Cifra X Platform Risk Disclosure Statement

2025/12/04 13:25
Risk Disclosure
Last updated on 4 DEC 2025

1. Introduction

This Risk Disclosure Statement (“Statement”) is issued by:

IDY BILGISAYAR BILISIM SISTEMLERI LIMITED COMPANY, a corporation incorporated under the laws of Turkey, with its head office located at Ataturk Neighborhood, Ertugrul Gazi Street, Metropol Istanbul Kozyatagi, Tax Office 470, Tax Number 150 7911 (hereinafter referred to as “IDY BILGISAYAR BILISIM SISTEMLERI LIMITED COMPANY”),

in connection with the operation of the Cifra X Platform (hereinafter referred to as the “Platform”, “we”, or “us”).

The Platform allows its users (hereinafter referred to as the “Users” or “you”) to trade in digital assets (“Digital Assets”) and access other services related to Digital Assets, which may include, without limitation:

• spot trading;
• margin trading and leveraged trading;
• derivatives trading (including futures, perpetual contracts and similar products);
• staking, “earn” and similar yield products;
• copy trading and trading-bot features;
• fiat on/off ramp and conversion services (where available); and
• any other services as may be offered from time to time (collectively, the “Services”).

This Statement forms an integral part of the Cifra X Platform User Agreement (the “User Agreement”). In the event of any conflict between this Statement and the User Agreement, the User Agreement shall prevail to the extent of such conflict, unless applicable laws require otherwise.

By creating an Account, accessing or using any of the Services, you acknowledge and agree that:

1. you have carefully read, understood and accepted this Statement;
2. you fully understand the nature, features and risks of the Services and Digital Assets;
3. you are able to bear all risks associated with the Services and Digital Assets, including the risk of losing all of your invested capital.

If you do not understand or do not agree with this Statement, you must not use the Services.

2. No Investment, Legal or Tax Advice

1. No advice. The Platform does not provide investment, financial, legal, accounting, tax or other professional advice. Any information, market data, charts, analytics, order book snapshots, indicators, research, community content or educational materials made available on or through the Platform are provided for general information only and do not constitute any recommendation or solicitation to buy, sell, hold or otherwise deal in any Digital Asset or to use any particular Service.

2. Independent judgement. You are solely responsible for your own investment decisions. Before entering into any transaction or using any Service, you should:

   • carefully assess whether such transaction or Service is suitable for you in light of your financial situation, experience, objectives, risk tolerance and local legal environment; and
   • where necessary, seek independent professional advice (including financial, legal and tax advice).

3. No guarantee. We do not guarantee any profits, yields, returns, interest, rewards, bonuses, airdrops or any other form of benefit from using the Services or holding any Digital Asset. Past performance, backtested strategies, simulated results or historical data are not indicative of future results.

3. General Risks of Digital Assets

You acknowledge and understand that Digital Assets and related markets involve high risks, including but not limited to:

1. High volatility. The prices of Digital Assets can fluctuate significantly within short periods of time. Such volatility may be caused by, among others, market speculation, changes in sentiment, technological developments, regulatory announcements, security incidents, macroeconomic factors or market manipulation.

2. Total loss of value. Some Digital Assets may lose all or substantially all of their value, may become illiquid or may cease to exist (e.g. due to project failure, hacking, regulatory intervention or abandonment by developers).

3. Lack of guarantees. Digital Assets are generally not issued, backed or guaranteed by any government, central bank or other public authority. They may not be subject to deposit protection or investor compensation schemes.

4. Irreversible transactions. Digital Asset transactions may be irreversible. Errors (e.g. incorrect addresses, incorrect network, unintended amounts) or unauthorised transactions may result in permanent loss of your Digital Assets.

5. Forks and airdrops. Protocol changes (“forks”) or airdrops may affect the characteristics, value and operation of Digital Assets. We may, at our discretion, decide whether and how to support any fork or airdrop, and we are not obliged to support all such events.

4. Trading and Market Risks (Spot Trading)

1. Market risk. Spot trading of Digital Assets exposes you to continuous market risk. The value of your Digital Assets may go down as well as up. You may suffer losses if you sell at a price lower than your purchase price.

2. Order execution risk. Orders placed on the Platform may be fully or partially filled, or may remain unfilled, depending on market conditions and liquidity. There is no guarantee that any order will be executed at a particular price or within a particular time.

3. Price slippage. Large orders or orders placed in volatile or illiquid markets may be executed at prices significantly different from those you expected due to slippage.

4. Short selling and borrowing. Where permitted, short selling or borrowing assets for trading purposes may involve additional risks, including margin calls, forced buybacks and potentially unlimited loss if the price moves against your position.

5. Leverage, Margin and Derivatives Risks

Where the Platform offers leverage, margin trading, futures, perpetual contracts or similar derivatives (“Derivatives”), you acknowledge that:

1. High-risk nature. Derivatives trading is highly speculative and involves a higher level of risk than spot trading. Price movements in the underlying Digital Assets may have a magnified effect on your positions.

2. Leverage effects. The use of leverage can work for you or against you. A relatively small price movement in the underlying market may result in large profits or large losses. You may suffer losses exceeding your initial margin or capital allocated to that position.

3. Margin calls and liquidation.

   • You are responsible for maintaining sufficient margin in your Account at all times.
   • If market movements cause your margin level to fall below the maintenance margin requirements, your positions may be partially or fully liquidated automatically, without prior notice, in accordance with the Platform’s rules.
   • In the event of liquidation, you may lose some or all of the assets in your Account allocated to margin or collateral.

4. Auto-deleveraging / clawbacks. In extreme market conditions or where insurance funds are insufficient, your open positions may be subject to auto-deleveraging or other risk control mechanisms. This may result in your positions being reduced, closed or otherwise adjusted, potentially at unfavourable prices.

5. Funding, interest and fees. Derivatives and margin products may involve funding rates, interest payments and various fees (e.g. trading fees, funding fees, borrowing fees). These may change over time and can impact your net returns or increase your losses.

6. Gap risk and extreme volatility. Markets may move sharply between the time you place an order and the time it is executed (or between two consecutive price ticks). Sudden “gaps” or flash crashes may result in executions at much worse prices than expected, or may trigger liquidation of your positions.

7. Product availability. Certain Derivatives or leveraged products may not be available in your jurisdiction due to legal, regulatory or risk considerations. You are responsible for ensuring that your use of such products is permitted under the laws and regulations applicable to you.

6. Staking, “Earn” and Similar Products Risks

The Platform may offer staking, “earn”, yield, savings, lending/borrowing or similar products (“Yield Products”). You understand and agree that:

1. No guaranteed returns. Any yields, interest, APY figures, rewards or illustrative returns shown on the Platform are not guaranteed and may change or be discontinued at any time. Actual returns may be lower, zero or negative.

2. Lock-up and liquidity risk. Some Yield Products may involve a lock-up or notice period during which you may not be able to withdraw your assets, or may only withdraw them subject to penalties or delays.

3. Slashing and protocol risk. For on-chain staking, your staked Digital Assets may be subject to penalties (e.g. “slashing”) if validators behave improperly, if there is a protocol error, or in other scenarios defined by the underlying network.

4. Counterparty and smart contract risk. Where Yield Products rely on third-party protocols, custodians or smart contracts, you are exposed to the risks of such counterparts and technologies, including hacking, vulnerabilities, insolvency or mismanagement.

5. Rehypothecation and use of assets. In certain Yield Products, your Digital Assets may be pooled, lent, staked or otherwise used by us or third parties in order to generate returns. In adverse circumstances, such use may result in delays, losses or inability to return your assets in full.

7. Copy Trading and Trading Bot Risks

The Platform may offer copy trading, strategy-following, signal services or automated trading bots (“Copy Trading/Bots”). You acknowledge that:

1. No guarantee of performance. The past or current performance, profitability, win rate or ranking of any strategy provider, trader, signal or bot does not guarantee future results. You may suffer losses when copying or following any strategy or using any bot.

2. Your responsibility.

   • You are solely responsible for choosing which trader, strategy or bot (if any) to follow or use, and for setting your own parameters (e.g. leverage, allocation, risk limits).
   • Copy Trading/Bots do not constitute investment advice or portfolio management by the Platform.

3. Execution and delay risks.

   • Execution of copied trades or bot orders may be delayed or differ from the source strategy due to network latency, liquidity conditions or technical limitations.
   • Such differences may result in materially different results compared to the source trader or strategy.

4. Disconnection and technical failures. Copy Trading/Bots may stop functioning or behave unexpectedly due to software bugs, connectivity issues, API errors, exchange downtime, maintenance, or other technical problems. This may result in unexecuted orders, duplicated orders, or unintended positions.

5. Overexposure and compounding risk.

   • Using high leverage, multiple strategies, or multiple bots simultaneously may create complex exposures that you may not fully understand or control.
   • You may incur cumulative losses across different strategies or bots.

You should carefully monitor your Account and open positions at all times and should not rely solely on Copy Trading/Bots.

8. Liquidity and Slippage Risks

1. Market depth and order book. Some Digital Assets or trading pairs may have low liquidity or thin order books. Placing large orders or trading in illiquid markets may lead to significant slippage and unfavourable execution.

2. Withdrawal and transfer limitations. In certain circumstances, such as extreme market conditions, network congestion, security incidents or legal requirements, we may temporarily suspend or limit deposits, withdrawals or transfers of specific Digital Assets.

3. Delisting and cessation of support. We may, at our discretion, delist, disable or otherwise cease to support a Digital Asset or trading pair. In such cases, you may be required to withdraw your Digital Assets within a specified period or may not be able to trade them on the Platform.

9. Technical, Cybersecurity and Operational Risks

1. System failures. The Platform or underlying infrastructure may experience interruptions, delays, errors, or failures due to software bugs, hardware malfunction, overload, maintenance, power outages or other operational issues.

2. Cyberattacks. The Platform, your Account or third-party service providers may be subject to hacking, phishing, denial-of-service attacks, malware, exploits or other cybersecurity incidents. Such events may lead to loss, theft or compromise of your Digital Assets or personal information.

3. Network congestion. Blockchain networks may experience congestion, delayed confirmation times, high transaction fees or temporary inability to broadcast or confirm transactions.

4. User-side risks. The security of your devices, internet connection and personal credentials is your sole responsibility. If you lose access to your email, phone, authentication device, password or other security credentials, you may permanently lose access to your Account and Digital Assets.

We do not guarantee continuous, uninterrupted or error-free access to the Platform.

10. Legal, Regulatory and Tax Risks

1. Changing regulations. The legal and regulatory status of Digital Assets and related services is evolving and may differ across jurisdictions. New laws, regulations, guidelines or enforcement actions may adversely affect the use, transfer, exchange, value or legality of Digital Assets and/or the Services.

2. Restrictions and prohibitions. Certain jurisdictions may prohibit or restrict the offering or use of some or all of the Services or Digital Assets. You are responsible for ensuring that your use of the Platform is compliant with the laws and regulations applicable to you.

3. Tax treatment. The tax treatment of Digital Assets may vary and is subject to change. Transactions involving Digital Assets (including trading, staking, airdrops, forks, and rewards) may be subject to income, capital gains, VAT or other taxes. You are solely responsible for determining your tax obligations, keeping appropriate records and paying any applicable taxes.

4. Freezing and disclosure. We may be required by law to freeze, block or close your Account, suspend transactions, or disclose information about you and your activities to authorities, without prior notice to you.

11. Stablecoin and Pegged Asset Risks

Certain Digital Assets may claim to be pegged to the value of a fiat currency, commodity or other reference asset (e.g. so-called “stablecoins”). You acknowledge that:

1. De-pegging risk. Pegged assets may lose their peg and trade at a discount or premium relative to their intended reference asset. Severe or prolonged de-pegging may result in significant losses.

2. Issuer and reserve risk. The value and stability of such assets depend on the issuer, reserve management, governance structure and legal framework. There is no guarantee that the issuer will maintain adequate reserves or honour redemption obligations.

3. Regulatory and operational risk. Stablecoin issuers may be subject to regulatory actions, freezing or seizure of reserves, or operational failures, which may adversely affect the value or usability of the stablecoin.

12. Third-Party Services and Integrations

Where the Platform relies on or provides access to third-party services, such as:

• payment service providers;
• custodians or wallet providers;
• liquidity providers;
• oracle or data providers;
• external APIs, smart contracts or protocols;

you understand that:

1. such third parties are not controlled by us;
2. their performance, security and reliability may affect your ability to use the Services or access your Digital Assets; and
3. failures, insolvency, hacking, mismanagement or other adverse events involving such third parties may result in loss or unavailability of your assets, delays or other negative consequences.

We are not responsible for the acts or omissions of such third parties unless explicitly required by applicable laws.

13. Fees, Funding and Other Costs

1. Fees. The Platform may charge various fees, including but not limited to trading fees, deposit or withdrawal fees, funding fees, borrowing interest, and other costs. Fee schedules may be updated from time to time.

2. Impact on returns. Fees, funding payments and other costs will reduce your overall returns or increase your losses.

3. Changes. We reserve the right to amend fees, funding mechanisms, interest rates and other economic parameters at any time, in accordance with the User Agreement.

You should familiarise yourself with the most recent fee schedule and product rules before using any Service.

14. Past Performance, Projections and Simulations

1. No guarantee. Any historical performance data, backtest results, projections, simulations, rankings, popularity indicators, “win rates” or similar metrics displayed on the Platform or otherwise provided by us or third parties do not guarantee future performance.

2. Limitations of data.

   • Data may be incomplete, delayed, approximate or subject to errors.
   • Simulated or hypothetical performance may differ significantly from actual results.

You should not rely solely on such information when making any investment or trading decision.

15. Your Representations and Acknowledgements

By accessing or using the Platform, you represent, warrant and acknowledge that:

1. you have read and understood this Statement in its entirety, and you fully understand the risks associated with Digital Assets and the Services, including the risk of losing all of your invested capital;

2. you have sufficient knowledge, experience and understanding of the nature and risks of Digital Assets, trading, leverage, derivatives, staking, and any other Services you choose to use;

3. you have carefully considered your own financial situation, risk tolerance and investment objectives and have determined that the Services and any particular transaction are appropriate for you;

4. you are able to bear all risks arising from the Services, including the risk of total loss, and you can bear such losses without impacting your essential living needs or legal obligations;

5. you have sought, or will seek, independent professional advice (including legal, tax and financial advice) where necessary;

6. you are acting on your own initiative, and not based on any statement, representation, warranty or guarantee made by us or any third party on or via the Platform regarding future profits, performance or outcomes;

7. you understand that the Platform is not responsible for monitoring your positions or managing your risk on your behalf (including in relation to margin, leverage, copy trading or bots); and

8. you are responsible for all losses and consequences arising from your use of the Services, to the maximum extent permitted by applicable law.

16. Amendments to this Statement

We reserve the right to determine, amend or modify any content of this Statement at any time at our sole discretion. The date and time displayed at the “Last updated on” section indicate the timing of the latest changes to the provisions contained herein.

The amended Statement will take effect immediately upon publication on the Platform. You are responsible for reviewing this Statement regularly. If you do not agree with the amended Statement, you must immediately cease using the Services. Any continued use of the Services shall be deemed as your agreement to the amended Statement.

17. How to Contact Us

If you have any questions regarding this Statement or the risks associated with the Services, you may contact us at:

Email: [email protected]