Terms of Service

December 3, 2025

PART A

1. General

1.1. These terms and conditions (“Terms”) govern the Customer’s use of the services provided by GOOBIT AB, corporate registration number 556911-9992, Kivra: 556911-9992, 106 31 Stockholm, Sweden (“GOOBIT” or the “Company”) through the website bt.cx (“BTCX”).

1.2. These terms consist of the following parts:

  1. Part A - General Terms,
  2. Part B - Policy for Exchange Services.

1.3. By using the Services, the Customer accepts these Terms. If the Customer does not accept the Terms, the Services may not be used.

1.4. GOOBIT operates in accordance with MiCA and applicable laws, including the Swedish Act (2017:630) on Measures Against Money Laundering and Terrorist Financing and Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto assets. The Swedish Financial Supervisory Authority (Finansinspektionen) is the competent supervisory authority. Until authorization as a crypto asset service provider has been granted, GOOBIT operates under the transitional provisions set out in Article 143 of MiCA.

1.5. GOOBIT provides two categories of services through BTCX (“Services”):

  1. (i) services that do not require registration (“Unregistered Services”), which are provided via BTCX Express, and
  2. (ii) services that require registration and an account with GOOBIT (“Registered Services”), which include BTCX Standard and OTC.

All Services are subject to these Terms, and by using the Services, the Customer agrees to be bound by them.

2. Definitions

For the purposes of these Terms:

“Customer” or “You” – the natural or legal person who enters into an agreement with GOOBIT for the provision of the Services.

“Services” – all services provided by GOOBIT from time to time through BTCX, including Registered Services, such as Exchange Services.

“Registered Services” – the Services that require registration and the creation of an account with GOOBIT, i.e., BTCX Standard and OTC.

“Unregistered Services” – the Services that do not require registration or an account with GOOBIT, i.e., BTCX Express.

“Exchange Services” – services for the exchange of crypto assets into fiat currency, or crypto assets into other crypto assets, available via BTCX Express, BTCX Standard, and OTC.

“Crypto asset” – a digital representation of value or rights that can be transferred and stored electronically using distributed ledger or similar technology and that falls within the scope of MiCA.

“Fiat currency” – legal tender recognized by a state, such as Swedish kronor (SEK) or euros (EUR).

“User Account” or “Account” – the account created by the Customer with GOOBIT to access the Registered Services.

“Fees” – the prices and charges applied by GOOBIT for the Services according to the current price list available at bt.cx.

“KYC” or “Customer Due Diligence” – the identification and verification measures carried out by GOOBIT in accordance with applicable legislation on anti-money laundering and counter-terrorist financing.

2. Registration and Verification

2.1. To access the Registered Services, the Customer must register and create an account on BTCX and be verified by GOOBIT. In order to comply with applicable legislation on anti-money laundering and counter-terrorist financing, GOOBIT is required to collect specific information from its Customers. Accordingly, GOOBIT has a legal obligation to verify the Customer’s identity and/or ownership structure and, where applicable, to verify the origin of funds and other assets. GOOBIT may therefore request information regarding the Customer’s identity, residence, and assets, as well as supporting documentation. If the Customer is a legal entity, GOOBIT may require information about the entity itself and about the individual(s) controlling it (including but not limited to a certificate of registration, share register, and information on the registered beneficial owner).

2.2. All information and documentation received by GOOBIT will be retained in accordance with applicable legislation. GOOBIT will always comply with laws and regulations concerning anti-money laundering and counter-terrorist financing. Under such legislation, GOOBIT is obligated to take appropriate measures and report any suspicion of money laundering or terrorist financing to the Police. GOOBIT is prohibited from informing the Customer if such a suspicion arises.

2.3. After registration, the Customer will be notified by email whether the verification process has succeeded or failed. The Customer is responsible for providing accurate and truthful information to GOOBIT. The Customer is also responsible for keeping the account password and other account credentials confidential. The Customer understands and agrees to immediately notify GOOBIT if their BTCX account has been, or may have been, compromised.

2.4. By accepting these Terms, the Customer warrants that the information provided to GOOBIT is accurate and truthful. Providing false or fraudulent information and/or using the Services for fraudulent purposes is strictly prohibited and constitutes a material breach of these Terms.

2.5. Registered Services may only be used by registered and verified Customers. If, due to technical issues or unauthorized actions by a third party, an unregistered Customer gains access to the Registered Services, the Customer must immediately:

  1. (i) refrain from using such services or information,
  2. (ii) treat all such information as confidential and as the property of GOOBIT, and
  3. (iii) promptly notify GOOBIT of the incident.

Any unauthorized use or dissemination of such information is strictly prohibited.

3. Use of the Services

3.1. General

3.1.1. By using the Services and thereby accepting these Terms, the Customer agrees and warrants that neither personally nor through any third party will they:

  1. Modify, dismantle, decode, decompile, or reverse engineer any part of BTCX and/or the Services, unless expressly permitted by law or authorized by GOOBIT,
  2. Distribute or reproduce all or part of BTCX and/or the Services,
  3. Use BTCX and/or the Services to transmit or upload data files or any other content that contains or consists of viruses, trojans, corrupted data, malicious software, or other programs that may harm computers, software, servers, data, or other property,
  4. Use BTCX and/or the Services to solicit or encourage other users to violate these Terms,
  5. Misuse BTCX and/or the Services or use them for any illegal or otherwise unauthorized purpose,
  6. Be resident outside the European Economic Area (EEA), which includes all EU member states as well as Norway, Iceland, and Liechtenstein. Please note that the United Kingdom is not part of the EEA and Customers residing there are therefore not permitted to use the Services.

3.2. Purchasing Crypto Assets

3.2.1. Due to applicable legislation regarding the prevention of money laundering and terrorist financing, as well as GOOBIT’s internal policy, there are limits governing both the number of transactions that may be conducted through the Services and the amounts that may be transferred per transaction. In this regard, the Customer agrees to comply with the limits in force on BTCX at any given time. These limits may be amended by GOOBIT and may vary from time to time.

3.2.2. Through the Services, the Customer is offered the opportunity to purchase crypto assets available via BTCX. To purchase crypto assets, the Customer must obtain and be responsible for one or more wallets (so-called “Wallets”) provided by third parties. GOOBIT is not responsible for the quality or security of wallets provided by third parties. The Customer may be required to accept the third party’s terms of use when obtaining a wallet.

3.2.3. The Customer is solely responsible for keeping their wallet password confidential. GOOBIT does not store the Customer’s passwords, and such passwords cannot be recovered. If a wallet password is lost, the Customer will irrevocably lose access to their wallet, and GOOBIT cannot restore the wallet or its contents. GOOBIT recommends that the Customer never shares their password with any third party and ensures that the password is sufficiently complex to prevent it from being guessed.

3.2.4. The Customer is only permitted to carry out transactions in crypto assets to their own wallet, which they personally can access and control, or to a third-party custodial wallet that is controlled by the Customer.

3.2.5. In the event of misuse or suspected misuse of a wallet, the Customer must immediately notify GOOBIT via BTCX’s support function. GOOBIT has the right, in case of suspected misuse, to block the account in order to protect the Customer and their assets. GOOBIT is liable for any damage arising from unauthorized access caused by GOOBIT’s negligence or technical failure. This condition does not limit the Customer’s rights under mandatory consumer protection laws.

3.3. Selling Crypto Assets

3.3.1. When the Customer uses the BTCX sell function – meaning that the Customer sells crypto assets in exchange for fiat currency (for example, SEK or EUR), which is then transferred to the Customer’s bank account – the Customer must create an account on BTCX and verify their identity in accordance with these Terms.

3.3.2. Customers wishing to sell crypto assets may be subject to verification and may be asked to provide documentation regarding the origin of funds or assets, in accordance with Section 2 above.

3.3.3. In order for the Customer to use the sell function, the Customer’s bank account must be verified. The Customer is only permitted to receive fiat payments to their own bank account. The Customer may be required to submit documentation proving ownership of the bank account before fiat funds are transferred.

3.3.4. The exchange of assets is carried out in accordance with the applicable exchange rate at the time BTCX receives the crypto assets that the Customer wishes to sell. This applies regardless of whether the prevailing exchange rate has risen or fallen during the period between the transfer of the crypto assets to BTCX and the payment of fiat currency to the Customer. It also applies regardless of whether any delay in payment has occurred, and irrespective of whether such delay was caused by the Customer or by BTCX, as well as regardless of the length of such delay.

3.4. Refunds

3.4.1. Refund of completed orders
For a processed and completed order where crypto assets have been transferred, no refund can be made. This is due to the irreversible nature of blockchain transactions.

3.4.2. Refunds for purchases of Bitcoin
Fiat funds that have been transferred cannot be refunded.

3.4.3. Refunds for sales of Bitcoin
Crypto assets that have been transferred cannot be refunded.

3.4.4. Orders halted for regulatory reasons or lacking sufficient information to be processed cannot be refunded after two years. After this period, the transaction shall be considered final, and no further action can be taken to restore the payment. The Customer thereby loses the right to claim a refund or request correction of any errors related to the transaction.

3.5. Payment and Pricing

3.5.1. The Customer may pay for the purchase of crypto assets using the payment methods specified on BTCX. GOOBIT may engage third-party companies or other entities within its corporate group to enable the Customer to make payments for the use of the Services. To complete a payment, the Customer may therefore be required to accept the terms and conditions of such third-party companies. GOOBIT may transfer information provided by the Customer through their use of the Services on BTCX to such third-party companies to allow them to perform preliminary assessments of the information for the purpose of determining whether the Customer is eligible to use their services (including the Customer’s transaction history on BTCX).

3.5.2. GOOBIT may also, through such third-party companies, obtain personal information about the Customer in order to ensure GOOBIT’s compliance with legal requirements regarding anti-money laundering and counter-terrorist financing, including the origin of funds and the Customer’s payment patterns. By accepting these Terms, the Customer consents to GOOBIT obtaining such information through third-party companies.

3.5.3. By transferring funds to GOOBIT, the Customer confirms the requested transaction. Before such confirmation, the Customer may cancel the transaction. The Customer acknowledges that the price of the crypto asset will be determined at the time GOOBIT approves the transaction from GOOBIT to the Customer.

3.5.3A Time for Contract Formation
An agreement for the purchase of crypto assets shall be deemed concluded and binding upon both parties at the time the Customer confirms the purchase in the BTCX system and initiates the payment to GOOBIT.
From that moment, the Customer is obligated to complete the transaction in accordance with these Terms, regardless of when the payment is received by GOOBIT, provided that the Customer’s identity and the transaction comply with applicable legal requirements as well as GOOBIT’s procedures for customer due diligence, anti-money laundering, and regulatory compliance.
The final exchange rate and settlement of the transaction shall be carried out in accordance with GOOBIT’s then-current Exchange Services Policy (Part B).

3.5.4. After the Customer has confirmed the transaction, GOOBIT may cancel the transaction up until the moment the transfer of funds from the Customer has been registered in GOOBIT’s account. Once payment has been received by GOOBIT from the Customer, the transaction is deemed completed and can no longer be cancelled. If the Customer fails to make payment within seven (7) days from confirmation, the transaction will automatically be cancelled. The Customer may cancel the transaction after confirmation only if the crypto assets have not yet been made available to the Customer by GOOBIT. In the event of such cancellation, the Customer shall pay an administrative fee in accordance with Section 3.5.8.

3.5.5. GOOBIT will process a purchase transaction until full payment has been received and shall thereafter promptly transfer the crypto assets purchased by the Customer to the wallet address provided by the Customer.

3.5.6. The Customer is solely responsible for providing a correct wallet address to GOOBIT. GOOBIT shall not be liable for any loss or damage of any kind resulting from the Customer providing an incorrect wallet address.

3.5.7. GOOBIT will issue an invoice if crypto assets have been transferred but payment has not been received. In the event of non-payment, GOOBIT has the right to charge the Customer a reminder fee of SEK 60 for consumers and SEK 450 for other Customers. GOOBIT also has the right to charge default interest of 20% plus the applicable reference rate until full payment has been made.

3.5.8. GOOBIT is entitled to charge Customers an administrative fee corresponding to GOOBIT’s additional costs in cases where the Customer fails to fulfil their obligations under this agreement.
Such failure to fulfil obligations may include, but is not limited to:

  1. Payment of an incorrect amount of crypto assets when selling to GOOBIT.
  2. The Customer transferring crypto assets from a wallet address belonging to another person or from an address that has engaged in transactions with sanctioned addresses.
  3. The Customer cancelling a payment transaction or carrying out a card transaction that results in insufficient funds being available at the time of payment.
  4. Providing an incorrect wallet address, where GOOBIT has undertaken work to recover incorrectly paid-out crypto assets.

3.6. Client Funds and Administrative Fees

3.6.1. In the event that GOOBIT receives funds that cannot be linked to a specific account or transaction, or where processing is halted due to a lack of necessary information from the Customer, such funds must be claimed by the Customer within two years. If the Customer does not claim the funds within this period, they will be forfeited to GOOBIT. Furthermore, GOOBIT reserves the right to charge an administrative fee of EUR 100 to facilitate the tracing and recovery of lost transactions and funds. This fee covers the administrative efforts required to handle such incidents and is intended to maintain the integrity and efficiency of our transaction processing.

4. Information on the Platform

4.1. GOOBIT may publish information on BTCX relating to crypto assets, market events and analyses, announcements concerning BTCX’s operations, publications by third parties (published with the author’s consent or under a royalty-free licence), and similar content.

4.2. In addition, GOOBIT provides information on BTCX regarding the exchange rates of crypto assets and GOOBIT’s own assessment of such exchange rates (which are used in transactions conducted through BTCX). GOOBIT may also obtain such information from third parties.

4.3. GOOBIT’s own assessments of exchange rates are calculated using proprietary methods. GOOBIT reserves the right to amend these methods at any time.

4.4. Copies of GOOBIT’s own publications may be republished, copied, and distributed. Such copies must clearly state the source of the publication (bt.cx), the author (if indicated in the original), and must not be used in any way that could cause loss or damage to GOOBIT, whether financial or to GOOBIT’s brand. Republication of GOOBIT’s evaluations of crypto asset exchange rates for comparison purposes may only take place with GOOBIT’s prior consent. Any further republication or use of the information mentioned herein requires GOOBIT’s consent, unless otherwise expressly stated above.

4.5. If the Customer becomes aware of any content that is incorrect, offensive, or in violation of these Terms, the Customer should immediately report this to BTCX via [email protected]. GOOBIT reserves the right to remove content at any time if deemed necessary. GOOBIT is not liable for any loss or damage resulting from decisions made based on information published on BTCX.

5. Intellectual Property Rights

5.1. The Customer acknowledges that BTCX and the Services contain information specifically provided by GOOBIT or third parties, and that such information may be protected by intellectual property rights.

5.2. The Customer undertakes to respect all intellectual property rights, including but not limited to copyrights, trademarks, and distinctive business names, whether registered or unregistered, that appear on BTCX or are otherwise made available to the Customer through the use of the Services.

5.3. The Customer may only use the content on BTCX for personal use of the Services and may not use such content in violation of applicable law or these Terms.

5.4. GOOBIT does not grant the Customer any licence or other right to use any intellectual property rights beyond what is expressly stated in these Terms.

5.5 The Customer acknowledges that parts of the content displayed on BTCX may be provided by third parties. GOOBIT is responsible for ensuring that content provided by third parties is clearly identified as such. GOOBIT is responsible for information published for marketing purposes or where GOOBIT could reasonably be expected to have verified its accuracy.

5.6. Republishing, copying, distribution, or any other use of content is subject to legislation concerning intellectual property rights and, as a general rule, requires contact with the copyright holder in each individual case unless otherwise explicitly stated.

6. Disclaimer of Liability

6.1. GOOBIT provides the Services and BTCX “as is,” and the Customer’s use of the Services and BTCX is at their own risk. GOOBIT strives to maintain high operational reliability and strong protection of the Customer’s information and assets. GOOBIT does not provide any warranties regarding the availability or accuracy of BTCX or the content published there, but is liable for any damages arising from GOOBIT’s negligence or carelessness in accordance with applicable law.

6.2. GOOBIT performs regular upgrades which may result in temporary downtime. GOOBIT may carry out maintenance or make changes to the Services as needed and at times determined by GOOBIT, which may lead to the Services being temporarily unavailable for limited periods. GOOBIT will, to the extent possible, announce such unavailability in advance. However, GOOBIT is not obligated to make such announcements and is not liable for any loss or damage resulting from the Services or BTCX being unavailable.

6.3. Should the Services become inoperable, GOOBIT shall, as soon as possible, notify the Customer through all available means of communication regarding the measures being taken and the expected time for the restoration of the Services.

6.4. If the Services remain inoperable for a period longer than seven (7) business days, GOOBIT shall consult with the Customer regarding the withdrawal of funds from unprocessed transactions.

7. Changes to the Services or the Terms

7.1 GOOBIT reserves the right, at any time and at its sole discretion, to amend these Terms. The Customer will be informed of any changes at least 30 calendar days before they take effect. Information about the changes will be provided by email or through other clear means of communication. The Customer will be given the opportunity to review and accept the new terms before continuing to use the Services. If the Customer does not accept the changes, the Customer has the right to terminate their use of the Services.

7.2. GOOBIT updates the exchange rate for crypto assets available on BTCX at intervals determined by GOOBIT. GOOBIT reserves the right, at any time, to unilaterally change these intervals, cease updating exchange rates, or remove them entirely.

7.3. If any provision or part of a provision of these Terms is declared invalid, this shall not render the Terms as a whole invalid. Instead, to the extent that the invalidity materially affects either party’s performance or rights under the Terms, a reasonable adjustment shall be made. The remaining parts of the Terms shall remain fully valid and enforceable against the Customer.

8. Limitation of Liability

8.1. The Customer is solely responsible for all actions taken through their account on BTCX. GOOBIT is not responsible for any content published on BTCX by a Customer.

8.2. To the extent permitted by mandatory law, GOOBIT shall not be liable to the Customer or any third party for any direct or indirect damages or any other losses of any kind, including but not limited to loss of profit, loss of income, loss of return, business interruption, or loss of goodwill, arising out of or in connection with these Terms and/or the use of, or inability to use or access, the Services or BTCX. GOOBIT has no obligation to satisfy any claims or other obligations that third parties may assert against the Customer.

8.3. GOOBIT assumes no responsibility for third-party products or services used in connection with the Services, including but not limited to the use of third-party wallets.

9. Indemnification

9.1. By accepting these Terms, the Customer acknowledges that they are liable to GOOBIT for any damage caused to GOOBIT or any third party as a result of the Customer’s breach of the Terms, including but not limited to misuse of BTCX and/or the Services. The Customer also agrees to indemnify and hold GOOBIT harmless from any claim, cost (including reasonable legal fees), damage, expense, liability, or loss arising from the Customer’s breach of these Terms.

10. Duration

10.1 These Terms shall remain in effect until further notice between GOOBIT and the Customer. Both parties have the right to terminate the agreement by giving the other party 30 days’ prior notice. The Customer may terminate their account by notifying GOOBIT in a clear and traceable manner, for example via email, contact form, or any other communication channel provided by GOOBIT. GOOBIT shall confirm receipt of the termination notice in writing.

10.2. The Customer is obligated to pay all fees for the Services during the period in which the agreement remains in effect. Termination of the agreement between GOOBIT and the Customer constitutes a complete cessation of all obligations set out in these Terms.

10.3. All rights held by GOOBIT under these Terms shall, however, remain in effect after the agreement has been terminated.

10.4. The Customer’s account with GOOBIT will be blocked once the agreement has been terminated.

11. Breach of Agreement / Early Termination

11.1. GOOBIT may, at any time and with immediate effect, terminate these Terms — constituting the agreement between GOOBIT and the Customer — if the Customer has committed a material breach of contract, otherwise failed to fulfil their obligations under these Terms, or taken any action or measure that has caused GOOBIT loss or damage.

11.2. In the event of a material breach by the Customer, GOOBIT reserves the right to investigate violations of the Terms and take appropriate measures, including but not limited to blocking the Customer’s account on BTCX, reporting suspected illegal activities to the authorities in Sweden or in the Customer’s country of residence, and disclosing any information necessary or appropriate to such authorities regarding the Customer’s account, profile, email address, registered address, crypto asset wallet, and transaction history that the authorities may require for their investigation.

11.3. The Customer’s account on BTCX may also be blocked upon request from a competent authority.

11.4. A blockage of the Customer’s account on BTCX may be lifted at any time if the reason for the blockage no longer exists or is deemed no longer relevant.

12. Language

12.1. These Terms, as well as information about the Services, are provided in both English and Swedish. The English version is available to the Customer on BTCX. In the event of any discrepancy or conflict between the language versions, the English version shall prevail. All other communication from GOOBIT shall be conducted in English or Swedish.

13. Dispute Resolution

13.1. These Terms are governed by and shall be interpreted in accordance with the laws of Sweden. Any dispute, claim, or controversy arising out of or in connection with these Terms shall be finally settled by a Swedish court.

13.2. Customers who are consumers when using the Services may contact the National Board for Consumer Disputes (Allmänna Reklamationsnämnden, ARN) to have a dispute with GOOBIT reviewed.

14. Privacy and Cookies

14.1. The processing of personal data and the use of cookies are governed by GOOBIT’s Privacy Policy, available at https://bt.cx/en/privacy-policy/.

14.2. By using the Services, the Customer confirms that they have read and understood the Privacy Policy.



PART B

Policy for Exchange Services

1. Purpose and Scope

This Execution Policy (the “Policy”) applies to GOOBIT AB’s (“GOOBIT” or “the Company”) exchange services provided via BTCX (bt.cx), namely BTCX Express, BTCX Standard, and OTC (collectively, the “Services”). The Policy has been adopted by GOOBIT’s Board of Directors.

When providing exchange services for crypto assets to Customers, GOOBIT may act in different capacities. GOOBIT may either exchange crypto assets with Customers against its own inventory of crypto assets or fiat currency, or execute orders for crypto assets on behalf of Customers.

This Policy sets out the rules applicable to orders where GOOBIT trades with the Customer on its own account, that is, the exchange of crypto assets for funds through the use of its own capital, in accordance with Article 77 of Regulation (EU) 2023/1114 on Markets in crypto assets (“MiCA”). The Policy further aims to ensure that GOOBIT AB fulfils its obligations under Article 78 of MiCA and describes how GOOBIT takes all necessary measures to achieve the best possible result for Customers when executing orders for crypto assets on behalf of Customers. This Policy also includes a non-discriminatory business policy specifying the types of Customers with whom GOOBIT agrees to conduct transactions and the conditions that such Customers must meet.

GOOBIT does not transmit orders for crypto assets on behalf of Customers to third parties; GOOBIT always executes orders on behalf of Customers in cases where the exchange of crypto assets with the Customer does not occur against the Company’s own inventory.

The Policy also applies to GOOBIT’s employees, including consultants and contractors.

2. Customer Consent and Acceptance Criteria

Before any order is executed, the Customer is informed of this Policy as part of GOOBIT’s Terms of Use. The Customer provides their consent to the Policy by using the Services and/or creating a user account for the BTCX Standard service, that is, before the Company carries out any transaction with the Customer.

GOOBIT provides the Services to individuals and legal entities that:

  1. comply with and accept GOOBIT’s Terms of Use as well as the Company’s requirements regarding Customer Due Diligence (CDD), anti-money laundering, and other relevant regulatory requirements;
  2. are authorised to conduct business within their geographical area;
  3. are not subject to sanctions or other types of restrictive measures; and
  4. have their residence or registered office in a geographical area where the Company provides the Services from time to time.

have their residence or registered office in a geographical area where the Company provides the Services from time to time.

3. Fees

GOOBIT charges a service-based fee for the use of the Services in the form of a spread, which includes all transaction costs and fees, and the Customer is informed of the size of the spread before the order is confirmed. Information about GOOBIT’s current pricing and fees is available on the Company’s website: bt.cx/en/fees.

In the order flow, the Customer is presented with an estimated exchange rate, which is an estimation of the amount of fiat or crypto assets the Customer will receive upon settlement of the transaction. The Customer accepts the estimated exchange rate by placing the order, and the final exchange rate is determined once GOOBIT has received payment and the Company’s acceptance criteria have been met.

When GOOBIT executes a Customer’s order against its own inventory by providing the crypto asset service of exchanging crypto assets for funds, the same requirements for achieving the best possible result for the Customer apply as when GOOBIT executes orders for crypto assets on behalf of Customers through a liquidity provider. This means that the exchange rate offered to Customers must not be less favourable when exchanging crypto assets for funds using the Company’s own inventory of crypto assets or fiat than when executing an order through a liquidity provider.

GOOBIT makes diligent efforts to ensure that the final exchange rate is not less favourable to the Customer than the estimated rate. However, due to the nature of crypto assets and factors such as volume, market volatility, and potential time delays between the Customer’s order placement and execution, there is always a risk that the final exchange rate may differ from the estimate.

4. Best Possible Result

4.1. Criteria and Necessary Measures

When GOOBIT executes orders for crypto assets on behalf of Customers, the Company shall ensure that appropriate measures are taken to achieve the best possible result for the Customer.

The following factors shall be specifically considered to achieve the best possible result when GOOBIT executes orders for crypto assets on behalf of Customers:

  1. price;
  2. cost;
  3. speed;
  4. likelihood of execution and settlement;
  5. size;
  6. nature;
  7. conditions for the custody of crypto assets; and
  8. other factors relevant to the execution of the order.

The best possible result for the Customer shall be determined based on the total cost related to the execution of the order, including the exchange rate of the relevant crypto asset(s) and any other related costs. This principle applies regardless of whether GOOBIT executes a transaction against its own inventory of crypto assets or executes a transaction through a liquidity provider.

GOOBIT applies an overall weighting where price and cost are generally given the greatest importance, unless specific circumstances exist - such as time-critical orders or large-volume orders - where execution speed may be prioritised.

4.2. Specific Instructions from Customers

If a Customer has provided GOOBIT with specific instructions, GOOBIT shall execute the order in accordance with those instructions. Upon receiving specific instructions from a Customer, the Customer shall be informed - in accordance with GOOBIT’s legal obligations - that executing an order in accordance with the Customer’s specific instructions may prevent GOOBIT from taking the necessary measures and following the procedures set out in this Policy, and may therefore hinder GOOBIT from fully complying with this Policy, potentially affecting the ability to achieve the best possible result.

4.3. Execution of Orders with Liquidity Providers

When GOOBIT does not execute a Customer’s order against the Company’s own inventory of crypto assets, the Company shall execute the Customer’s order with the available liquidity provider that can achieve the best possible result.

At present, GOOBIT may execute Customer orders with the following liquidity providers:

  1. K33
  2. Kraken
  3. Bitstamp
  4. BitGo

GOOBIT selects the liquidity provider that offers the most advantageous conditions for the specific order. The crypto assets are then transferred to the selected liquidity provider, and the order is completed in accordance with the terms agreed upon with the Customer. This ensures that the Customer receives the best possible execution of the order based on market data as well as the order’s size and time sensitivity.

GOOBIT does not receive any compensation, rebates, or non-monetary benefits for directing orders to any specific external party.

4.4. Orders Executed Outside a Trading Platform

When GOOBIT executes orders for crypto assets on behalf of Customers, the Company identifies the liquidity provider through which the best possible result for the Customer can be achieved. This means that GOOBIT may execute orders through liquidity providers that are not classified as trading platforms under MiCA.

Customers’ prior consent to this is obtained by their explicit acceptance of GOOBIT’s Terms of Use, including this Policy.

5. Execution Strategies and Oversight

5.1. Monitoring and Review

GOOBIT regularly monitors the quality of its internal pricing and order execution to ensure that the exchange of crypto assets against the Company’s own inventory, as well as orders executed on behalf of Customers, are carried out in accordance with this Policy and at a competitive price.

The Company conducts periodic reviews of its internal arrangements annually or as needed, covering at a minimum:

  1. pricing at the time of order execution;
  2. timing of execution;
  3. deviation reporting.

GOOBIT also performs annual and, when necessary, ongoing evaluations of trading platforms and liquidity providers to ensure that the Company can continue to offer the best possible results for Customers. This includes ensuring that such providers maintain appropriate internal rules and procedures for regulatory compliance and order execution.

Reviews of GOOBIT’s exchange services and related arrangements are documented and recorded. Where necessary, and in cases where deficiencies are identified, the review results shall serve as the basis for control measures and the correction of any deficiencies.

5.2. Orders Executed Outside a Trading Platform

Disruptions may occur due to market conditions or events within GOOBIT’s internal systems, which may result in reduced availability or interruptions in technical systems. In the event of a disruption where the Company determines that it is not appropriate or possible to execute an order in accordance with this Policy, GOOBIT shall take alternative measures to execute the order in a manner that achieves the best possible result for the Customer. If deemed necessary based on the extent and nature of the disruption, GOOBIT shall take reasonable steps to inform affected Customers whose orders have been placed but not yet executed and are impacted by the disruption. If GOOBIT is unable to contact the Customer, the Company shall take reasonable measures to act in the Customer’s best interest, and the Customer shall be bound by the resulting outcome.

6. Customer Information

Customers are informed about this Policy when they consent to the Company’s Terms of Use and use the Services. All material amendments to the Policy are published on the BTCX website.

Entering into or terminating collaborations with liquidity providers through which the Company may execute orders for crypto assets on behalf of Customers shall not be considered material amendments to the Policy.

Upon the Customer’s request, GOOBIT shall provide documentation demonstrating that the measures and procedures set out in this Policy have been followed.

GOOBIT continuously publishes information about completed transactions on bt.cx, including transaction volumes and transaction prices relating to transactions the Company has executed against its own inventory of crypto assets.

7. Supervision and Compliance

GOOBIT applies internal controls and technical restrictions to prevent employees from gaining unauthorized access to non-public information about Customer orders. Access is granted only to authorized personnel in functions relevant to the Services, and activity is logged.

GOOBIT continuously documents and analyses orders for crypto assets executed on behalf of Customers in accordance with this Policy and Article 78 of MiCA. Such documentation and analyses shall be provided upon request to the competent authority (e.g., the Swedish Financial Supervisory Authority).