Custody Policy
Safello has adopted a custody policy in order to ensure that Safello has adequate routines for safeguarding customers’ crypto-assets and that Safello manages customers’ crypto-assets in a safe and reliable manner in accordance with legal requirements. Below is a summary of the custody policy.
1. Policy
In order to protect the rights of its customers in respect of their crypto-assets, Safello shall:
• Segregate customers’ crypto-assets from Safello’s own holdings by using separate crypto-asset wallet addresses on the blockchain;
• Keep records to always be able to distinguish crypto-assets held for one customer from crypto-assets held for any other customer and from Safello’s own assets;
• Keep registers of positions in the name of each customer of the crypto-assets held by the Company on behalf of customers. Such statement of positions is accessible for customers upon log in to Safello’s website or mobile app;
• Have routines to minimise the risks of loss of customers’ assets.
2. Custody and safekeeping of customers’ crypto-assets
In the course of the Safello Wallet service, Safello acts as a custodian wallet provider, where the private keys to the wallet are held by, and hence controlled by, Safello. The crypto-assets held in Safello Wallet are assets held by Safello for the customers’ benefit on a custodial basis. This means that the ownership of the crypto-assets in Safello Wallet at all times shall remain with the relevant customer, and Safello shall not dispose of a customer’s crypto-assets unless instructed by the relevant customer.
Crypto-assets held in custody shall be legally segregated from Safello’s estate, so that creditors of the Company have no recourse to crypto-assets held in custody by Safello. Safello treats all customers’ crypto-assets as escrow funds (Sw. “redovisningsmedel”) held on behalf of each respective customer, and except as necessary or practicable to enable transfers of crypto-assets for customers, shall at all times hold such crypto-assets in a separate wallet and thereby separated from Safello’s own crypto-assets.
To ensure secure storage, Safello uses Fireblocks’ secure infrastructure, which is utilising Multi Party Computing (MPC) technology.
3. Use of third parties
Safello currently does not use any other crypto-asset service providers for the custody and administration of crypto-assets on behalf of customers. If Safello would do so in the future, such service providers must be authorized to provide that service in accordance with the MiCA regulation and Safello shall inform its customers of any such third party providers.