At a glance

  • Your crypto-assets are held in blockchain addresses that belong only to you. We do not pool client assets, and we do not mix them with our own.

  • We do not hold client money in fiat (EUR, CHF, USD, etc.). All cash settlement runs through regulated banking and payment partners.

  • The cryptographic keys that control your assets are encrypted, stored in protected infrastructure, and can only be used by an isolated signing system. They cannot be used directly by individual staff, including administrators.

  • Every withdrawal is checked against the address you have pre-approved and is screened by an automated compliance system before it can leave your wallet.

  • If Floin were to become insolvent, your crypto-assets do not form part of our estate and are not available to our creditors.

1. Your crypto-assets are kept separate from ours

Each client at Floin is assigned their own unique blockchain address(es) for every blockchain network they use (e.g., Bitcoin, Ethereum, Polygon). Your assets are held in those addresses and only those addresses.

We do not operate "omnibus" or pooled custody wallets (i.e., wallets that mix the holdings of multiple clients together). Your balance on our internal records is always backed one-to-one by the corresponding on-chain balance in your dedicated address(es).

Floin also holds its own operational wallets, used for our business operations (for example, for executing exchange transactions). These wallets are technically and logically separate from client custody wallets. Client custody balances are never held in Floin operational wallets, and Floin operational assets are never held in client custody wallets.

2. We do not hold your money in fiat

Floin's regulated activity is the custody, administration and exchange of crypto-assets. We do not provide client fiat accounts and we do not hold client money in fiat currency.

When you buy or sell crypto-assets through Floin, the fiat side of the transaction is settled through designated banking and payment partners that are themselves regulated for that purpose. We select these partners based on their regulatory status, jurisdiction, and operational reliability, and we review the arrangement at least annually.

Because Floin does not hold client funds in the sense of Article 70(2) MiCAR, neither the safeguarding rules for client money under Article 70(2), nor the related deposit rule under Article 70(3) (which would otherwise require client funds to be placed with a credit institution or central bank by the next business day), arise in Floin's business model. The protections described on this page concern your crypto-assets.

3. How we protect access to your assets

Control of a crypto-asset comes down to control of the cryptographic key associated with its blockchain address. Floin's key-safeguarding approach is built on two principles:

  • No single person can move your assets: Cryptographic keys are protected by Floin's infrastructure and cannot be used directly by individual employees, including administrators. Transactions are only signed once the system has independently verified that all required conditions are met (see Section 4).

  • Defence in depth: Keys are held in a protected environment with strict access controls, continuous monitoring, and full audit logging of any custody-relevant action.

The detailed technical and operational measures behind these principles are governed by Floin's internal policies and are audited regularly. We do not publish further implementation details, as doing so would itself create a security risk.

4. Every transfer is checked before it leaves your wallet

External withdrawals can only be sent to addresses you have pre-approved on your account. Every transfer is screened by our automated controls, and any transaction that does not pass those checks is paused and reviewed by our Compliance team before it can proceed. All custody-relevant actions are logged for audit purposes.

5. We continuously check that our records match the blockchain

Floin maintains an internal register that records, per client, the crypto-assets you hold with us. That register is reconciled on a recurring basis against the actual on-chain balances in your custody wallets. Any unexplained difference is treated as a custody incident and escalated immediately.

You can check your balances and transaction history at any time through your account on our platform, and you receive an electronic statement of position at least once every three months.

6. What happens if something goes wrong

Insolvency: If Floin were to become insolvent, your crypto-assets are not part of our estate and our creditors have no claim on them. The segregated structure described in Sections 1 and 5 is what makes this protection effective in practice.

Loss caused by us: In accordance with Article 75(8) MiCAR, Floin is liable to you for the loss of crypto-assets, or of the means of access to them, where the loss results from an incident attributable to our operations. Liability is capped at the market value of the affected crypto-assets at the time the loss occurred. Exceptions and force majeure are set out in our Terms of Service.

If an incident occurs: Floin maintains documented incident-response procedures designed to contain the impact, protect client assets, and inform affected clients without undue delay. The detailed procedures are set out in our internal incident response framework and are not published publicly.

7. Getting your crypto-assets back

You can request the return of your crypto-assets at any time through your Floin account.

After we verify your identity using our pre-established authentication methods (with additional manual review and four-eye control, if needed), the assets are transferred to one of the external addresses you have previously whitelisted on your account. The return is executed without undue delay, and a confirmation is recorded in your transaction history.

8. Information and updates

You receive information about your assets through several channels:

  • Continuous access to your balances and transaction history via your Floin account.

  • A quarterly electronic statement of position listing your holdings, balances, market values, and the transactions completed during the period.

  • Event-based notifications, for example where a blockchain event (such as a fork) affects your holdings, or where action is required from you.

This page is reviewed at least once a year as part of Floin's annual safekeeping and segregation review. We update it whenever there is a material change to the systems, policies or procedures described here.

9. Where to find more detail

The arrangements summarised on this page are governed in detail by:

  • The Standard Custody and Transfer Services Agreement that you accepted when opening your Floin account.

  • Our Custody and Administration Policy (P06) and our Segregation and Safekeeping of Clients' Crypto-Assets and Funds Policy (P03), available to clients on request in electronic format.

If you have any questions about how Floin safeguards your assets, please contact us at [email protected].