Last Updated: 10.10.2025
The Custody and Administration Policy (the “Policy”) outlines the description of custody and administration procedures for crypto-assets provided by Odin Pay s.r.o., a company registered in the Czech Republic, registration number 223 56 312 and having its official registered address at Olšanská 54/3 Prague 3 Žižkov 130 00, Czech Republic (the “Company”), as required by the MICA.
1. General Provisions And Odin Pay’s Platform
1.1 The Company provides custody and administration of crypto-assets on behalf of its Customers.
1.2 The relations between Odin Pay s.r.o. and its Customers are governed by the Customer Agreement (the “Customer Agreement”) allocated at the website https://odinpay.eu/ (the “Website”).
1.3 “Odin Pay’s Platform” means the internal software platform of the Company developed based on or linked to various third party software. It allows it to identify, verify and onboard Customers, open account at the Odin Pay’s Platform, initiate Instructions, Orders, make exchanges and store crypto-assets.
1.4 Odin Pay’s Platform is duly protected. The proper protection measures, the risks, and other information security terms and conditions are duly reflected in the Company’s policies and procedures, with oversight provided by the CISO and Risk Manager.
1.5 “Instruction” means a Customer’s request for crypto-assets transfer from a Customer’s crypto-assets safe-kept by the Company to the address provided by a Customer in such a request.
1.6 “Order” means a Customer’s order, being a request to buy or sell a specified quantity of a base asset (funds or crypto-asset) for the counter asset (crypto-asset or funds) at the exchange rate defined by the Company. This is based on the available market information, conditions, other information, and the Company interest fee.
1.7 The Company establishes and maintains the following arrangements to ensure that the crypto-assets of Customers are clearly identified as such within Odin Pay’s Platform and records:
1.7.1 Each Customer’s crypto-assets shall be designated and tagged within Odin Pay’s Platform, clearly distinguishing them from the Company’s own assets or those of other Customers;
1.7.2 A Customer’s crypto-assets shall be segregated in a manner that allows for easy identification and retrieval, ensuring they are not commingled with the Company’s operational crypto-assets;
1.7.3 The Company implements clear processes for the accurate identification and tracking of Customers’ crypto-assets throughout the custody and administration process;
1.7.4 The Company employs appropriate security measures to safeguard the integrity and confidentiality of Customers’ crypto-assets information, preventing unauthorized access. The implementation of these measures is the responsibility of the CISO.
1.7.5 The Company implements other measures.
1.8 The Company segregates holdings of crypto-assets on behalf of its Customers from its own holdings and ensures that crypto-assets of its Customers are clearly identified as such. The Company ensures that, on the distributed ledger, its Customers’ crypto-assets, are held separately from its own crypto-assets. The crypto-assets held in custody are legally segregated from the Company’s estate in the interest of the Customers of the Company, in accordance with applicable law, so that creditors of the Company have no recourse to crypto-assets held in custody by the Company, in particular in the event of insolvency. The Company ensures that the crypto-assets held in custody are operationally segregated from the Company’s estate.
2. Register Of Positions, Movements
2.1 In Odin Pay’s Platform, the Company keeps a register (the “Register”) of positions, opened in the name of each Customer, corresponding to each Customer’s rights to the crypto-assets.
2.2 The Company records as soon as possible in the Register any movements related to Instructions, Orders from the Customers, direct debit and execution of other rights of the Company.
2.3 The Register shall be comprehensive for each Customer, detailing the ownership and corresponding rights to crypto-assets held on behalf of the Customer.
2.4 The Register identifies each Customer, accurately reflects the Customer’s holdings and rights to each type of crypto-assets under custody and administration.
2.5 The Company ensures that any movement affecting the registration of the crypto-assets is evidenced by a transaction regularly registered in the Register.
2.6 Upon receiving Instructions, Orders from Customers regarding movements or transactions involving their crypto-assets, the Company shall promptly record such movements in the Register (but only if there are no grounds for such Instructions, Orders rejection, suspension, annulment, putting on hold or non-processing for any grounds).
2.7 Movements or transactions affecting the crypto-assets balances shall be documented and evidenced through transactions regularly registered in the Register.
2.8 Accuracy in recording movements or transactions in the Register shall be maintained at all times, with measures in place to reconcile discrepancies promptly.
2.9 Any errors or discrepancies identified in the Register shall be rectified without delay. The Management, Compliance Officer, and Risk Manager are responsible for ensuring that appropriate corrective measures are implemented to prevent recurrence.
2.10 The Company provides its Customers, at least once every three months and at the request of the Customer concerned, with a statement of position of the crypto-assets recorded in the name of those Customers. That statement of position shall be made in an electronic format. The statement of position shall identify the crypto-assets concerned, their balance, their value, and the transfer of crypto-assets made during the period concerned.
3. Liability For Loss Of Customers’ Crypto-Assets
3.1 The Company bears liability to its Customers for any loss of crypto-assets resulting from incidents attributable to the Company.
3.2 The liability of the Company for such losses shall be limited to the market value of the crypto-assets at the time the loss occurred, as determined by prevailing market rates. The source (liquidity provider entity) of the rates definition is chosen by the Company.
3.3 Customers shall be entitled to compensation up to the capped liability amount for losses incurred due to incidents attributable to the Company.
3.4 Such incidents may include, but are not limited to, problems inherent in the operation of distributed ledgers that the Company does not control, or events beyond the reasonable control of the Company:
3.4.1 Security breaches or cyberattacks targeting Odin Pay’s Platform or infrastructure, despite measures enforced by the CISO;
3.4.2 Failures or malfunctions in the Company’s custody and administration processes;
3.4.3 Unauthorized access or misuse of a Customer’s crypto-assets or assets by the Company personnel or persons engaged by the Company, with investigations overseen by the AML Officer and Compliance Officer;
3.4.4 or other events within the control of the Company.
3.5 Incidents not attributable to the Company include any event in respect of which the Company demonstrates that it occurred independently of the provision of the relevant service, or independently of the operations of the Company.
3.6 Such incidents may include, but not limited to:
3.6.1 Problems inherent in the operation of distributed ledgers that the Company does not control;
3.6.2 Natural disasters, acts of wars, riots, other force majeure events;
3.6.3 Regulatory changes or actions beyond the Company’s control affecting the crypto-assets market;
3.6.4 Incident occurred because of actions or omissions of a Customer;
3.6.5 Incident occurred as a result of a Customer’s fraud or fraudulent misrepresentation, or any obligations prescribed by the law;
3.6.6 or other events beyond the reasonable control of the Company.
3.7 In the event of an incident deemed not attributable to the Company, the Company shall not bear liability for resulting losses incurred by a Customer.
3.8 The Company collaborates with Customers that they could provide timely notification and cooperation in the investigation of incidents. The Compliance Officer and Legal Department facilitate the determination of liability and appropriate recourse.
4. Customers’ Rights Attached To Customers’ Crypto-Assets
4.1 When Customers keep their crypto-assets at the Company, they are granted with the following rights associated with their crypto-assets:
4.1.1 Right to transfer or exchange own crypto-assets with other Customers of the Company, with the Company;
4.1.2 Right to obtain information about the current general status or activity related to the Company;
4.1.3 Right to compensation for losses or compensation in case of loss or unavailability of crypto-assets, only in case of the incident occurrence within the Company’s control;
4.1.4 Other similar rights.
4.2 When Customers keep their crypto-assets at the Company, they are not granted with the following rights associated with their crypto-assets:
4.2.1 Right to receive dividends or other income, its share of the Company;
4.2.2 Right to participate in voting or decision-making, governing processes in the Company;
4.2.3 Rights to participate in the distribution of the Company’s own assets;
4.2.4 Rights within derivative transactions;
4.2.5 Similar rights.
4.3 The Company provides their Customers as soon as possible with any information about operations on crypto-assets that require a response from those Customers.
5. Return Of Crypto-Assets
5.1 Upon request from the Customer, the Company initiates the process for the return of crypto-assets without undue delay.
5.2 The grounds of crypto-assets return could be related to relations termination by the Customer or the Company, or just transfer of crypto-assets from the Customer’s crypto-assets safe-kept by the Company to her/his own external crypto-assets address.
5.3 In case of relations termination with a Customer, if a positive crypto-assets balance remains safe-kept by the Company, the Company is entitled to close the Customer’s account with Odin Pay’s Platform. It can also transfer and keep the Customer’s crypto-assets separately until receipt of the Customer’s instructions on their transfer to the address provided by such Customer.
5.4 The Company ensures that the return process is executed efficiently and securely, employing appropriate authentication and verification measures to safeguard a Customer’s crypto-assets and privacy. The CFO and COO manage the operational execution.
5.5 Any delay in returning crypto-assets beyond reasonable timeframes shall be promptly communicated to the Customer, along with the reasons for such delay and an estimated timeline for resolution, safe for cases when AML/CTF requirements require otherwise. The AML Officer, Compliance Officer, and Legal Department monitor compliance with AML/CTF requirements.
5.6 In the event of termination or discontinuation of services, the Company expedites the return of crypto-assets to Customers, prioritizing the protection and preservation of Customer crypto-assets.