UAB Teroxx Worldwide (The Company) prime goal is to properly safekeep and custody its customers’ crypto-assets and funds when providing crypto-asset services. At all times the Company’s customers crypto-asssets and funds are segregated from its own crypto-assets and funds. This segregation is achieved by implementing the following measures:

1. Common measures applicable to safekeep and custody customers’ crypto-assets and funds:

• Information and Accounting Systems - the information and accounting systems used by the Company enable it at any time and without delay to distinguish the assets held for one customer from the assets held for any other customer and from the Company’s own assets.
• Record-keeping - the Company’s records and accounts are maintained in a way that ensures their accuracy, in particular by ensuring the accuracy and correctness of records of crypto assets and funds held for the customers, thus enabling audit procedures to be carried out properly.
• Organisational Arrangements - the Company’s organizational arrangements minimize the risk of loss or diminution of customers’ assets or of rights in connection with those assets as a result of their misuse, fraud, poor administration, inadequate record-keeping or negligence.

2. Measures applicable to safekeeping and custody of customers’ crypto-assets:

• Crypto-assets Segregation - the Company is taking following steps to ensure that customers’ crypto assets are separately identifiable:
  • Operational Segregation – the Company has established and maintains a register of positions, opened in the name of each customer, corresponding to each customer’s rights to the crypto-assets. The Company maintains an internal ledger system that records the allocation of assets to each customer, ensuring accuracy and transparency, as well as recording as soon as possible any movements of crypto-assets following instructions from the customers.
  • Technological Segregation - the Company ensures that on the distributed ledger, customers’ crypto-assets are held separately from the Company’s’ crypto-assets. This is achieved by using different blockchain addresses to hold customers and the Company’s own crypto-assets. Customers’ crypto-assets are held in omnibus wallets dedicated for each type of crypto-asset separately. The Company provides each customer with a deposit wallet, for each type of crypto-asset supported by the Company. The company safekeeps cryptographic keys of crypto-assets belonging to customers and issues the customers with separate security credentials to access their crypto-assets wallets. Company’s own crypto-assets are held in distinct wallets with internal systems maintaining precise records of Company’s holdings;
  • Legal Segregation - custodial crypto-assets are legally segregated from the estate of the Company. The desired effect of this segregation is that in insolvency, creditors of the Company have no recourse to crypto-assets held in custody.
    
    
• No Reuse of Customers’ Crypto-assets - the Company ensures that crypto-assets belonging to customers are not pledged or otherwise used for its own or any other third party account.
• Quarterly Statements - The Company will provide their customers at least quarterly statements detailing the crypto-assets registered in their name.
• Cold Storage - In order to avoid the risk of a loss of Company's and its customers’ crypto-assets due to cyber threats (unauthorized access or theft), the Company will hold 70% of its own and its customers’ assets in a separate Cold Storage System, which will be disconnected from the internet. Cold Storage System will have the same set-up of segregated Company’s and its customers’ crypto-asset wallets, meaning that there will be segregated Company own crypto-assets wallet, segregated customers’ omnibus wallets dedicated for each type of crypto-asset separately and each customer separate wallets, for each type of crypto-asset.

3. Measures applicable to customers’ funds:

• Funds Segregation - the Company is taking all necessary steps to ensure that customer funds held with a Credit Institution are held in an account or accounts identified separately (dedicated customers’ omnibus account) from any accounts in which the Company’s funds are held. Before selecting a Credit Institution, the Company exercises a thorough due diligence of that Credit Institution.
• No Reuse of Customers’ Funds - the Company ensures that funds belonging to the Company’s customers are not pledged or otherwise used for the Company’s or any other third party account. The Company safeguards customers’ funds on a fiduciary basis and ensures that no enforcement of recovery of the Company’s debts would be made from those funds.
• Reconciliation - the Company is conducting, on a daily basis, reconciliations between the Company’s internal accounts and records and Credit Institution who hold the customers’ funds;

Credit Institutions with which the customers’ funds are safeguarded do not act as fiduciaries of the Company’s customers. Thus, a Credit Institution opens a regular payment account for the benefit of the Company’s customers and has a right to use the customers’ funds.

In the event of such a Credit Institution’s bankruptcy, the customers’ funds would be included in the total mass of Credit Institution’s assets, from which the claims of all creditors of a Credit Institution (including the Company’s customers) would be fulfilled. This means that all customers’ funds held with a Credit Institution may be lost in case of bankruptcy of the respective Credit Institution.