Conflicts of interest policy

A conflict of interest arises when what suits a company, its team or another customer may go against what suits you. This policy explains in what capacity each company acts in Pitiklini, what conflicts may arise, what risk they pose for you and what we do to avoid them. It follows Article 72 of Regulation (EU) 2023/1114 (MiCA) and Commission Delegated Regulation (EU) 2025/1142, which set out what crypto-asset service providers must publish.

At a glance

• Who provides what. Pitiklini provides the technology (the website and the app), manages your account, hosts and moderates the P2P ads, and supports users. The crypto-asset services are provided to you by the service provider, which has its own conflicts of interest policy.
• How we earn money. Through the fees we publish under Fees. That is why it is in our interest that you trade more.
• The main conflicts: that our income depends on how much you trade, that we decide which coins are offered and that we resolve P2P disputes.
• What we do: we do not advise you or push 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.
• Disclosing a conflict is not enough to resolve it: this policy also explains how we avoid it.

Who provides each service and in what capacity

The provider's details and where to check its authorisation are in the Legal notice. The provider has its own conflicts of interest policy, which MiCA requires of it: if you cannot find it, ask us at soporte@pitiklini.com and we will send it to you.

How we earn money

• Pitiklini charges the fees under Fees: the spot market fees, the fixed fee for each withdrawal and, if there is one, the P2P fee. The withdrawal fee also pays for the network fee, which the platform bears; if it is higher, the difference is income for us.
• The service provider charges for its services under its own terms. Pitiklini and the provider have a commercial agreement to offer its services on the platform.
• We do not charge anyone to show or rank ads, or issuers to have their coins offered.

Conflicts that may arise and what we do

Our income depends on how much you trade

• What happens: the more you trade, the more fees we earn.
• What risk it poses for you: that we encourage you to trade more than is good for you.
• What we do: 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 one that applies before you confirm; we do not run promotions that reward trading more; and our team's pay does not depend on how much you trade.

Which coins are offered and which are withdrawn

• What happens: together with the provider, we decide which coins can be used on the platform, and offering a fashionable coin can bring more trades.
• What risk it poses for you: that a coin is offered for commercial reasons rather than because of its risks, or that someone on our team takes advantage of knowing before anyone else that it will be offered or withdrawn.
• What we do: we only offer coins the provider can hold and whose technical document is published when MiCA requires it, and each coin 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 coin takes no part in the decision; and nobody on the team may trade a coin while its listing or withdrawal is being decided. If we withdraw a coin, we give you notice in time for you to withdraw it.
• A coin with our name: there is a crypto-asset called PTK, named after the platform. Today it cannot be deposited or withdrawn, and it is not offered on the website. If it were ever offered, we would say so here beforehand, with the measures to make sure nobody favours it.

The price at which you buy or sell

• What happens: the technology that matches spot market orders is Pitiklini's, and our fee comes from the trades.
• What risk it poses for you: that someone uses what they know about your orders to get ahead of them, or that the platform trades against you.
• What we do: Pitiklini does not buy or sell on its own account on the spot market or in P2P; orders are matched under the same rules for everyone; and our team may not use information about users' orders.

P2P: the crypto set aside and disputes

• What happens: while a P2P trade lasts, the crypto is set aside, and if there is a dispute, our team resolves it. The platform also has an interest in keeping its most active advertisers.
• What risk it poses for you: that a dispute is decided in favour of whoever suits us best rather than whoever is right.
• What we do: the P2P and dispute rules are published in the Terms and conditions; a person decides, with what both parties provide, and explains the decision to both, with the reasons and how to challenge it; above a certain amount, the decision needs 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 does not take part; and nobody on our team buys or sells in P2P with users.

Pauses and suspensions

• What happens: we may pause a trade or a service, for example for maintenance or security.
• What risk it poses for you: that something is paused at a time that suits us rather than you.
• What we do: we only pause for technical, security or legal reasons; the pause applies equally to everyone; and we announce it under Status.

Trading by the team

• What happens: people who work at Pitiklini may hold crypto or want to use the platform.
• What risk it poses for you: that they use information you do not have.
• What we do: anyone who works at Pitiklini and uses the platform does so on the same terms as any user; they may not use information that is not public or trade in P2P with users; and they must declare their interests in coins, issuers and other companies in the sector.

The relationship with the service provider

• What happens: Pitiklini has a commercial agreement with the provider to offer its services.
• What risk it poses for you: that we offer you its services because it suits us, or that it is not clear who provides you with each thing.
• What we do: in every document we tell you who provides each service; the provider's details and where to check its authorisation are in the Legal notice; and complaints about its services follow its procedure, explained on the complaints page.

Gifts and third-party incentives

• What happens: a coin issuer, a supplier or a user could offer us something to influence a decision.
• What we do: we do not accept gifts, payments or benefits that could influence our decisions, and we record anything offered to us.

Products that are not available today

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

How we manage conflicts in general

• The management of PITIKLINI SOLUTION SL is responsible for this policy and for making sure it is followed.
• Record: we record the conflicts we identify and what we did about them, and keep that record for five years.
• Separation of duties and permissions: each person on the team can only do in the administration panel what their role requires, and everything they do is recorded.
• Decisions that move money: they are made by a person, with a second check of their 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.

If a conflict cannot be avoided

If in any case we could not avoid a conflict, we would tell you before providing the service affected, in enough detail for you to decide, or we would not provide it. Telling you does not replace avoiding it: it is the last resort.

Review of this policy

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

Questions and complaints

If you have a question about this policy, write to us at soporte@pitiklini.com. If you think a conflict of interest has harmed you, you can complain on the complaints page or by writing to us.

Related documents

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