These are the terms and conditions of using the services of Change divided into specific chapters. By signing up you agree that you have read, understood, and accept all of the relevant terms and conditions. If you do not agree or fail to adhere to these or any other rules of any of the services, you are not entitled to use the services.
These Terms and Conditions are available in other languages for information purposes, in any case and if there is any semantic discrepancy, the English version will prevail.
In force from 2023-08-21
These are the general terms and conditions of using the services of Change. By signing up through our Website or Apps you agree that you have read, understood, and accepted all of the Terms. If you do not agree or fail to adhere to the terms and conditions or any other rules of any of the services, you are not entitled to use the services.
The Website and the Services offered by Change are NOT ADDRESSED TO AND MAY NOT BE USED BY:
As used in these Terms, including the preamble hereof, unless expressly otherwise stated or evident in the context, the following capitalised terms and expressions shall have the following meanings:
Account – the account opened with Change by a User, using which the User can access and use the Services, including Business Account;
Apps – the web, Android and iOS mobile apps of Change, which give access to the Services;
Business Account – the account opened with Change by a User, who is a legal person, using which the User can access and use the specific and limited Services, which are shown in the Apps;
Change – xChange AS, an Estonian public limited company registered under registry code 14428150, Rävala pst 4, 10143 Tallinn. References to “we”, “us” and “our” mean references to Change and/or if applicable Change Securities B.V.;
Change Tokens or Tokens – cryptographic ERC-20 tokens issued by Change as Change tokens (CAG) and in Apps as Change equity-like tokens (CNG). The list of cryptocurrency markets on which the Tokens are tradable may be amended by Change at its full discretion at any time without providing any prior notification thereof;
Conversion Rate – the price or exchange rate of one unit of a given supported cryptocurrency whereby the price of the offered asset is determined by Change. Conversion Rate is derived from multiple factors, such as direct and indirect asset acquisition cost and market risk to which Change is exposed to while completing the transaction, Rate Reference as indicative price point, as well as conversion fee as described in chapter Fees and Limits;
Conversion Service – regulated service of cryptocurrency conversion (for which Change has been issued a licence by the Estonian Financial Intelligence Unit, no FVT000072) through which Users can buy supported cryptocurrencies from Change, in exchange for specified Fiat currencies and other supported cryptocurrencies and specified Fiat currencies from Change, in exchange for supported cryptocurrencies, including the services of Market Order, Limit Order and Stop Order, and Growth Pocket;
Crypto Interest Account – proprietary wallets of Change operated either by Bitgo, Inc. or Payward, Inc. where Change deposits supported cryptocurrencies on behalf of customers for the purpose of earning and redistributing staking reward, i.e. interest;
Custodian – the person who holds and is responsible for the safekeeping of the cryptocurrencies and/or tokens (including the Tokens) transferred to or held in the Wallet by the User, who at the date of these terms and conditions is Bitgo Inc.;
Debit Card – VISA debit card connected to the Getchange Account as described in chapter Getchange Account and Debit Card;
Fees and Limits – full list of fees and limits of Services as described in the chapter Fees and Limits;
Fiat – currency that has been declared as legal tender by a government and is regulated by a central financial institution, i.e. the euro;
Getchange Account – electronic money account as described in chapter Getchange Account and Debit Card;
Growth Pocket – cryptoasset service, whereby the User is rewarded for buying supported cryptocurrencies from Change and allowing these to be deposited on Crypto Interest Account as described in chapter Growth Pocket and Staking;
Instant Deposit – Service allowing Users to add funds to their Fiat Account instantly by using their EEA-issued credit or debit card (limited up to 3 different cards) with the fee described in Fees and Limits;
Investment Gold or PAXG – a cryptocurrency created by Paxos Trust Company, LLC (hereinafter: Paxos), which is backed by investment gold as defined in Precious Metal Articles Act § 2(9), specifically each PAXG token is backed by one fine troy ounce (t oz) of a 400 oz London Good Delivery gold bar;
Limit Order – Service, whereby User submits an instruction to complete the transaction in the future when the price of the supported cryptocurrency has been risen above the Rate Reference set by the User has been reached;
Market Order – Service, whereby User submits an instruction to complete the transaction immediately;
Party – each of the User and Change;
Passive Account – a status assigned internally by Change to all Accounts that have not had any transactions related to either Conversion Service or CFD Trading service provided by Change Securities B.V. during the period of 90 consecutive days;
Rate Reference – the price of one unit of a supported cryptocurrency in terms of a specified Fiat currency or another supported cryptocurrency, which is based on the lowest ask price for buying or the highest bid price for selling a cryptocurrency on the exchanges operated by trusted third party vendors;
Services – services provided by Change, UAB Finansines paslaugos "Contis" and/or Change Securities B.V. to the Users, including the Wallet and the Conversion services;
Staking– cryptoasset service, whereby the User is rewarded for buying supported cryptocurrencies from Change and allowing these to be deposited on Kraken Account as described in chapter Growth Pocket and Staking;
Stop Order – Service, whereby User submits an instruction to complete the transaction in the future when the price of the supported cryptocurrency has been fallen below the Rate Reference set by the User;
Taxes ‒ taxes, levies, duties or similar governmental assessments of any nature, including, for example, value-added, sales, use or withholding taxes, assessable by any jurisdiction whatsoever;
Terms – these Terms and Conditions including all the chapters, as amended from time to time;
Token Swap – exchanging CAG Tokens to CNG Tokens as described in chapter Token Swap;
User – anyone who uses the Website, Apps and/or Services provided by Change. References to “you” and “your” mean references to the User;
Wallet ‒ User’s cryptocurrency wallet, which can be accessed via the Website or the Apps, and which is a regulated service (for which Change has been issued a licence by the Estonian Financial Intelligence Unit, no FVT000072), as further described in section 6 below, including the Services of Cryptocurrency withdrawal and Cryptocurrency deposit;
Website – websites located at https://changeinvest.com/ and at all subdomains.
2.1. To use any of the Services, which might be provided for a fee as stated in Fees and Limits, you must open the Account and any such use must be done through the Account. One digital identity associated with the Account will be used for accessing all Services.
2.2. Each User must be at least 18 years of age to register for an Account or to use any of the Services.
2.3. In order to register for a Business Account, the legal entity must be established in and have its place of business in Estonia, including all of its members of the board, shareholders and beneficial owners must be residents and/or citizens of Estonia. To open a Business Account all of the members of the board and the beneficial owners of the legal person must at all times be our Users as natural persons, who have successfully transferred Fiat funds onto their Account in accordance with Fiat Account and Conversion Service clause 2.1, and whose Account(s) have not been closed.
2.4. We reserve the right to unilaterally decide whether to open an Account and/or whether to provide Services to any persons and shall have no obligation to justify or outline the reasons for any rejection.
2.5. All information that you provide to us at any time (including but not limited to the information provided upon the opening of the Account) must be accurate, current and complete and may not be misleading in any respect. We may, from time to time, request such information to be provided and/or updated, in which case you are required to provide us with the information without delay. If you are unable or unwilling to provide or update such information or it is incorrect, we have the right to deny opening the Account, close the Account and/or restrict the usage of the Services.
2.6. You acknowledge that using the Services is limited to the amounts as described in Fees and Limits.
2.7. By opening an Account and using the Services, each User fully acknowledges that Change does not provide to the User any investment service or advice. Each User fully acknowledges that any information, product or service provided by us on our Website or Apps is not considered investment advice or recommendation, and independent professional advice should be sought where appropriate.
3.1. By using the Services you acknowledge that various types of risks are involved, including but not limited to risks relating to the fluctuation of the value of any assets related to the Services (including Change Tokens), technical imperfections of Change Tokens, other cryptocurrencies, the Website and the Apps, regulatory uncertainties, and risks related to our operations and financial viability. As our Users are taking risks and are exposed to them through our Services, we strongly recommend and encourage you to learn and gain a sufficient understanding of the risks involved prior to using our Services.
3.2. We encourage you to consult with a financial advisor or other appropriate professional prior to starting to use the Services.
4.1. Change administers and operates the Website and Apps from its location in Estonia. Although the Website and Apps are accessible worldwide, not all features, products or services discussed, referenced, provided or offered through or on our Website or Apps are available to all persons or in all geographic locations, nor are they appropriate or available for use outside Estonia.
4.2. We reserve the right to limit, in our sole discretion and without providing any justification related thereto, the provision and quantity of any feature, product or Service to any person or geographic area.
4.3. Any offer for any feature, product or Service made through or on our Website or Apps is void where prohibited.
4.4. By choosing to access the Website or download or access any of the Apps from outside Estonia, you are solely responsible for complying with applicable local laws.
5.1. You are responsible for maintaining adequate security and control of any and all login IDs, passwords, private keys, personal identification numbers (PINs), and any other codes or devices which are intended to or can otherwise be used to access the Account and/or use the Services.
5.2. You must prevent unauthorised access to the Account and unauthorised use of the Services, your account credentials or private keys, and must promptly notify us of any such unauthorised access or use.
5.3. In the event of an investigation of any suspected unauthorised access to the Account or use of the Services you must fully and timely cooperate with us in order to successfully solve the issue.
5.4. You are solely responsible, and to the maximum extent permissible under applicable legal acts, and we will have no liability, for any activity that takes place on your Account if the Account has been accessed with your account credentials, regardless of whether or not you authorised such access.
6.1. We provide the service of a cryptocurrency wallet pertaining to your Wallet. The Wallet service entails enabling you to interface with certain cryptocurrency networks listed in the Apps and on our Website, and if applicable to view and transmit information about public cryptographic keys. We have the right to unilaterally decide and change the cryptocurrencies which can be stored in the Wallet using the Wallet service or converted using the Conversion Service.
6.2. Upon using the Wallet service in addition to adhering to these Terms you agree to fully abide by the terms and conditions of the Custodian.
6.3. We are not a custodian of any cryptocurrency and/or tokens (including the Tokens) transferred to or held in the Wallet. All cryptocurrencies and tokens (including the Tokens) are held by the Custodian. We reserve the right to change the Custodian at any time, without prior notification or justification thereto. To the maximum extent permissible under applicable legal acts, we assume no liability for any possible damages caused by the Custodian.
6.4. Upon the creation of the Account, except for Business Account, the Wallet is automatically created for you, together with a public key, which serves as the address of the Wallet. We have the sole right to decide at our own discretion whether or not to disclose that public key to you and we may at any time, and without any prior notice, not disclose the public key to you.
6.5. To transmit information concerning the Account to the relevant cryptocurrency network (i.e. to carry out a transaction with cryptocurrency), two private keys (out of three private keys in total) are required. One of such private keys is held by us, the other by the Custodian and the third is held by a third-party backup service provider.
6.6. We do not own or control the underlying software protocols which govern the operation of cryptocurrencies held in the Wallet. Such protocols are subject to changes in protocol rules, which are outside our control and may materially affect the value, function, or name of the relevant cryptocurrency. You acknowledge and agree that:
6.6.1. we are not responsible for operation of the underlying cryptocurrency protocols and that we make no guarantee of their functionality, security, or availability; and
6.6.2. if a change in the software protocol related to the cryptocurrency occurs, we may suspend the Wallet service, and may decide not to provide Wallet service for the cryptocurrency being affected or may configure the Wallet service to enable you to transfer the affected cryptocurrency.
6.7. While using the services of Cryptocurrency withdrawal and Cryptocurrency Deposit, you are only able to transfer supported cryptocurrencies, which are stated in the Apps and on the Website, e.g. BTC and ETH, but not PAXG. We are not liable and shall not compensate you for any losses or damages, if you use the services of Cryptocurrency withdrawal and Cryptocurrency deposit with cryptocurrencies that are not supported.
6.8. Due to the nature of distributed ledger technology and blockchains you acknowledge that while using the services of Cryptocurrency withdrawal and Cryptocurrency deposit none of the transactions, which have been confirmed and added to the respective main ledger, cannot be reversed and you are fully liable for the transactions you have confirmed and ordered us to process.
6.9 Due to the nature of blockchain protocols and the lack of in advance knowledge of the network, gas or similar fees, Change is unable to determine the exact Cryptocurrency withdrawal fee before the specific transaction has been confirmed by miners. The Cryptocurrency withdrawal fee shown to you in the Apps is automatically calculated by Change after every 5 minutes by taking into account the concurrent price of the specific network, gas or similar fee and the relevant price predictions, regardless of the priority in the memory, transaction or other similar pool. While using the service of Cryptocurrency withdrawal, you agree to pay the specific Cryptocurrency withdrawal fee shown to you in the Apps by confirming the Cryptocurrency withdrawal in your email or in the Apps.
7.1. In order to manage the risk of money laundering and terrorist financing, and to abide by the statutory obligations applicable to us and to you for using our Services, we and you are obliged to follow certain principles of customer due diligence, as further specified in this section.
7.2. You are not allowed to use the Services nor the Wallet for any activities which are related to or facilitate money laundering, terrorist financing or any illegal activity whatsoever.
7.3. We reserve the right to, at any time:
7.3.1. identify you;
7.3.2. request from you any documents, either as originals or as copies and information (including personal), which we consider appropriate and/or relevant for the identification or for the mitigation of money laundering and terrorist financing risks;
7.3.3. regularly control your data and documents which are used for identification and/or for the mitigation of money laundering and terrorist financing risks;
7.3.4. transfer and disclose any information and documents received in accordance with this section to any and all governmental authorities and other persons to whom we are obliged to transfer and disclose information and documents in accordance with applicable legal acts;
7.3.5. transfer and disclose any information and documents received in accordance with this section to any and all third-party service providers, which we use to fulfil our obligations related to client identification and money laundering and terrorist financing prevention; and
7.3.6. transfer and disclose any information and documents received in accordance with this section to the Custodian, if applicable.
7.4. You acknowledge that we may upon the fulfilment of our obligations related to client identification and money laundering and terrorist financing prevention use the services of third-party service providers, and you hereby grant an irrevocable and unconditional consent to such use of third-party service providers and the transfer and disclosure of information to such third-party service providers.
7.5. You acknowledge that we may transfer and disclose to the Custodian any information and documents referred to in this section for the purpose of allowing the Custodian to fulfil their obligations related to client identification and money laundering and terrorist financing prevention, and you hereby grant an irrevocable and unconditional consent to such transfer and disclosure of information.
7.6. You are obliged to immediately inform us in writing of any information that might be relevant in accordance with this section and/or changes to the provided information and documents, inter alia:
7.6.1. change of your name, address or other contact information;
7.6.2. change of data regarding your identity document;
7.6.3. change of persons in the management board, beneficial owners or ownership structure;
7.6.4. the fact that you, any member of the management board or beneficial owner has become or is no longer a politically exposed person and/or a relative or a close associate of one; and
7.6.5. loss or theft of your identity document or credentials used for the Account or Services.
7.7. You are obliged to inform us in writing of any other information which might be relevant in relation to client identification and money laundering and terrorist financing prevention, immediately after becoming aware of such information.
7.8. You are obliged to fully and timely cooperate with us upon the gathering of information and documents referred to in this section, as well as the fulfilment of any other obligations we have in relation to client identification and money laundering and terrorist financing prevention under applicable legal acts. Should you refrain from cooperation with us in accordance with this section, we have the right or legal obligation to:
7.8.1. stop the provision of any Services;
7.8.2. block the Account and limit your access to the Website and the Apps;
7.8.3. withhold any payments made by or to you in relation to the Services; and/or
7.8.4. close the Account.
7.9. In addition to clause 7.8, we reserve the right to block the usage of your Account and limit your access to the Website and the Apps, when we suspect that:
7.9.1. the Account is being used by any person other than you;
7.9.2. an offence is being committed, using the Account; and/or
7.9.3. any of the information or documents provided by you to us or our third-party service providers may be untrue, and you do not provide sufficient and/or satisfactory evidence, proving the correctness of the information and documents.
7.10. To the maximum extent permissible under applicable legal acts, we assume no liability for any losses or damages caused to you or any other persons by the actions provided for in this section.
8.1. You have the right to close your Account at any time, provided that you have no obligations towards us nor the Custodian. From the moment of closing the Account, you shall not be entitled to use any of the Services.
8.2. In addition to specific circumstances described elsewhere in these Terms, we reserve the right to close your Account:
8.2.1. without any justification, by giving you an advance notice of at least 14 days and refunding you the market value of any assets which you have in the Wallet, for which such services have not yet been provided and cannot be provided after the closing of the Account;
8.2.2. in case you breach: (i) these Terms; (ii) the terms and conditions of the Wallet Custodian; or (iii) any other terms and conditions of the Services or otherwise binding on you, without giving any notice in advance;
8.2.3. in case you act in a manner that is threatening, abusive or racially discriminative to our staff or any of our representatives, without giving any notice in advance;
8.2.4. in case we have any suspicions of money laundering or terrorist financing, fraud or other criminal activity, without giving any notice in advance; and/or
8.2.5. in case closure of the Account is required by a competent authority, without giving any notice in advance.
8.3. If we have closed your Account without giving any notice in advance the cryptocurrencies held at your Account shall be automatically converted into specified Fiat funds by us and transferred to your bank account from which a payment had been previously made in accordance with the law.
8.4. Once an Account has been closed, it cannot be re-opened in the future.
9.1. You agree and are liable for the payment of all fees. Fees for Services, as amended from time to time, can be found in the chapter Fees and Limits, which shall form part of the Terms.
9.2. You are liable for and shall compensate Change any and all damages (including the loss of profits), which arise from your activities.
9.3. You agree that Change has the right to place a Market Order on behalf of you to settle any outstanding or delinquent payment of any fee or other types of liability. The Market Order will be placed for the cryptocurrency in the Wallet that has the biggest market capitalisation as per the order determined by Change. All respective fees apply to this transaction.
9.4. We are liable for and shall compensate you only direct monetary damages (and for the avoidance of doubt, no indirect damages or loss of profits) and only on the condition that such damages are caused to you by us either intentionally or due to gross negligence.
9.5. Our liability is reduced by the amount equal to the damages which you could have avoided by taking reasonable efforts.
9.6. In addition to the limitations described elsewhere in these Terms, to the maximum extent permissible under applicable legal acts, we assume no liability for any damages caused by third parties (including but not limited to the Custodian) or by circumstances outside our control (including but not limited to volatility of cryptocurrencies).
10.1. Unless otherwise stated, all materials including, but not limited to, logos, brand names, designs, images, photographs, video clips, written are copyrights, trademarks, service marks, and any other forms of intellectual property present in the Services or displayed in connection with the Services (e.g. in the Website), protected by registration or not, are owned by or licensed to us. The foregoing also applies towards any software solutions or parts of it, programs and code present in the Service.
10.2. We grant you a limited, non-exclusive, not sub-licensable licence to access and use the materials, as specified in this section of these Terms, for your personal use, as required for the use of Services.
10.3. You are not allowed to sell, distribute, publicly display, modify, otherwise alter or make any derivative use of the materials, as specified in this section, or any portion thereof, unless you have been granted an express and written prior permission to do so by us.
10.4. The licence granted under this section will automatically terminate upon the closing of the Account. Thereafter you are no longer allowed to access or use any part of the material belonging to us.
10.5. In case your actions or activities conducted in connection with the Service or while using the Service (including but not limited, through providing us feedback or leaving any comments addressed us) amount to copyright protected work under applicable legislation, you will automatically grant to us, from the moment of the creation of such work, a non-exclusive, world-wide, sub-licensable, free-of-charge licence, which is valid until the copyright is protected under applicable legislation, in relation to such work.
10.6. As stated in this section, we retain full ownership and/or exclusive licence of any software, program, code or parts of it. The foregoing might be protected by security measures, which you are not authorised to change, disseminate, hack or alter in any way.
11.1. It is your sole responsibility to determine whether, and to what extent, any Taxes apply to any transactions you conduct through the Apps and Website or are associated with the Services, and to withhold, collect, report and remit the correct amounts of Taxes to the appropriate tax authorities. Your transaction history is available through the Apps. The fees collected by us do not include any Taxes.
11.2. We may unilaterally amend these Terms without providing any advance notice or justification thereto. Any amendments to the Terms shall take effect as of uploading them to the Website and making them accessible in the Apps.
11.3. Our failure to exercise or enforce any right or provision of these Terms will not constitute a waiver of that right or provision.
11.4. If any part of these Terms is held to be invalid or unenforceable, such determination shall not invalidate any other provision of these Terms.
11.5. You agree that we may assign these Terms (either collectively or each right and/or obligation separately, as decided by us) to our parent company, affiliate or subsidiary without your consent. You may not assign any rights or obligations you have under these Terms without our prior written approval.
11.6. These Terms are governed by the laws of Estonia. Any dispute, controversy or claim arising out of or in connection with these Terms, or the breach, termination or invalidity hereof, which the Parties have failed to solve by negotiations will be settled in Harju County Court.
11.7. These Terms and all communication is published and provided in English. We may publish translated versions of these Terms or any chapter therein in any language other than English, however these versions are of informational nature. Should there by any discrepancies or deviations between the languages, the English version shall prevail.
In force from 2023-07-17
As used in these Terms, including the preamble hereof, unless expressly otherwise stated or evident in the context, capitalized terms and expressions shall have the meanings as stipulated under “General and wallet” chapter.
2 In order to add Fiat funds to your Account you must transfer at least 10 euros to the account provided by us, which will be added to your Account, from an account opened under your name in a credit or financial institution, registered or having its place of business in a contracting state of the European Economic Area. Any following transaction may be made from a different account, provided it is opened in your name, or by using the Service of Instant Deposit.
2.2. You acknowledge that all of the Fiat funds described in these Terms must belong to you and all the accounts described in these Terms must be opened under your name.
2.3. We reserve the right to decline accepting Fiat transfers to our account from any account due to any reason or decline transferring funds to an account that was not used to make a transfer in accordance with clause 2.1 by notifying you thereof. We have also reserved the right to decline accepting any payments while using the Service of Instant Deposit, e.g. to prevent fraud or in case more than 3 different cards have been used.
2.4. In case we decline accepting Fiat transfers, the funds will be immediately returned to your account opened in a credit institution in accordance with the law.
3.1 You are entitled at all times to instruct us to withdraw any Fiat funds from your Account by instructing us to transfer them to an account you previously transferred funds from as described in clause 2.1.
3.2. We reserve the right to decline to perform a withdrawal, if the withdrawal amount is lower than 10 euros.
3.3. In the case of Account closing you must instruct us to transfer all of the fiat funds to an account you previously transferred funds from as described in clause 2.1 and we will transfer it to your account in accordance with the law.
4.1 In order to buy a supported cryptocurrency with the Conversion Rate in exchange for a specified Fiat currency in accordance with these Terms, you must have had transferred the Fiat funds required for the transaction, as shown to you in the Apps or Website, to our account in accordance with clause 2.1.
4.2. In order to buy a supported cryptocurrency in exchange for another supported cryptocurrency in accordance with these Terms you must have had transferred to us the equivalent amount of supported cryptocurrency, which is to be used in exchange for the requested supported cryptocurrency and will be automatically debited from your Wallet.
4.3. In order to buy a supported cryptocurrency with the Conversion Rate in exchange for a specified Fiat currency or supported cryptocurrency, but not having transferred the required amount of the specified Fiat currency or supported cryptocurrency to us, the required specified Fiat currency or supported cryptocurrency must be held at your account or Wallet during the time of buying the supported cryptocurrency as a result of using the Conversion Service.
4.4. In case you have requested to buy a supported cryptocurrency, the amount of supported cryptocurrency bought by you will be transferred to your Wallet after the completion of the relevant transaction.
5.1. In order to sell a supported cryptocurrency with the Conversion Rate in exchange for a specified Fiat currency in accordance with these Terms, you must have had transferred to us the equivalent amount of supported cryptocurrency, which is to be used in exchange for the requested Fiat currency and will be automatically debited from your Wallet.
5.2. In case you have requested to sell a supported cryptocurrency in exchange for a specified Fiat currency, the amount of specified Fiat currency will be transferred to your Account after the completion of the relevant transaction specified in your instruction.
6.1. When buying or selling Investment Gold you have acknowledged and agreed with the third-party and cryptocurrency-related risks, and agreed with the relevant PAX Gold Terms and Conditions and any other relevant terms and conditions of Paxos. We shall not assume any liability for any unavailability of redeeming Investment Gold or the existence or termination of PAXG due to reasons not dependent on us, e.g. dependent on the specifics of the Ethereum blockchain or the issuer of PAXG, including but not limited to the sustainability, insolvency, liquidation or bankruptcy of Paxos or any of the service providers or persons connected to the Investment Gold in general.
6.2. After every resettlement cycle we ensure that the total amount of Investment Gold we hold on behalf of you with our partners, e.g. Payward Inc., matches with the total amount of Investment Gold held on your Account.
6.3. In order to redeem your Investment Gold into a specific gold bar, held in an London Bullion Market Association-approved security carrier vault, you must pay us exactly 430 PAXG tokens, as well as the Creation & Destruction Fee, and submit a redemption order through the Apps or via email. Please be advised that you are not able to redeem your Investment Gold into Unallocated Gold. If successful, you will receive a confirmation letter through the Apps or via email, confirming the date and time as of which you must collect and accept the delivery of your gold bar in person from our registered address within 2 weeks. For the delivery of the gold bar you are required to verify your identity by providing your valid passport.
6.4. You may demand for delivery of a substitute thing from us within 2 years as of the date of the delivery, if the gold bar delivered to you does not conform to the contract, e.g. the gold bar does not have the agreed characteristics, does not possess the quality usual for investment gold or is anyway damaged, provided the gold bar has not been removed from its original package and the damage did not occur after the delivery.
7.1. We carry out the transactions described in these Terms on the basis of irrevocable instructions from you, which can be submitted through the Apps or Website.
7.2. You are not allowed to cancel, reverse, or change any transaction marked as complete after the submission of an instruction in accordance with these Terms. We may unilaterally decline to carry out the transaction by notifying you thereof on the Website and/or in the Apps, and return you the relevant instruments, and shall assume no liability for any damages which arise to you as a result thereof. You may only cancel a pending instruction, if you have submitted it by using the services of Limit Order or Stop Order, provided the Rate Reference you set has not been reached and the transaction has not yet marked as complete.
7.3. You are displayed all supported cryptocurrencies with the estimated Conversion Rate prior to submitting the instructions in accordance with these Terms and/or exact Conversion Rate for transaction(s) marked as complete. By submitting the instructions in accordance with these Terms you irrevocably confirm to carry out the transaction without certainty of the Conversion Rate.
7.4. After receiving the instructions in accordance with these Terms, we will complete the requested transaction within 5 business days after receiving the payment (whereas a business day is considered to be a day when banks are open for business in Estonia), unless we decline to carry out the transaction in accordance with clause 6.2. We reserve the right to delay any transaction without notifying you thereof, should we perceive a risk of fraud or illegal activity.
7.5. Considering that the prices of cryptocurrencies and Investment Gold are dependent on fluctuations in the financial market, which we have no control over and which may occur within the withdrawal period, in accordance with Law of Obligations Act § 53(4)(1’) you are not entitled to use the right of withdrawal, including in the case of a distance contract.
8.1. You are strictly prohibited from attempting to reverse engineer our trading platform or any of the services provided or circumvent any security measures implemented.
8.2 You are not allowed to employ any software, artificial intelligence, ultra-high speed trading strategies, or mass data entry techniques that could manipulate, exploit, abuse, or provide an unfair advantage when using our systems or services.
8.3 It is not permissible to engage in trades that manipulate our systems or services, this includes manipulation of service fees and hedging.
8.4 It is strictly forbidden to act in an unfair, abusive, manipulative, or illegal manner when utilizing our services. This includes engaging in scalping or any other form of unethical trading practices.
8.5 Engaging in trades or other services with the intention of exploiting price errors is not permitted.
8.6 Engaging in trades or other services with the intention of exploiting system bugs or errors is not permitted. If such circumstance is detected in the course of trading or the use of other services, you are obliged to notify immediately about the issue email@example.com.
8.7 Your orders must comply with the rules and regulations of the exchange. Your orders must not be intended to defraud or manipulate the market.
8.8 If you generate profits by violating any of the above rules or your activity results in damage for xChange AS, we reserve the right to withhold assets on your account and we may deduct the amount from your account balances unilaterally, in case of which, we will provide full overview of the circumstances under which the activity takes place. Should assets be withdrawn from your account prior to the detection of any violation, you hereby consent to immediately reimburse all damages resulting from your activities upon receipt of the claim. Additionally, you agree to bear the costs associated with legal fees or similar expenses incurred in pursuing legal action if you fail to comply or refuse to cooperate in resolving the aforementioned claim.
8.9 Any breaches of the aforementioned rules will be documented. We may cancel your orders, freeze, block, and/or terminate our services, your account, and/or our agreement with you in response to such breaches. While we may provide notice in accordance with applicable laws, it is not mandatory for us to do so.
9.1 Should you breach any obligations described in these Terms, we have the right to refuse to carry out the requested transactions by notifying you thereof on the Website and/or in the Apps, and we shall assume no liability for any damages which arise to you as a result thereof.
9.2 We cannot guarantee and are not liable for the availability of the Conversion Service or the buying or selling of Investment Gold, and the act of buying supported cryptocurrency is not and may not be considered a guarantee from us that you could sell the cryptocurrencies or Fiat currencies obtained using the Conversion Service back to us nor with the set Rate Reference, while using the services of Limit Order or Stop Order.
In force from 2023-07-31
These Terms & Conditions apply to your Getchange account and Visa debit card. Please read them carefully. You can download a copy of these Terms & Conditions at any time from our website https://www.changeinvest.com/legal#account-and-debit-card/.
The Getchange account and Visa debit card are e-money services provided by UAB Finansinės paslaugos “Contis”. xChange AS may transfer funds from a wallet you hold directly with them to cover the value of transactions you make using your Visa card.
In these Terms & Conditions:
In these Terms & Conditions, “money” refers to e-money. When you receive a payment or add funds to your Getchange account or card, we deposit your funds in a safeguarding account, and add the equivalent value of e-money to your Getchange card account. Funds in the safeguarding account are not used or lent to any other person by us. If you make a payment or transfer e-money to a non- Getchange account, we remove the e-money from your Getchange account or card and transfer the equivalent value of funds from the safeguarding account to the recipient.
If you have any questions you can contact us by:
Your Getchange account and Visa debit card is issued by UAB Finansinės paslaugos “Contis”, company code 304406236, registered in the Register of Legal Entities of the Republic of Lithuania, having a head office at Gedimino pr. 20, LT-01103 Vilnius, Lithuania, telephone no. +370 800 50 500. You may find more information about the Bank of Lithuania at https://www.lb.lt/en.
1.1. A Getchange card is a Visa debit card that can be used worldwide wherever Visa is accepted. It can be used online, in shops, over the phone or to withdraw cash from an ATM.
1.2. You can only spend funds, including cryptocurrencies, that you hold on your Account, so before using your card you need to make sure there are enough funds on your Account.
1.3. Monies in the Getchange account are not bank deposits and do not earn interest.
2. Who can apply for a Getchange account and card?
2.1. You must be at least 18 years old and a UK or EEA resident to be issued with a Getchange account and card. You must provide an email address and mobile phone number to open an account so that we can communicate with you.
3.1. You can apply on our website https://www.changeinvest.com or you can apply through the Apps.
3.2. Before we can open an account for you and issue you with a card, we will require evidence of your identity and we may require evidence of your residential address. You may need to provide us with documents such as passport, driving licence, national identity documents, utility bills, bank statements or other documents to confirm your identity. We will also need to carry out checks on you electronically.
4.1. By logging into your Getchange account, you are agreeing to these Terms & Conditions.
4.2. As soon as you receive your card you must sign the signature strip on the back.
4.3. You will then need to activate your card. You can do this by following the activation steps provided on the card carrier.
4.4 You also need to obtain your PIN to authorise chip-and-pin transactions and ATM withdrawals. You can get your PIN through the Apps.
4.5. Your account and card must be used within 3 months of it being issued or it may be automatically cancelled, and your account may be closed.
5.1 If you want to change your PIN, you can do so at any ATM with PIN management functionality, locate ATMs with the “PIN change” attribute at https://www.visa.com/locator/atm.
5.2. You can get a reminder of your PIN through the Apps.
6.1. You may pay into your account via the Apps. The time taken to credit funds to your account will depend on the method of deposit used. You should not pay into your account by a balance transfer from a credit card.
6.2. Certain minimum and maximum limits and usage requirements apply to your account and card; such limits and requirements are detailed in the chapter Fees and Limits. We may also apply additional incoming transfers limits for the purpose of preventing financial crime. We reserve the right to refuse to accept any particular payment if we suspect any fraudulent activity or in the event of other exceptional circumstances, e.g. the payment does not originate from an account opened in your name.
6.3. As soon as we receive the funds that you have paid in, they will be on your Account and ready to use. There may be occasions when we delay the funds reaching your Account for up to three working days, this may happen when we need to confirm the transaction with the sending institution.
6.4. Where an overpayment has been made to your Account in error, we reserve the right to debit the Account with the excess amount to correct the payment transaction.
6. Any funds, including cryptocurrencies, on your Account can be used with the Getchange card. Please see other terms and conditions, specifically chapters General and Wallet and Fiat Account and Conversion to understand all the available methods of adding funds to your Account.
7.1 You can use your Getchange card to authorise the following transactions to merchants that accept Visa Debit card payments:
7.1.1. Chip and PIN card payments by inserting your Getchange card in the terminal and inputting your PIN;
7.1.2. Magnetic stripe card payments to any merchant that cannot accept Chip and PIN cards by signing the sales voucher;
7.1.3. Contactless card payments by waving the Getchange card over the contactless card reader;
7.1.4. Internet card payments to online merchants by providing the Getchange card details and any other security details such as your secure code credentials as requested by the online merchant;
7.1.5. Mail order or telephone order card payments to merchants by providing the Getchange card details as requested by the merchant;
7.1.6. ATM cash withdrawals at ATMs displaying the Visa logo by inserting your Getchange card at the ATM, inputting your PIN and following the instructions at the ATM;
7.1.7. E-wallet payments by adding your card to the Samsung Pay, Google Pay or Apple Pay (when available) wallets in your mobile phone and waving your mobile phone over the contactless card reader or checking the e-wallet option online. You authorise the e-wallet transaction using your mobile phone security protocol which may include biometric information such as fingerprint or face ID on your mobile phone.
7.2 Like other payment cards, we cannot guarantee a third party or ATM will accept your card.
7.3. You may, in addition, be required to enter a one-time passcode or other security information including, if available and you opt for this type of identification, biometric information to authorise a transaction or make account amendments. One-time passcodes will be sent to the mobile phone number registered to your account.
7.4. As soon as a transaction is authorised, we will deduct the value of your transaction from the available balance on your account. You have an agreement with Getchange to transfer funds from the Account you hold directly with them to cover the value of the transaction. If Getchange is unable to transfer the funds for the transaction to your Account, Solaris will be unable to authorise the transaction. Fees are listed in the chapter Fees and Limits and may be deducted at the time of authorisation or when the transaction has been confirmed through the Visa system. A full breakdown of each transaction, including charges, will be available to view on your online account portal. Whenever a transaction is credited via the Visa system, e.g. a refund for a transaction, you agree for Getchange to automatically transfer those funds to the Account you directly hold with them.
7.5 Once we have received a settlement request for a transaction, we will transfer funds to the retailer within 3 days. A transaction will be received for card transactions at the time we receive the transaction instruction from the retailer or ATM operator.
8.1. Generally, authorisation for a transaction may not be withdrawn by you. You may be able to withdraw your authorisation where you have authorised a transaction which will take place on a future date. However, where a specific date is agreed, you may not revoke a payment order after the end of the Business Day preceding the agreed date on which the transaction will occur.
8.2. To withdraw your authorisation of a Visa debit card continuous payment authority, you must notify the retailer before the close of business on the Business Day before the day on which the transaction was due to take place and provide us with a copy of the notice if requested.
8.3. We may charge you an Administration Fee if a transaction is revoked by you under this paragraph, see the chapter Fees and Limits.
9.1. Your card is denominated in euro. If you make a purchase or an ATM withdrawal in any other currency, we will convert the sum into euros using the exchange rate set by Visa on the day they process the transaction, this may differ from the actual date of the transaction.
9.2. If you use your euro denominated card in a European country, which does not use euros, you will receive a notification showing the exchange rate used and the euro amount, along with the difference between the rate applied by the card scheme and the European Central Bank (ECB) rate.
9.3. An international purchases fee will apply to each of these transactions, see the chapter Fees and Limits.
9.4. Any changes to the exchange rate used to convert foreign transactions will be made immediately. You can find the exchange rate for a transaction made in a currency other than euro on a given date and how that compares to the European Central Bank rates at https://www.visaeurope.com/making-payments/exchange-rates.
10.1. You may not use your card for illegal purposes. It also cannot be used for a limited number of specified transactions. Please see our website for details.
11.1. You can check your account by accessing it securely through the App, your statement will show:
11.1.1 information on the payee of each transaction and a reference enabling you to identify each payment transaction;
11.1.2 the amount of the transaction shown in the currency in which the transaction was paid or debited to the account;
11.1.3 the amount of fees for the transaction;
11.1.4 the exchange rate used in the payment transaction (where applicable);
11.1.5 the difference between the exchange rate applied and the European Central Bank rates if used within a European country that does not use euros; and
11.1.5 the date the transaction is authorised or posted on to the account.
11.2. This information is available at all times via the App free of charge, and can be stored and reproduced as necessary. Paper statements are available on request and are subject to a fee,see the chapter Fees and Limits.
11.3. You may, in addition, be required to enter a one-time passcode or other security information including, if available and you opt for this type of identification, biometric information to access your account. One time passcodes will be sent to the mobile phone number registered to your account.
12.1. Your card will be valid for 3 years. You will not be able to use your card after its expiry date. This agreement shall terminate when your card is cancelled or expires and is not replaced.
13.1. You can only spend the money that is paid into your account. Limits also apply to daily ATM withdrawals, and other limits may be applied to the amount of spend and the number of transactions you can perform for the purpose of preventing financial crime. We reserve the right to refuse transactions if we suspect any fraudulent or financial crime activity. You may contact Customer Services to enquire about other products, should the limits on your account not be suitable. See the chapter Fees and Limits and the App for further details.
13.2. If, for any reason, the transaction is completed when there are insufficient funds in your account then you will have to reimburse the shortfall to us, unless it is due to an error by the retailer with whom you made the transaction.
13.3. We may collect this shortfall from any card you have with Solaris or Getchange or from any funds which you subsequently pay into your account(s). We may suspend your cards until the negative balance is restored and charge you an Administration Fee for transactions that you make using your card that results in a negative balance or increase the negative balance on your account. See the chapter Fees and Limits and the App for further details.
14.1. If you dispute a transaction that has been processed on your card, you should contact the merchant first as this may lead to the quickest resolution. If the dispute cannot be resolved with the merchant or you dispute any other account transaction you should contact us without undue delay and in any event within 13 months on becoming aware of any unauthorised or incorrectly executed payment transaction.
14.2. Where you have informed us that an executed payment was not authorised by you in accordance with these Terms and Conditions, and you have taken all reasonable steps to keep safe personalised security information, including your account and card details, not disclosed your PIN or security information to anyone else and not acted fraudulently, with intent to disclose security credentials or with gross negligence, we will:
14.2.1. refund the amount of the unauthorised payment to you; and
14.2.2. restore the debited payment account to the state it would have been in had the unauthorised payment not taken place.
14.3. The refunded amount or restored balance will be completed as soon as practicable and, in any event, no later than the end of the Business Day following the day on which it becomes aware of the unauthorised transaction.
14.4. Beyond this, we will have no further liability to you in respect of such authorised transactions.
14.4. You may be entitled to claim a refund in relation to transactions where:
14.4.1. the transaction was not authorised under these Terms and Conditions;
14.4.2. we are responsible for a transaction which we fail to execute or incorrectly execute. In these circumstances, we will refund to you the amount of the non-executed or defective payment transaction and restore the debited payment account to the state in which it would have been had the defective payment transaction not taken place. We will also refund to you: (a) any direct charges for which you are responsible; and (b) any interest which you must pay, as a consequence of the non-execution or defective execution of the payment transaction; or
14.4.3. a pre-authorised transaction did not specify the exact amount at the time of its authorisation and the amount charged is more than could reasonably be expected, taking into account previous spending patterns on the card and the circumstances of the transaction. We will either refund the full amount of the payment transaction; or provide justification for refusing to refund the payment transaction. Any refund or justification for refusing a refund will be provided within 10 Business Days of receiving a request for a refund or, where applicable, within 10 Business Days of receiving any further information requested. A claim for a refund in these circumstances will not be accepted if the amount of the transaction was made available to you at least 4 weeks before the transaction date or if the claim is made more than 8 weeks after being charged to your account.
15.1 You must keep your card and security credentials safe and not let anyone else know or use them. You must keep your security information secret at all times; never disclose your PIN or security information to anyone and do not store details of your PIN with your card. Security information includes your login and password details used to access your account or any other website where your card or account details are stored. We also recommend that you check the balance on your account regularly through the App or by contacting Customer Services.
16.1. If you lose your card or it is stolen, or you suspect that someone else has found out your PIN or security information or accessed your account without your permission, you must tell us without undue delay by calling us or logging onto your account through the App or website and notifying us. Your card will be cancelled immediately and your account may be blocked. We run a dedicated line for lost or stolen cards; the number is +44 (0) 333 202 3645 and calls are charged at the standard geographical rate. If, after reporting a lost card, you subsequently find the card you must not use it. Cut it in half through the signature box, magnetic strip and chip.
16.2. If you ask Customer Services to do so, and provided that you provide information and assistance that we request from you, we will investigate any disputed transaction or misuse of your card or account.
16.3. If the investigations show that any disputed transaction was authorised by you, or you have acted fraudulently or with gross negligence (for example by failing to keep your card, security information or PIN secure or by failing to notify us without delay on becoming aware of the loss, theft, misappropriation or unauthorised use of the card or account), then we will not refund the transaction amount and you will be fully liable for all losses incurred because of the unauthorised use of the card or account.
16.4. If the investigations show that you have not acted fraudulently or with gross negligence, your maximum loss or liability to us for any unauthorised transaction will be limited to 50 euros and we will process a refund as soon as practicable, and in any event no later than the end of the Business Day following the day after Customer Services receive your notification.
17.1. We may refuse to pay a transaction:
17.1.1. if we are concerned about security of your card or account or we suspect your card or account is being used in an unauthorised or fraudulent manner;
17.1.2. if sufficient funds are not paid into your account at the time of a transaction to cover the amount of the transaction and any applicable fees;
17.1.3. if there is negative balance on your account;
17.1.4. if we have reasonable grounds to believe that you are not using the card or account in accordance with these Terms & Conditions;
17.1.5. if we believe that a transaction is potentially suspicious or illegal (for example, if we believe that a transaction is being made fraudulently); or
17.1.6. because of errors, failures (whether mechanical or otherwise) or refusal to process a transaction by merchants, payment processors or payment schemes such as Visa.
17.2. If we refuse a transaction, we will tell you why immediately by contacting you through the email you have provided or via the App, if we can, unless it would be unlawful for us to do so. You may correct any information Solaris holds and which may have caused the refusal of a transaction by contacting Customer Services.
18.1. You have a legal right to cancel your account and card up to 14 days from the date your account is opened without incurring any penalty and we will refund any card issue fees. We may charge you a Card Cancellation Fee if we have already incurred costs by ordering a card in your name. You can also cancel your card any time after the 14-day period subject to a Redemption Fee by contacting Customer Services, see the chapter Fees and Limits. You should cut your cancelled card in half through the signature box, magnetic strip and chip.
18.2. All fees and charges will be apportioned up until the time of the termination of the contract, and any fees and charges paid in advance will be reimbursed proportionally. You will not be entitled to a refund of money you have already spent on transactions authorised, or pending or any fees for use of the card or account before the card or account is cancelled or expires.
19.1. Solaris may cancel your account and this agreement by giving you at least 60 days’ notice. You should ensure any remaining funds on your Getchange Account or Card are spent or withdrawn within this notice period.
19.2. Reasons for cancellation may include:
19.2.1. if this agreement expires;
19.2.2. if your card expires and is not replaced;
19.2.3. if you break an important part of this agreement, or repeatedly break the agreement and fail to resolve the matter in a timely manner;
19.2.4. if you act in a manner that is threatening or abusive to our staff, or any of our representatives;
19.2.5. if we suspect unauthorised or fraudulent use of your card or account;
19.2.6. if we have any other security concerns;
19.2.7. if you fail to pay fees or charges that you have incurred or fail to pay back any negative balance on your card; or
19.2.8. your card has not been used for 3 consecutive months.
19.3. Solaris may also deny access to your card and/or account where we consider it to be at risk of money laundering or terrorism financing, fraud or other criminal activity. Should we need to take these actions and where possible, we will give reasons for doing so except where restricted by law.
19.5. In these circumstances where funds may be returned, you must tell us what you want us to do with any unused funds, see section 20 below for further details.
20.1. You can clear the balance on your account through spending or ATM withdrawals. The fees that would apply are described in the chapter Fees and Limits.
20.2. Alternatively, you may request a refund of the funds on your account by contacting Customer Services and confirming that your card has been destroyed by cutting it up. We will transfer your funds back to you at no cost to you, unless:
20.2.1. you are requesting redemption before termination or expiry of this agreement;
20.2.2. you cancel this agreement before any agreed termination or expiry date; or
20.2.3. you request redemption more than one year after the date of termination or expiry of this agreement.
20.3. If one of these situations listed in clause 20.2 does apply, then we will charge a Redemption Fee, see the chapter Fees and Limits.
20.4. We will not redeem the value of the funds on your account to you if your request for redemption of the funds is more than six years after the date of termination or expiry of this agreement.
20.5. All funds will be returned to a bank account of your choice in euros. We reserve the right to see proof of your ownership of the bank account before transferring funds to it. To enable us to comply with our legal obligations, we may ask you to provide us with certain information such as identification documents before we can process your refund request.
20.6. Please also refer to section 27 below for the circumstances in which we do not give you a refund.
21.1. The account and associated card are electronic money products and although it is a product regulated by the Bank of Lithuania, it is not covered by the Deposit Insurance System of the Republic of Lithuania. No other compensation scheme exists to cover losses claimed in connection with the account and associated card. Solaris will however ensure that any funds received by you are held in a segregated account so that should Solaris become insolvent your funds will be protected against claims made by its creditors.
22.1. If you are unhappy in any way with your card and account or the way it is managed, you can contact Customer Services so we can investigate the circumstances for you. Any complaints you have will be dealt with quickly and fairly.
22.2. Customer Services will address all points of the complaint in writing by post or a downloadable letter attached to an email. A response will be provided within 15 Business Days upon receiving the complaint. If a full response cannot be provided within these timeframes, due to exceptional circumstances, a holding reply will be sent which shall detail the reason for the delay, with a full response within 35 Business Days.
22.3. If we are unable to resolve your complaint to your satisfaction you may apply to the consumers disputes resolutions institution the Bank of Lithuania at https://www.lb.lt/en/dbc-settle-a-dispute-with-a-financial-service-provider by filing out a free-form application and sending it to the Supervision Service, Žirmūnų g. 151, LT-09128 Vilnius or by emailing to firstname.lastname@example.org.
23.1. You must let Customer Services know as soon as possible if you change name, address, telephone number, mobile number or e-mail address. If we contact you in relation to your account we will use the most recent contact details you have provided to us. Any email or SMS text message sent to you will be treated as being received as soon as it is sent by us. We will not be liable to you if your contact details have changed and you have not told us.
25.1. We may change these Terms & Conditions by notifying you by e-mail or other agreed means at least 60 days before the change is due to happen. Where the change is not detrimental to you it will take effect immediately. We will assume that you agree with the change. If you do not agree with the change you must tell Customer Services before the change happens and we will cancel your account immediately. If you cancel your account in this way, then we will return any balance on the account to you and you will not be charged a Redemption Fee.
25.2. An up-to-date version of these Terms & Conditions, as well as any notices of future changes will always be available via the website at https://www.changeinvest.com. You should check the website and the App regularly for such notices and changes.
26.1. From time to time, your ability to use your card or account may be interrupted, e.g. when we carry out system maintenance. If this happens, you may be unable to make a payment transaction or access your Getchange account, services and information.
26.2. In addition, like other payment cards, we cannot guarantee a merchant will accept your card, or that we will necessarily authorise any particular transaction. This may be because of a systems problem, something outside our reasonable control, to comply with legal and regulatory requirements, or because we have suspended, restricted or cancelled your account or refused to replace it in accordance with these Terms & Conditions.
27.1. If Solaris incorrectly deduct funds from your account, we will refund them. If we subsequently establish that the refunded amount had in fact been correctly deducted, we may deduct it from your available balance and may charge you a fee. If you do not have sufficient available balance, you must repay us the amount immediately on demand.
27.2. If unauthorised transactions occur after you have notified Customer Services of the loss, theft, compromise or unauthorised use of your card or account, and you have not acted fraudulently or in breach of these Terms and Conditions, then we will be liable.
27.3. Solaris will not be liable:
27.3.1. in any event that a merchant refuses to accept your card;
27.3.2. for any interruption, disruption or impairment of our service or any third party services on which we rely for the performance of our obligations hereunder;
27.3.3. for refusing to authorise a transaction;
27.3.4. for cancelling or suspending use of your card or account;
27.3.5. for any loss arising from your inability to use your card or access your account due to interruptions;
27.3.6. or any direct or indirect loss or damage you may suffer including loss of revenue, loss of reputation, goodwill, opportunity or anticipated savings as a result of your total or partial use or inability to use your card, the App, website or account or the use of your card or account by any third party (unless otherwise required by law);
27.3.7. for the quality, safety, legality or any other aspect of any goods or services purchased with your card; and
27.3.8. any abnormal and unforeseeable circumstances beyond our control, however so caused.
27.4. We are not responsible for lost, late or undelivered text messages, notifications, or communications. We accept no responsibility for any technical, computer, online, telephone, cable, electronic, software, hardware, transmission, connection, internet, website or other access issue which may hinder your ability to access the services.
27.5. Nothing in these Terms and Conditions shall operate to exclude liability for death or personal injury due to negligence or for fraud or fraudulent misrepresentation or for any statutory liability that cannot be excluded or amended by agreement between the parties.
28.1. We may charge you for any reasonable costs that we incur in taking action to stop you using your card or account and to recover any monies owed as a result of your activities if you:
28.1.1. use your card or account fraudulently;
28.1.2. do not use your card or account in accordance with these Terms & Conditions; or
28.1.3. have been grossly negligent, for example by failing to keep your card or PIN secure or by failing to notify us without delay after your card is lost, stolen, or used by someone else or where your account has been compromised.
28.2. In these circumstances we will not refund transactions and we reserve the right to charge you for any reasonable costs that we incur in taking action to stop you from using your account and to recover any monies owed as a result of your activities.
28.3. If you have not been fraudulent, or grossly negligent, and have used your card and account in accordance with these Terms & Conditions, your maximum liability for any unauthorised transaction resulting from the use of a lost or stolen card or details before you notify us will be 50 euros.
28.4. At our discretion, you will be charged an Administration Fee if we have to manually intervene to complete a payment or rectify an error on the account caused by an error or omission on your part.
29.1. You may not transfer or assign any rights or obligations you may have under these Terms & Conditions to any other person without our prior written consent. We may assign the benefit and burden of these Terms & Conditions to any other person at any time on giving you 60 days’ prior notice of this. If we do this, your rights will not be affected.
30.1. These terms and conditions and all communications will be available and provided for in English, unless for informational purposes we have published these Terms & Conditions in other languages. Should there be any discrepancies or deviations between the languages, the English version shall prevail.
30.2. You have the right to request the Lithuanian version of these terms and conditions at any time and we shall make them available to you on request.
30.3. These Terms & Conditions will be construed in accordance with laws of the Republic of Lithuania and subject to the exclusive jurisdiction of the courts of the Republic of Lithuania.
31.1. All the information is available in the chapter Fees and Limits and can be downloaded or printed from there.
In force from 2023-06-22
This chapter sets the terms and conditions for using Growth Pocket, and Staking - cryptocurrency services, which allow you to earn rewards on the supported cryptocurrencies held on your Account. By using the Conversion Service and buying the supported cryptocurrencies as described below, you have agreed to the use of and the terms and conditions of the services. Please be advised that the Staking service described in this chapter is not addressed to and may not be used by Users, who are located in or nationals or residents of specific territories, where such a service is not allowed, including any Restricted Jurisdiction.
1.1 While using Growth Pocket you have to use the Conversion Service, whereby you buy the supported cryptocurrencies, which are shown to you in the Apps, i.e. stablecoins, e.g. USDC, from us, in exchange for specified Fiat currencies, and vice versa. You are entitled to at all times buy specified Fiat currencies from us, in exchange for the supported cryptocurrencies, however interest is exclusively and at all times calculated on the current outstanding balance of the supported cryptocurrencies.
1.2 After having bought the supported cryptocurrencies, with Growth Pocket your cryptocurrencies may be deposited on your behalf to Crypto Interest Accounts operated by third-party custodians, e.g. Payward, Inc.
1.3 Interest is calculated on an hourly basis on the current outstanding balance of the supported cryptocurrencies held on your Account, and rewarded by the first day of the following calendar month at 12:00 EET in the same supported cryptocurrency, and consecutively converted into specified Fiat currency.
1.4 All fees, including network fees for the aforementioned transfers, have already been deducted from the interest offered.
1.5 Growth Pocket is a product provided by xChange AS under virtual currency service provider license no FVT000072 issued by Estonian FIU.
2.1. While using Staking you have to use the Conversion Service, whereby you buy the supported cryptocurrencies, which are shown to you in the Apps, from us, in exchange for specified Fiat currencies or other supported cryptocurrencies, and vice versa. You are entitled to at all times buy specified Fiat currencies or other supported cryptocurrencies from us, in exchange for the supported cryptocurrencies, however in these instances you may not be eligible for the reward.
2.2. After having bought the supported cryptocurrencies, with Staking all your supported cryptocurrencies may be deposited on your behalf to our Kraken Account, including for the use of services such as On-Chain Staking Services and/or Off-chain Staking Program, operated by third-party custodian, i.e. Payward Trading Ltd and/or BitGo, Inc. and/or our Ledger Vault, whereby access is provided to third-party service "non-custodial validation-as-a-service" providers that facilitate the management of staking processes without taking custody of the cryptocurrencies.
2.3 Interest for the specific calendar day (T) is calculated on a daily basis on the outstanding balance of the supported cryptocurrencies held on your Account at the beginning of the next calendar day (00:00 UTC; T+1), and rewarded shortly after but not later than the end of the day in the same supported cryptocurrency. The expected as well as the exact size and rate of the Staking reward at a specific time is shown to you in the Apps, which in turn is also subject to Staking in accordance with these terms and conditions. For absolute clarity, you are not entitled for a reward for the supported cryptocurrencies or any parts of it at a specific day (T), which were not held on your Account at the moment of the calculation (T+1), including whenever you have submitted a Stop Order or a Limit Order with the supported cryptocurrency.
2.4 For protocols with activation and deactivation periods, we reserve the right to pass rewards on to Users accounts at our discretion. This means for certain cryptocurrencies, the first reward is not distributed the next day, instead being subject to the activation period specified in the App after which regular reward distribution as stated in p.2.3 will start. This also means that for days prior to the activation period no rewards are earned by the user.
2.5 All fees, including network fees for the aforementioned transfers, have already been deducted from the interest offered.
3.1 Since Growth Pocket and/or Staking are in their entirety cryptocurrency services, your supported cryptocurrencies are not subject to statutory or voluntary deposit guarantee schemes or deposit insurance.
3.2 By using Growth Pocket and/or Staking you acknowledge that various types of risks are involved, including but not limited to risks relating to the changes in the operating rules or other features, e.g. the existence, availability, sustainability of or forks in the specific protocol or blockchain, or the fluctuation of the value or the existence of any supported cryptocurrencies, including where relevant the fiat currency it is pegged to, counterparty risks, including but not limited to the sustainability, insolvency, liquidation and bankruptcy of one of our partners and their partners, regulatory risks and uncertainties. Should any of the risks realise, you hereby understand and consent that you are solely liable for the consequences, and we shall not assume any liability nor obligations thereof.
3.3 By using Growth Pocket and/or Staking you understand and agree that rewarding you with the interest is in our sole discretion, not an obligation, and it is not a guarantee that you will receive the reward as a whole or any parts of it, or by the due date. We have reserved the right to from time to time change the interest rate, which is shown to you in the Apps, and these terms, and temporarily or permanently terminate or discontinue providing the services of Growth Pocket and/or Staking at any time, without giving you a prior notice thereof. If that is the case in terms of Growth Pocket, we will buy back the supported cryptocurrencies from you, in exchange for specified Fiat currencies, and the interest calculation shall be terminated as of that moment, and the interest shall be rewarded by the first day of the following month. If that is the case in terms of Staking, you are no longer eligible for any rewards, i.e. interest calculation shall be terminated as of that calendar day, and we are not obliged to give you any Staking rewards for the calendar day the service was terminated or discontinued.
3.4 Please be advised that Staking, especially the Off-chain Staking Program, is not addressed to and may not be used by Users, who are not treated as Eligible participants, including are located in or nationals or residents of: (i) any Restricted Location; (ii) Australia, Canada, Denmark, Finland, France, Germany, Hong Kong, Italy, Japan, Luxembourg, The Netherlands, Singapore, Sweden, the United Arab Emirates, the United Kingdom or the United States; (iii) any jurisdiction where the Off-chain Staking Program is not legally authorized; or (iv) any jurisdiction where the use of the Off-chain Staking Program would be illegal or otherwise violate any applicable laws or regulations of that jurisdiction.
3.5 In addition to agreeing to these terms, when using Growth Pocket and/or Staking you also consent and agree to abide by the terms of our partners. Please also pay extra attention to the risk disclosure sections. Relevant documents are available at https://www.bitgo.com/legal/terms-of-use/, and https://www.kraken.com/legal.
4.1. Change has performed and is constantly re-performing relevant due diligence on its partners and the financial, reputational and regulatory risks surrounding them. If it becomes known or Change deems the counterparty risk, including any security risk to your supported cryptocurrencies, to be unacceptable, we will immediately terminate the partnership and/or the service, and inform you thereof in the Apps.
4.2 In terms of Growth Pocket, your cryptocurrencies deposited on Crypto Interest Accounts may be transferred by the service provider into a cold storage system as a part of providing the service of Growth Pocket, the offline storage can only be accessed in a secure, access-controlled facility that is protected from cyber attacks.
4.3 In terms of Staking, despite cryptocurrency exchanges not qualifying for deposit insurance programs, because exchanges are not savings institutions, your cryptocurrencies deposited on Kraken Account are subject to a semi-annual advanced cryptographic accounting procedure conducted by trusted and independent third-party auditors, so-called Proof of Reserves audits, to ensure that the balance of the supported cryptocurrencies is backed by real assets.
In force from 2023-02-22
These Terms & Conditions apply to CFD Trading service and your Margin Account. Please read them carefully. You can access and download a copy of these Terms & Conditions at any time from www.changeinvest.com.
These are specific terms that will apply to you when you trade CFDs directly with Change Securities B.V. using Change Apps. The following terms apply to you in addition but not limited to the chapter General and Wallet, which apply to all of our services and not just to CFD Trading. Capitalised words have the same meaning which are given to those words in the General and Wallet chapter or in any other chapter in this regard. In the event of any discrepancies between the terms of CFD Trading and General and Wallet or other terms of Change, these terms of CFD Trading chapter shall prevail.
Citizens or residents of and persons located in Afghanistan, Algeria, American Samoa, Barbados, Belarus, Burkina Faso, Cambodia, Cayman Islands, China, Congo, Democratic Republic of the, Côte d’Ivoire, Cuba, Egypt, Guam, Haiti, Hong Kong, Islamic Republic of Iran, Iraq, Jamaica, Jordan, Democratic People’s Republic of Korea, Lebanon, Libya, Macao, Mali, Morocco, Mozambique, Myanmar, Nicaragua, Niger, Nigeria, Northern Mariana Islands, Pakistan, Palestine, Panama, Philippines, Puerto Rico, Russian Federation, Saudi Arabia, Senegal, Somalia, South Sudan, Sudan, Syrian Arab Republic, Trinidad and Tobago, Tunisia, Uganda, United Arab Emirates, United States Minor Outlying Islands, United States of America, Uzbekistan, Vanuatu, Virgin Islands (U.S.), Western Sahara, Yemen, Zimbabwe are prohibited from using the service of CFD Trading. The country list above shall not be treated as exhaustive, and we reserve the right to at all times at its own discretion decline to provide the services above to any person, who is a citizen or a resident of or located in a country, which we unilaterally deem as having an unacceptable risk, and amend the list without giving a prior notification thereof.
Any marketing or informational content published about the CFD Trading service, or distribution thereof, is not addressed to the Belgian public.
In these Terms & Conditions:
If you have any questions you can contact us by:
All of the terms and definitions not stipulated in these Terms & Conditions are stipulated in the General and Wallet chapter.
1.1. A contract for difference (“CFD”) is a financial product which allows you to trade on the price movements of an underlying product for example shares, forex, indices, commodities, or cryptoassets. When you trade a CFD, you are agreeing to exchange the difference in the price of an underlying product from the point in time when your position is opened to when it is closed.
1.2. We may act as principal or on a matched principal basis when providing you with the CFD Trading services. This means we will be the counterparty to your trades.
1.3. Where you buy and sell complex products, such as CFDs, we are required to assess the appropriateness of the product by taking into account your trading knowledge and experience by conducting the Appropriateness Assessment.
1.4. If we have assessed that the CFD Trading is not appropriate for you, we will either:
1.4.1. provide you with an appropriate warning, after which you may decide to continue at your own risk; or
1.4.2. refrain from enabling the CFD Trading functionality on your Account, so that you will not be able to trade using the Apps.
1.5. We allow you to trade CFDs using Margin Trading. This means you can make money quickly, but you can also lose money quickly. You can find out more about what Margin Trading and leverage are, the risks of trading CFDs, and the risks of leverage in section 3 and 5, the General Risk Disclosure, and on the Website.
1.6. If you are a retail client, we will make sure that your Open CFD Position will get closed when the unrealised net profit of that Open CFD Position falls to less than half of the initial margin.
1.7. If you are a retail client, we will make sure you do not lose more money than what you have deposited on your Margin Account.
2.1. When you trade a CFD, you will have an economic exposure to the underlying product of the CFD, but you will not have legal ownership of any underlying products. For example, if you trade a CFD over shares, you will not have the rights which legal owners have, such as voting rights or rights to dividends. However, we may carry out adjustments if such a Market Event occurs. Please refer to section 13 of these terms for more information on a Market Event.
3.1. CFDs are complex derivative products and come with a high risk of losing money quickly due to leverage. Trading with leverage magnifies your gains and losses, so small price changes in the underlying product can result in large losses or gains. It is therefore possible that you may lose more than your deposit in a specific trade. Please refer to section 5 of these terms for more information on Margin Trading.
3.2. The underlying assets of CFDs are often made up of equities, foreign exchange, commodities, cryptoassets and similar products. The markets of these products can be volatile, which means the prices of the products can change rapidly, and therefore may be unpredictable.
3.3. You should only trade CFDs if all of the following applies:
3.3.1. you have sufficient and relevant knowledge about or experience in, trading in volatile markets;
3.3.2. you have time to manage your Open CFD Positions on an active basis;
3.3.3. you fully understand how CFDs work (including all associated risks and costs), are aware that Margin Trading creates greater risks;
3.3.4. you understand that there are situations where we are allowed to close out your Open CFD Positions without giving you any notice;
3.3.5. you are trading with money you can afford to lose;
3.3.6. you have a high-risk tolerance; and
3.3.7. you want to gain short term financial exposure to a product.
3.4. You should ensure you fully understand the risks involved before using our Services and, if required, take appropriate investment, financial, legal, tax and other necessary professional, independent advice. More information on the risks associated with trading CFDs is set out in our General Risk Disclosure. You should read this document and fully understand the risks before accepting these Terms & Conditions.
4.1. Money that you have transferred to your Margin Account, i.e. the deposit is held by an independent foundation named Stichting Cliëntengelden Optionclub which keeps liquid assets equal to all balances of Margin Accounts. This means it is always guaranteed that all balances of Margin Accounts can be paid out.
4.2. We are covered by the Dutch investor compensation scheme (ICS) operated by the Dutch central bank. If we fail, the scheme guarantees that you will receive back your money deposited on the Margin Account up to € 20,000 or as may be updated from time to time.
4.3. Importantly, the protection is only applicable to regulated products i.e. CFD Trading. This means that any cryptoasset related Service is not protected.
4.4. Claims ensuing from investment losses suffered from CFD Trading are not eligible for compensation.
5.1. We allow you to trade CFDs using leverage. Leverage is a form of borrowing which allows you to deposit only a part of the cost of your transaction upfront. This deposit is called “margin” and is used by us as security against any potential losses you may incur. The more leverage you use, the less margin you need. Money being used as margin cannot be transferred out of your Margin Account.
5.2. Different amounts of leverage, i.e. margin requirements apply to different underlying products. Applicable law sets maximum leverage amounts, but we can decrease the leverage we offer at any time. The amount of leverage which you can access at a particular point in time can be viewed on the Website or in the Apps.
5.3. If you are a retail client, we are required by law to limit the amount of leverage that you can apply to certain transactions and set a minimum margin requirement. Professional clients will not be subject to these restrictions. The nature of these restrictions will depend on where you are a resident, and are likely to vary depending on the underlying product that you are trading. Where transactions were executed with a leverage or margin that is no longer permitted in the country where you live, we may close any or all of your Open CFD Positions without further notice to you and we may also close your Account. You acknowledge that this may result in a profit or a loss to you.
5.4. We will calculate your margin on a position by position basis. The money available as margin on a position, cannot equal less than 50% of the money that you might lose on that Open CFD Position at any time. If you do not have enough margin available, we may require additional margin to secure your trades. The amount of money that you must have available as a margin can be viewed on the Website or in the Apps.
5.5. It is your responsibility to monitor the money in your Margin Account against your potential losses, the margin required, and whether your position is close to your stop level, as we will not notify you when this happens. If you do not have enough money in your Margin Account to meet the margin requirement on a certain position, you should do the following:
5.5.1. close any or all of your Open CFD Positions to stop losing more money;
5.5.2. partially close any or all of your Open CFD Positions; and/or
5.5.3. adjust your stop levels, but please note, that the ability to adjust your stop levels is subject to you having the appropriate amount of money on your Margin Account.
5.6. Unless you carry out one or more of the steps listed in clause 5.5, your Open CFD Position will be closed irrespective of the total amount of money available on your Margin Account or the performance and balance of your other Open CFD Positions.
5.7. We may change our margin requirements i.e. leverage multipliers at any time, at our sole discretion, including in order to comply with the applicable law. One margin demand does not preclude another. Any amount needed to meet the new requirements must be satisfied in the currency we specify. The adjustment should be made immediately unless we specify a future date and/or time by which the adjustment must be made.
6.1. An order is any instruction given or request placed by you with us to purchase or to sell or otherwise deal in financial products, which may include a limit order, stop loss order and/or take profit order or such other order as may be available on the trading platform from time to time. We will then need to accept your order for it to take effect. Please read section 7 which explains when you might be able to change or cancel your order, as well as when we might not accept your order or cancel your order when using CFD Trading service.
6.2. You can place an order by using the Apps. Generally we do not accept orders over the phone, but may do so at our discretion.
6.3. We will execute orders that are received from your Account, and which we reasonably believe are from you, or authorised by you. Please be careful when placing an order. If you place orders by accident or in error, for example if you place multiple orders which are the same, we will assume that you did this on purpose and we will execute them without checking this with you.
6.4. Once we accept your order, we will execute it in accordance with any specific instructions that you give. This is called a trade. For more information on how you can place an order, the instructions that you can give, and how we may execute your order, please read our Best Execution Policy.
6.5. We cannot guarantee that your execution price will match your order price, including where you've placed a limit order, take profit and/or stop loss order. This is because the market may be volatile and/or the price may have moved up or down between the time that you place your order (or the time your limit order, take profit and/or stop loss order has been activated) and the time that we execute your order. This is known as slippage. When this happens, we will execute your order at the next best price and in accordance with our Best Execution Policy.
6.6. If you have placed an order during the condition stipulated in the following sub-clauses then the applicable order you have placed will be executed as soon as is reasonable under the circumstances when trading resumes. We do not guarantee that your order will be executed at the first available underlying market price at commencement of trading or within any specific range compared to other market prices which may be available to you from other sources. We are not liable for any loss or for other claims which you may have in connection with such orders. The conditions can be the following:
6.6.1. times in which the market of the underlying is suspended (for example, during the weekend or at off-market hours, suspension due to market conditions or due to any other event in which the market of the underlying is suspended); and/or
6.6.2. during the time the market was open, however, your order is triggered shortly following a suspension.
6.7. We will execute orders received during trading hours. Different products have different trading hours and these are available on the Website. It is your responsibility to ensure you are aware of the trading hours for the product you are trading. We may agree to execute orders outside of business hours, at our discretion.
6.8. Where you place an order outside of market hours, or where the product you are trading has a 24/7 market, but your order is placed during a period where there is limited trading (for example during the weekend), the availability of the different functionalities which we may provide as part of CFD Trading, including instructions which you may give in respect of a trade, may be delayed or may not be available. We are not liable for any loss which results from your inability to access or provide certain trading functionalities and instructions.
7.1. You may request to cancel or modify an order which we have not executed. However, we cannot guarantee that we will be able to carry out your request. This will depend on the product that you are trading.
8.1. We are not required to accept every order that you place and have reserved the right to decline any order or transaction. Even if we have accepted your order we are not required to execute it. The following is a non-exhaustive list of examples of situations where we may not accept an order, not execute or complete an order, or cancel an order:
8.1.1. we reasonably believe that the security of the App or your Account, including Margin Account is at risk, or if we're concerned about unauthorised or fraudulent use of your Account. This might happen if we think someone is using your Account without your permission;
8.1.2. you do not have enough money in your Margin Account to cover the maximum amount of loss associated with your order, plus any associated fees, charges and applicable margin;
8.1.3. we have a good reason to believe that there is an error with your order. For example, if you have placed an order that is unusually large and you have never done this before;
8.1.4. the order you have requested is unusual or for exaggerated volumes;
8.1.5. there is an error with the quote that we have provided. For example, if the quote is manifestly different from the market price, prices on exchanges, prices on other trading platforms, and/or if the quote lacks economical sense;
8.1.6. there is a change in the applicable law, which means that the order is no longer in compliance with the law;
8.1.7. there is a Market Event;
8.1.8. an exchange requests or recommends that the order is cancelled;
8.1.9. you breach the rules of trading;
8.1.10. an event of default occurs; or
8.1.11. an exceptional event occurs.
8.2. If we do not accept your order, execute your order, or cancel your order, we will inform you by making that information available in the Apps, unless there is a legal reason that we cannot provide this information to you. If we charged you a fee as part of the order, we will refund that money back into your Margin Account. If there were no fees or charges, then you will not receive a refund.
8.3. If we have executed your order, and therefore a transaction has occurred, we may take corrective actions and either modify the transaction, or void the transaction, under the scenarios listed in clause 8.1 above. We will inform you of errors by making information available on our trading platform, including any corrective actions we intend to take.
8.4. We will not be responsible for any losses you incur as a result of any actions or inactions taken by us in accordance with this section 8.
9.1. We are required to take sufficient steps to achieve the best possible result for you, on a consistent basis, when providing CFD Trading. Our Best Execution Policy sets out the procedures that we follow as well as the relevant market factors that we take into account as part of our best execution obligation. This policy, which may be amended from time to time, forms part of our agreement with you and is available on our Website.
9.2. We understand that the best execution result is one that produces the best possible financial result for you, and that the “best possible financial result” is the best possible result in combination across all your trades. This means that some trades, taken individually, may be less favourable. Where we reasonably believe that it is in the overall best interest of all our clients, we may combine your order with our own orders or those of other customers, or we may split your orders. Best interests are not solely determined by price, and we also consider other factors, such as the speed of the trade and the likelihood of the trade being successful, to be important. Aggregation or splitting of orders may result in you obtaining, on some occasions, more favourable terms or price, and, on other occasions, less favourable terms or price than if your order had been executed separately.
9.3. We monitor the effectiveness of our Best Execution Policy on a regular basis to ensure that we consistently achieve the best results for you.
10.1. We may close your Open CFD Position where our system or you have placed a stop-loss order and the stop price has been reached.
10.2. We may decline or cancel your order and close your Open CFD Position where you do not have the required margin in your Margin Account or you do not meet the margin requirements, as described in section 5 above. We may do this without further notice to you, and you may make a profit or a loss as a result.
10.3. We may also close your orders in special circumstances or when a Market Event occurs as described in section 13 below.
10.4. Please refer to section 8 above for more information about our rights and your rights in special circumstances.
11.1. Information about your trading activities, which includes records of the trades that you've concluded, your Open CFD Positions, margin, balances as well as other information about your trades and orders, is available online in your Account. Your Account will be updated no later than 24 hours after any activity takes place. You will be able to filter this information in different ways, for example on a per month basis. We are under no obligation to provide this information in hard copy or by email, but we may do so upon your request.
11.2. If you think there is a problem with your Account, please contact us as soon as possible and not later than 48 hours following the day on which the information became available. Otherwise, the information will be conclusive evidence of your transactions, concluded trades, your Open CFD Positions, margin, and balances.
12.1. There are rules which you need to follow when using our CFD Trading service. These are:
12.1.1. you must not reverse engineer or avoid any security measures on the trading platform;
12.1.2. you must not use any software, artificial intelligence, ultra-high speed, or mass data entry which might manipulate, game, abuse, or give you an unfair advantage when using our systems or Services;
12.1.3. you will not enter into trades which manipulate our systems or Services, for example entering into a buy trade as well as a sell trade, for the same or for a similar product, at the same or similar time;
12.1.4. you will not enter into transactions or combinations of transactions such as holding long and short positions in the same or similar instruments at similar times either by you or by you acting in concert with others, which, taken together or separately, are for the purpose of manipulating our systems or Services for gain;
12.1.5. you will not act in an unfair, abusive, manipulative, or illegal way when using our Services, for example scalping;
12.1.6. you will not enter into trades aimed at exploiting errors in prices and/or conclude trades at off-market prices; and
12.1.7. your order must not violate exchange rules or securities or commodities laws, regulations or rules, and/or be intended to defraud or manipulate the market.
12.2. If you make money by breaching the above rules, we may not pay that money to you or, if we have paid that money, we may deduct it from any of the balances of your Account.
12.3. If you breach any of the above rules we will record such breach. We may also cancel your orders, freeze, block and/or terminate our Services, your Account, and/or our agreement with you. We may, but are not required to, give you notice of this, subject to the applicable law.
13.1. There are various types of events that affect the trading of specific products resulting in for example higher price volatility, higher trading activity or changes related to the structure of a given product. Most of the latter can be categorised as corporate events which will result in a change to the financial instruments. Examples of corporate events include share consolidations, share splits, reorganisations, mergers, take-over offers (and similar), name changes and rebranding, dividend distributions, and delistings.
13.2. If a Market Event impacts the underlying product of a CFD, we will use reasonable endeavours to adjust all Open CFD Positions on that instrument, in a fair way and in accordance with market practice, and/or taking into account the treatment we may receive from our counterparties or any relevant third party and the deduction of any taxes applicable. The adjustments we carry out will depend on the circumstances of each event, and is according to our sole discretion, however we are not obliged to do this. Adjustments may include changing the price or the quantity of CFDs that you have to reflect the economic rights that you had prior to the Market Event occurring.
13.3. If an issuer of an underlying product goes into insolvency or is dissolved, we will close any Open CFD Positions related to that product. The closing date shall be the date of insolvency. Any money from the sale will be paid into your Margin Account. If you lose money as a result of the sale, we are not responsible for this.
13.4. We reserve the rights to close out any Open CFD Positions at the market price immediately prior to the Market Event taking place.
14.1. We are required to act in your best interest when providing our Services. However, there may be instances where your interests conflict with our interests, or with another customer's interests. For example:
14.1.1. we may execute hedging transactions before or after entering into a transaction with you to manage our risk in relation to the transaction, which may impact the price you pay or receive for such transactions, and we will retain any profits generated by such hedging. However, we are not required to hedge transactions if we do not want to;
14.1.2. we may enter into arrangements with third parties, or with other customers, where we make payments to them or receive payments from them based on your trading activity or volume, where such arrangements are permitted by the applicable law. These payments may include rebates, commissions, widened spreads and profit sharing;
14.1.3. we may provide, pay or receive fees, commissions or non-monetary benefits where such payments are permitted by the applicable law;
14.1.4. we may share dealing charges with our affiliate companies or receive remuneration from them in respect of transactions carried out on your behalf;
14.1.5. we may be the counterparty to trades that you enter into; and
14.1.6. we are responsible for setting the price of instruments and products which can be traded in the Apps. This means that our prices can be different from the prices provided by other brokers and the market price, as well as the current prices on any exchanges or trading platforms.
14.2. We have in place a number of internal policies and arrangements to help manage any conflicts. In addition, the potential conflicts related to trading detailed above are subject to an objective criteria which is set out in our Best Execution Policy.
15.1. You expressly consent to us using the Apps or Website, as we deem appropriate, to inform you of information about us and of changes to such information (including changes to Terms and Conditions and our Best Execution Policy).
15.2. We may also communicate with you via Apps and Website, by email, telephone, post, newsletter, letter, electronic chats, and/or any other means of communication. We will use the contact details you gave us when you opened your Account, and as updated by you to us.
15.3. If your details change, including your email address, contact numbers, name, home address, country of residence or nationality, you must tell us as soon as possible. If you do not let us know, you might not receive important information from us.
15.4. Our Terms and Conditions, i.e. our agreement with you, and all information, statements and notifications between you and us, will be in English and we will communicate in English. If we provide you with documents in another language, and there is an inconsistency, the English version will prevail.
16.1. If you are unhappy with a Service or something has gone wrong, please contact us so we can investigate the circumstances for you and we will try to put it right. You may contact us using any of the following means:
16.1.1. email to email@example.com;
16.1.2. log in to the Apps and send us a secure message; or
16.1.3. send a letter to Keizersgracht 482, 1017EG Amsterdam, the Netherlands.
16.2. We will make every possible effort to address all points of complaint by email. We will respond within 5 business days upon receiving the complaint. If a full response cannot be provided within these timeframes, we will send a holding reply with a full response to follow within 20 business days.
16.3. If you want to know more about how we handle customer complaints, please read our Complaints Handling Procedure.
16.4. If you're still not happy with how we've dealt with your complaint, you can refer it to the Dutch Financial Services Complaints Tribunal (Kifid) using our registration number 400.000422. The Kifid consists of the Financial Services Ombudsman and the Financial Services Disputes Committee.
16.5. Ultimately you may turn to the Dutch Authority for the Financial Markets (AFM) or to relevant courts. For more information on such alternative solutions, please refer to the Website.
17.1. We may change these Terms & Conditions by notifying you by e-mail or other agreed means at least one month before the change is due to happen. We will assume that you agree with the change. If you do not agree with the change you must tell us before the change happens and we will cancel your account immediately. If your account is cancelled or you cancel your account in this way, we will return any balance on the account to you.
17.2. An up-to-date version of these Terms & Conditions, as well as any notices of future changes will always be available on the Website. You should check it regularly for such notices and changes.
18.1. You may not transfer or assign any rights or obligations you may have under these Terms & Conditions to any other person without our prior written consent. We may assign the benefit and burden of these Terms & Conditions to any other person at any time on giving you two months prior notice of this. If we do this, your rights will not be affected.
19.1. This agreement is concluded in English. All communications with you will be in English. These Terms & Conditions are governed by Dutch law and all disputes shall be solved by a way of negotiations, or if the Parties fail to do so in respective Dutch courts.
20.1. We will charge you a fee for each order we execute for you. This is called a spread. A spread is the difference in the sell and the buy price. The spread is different for each type of product and Service and can be found in the Apps and on the Website.
20.2. We will estimate the total amount of spread that applies each time you place an order. We cannot provide you with an exact amount because the spread may change between the time you make an order, and the time we execute your order.
20.3. The spreads which we charge can change due to market conditions. For example, there may be instances when market conditions cause spreads to widen beyond the typical spreads displayed on our website and/or platform.
20.4. All the information is available in chapter Fees and Limits. However, for specific Services, other fees may also apply. For example, if you trade CFDs, we also charge you an overnight fee. We may update our commissions, charges, fees and costs from time to time. It is your responsibility to keep up to date with any changes, and to be aware of the commissions, charges, fees and costs that apply to your trades and the Services that you use.
20.5. You acknowledge that all amounts due to us shall be deducted from any of the balances of your Account.
21.1. When you terminate your relationship with us and provide us with instructions for closing your Account, we will arrange for your Open CFD Positions to be closed as soon as reasonably possible in accordance with these Terms & Conditions. Where securities are sold, you may suffer a shortfall between the amount you invested and the amount you get back after sale. We are not responsible for any shortfall that arises. Any shortfall will be borne by you.
21.2. We will hold all the proceeds as client money and we will charge fees and any other applicable charges and taxes from that money.
21.3. We are required to keep your records for at least five years after your Account is closed. This period may be extended by the applicable law or agreement between you and us in writing. These records will be our sole property.
In force from 2020-07-03
This is a specific policy that will apply when you use CFD Trading Service i.e. trade CFDs directly with Indexa B.V. using Change Apps. In this procedure:
The Best Execution Policy (hereinafter "the Policy" is provided to the Client in accordance with the Provisions of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Markets Laws supervised by The European Securities and Markets Authority (ESMA) and Netherlands Authority for the Financial Markets (AFM), (hereinafter "the Law"). Pursuant to the Law, the Company is required to take all sufficient steps to obtain the best possible result on behalf of its Clients when providing to them the Investment Services that the Company is licensed to provide. The Client acknowledges that by opening a Margin Account with the Company his orders will be executed Over-the-Counter ("OTC"). That means that Client orders will be executed outside Regulated Markets and/or Multilateral Trading Facilities.
The Company is authorised to execute orders on Clients’ behalf. The present policy applies only to Retail Clients, it does not apply to Eligible Counterparties and Professional clients.
The Company takes all sufficient steps to act in the best interest of its Customers when executing Customer’s Orders and obtain the best possible result for Customers taking into account the following factors when dealing with Customers Orders: price, cost, speed, likelihood of execution and settlement, size, market impact or any other consideration relevant to the execution of an order. The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor. The Company when executing Clients’ Orders is required under the relevant regulatory framework to assign a relative importance on the following execution factors:
a. Price: For any given CFD, the Company will quote two prices: the higher price (ASK) at which the Client can buy (go long) that CFD, and the lower price (BID) at which the Client can sell (go short) that CFD. Collectively, the ASK and BID prices are referred to as the Company’s price. The difference between the lower and the higher price of a given CFD is the spread. Such orders as Buy Limit and Stop Loss, Take profit for opened short position are executed at ASK price. Such orders as Sell Limit and Stop Loss, Take profit for opened long position are executed at BID price. The Company’s price for a given CFD is calculated by reference to the price of the relevant underlying asset, which the Company obtains from third party external reference sources. The Company’s prices can be found on the Company’s website and/or trading platforms. The Company updates its prices as frequently as the limitations of technology and communications links allow. The Company reviews its third party external reference sources in frequent periods to ensure that the data obtained continues to remain competitive.
b. Costs: For opening a position in some types of CFDs the Client may be required to pay a mark-up on spread and an overnight financing fee (“swap”) if the Client wished to hold his position overnight. The amount of the costs is disclosed on the Company's website and/or trading platforms. Commissions may be charged either in the form of a percentage of the overall value of the trade or as fixed amounts. In the case of financing fees, the value of opened positions in some types of CFDs is increased or reduced by a daily financing fee “swap rate” throughout the life of the contract. Financing fees are based on prevailing market interest rates, which may vary over time. Details of daily financing fees applied are available on the Company’s website and/or trading platforms. For all types of CFDs that the Company offers, the commission and financing fees are not incorporated into the Company’s quoted price and are instead charged explicitly to the Client account.
c. Speed of Execution: The Company places a significant importance when executing Client’s Orders and strives to offer high speed of execution within the limitations of technology and communication links. In case where the Clients use a wireless connection or a dial up connection or any other communication link that can cause a poor internet connection, which can cause unstable connectivity with the Company's trading platform, resulting to the Client placing his orders at a delay and the orders being executed at a better or worse prevailing price offered, the Company does not accept any liability in case of such incident.
d. Likelihood of Execution: There would be cases where it may not be possible to arrange the order for execution. That is because we rely on third-party LPs for prices and available volume. Therefore, the execution of Clients’ orders will depend on whether there are prices and liquidity available at the time these orders are received. The availability on execution may be subject to variation, especially during abnormal market conditions, such as:
e. Likelihood of settlement: The CFDs offered by the Company do not involve the delivery of the underlying asset, so there is no settlement as there would be for example if the Customer had bought shares.
f. Size of Order: The minimum size of an order may be different for each asset type and/ or financial instrument. A Lot is a unit for measuring the transaction amount and is different for each type of Financial Instrument. Please refer to the website and/or platform for the value of minimum size of an order or minimum Lot for a given CFD type.
g. Market Impact: Some factors may rapidly affect the price of the underlying instruments/products from which the Company’s quoted price is derived and may also affect other factors listed herein. The Company will take all reasonable steps to obtain the best possible result for its Clients.
h. Partial Fills: This is the practice of executing an order in parts if there is not enough liquidity in the market at the time in order to fill-in the full order at a specific price. Partial fills may be executed at different prices.
a. Slippage: This situation occurs when there is latency between the quoted and executed price. Latency can lead to slippage i.e. the difference between the expected price of an order, and the price the order is actually executed at. Negative slippage occurs when the executed price is worse than the price requested by the Client. Positive Slippage occurs when the execution price is better than the price requested by the Client. Slippage is more likely to occur in the forex market when volatility is high, perhaps due to news events, or during times when the currency pair is trading outside peak market hours. Additionally, slippage can occur both to market and pending orders. Pending orders will be executed at the next best available price. As part of monitoring its best execution, the Company ensures that it does not apply asymmetric slippage to its clients.
b. Re-quotes: The Company only has market execution. Thus, it will not provide a secondary quote to the Client after an order has been submitted.
a. Market Order(s): A Market Order is an order to buy or sell a CFD at the current price. Execution of this order results in opening a position. CFDs are bought at the ASK price and sold at the BID price. Stop Loss and Take Profit Orders can be attached to a Market Order. Market Orders are offered for all types of accounts.
b. Pending Order(s): The Company may offer the following types of Pending Orders:
These are the entities with which the Company places and executes Client Orders. The Execution Venue(s) that the Company is using are found in Annex I.
The Customer acknowledges that the transactions entered into with the Company for the financial instrument provided by the Company are undertaken through the trading platform of the Company. The Orders will be executed on an ‘over the counter’ basis.
The Company shall not receive any remuneration, discount or non-monetary benefit for routing client Orders to a particular execution venue which may lead to a conflict of interest. The company will not pay or be paid any fee or commission, or provide or be provided with any non monetary benefit in connection with the provision of an investment service or an ancillary service, to or by any party except the client or a person on behalf of the client, other than where the payment or benefit:
a. is designed to enhance the quality of the relevant service to the client; and
b. does not impair compliance with the investment firm’s duty to act honestly, fairly and professionally in accordance with the best interest of its clients.
The Company takes sufficient steps to obtain the best possible result for our Clients, when executing orders, taking into account the price, costs, speed, likelihood of execution, size, nature or any other consideration relevant to the execution of the order. In relation to the best execution criteria, for orders that are not wholly covered based on your specific instructions, we shall take into consideration the execution factors and their relevant importance in the order presented below:
Price is one of the most important factors in order for the Company to meet its best execution obligations. The Company receives its prices from its Liquidity Providers and uses price aggregation technology to detect and quote the best Bid and Ask quote from the LPs to the trading platform. We do not however guarantee that our quoted prices will be at a price which is as good, or better, than one might have been available elsewhere.
We place a significant importance in this factor when executing Client orders and to this end we maintain high speed connections through multiple servers hosted globally within the limitations of technology and communications links. However, the use of any form of unstable connection at the Client’s end, whether wireless or dial-up, may result in poor or interrupted connectivity, which may cause delays in the transmission of data between the Client and us. As the Client places Orders through the Company’s Electronic Trading Platform, the Client is exposed to risks associated with that, including the failure of hardware and software (e.g. Internet connectivity issues, server downtimes, etc). This may result that client’s Order is either not executed in accordance with his expectations or it is not executed at all. The Company does not accept any liability in the case of such a failure.
The Company is the sole Execution Venue for the execution of the Client’s Orders for the Financial Instruments provided by the Company and, as such, it strives to execute, in whole, all Orders placed by the Clients. However, it reserves the right to decline or partly fill in any Order or to execute the order at the first available market price without providing any justification to Client. We rely on third-party LPs for prices and available volume of the different financial instruments we offer. Therefore, the execution of Client's orders will depend on whether there are prices and liquidity available at the time these orders are received. By having various LPs, the likelihood of execution across the instruments we offer is high. This availability may be subject to variation, especially during abnormal market conditions, such as:
The minimum size of an order may be different for each asset type and/or financial instrument. A Lot is a unit measuring the transaction amount and it is different for each type of Financial Instrument. Please refer to the website and/or platform for the value of minimum size of an order or minimum Lot for a given CFD type.
All transactions are settled upon execution.
Some market factors may affect rapidly the Company’s quoted price of the Financial Instruments. These factors may, in turn, affect some of the other execution factors listed above. The Company takes all reasonable steps to obtain the best possible result for its Clients. The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor.
Whenever a Client gives a specific instruction as to the execution of their order, the Company will execute that order in accordance with the Client’s specific instructions. In following those specific instructions, the Company will be deemed to have satisfied its best execution obligations in respect of that part of the order to which the specific instructions relate. If a Client requires their order to be executed in a particular manner, they must clearly state their desired method of execution when they place their order. To the extent that the Client’s specific instructions are not comprehensive, the Company will determine any non-specified aspects in accordance with this Policy. It should be noted that specific instructions from a Client may prevent the Company from taking the necessary steps it has designed and implemented in this Policy, to obtain the best possible outcome for the execution of those orders in respect of the elements covered by those instructions.
The Company has processes and procedures which analyse the execution quality and monitor best execution. The Company monitors and measures the competitiveness of its prices and the speed of its execution against other Forex Brokers.
The Company’s second and third line of defences, namely the Compliance and Internal Audit perform additional reviews and assessments on best execution on a regular basis and at least annually or whenever a material change occurs that affects the Company’s ability to continue obtaining the best result for Clients’ orders.
These reports should be stored in an internal electronic folder.
Specific Leverage restrictions apply for Retail Clients. Hedging is not permitted while using CFD Trading. Where a Customer opens a second position on the same instrument, this will be netted-off against the existing open position. CFDs are not eligible for sale or distribution in certain jurisdictions or countries. This Policy is not directed to any jurisdiction or country where its publication, availability or distribution would be contrary to local laws or regulations.
The table below lists brokers (Liquidity Providers / Execution venues) that the Company currently uses for executing the Orders. The Company reserves the right to use other execution venues and third parties where we consider that it is appropriate in the light of this Policy, and we may from time to time add or remove an execution venue or a broker from this list. The following execution venues will be used for executing the Orders:
Country of Establishment
Commencement of the relationship with the Company
Financial Conduct Authority
9th of June, 2020
In force from 2022-06-29
This procedure applies to CFD Trading service. You can access and download a copy of this document at any time from www.changeinvest.com.
This is a specific procedure that will apply when you use CFD Trading Service i.e. trade CFDs directly with Change Securities B.V. using Change Apps and lodged a Complaint. In this procedure:
If you have any questions you can contact the Company by:
All of the terms and definitions not stipulated in this document are stipulated in the various chapters of the Terms and Conditions available on the Website.
1.1. Under the law the Company is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of Complaints or grievances received from Complainants and keep records of each Complaint as well as any actions taken by the Company to remedy the situation in accordance with the provisions of the competent authorities.
1.2. This procedure sets out the method for the submission of Complaints with the Company from its clients and the processes followed by the Company when dealing with such Complaints.
1.3. The Company considers having a Complaint when the Complainant has filled out the relevant Complaint Form, available on the Website, and submitted it to the Company via the following methods:
1.3.1. by email at firstname.lastname@example.org; or
1.3.2. by post Keizersgracht 482, 1017EG Amsterdam, the Netherlands.
1.4. In case the Company receives a notification through the line of communication established by the Company, but which does not fall within the definition of clause 1.3 and can be characterised not as Complaint, this shall be categorised as an enquiry and will be forwarded to the relevant contact within Company to be handled accordingly. The Complainant maintains the right to request for the reclassification of the enquiry as a Complaint.
2.1. The customer support and if necessary, member of the compliance staff, shall efficiently handle any Complaint received by a Complainant. In the case that the Complaint is against the compliance staff, the Complaint shall be handled by a director of the Company.
3.1. It is the Company’s policy not to accept any verbal complaints or grievances. Should any of the Company’s employees (regardless of department) receive a verbal Complaint or grievance, the procedure stipulated in the following clauses 3.2-3.3 must be followed.
3.2. The member of the staff receiving the verbal complaint or grievance shall take all the necessary actions so that the Complaint or grievance is properly addressed. The person will inform the Complainant that all the Complaints or grievances must be made in writing by completing the relevant Complaint Form as stipulated in clause 1.3. Once the Complainant completes and submits the Complaint Form the procedure for written Complaints shall be followed as described in section 4.
3.3. The member of the staff, in addition to the above, should make all best efforts to ensure that in the case of the Complaint or grievance being of such nature that can be resolved immediately, to do so that the Complainant will not have to fill out the Complaint Form. The member of staff in such a case shall not do the following:
3.3.1. commit on behalf of the Company in taking any action prior to examining the issues in a formal manner;
3.3.2. commit in any way to the Complainant;
3.3.3. address any issues in relation to best execution; nor
3.3.4. address any issues relating to legal, compliance or regulatory issues.
4.1. If the complaint was received in the manner not fulfilling the conditions stipulated in section 1, i.e. the complaint was received through internal channels of communication such as chat, client correspondence, on other Company’s email addresses, or by any other Company’s member of the staff, then the complaint, in the form that has been received, must be forwarded, in the form it has been received to email@example.com within the same working day.
4.2. Once the Complainant submits a written complaint, customer support will send an electronic acknowledgment of receipt to the Complainant’s registered email address within five (5) working days following receipt, to verify that the Company has received the written Complaint and will request the Complainant to complete the relevant Complaint Form.
4.3. Upon completion and submission of the Complaint Form, customer support will investigate the grounds of the Complaint and if, based on the information provided, the grievance does not fall within the definition of Complaint or is not considered to be a Complaint it will be categorised as an enquiry and will be forwarded to the relevant member of the staff to be handled appropriately.
4.4. If the grievance falls within the definition of Complaint or is considered to be a Complaint, then the member of the staff will register the Complaint to an internal registry by giving it a unique reference number and by categorising it accordingly (e.g. technical, operational, compliance, legal) for the purpose of handling the Complaint most effectively.
4.5. In addition, within five (5) working days customer support shall inform the Complainant of the following:
4.5.1. that the Complainant must use the given reference number in all future correspondence with the Company regarding the submitted Complaint;
4.5.2. the process which is followed when handling a Complaint;
4.5.3. who is the member of the staff that is dealing with the Complaint and their contact details;
4.5.4. what is the indicative handling time (as a standard 20 working days); and
4.5.5. that the Complaint handling procedure is free of charge.
4.6. Moreover, the customer support must make sure that the following information is obtained from the Complainant, to the extent possible on the Complaint Form, and recorded:
4.6.1. full name and surname;
4.6.2. email address;
4.6.3. affected transactions (if applicable);
4.6.4. the date that the issue arose and a description of the issue;
4.6.5. the Service provided by the Company related to the Complaint;
4.6.6. member of the staff responsible for the provision of this Service (if applicable);
4.6.7. Complainant’s own description of the facts related to the Complaint, i.e. the content; and
4.6.8. reference of any correspondence exchanged between the Company and the Complainant (if applicable).
4.7. The Company will thoroughly examine and assess the facts and the information provided by the Complainant and the relevant members of the staff. Compare these facts with the information and data which have been retrieved from the Company’s archive (i.e. the Complainant’s transactions, trading history, correspondence, other electronic records). This investigation will also include the events preceding or leading to the Complaint.
4.8. The Company will not handle or investigate a Complaint if the Complainant does not complete the Complaint Form or does not provide the information requested in clause 4.6. of this procedure. In such an event the Company shall revert back to the Complainant and request to send any additional information. In any event, a member of senior management may contact the Complainant directly in order to obtain further clarifications and information relating to the Complaint. The Company shall need the Complainant’s cooperation in order to handle the Complaint.
4.9. The Company upon examining the complaint and reaching a decision to this respect shall inform the Complainant about the Company’s decision, in writing and in plain language which is clearly understood, together with the reasoning of the Company’s decision and any remedial measures it intends to take.
4.10. The Company shall make every effort to resolve the complaint within fifteen (15) working days. When deemed necessary, customer support or a member of the compliance staff shall convey the complaint to the senior management for further investigation. In this case, the Company might take additional five (5) working days to finalise the reply. The senior management shall investigate further and coordinate with relevant members of the staff to attend to the subject of the Complaint.
4.11. In the event that the Company cannot provide a response to the Complainant within the handling time given to the complainant, it will keep the Complainant informed about reasons of delay and indicate when the investigation is expected to be completed. This period of time cannot exceed two (2) months from the submission of the Complaint.
4.12. Once the Complaint is concluded and Company has reached final decision customer support will be responsible of keeping an full electronic record of the Complaint received, detailing the course of action which was taken, including what information, data and evidence were gathered, what measures were taken for the resolution, whether any conflicts of interest between the Company and its clients and between other clients were identified, what was the outcome and how that outcome was reached.
4.13. The Company shall maintain record of all complaints for a minimum period of five years after the closure of the Customer’s Margin Account.
5.1. If the Complainant is not fully satisfied with the Company’s final decision the case can be referred to the Dutch Financial Services Complaints Tribunal (Kifid) using Company’s relevant registration number 400.000422. The Kifid consists of the Financial Services Ombudsman and the Financial Services Disputes Committee.
5.2. Ultimately the Complainant may turn to the Dutch Authority for the Financial Markets (AFM) or to relevant courts.
6.1. Customer support will analyse, on an on-going basis, Complaints handling data, in order to identify and address the causes of the individual Complaints and/or any recurring or systematic problems and/or any potential legal and operational risks. Subsequently the relevant member of the staff or senior management should be informed and if necessary, take corrective action.
6.2. This Complaints Handling Procedure will be made available on the Website.
6.3. The Complaints Handling Procedure is available to all the members of the staff through email and an internal folder in the Company’s channels of communication which can be accessed at any time without any restrictions.
This form is an electronic document that must be filled out by you to lodge a formal Complaint about CFD Trading service provided by Change Securities B.V. This form is part of the formal Complaints Handling Procedure regarding the investment or ancillary services provided to you.
Please note that it is Company’s policy not to accept any verbal complaints or grievances.
If you have any questions please contact the Company by email firstname.lastname@example.org, through mobile application or sending the letter to Keizersgracht 482, 1017EG Amsterdam, The Netherlands.
In force from 2023-05-18
Conversion fee is service expense, which is applied in addition to Conversion Rate.
In force from 2023-09-18
Conversion fee is service expense, which is applied in addition to Conversion Rate.
Exciting news - we’re upgrading our Bug Bounty Programme!
Your funds and data security are paramount for us. So, we truly appreciate the time and effort you put into helping improve our app by detecting and reporting vulnerabilities to us. To make it worth your while, we’re reviewing and upgrading our Bug Bounty Programme.
The new rewards system alongside updated terms and conditions are 'under construction' as we speak. You’re still welcome to report any vulnerabilities by emailing us at email@example.com. However, we can’t guarantee any rewards while we’re reviewing the programme.
Thank you for your patience. Stay tuned!
Token Swap Terms constitute a legally binding agreement between the SPV and each Tokenholder or holder of CNG Tokens. Accepting the Terms and/or acquiring CNG Tokens means that you have fully agreed to all the terms and conditions. In addition to the Terms, each Tokenholder or holder of CNG Tokens is obliged to comply with the technical rules associated with the relevant smart contract.
Token Swap Terms are available on this link.
If you have any questions regarding the Terms or such technical rules, please contact us at firstname.lastname@example.org.
In force from 2022-09-29
Change has appointed a data protection officer, who can be reached via email@example.com. All of the inquiries and complaints concerning the processing of personal data should be addressed to said email address.
1.1. Change is to be considered a data controller in respect of personal data collected and processed in respect of providing Services to you.
1.3. In the case of Getchange account and debit card UAB Finansinės paslaugos “Contis“ is to be considered a data controller, the terms stipulated in clause 1.2 respectively apply, and Change is considered either a data processor, data controller or a joint controller, provided the purpose and means of processing of personal data has been jointly determined by the parties. More information about the processing of personal data in respect of providing payment services to you can be found from this link.
1.5. Generally personal data is collected directly from you, and from the information and documents you have provided. However, in order to comply with the legal obligations personal data, e.g. identification, identity document and financial data, is also collected from other sources, e.g. from third parties and public sources.
2.1. We are processing the following categories of personal data:
2.1.1. identification data, e.g. your photo, name, date and place of birth, address;
2.1.2. identity document data, e.g. photo of the document, number and validity;
2.1.3. contact data, e.g. phone number, email address;
2.1.4. financial data, e.g. ownership and source of funds and/or wealth;
2.1.5. transaction data and the nature of using the service, e.g. transaction sums, counter-parties, bank account and card number(s) and account holders;
2.1.6. other data used for performing customer due diligence measures, assessing trustworthiness and to prevent fraud, e.g. media coverage, occupation and connection to other persons, and device information and location; and
2.1.7. correspondence between you and us.
3.1. In general we are processing your personal data for the performance of or entering into a contract with you, i.e. personal data is processed for the purposes of providing the services. Without processing personal data, we would be unable to provide services to you, including due to regulatory restrictions.
3.2. The purposes for which we are processing personal data are the following:
3.2.1. fulfilling a contractual obligation, e.g. executing your transaction orders and ensuring the safety of your assets;
3.2.2. fulfilling a legal obligation, e.g. ensuring the security of accessing the Account and the transactions and using the data for accounting and reporting purposes;
3.2.3. public interest, e.g. by performing necessary acts in order to prevent money laundering and the financing of terrorism and thus to ensure the proper identity verification;
3.2.4. sending informative and promotional notifications, or collecting, processing storing and disclosing personal information, e.g. name and contact information, with our partners in order to conduct campaigns and ship the rewards, under a revocable consent received from you; and
3.2.5. our legitimate interest to prevent fraud and to improve our products and services, as well as to promote the launch and usage of new functionalities and features and to illustrate the benefits and possibilities of cryptocurrencies and investing, e.g. by identifying concurrently used app versions and by sending promotional content regarding new features and products, and to conduct campaigns, including in co-operation with third-parties, and ship the rewards.
3.3. For entering into and for the performance of the contractual agreement between you and us and for public interests, Change is applying certain automated decision-making methods to assess your capability, suitability, behaviour and reputation, whether to enter into or to continue a contractual relationship. The aforesaid assessment is accompanied by human-intervention by an employee of Change, who will perform the final assessment.
3.4. For entering into a contract and for the performance of a legal obligation Change may be obliged to assess your capability, suitability, behaviour, reputation and financial situation, whether to enter into or to continue a contractual relationship with you, in which case the personal data is processed by Change as a data processor on behalf of Change Securities B.V..
4.1. Your personal data is being processed by the following categories of data recipients:
4.1.1. our employees responsible for specific tasks regarding the Services;
4.1.2. data processors who help us with providing the services, e.g. service providers for the maintenance of our IT-systems and for fulfilling our legal obligations;
4.1.3. third parties to whom we are required to transfer data under applicable legislation, e.g. relevant state institutions and sector-specific authorities.
4.1.4. third parties who help us in developing and promoting the services.
4.2 Change has engaged with two third-party service providers,
4.3. We are not responsible for the actions and processing activities of any third parties. Third parties are considered to be separate data controllers, whose services can be procured by concluding separate agreements with them. Third parties may transfer your personal data to Third Countries and process it for independent purposes.
4.4. Although generally the personal data is processed within the European Economic Area, certain activities may result in the transferring of personal data to Third Countries, meaning countries located outside the EU/EEA, and to countries in relation to which the EU Commission has not issued an adequacy decision, e.g. the US. For ensuring that your personal data is protected, we have committed to applying appropriate safeguards, including but not limited to assessing the security and due diligence measures and regulatory compliance of these persons, concluding relevant data processing agreements and standard data protection clauses adopted by the European Commission for the transfers. In case you wish to know more about the safeguards and obtain a relevant copy of them, please contact us using the details specified above.
4.5. We shall maintain the confidentiality of all information of which we become aware on the basis of the relationship with you, including information concerning you and the Payment Account and Payment Transactions thereof, unless the right or obligation to disclose information arises from legislation.
4.6. We shall be released from the obligation to maintain confidentiality to the extent that you have granted consent to the disclosure of information in writing or in the Apps or our Website or to the extent a disclosure of confidential information is allowed or required under applicable laws and/or mandatory orders by regulatory authorities.
5.1. Your personal data is generally retained as long as you are using the Services. After you have stopped using the Services and your Account has been closed, your personal data shall be retained as long as any claims can be presented on the basis of such data under applicable legislation.
5.2. Certain data, e.g. data obtained for the purposes of the fulfilment of obligations related to anti-money laundering and terrorist financing prevention, or data necessary for accounting purposes, shall be retained as required under applicable legislation and industry standards. Generally, respectively at least for 5 or 7 years since the date of closing the Account, but not longer than 10 years.
5.3. We shall immediately terminate processing the data that is processed under your consent, if the consent is revoked, and the processing of personal data under legitimate interest, if you have declared objection to such processing.
6.1. You, as a data subject, are, at any time, entitled to exercise the following rights:
6.1.1. The right to request the correction of your personal data;
6.1.2. The right to request access to your personal data;
6.1.3. The right to request the erasure of your personal data;
6.1.4. The right to withdraw the consent on which the processing is based;
6.1.5. The right to request the restriction of processing your personal data;
6.1.6. The right to object to the processing of your personal data;
6.1.7. The right to exercise data portability in cases where such data has been provided by you for the performance of or entering into a contractual relationship by accepting the Terms or under the consent; and
This document applies to all Services provided via Change Apps. You can access and download a copy of this document at any time from www.changeinvest.com.
This notice provides you with information about the risks associated with cryptoasset services provided by Change and investment services provided by Company. In this document:
If you have any questions you can contact the Company by:
All of the terms and definitions not stipulated in this document are stipulated in the various chapters of the Terms and Conditions available on the Website.
You gain ownership of the underlying asset when using the Conversion Service offered by Change. In addition, Company offers contracts for difference (CFDs) that provide exposure to cryptoassets, stocks, commodities, ETFs or indices.
Any transactions relating to cryptoassets, stocks, ETFs and indices where leverage is offered or which allow you to enter into short-selling transactions shall be considered CFD Trading provided by Company.
Since cryptoasset markets are decentralized and not regulated to the degree of investment services then customers using the services provided by Change will not fully benefit from the protections available to clients receiving regulated investment services such as the access to the Dutch investor compensation scheme (ICS) operated by the Dutch central bank and the Dutch Financial Services Complaints Tribunal (Kifid) for dispute resolution. Customers of Company will continue to benefit from the rules relating to best execution and client money and safekeeping of client assets.
All these products carry a high degree of risk and are not suitable for many investors. This notice provides you with information about the risks associated with these products but it cannot explain all of the risks nor how such risks relate to your personal circumstances. If you are in doubt you should seek professional advice. It is important that you fully understand the risks involved before deciding to use the Services and that you have adequate financial resources to bear such risks and that you monitor your positions carefully. Trading involves risk to your capital. You should not invest money that you cannot afford to lose, however you cannot lose more than the equity in your account.
CFD stands for “Contract For Difference”, meaning you are not buying the underlying asset, but rather purchasing a contract to settle the difference in the initial and ending price of the asset. When trading CFDs, you generally trade on margin, which means you only have to deposit a small percentage of the overall value of your position. This is known as “leverage”, and even small market movements may have a great impact, negative or positive on your trading account.
If the market moves against you, you may sustain a total loss greater than the funds invested in a specific position. You are responsible for all losses on your account up to the equity in your account.
Before deciding to trade on margin you should carefully consider your investment objectives, level of experience, and risk appetite. Company’s CFDs are not listed on any exchange. CFDs involve greater risk than investing in on-exchange products, as market liquidity cannot be guaranteed and it may be more difficult to liquidate an existing position. The prices and other conditions are set by us in accordance with our obligation to provide best execution as set out in our order Best Execution Policy, to act reasonably and in accordance with the applicable Terms and Conditions. The characteristics of our CFDs can vary substantially from the actual underlying market or instrument. Full details of all of our CFDs are set out on our website. In respect of corporate events with respect to the underlying assets, We do not aim to make a profit from our clients from the outcome of corporate events such as rights issues, takeovers, mergers, share distributions or consolidations and open offers. We aim to reflect the treatment we receive, or, would receive if we were hedging our exposure to you in the underlying market. Ultimately however, you are not dealing in the underlying market and therefore in relation to our CFDs the treatment you receive may be less advantageous than if you owned the underlying instrument.
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. Between 74-89% of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work, and whether you can afford to take the high risk of losing your money.
CFDs are not suited to the long term investor. If you hold a CFD open over a long period of time the associated costs increase (such as overnight fees), and it may be more beneficial to buy the underlying asset instead. Sudden market movements, known as “gapping” may occur, causing a dramatic shift in the price of an underlying asset. Gapping may occur when the underlying market is closed, meaning the price on the underlying market may open at a significantly different level, and at a less advantageous price for you.
At all times during which you have open positions, you must ensure that your account meets margin requirements, which may change from time to time. Therefore, if the price moves against you or if margin requirements have changed, you may need to provide a significant amount of additional funds to meet your margin requirement, at short notice, to maintain your open positions. If you do not do this, Company will be entitled to close one or more or all of your positions and you alone will be responsible for any losses incurred as a result.
Before we open a Margin Account for you, we are required to make an assessment of whether the product(s) and/or services you have chosen are appropriate for you, and to warn you if, on the basis of the information you provide to us, any product or service is not appropriate. If you decide to continue and open a Margin Account with us, you are confirming that you are aware of and understand the risks.
You should further ensure you are able to monitor positions on your account at all times, as you are solely responsible for this. We are not responsible for monitoring positions on your account.
Although the CFD trading platform is automated and we are giving you the best execution available, it is possible that the market price could have changed between order placement and execution time, and therefore we cannot guarantee that the price requested will be the same as the price that the order is executed, the price you receive can be in your favour or against you.
To limit losses, we require you to choose or set ourselves “stop-loss” limits. These set limits to automatically close your position when it reaches a price limit of your choice. There are however circumstances in which a “stop-loss” limit is not fully effective – for example, where there are rapid price movements, or market closure.
In addition, there are risks associated with use of online deal execution and trading systems including, but not limited to, software and hardware failure and internet disconnection.
Since cryptoasset markets are decentralized and not regulated to the degree of investment services then customers using the services provided by Change will not fully benefit from the protections available to clients receiving regulated investment services under the so-called MiFID regime. This also means that there is no central bank that can take corrective measure to protect the value of cryptoasset in a crisis or issue more currency.
Cryptoasset market is determined only by supply and demand and is often highly unpredictable and volatile. The price of a cryptoasset is usually not transparent and highly speculative and susceptible to market manipulation. In the worst case scenario the product could be rendered worthless.
It is important to make a distinction between indicative prices which are displayed on charts and dealable prices which are displayed in the Apps. Indicative quotes only give an indication of where the market is. Because the cryptoassets markets are decentralized, meaning it lacks a single central exchange where all transactions are conducted, each market maker may quote slightly different prices. Therefore, any prices displayed on any chart made available by us or by a third party will only reflect indicative prices and not necessarily actual dealing prices where trades can be executed.
Cryptoasset trading is prone to being misused for illegal activities due to the pseudonymity or even anonymity of transactions and investors would be adversely affected if law enforcement agencies investigate any alleged illicit activities.
Accordingly, cryptoassets should be seen as an asset class with extremely high risks and you should never invest money that you cannot afford to lose. Given the foregoing, cryptoasset are not appropriate for all investors. You should not deal in these products unless you have the necessary knowledge and expertise, you understand these products’ characteristics and your exposure to risk. You should also be satisfied that the product is suitable for you in light of your circumstances and financial position. In addition, use of our Services can never be considered a safe investment rather only an investment with a high risk of loss inherently associated with it. Furthermore, our own fee is added to online quotes, if applicable, which makes trading with the Apps even more volatile.
The risk of loss in trading cryptoassets can be substantial. You should, therefore, carefully consider whether such trading is suitable for you in light of your circumstances and financial resources. You should be aware that you may sustain a total loss of the money deposited.
Since blockchains are independent public or private peer-to peer network and not in any way or manner controlled by us, we shall not be responsible for any failure and/or mistake and/or error and/or breach which shall occur in any blockchain or in any other networks in which the cryptoassets are being issued and/or traded. You will be bound and subject to any change and/or amendments in the blockchain system and subject to any applicable law which may apply to the blockchain. We make no representation or warranty of any kind, express or implied, statutory or otherwise, regarding the blockchain functionality nor for any breach of security in the blockchain.
Change does not own or control the underlying software protocols which govern the operation of cryptoasset available for trading in the Apps. In general, the underlying protocols are open source and anyone can use, copy, modify, and distribute them. Change is not responsible for operation of the underlying protocols and makes no guarantee of their functionality, security, or availability. The underlying protocols are subject to sudden changes in operating rules (so-called forks), and such events may materially affect the value, function, and/or even the name of the cryptoasset Change holds on your behalf. In the event of a fork, we may temporarily suspend operations (with or without advance notice to you) and that Change may (a) configure or reconfigure its systems or (b) decide not to support (or cease supporting) the forked protocol entirely. Change may, but is not obligated to do so, adjust your account in respect of a fork depending on the circumstances of each event attributable to any specific cryptoasset held by you.
We may elect to execute any order and/or hold any fiat money and cryptoasset via third parties. Such third parties are not banks that guarantee the deposits made to them. If any such third party loses any money, fails or goes out of business, there is no specific legal protection that covers you for losses arising from any funds or cryptoassets you may have held with such third party, even when such party is registered with a competent authority. Depending on the structure and security of the digital wallet, some may be vulnerable to hacks, resulting in the theft or loss of customer assets. Change will not be responsible in the event of losses caused by those third parties.
If at any time any of the cryptoasset that forms the subject of your order is delisted and/or we no longer support the trading in such cryptoasset for any reason, then the applicable order will be immediately closed. If Change is notified that a cryptoasset you hold is likely to be delisted and/or removed and/or canceled from any of the exchanges (some of them or all) and we believes that it shall not be able to trade in such cryptoasset, we shall make an effort to sell the cryptoasset on your behalf at such time and price, and in such manner, as it determines.
While trading using the Apps, system errors might occur. You should be aware of the risks that may result from any system failure which could mean that your order may be delayed or fail.
You acknowledge that there are risks associated with utilizing a mobile-based trading system over the internet including, but not limited to, the failure of hardware, software, and internet connections, the risk of malicious software introduction, the risk that third parties may obtain unauthorized access to information and/or assets (including your cryptoasset) stored on your behalf, cyber-attack, the cryptoasset network failure (such as blockchain), computer viruses, communication failures, disruptions, errors, distortions or delays you may experience when trading via the Services, howsoever caused, spyware, scareware, Trojan horses, worms or other malware that may affect your computer or other equipment, or any phishing, spoofing or other attack. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from us.
Our fees and charges are set out on the Website and in the Apps. Please be aware of all costs and charges that apply to you, because such costs and charges will affect your profitability.
Any opinions, news, research, analyses, prices, or other information contained on the Website or in the Apps are provided as general market commentary, and do not constitute investment advice. We shall not be responsible for any loss arising from any investment based on any recommendation, forecast or other information provided.
Past performance is not an indication of future performance. The value of investments can go down as well as up.
All balances related to your Account with us are held in euros which may be different from the currency you used to deposit, accordingly you should be aware of currency fluctuations.