Crypto-bewaarbeleid.

Client Summary
Custody and Administration Policy

Version 1.0

Date: 01.02.2026

1.0 Introduction

The Custody and Administration Policy ("Policy") of Cryptonow GmbH ("Cryptonow") sets out a clear and robust framework for the handling, protection, and management of clients’ crypto-assets. As a licensed crypto-asset service provider ("CASP") under the Markets in Crypto-Assets Regulation ("MiCAR"), Cryptonow is committed to upholding the highest standards of asset security and regulatory compliance.

This content (the "Summary") offers an overview of the custody and administration services Cryptonow provides to its clients ("Clients" or "you") via the Cryptonow platform ("Cryptonow Platform"). It explains the safeguards and procedures in place to protect Clients' crypto-assets from unauthorized access or misuse, ensure accurate record-keeping, and guarantee the full separation – both operationally and legally – of Clients' crypto-assets from those of Cryptonow. Additionally, it outlines Client rights related to their crypto-assets. Clients must carefully review the full terms and conditions that govern the custody and administration services. This Summary does not substitute the knowledge and understanding of the terms and conditions.

Cryptonow acknowledges its vital responsibilities as a custodian and is committed to maintaining openness and trust with its Clients. This Summary highlights the essential elements of the internal Custody and Administration Policy to ensure Clients have a clear understanding of how their crypto-assets are safeguarded and managed.

2. Contractual Partner

Cryptonow is the sole contractual counterparty of Clients for the provisioning of custody and administration services under the custody agreement, as part of the full terms and conditions. Cryptonow can be contacted via the following channels:

  • Customer support via the Cryptonow Platform here: https://www.cryptonow.net/en/email-support-form

  • In addition, a formal complaint can be submitted for example by using the standardized complaints template here: https://www.cryptonow.net/en/official-complaint

Upon request and during the contractual relationship related to custody and administration services, this Summary can be provided to you in electronic format.

3. Competent Supervisory Authority

The Austrian Financial Markets Authority (Österreichische Finanzmarktaufsicht, "FMA") is the competent supervisory authority for Cryptonow.

4. Client Segregation and Safeguarding

The custody services provided by Cryptonow are governed by a custody agreement (contained in the general terms and conditions) between Cryptonow and each Client. Under this agreement, Cryptonow is obligated to safeguard Clients' crypto-assets with utmost care, ensuring that Clients retain ownership rights of their crypto-assets. Clients' crypto-assets are legally and operationally separated from Cryptonow's own assets, providing protection in the event of Cryptonow's insolvency.

The custodial infrastructure uses a multi-layer IT system which, based on overall assets in custody , supports various wallet types, including hot, warm, and cold wallets, to manage and protect Clients' assets.

At this point in time, Cryptonow only operates hot and warm wallets. Hot wallets enable quick access and ensure that withdrawal requests can be met in a timely manner. The hot wallets and the respective private keys are protected by MPC-technology (multi-party computation) which provides protection against unauthorized access. Warm wallets and the respective private keys are also secured through MPC-technology. Compared to hot wallets, however, warm wallets require manual transaction approval with no automation, enhancing security and governance. In line with the expected growth of Cryptonow's business operations, it will adjust its custody strategy, introducing cold wallets based on predefined thresholds to further hence security while upholding accessibility. As soon as the custody strategy is updated, a new version of this Summary will be made available to Clients.

Operational segregation is crucial for effective legal segregation, and Cryptonow employs a comprehensive IT infrastructure to ensure this separation. Key measures include explicit identification and record-keeping of Clients' crypto-assets within the Order Management System ("OMS"), individual Client accounts for tracking, internal controls for compliance, and strict separation of Clients' and Cryptonow's assets through dedicated vaults. Access to Clients' crypto-assets is rigorously restricted, and all transactions are recorded to provide transparency and regulatory compliance.

5. Client Crypto-Asset Administration and Client Rights

The Policy is designed to prioritize the recognition and protection of each Client’s rights to their crypto-assets. Clients retain their (civil law) ownership rights over their crypto-assets and Cryptonow acts as custodian under the custody agreement. This means that the Clients are always the beneficial owners of their crypto-assets as well as retain legal ownership over them. Cryptonow maintains a comprehensive register of positions that accurately reflects each client's individual holdings. This register tracks all asset movements – such as deposits, withdrawals, and transfers – as well as ownership, ensuring a continuously updated and transparent record of Client holdings.

This register plays a critical role in supporting both the legal and operational framework of Cryptonow's custody services. It ensures that every transaction affecting a Client’s crypto-asset is promptly recorded and that ownership rights are clearly defined and upheld. Cryptonow's internal systems are built to process these updates efficiently, enabling swift and accurate execution of Client instructions.

Clients have full access to their crypto-asset information through their Cryptonow account, where they can view detailed reports of their holdings, transaction history, and any relevant updates. This level of transparency reflects Cryptonow's commitment to managing Client crypto-assets with integrity, precision, and accountability.

6. Client Crypto-Asset Transaction Management

Cryptonow's administration services involve on-chain transactions with Clients' crypto-assets, relying on a robust custodian infrastructure that balances efficiency and security. Transactions can be fully automated, semi-automated, or require manual approval, depending on the wallet type and associated security policies. Hot wallets allow for automated processing, enabling rapid transaction execution. Warm wallets utilize automation for transaction creation but require manual approval before broadcasting to the blockchain. Cold wallets store private keys offline for enhanced security, necessitating manual administration. In line with section 2 of this Summary, Cryptonow currently utilizes hot wallets and warm wallets, whereas cold wallets are planned to be added in accordance with the business' growth.

All transactions are governed by Cryptonow’s policy-based security framework, which defines parameters such as transaction thresholds, whitelisted addresses, and approval levels. This framework allows for tailored transaction processes that meet specific security and operational needs. Real-time monitoring systems oversee wallet activities and balances, ensuring swift action in the case of Client withdrawals.

7. Compliance and Risk Management Strategies

Cryptonow adheres to MiCAR and Digital Operational Resilience Act ("DORA") requirements, utilizing industry-leading third-party software solutions to minimize risks and ensure operational efficiency. Key components of the architecture include the OMS for balance processing, secure crypto-asset administration, and anti-money laundering (AML), counter financing of terrorism ("CFT") and compliance solutions (including sanctions and fraud checks). These systems are interconnected through the Cryptonow backend, which supports Client transactions and liquidity management.

Additionally, Cryptonow has established internal procedures for risk assessment and management specifically tailored to its custody and administration services. This includes systematic identification of potential threats, development of contingency plans, and regular review of risk mitigation measures, focusing on primary risks such as cybersecurity threats, operational failures, fraud, and human error. A structured risk classification process evaluates potential threats based on their likelihood and impact, allowing Cryptonow to prioritize resources for critical risks. The risk identification process involves system analysis, management engagement, threat modeling, risk mapping, and assessment of general risk management policies. Cryptonow implements advanced access control and permission models, adhering to information and communications technology ("ICT") security guidelines to ensure the highest standard of protection for Clients' crypto-assets. In line with DORA requirements, comprehensive exit plans have been developed to ensure continuity of operations in the event of a third-party provider failure and to ensure that the Client's position is at no time compromised or negatively impacted.

8. Transparency and Documentation

Cryptonow maintains comprehensive records and documentation of all actions taken to minimize risks and ensure compliance with regulatory requirements. Additionally, Cryptonow is committed to continuous improvement by regularly assessing its measures and incorporating feedback from potential incidents and reviews. Policies and procedures are updated as necessary to maintain security, compliance, and alignment with evolving regulatory requirements.

9. Client Communication and Reporting

Cryptonow prioritizes clear and effective communication to ensure Clients are fully informed and supported throughout the provision of crypto-asset custody and administration services. To facilitate this, Cryptonow offers contact channels, providing Clients with convenient access to assistance whenever needed.

Clients receive quarterly statements of their crypto-assets, detailing balances, amounts, current values, and transfers, which can be accessed and downloaded via the Cryptonow Platform under "Settings/Reports," ensuring full transparency regarding their assets. This proactive communication approach ensures transparency and reinforces Client confidence in the custody of their crypto-assets.

Beyond routine updates, Cryptonow provides dedicated customer support to address any questions or issues through the help center at https://www.cryptonow.net/en/help. The support team is well-equipped to handle topics related to custody operations on the Cryptonow Platform.

© Copyright 2026 Cryptonow GmbH. Alle rechten voorbehouden.

Cryptonow GmbH, Marc-Aurel-Straße 10-12/15a, 1010 Wenen, Oostenrijk, levert de gereguleerde dienst voor het wisselen van crypto-activa voor andere crypto-activa en/of fiat-valuta als de belangrijkste tegenpartij voor de klant.

Cryptonow GmbH heeft een vergunning als aanbieder van crypto-activadiensten (CASP) onder de Oostenrijkse wetgeving. De handel in crypto-activa brengt aanzienlijke risico's met zich mee en is mogelijk niet geschikt voor alle beleggers. Voordat je een transactie aangaat, moet je jouw beleggingsdoelstellingen, ervaringsniveau en risicotolerantie zorgvuldig beoordelen. De waarde van crypto-activa is zeer volatiel en kan binnen korte tijd tot aanzienlijke verliezen leiden. Elke crypto-activa bezit specifieke kenmerken en je moet grondig onderzoek doen en ervoor zorgen dat je een activa volledig begrijpt voordat je een transactie aangaat. Resultaten uit het verleden zijn geen betrouwbare indicator voor toekomstige resultaten. Deze inhoud geldt als marketingcommunicatie in de zin van de Markets in Crypto-Assets Regulation (MiCAR), vormt geen beleggingsaanbeveling of financieel advies en je moet ervoor zorgen dat je alle bijbehorende risico's begrijpt, inclusief het potentiële verlies van het volledige belegde kapitaal. Fondsen mogen niet worden belegd als het verlies ervan financieel niet kan worden gedragen.