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Trading Rules

Last updated: October 15, 2021

Philippine Digital Asset Exchange (PDAX), Inc. (Formerly, FYNTEGRATE, INC.) is a corporation registered and authorized to do business in the Philippines with office address at 12/F, Picadilly Star Building, 27th Street, Bonifacio Global City, Taguig City, Philippines.

The terms “PDAX”, “Company”, “we”, and/or “our” shall refer to the Philippine Digital Asset Exchange (PDAX), Inc., or any of its products or services. The terms “Services” shall refer to any account(s), or product(s), or service(s) availed pursuant to the terms and conditions of the PDAX User Agreement (“Agreement”). The word “you” refers to the user of the Services.

Your access and use of PDAX’s Services through its website, mobile applications, or APIs (collectively, the “Platform”) are subject to these Trading Rules (“Rules”) and any terms expressly incorporated herein. By accessing or availing of any the Services, you acknowledge and accept that these Rules are a binding and enforceable agreement between you and PDAX and that you shall use the Services in accordance with these Rules. PDAX can amend and/or revise these Rules at any time by posting on and updating this page. You are bound by any amendments and/or revisions made by the Company, and you should periodically visit this page to review and be updated on any changes made to the Rules to which you are bound by your continued use of PDAX’s Services.

The Agreement, Privacy Policy, and all other rules, policies, and procedures posted on the Platform constitute an integral part of and are hereby incorporated by reference in their entirety into these Rules.

You agree and accept that it is your responsibility to review these Rules regularly to ensure that you understand all the terms and conditions, and any amendments made to them at any time, that apply to your access and use of the Services.

The following set of Rules governs Orders placed via PDAX’s exchange Platform.

1. Definition of Terms

The following words and phrases used in these Rules have the following meanings:

  • Account means the User’s account with PDAX and refers to the relationship you have established with PDAX, which enables you to conduct a range of transactions such as, but not limited to, placing Orders, trading, cashing in and cashing out, as well as sending and receiving of digital and non-digital assets.

  • Asset means a Digital Asset like cryptocurrency, or a similar digital or electronic instrument, which may be centralized or decentralized; or Fiat Currency.

  • Available Balance or Funds means a User’s Total Asset Value in his/her Account less any amounts subject to a Hold for Open Orders, fees, and such other obligations or liabilities to PDAX

  • Base Asset means the Asset being traded on the Order Book; the first Asset in the Trading Pair.

  • Cancellation-only Mode means that Users cannot place new Orders and are only able to cancel open Orders. No Orders will be filled.

  • Digital Asset  refers to a digital representation of value based on (or built on top of) a cryptographic protocol of a computer network, such as but not limited to cryptocurrencies like Bitcoin.

  • Fiat Currency means the Philippine government-issued currency [Philippine Peso], or any other government-issued currency.

  • Fill means a match of a buy Order and a sell Order. Also referred to as an execution which leads to a Trade or Transaction.

  • Failed Trade means Orders which are processed and/or matched by the Platform despite being unfunded or underfunded, irrespective of the cause for the processing, which PDAX shall reverse or cancel.

  • Regular Trading Operations means the normal operation of the Platform, during which Users can place Market Orders and Limit orders and can cancel Open Orders. ​

  • Hold means the setting aside of Assets earmarked to fulfill obligations arising from an Order.

  • Limit Order means an Order to buy or sell a specified quantity of an Asset at a specified price or better.

  • Limit Order-only Mode means that Users can only place and cancel Limit Orders but any Market Order will be rejected. During this mode, Limit Orders can be filled.

  • Maker Order means a Limit Order placed on the Order Books, which is not immediately filled, when a User places a buy Order (or portion thereof) below the best offer or places a sell Order (or portion thereof) above the highest bid, and the User is waiting for a willing seller or buyer to enter and trade at the User’s specified prices.

  • Market Order means an Order to buy or sell a specified quantity of an Asset at the best available price of existing Orders on the Order Book.

  • Order means an instruction to buy or sell a specified quantity of the Base Asset at a specified price in the Quote Asset.

  • Order Book means the Platform’s electronic list of buy and sell orders for a specific digital asset pair or digital asset to fiat currency pair (“Trading Pair”) , indicating the number of digital assets being bid on or offered at each price point.

  • Open Order means a Maker Order which has been posted but not Filled, canceled or expired, or a Stop Order which is currently active.

  • Platform refers to the software applications through which PDAX provides its products, services, and content, including such applications’ servers, source code, code base, and wallets.

  • Price-Time Priority means that Orders placed on the Order Book earlier in time will have priority over later Orders.

  • Quote Asset means the Asset in which trading is denominated on the Order Book; the second Asset in the Trading Pair.

  • Scheduled Downtime means a market recess or a planned temporary outage for maintenance and/or upgrades.

  • Stop Order means an instruction to post an Order to buy or sell a specified quantity of an Asset but only if and when the last trade price on the Order Book equals or surpasses the Stop Price.

  • Stop Price means the price specified in a Stop Order.

  • Taker Order means an Order to immediately buy / sell Orders on the Order Books. When a User places a buy Order equal to or above the best offer price or places a sell Order equal to or below the best bid price, the Order is Filled immediately and is termed as a Taker Order.

  • Total Asset Value means the gross value of all of a User’s Assets for the relevant Order Book, expressed in the Quote Asset or Fiat Currency based on the last traded price, or an approximation of it . This includes all Assets allocated to Open Orders.

  • User  means each customer trading on the Platform.

  • Trade or Transaction means your purchase or sale of Digital Assets through the facilities of PDAX’s Platform (in exchange for other Digital Assets or Fiat Currency).

  • Trading Contract means the contract of sale perfected between the seller and the buyer of the Digital Assets upon the matching of their respective sell and buy Orders on the Order Book and the simultaneous delivery through the Platform of the Digital Asset(s) sold in exchange for the Digital Asset(s) or Fiat Currency that is the consideration for such sale.

  • Trading Halt means that Users cannot place or cancel any Orders on the Platform.

  • Trading Pair means each pair of a Base Asset and a Quote Asset offered on the Platform. Each Trading Pair, as shown on the Platform, indicates the amount of Quote Asset displayed on the right side of the Trading Pair that is needed in exchange for one unit of the Base Asset on the left side of the Trading Pair (e.g., BTC:PHP; BTC:ETH).

Certain capitalized words and phrases used in these Rules are defined in the Agreement.

2. Trading Times

PDAX shall make its electronic Platform open for trading at all times of the day, except for Scheduled Downtime or in the event of Interruptions as defined in these Trading Rules. Except as otherwise provided in these Rules and/or the Agreement, account transfers of Fiat Currency and Digital Assets between the buyer and seller, if in accordance with a valid Order or Fill, shall take place immediately on the Platform’s exchange.

PDAX has the sole discretion to change the trading times.

PDAX reserves the right to close its electronic Platform to the public in case of outages, system maintenance, whether scheduled or made necessary by emergency technical difficulties or other such occurrences which, in PDAX’s sole discretion, present risks to the Platform or its users.

3. Trading Overview and Guidelines

  1. PDAX operates a central limit Order Book trading Platform that facilitates the purchase and sale of Digital Assets, and settles Trades in a number of Digital Asset Trading Pairs or Digital Asset and Fiat Currency Trading Pairs. The Trading Pairs available to you for trading may depend on the type and level of your Account.

  2. You are aware and understand that Orders are placed and Transactions executed using an electronic transaction system. If you incorrectly enter an Order or your Order violates these Rules, your intended Order may not be executed, or an unintended Order may be executed. PDAX will not be liable for any resulting loss or damage you may suffer under such circumstances.

  3. Only verified Users or Account holders are allowed to buy, sell, and use the Services provided on the Platform. You may use your Account to place Orders to buy and/or sell Digital Assets by placing your Orders through the Platform.

3.1. Orders

  1. When you enter an Order, you authorize PDAX to execute a Trade for all or a portion of the quantity of Digital Assets and/or Fiat Currency (“Funds”) specified in your Order in accordance with such Order. Before you engage in a Trade you must transfer a sufficient amount or number of Funds to your Account to ensure the Available Balance in your Account is sufficient to cover the total value of the Order plus any applicable fees. You are required to maintain in your Exchange Account a sufficient balance of the applicable Funds to satisfy any open Limit Order.

  2. If your Account’s Available Balance is insufficient to fulfill an Order, PDAX may cancel the entire Order or may fulfill an Order partially to the extent it can be covered by the Available Balance in your Account (after deducting any fees payable to PDAX in connection with the Trade), and may reverse or cancel, partially or in its entirety, Fills that arise from an Order by a User with insufficient Available Balance.

  3. When you place an Order, that quantity of the relevant Digital Asset or Fiat Currency required to fulfill your Order(s), including any applicable Trading fee, becomes subject to a Hold. This Hold prevents you from withdrawing or placing another Order using these Digital Assets or Fiat Currency.

  4. A User can place an Order as either a Limit Order or a Market Order.

    1. A Limit Order is an Order to buy or sell a specified quantity of a Digital Asset at a specified price or better.

      1. A Limit Order will only ever Fill at the specified price or a better price. A Limit buy Order will only be matched with the limit price or lower. A Limit sell Order will only be matched with the limit price or higher.

      2. A Limit Order will be immediately posted to the Order Book (subject to any Time in Force Instructions) and can result in a Maker Order or a Taker Order, or an Order that is partially a Maker Order and partially a Taker Order.

      3. Limit Orders may be placed with one of the following Time in Force Instructions.

        • Good until canceled: if posted, the Order will remain on the Order Book until canceled by the User in accordance with these Trading Rules. This is the default Time in Force Instruction.

        • Immediate or Cancel: the Order will only be posted to the Order Book to the extent that it would be immediately Filled; any remaining quantity is canceled. This results in a Taker Order.

        • Fill and Kill: the Order will only be posted to the Order Book if it would be immediately and completely Filled. This results in a Taker Order.

    2. A Market Order is an Order to buy or sell a specified quantity of an Asset at the best available price of existing Orders on the Order Book.

      1. A valid Market Order will be immediately posted to the Order Book. A Market Order is always a Taker Order.

      2. When a Market Buy Order is placed, the Order quantity is Filled starting with the lowest-priced sell Order currently available. When a Market Sell Order is placed, the Order quantity is filled beginning with the highest-priced Buy Order posted at the time of the Market Sell Order.

      3. PDAX will attempt, on a commercially reasonable basis, to execute the Trade on or close to the prevailing market exchange rate, as defined via the Services. You acknowledge and agree that the price information made available via our Platform may differ from prices in other markets or made available via other sources outside of the Services or the Platform.

      4. There is no guarantee that a Market Order will Fill at the price specified. A Market Order may Fill at a number of different prices, based on the quantity of the Market Order and the quantities of the existing Orders on the Order Book at the time.

      5. Depending on the volume and prices of Orders on the Order Book at the time when a Market Order is posted, the Market Order may Fill at a price less favorable than the most recent Trade price. There may be instances where there is a difference between the price specified by the User (the price displayed on screen when placing an Order or when the Order is confirmed by the User) and the actual execution price due to market movements or other such reasons after an Order is placed. This is referred to as ‘slippage,’ and may cover a situation where the price at which a Market Order is Filled is lower or higher than the most recent trade price. PDAX bears no liability whatsoever in relation to slippage.

  5. You may cancel or change an open Limit Order at any time before it is Filled. Once your Order has been executed, you may not change, withdraw, or cancel your authorization for PDAX to complete such Transaction. If an Order has been partially filled, you may cancel the unfilled balance unless the Order relates to a Market Order.

    No fees are charged for canceled Orders.

    Market Orders cannot be canceled nor changed. PDAX expressly reserves the right to refuse any cancellation request associated with a Market Order once you have submitted such Order.

  6. Responsibility of and Risks Assumed by a User upon Order Placement

    1. The User, upon placing an Order, warrants to PDAX that the Order is valid, binding, and enforceable and that all authorizations necessary to place such Order have been obtained by the User.

    2. The User shall be held liable for all obligations arising from the User’s Account and/or use of the Platform.

    3. The User may not place an Order without providing the corresponding Fiat Currency or Digital Assets required to fulfill the Order once executed. The User must pre-fund every Order by delivering to the Exchange the Digital Assets or Fiat Currency (which shall be subject to a Hold), prior to the Order being placed.

    4. The User warrants that he or she understands the potential risks of investing in Digital Assets.

    5. The User shall be solely and fully liable and shall hold PDAX free and harmless for any and all liabilities, claims, or damages, arising out of, or in connection with, any and all Orders placed on the Platform, including any tax, estate, or any such obligations or claims.

    6. The User understands and agrees that PDAX will only process Orders, sale, or purchases of supported Digital Assets in accordance with the User’s valid instructions. The Company does not guarantee the identity of any user, receiver, or third parties, and the sufficiency and legality of the title, custody, or possession of Digital Assets subject of an Order and/or Transaction.

    7. The User understands and agrees that he/she shall be solely responsible in verifying information of his/her Transaction (including the correct addressing information) before sending any instructions to PDAX. The User acknowledges that prior to placement of any Order, he/she should review the amount of Digital Assets to be bought or sold; its purchase price or sale proceeds; any fees associated with such Order; and the net proceeds to be transferred to the User’s designated Digital Asset or Fiat Currency account. Once the User submits the instruction through the Platform, such Order will be unconfirmed pending sufficient verification of the transaction by PDAX.

    8. By entering and providing any instructions, Orders, or otherwise using the Services, you hereby authorize PDAX to undertake and perform each action that is designed and appropriate to execute such instructions, Order, or the intended purpose of the Services.

3.2. Posting of Orders to the Order Book

  1. If a Taker Order is posted to the Order Book at the same price as one or more existing posted Orders, it will generally result in an immediate Fill at that price, to the extent of the total quantity of those existing Orders.

  2. To the extent that an Order is posted to the Order Book at a different price to all existing Orders, it is a Maker Order which will remain open at that price on the Order Book until:

    • It is canceled by the User;
    • It is canceled by PDAX during an outage due to maintenance or during a Scheduled Downtime or an Interruption;
    • It expires due to a Time in Force Instruction; or
    • It is completely Filled by one or more Taker Orders placed by another User at the same price.

3.3. Order Minimums/Maximums

  1. All Market Orders and Limit Orders placed on the Platform are subject to the minimum and maximum Order size requirements listed on support.pdax.ph.

  2. Updating Order Parameters: From time to time, PDAX will update the applicable Order minimums, Order maximums, and total number of Orders allowed per Order Book to reflect changing market conditions, the notional value of the assets, or any other changing conditions. For more information, you can refer to https://support.pdax.ph/s/toparticles.

3.4. Cancellation of Orders

  1. You agree and understand that it is your sole responsibility to timely cancel any Order you no longer want to be Filled except in cases where the Company has reserved its right to cancel or maintain such Order/s.

  2. Furthermore, you acknowledge that you cannot cancel an Order after its partial or complete fulfillment, and that PDAX will not be liable to you for the completion of an Order you submitted for cancellation.

  3. PDAX reserves the right to reject any cancellation request related to the Order you have submitted. If your Available Balance is insufficient to execute an Order, PDAX has the sole option to cancel the entire Order, or execute part of the Order with the amount of Digital Assets or Fiat Currency in your Account and charge Transaction fees accordingly.

  4. PDAX may, at its sole discretion and determination, cancel Open Orders in the following circumstances:

    • Orders placed by Users who, in PDAX’s sole determination, have engaged in abusive use of the Platform, for example, Market Manipulation or Prohibited Trading as defined in these Rules, or used the API in a manner which unreasonably or deliberately burdens the Platform.
    • Orders which, under the attendant circumstances, involve what PDAX reasonably determines to be an obvious error with respect to price, quantity, or other parameters - a ‘clearly erroneous transaction’.
    • If required by any applicable law or regulation, including but not limited to where PDAX is required by the Anti-Money Laundering Act, as amended, or other regulations to suspend or terminate a User’s Account or cancel an Order or Trade.
    • If required for technical reasons or to preserve the integrity of the market.

3.5. Processing Orders

  1. You understand and agree that we do not guarantee that any Order you place will be accepted, Filled, or executed. You further acknowledge that any of your Orders may be subject to delays, difficulties, and other conditions affecting its transmission or execution, over which the Company has no control including but not limited to electronic failure, slow internet connection, or market congestion. PDAX shall not be liable for any damage arising from any delay or error in processing or completing your Order.

  2. You acknowledge that any Order placed during the Company’s system updates, Downtimes, or any period in which it cannot process any Order such as but not limited to Interruptions, will be handled once the Platform resumes operation.

  3. You acknowledge that PDAX reserves the right to decline or cancel any Order or reverse any Trade or Transaction, at any time, if your Order is placed during Downtime, or if your Order is found to be materially unmarketable, unfunded, void, or illegal. Furthermore, you acknowledge that it is your sole responsibility to review any and all of your Transactions, history, Order receipts, and Trade receipts on a regular basis to ensure compliance with the above provisions

3.6. Placing and Matching Orders, Fills, and Settlement

  1. You understand and agree that PDAX operates as an exchange that facilitates buying and selling of Digital Assets and merely provides a service to its Users.

  2. The exchange functions of the Platform will Fill and match Orders at the best possible available market price, in accordance with the User’s Order instructions. With the continuous and unpredictable movement of market prices, the prices displayed on user interfaces, on the web app, mobile apps, or any part of the Platform are in no way guaranteed. The Company will not be liable under any circumstances for the consequences of any delay in Order Filling or failure to deliver or perform.

  3. When a Maker Order is matched with a Taker Order, those Orders are Filled and will be executed. A Maker Order may be matched with and Filled by one or more Taker Orders at the same price.

    A Limit order for a large quantity of Digital Assets can be partially matched, executed, and settled with smaller matching Orders. The portion that remains unfilled will remain good until filled or cancelled by the User, as may be allowed under these Rules.

  4. If one of your Orders fully or partially matches another user’s Order, the Order will be Filled, which results in an executed Trade or Transaction. The Platform settles all Filled Orders immediately, by debiting and crediting the relevant balances of Digital Assets or Fiat Currency, as may be applicable in each of the counterparties’ User’s Account.

  5. Once the Transaction is executed, your Account will be updated according to whether the Order has been fully executed and closed, or the Order has been partially executed. The Order will remain uncompleted until it is fully executed or cancelled as permitted under these Rules. All Orders that are Filled, executed, matched, or completed shall be recorded on the exchange ledger immediately.

  6. A Trade receipt, which shall contain the trade date and trade type among other information, will be sent to your registered email address after your Order is filled.

  7. Orders, once Filled and executed, are final and irreversible on the part of the counterparties in accordance with applicable law, including but not limited to The National Payment Systems Act, and you may not change, withdraw, or cancel your authorization for the Platform to complete such Transaction. Any perfected and/or executed Trade or Transaction constitutes a contract solely and exclusively between the Users who are the buyer and the seller, respectively, and counterparties of each executed Trade (“Trading Contract”). This is without prejudice to and subject to PDAX’s sole right and discretion, which the User expressly recognizes and accepts, to reverse or cancel Transactions, including Failed Trades, in accordance with these Rules.

  8. You acknowledge that any Order that exceeds the amount of Available Balance in your Account or that of your counterparty will be rejected. Those Orders which are nevertheless processed and/or matched by the Platform despite being unfunded or underfunded shall be     reversed or cancelled, irrespective of the cause for the erroneous processing (“Failed Trade”). Your affected Account shall revert to its balance immediately preceding the Failed Trade.

  9. For the avoidance of doubt, PDAX expressly reserves its absolute right, prerogative, and authority to reverse and/or cancel any invalid, void, illegal, or inexistent Transaction, such as but not limited to the following circumstances: (1) when the Trading Contract is void and inexistent or illegal under applicable law; (2) Failed Trades or when any buy and/or sale Order is unfunded or inadequately funded; (iii) when it is shown and established that any Fund or Digital Asset so paid and transferred was not legally due, and such amount constitutes a new monetary obligation owed by the payee /recipient to the person who caused the payment.

3.7. Trading Fees

  1. PDAX reserves the right to charge network and/or miner fee to process your order. The Company shall calculate fees in its discretion.

  2. Trading fees are settled by debiting the User’s Available Balance for the amount of the fee at the time that the Order is posted.

  3. Fees may vary according to Trading Pairs and by account tier/level. The current fee rates can be found at support.pdax.ph.

4. Market Integrity and Error Trade Policy

An integral and necessary component of market integrity and stability is the assurance that, except in extraordinary circumstances, a Trade once executed, will stand and not be subject to cancellation, reversal, or price adjustment. As a general rule, any Trades that do not have an adverse effect on the market and are not otherwise prohibited or void under applicable law or regulation should not be cancelled or price adjusted, even if executed in error, subject to the qualifications set forth in these Rules and/or the Agreement.

PDAX has the authority and sole discretion to take any action deemed necessary or appropriate to preserve market integrity. Without limiting their generality, such actions include a trading halt, modification of risk-mitigating parameters, restriction of access to an Account and/or the Services, restriction of Order types to post-only or limit only, cancelation of open Orders posted on the Order Book, or any other actions deemed to be in the best interest of PDAX and/or the market.

This is subject to PDAX’s sole discretion, right, and authority to do any of the following to protect the Users and the market, in general, or to comply with legal or regulatory requirements:

  1. We may: (a) refuse to complete, or place on hold, block, cancel, or reverse a Transaction you have authorized (even after Digital Assets and/or fiat currency have been debited from or credited to your PDAX Account), (b) suspend, restrict, or terminate your access to any or all of the Services, and/or (c) suspend, cancel, or terminate your Account with immediate effect for any reason, including but not limited to where:

    1. We are required to do so by applicable law, regulation, or any court or other governmental authority to which we are subject;

    2. We have reasonable basis to suspect that you have violated the User Agreement;

    3. When the underlying Trading Contract is void, non-existent, or prohibited under applicable law.

    4. We have concerns that a Transaction is erroneous or about the security of your Account or we suspect that the Services are being used to perpetuate or commit fraud or other unauthorized activities;

    5. We suspect money laundering, terrorist financing, fraud, or any other financial crime;

    6. The Account or its use is subject to any pending litigation, investigation, or government proceeding or order and / or we perceive a heightened risk of legal or regulatory non-compliance associated with your Account activity; and / or

    7. You take any action that may circumvent our controls such as opening multiple Accounts or abusing promotions which we may offer from time to time.

  2. PDAX may also refuse to complete or block, cancel, or reverse a Transaction you have authorized where there are insufficient Digital Assets and/or Fiat Currency in your Account and/or your counterparty’s Account to cover the Transaction and (where applicable) associated fees at the time that we receive notification of the Transaction.

  3. Without prejudice to any other provision of the User Agreement or these Rules, PDAX reserves the right to correct, reverse, or cancel any Order, Trade, transfer, or other transaction or activity caused or affected by any error or abnormality, whether such error or abnormality was caused by you, PDAX, or a third party or due to technical issues, system or system design issues, operational issues, software failure or otherwise. In taking the appropriate action, PDAX may take into account:

    1. That the price traded is not representative of market value (deviates from price parameters, out of the normal price range, or fair market value);
    2. The Trade, if not reversed, will be detrimental to fair and orderly Trading;
    3. Extraordinary or aberrational market conditions exist in which cancellation is necessary for the maintenance of a fair and orderly market;
    4. The Trade is the result of misconduct, system trouble, obvious errors in price, quantity or identification of the Asset.

    In such instances, PDAX also reserves the right to halt or suspend Trading or place the Platform under maintenance to ensure a fair and orderly market and to prevent any further negative repercussions of the reversed or cancelled Trade.

    You hereby authorize PDAX to make any such correction, reversal, or cancellation at its sole discretion. PDAX does not warrant or guarantee that any such attempt will be successful and will have no responsibility or liability for such error(s) or any correction attempt(s).

  4. If PDAX refuses to complete or cancels a Transaction and / or suspends, restricts, or closes your Account, and / or terminates your use of the Services or access to the Platform, we will, unless prohibited by law, regulation, or governmental order, provide you with notice of our actions and the reasons for refusal, reversal, suspension, termination, or closure, and where appropriate, with the procedure for correcting any factual errors that led to the refusal, suspension or closure of your Account. In the event that we refuse or are unable to complete a transaction and / or suspend your Account, we may, at our absolute discretion, lift the suspension or complete the Transaction as soon as reasonably practicable, once the reasons for refusal and / or suspension no longer exist. However, we are under no obligation to allow you to reinstate a transaction at the same price or on the same terms as the suspended, reversed or cancelled transaction.

  5. You acknowledge and accept that PDAX’s decision to take certain actions, including limiting access to, suspending, or closing your Account, may be based on confidential criteria and conditions that are essential for the purposes of risk management, security protocols, and/or regulatory compliance. You agree that PDAX has no duty to disclose to you the details of its risk management and security procedures or its regulatory compliance that must be maintained confidential under applicable law.

5. Access to the Platform

All verified Users have equal access to the PDAX Site, Platform, APIs, and Web Interfaces. PDAX does not provide prioritized access to any User in terms of placing and fulfillment of Orders placed on the Platform. However, there may be features, such as, but not limited to Transaction Limits, which vary and may be available depending on type of account.

6. Interruptions

  1. The Platform’s electronic transaction system may be unusable temporarily or for a certain period for many reasons, such as malfunctioning telecommunications or system equipment, scheduled or unscheduled maintenance, telecommunication network problems at the Company or a customer. An Order may be invalidated if a customer’s instructions for placing an Order arrive late (or not at all) to the Company’s system. In addition, a User’s ability to transact may be suspended in some cases whenever there is an electronic transaction system failure.

    If there is a sudden and severe change in the market, the retrieval of price information may be delayed, leading to discrepancies between the price information on the Platform’s electronic transaction system and the actual market prices.

  2. There is the risk that a system failure may occur due to changes to the external environment, etc., and this may disrupt your ability to execute Transactions. A “system failure” is when the Company finds that a malfunction (not including obstructed network lines or problems with a customer’s computer, etc.) has clearly arisen in the system required to provide the Company’s Services, and Users are no longer able to place Orders over the Internet (the Company’s website, Platform, mobile site, or applications) or Users’ Orders arrive late or cannot be placed.

    To mitigate these risks the Company will exert reasonable efforts to secure its system and to verify the accuracy of the information in the Platform and its Services.

  3. If technical reasons prevent or restrict the User’s ability to place or cancel Orders, or prevent or restrict access to the Platform or Site or adversely affect the operation of PDAX’s Platform, Order Books, or matching engines, then PDAX may, in its discretion, take one or more of the following actions in respect of one or more Order Books:

    • Temporarily disable depositing or withdrawing Assets.
    • Cancel Open Orders.
    • Disable the ability to place new Orders (Cancellation-Only Mode).
    • Disable sign-in to all or selected Accounts.
    • Disable the APIs.
    • Disable access to the Website.
    • Take any action or measure that PDAX deems necessary, reasonable, and appropriate under the circumstances.
  4. Please be aware that in the event that you lose any opportunity (e.g., the Company is unable to receive your Order and you therefore lose the opportunity to place the Order, losing profits that you ordinarily would have earned) due to emergency system maintenance or a system failure, the Company will not be able to execute a process to fix the error because it will be unable to identify the Order details that you intended to place (the original Order). The Platform may produce an aberrant value for the buy or sell price of the Digital Asset calculated by the system. Please be aware that if the Company finds that a Transaction took effect based on an aberrant value due to such system or Platform failure, the Company has the discretion and authority to cancel the transaction, without prejudice to its other remedies and courses of action as provided in these Rules and/or the Agreement.

7. Scheduled Downtime

PDAX may suspend trading temporarily for maintenance or upgrades. Absent extenuating or exceptional circumstances, PDAX will follow a commercially reasonable procedure to notify the Users on this process for closing and re-opening trading.

8. Market Manipulation and Other Prohibited Trading Activity

  1. Market Manipulation is defined as actions taken by any User or a person acting in concert with or on behalf of a User which are intended to:

    • Deceive or mislead other Users;
    • Attempt to interfere with a free, fair, and transparent market for all Users or which interferes with PDAX's normal market operations.
    • Artificially control or manipulate the price or trading volume of an Asset; or
    • Aid, abet, enable, finance, support, or endorse any of the above.

    This may include actions on or outside the Site and Platform.

  2. Prohibited Trading Activities and Market Manipulation include, without limitation: front-running, wash trading, spoofing, layering, churning, and quote stuffing.

    • Churning: Placing both buy and sell orders at the same (or similar) prices to increase the price by attracting more traders.
    • Pump and dump: Large scale buying of any Digital Asset to create artificial sentiment around a specified Asset to attract other buyers with a view to driving the Asset price and volumes higher and then selling the Asset at such inflated prices.
    • Ramping: Artificially raising the price of a Digital Asset to give the impression of trading volume and/or price increase, in order to make profit.
    • Wash trading: Selling and repurchasing the same Digital Asset to generate trading activity and increase the price.
    • Quote stuffing: Entering and withdrawing large quantities of Orders in a short space of time in an attempt to affect the market, thereby gaining an advantage over slower market participants. This may include the use of high frequency trading programs. (Note: High frequency trading is not, in itself, illegal and thus any action by PDAX would be taken in light of the nature and pattern of such trading.)
  3. Users are prohibited from engaging in certain activities that will be detrimental to the Platform and the market in general, including but not limited to Market Manipulation and/or Prohibited Trading Activities. Any form of Market Manipulation is a violation of these Rules and the User Agreement. When PDAX determines, in its sole discretion, that a User has or is engaged in such prohibited activity, PDAX has the right and authority to suspend or terminate the User's account and to freeze or appropriate any Funds and Assets (both Fiat Currency and Digital Assets) within the User's account as compensation for costs, losses, expenses, and any other damage suffered by PDAX or any of its other users.

9. Fair Dealing and Treatment

  1. Pursuant to and in compliance with the Financial Consumer Protection regulations of the Bangko Sentral ng Pilipinas (BSP), as set forth in the Manual of Regulations for Non-Bank Financial Institutions and BSP Circular 1048, PDAX is committed to upholding the integrity and transparency of Transactions on its Platform and fair and reasonable treatment of its Users. By protecting the interests of the Users and the market in general, PDAX aims to foster the User’s high confidence in Digital Asset exchange transactions.

  2. PDAX outlines its consumer protection guidelines in relation to the needs of financial consumers and hereby puts in place the following charter:

    • We commit to fairness as part of organizational culture and values.

      • All employees will practice fairness and reasonableness in internal and inter-departmental dealings as well as interactions and dealings with Users.
      • We will avoid activities that are and may potentially give rise to a conflict of interest or be perceived as constituting a conflict of interest, including assessing the potential conflict on a Company level down to the individual staff level.
      • We will implement rules and policies for employee trading, which will include, among others, an obligation of full disclosure of any foreseen conflict of interest by an employee to the Company’s Risk Management Department.
      • We will train relevant staff attending to User/customer needs in providing quality and timely response and information to ensure proper action and feedback.
      • We will take all valid and reasonable customer feedback and relay it to appropriate departments and related staff for continuous improvement.
    • We commit to fairness and integrity in trading for all Users across the Platform and Site.

      • We will match User Orders with the best available Order available on the Order Book.
      • We will display fees related to Trades and Transactions, Digital Asset deposit and withdrawal, and other services as part of informing Users of the corresponding fees before Users confirm the activity.
      • We will implement employee trading policies, as the need arises, and in accordance with applicable BSP and other regulatory requirements.
    • We commit to fairness in communication.

      • We will provide Users with real-time information about their Accounts, including account balance and the value of their Assets.
      • We will provide Users with relevant information on PDAX products and services.
      • We will ensure that our User Agreement/Terms and Conditions, Trading Rules, Privacy Policy, and other applicable documents are accessible and the guidelines set out in these documents are in plain language as much as possible so Users understand their rights and responsibilities.
      • We will ensure marketing and advertising materials and activities do not make false or misleading claims that would improperly influence the User’s decision.
      • We will put forth a disclosure to Users about the risks of trading, which can be located on our Platform and in the Terms and Conditions.
    • We commit to fairness in handling User feedback, complaints, and claims.

      • We will listen and be understanding of the valid concerns raised by our Users.
      • We will be fair, unbiased, and thorough in our investigations, take feedback into consideration, and if appropriate, apply preventive actions.
      • We will act and respond in a timely manner with relevant information and be fair, reasonable, and transparent as warranted by the established attendant circumstances. Depending on the severity of the situation, we shall provide the basis for the decision made, in so far as permitted by laws and regulations on confidentiality,.
      • We will monitor the quality of response handling by responsible staff and constantly review concerns being raised for improvement, as applicable.
  3. As PDAX champions fair and transparent dealing and trading, suspicious trading activities, including but not limited to Market Manipulation and Prohibited Trading Activities under Section 8, will not be tolerated, will be reported to the relevant authorities, and made subject to appropriate action.

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