1.1. BITSTACK SAS, having its registered office at Pepiniere Michel Caucik 100 Impasse des Houillères - Le Pontet, 13590 Meyreuil, (France), registered with the Aix-en-Provence Trade and Companies Register under the number 899 125 090 (“BITSTACK”) and registered with the French Financial Markets Authority (“AMF”) as a Digital Asset Service Provider (“DASP”) in accordance with Article 62 of Regulation 2023/1114 of 31 May 2023 on markets in crypto-assets (“MiCA”) under the number A2025-003 since 30 June 2025 for the provision of the following services:
• the safekeeping and administration of crypto-assets on behalf of customers; (Article 3 (16) (a) MiCA), i.e. "the custody or control, on behalf of customers, of crypto-assets or the means of access to these crypto-assets, where appropriate in the form of private cryptographic keys".
• the exchange of crypto-assets for funds; (Article 3 (16) (cb) MiCA), namely "the management of one or more multilateral systems, which bring together or facilitate the meeting of multiple buying and selling interests expressed by third parties for crypto-assets, within the system and in accordance with its rules, in a manner that results in a contract, either through the exchange of crypto-assets for funds or through the exchange of crypto-assets for other crypto-assets".
• the exchange of crypto-assets for other crypto-assets; (Article 3 (16) (cd) MiCA), i.e. "the conclusion, with customers, of contracts for the purchase or sale of crypto-assets for funds, using equity capital;".
• the execution of orders on crypto-assets on behalf of customers: (Article 3 (16) (e) MiCA), i.e. "the conclusion, on behalf of customers, of agreements to buy or sell one or more crypto-assets, or the subscription, on behalf of customers, of one or more crypto-assets, including the conclusion of contracts for the sale of crypto-assets at the time of their public offering or admission to trading".
• the service of transferring crypto-assets on behalf of customers; (Article 3 (16) (e) MiCA) i.e. “ providing services transferring, on behalf of a natural or legal person, crypto-assets from one address or a distributed ledger account to another”.
Hereinafter in the Policy, the services provided by BITSTACK as a DASP are collectively referred to as the “Services”.
1.2. This commercial policy (the “Policy”) applies to Bitstack with respect to third parties with whom Bitstack wishes to establish a commercial relationship (the “Customers”).
1.3. The Policy, published on the Bitstack website, is intended to provide information on the non-discriminatory method of selecting Customers with whom Bitstack agrees to deal.
1.4. The Policy complies with the relevant provisions of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (“MiCA”).
1.5. Any update or modification of the Policy replaces the previous versions and is deemed immediately applicable upon its publication on the Bitstack website.
2. Scope
2.1. This Policy applies only to certain Services provided by Bitstack to its Customers.
3. Non-Discrimination
3.1. Bitstack selects the Customers with whom it agrees to negotiate at its sole discretion, within the framework of the objective and non-discriminatory criteria described in Article 3.2 hereof.
3.2. Bitstack may refuse to enter into a relationship or terminate a business relationship in respect of:
• the Customer’s solvency;
• the Customer's lack of knowledge and/or experience in financial investment and/or in the crypto-assets sector;
• the counterparty risk;
• the Customer’s good repute and credibility;
• the existence of suspicions related to the occurrence of a risk of money laundering or terrorist financing;
• the existence of suspicions related to the occurrence of a fraud risk
• any change in the Customer's profile and situation that would have an impact on their ability to use Bitstack's services;
• the Customer's previous dealings with Bitstack.
4. Multiple transactions
When Bitstack is exposed to multiple transactions with the same Customer and cannot execute them without taking excessive risk, Bitstack may, in a non-discriminatory manner and on the basis of the aforementioned criteria, limit the number of transactions it agrees to carry out for the same Customer.
5. Method of determining the price of crypto-assets
The method for determining the price of crypto-assets proposed by Bitstack is specified in the Pricing Policy. In practice, Bitstack applies the following method:
5.1. Price of crypto-assets
The exchange price of crypto-assets for funds or for other crypto-assets is determined by Bitstack. Bitstack sets the price of crypto-assets based on, among other things, the prices used, including the prices applied by its liquidity provider(s), market conditions and volumes.
The price offered to the customer is established according to a transparent mechanism, based on three components:
• The amount of the transaction;
• The difference between the price of the crypto-asset available in Bitstack's stock and the price offered by the liquidity provider;
• Real-time analysis of the aggregated order book of liquidity providers, making it possible to assess market conditions (volatility, depth, available liquidity, etc.).
This leads to a variable margin, between 0.01% and 1%, calculated algorithmically. Bitstack ensures that the margin never exceeds 1% to ensure a competitive price.
The commissions received by Bitstack are applied to this price (see Point 5.2).
5.2. Commissions received by Bitstack
The buying and selling commissions received by Bitstack are applied on a decreasing scale based on the transaction volume carried out over the last thirty (30) days.
Operating volume of the last thirty (30) days
Rate corresponding to commissions received by Bitstack
The minimum commission amount for card purchases is €0.29. When a user makes a purchase of crypto-assets by credit card, a minimum fee of 0.29 EUR is charged (i.e. if the % buy/sell fee is less than 0.29 EUR, then the user will pay a minimum fee of 0.29 EUR).
The buying and selling commissions are deducted directly upon delivery of the transactions.
6. Publication of information on transactions
In accordance with Article 77 (4) of the MiCA Regulations, Bitstack publishes on the Application information relating to the transactions carried out by its customers such as the volumes and prices of the transactions.
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