Gemini Intergalactic EU, Ltd. Commercial Policy

Last updated: September 29, 2025

1. SCOPE AND APPLICABILITY 

1.1 Gemini Intergalactic EU, Ltd (the “Company”), a private limited liability company established and registered under the laws of Malta, with company registration number C110029, is duly authorised as a crypto-asset service provider by the Malta Financial Services Authority (the “MFSA”) to provide:
a) providing custody and administration of crypto-assets on behalf of clients; 
b) exchange of crypto-assets for funds or other crypto-assets (dealing on own account); 
c) execution of orders for crypto-assets on behalf of clients; 
d) placing of crypto-assets; 
e) reception and transmission of orders for crypto-assets on behalf of clients; 
f) providing transfer services for crypto-assets on behalf of clients.
1.2 The Company is required to have a Commercial Policy (this “Policy”) in respect of the “exchange of crypto-assets for funds or other crypto-assets” (the “Exchange Services”). This Policy outlines the relationship and practices between the Company and its clients (the “Clients”) in respect of the Exchange Services. 
1.3 The Exchange Services shall be delivered to Clients in a fair, transparent, compliant and non-discriminatory matter in compliance with the framework established under Regulation (EU) 2023/1114 on Markets in Crypto-Assets and other applicable laws, regulations and rules applicable to the Company (collectively, “Applicable Law.”)

2. THE SERVICE OFFERING BY THE COMPANY 

 2.2 Nature of Clients
The Company ensures that each Client shall receive appropriate services tailored to specific needs and requests. The Company provides the Exchange Services to individual retail investors, institutional investors, and corporate entities.
The Company’s target market is the EU/EEA accessed via the passport rights under MICA. 
2.2 Client Acceptance Policy
The Company has established clear eligibility criteria for accepting new clients, ensuring compliance with Applicable Law, and the Company’s risk management framework. Customer Acceptance Policy (within AML/CFT and Sanctions Policy) of the Company is the main framework establishing the criteria and procedures for onboarding new clients.
The Company has efficient and streamlined client acceptance processes, which implement applicable regulatory requirements with due consideration being given to the business profile of the prospective client.
2.3 Transparent Pricing Structure
All fees and charges are clearly communicated to clients.
All fees and charges of the Company shall be transparent, reasonable, and applied consistently across all types of Clients. Any variations shall be based solely on objective factors such as account type, specific service agreements, and other acceptable matters determined by the Company from time to time and shall be implemented on a non-discriminatory basis. The Company will exchange crypto assets for funds or other crypto assets with its Clients on the basis of prices that are aligned with market prices. 
The pricing mechanism applied by the Company is influenced by prevailing market conditions, specifically including trading volume and market volatility associated with the relevant Crypto-Assets. Elevated trading volumes generally contribute to tighter spreads and improved execution outcomes due to enhanced liquidity, whereas periods of heightened volatility may necessitate wider spreads or dynamic price adjustments to reflect increased market risk and reduced execution certainty. Notwithstanding such fluctuations, the Company shall ensure that all pricing remains consistent with prevailing market prices, taking into account real-time data sourced from Gemini’s internal systems and, where applicable, reputable third-party market data providers. This data serves as a reliable benchmark to validate the competitiveness and fairness of prices offered to Clients. 
2.4 Service Provision
The Company shall provide Exchange Services to all eligible Clients under equal terms and conditions. 
A Client shall not receive preferential treatment unless such treatment is justified by objective criteria. The Exchange Services are regularly updated to meet evolving market conditions, technological advancements, and regulatory changes. The Clients are kept informed of any significant changes that may affect the Exchange Services.
All transactions will be undertaken on a “pre-funded” basis which means that the Client will be able to buy or sell crypto assets only to the extent that his account has the necessary funding/ holding. This will avoid the risk of settlement failures. 
2.5 The Obligations & Responsibilities of Clients
The principal obligations of Clients in relation to the Exchange Services are the following:
Accurate Information: The Clients must provide accurate and up-to-date information during the onboarding process and throughout the relationship. This includes promptly notifying the Company of any changes to their personal or financial circumstances.
Compliance with Regulations: The Clients must comply with Applicable Law, including that related to AML-CFT. The Clients are responsible for ensuring that the source of their funds is legitimate and that they do not engage in any illicit activities.
Understanding Risks: The Clients are expected to fully understand the risks associated with investing in crypto-assets. The Company provides educational resources and risk disclosures, but the Clients must take responsibility for their activities and decisions.
Use of Services: The Clients must use the Company’s services in a lawful and ethical manner, adhering to the terms and conditions outlined in the User Agreement. Any misuse of services may result in the termination of the client relationship.
2.6 Frequency & Content of Reports to Clients
Regular Reporting:
The Company provides Clients with regular reports detailing the performance and status of their crypto-asset investments. The Clients’ holdings with the Company are available through the Company’s trading platform. The Company may issue statements of holdings to its clients upon request. 
Clients can request additional reports or specific information at any time. The Company will provide reports promptly, subject to reasonable limitations based on the nature of the request by the Client.
2.7 Review & Monitoring of Client Relationships
The Company conducts ongoing monitoring of client relationships to ensure compliance with internal policies and regulatory requirements. This includes:
Transaction Monitoring: The regular review of transactions to detect and prevent any suspicious activity.
Periodic Reviews: Scheduled reviews of client accounts/ profiles to ensure that the Exchange Services provided remain suitable and that the Client’s risk profile has not changed.
Client Feedback: The Company seeks feedback from Clients to improve service delivery and address any concerns. Feedback is reviewed regularly, and necessary adjustments are made to enhance the client experience.
3. CLIENT COMMUNICATION
3.1 Clear and Timely Communication: The Company shall provide clear, accurate, and timely communication to all Clients including:
Pre-Contractual Information: The Clients will receive all necessary information before entering into any agreement, including details about the Exchange Services, associated fees, and potential risks.
Ongoing Updates: The Company will keep Clients informed about any changes to the Exchange Services, market conditions, or regulatory requirements that may affect them.
Accessible Communication Channels: Multiple communication channels will be available to Clients, including email, telephone, and online chat, ensuring accessibility and responsiveness.
3.2 Disclosure of Risks: The Company will provide Clients with detailed information about the risks associated with crypto-assets and the Exchange Services. 
3.3 Client Support: The Company offers comprehensive support to all Clients, including:
Help Desk: A dedicated help desk will be available to assist Clients with any queries or issues related to the Exchange Services.
Technical Support: The Company will provide technical support for issues related to the r service access through API keys, as applicable. 
Educational Resources: The Clients will have access to educational materials and resources to enhance their understanding of crypto-assets and the related Exchange Services.
Complaints Management: The Clients have the right to submit complaints regarding any aspect of the Exchange Services provided by the Company as set out below. 
3.4 Record Keeping: The Company will keep accurate records of the agreements, communications and reports provided to Clients in accordance with Applicable Law and the requirements in the Record Keeping Policy of the Company.
3.5 Data Protection: The Company will handle all client data in accordance with applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and the Data Protection Act (Chapter 586, Laws of Malta). The personal data of Clients will be processed transparently and securely.
4. COMPLAINTS MANAGEMENT
4.1 The Company maintains a complaints management policy/ procedures (the “Complaints Management Policy”) with effective and transparent procedures for the prompt, fair and consistent handling of complaints. Clients can file complaints free of charge with the Company regarding any aspect of the Exchange Services. A complaint can be submitted through the online forms on the website or via the mobile app.
4.2 The Company shall investigate all complaints in a timely and fair manner, and communicate the outcome of such investigations to Clients within a reasonable period. The Company shall keep a record of all complaints received from Clients and any measures taken in response thereto.  
4.3 A summary of the Complaints Management Policy is available on the website maintained by the Company.
5. TRAINING AND AWARENESS
5.1 This Policy has been provided to all relevant staff of the Company. An overview of this Policy has also been incorporated into the Company’s induction and annual training.
6. REVIEW OF THIS POLICY
6.1 The Company may update or amend this Policy from time to time to reflect changes in regulatory requirements or business practices. Clients will be notified of any significant changes, and any such updates or amendments will be made in a manner that ensures continued compliance with Applicable Law.
6.2 This Policy shall be assessed and periodically reviewed at least on an annual basis. The Board of Directors is responsible for the maintenance/ review of this Policy and shall address and take all appropriate measures to address any deficiencies.

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