Order execution 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"), publishes this order execution policy. It is addressed to anyone who holds a user account on the Platform (the "Account"), whom we refer to as "you".

This policy explains how the orders to buy, sell and convert crypto-assets that you place on the Platform are executed, what is taken into account to obtain the best possible result and how you can check it. It follows Article 78 of Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) and Article 15 of Commission Delegated Regulation (EU) 2025/305, which sets out what an execution policy must contain.

Summary

• Who executes your orders. They are executed by DEPASIFY S.L. (the "Provider"), a crypto-asset service provider subject to the MiCA Regulation, in the account you hold with it. Pitiklini provides the technology you use to place your orders and charges its fee.
• How. Each order is executed immediately, as a market order, at the best available price. Before it is sent, the price is checked again: if it has moved against you by more than the margin published under Fees, the order is not sent and you are not charged anything. The purchase of the USDC for a transfer by local payment has its own rule, explained below.
• Where. The Provider currently executes all Platform orders with the liquidity provider Kraken. Your orders may be executed outside a trading platform authorized under MiCA, which is why we ask for your express consent.
• Your consent. Before your first order, the Platform asks you, separately, to accept this policy and to give your express consent for your orders to be executed outside a trading platform. Without both, no order is sent.
• How it is checked. Each order is recorded with the price you saw, the price at which it was executed, its costs and the version of this policy in force, and our team reviews any order that departs from what was expected.

Which orders it covers

This policy applies to the orders you place on the Platform to:

• buy crypto-assets with euros;
• sell crypto-assets for euros;
• convert one crypto-asset into another;
• buy with euros the USDC that funds a transfer to another country by local payment.

It does not apply to P2P trades between users, in which you buy from or sell to another person at the price the two of you agree, or to deposits, withdrawals and other sends, which are not buy or sell orders.

How you give your consent

Before your first order, the Platform asks you for two consents, each one separately and not pre-checked:

1. Your acceptance of this policy (Article 78(3) of MiCA).
2. Your express consent for your orders to be executed outside a trading platform (Article 78(5) of MiCA). You give it as a general agreement, for all your orders, not order by order.

Without both, the Platform does not send any order. Each consent is recorded with its date and, for this policy, with the version you accepted.

When we publish a new version of this policy, we will ask you to accept it again before your next order. Your express consent remains valid until you withdraw it. You can withdraw it at any time in Account › Legal information, in the app, or by writing to soporte@pitiklini.com; from then on you will not be able to place new orders until you give it again, because currently any of them may be executed outside a trading platform.

Definitions

• Order: the instruction you give on the Platform to buy, sell or convert a crypto-asset.
• Execution: the purchase or sale the Provider carries out in your account to fulfill the order.
• Execution venue: the entity with which the Provider executes the order, such as a trading platform, a liquidity provider or a market maker.
• Trading platform: a multilateral system for trading crypto-assets operated by a provider authorized to do so under Article 59 of MiCA.
• Margin: the maximum difference, published under Fees, allowed between the price you see when reviewing the order and the price at the time it is sent.

How the best possible result is obtained

The Provider must take all necessary steps to obtain the best possible result when executing your orders (Article 78(1) of MiCA). For Platform orders, the factors that Article requires are taken into account as follows, in this order of importance:

1. Price and costs, together, that is, what you pay or receive in total. The price you see before confirming is the price per unit and includes all execution costs except Pitiklini's fee, which is shown separately, also before confirming, and is published under Fees. The Provider's price may include a difference between the buy price and the sell price, as explained in the risk warning.
2. Speed and likelihood of execution. The order is executed immediately, at market. The price check before it is sent may prevent an order from being executed, but only when the price has moved against you by more than the margin: you then decide with the new price.
3. Likelihood of settlement and custody conditions. The order is executed in the account you hold with the Provider, and what you buy stays in it, in its custody, without passing through any Pitiklini account.
4. Size and nature of the order. These are spot orders, without leverage or derivatives: the crypto-asset is bought or sold and delivered. Each order must be between the minimum and the maximum published under Fees.

How each order is executed

1. You choose what to buy, sell or convert and the amount, in euros or in the crypto-asset.
2. The Platform shows you the current price, which is refreshed every few seconds, and the fee.
3. When you confirm, the price is checked again. If it has moved against you by more than the margin, the order is not sent, you are not charged anything and we show you the new price so you can decide.
4. If it is within the margin, the Provider executes the order at market, at the best price available at that moment at the execution venue. That price may be slightly better or slightly worse than the one you saw.
5. If you specified the amount in euros, the Provider converts it into the quantity of the crypto-asset when executing the order, so what is executed may differ slightly from what was expected.

Conversions. A conversion of one crypto-asset into another is executed with a single order in the pair of the two crypto-assets, if there is one. If not, it is executed with two orders through the euro: first the sale and then the purchase. Before the second one is sent, the price and the fee are checked again; if the price has moved against you by more than the margin, the second one is not sent and you keep the euros from the first.

Transfers to another country by local payment. The purchase of the USDC that funds the transfer is executed at market, in your account, when the transfer goes out: when you confirm it or, if our team reviews it, when the review ends. What the beneficiary receives is set then, with the USDC already bought, and instead of the margin you are protected by the cap published under Fees for local payments: if they would receive less than what you saw by more than that cap, we ask you before sending it. If you do not accept it or do not answer in time, the transfer does not go out: the USDC bought stays in your balance and we refund the transfer fees, except the conversion fee, as the conversion has already happened. You see the rate applied, what the beneficiary receives and the conversion fee in the transfer details.

Partial executions. Market orders are normally executed in full and immediately. If one is executed only in part, or at a price that departs from the one shown by more than expected, our team reviews it, and you see on the Platform what was actually executed.

No aggregation. Each order is executed separately, in the account you hold with the Provider. It is not aggregated with those of other users or with transactions by Pitiklini, which does not buy or sell crypto-assets on its own account.

Execution venues

The Provider chooses the execution venues it works with and is responsible for obtaining with them the best possible result for you.

Currently, the Provider executes all Platform orders, for all the crypto-assets offered on it, with the liquidity provider Kraken. If the execution venue changes, we will update this policy.

Pitiklini does not choose the execution venue and does not receive from any venue any remuneration, discount or non-monetary benefit for routing orders to it. What the Provider charges for the Crypto-Asset Services is set by its own terms; what Pitiklini charges is published under Fees.

Execution outside a trading platform

Under MiCA, the only trading platforms are those operated by a provider authorized to do so under its Article 59. According to the European Securities and Markets Authority (ESMA), executing an order with any other venue, such as an over-the-counter venue, a trading platform in a country outside the European Union or a decentralized exchange, is executing it outside a trading platform. As the Provider executes your orders with a liquidity provider, they may be executed outside a trading platform, which is why we ask for your express consent (Article 78(5) of MiCA).

What it means for you:

• According to ESMA, such an execution may be subject to lesser regulatory scrutiny or offer you a lower level of protection than a trading platform authorized under MiCA. For example, the rules MiCA imposes on those platforms, such as making public the buy and sell prices and the executed trades (Article 76 of MiCA), do not apply to it.
• The Provider remains bound to obtain the best possible result for you, and remains responsible for executing the order and for the custody of your crypto-assets.

Specific instructions

On the Platform you decide what to buy, sell or convert, how much and when. You do not choose the execution venue or the way the order is executed. If in the future the Platform accepted specific instructions, such as a limit price, we would warn you beforehand: a specific instruction may prevent the best possible result from being obtained for what that instruction covers (Article 78(1) of MiCA).

Misuse of order information

Pitiklini does not buy or sell crypto-assets on its own account, and our team may not use information about users' orders. Each team member can only take, in the administration panel, the actions that belong to their role, and all of them are recorded. Article 78(2) of MiCA also requires the Provider to prevent its staff from misusing that information.

Monitoring and review

• Each executed order is compared with the price you saw. If the execution price departs from the one shown by more than expected, or the order is executed only in part, our team reviews it. If this happened repeatedly, we would review the execution venue with the Provider.
• The Provider regularly checks whether the execution venues provide the best possible results for you, as Article 78(6) of MiCA requires.
• We review this policy at least once a year and whenever the execution venue or the way orders are executed changes.

Information and changes to this policy

The version of this policy in force is always on this page, with its date, and previous versions remain available with theirs. Each new version is published with a summary of the changes, and the Platform asks you to accept it before your next order.

How you can check the execution of your orders

• On the Platform you see each order with the price at which it was executed, what you received and the fee; the purchase for a transfer by local payment, in the transfer details.
• At your request, we will show you that one of your orders was executed in accordance with this policy, with its record (Article 78(4) of MiCA). Write to us at soporte@pitiklini.com.
• Record. Each order is recorded with its date and time, the price you saw, the price at which it was executed, its costs and the version of this policy in force. We keep that record and the record of your consents for at least five years (Article 68(9) of MiCA), and we provide them to you if you ask.

Questions and complaints

For any question about this policy, you can contact soporte@pitiklini.com. If you consider that one of your orders was not executed in accordance with this policy, you can file a complaint on the complaints page, which explains the procedure, or by writing to that same address.

Related documents

• Terms and conditions
• Risk warning
• Conflicts of interest policy
• Fees
• Legal notice