window of fixed-price quotes to prevent stale pricing.
  3. If a particular crypto-asset is thinly traded or subject to withdrawal limitations (e.g., network congestion), this may increase transaction costs or extend confirmation timeframes.
  4. The pricing engine uses volatility indexes and internal execution history to recalculate spreads and rates every few seconds. These calculations are recorded in the internal system logs and are subject to compliance review and audit.
6. Bitflow Lab provides clients with all relevant pricing information before confirming any transaction. This includes:
  1. Service fees and network charges;
  2. Effective exchange rate;
  3. Quote validity period;
  4. Total cost estimation.
  All charges are displayed clearly on the interface and do not vary based on user profile. Refunds and reversals are governed by the Terms of Use and Refund Policy.
7. The Company retains the right to reject or cancel a transaction where:
  1. The quote has expired due to delay in confirmation;
  2. There is a material technical error or feed interruption;
  3. The transaction exceeds platform limits;
  4. Fraud or prohibited activity is detected.
  5. Clients are promptly notified of rejected transactions and, where applicable, given the opportunity to re-initiate the order at a new rate.
COMPLAINTS HANDLING
1. Bitflow Lab s.r.o. is fully committed to ensuring that all client complaints are addressed fairly, objectively, transparently, and in a timely manner. The Company views complaints not only as a regulatory requirement but also as an opportunity to improve its services, systems, and client experience. This policy applies to all types of complaints, including but not limited to: service quality, execution of transactions, delays, pricing discrepancies, access to accounts, and data protection.
2. Clients have the right to submit a complaint free of charge through any of the following channels:
  1. A dedicated complaint form available on the Company’s official website;
  2. Email communication to the Company’s designated support or compliance address;
  3. Secure in-app messaging or support ticketing systems available in the user interface;
  4. Postal mail to the Company’s registered office address (for formal or legal submissions);
  5. Telephone complaints may be accepted if followed up with written confirmation.
  6. The Company ensures accessibility of its complaints procedure to persons with disabilities or limited access to digital tools.
3. Upon receipt of a complaint, Bitflow Lab:
  1. Sends an acknowledgment of receipt to the client within three (3) business days;
  2. Assigns the complaint to a trained Compliance Officer or other impartial staff member not directly involved in the subject matter of the complaint;
  3. Conducts a fair investigation based on the facts and evidence provided by the client and internal system logs;
  4. Maintains the client’s confidentiality throughout the process.
4. A formal response will be provided to the client within fifteen (15) business days of acknowledgment. If the complaint cannot be resolved within this timeframe due to its complexity or other exceptional reasons, the Company will:
  1. Notify the client before the 15-day deadline expires;
  2. Explain the reason for the delay;
  3. Provide an estimated final response date, which shall not exceed an additional fifteen (15) business days.
5. The final complaint response shall include:
  1. A summary of the client’s complaint;
  2. A clear explanation of the outcome of the investigation and the Company’s position;
  3. If applicable, a description of corrective or remedial action taken;
  4. If the complaint is rejected, the reasons for the rejection;
  5. Details of escalation or alternative dispute resolution (ADR) mechanisms, including the option to refer unresolved complaints to the Czech Financial Arbitrator or other competent bodies, depending on the nature of the service.
6. The Company maintains a central complaints register which logs:
  1. The nature and category of each complaint;
  2. Timeline and actions taken;
  3. Final resolution and client feedback, if any.
  4. These records are retained for at least five (5) years, or longer if required by law, and are subject to periodic review by internal audit and compliance.
7. Bitflow Lab ensures that:
  1. All clients are treated equitably, regardless of complaint content or status;
  2. Clients will not be subject to retaliation, reduced service quality, or discrimination for submitting a complaint;
  3. Systemic issues identified through complaints are escalated internally to the Risk Committee or senior management for process improvement;
  4. Summary statistics and findings from complaints handling are included in the Company’s compliance reporting and may be disclosed to regulators upon request.
8. Clients are encouraged to consult the full Complaints Handling Procedure, available on the website and included as an annex to the Company’s Terms of Use. This procedure outlines the detailed steps, escalation paths, and timeline expectations in line with Article 73 MiCA and best practices under Delegated Regulation 2025/305.
ENTRY INTO FORCE
1. This Non-Discriminatory Commercial Policy shall enter into force as of the publication date stated in the document heading and shall remain in effect until superseded, revoked, or materially amended.
2. The Policy is binding on all employees, partners, and contractors involved in the provision of crypto-asset services under the MiCA framework. It is incorporated by reference into the Company’s Terms of Use and is made available to all clients via the official website.
REVIEW AND AMENDMENTS
1. Bitflow Lab s.r.o. shall review this Policy:
  1. At least once per calendar year;
  2. Following any material change in regulatory requirements, including updates to Regulation (EU) 2023/1114 or Delegated Regulation 2025/305;
  3. In response to internal audit findings, operational incidents, or client feedback;
  4. Upon request or instruction from the Czech National Bank or other competent authority.
2. Any amendments shall be approved by the senior management and Compliance Officer. Clients will be notified of material updates at least 14 days in advance unless urgent regulatory or security grounds require immediate implementation.
3. Previous versions of the Policy shall be archived and retained for regulatory compliance and client reference. Upon request, the Company shall provide clients with access to past versions applicable at the time of their transaction or complaint.