Conflicts of interest policy

PITIKLINI SOLUTION SL ("Pitiklini", "we", "us" or "our"), owner of the Pitiklini brand and of the pitiklini.com website and the Pitiklini app (together, the "Platform"), applies this conflicts of interest policy. It is addressed to anyone who visits the Platform or holds a user account on it (the "Account"), whom we refer to as "you".

A conflict of interest exists when the interests of a company, its team or another customer may be contrary to yours. This policy describes the role of each company on the Platform, the conflicts that may arise, the risk they pose to you and the measures we apply to avoid them. It follows the criteria of Article 72 of Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) and of Commission Delegated Regulation (EU) 2025/1142. Both govern the identification, prevention, management and disclosure of conflicts of interest in crypto-asset services.

Summary

• Provision of the services. The custody, purchase and sale, exchange and transfer of crypto-assets, and the related euro payments (the "Crypto-Asset Services"), are provided by DEPASIFY S.L. (the "Provider"), a crypto-asset service provider subject to the MiCA Regulation. Pitiklini provides the technology platform: it develops and maintains the website and the app, manages Accounts, hosts and moderates P2P listings and provides user support. Each company applies its own conflicts of interest policy; this one is Pitiklini's.
• Sources of income. We charge the fees published under Fees, so it is in our interest that you trade more.
• Main conflicts. They arise because our income depends on how much you trade, because we decide which crypto-assets are offered and because we resolve P2P disputes.
• Main measures. We do not advise you or encourage you to trade, we decide under published rules and in writing, we separate duties, and decisions that move money are made by a person and recorded.
• Prevention before disclosure. Disclosing a conflict is not enough to resolve it, so this policy also explains how we avoid it.

Role of each company

The Provider's conflicts of interest policy, which MiCA requires of it, may be requested at soporte@pitiklini.com: we will send it to you. The identification details of both companies are set out in the Legal notice.

Sources of income

• Pitiklini charges the fees published under Fees: the spot market fees, the fixed fee for each withdrawal and, where applicable, the P2P fee. The withdrawal fee also covers the network fee, the cost of which we bear; where the withdrawal fee is higher, the difference is income for us.
• The Provider charges for the Crypto-Asset Services under its own terms. Both companies have a commercial agreement to offer those services on the Platform.
• We do not charge anyone to show or rank listings, or issuers to have their crypto-assets offered.

Conflicts identified and measures taken

Income linked to trading volume

• Source of the conflict: the more you trade, the more fees we earn.
• Risk to you: that we encourage you to trade more than is in your interest.
• Measures: we do not advise you or recommend what to buy or sell; we show you the risk warning before you trade and on every product page; we publish all fees with their date and show you the applicable fee before you confirm the trade; we do not run promotions that reward trading more; and our team's remuneration does not depend on how much you trade.

Listing and delisting of crypto-assets

• Source of the conflict: together with the Provider, we decide which crypto-assets can be used on the Platform, and offering a crypto-asset in high demand can bring more trades.
• Risk to you: that a crypto-asset is offered for commercial reasons rather than after an assessment of its risks, or that someone on our team takes advantage of knowing in advance that it will be listed or delisted.
• Measures: we only offer crypto-assets that the custody service supports and whose white paper is published when MiCA requires it, and each crypto-asset's profile links to its source; the decision is made in writing, with its reasons, and recorded; we do not charge issuers; anyone with an interest in a crypto-asset takes no part in the decision; and nobody on the team may trade a crypto-asset while its listing or delisting is being decided. If we stop offering a crypto-asset, we will give you sufficient notice to withdraw it.
• A crypto-asset linked to the brand: there is a crypto-asset called PTK, named after the Pitiklini brand. It currently cannot be deposited or withdrawn, and it is not offered on the website. If it is ever offered, we will state this in this policy beforehand, together with the measures needed to ensure that nobody favours it.

Price of trades on the spot market

• Source of the conflict: the spot market technology belongs to Pitiklini, and our fee comes from those trades.
• Risk to you: that someone uses information about your orders to trade ahead of them, or that Pitiklini trades against you.
• Measures: Pitiklini does not buy or sell on its own account on the spot market or in P2P; orders are executed under the same rules for everyone; and our team may not use information about users' orders.

P2P trades: crypto-assets on hold and disputes

• Source of the conflict: while a P2P trade is in progress, the crypto-assets are held and, if a dispute arises, our team resolves it. We also have an interest in keeping the most active advertisers on the Platform.
• Risk to you: that a dispute is decided in favour of whoever suits us best rather than whoever is right.
• Measures: the P2P and dispute rules are published in the Terms and conditions; a person decides, based on what both parties provide, and gives both parties a reasoned decision, explaining how to challenge it; above a certain amount, the decision requires two different people on the team; everything is kept in a record that cannot be changed; anyone with an interest in the trade or in one of the parties takes no part; and nobody on our team buys or sells in P2P with users.

Pauses and suspensions

• Source of the conflict: we may pause a trade or a service, for example for maintenance or security reasons.
• Risk to you: that a pause takes place at a time that suits us rather than you.
• Measures: we only pause for technical, security or legal reasons; a pause applies equally to all users; and we announce it under Status.

Personal transactions by the team

• Source of the conflict: people who work at Pitiklini may hold crypto-assets or wish to use the Platform.
• Risk to you: that they use information you do not have.
• Measures: anyone who works at Pitiklini and uses the Platform does so on the same terms as any other user; they may not use non-public information or trade in P2P with users; and they must declare their interests in crypto-assets, issuers and other companies in the sector.

Commercial agreement to offer the Crypto-Asset Services

• Source of the conflict: both companies have a commercial agreement to offer the Crypto-Asset Services on the Platform.
• Risk to you: that we offer you those services because it suits us, or that it is not clear who provides you with each service.
• Measures: in every document we state who provides each service; the identification details of both companies are set out in the Legal notice; and complaints about the Crypto-Asset Services follow the Provider's procedure, which is explained on the complaints page.

Gifts and third-party incentives

• Source of the conflict: a crypto-asset issuer, a supplier or a user could offer us something to influence a decision.
• Measures: we do not accept gifts, payments or benefits that could influence our decisions, and we record anything offered to us.

Products in preparation

Rewards, referrals, staking and the other products marked "Coming soon" have their own conflicts. Before launching them, we will update this policy.

General management of conflicts

• The management of PITIKLINI SOLUTION SL is responsible for this policy and for ensuring compliance with it.
• Record: we record the conflicts identified and the measures taken in each case, and keep that record for five years.
• Separation of duties and permissions: each person on the team can only carry out in the administration panel the actions that their role requires, and all of those actions are recorded.
• Decisions that move money: they are made by a person, with a second check of that person's identity, and the most important ones by two different people.
• Abstention: anyone with an interest in a matter takes no part in it.
• Training: anyone who joins the team learns this policy before starting work.

Disclosure of conflicts that cannot be avoided

If we are unable to avoid a conflict in a particular case, we will inform you before providing the service affected, in sufficient detail for you to make a decision, or we will not provide that service. Disclosure does not replace prevention: it is the last resort.

Review of this policy

We review this policy at least once a year and whenever a service changes. Each version is published on this page with its date and a summary of the changes.

Enquiries and complaints

If you have any question about this policy, you may contact us at soporte@pitiklini.com. If you consider that a conflict of interest has harmed you, you may submit a complaint on the complaints page or by writing to that same address.

Related documents

• Legal notice
• Terms and conditions
• Risk warning
• Fees