Last Modified: August 21, 2025

By agreeing to the terms of any agreement you may have with Paxos Trust Company, LLC, a New York State chartered limited purpose trust company (“Paxos Trust”) or its applicable affiliates, including Paxos Global PTE LTD (“Paxos Global”), Paxos Digital Singapore Pte. Ltd. (“Paxos Digital”), Paxos Issuance Europe Oy (“PIE”) and Bruntal S.A. (dba Paxos Uruguay) (“PUY”), (collectively, “Paxos,” “we,” “us” or “our”), including, for example, the General Terms and Conditions available at https://www.paxos.com/terms-and-conditions/general-terms-and-conditions and/or the Terms and Conditions for Paxos Platform Services (collectively, “Paxos Contractual Documentation”), Customers also agree to abide by the following marketplace rules for the crypto asset trading platform managed by Paxos and operating under the trade name itBit   (the “Trading Platform” and these “Marketplace Rules”). All capitalized terms not defined herein will have the meaning ascribed to them in the Paxos Contractual Documentation, as applicable.

1. General Fraudulent Acts. Customers will not engage in any fraudulent act or engage or attempt to engage in any scheme to defraud, deceive or trick users of the Trading Platform, employees of the Trading Platform or the underlying software of the Trading Platform.

2. Fictitious Transactions. Customers will not place any order with no intention to execute.

3. Market Manipulation. Customers will not engage in any disruptive trading or manipulation of the Trading Platform. This includes orders placed for the purpose of generating volatility or creating a condition in which prices do not or will not reflect bona fide supply and demand.

4. Violation of Applicable Laws and Regulations. Customers will not use the Trading Platform in a way that violates the laws and regulations applicable to Paxos and the Trading Platform.

5. Misstatements. Users and Customers will not make any misstatement of material fact to Paxos.

6. Activities That Bring Disrepute upon Paxos. Users and Customers will not access the Paxos Platform or use the Trading Platform or any Trading and Custody Services in any way that could be expected to bring disrepute upon Paxos.

7. Disclosing Orders. Customers will not disclose to any person, including, but not limited to, another market participant, any order placed by Customer or any related party or any order placed by another person, including, but not limited to, another Customer.

8. Pre-Arranged Trades. Members will not place any order on the Trading Platform that has been pre-arranged (or discussed with another Customer prior to being placed on the Trading Platform) for the purpose of creating an artificial price, fictitious trade, or other disruptive, fraudulent, noncompetitive, or unfair impact on the Trading Platform.

9. Wash Trades. Customers, through one or more accounts owned by Customer or any related party, will not place or accept buy and sell orders at the same price, where Customer or any related party knows that the purpose of the orders is to artificially create the appearance of activity (transactions commonly known as wash trades).

10. Money Passes. Customers will not prearrange the execution of transactions on the Trading Platform for the purpose of passing money between accounts.

11. Accommodation Trading. Customers will not enter into transactions on the Trading Platform for the purpose of assisting another person to engage in transactions that are in violation of these Marketplace Rules or any applicable laws and regulations.

12. Front-Running. Customers will not take a position based upon non-public information regarding an impending transaction by another Customer.

13. Disruptive Practices. Customers will not engage in any trading, practice or conduct on the Trading Platform that: (i) demonstrates intentional or reckless disregard for the orderly execution of transactions or (ii) involves spoofing (bidding or offering with the intent to cancel the bid or offer before execution).

14. Customers will not engage in any conduct that threatens, harasses, coerces, intimidates or otherwise attempts to improperly influence another Customer or any other person.

MARKETPLACE RULES VIOLATIONS 

If we suspect that you have violated these Marketplace Rules, we will give you written notice of such suspected violation, including the general nature of the activity observed. You will have the right to submit within ten (10) calendar days from the date of notification, a written explanation to us as to why no disciplinary action should be taken. You agree and understand that you are obligated to respond in writing to any queries from us within the time period for response set forth therein and to furnish documents and other information in connection with any investigation initiated under these Marketplace Rules. Following the conclusion of the investigation, we will make a determination, in our sole discretion, as to whether your conduct violated these Marketplace Rules. If we determine that you have violated these Marketplace Rules, in addition to terminating your Account, we may notify our regulators, self-regulatory organizations, including any organizations with which we share Market Data, and law enforcement of the activity, including your identity, and you agree to the same.