Summary Of Transfer Services For Crypto-Assets Policy

Last Updated: 10.10.2025
Effective Date: 17.10.2025

This Transfer Services for Crypto-Assets Policy Summary (the “Policy”) is developed 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”).

1. Procedure for Determining the Time of Receipt of an Instruction or Consent to a Transfer of Crypto-Assets and Applicable Cut-Off Times.

1.1 The Company has implemented the following procedure to determine the time of receipt of an instruction or consent regarding the transfer of crypto-assets:

1.2 Time of Receipt:

1.2.1 The time of receipt of an instruction or consent is defined as the exact time at which the Company’s platform confirms successful submission of the instruction or consent by the Customer.
1.2.2 The confirmation of submission shall be evidenced by a system-generated timestamp, recorded automatically in Central European Time (CET or CEST, as applicable).
1.2.3 An instruction or consent is considered valid only upon full authentication and successful technical validation (including but not limited to two-factor authentication, electronic signatures, or any additional security requirements). Technical validation is overseen by the CTO and CISO.

1.3 Cut-Off Time:

1.3.1 The standard daily cut-off time for the receipt and same-day processing of instructions and consents is 18:00 CET/CEST.
1.3.2 Instructions or consents received after 18:00 CET/CEST are deemed to have been received on the next business day and will be processed accordingly.

1.4 Business Days Definition:

1.4.1 Business days are defined as Monday to Friday, excluding official public holidays recognized in the Czech Republic.
1.4.2 Instructions or consents received on weekends (Saturday or Sunday) or public holidays are considered received on the next available business day.

1.5 Technical Failures and Exceptional Circumstances:

1.5.1 In the event of technical failures, system maintenance, or force majeure events affecting the timely receipt of instructions, the Company reserves the right to adjust the time of receipt, following procedures established by the CTO and Risk Manager.
1.5.2 Customers will be informed promptly of any such delays through official communication channels (e.g., email notifications, system alerts).

1.6 Record-Keeping:

1.6.1 All records of instruction submissions, including time of receipt, authentication logs, and transaction metadata, are securely stored for a minimum period of eight (8) years, in compliance with applicable regulatory requirements. The CISO is responsible for ensuring the technical security of these records.

1.7 User Notification:

1.7.1 Customers receive an automated confirmation notice indicating the time and status of receipt after submitting an instruction or consent.
1.7.2 Any discrepancies identified by the Customer must be reported to the Company’s support team within 24 hours of receipt of the confirmation notice. The Management ensures that the support team coordinates with the Compliance Officer and Risk Manager for investigation.

2. Technical Parameters for Crypto-Asset Transfers

2.1 The information provided aims to ensure transparency regarding the expected processing times, network-specific characteristics, and settlement assurances associated with crypto-asset transfers. Please refer to the table below for detailed information applicable to each supported crypto-asset.

2.2 The key technical parameters associated with the transfer of supported crypto-assets through our Service:

* Each supported blockchain network defines its own confirmation rules and consensus mechanisms (e.g., Proof of Work, Proof of Stake, or Byzantine Fault Tolerance).
The custody system identifies the finality of a transaction through the blockchain’s native confirmation process. Once the required number of confirmations, as defined by the network protocol, has been reached, the transaction is considered final and irreversible.
The Organisation relies on the custody provider’s monitoring infrastructure, which continuously tracks the number of confirmations on the relevant mainnets according to the parameters defined in the provider’s technical documentation (e.g., Confirmation Delay).

The custody system identifies the finality of a transaction through the blockchain’s native confirmation process. Once the required number of confirmations, as defined by the network protocol, has been reached, the transaction is considered final and irreversible.

The Organisation relies on the custody provider’s monitoring infrastructure, which continuously tracks the number of confirmations on the relevant mainnets according to the parameters defined in the provider’s technical documentation (e.g., Confirmation Delay).

Final settlement status is therefore determined automatically, based on the technical rules of each blockchain and its consensus layer. These mechanisms ensure the integrity and non-repudiation of transactions prior to updating client balances within the custody system.

For operational clarity, the number of confirmations required for each supported asset and network is defined herein.

2.3 Transaction execution time and the number of confirmations may vary depending on network load and the policies of specific platforms.

2.4 The debit value date for the Customer’s crypto-assets address is no earlier than the time at which the amount of the transfer is debited to that crypto-assets address.

2.5 The execution times could be postponed if the proper process is required by the AML/CFT policies and procedures of the Company, as enforced by the AML Officer.

2.6 Customers could not revoke an instruction it has been received by the Company, unless otherwise specified in this Policy and/or the Customer Agreement.

2.7 Where the transfer is initiated by the Company, in case of contractual debiting under the Customer Agreement among them, the Customer shall not revoke such debiting after acceptance of the Customer Agreement or giving consent to the Company to initiate the transfer.