General Risk Disclosure

This document applies to all Services provided via Change Apps. You can access and download a copy of this document at any time from

This notice provides you with information about the risks associated with cryptoasset services provided by Change and investment services provided by Indexa. In this document:

  • “Apps” mean the web, Android and iOS mobile apps of Change, which give access to the Services;
  • “Change” means xChange AS, an Estonian public limited company registered under registry code 14428150, Rävala pst 4, 10143 Tallinn which provides cryptoasset services under virtual currency exchange license no FVR000034 and wallet service provider license no FRK000026 issued by Estonian FIU, and to whom Indexa B.V. relies on to comply with requirements included in the Dutch Wet ter voorkoming van witwassen en financieren van terrorisme and the Santiewet 1977, namely the application of due diligence measures, identification of politically exposed persons and customer data retention, but also customer support;
  • “Indexa” means Indexa B.V. (Chamber of Commerce no. 50755854, previously B.V.), De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands, who provides CFD Trading service on a cross-border basis and is authorised and regulated by the Dutch Authority for the Financial Markets (AFM);
  • We”, “us” or “our” means Change and/or Indexa depending on the specific context.

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, Indexa offers contracts for difference (CFDs) that provide exposure to cryptoassets, stocks, ETFs and 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 Indexa.

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 Indexa 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.

Risks associated with CFDs

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 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. Indexa’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 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, Indexa 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 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.

Risks associated with cryptoasset

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 cryptoasset 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 cryptoasset 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 blockchain is an independent public or private peer-to peer network and is not controlled in any way or manner by us, we shall not be responsible for any failure and/or mistake and/or error and/or breach which shall occur in blockchain or in any other networks in which the cryptoasset 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.

General risks

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.