SDT Crypto Asset Delisting Policy

Last Updated: March 3rd, 2023
CoinSmart

In accordance with regulatory requirements, Simply Digital Technologies Inc., (“SDT”, “us”, we”, “our”, “firm”) has established policies and procedures to review crypto assets and determine whether they are best suited to be listed on our platform. This review includes considering the governance, usage and design of each crypto asset, the roadmap of the developer community, the utility and liquidity of the crypto asset, and material technical risks associated with the crypto asset. Once an asset is listed on the platform we continually monitor the listed crypto assets for significant changes. If we identify significant changes that materially change the risks associated with the crypto asset we will make a determination as to whether the crypto asset should be delisted from our platform.

When SDT decides to delist a Crypto Asset on its platform, it will take the following steps:

● thirty (30) days before delisting the crypto asset (the “Announcement Date”), SDT will communicate to its users via email, social media and in-app notifications and will communicate the timeline allotted to have the crypto asset removed from the platform (the “Deadline Date”).

     ○ When this occurs, users will no longer be able to:

        ■ (i) trade the crypto asset;

        ■ or (ii) fund their account with the crypto asset;

     ○ Instead the user can sell or withdraw the asset

● fifteen (15) days before the Deadline Date, SDT will send an additional communication to its users via email, social media and in-app notifications and remind users about the timeline.

     ○ During this time users will not be able to:

        ■ (i) trade the crypto asset; or

        ■ (ii) fund their account with the crypto asset;

● seven (7) days before the Deadline Date, SDT will provide users with another communication via email, social media and in-app notifications that within seven days they will no longer be able to:

     ○ (i) trade the crypto asset; or

     ○ (ii) fund their account with the crypto asset;

● twenty-four hours before the Deadline Date, SDT will send a final communication to its users via email, social media and in-app notifications that within twenty-four hours they will no longer be able to: ○ (i) trade the crypto asset; or ○ (ii) fund their account with the crypto asset;

● All Limit orders for the crypto asset will be canceled by the Deadline Date

● on the Deadline Date, SDT:

     ○ (i) will delist the crypto asset from the platform by disabling trading in the crypto asset and funding of accounts using the crypto asset; and

     ○ (ii) will communicate to its users via email, social media and in-app notifications and advise users that they will be provided with a thirty day deadline of the remaining crypto asset on the platform (the “Final Withdrawal Date”), they will no longer be able to withdraw their holdings of the crypto asset off the Platform;

● fifteen (15) days before the Final Withdrawal Date, SDT will communicate to its users via email, social media and in-app notifications that within fifteen days they will no longer be able to withdraw their holdings of the crypto asset off the Platform;

● five days before the Final Withdrawal Date, SDT will communicate to its users via email, social media and in-app notifications that within five days they will no longer be able to withdraw their holdings of the crypto asset off the Platform;

● twenty-four hours before the Final Withdrawal Date, SDT will communicate to its users via email, social media and in-app notifications that within twenty-four hours they will no longer be able to withdraw their holdings of the crypto asset off the Platform;

● on the Final Withdrawal Date, SDT will disable the ability of users to withdraw their holdings of the crypto asset off the Platform.

● For clients that do not have the minimum balance required to sell or withdraw the crypto asset from the platform, SDT will provide the user with the Canadian dollar equivalent of the crypto asset in the user account based on the crypto asset rate as of the final withdrawal date.

 

At the sole discretion of the firm, SDT may also decide to continue to store the delisted crypto asset for its users and allow the withdrawal of the crypto asset by its users for a period of time that is shorter or longer than thirty days following the Deadline Date. A decision in this regard could be triggered by risks that impact the user or the firm such as cybersecurity, regulatory risks and or maintaining storage capabilities for the delisted crypto asset.