Investor Protection and Compensation Policy

Investor Protection and Compensation Policy

Lux Pay Digital Services S.r.l.

1. Introduction

Lux Pay Digital Services S.r.l. adopts measures designed to ensure investor protection and safeguard clients who use the financial and investment services offered through the platform.

Investor protection is implemented in compliance with applicable regulations, including:

• MiFID II – Directive 2014/65/EU
• Italian Consolidated Finance Act (Legislative Decree 58/1998)
• CONSOB Regulations
• European investor protection regulations

2. Client Classification

Under MiFID II regulations, clients may be classified as:

• Retail Clients
• Professional Clients
• Eligible Counterparties

This classification determines the level of protection applied to investment services.

3. Risk Information

Clients receive information about the risks associated with financial instruments before carrying out transactions.

These risks may include:

• market volatility
• risk of capital loss
• liquidity risk
• leverage risk

4. Investor Compensation Schemes

Under applicable regulations, clients may benefit from investor protection schemes established by European or national legislation.

These schemes may provide mechanisms to protect customers in the event of insolvency of the financial intermediary, within the limits established by law.

Client Asset Safeguarding Policy

1. Protection of Client Funds

Lux Pay adopts procedures to ensure the protection of funds and assets held on behalf of clients.

These measures may include:

• segregation of client funds
• separate accounts from company funds
• periodic accounting controls

2. Custody of Financial Instruments

Financial instruments held on behalf of clients may be safeguarded with:

• authorized custodians
• regulated financial institutions
• specialized custody infrastructures

3. Internal Controls

Lux Pay implements internal control systems to ensure:

• proper recording of transactions
• protection of client assets
• compliance with financial regulations

Trading Risk Disclosure

1. Introduction

Trading financial instruments involves significant risks.

Before using trading services, clients should carefully evaluate whether such operations are appropriate for their financial situation.

2. Market Risk

The price of financial instruments may fluctuate rapidly due to:

• economic conditions
• geopolitical events
• regulatory changes

3. Leverage Risk

Derivative instruments, including CFDs, may involve financial leverage.

Leverage may amplify both gains and losses.

4. Liquidity Risk

Some financial instruments may have limited liquidity, making it difficult to execute orders quickly or at expected prices.

5. Technological Risk

Online trading depends on technological infrastructure.

Network interruptions or technical failures may affect order execution.

Crypto Custody Policy

1. Custody of Crypto Assets

Lux Pay may provide custody services for crypto-assets held on behalf of clients.

Security measures may include:

• cold storage solutions
• multi-layer custody systems
• advanced access controls

2. Protection of Cryptographic Keys

Private keys used to access digital assets are protected through advanced security systems.

Access to such keys is limited to authorized personnel.

3. Risks of Crypto Assets

Users should be aware of the risks associated with crypto-assets, including:

• price volatility
• technological risks
• regulatory changes

Sanctions and Compliance Policy

1. Regulatory Compliance

Lux Pay operates in compliance with national and international regulations concerning:

• anti-money laundering (AML)
• economic sanctions
• counter-terrorism financing

2. Sanctions Screening

The Company may perform checks on clients using:

• international sanctions lists
• compliance databases
• transaction monitoring systems

3. Restrictions

The Company may limit or block access to services if:

• a customer is subject to international sanctions
• suspicious activities are detected
• required by competent authorities

Transaction Monitoring

Lux Pay uses automated systems to monitor transactions and identify potentially unlawful activities.

These systems analyze:

• transaction patterns
• anomalous behaviors
• suspicious financial flows

Cooperation with Authorities

Lux Pay may cooperate with competent authorities, including:

• financial authorities
• supervisory authorities
• judicial authorities

The Company may provide information where required by law.

Policy Updates

These policies may be updated to reflect:

• regulatory changes
• technological updates
• improvements to security procedures