Legal іnformation

Impressum

Hyphe Markets GmbH
Adelgundenstraße 2
80538 München
Germany

Web: www.hyphe.com
Email: [email protected]
Contact us: https://hyphe.com/contact

Board of Directors: Dolf Diederichsen (Geschäftsleiter Markt, CEO), Claus Huth (Geschäftsleiter Marktfolge, COO)

Legal form: Limited liability company (Gesellschaft mit beschränkter Haftung, GmbH)

Registered Office: München

Commercial Register: Amtsgericht München, HRB 272346

VAT Number: DE351368399

Legal Entity Identifier (LEI): 3912000K5NAA00M4HH04

Supervisory Authority:
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Graurheindorfer Strasse 108
53117 Bonn

Securities Supervision:
Marie-Curie-Strasse 24 – 28
60439 Frankfurt am Main

www.bafin.de

Compensation Scheme:
Entschädigungseinrichtung der Wertpapierhandelsunternehmen (EdW)
10865 Berlin

www.edw.de

Web: www.hyphe.com
Email: [email protected]
Contact us: https://hyphe.com/contact

Legal disclaimer

Hyphe Markets GmbH is a limited liability company which is licensed under Section 15 (1) German Investment Firms Act (WpIG) as regards proprietary trading (Eigenhandel) (Section 2 (2) no. 10c WpIG), proprietary business (Eigengeschäft) (Sec. 15 (3) WpIG) and under Markets in Crypto Assets Regulation (MiCAR) as regards exchange of crypto-assets for funds (Art. 3 (1) Nr. 16c, Nr. 19 MiCAR).

Disclaimer of liability

The trading of digital currencies involves significant risk. Any decision to purchase or sell digital currencies is your own decision and Hyphe Markets GmbH cannot be held liable for any loss or damage suffered. Information contained on this website does not constitute any legal or investment advice. We accept no liability for the content of external websites to which we link.

Accountability for content

We have taken the utmost care in creating the content of this website and always endeavor to provide up-to-date and correct information. Nevertheless, we cannot assume any liability for the accuracy, completeness and topicality of the information. As a service provider, we are responsible for our own content on these pages in accordance with Section 7 (1) German Telemedia Act (TMG). However, in accordance with §§ 8 to 10 TMG, we are only responsible for third-party content that is made accessible via this site if we are aware of illegal activity and it is technically possible and reasonable for us to prevent its use. We accept no liability for decisions you make on the basis of the information provided here.

Copyright

All contents of this website, including texts, images, graphics, videos, sounds and software, are protected by copyright. Unless otherwise stated, the rights are held by Hyphe Markets GmbH. Any use that goes beyond the legally permitted private use requires the prior written consent of the rights holder. This applies in particular to reproduction, distribution, making available to the public, editing, translation, storage, processing and any other use.

Trademark protection

All trademarks used on this website are protected by law.

Privacy policy

Your privacy matters to us. In this Hyphe Markets Website Privacy Statement we explain how Hyphe Markets GmbH (“Hyphe Markets”) collects, uses and processes your personal data collected through our website www.hyphe.com, and our interactions with you via this website.

We may change this Hyphe Markets Website Privacy Statement from time to time. At all times, we will publish the up-to-date version on our website. For this reason, we suggest that you review this Hyphe Markets Website Privacy Statement on a regular basis. If we make any important changes to this Hyphe Markets Website Privacy Statement (e.g. with regard to the personal data we collect, how we use it or why we use it).

1. Who is the data controller?

Hyphe Markets GmbH, Adelgundenstraße 2, 80538 München, is the controller of the personal data processed on our website.

If you have any questions or complaints in relation to the use of your personal data or if you would like to receive more information about how Hyphe Markets processes your personal data, please contact us via [email protected].

2. What types of personal data do we collect?

Via our website, we collect, store, and use the following personal data about you.

Personal data relating to you as a website visitor

• Contact request form data, such as your name, telephone number, business email address and company;
• Research data from public sources, such as your name, telephone number, business email address and company;

Personal data relating to your use of our website

• Personalised data, such as your search terms used to reach our website via external search engines, search terms used in the search engine on the website itself and links used to reach our website (referrers);
• Equipment data, such as your equipment type and brand, IP address, browser and operating system;
• Web analytics data, such as details of your visits to our website, the resources that you access, traffic data, geographic data, weblogs, contact preferences, online identifiers (such as IP address) and hardware attributes.

Personal data relating to your use of our communications functionality

• Communication and contact data, such as the information included in the contact request form and email communication with you, such as your name, telephone number, business email address and company.

Personal data relating to applications that you send us

• General personal data (name, address, contact details, etc.);
• Information on your professional qualifications and school education;
• Further professional training;
• Your employment history;
• For specific positions, we might ask for a certificate of good conduct;
• Other data that you provide to us in connection with your application.

3. How do we obtain your personal data?

Your personal data is (i) provided by you and (ii) created by us in the course of your usage of our website, (iii) obtained by us from public sources (e.g. company websites, LinkedIn etc.) or through recruiting companies.

4. Why do we process your personal data and what is the applicable legal basis for our data processing?

Please find below an overview of each of the purposes for which we process your personal data as set out in paragraph 2 and the legal basis relied upon:

• Maintenance of a business relations database;
  Legal Basis: necessary for the purpose of our legitimate interest, namely to adequately manage our business relations.
• Maintenance of a customer database;
  Legal Basis: Necessary for the purpose of our legitimate interest, namely to maintain an adequate business administration.
• Answer to contact requests;
  Legal Basis: Necessary for the purpose of our legitimate interest, namely to reply to your contact requests.
• Strategic marketing research;
  Legal Basis: Necessary for the purpose of our legitimate interest, namely to improve our products and services.
• Sending and analysing direct marketing communications by Hyphe Markets, including newsletters, surveys and new website features;
  Legal Basis: Consent based on e-Privacy regulations.
• Maintaining and ensuring a secured online environment on our mobile application and website;
  Legal Basis: Necessary for the purpose of our legitimate interest, namely to maintain a secure online environment on our website.
• Creating analytical reports for improvement of our website;
  Legal Basis: Necessary for the purpose of our legitimate interest, namely to maintain and improve our website’s performance.
• Establishment of an employment relationship;
  Legal basis: for purposes of a potential employment relationship, Art. 88 GDPR (in conjunction with Section 26 BDSG for applicants in Germany);
  If an employment relationship arises between you and us, we may, in accordance with Art. 88 DSGVO (in conjunction with Section 26 BDSG), further process the personal data already received from you for the purposes of the employment relationship, insofar as this is necessary for the implementation or termination of the employment relationship or for the exercise or fulfillment of the rights and obligations of the employee representation resulting from a law or a collective agreement, a company or service agreement (collective agreement);
• Legal claims (Art. 6 Para. 1 lit. f GDPR);
  We may process personal data from you if this is necessary for the or for the defense or assertion of legal claims. The legitimate interest is, for example, a duty of proof in proceedings under the German General Equal Treatment Act (AGG);
• Express Consent (Art. 6 (1) lit. a GDPR);
  If you give us express consent to process personal data for specific purposes, the lawfulness of this processing is based on your consent pursuant to Art. 6 (1) lit. a GDPR. Consent given can be revoked at any time with effect for the future (see section 9 of this data protection information).

5. Who do we share the personal data with?

Your personal data may be processed on our behalf on the basis of order processing contracts pursuant to Art. 28 GDPR. In these cases, we ensure that the processing of personal data is carried out in accordance with the provisions of the GDPR. The categories of recipients in this case are providers of internet service providers as well as providers of personnel services including but not limited to the following third parties:

• Google LLC;
  Purpose: Google Analytics.
• Google LLC;
  Purpose: Google Tag Manager.
• Google LLC;
  Purpose: Communication via e-mail.
• LinkedIn Ireland Unlimited;
  Purpose: LinkedIn Insight Tag.
• Facebook Ireland Limited;
  Purpose: Facebook Pixel.
• Vimeo.com Inc.;
  Purpose: Video hosting
• De Nederlandsche Bank N.V.;
  Purpose: Regulatory supervision
• Bundesanstalt für Finanzdienstleistungsaufsicht;
  Purpose: Regulatory supervision.
• Public Prosecutor’s Office;
  Purpose: To comply with a legal obligation and to detect and prevent money laundering.

Further, we may disclose or share your personal data if:

• we sell our company or part thereof (including separate assets), or if we merge with another company. In such event, we may share your personal data with the new owner or merging party respectively, but only to the extent necessary for the purpose for which your personal data are processed;
• we are subject to insolvency proceedings, as part of the sale of our assets by a liquidator (or similar); or
• we are legally obliged to do so. In such an event we shall share your personal data with the relevant supervisory authority, investigative authority or other governmental body.

6. Third party sites

Our website may contain links to websites operated by third parties. This Hyphe Markets Website Privacy Statement does not apply to these third party websites or services. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms and conditions and that we do not accept any responsibility or liability for their policies. Links should be clicked at your own risk, and it is your sole responsibility to review the applicable privacy policy and terms and conditions of any third party website accessed.

7. What about cookies?

To enable our systems to recognise your browser or device and to provide and improve our website, we use cookies and other identifiers. For more information about cookies and how we use them, please read Hyphe Markets Cookie Notice.

8. How long do we retain your personal data?

We do not process your personal data any longer than necessary for the processing purpose. In this context, we keep your personal data two years after the relationship with you as a client has been terminated or two years after receipt of your contact request if no further customer relationship is established. If we are subject to a statutory retention period, we will retain your personal data for the period specified by the law.

Notwithstanding the above, we may retain your personal data for the establishment, exercise or defence of legal claims. Likewise, we may retain your personal data in order to make it available to regulatory authorities, law enforcement, the public prosecutor, the courts and public administrations for the period specified by the law.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such personal data without further notice to you.

9. Where do we store your personal data?

Your personal data is stored in the European Economic Area (EEA).

In case of transfers of personal data to countries outside the EEA, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

10. What are your rights?

You have the right to access your personal data, the right to have your personal data rectified or erased, the right to restriction of the processing, the right to data portability and the right to object to the processing. Most of these rights are not absolute and are subject to exemptions in the law.

Below we set out your rights in more detail and give information on how you can exercise these. We will respond to your exercise of right request within one month, but have the right to extend this period to two months. If we extend the response period, we will let you know within one month from your request.

• Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If your request is clearly unfounded or excessive we reserve the right to charge a reasonable fee or refuse to comply in such circumstances;
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims;
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
• Data portability: you may request the transfer of a copy of certain of your personal data to you or another party (if technically feasible). You have the right to ask that we provide your personal data in an easily readable format to another company;
• Objection: where we are processing your personal data based on our legitimate interest, you may object to processing on this ground. However, applicable laws may allow us to continue processing your personal data based on our legitimate interests.

Where you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.

If you want to exercise any of these rights, or withdraw your consent, please contact us at [email protected].

11. How can you lodge a complaint with a supervisory authority?

If you have any complaint about the way we process your personal data, you may lodge a complaint with a supervisory authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. A list of EU supervisory authorities and their contact details is available here.

Last updated: August 1, 2024

Cookie notice

We, Hyphe Markets GmbH including all its affiliates (together “Hyphe Markets”, “us”, “our”, or “we”), use cookies and other similar technology on our website. This Cookie Notice informs you about our use of cookies and similar technologies and our contact details in case you have any questions concerning this Cookie Notice.

This Cookie Notice applies to our website, https://hyphe.com. If we collect your personal data via cookies and similar technologies, our Privacy Statement applies accordingly. Please find our Privacy Statement here.

We may change this Cookie Notice from time to time. At all times, we will publish the up-to-date version on our website.

You may give or refuse your consent to the use of various categories of cookies that are not strictly necessary, through our Consent Management Tool. You have the option to withdraw your consent at any time. We cannot guarantee that our website will function properly if you do not accept certain cookies; some functions may be lost or that you may not see certain pages at all.

1. What are cookies and similar technologies?

Cookies are small and simple text files that are stored on your computer or mobile device when you visit our website. 'Similar technologies' falling under the generic term 'cookies' also include local objects (sometimes called flash cookies), web beacons, pixels, browser fingerprinting technologies or any technology that stores or accesses information on the user's device.

2. Which cookies do we use?

We use first and third party cookies. First party cookies are cookies set by us. Third party cookies are cookies placed by a domain different from our domain. This means that someone other than us places these cookies. Please refer to any third party's privacy policy for more information on their processing of data collected through third party cookies.

We distinguish between the following types of cookies we use on our website:

• Essential cookies: We use these cookies for the sole purpose of carrying out or facilitating the transmission of a communication over an electronic communications network; and they are strictly necessary to provide you with the service you requested. Therefore, these cookies cannot be turned off; otherwise some technical functionalities are not able to operate properly. These cookies enable that you can access and use our website and ensure a proper performance, security and functionality of our platform. These cookies do not store any personal data. No consent is required for the use of essential cookies.

List of essential cookies at https://hyphe.com:

1. Cookie name: cookieNoticeApprovedByUser; Lifetime: 1 month; Storage location: the web browser; To which data does it refer: user accepted cookies on the website or not.

• Functional cookies: These cookies are optional and help you to have a better user experience on our website, namely to display drop down menus correctly and to ensure that you can easily click or swipe through the list of topics on our website.

• Analytical cookies: These cookies are optional and used to conduct research on user preferences, to estimate our audience size and to improve our website. These statistics give us more information on which pages are visited most, how visitors came to our website and which search terms are used in our search engine. Based on this research and analysis, we are able to provide our services and a better website. These analytical cookies are third party cookies set by Google, Linkedin and Vimeo which are different from our domain that you are visiting. We collect these statistics via the web analysing tools provided by Google, Linkedin and Vimeo. To comply with legal requirements, we have agreed on a data processing agreement with Google and LinkedIn and Vimeo, which, among other things, guarantees that Google and LinkedIn and Vimeo will not share any collected data with third parties.

List of Analytical cookies at https://hyphe.com:

1. Cookie name: UserMatchHistory. Description: LinkedIn Ads ID syncing. Duration: 30 days
2. Cookie name: AnalyticsSyncHistory. Description: Used to store information about the time a sync with the lms_analytics cookie took place for users in the Designated Countries. Duration: 30 days
3. Cookie name: li_oatml. Description: Used to identify LinkedIn Members off LinkedIn for advertising and analytics outside the Designated Countries and, for a limited time, advertising in the Designated Countries. Duration: 30 days
4. Cookie name: lms_ads. Description: Used to identify LinkedIn Members off LinkedIn in the Designated Countries for advertising. Duration: 30 days
5. Cookie name: lms_analytics. Description: Used to identify LinkedIn Members in the Designated Countries for analytics. Duration: 30 days
6. Cookie name: li_fat_id. Description: Member indirect identifier for Members for conversion tracking, retargeting, analytics. Duration: 30 days
7. Cookie name: li_sugr. Description: Used to make a probabilistic match of a user's identity outside the Designated Countries. Duration: 90 days
8. Cookie name: U. Description: Browser Identifier for users outside the Designated Countries. Duration: 3 months
9. Cookie name: _guid. Description: Used to identify a LinkedIn Member for advertising through Google Ads. Duration: 90 days
10. Cookie name: BizographicsOptOut. Description: Determine opt-out status for 3rd party tracking. Duration: 10 years
11. Cookie name: li_giant. Description: Indirect indentifier for groups of LinkedIn Members used for conversion tracking. Duration: 7 days

3. Your options

If you do not want to store cookies on your computer you can adjust your browser settings. You can also adjust your settings to the extent that your browser refuses all cookies or only those from third parties. You can delete cookies that have been placed. You will have to adjust the settings for each browser and computer you use. How to adjust these settings differs per browser. Click on one of the below icons to proceed directly to the manual of your browser or, if necessary, consult your browser's help function.

• Chrome
• Firefox
• Internet Explorer
• Safari
• Microsoft Edge

4. Questions

If you have any questions about this Cookie Notice, our Privacy Statement or our data processing activities, you can contact us via [email protected]

Asset documentation

Download table as .csv file here.
Download all ESG reports as PDF here.

Product announcements

Pricing policy (MiCAR)

1. Introduction and Purpose

The crypto-asset markets evolve rapidly, driven by innovation, client demand, and an increasingly complex regulatory environment.

Clients seeking to trade crypto-assets face significant variation in execution standards among exchanges, liquidity providers, and brokers. This can result in uncertainty regarding price, spreads, slippage, execution speed, hidden transaction costs, and associated risks.

Hyphe is committed to the highest possible standards of price determination, execution quality, and transparency. We aim to anticipate and comply with the strictest regulatory outcomes, including the Markets in Crypto-Assets Regulation (MiCAR).

This Hyphe Pricing Policy (“Policy”) describes the methodology used by Hyphe Markets GmbH (“Hyphe”) to obtain, when exchanging crypto assets for funds or for other crypto assets, the best possible result for its clients. It specifies:

• The methodology for determining the execution price of crypto-assets
• Applicable trading limits set by Hyphe for risk management purposes.
• Circumstances in which pricing may be adjusted due to market or client-specific risk factors.

2. About Hyphe

Hyphe provides regulated financial institutions with direct API-based access to deep crypto-asset liquidity. Operating a proprietary liquidity pool, Hyphe serves retail banks, brokers, asset managers and trading firms across a broad range of digital assets.

Hyphe Markets GmbH is licensed for proprietary trading under Sec. 2 (1) Nr. 10c of the German Wertpapierinstitutsgesetz (WpIG) and licenced as a crypto asset service provider to exchange of crypto-assets for funds in accordance with Markets in Crypto-Assets Regulation (MiCAR).

For further information: https://www.hyphe.com

3. Scope

This Policy applies to all client orders accepted by Hyphe for buying or selling of crypto assets, specifically:

• Exchange of crypto-assets for funds
Specific client instructions may override this Policy, but doing so may impact execution quality.

Exceptional circumstances: In the event of extreme volatility, system outages, regulatory restrictions, or other force majeure events beyond Hyphe’s control, Hyphe may suspend trading or apply temporary adjustments to pricing and/or limits. It is possible that in adverse market conditions different clients submitting orders with similar profiles with a slightest time difference may achieve different outcomes; including whether and when crypto assets or funds will be exchanged. Information shared in this document does not constitute any legal or investment advice. Furthermore, Hyphe may also provide information on (events that have affected) the price of digital currencies.

The trading of digital currencies involves significant risk, and in the worst case can lead to a total loss of the investment. Any decision to purchase or sell digital currencies is exclusively the individual decision of our trading partners/ clients, and Hyphe cannot be held liable for any loss or damage suffered. This policy applies to any of Hyphe’s legal entities and clients.

4. Definitions

5. Crypto-Assets

Hyphe’s actual product universe consists of a broad range of crypto-assets.

Hyphe has established clear criteria for a crypto assets to be added to the product universe, and any digital currency new to the universe is subject to a defined and strict due diligence process.

The criteria state that a cryptocurrency in Hyphe’s product universe

• must be reviewed regarding its nature, source, technical aspects and goals,
• must be covered by at least one of the exchanges or trading venues Hyphe is working with,
• must be traded regularly,
• must be covered by the tools Hyphe uses for the monitoring of crypto assets,
• must be compliant with any further regulatory requirements.

Additionally, the crypto-asset is checked internally regarding any known specific risk, negative information or reputational concerns in the public domain.

The due diligence process is initiated by Hyphe’s client facing business area Markets, assessed by Compliance, Risk Management and approved by the board of directors.

Hyphe conducts an annual review of any cryptocurrency in Hyphe’s product universe.

A full list of crypto-assets offered is available at hyphe.com/assets

This list is updated whenever a new crypto-asset is added to Hyphe’s product universe.

6. Order Types & Execution

Subject to individual agreement with our clients, we currently offer the following order types:

Quote Order: The client submits an offer to buy/sell a certain quantity of crypto assets. As a response, Hype sends a quote for that specific offer back, indicating the execution price in accordance with the pricing mechanism (see below Chapter “Price and Costs”.). The client can accept or reject this price. In the case of an accepted quote the order is deemed to be final and Hyphe can accept the order by executing to the quoted price.

Market Order: The client submits an offer to buy/sell a certain quantity of Crypto Assets without knowing the exact purchase price for this and grants Hyphe the right to set the purchase price in accordance with the pricing mechanism (see below chapter “Price and Costs”.). Hyphe can accept the Offer by naming the execution price. In this case the order is deemed to be final and will be executed to the named price.

Client orders are executed by Hyphe on an “over the counter” (OTC) basis between the client and Hyphe. Trades are executed via Hyphe’s proprietary API, Prime-Access, using the price finding method of Clear Calculus described below in the chapter “Price and Costs”.

7. Price, Costs and Order Limits

Hyphe assures a price finding using a unique and proprietary methodology to resemble pricing on crypto markets. The methodology, known as Clear-Calculus, gathers live order book data from multiple cryptocurrency exchanges and trading venues as described in chapter “Price Data Gathering”. Clear-Calculus generates quotes and prices for client orders and transactions, with the exception of agreed fixed prices if there is such an individual agreement between Hyphe and a client.

With the help of Clear-Calculus, Hyphe's price finding reflects the market for any respective crypto asset in a fair and transparent manner based on the current market conditions on cryptocurrency exchanges and trading venues as described in chapter “Price and Data Gathering”. The main method of Clear Calculus for determining the price of the crypto-assets that Hyphe proposes to exchange for funds is:

• the Hyphe Price, calculated on a weighted basis using live order book data from the exchanges Hyphe uses, also reflecting the spreads,
• the Liquidity Function in the respective digital currency,
• the Order Amount and
• Risk-Based Premium - where applicable, an adjustment for specific risk factors such as market volatility, liquidity stress, or the execution profile of a client’s trading activity, if these materially impact Hyphe’s execution costs or market risk exposure.

To find the Hyphe Price, regular order book snapshots from the exchanges are taken. As a starting point, we measure the current price of an individual exchange by decomposing its order book into symmetric bid-ask spreads whose mid prices serve as the atomic observations of the price. We then apply Bayesian weighting to these observations, i.e. we weigh each observation inversely proportional to its measurement variance. In turn, the measurement variance of each atomic observation is naturally defined by the size of its spread and its quoting amount. This calculation is carried out for the cryptocurrency exchanges and trading venues as described in chapter “Price and Data Gathering”. The weighting of the individual exchanges is also performed automatically by using the same Bayesian approach, i.e. we weigh each exchange’s fair price inversely proportional to the variance of its measurement. These calculations are performed several times per second for each cryptocurrency. Each time the calculations are performed, we define the result as the concurrent fair price, which is directionally unbiased and fully independent of our clients trading flow.

To account for Liquidity Function, we take Hyphe’s liquidity book into consideration and we analyse the live order book snapshots from the connected exchanges as described in chapter “Price and Data Gathering” again to assess the premium for different order sizes, resulting in a liquidity function for bids and asks for each cryptocurrency.

To arrive at the execution price for a given Order Amount we combine the Hyphe price with the liquidity function as described above. If risk factors as described above materially change Hyphe’s cost of execution or risk profile, an additional Risk-Based Premium may be applied to the liquidity function in a rules-based and pre-defined manner, ensuring the resulting execution price remains consistent with the principles of fairness, transparency, and proportionality.

The fees paid by clients per trade are agreed upfront depending on defined traded crypto asset groups and thus, ensuring that any transaction cost included in the spread has already been detailed in a clear and transparent manner. Where a maximum fee has been agreed with a client, this applies only to the scope, instruments, and trading volumes defined in the respective agreement, and may exclude the application of risk-based adjustments outside these parameters. For Hyphe’s clients, there are no additional trading costs beyond those described in this chapter.

Hyphe sets further customised trading limits are set based on risk management requirements and the liquidity of the individual asset groups:

• Daily limit: net trading volume across all asset groups per trading day that a Client can trade with Hyphe
• Order limit: limit per order that a Client can trade with Hyphe. The order limit can be different for buy and sell orders.

Limits are set based on asset liquidity and Hyphe’s risk capacity and agreed upfront with the Client.

8. Price Data Gathering

Hyphe uses multiple cryptocurrency exchanges and trading venues to gather live order book data for Clear-Calculus. We consider the selection of these venues as an important measure to assure Hyphe’s Pricing, as the pricing methodology (as described in section 7 of this Policy) is based on those venues’ order book data.

Hyphe has established clear criteria for any venue it uses in this sense. Any new exchange or trading venue is subject to a defined and strict due diligence process.

The criteria state that an exchange or trading venue used by Hyphe must:

• be incorporated in a location that is not on the list of countries with heightened or high money laundering, terrorist finance, or similar Compliance risks (acc. to Hyphe´s internal Compliance standards) and
• be regulated in an EU member state,
• is trading in Euro,
• have an EU-IBAN,
• be accessible regularly.

Additionally, the venue's business model, client structure and execution standards are reviewed internally regarding any known risks, negative information or reputational concerns in the public domain.

The due diligence process is initiated by Hyphe’s trading department, assessed by Compliance and approved by the board of directors. Following the criteria described above, Hyphe has chosen multiple exchanges and trading venues and conducts an annual review of any venue used. Hyphe reserves the right to temporarily or permanently include or exclude an exchange for specific coins or trading pairs if market conditions, technical issues, or anomalies materially affect the accuracy of pricing. This may include, for example, massive price deviations from the prevailing market, abnormal spreads, liquidity collapse, or other irregularities.

9. Policy Ownership, Monitoring and Reviews

This Policy will be reviewed on an annual basis by Hyphe’s Compliance function. The review includes random samples of trades that are controlled against the principles of this Policy. On a day-to-day basis, trades are monitored and controlled by the first line of defense (here: Middle Office) to ensure Hyphe obtains the best possible results when executing client orders.

In the case of regulatory changes, this Policy may be reviewed on an “ad hoc” basis between the annual reviews mentioned above.

The most important execution factors are under constant and regular review by Hyphe’s IT development department. Furthermore, they are subject to random checks by the compliance functions.

The list linked in the chapter “Crypto-Assets” will be reviewed as indicated, at any time when there is a change in its content.

Policy Owners of this Policy are Hyphe’s Compliance functions under the respective senior management’s general responsibility.

In case of any questions, please address via email to [email protected].

Risk disclosure (MiCAR)

Introduction

This Risk Disclosure Note is provided by Hyphe Markets GmbH ("Hyphe") to its professional B2B clients in accordance with Article 66(3) of Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCAR). Effective Date: November 2025

This Risk Disclosure Statement outlines a non-exhaustive list of risks associated with the use of the services offered by Hyphe and trading in crypto-assets. The use of our services and engaging in transactions may carry risks that are beyond our control, and Hyphe is not liable for such risks. This is not a comprehensive disclosure of all risks, and additional product-specific risks may be detailed in the respective whitepaper of a given crypto-asset.

Crypto-assets are highly speculative, highly volatile, and subject to rapid change. They carry a risk of complete loss. Before engaging in any transactions, you must carefully evaluate whether investing in crypto-assets is suitable for your risk tolerance, investment goals, financial situation, tax circumstances, and other relevant factors. No information provided by Hyphe should be construed as financial, investment, trading, legal, or tax advice. Clients are responsible for their own due diligence, risk assessment, and legal/tax compliance. Hyphe is not liable for losses resulting from risks beyond its control.

1. General Market, Liquidity and Price Risks

Investing in crypto-assets carries a high degree of risk, including the possibility of a complete loss of your invested capital. These risks are fundamentally different from traditional financial instruments, including:

1.1 Market Volatility and Price Risk
The value of crypto-assets can fluctuate significantly over short periods of time. Past performance is not an indicator of future results. Prices are determined by market forces, which can be influenced by demand, liquidity, and global events. Unlike equities or bonds, crypto-assets generally lack a directly measurable intrinsic value, making them prone to severe, rapid, and unpredictable price swings (extreme volatility). Clients must be prepared for the possibility of a complete loss of capital invested in or exposed to crypto-assets. Furthermore, the broader crypto-asset market may be targeted by fraud, scams, market manipulation (such as 'pump and dump' schemes), or other illicit activities by third parties. These external factors can artificially inflate or deflate prices independently of Hyphe's own rigorous compliance and surveillance measures.

1.2 Liquidity and Execution Risk
Some crypto-assets may have low liquidity, which can lead to a wider spread between buying and selling prices, higher transaction costs, or an inability to execute an order in a timely manner. Low liquidity, especially for mid-to-low market cap crypto-assets, can result in wider bid-ask spreads and significant price slippage during the execution of large orders, increasing effective transaction costs. Transactions executed at demonstrably non-market prices may be cancelled by Hyphe (Mistrades).

1.3 No Investor or Deposit Protection
Investments in crypto-assets are not covered by any deposit guarantee or investor protection schemes.

1.4 Delisting and Suspension Risk
Hyphe reserves the right to delist or suspend trading for any crypto-asset at its sole discretion (e.g., due to regulatory changes, or network insecurity). In such events, you may be unable to buy or sell the according crypto-assets.

2. Technology, Protocol and Cybersecurity Risks

Crypto-assets are highly dependent on underlying software protocols and public networks, which introduce unique technical risks:

Crypto-assets and the underlying software applications, such as smart contract systems and blockchain platforms, are in an early stage of development and are not centrally certified. The technology may contain unforeseen vulnerabilities, weaknesses, or bugs that could lead to a total loss of your crypto-assets.

2.2 Network and Internet Vulnerability
All transactions rely on the public internet, which is susceptible to attacks, including Distributed Denial of Service (DDoS), hacking, malware, and other cyber threats targeting communication channels or IT interfaces.

2.3 Blockchain-Specific Risks
Crypto-assets can be vulnerable to network attacks such as double-spend attacks, 51% attacks, or other mining-related and non-mining-related attacks that are beyond our control. Protocol changes (Hard Forks) can split a crypto-asset into two incompatible versions. This may result in clients not receiving the assets of the new chain, or Hyphe choosing not to support the resulting crypto-asset. Transactions in crypto-assets are generally irreversible due to the finality of blockchain protocols. Once a client's transaction is signed and broadcast to the network, it cannot be reversed, cancelled, or modified by Hyphe. Losses resulting from the client's accidental or incorrect transactions (e.g., sending assets to a wrong or non-existent wallet address) may not be recoverable, and Hyphe cannot guarantee the retrieval of such lost assets.

2.4 Data and Account Security Risks
We strongly recommend using Two-Factor Authentication (2FA), but even this may be compromised if both factors are accessed with the same credentials or device. Weak passwords or the loss of login credentials can result in unauthorized access to your account and assets.

2.5 Phishing and Social Engineering
Our communication channels are vulnerable to spoofing and phishing attacks. You should always verify the authenticity of any communication and log in directly to your account rather than following links. We are not responsible for losses incurred from such attacks.

3. Regulatory, Jurisdictional and Legal Risks

The regulatory environment for crypto-assets is constantly evolving, particularly with the introduction of MiCAR. Changes in laws or regulations may materially impact our services or the value of crypto-assets.

3.1 Regulatory Uncertainty and Legal Limitations
The regulatory and legal status of crypto-assets is still unclear in many jurisdictions. Legislative or regulatory changes, including those stemming from MiCAR, could lead to the limitation or termination of certain services. While MiCAR provides a comprehensive framework in the EU, global regulatory shifts or new national interpretations (e.g., via the German Crypto Asset Oversight Act) could negatively affect the market. Jurisdictions may impose outright bans or severe limitations on the use, exchange, or mining of certain crypto-assets, which could lead to a rapid devaluation or total loss. The legal classification of a crypto-asset (e.g., as a asset referenced token, security, e-money, or another category) may change, potentially rendering it non-tradable or subject to a different, more restrictive regulatory regime. The specific civil law treatment of certain crypto-assets and related rights (e.g., regarding security rights or transfer of ownership) remains unclear in some jurisdictions.

3.2 MiCAR Compliance
As an entity, functioning in a regulated framework, Hyphe must comply with all requirements under MiCAR. These rules aim to protect clients and market integrity, and may require us to make changes that affect our business operations and the services we provide.

3.3 Regulatory Market Abuse Risk
As Hyphe is subject to MiCAR's market integrity provisions (Title VI), there is a risk of insider dealing (unauthorized access to or use of "inside information" regarding a crypto-asset) and / or market manipulation (transactions, orders, or other behaviour that gives false or misleading signals as to the supply, demand, or price of a crypto-asset (e.g., wash trading, spoofing, or pump-and-dump schemes). Hyphe, as a CASP, is required to implement controls to prevent, detect, and report (via STORS - Suspicious Transactions and Order Reports) potential market abuse to the competent authorities.

3.4 Supervision
The supervision of crypto-asset services and token issuers falls to national competent authorities, with Germany's Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin) serving as the primary regulator. For specific 'significant' tokens, supervision is also carried out at the European level by authorities like the EBA and ESMA. These regulators are equipped with broad enforcement powers, including the authority to impose fines and suspend services to ensure market integrity and client protection.

3.5 Issuer Liability Risk
For certain decentralized crypto-assets, the identity of the issuer, original developers, or the current governance entity may not be clearly known or public. This lack of transparency means there is no clearly identifiable party responsible for maintenance, updates, security fixes, or legal liability in the event of failure or exploit. Hyphe executes rigorous due diligence (Product Governance) before offering any crypto-asset to clients. However, due to the inherent opacity, decentralization, and speed of change within crypto markets, Hyphe cannot guarantee the complete exclusion of all technical, legal, or governance-related risks associated with the crypto-asset or its underlying protocol.

3.6 Cross-Border Services
The provision of cross-border crypto-asset services is subject to MiCAR's rules, which may differ from those in third countries.

4. Counterparty, Operational and Credit Risks

The provision of crypto asset services is reliant on the operational integrity of the service provider and its network of third-party partners, exposing the client to counterparty, operational risks and credit risks.

4.1 Counterparty and Settlement Risk
In the course of providing our services, we may engage regulated third-party trading venues and other financial institutions. A default, failure, or operational error by one of these third-party counterparties could lead to delays in execution, non-settlement of transactions, or complete loss of funds/assets held with that counterparty, despite Hyphe's due diligence efforts.

4.2 Systemic Risk
The crypto-asset ecosystem is highly interconnected. The insolvency or failure of a major participant (e.g., a large exchange or a stablecoin issuer) could trigger a cascading failure, affecting the liquidity, pricing, or accessibility of a wide range of crypto-assets, even if they are not directly linked to the failing party.

4.3 Hyphe Operational and IT Risk
System failures, errors in Hyphe's trading algorithms, inadequate internal controls, or human error can lead to erroneous trades, financial loss, or non-compliance. Specifically, technical outages or service disruptions may temporarily prevent you from executing trades to manage your exposure, even during periods of high market volatility. Hyphe's internal controls and compliance systems are designed in accordance with MaRisk (Minimum Requirements for Risk Management) principles, but these measures cannot eliminate all risks completely.

4.4 Wallet Risk
Assets held by Hyphe during the period between trade execution and settlement are protected using industry-standard security measures. Nonetheless, certain residual risks cannot be fully eliminated. These include, for example, the loss of access to private keys, operational or service disruptions, or external security breaches that could compromise stored funds. Should such an incident affect the wallets utilized by Hyphe, the recovery of your assets may be limited.

5. Tax and Financial Risks

5.1 Tax Liability Risks
The purchase, sale, exchange, or holding of crypto-assets may have tax consequences. You are solely responsible for compliance with all applicable national and international tax laws. We recommend consulting a tax advisor for guidance. Hyphe does not provide tax advice.

5.2 Reporting and Withholding
Hyphe may be required by law to report transaction information to tax authorities or withhold taxes from your transactions. We will not be able to refund any amounts withheld.

5.3 No Financial Advice
The availability information of a crypto-asset on our website does not constitute a public offer and is not a recommendation to engage in any specific transaction, nor is it a guarantee that the crypto-asset is suitable or appropriate for you. All information we provide is for informational purposes only and should not be relied upon for investment decisions. You are solely responsible for your own investment decisions.

Users are strongly encouraged to review the relevant whitepaper and / or summary documentation for each crypto-asset before transacting. It is your sole responsibility to understand the specific features, technical design, and risks associated with the assets you trade.

By using our services, you confirm that you have read, understood, and accept these risks.

Conflicts of interest

Conflicts of Interest Disclosure

Effective Date: November, 2025

Hyphe Markets GmbH ("Hyphe") is committed to acting honestly, fairly, and professionally in the best interests of our clients and the integrity of the crypto-asset and financial markets. Pursuant to our obligations under the Markets in Crypto-Assets Regulation (MiCAR) and the Markets in Financial Instruments Directive II (MiFID II), this disclosure outlines the general nature and sources of conflicts of interest that may arise in the course of providing our services and the measures we take to manage them.

Definition and General Nature of Conflicts of Interest

A conflict of interest (CoI) is a situation where the personal or financial interests of Hyphe, a related party, or an individual acting on our behalf could improperly influence our professional actions, potentially leading to biased or unfair outcomes for our clients.

Our conflicts policy explicitly covers potential conflicts of interest between

1. Hyphe and:
• its shareholders or members; or
• any person directly or indirectly linked to Hyphe or our sharehilders or members by control; or
• its management body (managing directors); or
• its employees; or
• its clients; or

b) Two or more clients themselves whose mutual interests conflict.

Sources of Potential Conflicts

We identify and manage potential conflicts across our services, grouped as follows:

• Conflicts between Hyphe and:
• Its shareholders or members:
- This could arise when the interests of shareholders (e.g., maximizing short-term profits) conflict with the Hyphe’s duty to act in the best interests of its clients.
• (ii) Any person directly or indirectly linked to Hyphe or its shareholders or members by control:
- This addresses situations involving related entities (e.g., subsidiaries, affiliates). Conflicts can occur if transactions between these entities are not conducted at arm's length, potentially disadvantaging clients.
• (iii) Members of its management body:
- Personal financial interests of managers could influence their decisions, leading to actions that are not in the best interests of Hyphe's clients.
• (iv) Its employees:
- Conflicts can arise from employee remuneration or incentive structures that encourage them to prioritize their own interests or Hyphe’s interests over those of clients.
• (v) Its clients:
- This is the most direct conflict. Hyphe might prioritize its own profits or interests over providing fair and impartial services to its clients. This could manifest in various ways, such as unfair pricing or preferential treatment.

(b) Conflicts between two or more clients whose mutual interests conflict:

• A conflict can arise when we hold a large order from one client and a competing large order from another.
• Information obtained from one client in the course of business could be potentially beneficial to another client.

Our Mitigation Measures:

• We enforce strict Information barriers and maintain clear segregation of duties to prevent the misuse of sensitive, non-public information.
• We have procedures to ensure that all orders are executed fairly and transparently, without giving one client an undue advantage.
• We maintain a robust and fair Pricing Policy to ensure that all client transactions are conducted transparently and at a price that minimizes the potential for conflicts arising from our proprietary interests, thereby ensuring fair treatment of clients.
• Our internal process explicitly covers the management of gifts and entertainment, enforcing strict reporting and monetary thresholds to prevent improper influence.
• All activities are subject to regular monitoring and supervision to ensure compliance with internal and regulatory requirements.
• The Compliance Function operates independently with the necessary authority and resources to monitor the effectiveness of the Conflicts of Interest management arrangements and report directly to the Management Body.
• Our remuneration policy is designed to reduce the risk of conflicts of interest by aligning employee incentives with the principle of acting in the client's best interest.
• In cases where a conflict cannot be fully managed by our internal arrangements, we will provide specific, timely, and comprehensive disclosure to the affected client. This is always a measure of last resort.

Disclosure as the Measure of Last Resort

Hyphe's priority is always the prevention and effective management of conflicts. Disclosure is explicitly a measure of last resort (ultima ratio), used only when our internal administrative and organizational arrangements are insufficient to prevent the risk of damage to client interests with reasonable confidence.

In such a case, we will:

• Provide the client with a specific, timely, and comprehensive disclosure in a durable medium.
• Ensure the disclosure contains sufficient detail on the conflict's nature, its source, and the specific risks to the client, enabling the client to make an informed decision about proceeding with the service.

Customer complaints

1. Introduction and Principles

This document describes the internal complaints procedure of Hyphe Markets GmbH (hereinafter "Hyphe") regarding client complaints related to our services. Our goal is to establish and maintain effective and transparent procedures for the prompt, fair, and consistent handling of all incoming complaints. We are committed to objectively and fairly examining every complaint to protect our clients' interests.

2. Admissibility of Complaints

A communication is considered a complaint if it expresses dissatisfaction with a relationship with Hyphe, its personnel, products, or services and includes an expectation for a remedy or clarification. To be considered admissible, a complaint must meet the following criteria:

• The complaint must clearly identify the complainant, including their full name and contact details. Anonymous complaints cannot be processed.
• The complaint must relate to a specific service, product, or action/omission of Hyphe.
• Accepted languages for the submission of complaints and the subsequent response from Hyphe are German and English.

3. Filing Complaints

Complaints can be filed with and processed by Hyphe free of charge.

3.1 Channels for Filing Complaints
Hyphe provides several accessible channels for submitting a complaint to ensure ease of communication for the complainants. Please include the information listed in Section 3.3. for the quick and efficient processing of your complaint.

You can submit a complaint via email: [email protected] or by post:

Hyphe Markets GmbH
Adelgundenstr. 2
80538 München
Germany

3.2 Use of the Standard Template
We provide a standard template for submitting complaints in Annex I of this document. While the use of this template is not mandatory, it facilitates the quick and efficient processing of your complaint.

3.3 Required Information from the Complainant
To process your complaint promptly, we ask you to provide the following information:

• Full name/Legal Entity Name of the complainant
• Contact details (email address, phone number, postal address)
• Date of the complaint
• A detailed description of the facts leading to the complaint, including relevant dates, times, and involved parties. For technical or trading-related complaints, please include specific Transaction IDs, API timestamps, and relevant order/trade references.
• If applicable, relevant documents or evidence to support your complaint.

3.4 Identity and Contact Details of the Responsible Department
The Compliance Department at Hyphe is the central coordination point for complaints handling. The complaints will be handled by the Compliance Officer, and/or, in the case of absence by other employees of the compliance department.

4. Complaint Handling Process

4.1 Acknowledgment of Receipt
The receipt of your complaint will be confirmed to you without undue delay in writing (usually by email). This confirmation will include a reference number, the date of receipt, and the contact details of the person or department handling the complaint.

4.2 Investigation of the Complaint and Request for Additional Information
The Compliance Department will carefully and objectively examine the matter. We will assess if the complaint is clear and complete, and if additional information or documents are needed for the investigation, we will contact you immediately. We will not require information already in our possession. We will keep you informed about any additional steps taken to handle the complaint.

4.3 Communication of the Decision
The results of our investigation and our position on your complaint will be communicated to you in writing in clear, concise, and understandable language (usually by email). The decision will address all points raised in your complaint and state the reasons for the outcome. If our decision does not fully satisfy your request, it will clearly set out the reasoning and contain information on available remedies, such as external dispute resolution options.

4.4 Timelines for Processing and Response
We aim to process your complaint within a reasonable timeframe. We will communicate our decision on a complaint without undue delay, and in any case, within two months of the date the complaint was received. Should the processing of your complaint exceptionally take longer, you will receive an interim update from us without undue delay, including the reasons for the delay and a new expected date for the decision.

5. Registration and Record-Keeping of Complaints

All incoming complaints, their processing, the measures taken, and the final decisions will be systematically recorded and documented in a secure electronic complaint log/register. These records will be retained for a period of at least five years, or longer if required by the competent supervisory authority (BaFin) or by specific Regulatory Technical Standards (RTS). The systematic analysis of complaints serves to identify recurring or systemic problems and risks, ensuring continuous improvements to our processes and services.

6. Complaint Form

Download complaint form here