12.1 Description of Service
Client Funds: Client funds (fiat) are held in a K33 client account with a Norwegian bank and as such kept segregated from K33’s own assets to ensure clients’ segregation rights. Client funds are comingled between clients, and an internal ledger is maintained to map clients' ownership.
Client Wallets: K33M maintains segregated Client Wallets per blockchain relevant for assets accepted for custody by K33M. The Client Wallets are comingled between clients, and an internal ledger is maintained to map clients’ ownership. All Client Wallets are segregated from K33 Markets assets.
Vault Service: For certain customers, K33 offers storage of cryptocurrency in custodial wallets, a service called Vault (Vault service). Each Vault customer is provided with an individual wallet that can be monitored on any block explorer using their own unique address per token and blockchain network. Cryptocurrency held in Vault are segregated from K33 assets, as well as from other Customer’s assets.
Use of the Vault Service requires the client to enter into a separate Vault Agreement with K33. In the event of any inconsistency between these Terms and Conditions and the Vault Agreement, the terms of the Vault Agreement shall prevail for all matters relating to the Vault Service.
12.2 Custody Policy
K33 maintains a formal Custody Policy that sets out internal rules and procedures to ensure the safekeeping and control of Client funds and assets.
The policy minimises the risk of loss due to fraud, cyber-attack, or operational error through segregation, access control, and multi-layered authentication.
A summary of the Custody Policy is available on our website.
12.3 Communication and Authentication
All communication between K33 and the Client takes place through secure channels, including the Client Portal, API, and registered email.
Clients authenticate using multi-factor authentication (MFA) and other verification procedures.
K33 may refuse to act on instructions if authentication cannot be confirmed or if the request appears fraudulent or unauthorised.
12.4 Security Systems
K33 employs institution-grade security systems combining cold storage, hardware security modules (HSMs), key-sharding, and encryption of all access credentials.
Transactions and access requests are subject to multi-person approval and continuous monitoring.
K33 conducts regular penetration tests, security audits, and resilience testing in line with DORA Articles 9–12 and industry standards.
12.5 Fees, Costs, and Charges
K33 does not charge any separate fees for the custody or safekeeping of client funds (fiat) or crypto-assets (Client Wallets). K33 earns its remuneration through the trading margin included in client transaction prices and covers all bank transfer fees and blockchain network fees related to custody, settlement and withdrawals. These costs are not charged to clients.
Vault clients enter independent agreements covering applicable fees and withdrawal rules, which apply instead of the provisions above.
No additional custody charges apply unless explicitly stated in these Terms and Conditions.
12.6 Other service providers
K33 uses technology provided by Fireblocks in its Custody service and all coins are held securely in a multi-signature setup. Fireblocks provides merely the underlying technology to K33 for its Custody service and does not have access to the funds stored in Customer Wallets.
12.7 The Customer is free to deposit / send crypto to their wallet at any time. However, the Customer bears the responsibility to ensure that the token it is transferring is supported by K33 Markets. K33 Markets may decide to withdraw support for custody of a coin. If such a case arises, K33 Markets will offer the Customer the opportunity to either sell or withdraw the funds.
12.8 The Customer can withdraw crypto from its wallet. Withdrawals are to be completed in interaction with K33 Markets representatives and subject to withdrawal rules, see Section 13.
12.9 We maintain records of all holdings to ensure that client funds and crypto-assets are clearly identifiable and fully segregated from K33M’s own assets.
K33 provides clients, at least every three months and upon request, with an electronic statement identifying the crypto-assets held in their name, including balances, values and transfers made during the relevant period. Clients may also access full historical data and export transaction history at any time through the platform.
For the Vault service, assets are held in individually segregated on-chain wallets that are directly auditable by the client. K33 will nonetheless provide a quarterly electronic statement in accordance with MiCA requirements.
12.10 In the case of a change of the custody set up, the Customer will be notified. A reasonable period will be provided for the Customer to move their funds. If there is a balance on the Customer's wallet after this period has elapsed, migration will be done by K33 Markets on behalf of the Customer. Wallet addresses corresponding to the new wallets might be different. The Customer will be informed of the addresses for the new wallets. It is the Customer's responsibility solely to ensure that correct and updated addresses are provided as part of transaction instructions.
12.11 Wallet addresses are active (can receive funds) unless notified otherwise. K33 Markets is not responsible for tokens transferred to a wallet address after termination/cancellation of an address has been communicated to the Customer.
12.12 Rights arising from changes to the underlying distributed-ledger technology, including forks and airdrops, will be distributed by K33 Markets on a best-effort basis. K33 Markets will never retain fork-coins or airdropped assets for its own economic gain. However, K33 Markets cannot guarantee that it will be able to support, access, or facilitate the exercise of rights arising from forks, airdrops, protocol upgrades or other events that modify the underlying distributed-ledger technology.
Clients are informed during onboarding that exercising such rights may require withdrawing assets to a self-custodial wallet, and K33 obtains the client’s explicit and separate consent to this limitation.
12.13 K33 Markets will provide necessary information for the understanding of the Vault service, however, due to security reasons, K33 Markets or affiliates will not disclose or respond to requests for information regarding internal procedures including but not limited to multi-signature and personnel.
