User Terms and Conditions for Penning

1. General Company Information

2. Access to Services

2.1 Account Creation and Screening

To gain access to our services, customers are required to create an account. As part of the account creation process, Penning collects detailed personal and/or corporate information to verify the identity of the applicant and ensure compliance with legal and regulatory requirements.

The information collected includes but is not limited to:

• Private Customers: Full name, residential address, date of birth, nationality, and valid contact information (e.g., phone number and email).
• Business Customers: Company name, official registration number (e.g., CVR in Denmark), ownership structure (including ultimate beneficial owners), and designated contact person.

2.2 Identity Verification (KYC/KYB)

Penning employs advanced technological solutions for identity verification in compliance with Know Your Customer (KYC) and Know Your Business (KYB) regulatory standards. These processes include the following:

1. Document Verification:
   Customers are required to upload and provide scanned copies of official identification documents, such as passports, national identification cards, or other government-issued IDs.
2. Biometric Validation:
   Penning may require customers to undergo biometric verification, including facial recognition (e.g., through selfie matching) to ensure the authenticity of the provided identity documents.
3. AML Screening:
   All customers are screened against global lists of Politically Exposed Persons (PEPs), sanctioned individuals/entities, and high-risk jurisdictions as part of Penning’s Anti-Money Laundering (AML) procedures.

2.3 Definitions and Explanations

• Know Your Customer (KYC):
  This is the process of collecting and verifying customers' identities to prevent illegal activities such as money laundering or fraud. KYC procedures ensure that Penning knows who their customers are and the legitimacy of their activities.
• Know Your Business (KYB):
  AML refers to the policies, procedures, and laws established to prevent criminals from disguising illegally obtained funds as legitimate income. This includes transaction monitoring and suspicious activity reporting.
• Anti-Money Laundering (AML):
  All customers are screened against global lists of Politically Exposed Persons (PEPs), sanctioned individuals/entities, and high-risk jurisdictions as part of Penning’s Anti-Money Laundering (AML) procedures.
• Countering the Financing of Terrorism (CFT):
  CFT measures are specifically aimed at preventing the financing of terrorism. These measures involve screening customers against sanctioned persons, organizations, and high-risk jurisdictions.

2.4 Risk Assessment

Penning Financial Services assigns a risk score to all customers as part of its compliance framework. This risk score determines the level of scrutiny required for each customer:

• Low-Risk Customers:
  These customers are automatically approved after basic verification.
• High-Risk Customers:
  Customers identified as high-risk undergo a detailed manual review by the compliance team. Additional documentation and checks may be required before approval.

2.5 Intended Customer Groups

Penning Financial Services ApS provides services to the following customer groups:

1. Private Customers: Individual clients who wish to store, exchange, or invest in crypto assets.
2. Small and Medium-Sized Enterprises (SMEs): Companies seeking crypto asset services.
3. Institutional Investors:Entities such as investment funds and financial institutions with an interest in crypto assets.

3. Description of Services

Penning offers a range of crypto asset-related services categorized as follows:

3.1 Custody and Administration of Crypto Assets

Penning provides secure custody solutions for customers' crypto assets. This service includes dedicated digital wallets, ensuring that customers do not need to manage their encryption keys directly. The wallets are protected by multi-signature authentication and cold storage solutions to minimize security risks.

3.2 Exchange Services

1. Crypto-to-Fiat Exchange:Customers can exchange crypto assets for fiat currencies (e.g., EUR, DKK) and vice versa through Penning's platform.
2. Crypto-to-Crypto Exchange: The platform also facilitates exchanges between different crypto assets.

3.3 Execution of Orders

Penning offers an execution service that enables customers to place orders for buying and selling crypto assets. The platform ensures rapid and efficient order execution to provide the best possible customer experience.

3.4 Portfolio Management

Customers can choose from predefined portfolio strategies based on their risk tolerance. Penning’s portfolio management service includes automated rebalancing to maintain the chosen risk profile.
Note: Penning does not offer personalized financial advice on crypto assets.

3.5 Transfer of Crypto Assets

Penning ensures the secure transfer of crypto assets between customers’ wallets and external wallets. All transactions are logged and monitored to ensure transparency and compliance with AML regulations.

4. Fees and Payments

4.1 Fee Structure

Penning applies transparent fees for all services. The applicable fees are displayed clearly at the time of order placement and must be accepted by the customer before proceeding with the transaction.

4.2 Payment Methods

Payments for services can be made in either fiat currencies or crypto assets, depending on the type of service.

5. Risks

5.1 Market Volatility

Crypto asset markets are highly volatile. Customers should be aware that the value of their investments can fluctuate significantly, and they may incur substantial losses.

5.2 Security Risks

While Penning employs state-of-the-art security measures, there are inherent risks associated with online platforms, including cyberattacks and technical malfunctions. Customers are encouraged to take additional precautions to protect their accounts.