Addendum – Custody of Crypto-Assets

Legal & Privacy

Addendum – Custody of Crypto-Assets – Young Platform

Last updated: 14.05.2025

This Addendum constitutes an Annexe to the General Terms and Conditions of Young Platform S.p.a. (the “Terms and Conditions”) and forms an integral and substantial part thereof. For the Terms and Conditions, the custody and administration service of crypto-assets described herein (the “Custody Service”) shall in all respects be considered a “Service” as defined under Article 2 of the Terms and Conditions. In the event of any conflict between the provisions of the Terms and Conditions and those of this Addendum, the latter shall prevail, but solely concerning the regulation of the Custody Service.

Identity of the Parties

The service is provided by Young Platform S.p.a., with its registered office at Via Francesco Cigna no. 96/17, Turin (TO). Young Platform is a crypto-asset service provider (CASP). The User is the natural or legal person who uses the custody and administration service of crypto-assets provided by Young Platform.

Nature and Description of the Crypto-Asset Custody Service

Young Platform provides custody and administration services for crypto assets on behalf of users. This means that Young Platform is responsible for safeguarding and managing the Users’ digital crypto-assets, ensuring their protection and security. The service includes the custody of crypto-assets in a unified dedicated wallet, which is formally registered in the name of Young Platform but structured in such a way as to ensure the technical and accounting segregation of individual holdings. It also comprises transaction recording, balance reconciliation, and the implementation of security measures designed to protect the crypto-assets from unauthorised access, loss, or theft. The Custody Service is made available to the User via the Platform, subject to acceptance of this Addendum. It constitutes a Tool for the purposes and effects of the General Terms and Conditions.

Custody Policy

Customer crypto-assets are held within a secure and resilient infrastructure, designed to ensure the integrity, availability, and traceability of digital assets at all times. Young Platform adopts a custody model supported by Fireblocks Ltd., a provider specialising in technological solutions for the custody and security of crypto-assets. Customer crypto-assets are stored in a dedicated wallet, separate from the Company’s wallets.

The custody of crypto-assets is managed by adopting advanced security measures, including the use of Multi-Party Computation (MPC) technology for managing cryptographic keys, and the operational and accounting segregation of customer crypto-assets. Segregation is achieved through the individual management of positions via unique deposit addresses and customer identifiers, an analytical accounting system that ensures continuous alignment between actual holdings and internal records, and a combination of automated controls and manual verifications that validate each transaction.

The entire configuration is designed to prevent any commingling between customer crypto-assets and those of the Company, and to ensure that such assets are excluded from the insolvency estate in the event of the service provider’s bankruptcy.

Means of Communication and Customer Authentication System

Communications between Young Platform and the User shall primarily take place via email, using the address provided by the User during the registration process. Young Platform reserves the right to employ other means of communication as well.

To access their account and utilise the services, the User must use their login credentials (username and password). The User is responsible for maintaining the security and confidentiality of their credentials and must not disclose them to third parties. If the credentials are compromised, the User must promptly notify Young Platform. The latter may also offer additional security measures, such as multi-factor authentication.

Security Systems Employed

In addition to the security measures outlined in the General Terms and Conditions, this Addendum details the specific safeguards relating to the Custody Service. Access to and transfer of crypto-assets are subject to multi-level authorisation rules, based on the distribution of cryptographic keys among several authorised internal personnel; the use of secure signing devices subject to continuous monitoring and advanced authentication; and a system of predetermined transaction policies governing limits, signature thresholds, and approval criteria depending on the nature of the transaction. The system is designed according to a “block by default” model: no transaction may be executed outside expressly authorised scenarios. This ensures robust protection against potential risks, including fraud, human error, or external attacks.

Young Platform implements a range of security systems to protect customers’ crypto-assets. These include:

Protection of cryptographic keys using Multi-Party Computation (MPC) technology, which involves splitting the private key into multiple cryptographic fragments (key shares) stored separately;
Access control and privilege segregation, to ensure that only authorised personnel within the Company can access critical systems;
Prevention and detection systems for unauthorised access, such as multi-factor authentication and real-time access monitoring;
Business continuity and disaster recovery measures, to ensure the availability of crypto-assets even in the event of unforeseen incidents;
A structured incident management framework enables timely responses to events that may compromise crypto-assets’ security.

Furthermore, Young Platform adopts a consistent set of organisational, technical, and procedural measures to ensure that the crypto-assets held on behalf of customers are at all times:

Identifiable and traceable;
segregated from those of the Company;
immediately available to the User;
Not at risk of misuse.

To this end, weekly reconciliations are carried out between internal records and actual holdings; a weekly Proof of Solvency is conducted, demonstrating the existence and complete coverage of Users’ aggregate positions; and second-level controls by the Compliance Function are performed, alongside periodic audits, including independent ones.

Management of Rights Related to Crypto-Assets

In compliance with applicable regulations, Young Platform ensures, where technically feasible, the management of rights related to the crypto-assets held on behalf of clients. This includes the exercise of automatic or passive rights associated with having such assets, and participation in distribution mechanisms, where compatible with the custody system. Each relevant event is assessed on a case-by-case basis and, where it is not possible to proceed securely with execution, the client is promptly informed, along with the reasons for such a decision.

Transparency Towards Clients

Young Platform adopts a transparent and proactive approach to managing custody services. In particular:

The dedicated area of the platform allows each user to access their updated crypto-asset balance and the historical record of completed transactions in real time.
A monthly summary report containing the balance, transactions carried out during the period, and any other relevant additional information is made available.
Upon registration, the User receives clear information regarding the custody model, the guarantees provided, and applicable limitations. Any substantial changes to the operational model are promptly communicated, by the principles of good faith and contractual transparency.

Fees, Costs and Charges

Information regarding the fees, costs, and charges applied by Young Platform for the custody service of crypto-assets is available in the “Fees and Pricing” section of the Young Platform website, accessible via the following link: https://exchange.youngplatform.com/fees.

Applicable Law

This Addendum applies in conjunction with the Terms and Conditions, which generally govern the use, responsibilities, and management of the contractual relationship.

Thank you for your attention.
Last modified on 14.05.2025