EXCHANGE TRADING RULES

2. DEFINED TERMS

Unless otherwise required by context, the following terms have the meanings shown below:

3. APPLICABILITY

These Rules apply to all Users and to all Virtual Asset transactions executed on the XchangeOn Platform. Any amendments to these Rules become effective upon publication on the Platform, unless a later date is specified. These Rules continue to apply to a User for twelve (12) months following account termination.

4. POWERS OF XCHANGEON

XchangeOn has the authority, under these Rules and VARA’s Exchange Services Rulebook, to supervise its market. Without limitation, XchangeOn may:

• Publish terms, conditions, rules, restrictions, and procedures for User registration;
• Publish terms, conditions, rules, restrictions, and procedures for adding or removing Virtual Assets from the Platform;
• Stipulate the time, mode, and manner for executing trades and settling transactions;
• Determine fees and other charges payable by Users;
• Monitor and supervise trading activity;
• Initiate disciplinary proceedings and impose sanctions on Users who breach these Rules, the User Agreement, or VARA’s directives, consistent with VARA Exchange Services Rulebook III.A.2;
• Suspend trading;
• Amend these Rules from time to time;
• Take any measures required by VARA or any other Competent Authority;
• Exercise VARA‐mandated powers (see Exchange Services Rulebook III.A.3) to issue or impose:
  • Warnings
  • Reprimands
  • Training requirements
  • Qualification minimums
  • Remediation plans
  • Compliance audits
  • Restitution orders
  • Contractual penalties
  • Conditions or prohibitions on trading
  • Trading suspensions or restrictions
  • Expulsions
  • Cancellation of a User’s Orders and outstanding instructions
  • Reporting breaches to VARA
  • Criminal referrals;
• Exercise any other powers granted by XchangeOn’s constitutional documents, the User Agreement, or other contracts;
• Exercise any powers granted under Applicable Laws and Regulations.

5. USER ACCESS & ONBOARDING

• XchangeOn operates a Direct‐Access Model, where Users trade directly on the Platform without intermediaries. All new Applicants undergo due diligence and ongoing compliance monitoring.
• To become a User, an Applicant must: (i) Complete the online application form; (ii) Agree to and accept the User Agreement; (iii) Read, understand, and agree to abide by these Rules, confirming via checkbox; (iv) Satisfy our eligibility criteria set forth below; (v) Provide all information required for customer due diligence (CDD), AML/KYC checks, suitability assessment, and classification; and (vii) Complete all onboarding procedures, including AML/KYC checks to XchangeOn’s satisfaction.
• XchangeOn conducts CDD and KYC in accordance with Applicable Laws. Applicants must supply identity documents and any additional information XchangeOn requests, based on risk assessment. XchangeOn periodically reviews and refreshes CDD records.
• XchangeOn may, at its sole discretion, accept an Applicant as a User if they satisfy Rules 5.2–5.3 and Rule 6. Each application is vetted by XchangeOn’s AML/KYC Compliance Team.
• XchangeOn may restrict, suspend, or terminate a User’s Platform access at any time, without liability or obligation to explain, in accordance with the User Agreement and these Rules. XchangeOn will endeavour to notify the User by email of any such action.
• XchangeOn will continuously monitor Users’ transactions and may request additional information at any time, at its sole discretion, to ensure compliance.

6. USER ELIGIBILITY CRITERIA

• By applying for an Account, each User represents and warrants that, at all times:
  1. They are a natural person at least 21 years old or a legal entity validly organized and in good standing under applicable laws.
  2. They agree to comply with these Rules.
  3. They have not been suspended or terminated by XchangeOn or any other virtual asset exchange.
  4. They do not currently hold or have access to any other Account with XchangeOn.
  5. They open an Account solely for their own use, not on behalf of another party.
  6. They have full authority to enter into the User Agreement, without violating any other contract.
  7. They do not reside in, nor attempt to access the Platform from, any jurisdiction where XchangeOn’s services are restricted or prohibited (e.g., locations subject to economic sanctions).
  8. They are not named on any sanctions list and are not subject to any applicable sanctions.
  9. They are fit, proper, and of good repute.
  10. They possess sufficient technical competence to use the Platform.
  11. They have no conviction for crimes or financial impropriety.
• Applicants who are Politically Exposed Persons (“PEP”) require additional approval before onboarding.
• By enforcing these criteria, XchangeOn ensures only suitable Users gain access, enhancing Platform security and integrity.

7. COMPLIANCE

• Users’ conduct is governed by these Rules, the User Agreement, and all Applicable Laws and Regulations.
• Upon accepting the User Agreement, each User agrees to comply fully with their obligations under these Rules, the User Agreement, and all Applicable Laws.
• XchangeOn cooperates with Competent Authorities. It reserves the right to freeze or terminate Accounts and funds flagged or investigated by any authority.
• XchangeOn will promptly report any User conduct that may involve market abuse, financial crime, or regulatory violations to the relevant Competent Authorities, sharing KYC and trading details (e.g., open positions, order history).
• Users must comply with any information request from XchangeOn regarding their activities or KYC data.
• XchangeOn may, by written notice, request additional information from a User whenever it deems necessary for compliance or risk management.
• Users must not knowingly provide false, misleading, or inaccurate information to XchangeOn at any time.
• XchangeOn may disclose any User‐provided information or documents to any person (including Competent Authorities) when required by law or to maintain market integrity.

8. ENFORCEMENT & INVESTIGATION

• XchangeOn may supervise Users and their activities. To ensure compliance with these Rules, the User Agreement, or Applicable Laws—or to protect market integrity—XchangeOn may conduct surveillance, monitoring, examinations, and investigations.
• XchangeOn may request any documents, books, contracts, or records from a User to investigate suspected violations.
• XchangeOn may investigate: (i) Any suspected breach of these Rules by a User, however discovered; (ii) Any complaint against a User; (iii) Any matter that may affect fair and orderly trading.
• XchangeOn has no obligation to notify a User when an investigation begins.
• XchangeOn may disclose User information for: (i) Instituting, defending, or resolving legal proceedings; (ii) Compliance with any Competent Authority directive or legal compulsion; (iii) Maintaining high standards of market integrity and fair dealing; (iv) Any other purpose with the User’s consent and in compliance with Applicable Laws.
• If XchangeOn concludes a User breached these Rules, it may impose disciplinary action under Rule 16 (DEFAULT EVENTS & DISCIPLINARY ACTIONS).
• XchangeOn records all investigations and disciplinary outcomes on the User’s compliance record.
• Any Rule, User Agreement, or legal violation may lead to investigation and referral to Competent Authorities.
• Users are bound by any findings, decisions, or penalties resulting from these proceedings.
• Users must fully cooperate with XchangeOn or its delegated agents during any investigation, providing requested information within specified timeframes.

9. USER’S CONTINUING OBLIGATIONS

• At all times, each User must:
  1. Refrain from illegal or deceptive activities (fraud, market abuse, financial crime).
  2. Refrain from using web crawlers or similar tools to extract data.
  3. Refrain from using VPNs to circumvent jurisdictional restrictions.
  4. Refrain from reverse‐engineering the Platform or its source code.
  5. Avoid any action that imposes an unreasonable load on the Platform or disrupts its operation.
  6. Refrain from depositing or sending Virtual Assets to or from addresses linked to illicit activities.
  7. Respect all intellectual property rights; do not infringe on XchangeOn’s or third parties’ IP.
  8. Keep passwords and credentials secure and unique.
  9. Maintain a valid, up‐to‐date email address and phone number.
  10. Maintain required hardware, software, and network connectivity to use the Platform.
  11. Maintain adequate security measures (antivirus, firewalls) to protect against malware.
  12. Cooperate fully with XchangeOn and any Competent Authority in investigations.
  13. Timely fulfill all notification obligations under Rule 10 (NOTIFICATION OBLIGATIONS).
  14. Honour any undertakings given to XchangeOn or under any other agreement with XchangeOn.
  15. Comply with all procedural, operational, and technical requirements specified by XchangeOn.
  16. Keep all information and documents (including KYC data) current and accurate.
  17. When applicable, maintain sufficient personnel and resources for compliance.
  18. Pay all applicable fees and charges promptly.
  19. Indemnify XchangeOn against any liabilities, costs, or losses arising from their use of the Platform.
  20. Act with honesty, integrity, fairness, and due care to preserve market integrity.
  21. Avoid actions that could harm XchangeOn’s reputation.
  22. Continuously meet eligibility criteria under Rule 6 (USER ELIGIBILITY CRITERIA).
  23. Log out at the end of each session on shared or public devices.
• Users are responsible for all acts and omissions on their Account, whether authorized or not.
• Each User acts as principal in all interactions with XchangeOn.
• In addition to Rule 15 (CODE OF CONDUCT & PROHIBITED CONDUCT) on prohibited activities, Users must not:
  1. Place Orders that create artificial market activity, including “wash trades” (simultaneous buy/sell to inflate volume).
  2. Collude on pricing (quotations) or trading strategies with other Users.
  3. Use any means to take unfair advantage of other Users.
• Users must not:
  1. Coordinate or share pricing information with other Users for the purpose of market manipulation.
  2. Pressure or coerce other Users or third parties in any manner related to trading.
  3. Engage in behavior that implies false endorsement by or affiliation with XchangeOn.
• Users are responsible for ensuring that they have:
  1. Sufficient authority to transact business on the Account.
  2. Sufficient knowledge and understanding of their responsibilities under these Rules and the Applicable Laws and Regulations at all times.
  3. Sufficient knowledge, understanding and experience with respect to financial markets, Virtual Assets, and trading.
  Failure to comply with this Rule 9 may result in disciplinary action as outlined in Rules 4 (POWERS OF XCHANGEON) and 16 (DEFAULT EVENTS & DISCIPLINARY ACTIONS).

10.NOTIFICATION OBLIGATIONS

• A User must promptly notify XchangeOn if:
  1. They commit or may commit a material breach of these Rules, the User Agreement, or any Applicable Laws.
  2. They are under investigation or enforcement action by any Competent Authority.
  3. They receive any injunction, sanction, or legal notice from a Competent Authority related to Platform activities.
  4. A Default Event has occurred or is imminent.
  5. They suspect unauthorized access or security breaches of their Account.
  6. Any material change affecting their ability to comply with these Rules or Applicable Laws.
  7. They fail to meet eligibility criteria under Rule 6 (USER ELIGIBILITY CRITERIA) or continuing obligations under Rule 9 (USER’S CONTINUING OBLIGATIONS).
  8. Any material operational or security incident relating to their Account.
• Notifications must be submitted using XchangeOn’s prescribed channels (e.g., email, in‐App messaging).

11. COMMUNICATIONS WITH USERS

• Unless otherwise agreed, XchangeOn’s communications to Users—agreements, notices, disclosures, etc.—are deemed delivered if:
  1. Posted on the Platform; or
  2. Emailed to the User’s registered email address.
• All communications shall be in English and/or Arabic.

12.LISTING OF VIRTUAL ASSETS

• XchangeOn may only list Virtual Assets approved by VARA.
• Listing decisions are at XchangeOn’s sole discretion. Notice of a new listing must include the effective date and any Pre‐Open Session period.

13.DELISTING & TRADING SUSPENSION

• XchangeOn will delist or suspend trading of a Virtual Asset if:
  1. VARA or any Competent Authority directs it;
  2. Required for legal or regulatory compliance;
  3. Necessary to protect fair and orderly trading;
  4. The Virtual Asset’s price volatility exceeds predefined thresholds;
  5. The Virtual Asset no longer meets these Rules;
  6. The Virtual Asset is affected by a hard fork;
  7. The Virtual Asset is affected by Downtime.
• Delisting or suspension decisions are at XchangeOn’s sole discretion. XchangeOn will:
  1. Publish notice with effective date;
  2. Cancel all Open Orders for the Virtual Asset to be delisted;
  3. Disallow new Orders or deposits from effective date;
  4. Halt matching of Orders during suspension.
• After any suspension (Rule 13.2), XchangeOn may resume trading at its discretion. XchangeOn is not, and will not be, liable for any losses or consequences arising from delisting or suspension.
• Before resuming, a Pre‐Open Session may be held during which:
  1. Users may submit or cancel Limit Orders only;
  2. No Order matching will occur.

14.SUSPENSION OR TERMINATION OF USER ACCESS

• XchangeOn may suspend or terminate a User’s Platform access at any time if:
  1. A Default Event occurs (Rule 16) (DEFAULT EVENTS & DISCIPLINARY ACTIONS);
  2. Required by law or Competent Authority;
  3. Security concerns or suspected fraud;
  4. User no longer meets eligibility requirements (Rule 6) (USER ELIGIBILITY CRITERIA);
  5. User’s conduct threatens market integrity;
  6. User’s account is subject to litigation or investigation;
  7. User attempts to circumvent controls (e.g., creation of multiple accounts);
  8. User infringes others’ rights;
  9. User’s actions harm XchangeOn’s reputation.
• If suspended or terminated:
  1. XchangeOn may cancel the User’s Open Orders;
  2. All transactions remain binding;
  3. All access credentials may be disabled.
• Suspension/termination may be immediate or scheduled; XchangeOn will endeavour to notify via email.
• A suspension may be lifted if XchangeOn determines the underlying issue is resolved; otherwise, XchangeOn may extend the suspension.
• Upon actual account termination, XchangeOn will permanently revoke access and all obligations under these Rules will survive for acts occurring prior to the termination.

15.CODE OF CONDUCT & PROHIBITED CONDUCT

• Users must trade lawfully, ethically, and fairly.
• Prohibited conduct includes any Market Abuse, Financial Crime, or other violations of these Rules or Applicable Laws, such as:
  1. Placing Orders to mislead the market (spoofing, layering).
  2. Wash trading (buying and selling the same Virtual Asset to inflate volume).
  3. Insider Dealing or Unlawful Disclosure of Inside Information.
  4. Front‐running or other unfair trading.
  5. Coordinating orders or pricing with other Users.
  6. Colluding to manipulate market prices.
• XchangeOn uses proprietary and third‐party surveillance software to detect suspicious trading. Violators are subject to disciplinary action (Rule 16) (DEFAULT EVENTS & DISCIPLINARY ACTIONS).
• Users must not disclose Inside Information to any party except as required by law or legitimate business.
• Users must not induce others to trade on Inside Information.
• Placing simultaneous buy/sell Orders that self‐match (“wash trades”) is strictly prohibited.
• Failure to comply with this Rule 15 may result in disciplinary action, including but not limited to suspension, fines, or account termination.

16.DEFAULT EVENTS & DISCIPLINARY ACTIONS

• A “Default Event” occurs if a User:
  1. Fails any obligation under the User Agreement, these Rules, or any XchangeOn policy.
  2. Breaches these Rules or the User Agreement.
  3. Makes any material misrepresentation to XchangeOn.
  4. Is declared bankrupt or enters insolvency proceedings.
  5. Engages in Market Abuse or Financial Crime.
  6. Is subject to enforcement, sanction, or investigation by any Competent Authority.
• Upon a Default Event, XchangeOn may declare the User a “Defaulter” by email.
• For a Defaulter, XchangeOn may, in its sole discretion, take any of the following disciplinary actions (based on severity):
  1. Issue a written warning;
  2. Request additional information or documents within a specified timeframe;
  3. Order the User to remedy the violation within a specified period;
  4. Cancel some or all of the User’s Open Orders;
  5. Sell the User’s Virtual Assets to cover losses or fees;
  6. Suspend or terminate the User’s Account (per Rule 14) (SUSPENSION OR TERMINATION OF USER ACCESS);
  7. Freeze or block the User’s accounts.
• XchangeOn may report any Default Event and disciplinary action to relevant Competent Authorities without prior notice to the User.

17.TRANSPARENCY

• Pre‐Trade Transparency: XchangeOn continuously displays current bid/ask prices and depth indications for each trading pair.
• Post‐Trade Transparency: XchangeOn publishes, as close to real time as technically possible, the price, volume, timestamp, and trading pair of every executed trade.

18.FEES & CHARGES

• Users must pay all fees published in XchangeOn’s Fee Schedule. Advance notice is provided for any fee changes.
• Each trade incurs:
  1. Maker Fee – When a Limit Order adds liquidity to the Order Book.
  2. Taker Fee – When a Market Order or Limit Order removes liquidity.
• XchangeOn displays the applicable fee in the order confirmation.

19.SETTLEMENT

• All filled trades are settled off‐chain by debiting and crediting Users’ internal balances in real time.
• Once debited/credited, settlement is final and reflected in Account transaction history.
• Each trade is bilateral: the buyer’s debit equals the seller’s credit.

20.PRE‐TRADE RISK CONTROLS

• To protect market integrity and mitigate errors or manipulative Orders, XchangeOn enforces:
  1. Price‐checking logic: Validates Limit Order prices against recent best bid/ask.
  2. Volume limits: Blocks Orders exceeding maximum per‐Order size thresholds.
• Orders outside these risk limits trigger warning messages or rejections.

21.MARKET ABUSE & FINANCIAL CRIME

• Users must not engage in any Market Abuse, Market Manipulation, Financial Crime, Insider Dealing, or related offenses, including:
  1. Spoofing or layering (placing and canceling Orders to mislead);
  2. Wash trading (self‐matching Orders to inflate volume);
  3. Front‐running (trading on non‐public order information);
  4. Unlawful Disclosure of Inside Information;
  5. Coordinating prices or trades with other Users;
  6. Using illicit addresses or funds.
• Orders must be placed in good faith for bona fide trading.
• Users shall only deposit or withdraw Virtual Assets to/from addresses they control and are pre‐registered.
• XchangeOn monitors trading for suspicious activity using automated and proprietary tools. Any suspicious Orders or trades may be canceled, and relevant details reported to Competent Authorities.
• If XchangeOn suspects Market Abuse or Financial Crime, it will immediately notify the appropriate authority.

22.TRADING RULES

• Trading Hours: XchangeOn’s Platform operates 24 hours a day, 7 days a week—unless subject to Downtime (Rules 17.2–17.4) or Trading Suspension (Rule 13).
• Scheduled Downtime: XchangeOn may schedule Downtime for maintenance or upgrades. Scheduled Downtime will be announced at least 24 hours in advance via email or Platform notice.
• Unscheduled Downtime: If an emergency or unforeseen technical issue occurs (e.g., system failure, cyberattack), XchangeOn may suspend trading and notify affected Users of the issue and its impact.
• Emergency Halts: In extraordinary circumstances (e.g., severe price volatility, regulatory directive), XchangeOn may immediately halt trading.
• Order Types: Users may place the following Orders:
  1. Market Order: Executes immediately at the best available price. XchangeOn does not guarantee execution price.
  2. Limit Order: Specifies a maximum (buy) or minimum (sell) price. Remains open until matched or canceled. May become Maker or Taker.
  3. Time Condition Order: Executes only when a predetermined time interval is reached and price conditions are met.
  4. Conditional Order: Executes only if a specified price trigger (e.g., “stop price”) is met, then becomes a Limit Order.
• Order Placement & Pre‐Funding:
  1. Users may place Orders via XchangeOn’s web or mobile app.
  2. To place an Order, the User must have sufficient Virtual Asset or fiat balances in their Account (all Orders are pre‐funded). Upon Order placement, the required assets are placed on hold until the Order is Filled, canceled, or expires.
  3. If a User’s balance is insufficient, the Order is automatically rejected.
  4. XchangeOn sends an email confirmation for each new Order, and subsequent fills (partial or full).
• Order Matching (“Price‐Time Priority”):
  1. When a Taker Order is submitted, XchangeOn’s matching engine:
     1. Matches the Taker Order against the oldest Maker Order at the best price.
     2. If unfilled, matches any remaining quantity against the next Maker Order(s) at that price, in time order.
     3. If still unfilled, repeat at the next best price.
  2. The process continues until the Taker Order is fully matched or becomes a Maker Order.
  3. Each Fill debits and credits Users’ Accounts in real time (off‐chain).
• Limit & Taker Orders:
  1. A Limit Order not matched immediately remains in the Order Book.
  2. A Market Order consumes liquidity immediately and may execute across multiple price levels.
• Order Cancellation:
  1. Users may cancel any Limit Order before it is Executed.
  2. XchangeOn may cancel any Open Order if:
     1. It violates these Rules or Applicable Laws;
     2. It appears fraudulent or erroneous;
     3. XchangeOn deems cancellation necessary to preserve a fair market.
  3. Users will receive email notification when an Order is canceled.
• Trade Reversals:
  1. XchangeOn may reverse any trade if:
     1. Required by law, VARA, or Competent Authority;
     2. It resulted from a technical failure or malicious activity;
     3. The execution price is materially inconsistent with market levels;
     4. Volume is inconsistent with normal trading patterns;
     5. A User requests reversal within 30 minutes of execution, and XchangeOn deems it valid.
  2. When reversing a trade, XchangeOn notifies both counterparties and explains the reason.
• Pre‐Trade Risk Controls:
  1. XchangeOn implements risk checks on Orders to prevent:
     1. Fraudulent or erroneous trades;
     2. Market Abuse or manipulative Orders;
     3. Orders that might create false or misleading market signals.
  2. Orders outside predetermined limits trigger warning messages; repeated violations may lead to suspension.

23.PENALTIES

• Violations of these Rules may result in disciplinary measures, including but not limited to:
  1. Warnings or reprimands;
  2. Fines or restitution;
  3. Suspension or termination of Account;
  4. Cancellation or reversal of Orders/trades;
  5. Reporting to Competent Authorities.
• XchangeOn may modify penalties at its sole discretion. Users will be notified of any changes.

24.MEASURES TO MAINTAIN FAIR & ORDERLY TRADING

• Control Measures: In the interest of market integrity, XchangeOn may:
  1. Suspend trading (Rule 14).
  2. Apply or modify pre‐trade risk controls (Rule 20) (PRE‐TRADE RISK CONTROLS).
  3. Suspend or terminate User access (Rule 14).
  4. Cancel Open Orders (Rule 22.9) (Order Cancellation).
  5. Reverse executed trades (Rule 22.10) (Trade Reversals).
  6. Any other measures deemed necessary to protect Users or the Platform.
• Exceptional Circumstances: XchangeOn may invoke control measures during conditions such as:
  1. Extreme price volatility or flash crashes,
  2. Pending publication of material news affecting a Virtual Asset,
  3. Changes in Applicable Laws affecting operations,
  4. Any scenario XchangeOn deems disruptive to fair trading.
• Emergency Situations: Control measures may also apply when:
  1. There are Platform system failures or cyberattacks,
  2. User access issues or widespread outages,
  3. Custody or settlement system failures,
  4. Force Majeure events,
  5. Other emergencies compromising market integrity.
• Technical Issues: XchangeOn may activate pre‐trade or post‐trade controls if technical issues prevent placement or cancellation of Orders, impair Platform access, or disrupt the Order Book (including malicious attacks on third‐party service providers).

25.CUSTODY & SAFEKEEPING

• Title & Control:
  1. Title to all Virtual Assets and fiat currency held in a User’s Account remains with the User. XchangeOn holds no proprietary interest; assets are not subject to XchangeOn’s creditor claims. The User bears all risk of loss.
  2. Users control their assets while on the Platform. They may withdraw anytime (subject to Downtime, pending reviews, or legal holds) to pre‐registered external addresses.
• Virtual Assets Custody:
  1. XchangeOn uses Fireblocks as its third‐party custody solution. Fireblocks securely manages private keys in a combination of hot and cold storage.
  2. Supported Virtual Assets are held in omnibus wallets. Individual User interests are tracked on XchangeOn’s ledger, ensuring segregation from XchangeOn’s own holdings.
  3. Up to five percent (5%) of Client Virtual Assets remain in hot wallets for operational liquidity. At least ninety‐five percent (95%) reside in cold wallets. Multiple hot wallets may be used per blockchain to reduce concentration risk.
  4. XchangeOn does not use other third‐party custodians. Any changes to custody arrangements will be promptly disclosed.
  5. Users must not send unsupported Virtual Assets to their XchangeOn Wallet; unsupported transfers may be irretrievably lost. XchangeOn is not liable for incorrect or unsupported deposits.
  6. Once assets leave XchangeOn’s control (pre‐deposit or post‐withdrawal), XchangeOn is no longer responsible for their security.
• Fiat Currency Custody:
  1. XchangeOn holds Users’ Supported Fiat Currencies (e.g., USD, AED) in a segregated omnibus client account with a licensed UAE financial institution.
  2. Client Money remains in trust and is never commingled with XchangeOn’s own funds.
  3. No interest is paid on fiat or Virtual Assets held for Users.

26.COMPLAINTS

• Any person may lodge a complaint regarding XchangeOn’s operation of the Platform, including account or service issues. Complaints must be submitted via:
  1. Email: support@xchangeon.io
  2. Complaint form (available on the Platform)
  3. Letter to XchangeOn’s office address
• Complaints should include:
  • User’s name and User ID
  • Date of complaint
  • Contact details
  • Detailed description of the issue
  • Supporting documents, if any
• Upon receiving a complaint, XchangeOn acknowledges receipt within one (1) week and provides:
  1. Contact details of the complaint handler
  2. Key particulars of the complaints process
  3. Notice that the full Complaints Handling Policy is available free of charge
• XchangeOn investigates complaints promptly, implements corrective measures when appropriate, and provides a summary of the outcome to the complainant. If the complaint is rejected, detailed reasons are provided.
• If unresolved within four (4) weeks (or six (6) weeks in extraordinary circumstances), Users may escalate the complaint to VARA or pursue external dispute resolution (e.g., DIAC arbitration or Dubai courts).
• For complaints involving third‐party services, XchangeOn will forward the complaint to the relevant third party and remain responsible for resolution under these Rules, subject to the User’s consent.
• If XchangeOn determines that another Virtual Asset service provider (“VASP”) is wholly or partly responsible, XchangeOn may refer the complaint (or portion thereof) to that VASP, with the User’s written consent, and notify the User of the referral details.
• XchangeOn retains all complaint records for at least eight (8) years, per regulatory requirements.

For any questions or concerns regarding these Exchange Trading Rules, do not hesitate to reach out to us at support@xchangeon.io and we will be happy to answer your question and resolve your concerns in a timely manner.