Update of our User Agreement

As previously announced, Bitonic has obtained the Markets in Crypto-Assets Regulation (MiCAR) license from the Dutch Authority for the Financial Markets (AFM). As a result, several changes are being made to our User Agreement, as well as to its annexes, including the privacy policy. These changes apply to both private and business customers.

The main updates

Supervision from DNB to AFM

The introduction previously stated that Bitonic was registered with De Nederlandsche Bank (DNB). This has now changed to a license from the Dutch Authority for the Financial Markets (AFM), including the authorisation number. It has also been clarified that the AFM is the primary supervisory authority, while DNB remains responsible for prudential supervision of Bitonic.

Processing of personal data under MiCAR and TFR

Our privacy policy now clarifies that the processing of personal data is necessary to comply with legal obligations applicable to Bitonic, including obligations arising from MiCAR and TFR. The latter regulation is particularly relevant for sending information about the sender in order to comply with the travel rule.

Minor language and style updates

We have made several minor language and style adjustments to improve readability. Additionally, the service name Bitonic Auto Invest (formerly: Bitonic Savings) has been updated. To enable similar minor updates in the future that do not materially impact the rights and obligations of our customers, we have amended article 22 section 3. This allows us to make linguistic corrections and editorial changes without burdening customers with unnecessary updates. All other changes will, of course, be communicated by email and will take effect thirty (30) days after notification.

Third parties

For marketing and informational emails that do not process customer data (other than the name), we switched earlier this year to the email provider Mailgun. Since emails sent from our own server were often marked as spam (for example by Microsoft, which may consider the word "bitcoin" suspicious), we will be switching account-related emails to the new email provider Scaleway. This change is intended to ensure that our emails no longer end up in spam folders and is reflected in our privacy policy. In addition, we have added Bluem, Factiva and Notabene as data providers.

DAC8

In preparation for the European DAC8 directive, we have updated our privacy policy. This allows us to request and store certain information from customers registering with us from 1 January 2026, ensuring Bitonic can meet its legal obligations.

OTC

Executing orders on behalf of customers is a specific regulated service under MiCAR. Therefore, we have made several changes to article 13. For example, our OTC customers must explicitly agree to the Order Execution Policy (OTC addendum). This addendum has also been updated stylistically to make it easier for customers to sign.

Deposits and withdrawals

Providing transfer services is also a specific regulated service under MiCAR. In plain terms: depositing or withdrawing bitcoin. To formalise the rights and obligations of both Bitonic and the customer, we have introduced a new article 14.

Do you have any questions?

Please read these changes carefully and familiarise yourself with the changes. If you have any questions, feel free to contact us via email, chat, or by phone: +31 (0) 20 226 5289 (Mon - Fri, 10 AM - 12:00 PM).

Read our User Agreement here.