This disclosure is presented to you at the time of opening your account, is incorporated by reference into the Terms and is available to you on the website and mobile application of Bitbuy Technologies Inc. (“Bitbuy” or “we”). This disclosure provides details about our services, the features of your account, how they operate and our responsibilities to you. By opening an account with Bitbuy’s crypto asset trading platform (the “Platform”), you are acknowledging having received, read and understood this disclosure.
The Platform enables Canadians to buy, sell, hold, withdraw and deposit crypto assets. The Platform is made available through Bitbuy’s website and mobile application. Bitbuy has been registered as a restricted dealer in every jurisdiction of Canada subject to specified terms and conditions that are the subject of a specific order and as such may not be subject to all requirements otherwise applicable to an investment dealer and IIROC member, including those that apply to marketplaces and to trading on marketplaces.
Bitbuy is not a member of the Canadian Investor Protection Fund. Crypto contracts and crypto assets purchased and held in an account with Bitbuy are not protected by the Canadian Investor Protection Fund, the Canadian Deposit Insurance Corporation or any other investor protection insurance program.
The following is additional information concerning your relationship with Bitbuy:
The Nature of Your Account with Bitbuy
When you open an account with Bitbuy, you enter into a contract with Bitbuy that provides you with the right to buy, sell, hold, withdraw and deposit crypto assets. When you buy or sell crypto assets using the Platform, you are placing buy and sell orders using the Platform’s order book and are therefore trading with other Platform users. Bitbuy enables you to use your own cash or crypto assets to purchase a crypto asset and then custodies that crypto asset for you should you decide not to withdraw it to a personal wallet. Crypto assets are owned by you from the time of purchase until the time of sale.
When entering into trades using the Platform, it is possible that 21 Digital Inc. (“21D”), an affiliate of Bitbuy, will be the counterparty to your order. 21D participates on the Platform in order to provide liquidity to the Platform. For more information concerning 21D’s participation on the Platform, please see our conflict of interest policies and procedures document.
Funding and Withdrawal
As Bitbuy does not offer margin or leverage, your account will need to be pre-funded to complete any trades on the Platform. Bitbuy allows you to fund your account in Canadian dollars by way of Interac e-Transfer or bank wire. Bitbuy also allows you to fund your account with any of the crypto assets we make available for trading on the Platform that you hold in a personal wallet. Similarly, you are able to withdraw: (i) Canadian dollars from your account using Interac e-Transfer or bank wire; and (ii) crypto assets to a personal wallet. For more information on the steps you need to take to fund your account or withdraw Canadian dollars or crypto assets from the Platform, please visit Bitbuy’s support page.
How Your Cash Is Handled
Users’ cash assets are held separate from Bitbuy’s own funds in segregated accounts with Credit Union Atlantic, a Canadian financial institution, and People’s Trust, a Canadian trust company. When you wish to purchase crypto assets using cash, you will instruct Bitbuy to transfer the cash held on your behalf with Credit Union Atlantic and/or People’s Trust to fund your purchase. When you sell crypto assets from your account with Bitbuy, the cash proceeds will be transferred by Bitbuy to Credit Union Atlantic and/or People’s Trust. There may be risk in permitting Bitbuy to have access to your cash in this manner insofar as it could be accessed improperly and misused. However, access to your cash is permitted only to settle transactions initiated by you.
How Your Crypto Assets Are Handled
Bitbuy allows and encourages users to withdraw crypto assets purchased on the Platform to their own private wallets. However, Bitbuy recognizes that certain customers may desire the convenience of relying on Bitbuy’s custodial solutions. If you do not withdraw your crypto assets to a personal wallet, Bitbuy stores all of the crypto assets that you own with BitGo Trust Company (“BitGo”), a third-party custodian. BitGo is regulated as a trust company under the Division of Banking in South Dakota. The holding of your crypto assets with a third party custodian may increase certain risks when compared to you holding your assets on a private wallet. In particular, you may be exposed to insolvency risk (credit risk), fraud risk or proficiency risk on the part of Bitbuy. You may also face risk in permitting Bitbuy to have access to crypto assets owned by you that are held with BitGo, in the event that crypto assets could be accessed improperly and misused. Neither Bitbuy nor BitGo will pledge, re-hypothecate or otherwise use your crypto assets in the business of Bitbuy or its affiliates.
Risks and Descriptions of Crypto Assets
Bitbuy believes that our users should understand the crypto assets that they are able to trade on our Platform, as well as the general and specific risks involved in trading them. For more information on those crypto assets and the specific and general risks involved in trading them, you should review the plain language statements for each crypto asset and the risk disclosure document we prepare for our users. In addition, Bitbuy encourages you to carefully consider whether crypto assets are suitable investments for you given your financial resources, investment experience and knowledge, investment objectives, time horizons and risk tolerance. Trading in crypto assets may not be suitable when using retirement savings, borrowed funds, emergency funds or funds set aside for other specific purposes.
Conflicts of Interest
Bitbuy has implemented policies and procedures which allow it to identify, handle and prevent conflicts of interest arising in connection with its operation of the Platform, including in respect of 21D’s participation on the Platform. For more information, please see our conflict of interest policies and procedures document.
Charges and Other Compensation
Except for trades conducted using the Platform’s Express Trade feature, which are subject to a standard fee of 0.5%, Bitbuy charges “maker” and “taker” fees on the trades conducted on the Platform. The maker and taker model is a way to differentiate fees between trade orders that provide liquidity (“maker orders”) and take away liquidity (“taker orders”). Maker and taker trade orders are charged different fees. A trade order gets the maker fee of 0.1% if the trade order is not matched immediately against an order already on the order book, which adds liquidity. A trade order gets the taker fee of 0.2% if the trade order is matched immediately against an order already on the order book, which removes liquidity. Bitbuy also charges fees on the deposit and withdrawal of cash as well as the withdrawal of crypto assets. No compensation will be paid to Bitbuy by any other party in relation to the Platform. For more information on the fees charged by Bitbuy in connection with its operation of the Platform, please see our fee schedule.
Reporting
From Bitbuy, you will receive electronic trade confirmations setting out the details of your transactions. You will also be able to access and download statements setting out details of your transaction history at all times when the Platform is operational.
Complaints and Dispute Resolution
The members of Bitbuy Technologies Inc. (Bitbuy) take your complaints seriously and are committed to helping resolve your complaint about Bitbuy or the service you’ve received.
The Bitbuy platform is operated by Coinsquare Capital Markets Ltd. (CCML) and as a user of Bitbuy, you are a client of CCML.
Step 1 – Voice Your Complaint
Should you wish to make a complaint, please raise the issue as soon as it comes up. Contact our Client Success team that will attempt to address your concerns or will forward your complaint to the appropriate team as required.
If you're not completely satisfied with the response that you have received from our Client Success representatives, you may request that your concerns be escalated to the Compliance team. You can also directly request our Compliance team to review your complaint.
By Email - complianceteam@coinsquare.com
By Mail -
Chief Compliance Officer
Coinsquare Capital Markets Ltd.
110 Cumberland St, Unit 342
Toronto, ON, Canada M5R-3V5
Use the complaint process to tell us about:
Note that service-related issues about your account are handled by our Client Success team. A complaint which is deemed to be service related involves issues which are not subject to any regulatory rules or policies of any securities or financial services regulatory or self-regulatory organization in any jurisdiction either inside or outside of Canada; or any legislation or law concerning securities or exchange contracts of any jurisdiction either inside or outside of Canada.
Step 2 – Complaint Examination
If your complaint is not a service-related issue or if it includes an allegation of misconduct or wrongdoing on the part of CCML, we are required to review those allegations of misconduct or violation of applicable securities laws on the part of CCML or its employees. Complaints handled by the Compliance team will be handled as follows.
We Will Acknowledge Your Complaint
Within five (5) business days of us receiving your complaint, you will be provided with an acknowledgement email from our Compliance Department confirming:
The CIRO brochures concerning the complaint handling process and investor protection entitled ‘How to Make A Complaint’ and ‘How CIRO protects investors’. These brochures (and additional information) are available on the following pages of the CIRO website:
Step 3 – Complaint Resolution
Within ninety (90) calendar days you will be provided with our substantive response to your complaint, or correspondence acknowledging that we require more time or information to complete our review and resolve your complaint.
Our Substantive Response
We will provide our conclusion via the substantive response letter that includes:
Not Satisfied with Our Decision?
If you are not satisfied with our decision, there are different options available to you depending on the province or territory you live in including:
Note that there are time limits with the options mentioned above and delays could hamper your ability to pursue these opportunities.
Have any questions? Please contact us at complianceteam@coinsquare.com.
Suitability
We are required by law to assess whether a purchase or sale of a crypto asset is suitable for you prior to trading with another investor. While our onboarding process is designed to tell us whether you are (or are not) a suitable candidate for the Platform, it is important to understand that you will not get advice from a human being and you must conduct your own due diligence on crypto assets.
The amount of crypto assets you are able to trade on the Platform may be limited to the extent that: (i) you are not an accredited crypto investor or eligible crypto investor; and (ii) financial resources, investment experience and knowledge, investment objectives, time horizon and risk tolerance demonstrates it would not be suitable for you to invest more than a specified portion of your net financial assets in crypto assets.
With respect to the former limits, Bitbuy ensures that the maximum amount of crypto assets, excluding Bitcoin, Ether, Bitcoin Cash and Litecoin, that an investor may purchase on a net basis on the Platform in the preceding 12 months:
With respect to the latter limits, Bitbuy has designed a proprietary algorithm that analyzes the information you provide to us on account opening and during the course of our relationship with you to determine a concentration limit applicable to your account. This concentration limit is established to prevent overconcentration in crypto assets offered on the Platform and is based on your financial resources, investment experience and knowledge, investment objectives, time horizon and risk tolerance. If you propose to purchase a crypto asset on the Platform which would result in your total crypto holdings on the Platform to exceed the concentration limit applied to your account, you will be provided with a notification warning you that the trade has been deemed unsuitable for you.
Information Collected by Bitbuy
You will be asked to fill out brief assessment on your knowledge and experience with crypto assets when you open your account and will also be asked to provide certain personal and financial information in order for us to conduct our suitability assessment (see “Suitability” above for more information). In addition, you must also satisfy the “know your client” requirements set by Bitbuy from time to time, which are designed to comply with the requirements set by applicable securities regulations and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations.
Historical Price Data
You will have access to historical pricing information and performance graphs and data for crypto assets made available on the Platform.
