Date: 01.10.2025.
1.1. These General Terms and Conditions for the Use of the Trading Service (hereinafter referred to as: General Terms and Conditions) in which the Company permanently or occasionally provides an additional investment service for the receipt and transmission of orders related to virtual assets, for trading outside multilateral systems (venues) of organized trading in financial instruments (regulated market or multilateral trading platform), so-called OTC (Over The Counter) transactions, via the website www.adveniotrader.com which supports the Kraken trading platform for trading virtual assets.
1.2. In the General Terms and Conditions, the terms specified herein, unless the context indicates otherwise, shall have the following meanings, in the singular or plural:
The Company means CREDOS d.o.o., Jurišićeva 21, OIB: 21667415955, Zagreb, Republic of Croatia.
Third party means a third entity or third party to which the company Credos d.o.o., Jurišićeva 21, Zagreb transfers orders for the purchase and/or sale of financial instruments that are traded on markets where the Company is not a direct member. The list of third parties to which the Company transfers orders for the purchase and/or sale of financial instruments is attached as the List of Order Executors.
Contractual relationship: By accepting these General Terms and Conditions, the Client enters into a contractual relationship with the Company regarding the use of the Company’s additional service of receiving and transmitting orders for trading virtual assets under the conditions set out in these General Terms and Conditions.
REGULATOR is authorized competent regulatory body.
REGULATOR rules means the law that regulates the provision of additional investment services, the execution of additional investment activities, the operation of regulated markets and other related matters, the law on activities to prevent and prohibit money laundering, directives and circulars and all other provisions issued in accordance with these laws and all guidelines, administrative notices, bulletins and rules published by the regulatory body.
CMA means the Capital Market Act (Official Gazette 65/18, 17/20, 83/21, 151/22, 85/24 and any subsequent amendments and/or additions).
FATCA stands for the Foreign Account Tax Compliance Act.
FFI stands for Foreign Financial Institution in the sense of FATCA.
Relevant regulations means:
1) CMA, regulations adopted on the basis of that Act or any other rules of HANFA
2) Rules of the regulatory body
3) All other applicable laws (especially the Personal Data Protection Act, the Anti-Money Laundering and Terrorist Financing Act, the Restrictive Measures Act, FATCA), rules and regulations in force at the relevant time.
MTP stands for Multilateral Trade Platform.
OTC means ‘Over The Counter’, i.e. outside multilateral systems (venues) of organized trading in financial instruments (regulated market or MTP).
The Advenio Trader service means auxiliary investment services of receiving and transmitting orders for trading outside multilateral systems (venues) of organized trading in financial instruments (regulated market or multilateral trading platform), OTC transactions via trading platforms of order execution agents (hereinafter: the Service). The Service does not include the service of providing advice to clients regarding the service under the General Terms and Conditions.
Financial instruments for the purposes of the Service mean financial instruments traded outside multilateral systems (venues) of organized trading in financial instruments (regulated market or multilateral trading platform), i.e. OTC transactions.
Client means a person who uses the Service under the General Terms and Conditions.
List of order execution venues – A list of venues to which the Company sends received client orders for execution.
Inside information means inside information within the meaning of the provisions of the Capital Market Act – information of a precise nature that is not publicly available and that relates directly or indirectly to one or more issuers of financial instruments or to one or more financial instruments and which, if made publicly available, would likely have a significant effect on the prices of those financial instruments or on the prices of related derivative financial instruments.
Account means an account that the Client has with the Company for trading outside multilateral systems (venues) of organized trading in financial instruments (regulated market or multilateral trading platform) in accordance with the General Terms and Conditions of the Service, and through which the Account is assigned a specific number.
Base currency means EUR.
Event of Breach means any of the following events:
1) failure of the Client to pay a financial obligation when due;
2) any breach of these General Terms and Conditions that is not remedied within 1 (one) business day
3) after the breaching party receives a notice from the other party informing it of the breach and requesting its remediation.
4) if the Company reasonably determines that the Client exhibits unusual trading-related activities or behaves in a manner that could reasonably be considered abuse in accordance with the applicable regulations of the Republic of Croatia or has adopted trading strategies aimed at exploiting misquoted prices (or generally appears to be acting in bad faith or attempting to misuse information or content available through the Service);
5) events or circumstances that one party believes have, may have
6) and or will have, an adverse effect on these General Terms and Conditions or on the ability of the other party to fulfill any obligation under the General Terms and Conditions;
7) a statement by one of the parties that it will not be able or does not intend to fulfill its obligations under the General Terms and Conditions;
8) failure to comply with or breach of the representations and warranties provided in the provisions of Article 8 of the General Terms and Conditions.
The Company’s Privacy Policy refers to the Company’s Privacy Policy Statement located on the website www.adveniotrader.com, which may be changed from time to time, and forms an integral part of the General Terms and Conditions and includes the ways in which the Company collects, processes, stores, uses and protects the Client’s personal data.
Company’s Risk Disclosure Policy means the Company’s Risk Disclosure Policy available on the website www.adveniotrader.com, which may be amended from time to time, and which forms an integral part of this Agreement and includes warnings of risks related to the use of the Service.
Transaction means all transactions specified in these General Terms and Conditions and include virtual assets for which a third party is authorized to execute the Client’s order.
1.3. The terms defined in these General Terms and Conditions have the same meaning as described in these General Terms and Conditions.
1.4. In the event of a conflict between the provisions of the General Terms and Conditions and the applicable Trading Rules, the Trading Rules shall prevail.
1.5. The titles of individual sections of these General Terms and Conditions are for convenience only and shall not affect their interpretation.
2.1. The Company provides additional investment services for receiving and transmitting orders for virtual assets.
2.2. The Third Party is an order execution and market maker for virtual assets. The Third Party will execute the Client’s order in accordance with the Third Party’s Trading Rules.
2.3. Relevant information about the Company is available on the website www.adveniotrader.com.
3.1. By entering into a contractual relationship with the Company, the Client confirms that he is familiar with the content and agrees to the application of the following documents:
1) These General Terms and Conditions,
2) The Company’s Privacy Policy Statement
3) The Company’s Risk Limitation Statement
4) List of Execution Venues
5) Price List
3.2. By entering into a contractual relationship with the Company, the Client confirms that he is familiar with the categorization, or classification of the Client as a retail or professional investor, or qualified principal, when applicable.
3.3. By entering into a contractual relationship with the Company, the Client confirms that the Company may at any time amend these General Terms and Conditions and other documents of the Company in accordance with legal regulations and the Company’s business policy and that any further amendment or supplement to these General Terms and Conditions and other documents of the Company shall be binding from the moment of their entry into force. Any amendment or supplement to these General Terms and Conditions and other documents of the Company shall be drawn up on a durable medium, displayed in a visible and accessible place to the Client on the website www.adveniotrader.com. By entering into a contractual relationship with the Company, the Client confirms that a third party may at any time amend the Trading Rules and other documents in accordance with legal regulations and the business policy of the third party and that any further amendment or supplement to the documents of the Company shall be binding from the moment determined by the third party.
3.4. The rights and obligations of the Company and the Client regarding the implementation of additional services that are the subject of the General Terms and Conditions will be implemented, in addition to other contractual agreements, under the following conditions and assumptions:
3.5. The Company may register and keep records of the IP addresses from which the Client logged in to the trading platform in order to prevent the implementation of trading strategies aimed at exploiting price errors and/or concluding transactions at off-market prices (a strategy known as “sniping”). Such IP addresses may be transferred to third parties.
4.1. The Client may place an order in electronic form via the online trading system or, exceptionally, orally by telephone to the Trading Department in accordance with the Company’s rules.
4.2. Types of orders accepted
Some types of orders that the Company accepts include, but are not limited to:
4.3. After submitting an order, the Client is solely responsible for being available for the order and completing confirmations and other communications regarding his account until all open orders have been completed. Accordingly, the Client must frequently monitor his account when he has open positions in the account.
4.4. The Client’s Order will be valid in accordance with the type and time of the order given, as specified. If the validity period or date/time of the order is not specified, it will be valid indefinitely.
4.5. It is the sole responsibility of the Client to clearly indicate the terms of the order when it is placed, whether it is a market order, a limit order, a stop-loss order or another type of order, including the relevant price and lot size. The client accepts that the price at which execution takes place may differ significantly from the price specified in his order. This may result from sudden price movements in fixed assets that are beyond the Company’s control. The company will not be responsible for failure to execute the order. The Company shall have the right, but not the obligation, to reject any order in whole or in part, prior to execution, or to cancel any order, where the Client’s account does not have sufficient collateral to support the entire order or where such order is illegal or otherwise inappropriate.
4.6. The Company may temporarily or permanently suspend the placing of orders for the purchase and/or sale of virtual assets by the Client, if the Company assesses that the placing of such orders could constitute market manipulation or otherwise indicate a violation of legal and regulatory provisions, as assessed by the Company, and in accordance with the Company’s legal powers. In the aforementioned case, the Company will notify the Client of the temporary suspension in the manner provided for in these General Terms and Conditions.
5.1. The Client may deposit funds exclusively into one of the Company’s accounts available here. The Company accepts deposits exclusively from Clients, i.e. deposits from third parties are not permitted. The Client may open his/her trading account(s) in EUR. The account balance will be calculated in EUR.
5.2. Client orders to purchase financial instruments are considered received only when they are received by the trading platform system.
5.3. Any Client funds that the Company may receive outside of business hours on a business day or on a non-business day are considered received on the first following business day.
5.3. The Client is aware that the Company or the third party to whom the funds are forwarded for the purpose of executing the Client’s order will receive the funds within a certain time after the payment has been made, whereby payments abroad may require a longer time to complete the transfer of funds.
5.4. The Client is obliged to pay, at the request of the Company and/or a third party:
5.5. If the Client makes any payment of an amount that is subject to fluctuations, withholdings or deductions, the Client shall pay additional amounts to the Company to ensure that the amount actually received by the Company is equal to or greater than the amount of the obligation that the Client is settling by payment.
5.6. The Company shall credit the Client’s account for the amount of funds paid only after the Company has received each individual payment.
5.7. If the Client wishes to withdraw funds from his trading account, the Client shall be required to complete and sign a Withdrawal Request. Within 1 (one) business day from the date of receipt of a duly completed and signed Withdrawal Request, the Company shall deposit the funds into the same bank account from which the funds were initially paid or into a bank account of a known owner subsequently provided to the Company, all provided that the conditions for withdrawal in accordance with the Trading Rules are met.
5.7. The Company may at any time allocate the Client’s funds to a settlement account in accordance with the Third Party Trading Rules
5.8. All financial instruments will be held by a third party or a third party nominated by the third party and the investment firm to which the order is forwarded for execution or a third party nominated by the third party will be responsible for the realization of the rights under the financial instruments belonging to the Client.
5.9. The client irrevocably authorizes the Company to take the following actions:
5.10. If the Client fails to timely deliver the amount of money required to execute the transaction in accordance with the given order, the Company may close any open position without prior notice to the Client and direct the proceeds generated in this way to the payment of obligations owed by the Client to the Company.
5.11. If the Client fails to make payment on time, the Company has the right to calculate and collect interest on the due amounts at the statutory default interest rate, counting from the due date of the individual amount until the date of settlement.
5.12. The Company and/or a third party has the right, but not the obligation, to reject any order in whole or in part, before execution, or to cancel any order, where the Client’s account does not have sufficient collateral (margin) to support the entire order or where such order is illegal (the Company /or a third party reasonably suspects that the Client has inside information or similar) or is otherwise inappropriate or abnormal trading conditions have occurred.
6.1. The Company shall, unless otherwise agreed, transmit Orders only in relation to freely transferable virtual assets on which the ownership right is not limited, conditioned, time-limited or encumbered by any rights or encumbrances in favour of third parties, and the Client is obliged to register exclusively such virtual assets with a Third Party.
6.2. If there is or is subsequently established a restriction on the ownership right, or the right to dispose of rights from virtual assets, the Client undertakes to immediately inform the Company of the aforementioned facts, whereby the Company and the Client shall without delay endeavour to clarify the disputed situation. If the Client fails to inform the Company without delay of the restrictions, or encumbrances in favour of third parties on the virtual assets referred to in this paragraph, the Client shall be liable to the Company for any damage caused by such culpable conduct of the Client.
7.1. The Company shall, at least every three months, by displaying it on the Client’s account in the trading system or by e-mail, send to each Client for whom the Company holds financial instruments or funds a Report on the Client’s financial instruments and/or funds. The Company shall send to the Client a Report on the collected fees once a year for the previous year in the same manner.
7.2. The Client shall be informed via the trading system about the execution of orders and the status of the trading account.
7.3. All other notifications that the Company is obliged to deliver to the Client under these General Terms and Conditions may be sent to the Client by e-mail or by displaying it on the Client’s account in the Service system, or by posting it on the trading page.
7.4. The Client must provide the Company with a valid e-mail address for the aforementioned purposes, as the Company is obliged to deliver the aforementioned notifications to the Client electronically. An e-mail message is deemed to have been received by the Client at the moment the Company sends it. The Company is not responsible for any delays, changes, redirections or any other changes that may occur in the message after it has been sent by the Company. A message that is on the Client’s account on the Trading Platform is considered received by the Client when the message is placed on the Trading Platform. It is the Client’s responsibility to ensure that the settings on the software used are such that they do not restrict the receipt of e-mail messages or the Company’s access to the Trading Platform.
7.5. The client is obliged to check the content of each document, including documents sent in electronic form by the Company. Such documents will be considered final unless the Client objects to their content immediately after receiving such document.
7.6. By accepting these General Conditions, the Client accepts that he will not receive from the Company the Confirmation of the executed order and the Report on the client’s financial instruments and/or funds in printed form by mail, unless he specifically requests this for individual transactions.
10.1. The following will constitute a breach of contractual obligations:
1) if the Client does not make payment by the due date according to this contractual relationship or you do not respect or do not fulfill some other provision of these General Terms and if such non-fulfillment continues one working day after we have given you a notice of non-fulfilment;
2) if a voluntary or forced bankruptcy, liquidation, reorganization or any other activity aimed at the settlement of debts has been initiated against the Client according to the regulations governing bankruptcy, bankruptcy, liquidation, insolvency and the like, i.e. the regulations by which the regulatory authorities carry out the procedure for the settlement of the Client’s debts, or if the Client is over-indebted, but the conditions for opening bankruptcy, liquidation, reorganization or a similar procedure have not yet been met;
3) if the Client dies, ceases to have full legal capacity, is unable to pay its debts as they fall due or becomes bankrupt or insolvent, as defined under any bankruptcy or insolvency law applicable to the Client: or if any debt of the Client is not paid as it falls due or can at any time be declared due and payable under contracts or instruments evidencing such debt before it would otherwise have become due or payable or any suit, court action or other proceedings in connection with this contractual relationship are instituted for enforcement, as well as any seizure, court order of seizure or execution or a lienholder takes possession of all or part of the assets (movable and immovable) of the Client;
4) if the Client or any credit support provider (or any custodian acting on behalf of the Client or the credit support provider) terminates, fails to acknowledge or repudiates any obligation under this contractual relationship or any guarantee, mortgage agreement, loan agreement with the pledge of financial instruments and/or financial resources (margin agreement) or insurance or document, or any document containing an obligation of a third party (“Credit Support Provider”) or the Client, in favor of the Company (each “Credit Support Document”)
5) if the guarantees given by the Client or deemed to have been given by the Client under this contractual relationship or the credit support documents are shown to be false or misleading in any material respect at the time when they were given by the Client or deemed to have been given by the Client;
6) if any credit support provider or the Client fails to comply with or perform the Agreement or the obligations to be fulfilled or performed under the applicable credit support document;
7) if any credit support document expires or ceases to be in full legal force and produce legal effects before fulfilling all the Client’s obligations under this contractual relationship, unless the parties agree otherwise in writing;
8) if it turns out that any guarantee given by the credit support provider or deemed to have been given in accordance with any credit support document is false or misleading in any material respect at the time it was given or when it is considered to have been given;
9) if any event occurs that indicates the impossibility of fulfilling the obligations arising from the execution of the order;
10) if the Company considers it necessary for its own protection or if any action is taken or an event occurs that the Company considers could have a materially negative effect on the Client’s ability to fulfill any obligations under these General Terms and Conditions;
11) if the Client does not inform the Company that he is the real owner of more than one account with the Company and/or that he acts as a proxy, trustee or in any other way on behalf and/or for the account of another Client of the Company;
12) if the Client takes advantage of price delays and places an order for trading at outdated prices, if he trades at off-market prices and/or outside trading hours, manipulates the trading system at prices that were not quoted by a third party and if he performs other actions that constitute inappropriate trading;
13) if it turns out that any of the Client’s statements are not true or not up-to-date, that is, if the Client does not provide the required data and documentation necessary to determine FATCA status and implement FATCA regulations; and/or
14) if any non-fulfillment of obligations (regardless of how described) of the Client towards the Company occurs.
11.1. Unless otherwise required by applicable law, this Agreement may be terminated by either party upon ten (10) days prior written notice of termination.
11.2. The Company may immediately, without leaving a subsequent deadline, terminate this contractual relationship if the Client does not comply with any provision of these General Terms and Conditions, i.e. if he does not fulfill his obligations (provision 10.1. of these General Terms) or in case of threatened insolvency of the Client.
11.3. After termination:
11.4. Cancellation/termination will not affect any outstanding rights and obligations and transactions that will continue to be governed by this agreement, and certain clauses that have been agreed between the Client and the Company in connection with those transactions, until all obligations have been fully performed.
11.5. Cancellation is made by email or registered mail.
12.1. Unless otherwise specifically agreed, the Client shall communicate with the Company in connection with the performance of the contractual relationship exclusively to the addresses available at www.adveniotrader.com/contact.
12.2. For the purposes of performing all tasks provided for in these General Terms and Conditions, notices and other mutual communications shall be deemed to have been received on the same day if sent on a Business Day during business hours (9:00 AM – 4:30 PM), except in the case of sending registered mail, which shall be deemed to have been received on the day of receipt or, if the mail cannot be delivered to the recipient by delivery for any reason, on the day when the recipient is notified of the arrival of the mail by the legal entity authorized to deliver mail.
12.3. By signing the Agreement, the Client expressly consents to the Company that when carrying out any form of communication with the Client, the Company may record or otherwise record the entire or individual communication, without having to specifically warn the Client before the start of each individual recording or recording, and the Company may use recorded conversations and transcripts of recorded conversations made by the Company as evidence in the process of verifying data and Orders and instructions sent by the Client to the Company, either before a court or other competent authority, or for any other purpose related to the exercise of rights and obligations under these Terms, or any other agreement between the Client and the Company.
12.4. The Company’s records, unless proven to be incorrect, shall be evidence of the use of the Service. The Client shall not object to the Company’s records as evidence in any legal proceedings since these records are not original, are not in writing, and are not computer-generated documents. The Client undertakes not to use the Company’s records to fulfill its record keeping obligations, although the Company may, at the Client’s request, provide access to the Company’s records relating to that Client.
12.5. The client undertakes to keep appropriate records in accordance with the applicable provisions in order to show the nature of the orders sent and the time at which these orders were sent. The client has access to his reports online at any time through the trading platform.
12.6. The Company handles the Client’s complaint in accordance with the Rulebook on Handling Client Complaints.
13.1. If any provision of these General Terms and Conditions is subsequently found to be invalid, this will not affect the other provisions and the General Terms and Conditions shall remain valid and in force in their entirety, provided that the contracting parties shall replace the invalid provision with a valid one that will, to the greatest extent possible, enable the achievement of the objective sought to be achieved by the provision that was found to be invalid.
14.1. These General Terms and Conditions are subject to the application of Croatian law, except for conflict of law rules.
14.2. All disputes arising in connection with the application of these General Terms and Conditions shall be resolved amicably by the Client and the Company, and if no agreement is reached, the jurisdiction of the court with actual jurisdiction in Zagreb shall be agreed upon.
14.3. These General Terms and Conditions shall enter into force on 01.10.2025.
I HAVE READ, UNDERSTOOD AND ACCEPT THESE GENERAL TERMS AND CONDITIONS