End User License Agreement
1. About this agreement
This Agreement is entered into between you, the individual or entity that installs, accesses, or uses the Software (“you,” “your,” or the “User”), and deToon, the entity that operates the Dojiq service (“Dojiq,” the “Operator,” “we,” “us,” or “our”). Our contact details are set out at section 24 and in the Terms of Service.
By clicking “I accept,” ticking an acceptance box, creating an account, connecting a brokerage or exchange account, or otherwise accessing or using the Software, you acknowledge that you have read, understood, and agree to be bound by this Agreement, and you represent that you have the legal capacity and authority to do so. If you accept on behalf of an entity, you represent that you are authorised to bind that entity. Our contact details are set out at section 24.
Your acceptance is recorded together with the version identifier of the legal documents then in force. If we make material changes, section 21 governs how those changes take effect and how you are notified.
2. Definitions
- Software / Service
- The Dojiq application, website, dashboards, application programming interfaces, models, algorithms, strategy engine, risk “gauntlet,” and all related software, documentation, and updates that we make available.
- Connected Account
- A brokerage, exchange, or other third-party trading account that you own and control and that you link to the Software using your own API Credentials.
- Broker
- Any regulated third party through which your trades are actually placed, executed, cleared, settled, and held — including, without limitation, Alpaca Securities LLC and Alpaca Crypto LLC (for U.S. securities and crypto) and Bitvavo B.V. and Stichting Bitvavo Payments (for EU crypto and the safekeeping of associated funds). Brokers are defined further at section 4.
- API Credentials
- The API keys, secrets, tokens, and permissions you generate at a Broker and provide to the Software so that it can read data from, and place instructions on, your Connected Account.
- Order / Instruction
- Any buy, sell, cancellation, or other trading instruction transmitted from the Software to a Broker in respect of your Connected Account.
- Strategy
- A configurable set of entry and exit rules — whether a Dojiq-provided preset, an ensemble, or one you compose — that generates candidate signals.
- Gauntlet
- The fixed, platform-operated sequence of risk gates that a candidate live order must pass before the Software transmits it. The Gauntlet is a discipline layer; it is not a guarantee of profit or of loss avoidance (see sections 9 and 10).
- Paper Trading
- Simulated trading that does not place real orders and does not involve real money.
- Live Trading
- The transmission of real Orders to a Broker against a real Connected Account, involving real money and real risk of loss.
3. What Dojiq is — and is not
Understanding what the Software is, and what it is not, is essential to this Agreement and to your rights and obligations. Dojiq is a software and decision-support layer. It is, in plain terms, a “bot” or “brain” that analyses market data, generates signals from strategies you select or configure, applies risk checks, and — where you have enabled Live Trading — transmits your Orders to a Broker of your choosing using API Credentials that you supply.
Dojiq is not, and does not act as, any of the following: a broker-dealer; a securities or investment firm; a crypto-asset service provider, exchange, or trading venue; a custodian, wallet, or depositary; a bank, e-money institution, or payment service provider; a money transmitter or money services business; an investment adviser, portfolio manager, or financial adviser; or a fiduciary. Dojiq does not receive, hold, custody, safeguard, transfer, or have title to your money, securities, crypto-assets, or any other funds or assets at any time. Dojiq operates no client account and issues no financial instrument.
All of your money, securities, and crypto-assets remain, at all times, in your own Connected Account at the relevant Broker, held under the Broker’s own terms and its own regulatory framework (see section 4). The Software never takes possession or control of those assets; it transmits instructions that you have authorised. We strongly recommend — and by using the Service you agree — that you provide only trade-enabled API Credentials with withdrawal and transfer permissions disabled, so that the Software cannot move funds off your Connected Account even if your Credentials were exposed. Dojiq does not itself verify or enforce these Broker-side permission settings; configuring them correctly is your responsibility (see section 7).
Nothing in the Software — including any signal, ranking, score, projection, backtest, paper result, dashboard, insight, verdict, or the operation of the Gauntlet — is, or should be construed as, investment advice, a recommendation, a solicitation, an offer, or an assurance that any transaction or strategy is suitable, appropriate, or profitable for you. See sections 8 and 10.
4. Custody & execution: the role of the brokers
The regulated activity of holding your assets and executing your trades is performed by the Brokers, under agreements between you and those Brokers to which Dojiq is not a party. You must have, and must maintain in good standing, your own account and legal relationship with each Broker you connect. The Broker’s agreements — not this Agreement — govern the custody, execution, clearing, settlement, and protection of your assets. The summaries below are provided for your understanding only; the Brokers’ own current documents control.
4.1 U.S. securities — Alpaca
Where you connect an Alpaca account, your trades in U.S. securities are carried out and your securities and cash are custodied by Alpaca Securities LLC (CRD #288202; SEC #8-69928), a broker-dealer registered with the U.S. Securities and Exchange Commission, a member of the Financial Industry Regulatory Authority (FINRA), and a member of the Securities Investor Protection Corporation (SIPC). In the Dojiq service, Alpaca is used for U.S. securities (stocks); cryptocurrency is provided through Bitvavo (section 4.2), not Alpaca. Alpaca separately offers cryptocurrency through Alpaca Crypto LLC — a FinCEN-registered money services business (NMLS #2160858) that is not a member of FINRA or SIPC and whose crypto is not SIPC/FDIC protected — but Dojiq does not route cryptocurrency orders to Alpaca. Technology is provided by AlpacaDB, Inc. Your Alpaca account is self-directed; under Alpaca’s customer agreement you are “solely responsible for any and all orders” placed in your account, expressly including orders placed through the API or by any third party you authorise (such as the Software), and you agree to indemnify Alpaca in respect of such third-party access. Your relationship with Alpaca is governed by the Alpaca Customer Agreement and its disclosures (indexed in Appendix A).
SIPC protects the custody of securities held at a member broker up to US$500,000 per client, including up to US$250,000 for cash, if the broker fails; some brokers arrange additional “excess-SIPC” coverage. SIPC and any excess coverage protect against the failure of the broker — not against a decline in the market value of your investments, and not against trading losses. Cryptocurrency is not protected by SIPC or by the FDIC. None of these protections apply to Dojiq, which holds nothing.
4.2 EU crypto-assets — Bitvavo
Where you connect a Bitvavo account, your crypto-asset trading is provided by Bitvavo B.V. (Amsterdam, Netherlands; Chamber of Commerce no. 68743424), which is authorised as a Crypto-Asset Service Provider under Regulation (EU) 2023/1114 (“MiCA”) by the Netherlands Authority for the Financial Markets (Autoriteit Financiële Markten, the “AFM”), with its e-money-token activity supervised by De Nederlandsche Bank (DNB). Under Bitvavo’s user agreement, your crypto-assets and your euro balances are held for safekeeping by Stichting Bitvavo Payments (Chamber of Commerce no. 69228922), a separate, bankruptcy-remote foundation that segregates user funds from Bitvavo’s own assets and holds them on at least a 1:1 basis, with you retaining a direct claim on the foundation. Crypto-assets may be held with third-party custodians and euro balances in bank accounts and low-risk assets. Your relationship with Bitvavo is governed by the Bitvavo User Agreement and Risk Disclosure (indexed in Appendix A).
Crypto-assets and associated e-money balances at Bitvavo are not bank deposits and are not covered by the Dutch deposit-guarantee scheme (depositogarantiestelsel) or any equivalent scheme. Your protection is the segregation and 1:1 safekeeping described above, not a state guarantee. Bitvavo’s account-guarantee programme for unauthorised-access incidents expressly does not apply where funds are withdrawn using an API key that you generated, or where you have shared API or login credentials — which is precisely the API model the Software uses. You therefore bear the risk associated with issuing and using API Credentials.
4.3 Your responsibility across all Brokers
You are responsible for: qualifying for and maintaining each Connected Account; complying with each Broker’s agreements, eligibility rules, and jurisdictional restrictions (for example, Bitvavo does not serve U.S. persons and Alpaca has its own eligibility criteria); the tax treatment of your trading; and every Order transmitted on your behalf. If a Broker suspends, restricts, closes, or changes your account, or changes its API, fees, availability, or asset coverage, that is a matter between you and the Broker, and we are not responsible for it, even if it affects the Software’s operation.
5. Licence grant & scope
Subject to your continuous compliance with this Agreement and the Terms of Service, and to payment of any applicable fees, we grant you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Software, in object-code / hosted form only, solely for your own lawful trading purposes and only for the period your account is active.
This is a licence to use a service; no ownership is transferred (section 13). All rights not expressly granted are reserved. We may issue, meter, or scope the licence by subscription tier, feature, capital ceiling, or usage limit as described at the point of sale or in the Terms of Service, and we may enforce those limits technically.
6. Eligibility & your account
- You must be at least 18 years old and have full legal capacity to contract.
- Access is currently invitation-only. We may accept, decline, waitlist, suspend, or revoke access at our discretion.
- You must provide accurate registration information, keep it current, and keep your credentials confidential. You are responsible for all activity under your account.
- You must not use the Software where doing so, or where your trading through a Broker, would be unlawful for you, or where you are barred, sanctioned, or resident in a restricted jurisdiction.
- One account per person unless we agree otherwise in writing. You must not share, sell, or transfer your account.
- You are responsible for enabling appropriate security on your account and for promptly notifying us of any suspected compromise.
7. Connected accounts & API credentials
To enable Live Trading you connect a Connected Account by supplying API Credentials that you generate at the Broker. You represent that you are entitled to connect that account and to authorise the resulting activity. You alone decide which Broker to use, which permissions to grant, how much capital to allocate, and which Strategies to arm.
- Trade-only keys. You must, wherever the Broker supports it, generate API Credentials with trading enabled but with withdrawal, transfer, and account-management permissions disabled. So configured, the Software cannot move funds off your Connected Account; Dojiq does not itself verify or enforce your Broker-side key permissions. If you grant broader permissions, you do so at your own risk and against our recommendation.
- Storage. We store your API Credentials encrypted at rest and decrypt them only transiently, in memory, to read data or transmit Orders you have authorised. See the Privacy Policy.
- Your responsibility. You are responsible for the keys you generate, the permissions you grant, the security of your Broker account, and all activity on your Connected Account, whether or not initiated by the Software and whether or not authorised, consistent with the Brokers’ own terms.
- Revocation. You may disconnect a Connected Account or revoke its API Credentials at the Broker at any time; doing so will stop the Software from acting on that account. Revocation does not unwind Orders already transmitted or executed.
8. Self-directed trading; no financial advice
Your use of the Software is entirely self-directed. You, and not Dojiq, make and are responsible for every investment decision: which markets to trade, which Strategies to run, how to size and schedule them, when to arm or disarm them, and whether to trade at all. By arming a Strategy for Live Trading, you authorise, in advance, each Order that the Software generates and transmits in accordance with that configuration, exactly as if you had entered it yourself.
Dojiq does not provide investment, financial, legal, tax, accounting, or regulatory advice, and nothing produced by the Software is a recommendation or solicitation to buy, sell, hold, or allocate any asset, or an opinion that any transaction or strategy is suitable for you. Signals, scores, rankings, projections, backtests, paper results, and “insights” are informational and educational only, are inherently uncertain, and may be wrong. You are solely responsible for evaluating the merits and risks of any decision. If you need advice, consult a licensed professional.
9. Automation, the gauntlet & paper trading
The Software can operate automatically according to the configuration you set, including generating and transmitting Orders without a further manual step from you for each Order. You acknowledge and accept the nature of automated trading, including that it may act quickly, repeatedly, at times you are not watching, and in ways that produce losses.
The Gauntlet is a fixed, platform-operated sequence of institutional-grade risk checks that a candidate live order must pass before transmission. The Gauntlet is a discipline and risk-reduction feature that we operate uniformly; you cannot configure or disable the core gates. The Gauntlet does not guarantee any outcome, does not prevent losses, does not detect all adverse conditions, and may block trades that would have been profitable or permit trades that produce losses. Kill-switches, entry pauses, schedules, stop-loss and take-profit logic, and similar controls are tools that can fail, be delayed, or be defeated by market conditions (such as gaps, halts, illiquidity, or outages) and must not be relied upon as guarantees.
Paper Trading is a simulation. Simulated results do not involve real money, do not account for all real-world frictions (such as slippage, latency, fees, partial fills, or liquidity), and are not indicative of future or live results. Past and simulated performance is not a reliable indicator of future performance.
10. Risk disclosures
Trading financial instruments and crypto-assets involves substantial risk. By using the Software for Live Trading you represent that you understand and accept these risks and that you are financially able to bear them. Without limitation:
- Risk of loss, including total loss. You can lose some or all of the capital you allocate. You should not trade with money you cannot afford to lose entirely.
- No profit guarantee. No Strategy, signal, ensemble, model, or the Gauntlet can guarantee profit or prevent loss. Our own research indicates that no strategy has been shown to reliably outperform a simple buy-and-hold benchmark on an out-of-sample basis; we make no performance promise of any kind.
- Market risk. Prices are volatile and can move sharply and unpredictably due to market, economic, political, or other events, including outside trading hours.
- Crypto-asset risk. Crypto-assets are especially volatile, may be illiquid, are largely unregulated or newly regulated, are not bank deposits, and are not covered by investor-compensation or deposit-guarantee schemes. You can incur a substantial or total loss.
- Leverage / margin risk. Some Connected Accounts (for example, an Alpaca margin account) may report buying power that exceeds your equity. Trading on margin amplifies both gains and losses and can result in losses exceeding your deposits. You are responsible for understanding and controlling your effective leverage and position sizing.
- Automated-system risk. Software, models, data feeds, connectivity, and the Brokers’ systems can fail, be delayed, contain errors, or behave unexpectedly, which can cause missed trades, duplicate trades, unintended trades, or losses. We are not liable for such system failures (see section 17).
- Data risk. Market data, news, sentiment, and indicators may be delayed, incomplete, or inaccurate, and Strategies acting on them may perform poorly.
- Third-party risk. The Brokers and other third parties may suspend, restrict, error, or fail, affecting your ability to trade, exit, or access your assets.
- Tax and regulatory risk. You are responsible for the tax, reporting, and regulatory consequences of your trading in your jurisdiction.
11. Acceptable use & restrictions
You must not, and must not permit anyone to:
- copy, modify, translate, distribute, sell, rent, lease, sublicense, or create derivative works of the Software;
- reverse engineer, decompile, or disassemble the Software, or attempt to derive its source code, models, or algorithms, except to the limited extent applicable law expressly permits and cannot be excluded;
- access or use the Software to build, train, or benchmark a competing product or service, or to scrape or harvest data beyond your own;
- circumvent, disable, or interfere with security, rate limits, the Gauntlet, licensing, metering, or other controls;
- access another user’s data or account, or disrupt or compromise the integrity, security, or performance of the Software or the Brokers;
- use the Software for market manipulation, fraud, money laundering, sanctions evasion, or any unlawful purpose, or in breach of any Broker’s terms, API rules, or rate limits;
- remove, obscure, or alter any proprietary notice; or
- use the Software to provide a service to third parties, or as a broker, adviser, or fund, unless expressly authorised by us in writing.
We may investigate suspected violations and cooperate with Brokers, regulators, and law enforcement. Violation may result in immediate suspension or termination (section 19).
12. Fees, subscriptions & billing
Certain features are or may become paid. Where billing is enabled, fees, billing cycles, and any capital-based pricing are presented to you before you subscribe and are governed by the Terms of Service. Payments are processed by a third-party payment processor; we do not receive your full card details. Unless required by law or expressly stated, fees are non-refundable and exclusive of taxes, which are your responsibility. We may change fees prospectively on notice; continued use after a change takes effect is acceptance. Failure to pay may result in suspension or downgrade. Paper Trading and other features may be offered free of charge and may be changed or withdrawn.
13. Intellectual property & ownership
The Software is licensed, not sold. As between you and us, we and our licensors own and retain all right, title, and interest in and to the Software, including all models, algorithms, the Gauntlet, source code, designs, text, and all intellectual-property rights, and all improvements and feedback-derived enhancements. You retain ownership of the data and credentials you provide. You grant us a limited licence to process your data and credentials as necessary to operate the Software and as described in the Privacy Policy. If you provide feedback, you grant us a perpetual, irrevocable, royalty-free licence to use it without obligation to you.
14. Availability & updates
The Software is provided as an evolving service and may be modified, updated, suspended, or discontinued, in whole or in part, at any time. Updates may be applied automatically and are governed by this Agreement unless accompanied by a separate licence. We do not guarantee any level of availability, uptime, latency, or that the Software will operate uninterrupted, error-free, or at any particular time relative to market conditions. Maintenance, outages, and failures — ours or a third party’s — may occur, including during market hours, and may affect open positions.
15. Third-party services
The Software interoperates with third-party services, including Brokers, market-data and news providers, payment processors, email providers, and hosting and infrastructure providers. Those services are governed by their own terms and privacy policies, which you are responsible for reviewing and complying with. We do not control and are not responsible for the availability, accuracy, security, actions, or omissions of any third party, and we do not endorse them. Your relationship with each Broker is directly between you and that Broker.
16. Disclaimer of warranties
The software and all related materials are provided “as is” and “as available,” with all faults and without warranty of any kind. To the maximum extent permitted by law, we disclaim all warranties, whether express, implied, statutory, or otherwise, including any implied warranties of merchantability, fitness for a particular purpose, title, accuracy, and non-infringement, and any warranties arising from course of dealing or usage of trade. We do not warrant that the Software will be uninterrupted, timely, secure, or error-free; that defects will be corrected; that data, signals, or results will be accurate, complete, or reliable; or that the Software will achieve any particular trading, financial, or performance result. No advice or information obtained from us or the Software creates any warranty not expressly stated here. Some jurisdictions do not allow the exclusion of certain warranties, so some of the above may not apply to you; in that case such warranties are limited to the minimum extent permitted by law.
17. Limitation of liability
To the maximum extent permitted by applicable law:
- we, our affiliates, and our respective officers, employees, agents, and licensors (the “Dojiq Parties”) will not be liable for any trading, investment, or financial losses whatsoever, whether or not foreseeable, arising out of or relating to the Software, your Strategies, any Order, the operation or non-operation of the Gauntlet, any Connected Account, or any decision made or not made in connection with the Software;
- the Dojiq Parties will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, data, goodwill, or opportunity, even if advised of the possibility;
- the Dojiq Parties will not be liable for losses arising from System Failures, market conditions, gaps, halts, illiquidity, slippage, delayed or inaccurate data, unauthorised access to your accounts, your acts or omissions, or the acts, omissions, suspension, restriction, or failure of any Broker or other third party; and
- our and the Dojiq Parties’ total aggregate liability arising out of or relating to the Software and this Agreement, from all claims combined, will not exceed the greater of (a) the total fees you actually paid to us for the Software in the twelve (12) months immediately preceding the event giving rise to the claim, or (b) €100.
These limitations apply to all theories of liability (contract, tort, negligence, statute, or otherwise), form the basis of the bargain between us, and survive any failure of essential purpose of any limited remedy. Nothing in this Agreement excludes or limits any liability that cannot lawfully be excluded or limited — for example, liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any mandatory rights of consumers under applicable law. If you are a consumer, this section applies only to the extent permitted by the mandatory consumer-protection laws of your jurisdiction, and your statutory rights are unaffected.
18. Indemnification
To the maximum extent permitted by law, you will defend, indemnify, and hold harmless the Dojiq Parties from and against any and all claims, demands, actions, losses, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or relating to: (a) your use of the Software; (b) any Order, trade, or activity on any Connected Account, including any placed by the Software at your direction; (c) your API Credentials and the access you grant; (d) your breach of this Agreement, the Terms of Service, or any Broker’s agreement, API rules, or applicable law; (e) your violation of any third-party right; or (f) your tax, reporting, or regulatory obligations. We may, at our option, assume the exclusive defence and control of any matter subject to indemnification, in which case you will cooperate with us. This mirrors and is in addition to the indemnities you separately owe the Brokers for third-party/API access to your accounts.
19. Term, suspension & termination
This Agreement applies from your first access and continues until terminated. You may terminate at any time by ceasing use, disconnecting your Connected Accounts, and closing your account. We may suspend or terminate your access, in whole or in part, immediately and without liability, if you breach this Agreement or the Terms of Service, if we are required to by law or by a Broker, to protect the Software, other users, or ourselves, or if we discontinue the Software. We may also operate suspension mechanisms (such as an entries pause, maintenance mode, or a kill-switch) at our discretion.
On termination, your licence ends and you must stop using the Software. Termination does not unwind Orders already transmitted or executed, does not by itself close or affect your Connected Accounts at the Brokers, and does not relieve you of amounts owed. Provisions that by their nature should survive — including sections 3, 4, 8, 10, 13, 16, 17, 18, 22, and 23 — survive termination.
20. Force majeure
We are not liable for any failure or delay in performance caused by events beyond our reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, government action, changes in law, labour disputes, epidemics, failures or interruptions of the internet, telecommunications, cloud or hosting providers, exchanges, brokers, market-data providers, or payment processors, cyber-attacks, power failures, and market disruptions, halts, or extreme volatility.
21. Changes to this agreement
We may update this Agreement from time to time. When we do, we will change the version identifier and the “last updated” date at the top and, for material changes, provide notice through the Software or by email. Unless a change is required to be effective immediately by law or for security, material changes take effect on the date stated in the notice, and your continued use after that date constitutes acceptance. We may also require you to re-accept the current version before continuing to use the Software. If you do not agree to a change, your remedy is to stop using the Software and close your account.
22. Governing law & dispute resolution
This Agreement, and any dispute or claim arising out of or in connection with it or its subject matter (including non-contractual disputes or claims), are governed by the laws of the Netherlands, without regard to conflict-of-laws rules, and the courts of Amsterdam, the Netherlands, have exclusive jurisdiction, unless a mandatory law of your country of residence provides otherwise. If you are a consumer, you benefit from any mandatory provisions of the law of the country in which you reside, nothing in this section deprives you of the protection of those provisions, and you may be entitled to bring proceedings in your local courts. The United Nations Convention on Contracts for the International Sale of Goods does not apply. Where available, disputes may also be submitted to the EU Online Dispute Resolution platform. You agree to attempt in good faith to resolve any dispute with us informally by contacting us first (section 24) before commencing proceedings.
23. General provisions
- Entire agreement. This Agreement, together with the Terms of Service and Privacy Policy, is the entire agreement between you and us regarding the Software and supersedes all prior understandings. To the extent of any conflict between them regarding the licence to the Software, this EULA controls; the Terms of Service otherwise control the service relationship.
- Severability. If any provision is held unenforceable, it will be modified to the minimum extent necessary or severed, and the remaining provisions remain in full force.
- No waiver. Our failure to enforce any provision is not a waiver of it.
- Assignment. You may not assign or transfer this Agreement without our prior written consent. We may assign it, including in connection with a merger, acquisition, or sale of assets.
- No third-party beneficiaries, except that the Dojiq Parties may enforce the provisions that benefit them.
- Notices. We may give notices through the Software or to your registered email; you contact us as set out at section 24.
- Language. The governing language of this Agreement is English; any translation is for convenience only.
- Relationship. Nothing here creates any partnership, agency, employment, fiduciary, or joint-venture relationship between you and us.
24. How to contact us
The Dojiq service is operated by deToon, Kerklaan 30, 9751 NN Haren, the Netherlands (Chamber of Commerce (KvK) no. 71447210; VAT no. NL002349019B52), online at de-toon.com. For questions about this Agreement, formal notices, or to raise a dispute, contact us at info.dojiq@gmail.com. For privacy matters, see the Privacy Policy.
info.dojiq@gmail.com is the only email address deToon operates in connection with Dojiq. Any message, notice, invoice, or request that purports to come from Dojiq or deToon but originates from any other address is not from us and is not authorised by us; we accept no responsibility or liability for it, and you should not rely or act on it.
Appendix A — Regulatory framework, compliance & sources
This appendix records the legal and regulatory frameworks that apply to the Dojiq service and to the regulated third parties through which your assets are custodied and your trades are executed, together with links to the authoritative public documentation. It forms part of, and is incorporated by reference into, each of Dojiq’s Terms of Service, End User License Agreement, and Privacy Policy. Where a linked third-party document conflicts with any summary here, the third party’s own current document governs your relationship with that third party. Outgoing links are provided for transparency; we are not responsible for the content of external sites.
A.1 — Dojiq’s regulatory position & compliance
Dojiq is a provider of trading-automation software. It does not itself carry out any regulated financial activity, does not take custody of client money or assets, and accordingly does not hold, and is not required to hold, a licence as a broker-dealer, investment firm, crypto-asset service provider, e-money or payment institution, or bank (see the division of responsibility at Terms §4 and EULA §3–4). The regulated services of custody, execution, and any advice are provided to you by the Brokers under their own authorisations (A.2). In operating the software service, Dojiq is designed to comply with the laws applicable to it as a Netherlands/EU-based online service provider, including in particular:
- the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and the Dutch GDPR Implementation Act (Uitvoeringswet AVG), as detailed in our Privacy Policy;
- EU consumer-protection law, including the Consumer Rights Directive (2011/83/EU) and the Unfair Terms in Consumer Contracts Directive (93/13/EEC), as transposed into the Dutch Civil Code (Burgerlijk Wetboek);
- the EU e-Commerce Directive (2000/31/EC) and applicable information-society-service and electronic-contracting rules; and
- applicable anti-money-laundering, sanctions, and market-abuse laws to the extent they apply to our activities.
Nothing in this appendix is a representation that Dojiq holds any financial-services licence or provides any regulated service.
A.2 — The Brokers: regulated status & public registers
Your money, securities, and crypto-assets are held and your trades executed by the following regulated entities, each under its own agreement with you (A.5). You can verify each entity in the public registers linked below.
| Entity | Role | Regulator / registration | Verify |
|---|---|---|---|
| Alpaca Securities LLC | U.S. broker-dealer; carries & custodies your securities and cash; clears your trades | Registered with the U.S. SEC; member of FINRA; member of SIPC. CRD #288202, SEC #8-69928 | FINRA BrokerCheck |
| Alpaca Crypto LLC | Alpaca’s U.S. cryptocurrency entity (Dojiq routes crypto to Bitvavo, not Alpaca) | FinCEN-registered money services business, NMLS #2160858. Not FINRA/SIPC; crypto is not SIPC/FDIC protected | NMLS Consumer Access |
| Bitvavo B.V. | EU crypto-asset service provider: operates the trading venue, custody & administration, and transfer services | Authorised as a CASP under MiCA (Reg. (EU) 2023/1114) by the AFM; e-money-token activity supervised by DNB. KvK 68743424 | Bitvavo Imprint · DNB register |
| Stichting Bitvavo Payments | Bankruptcy-remote foundation that safeguards user funds (crypto & euro) on at least a 1:1 basis; you hold a direct claim on it | Dutch foundation, KvK 69228922 | Bitvavo User Agreement |
| Bitvavo Custody B.V. | Party for the Bitvavo lending service only | Dutch company, KvK 80118844 | Bitvavo User Agreement |
A.3 — Investor & asset-protection frameworks (and their limits)
- SIPC (U.S. securities). Protects the custody of securities and cash held at a member broker (up to US$500,000, including US$250,000 cash) if the broker fails. It does not protect against market losses or trading losses, and does not cover cryptocurrency. See Alpaca’s SIPC explainer.
- MiCA safeguarding (EU crypto). Under MiCA, Bitvavo segregates client assets via the bankruptcy-remote Stichting Bitvavo Payments, held at least 1:1, with you retaining a direct claim. This is asset segregation, not a state guarantee.
- No deposit guarantee for crypto. Crypto-assets and associated e-money balances are not bank deposits and are not covered by the Dutch deposit-guarantee scheme (depositogarantiestelsel) or any equivalent, and are not FDIC-insured.
- None of these protections apply to Dojiq, which holds no client money or assets. They attach to your account at the relevant Broker.
A.4 — Applicable legal & regulatory frameworks
| Framework | Relevance | Source |
|---|---|---|
| MiCA — Regulation (EU) 2023/1114 | Crypto-asset services (Bitvavo) | EUR-Lex |
| GDPR — Regulation (EU) 2016/679 | Personal-data processing (Dojiq) | EUR-Lex |
| U.S. securities regulation | Securities custody/execution (Alpaca Securities) | SEC · FINRA |
| Securities Investor Protection Act / SIPC | Broker-failure protection | SIPC |
| U.S. Bank Secrecy Act / MSB registration | Crypto money-services (Alpaca Crypto) | FinCEN |
| EU Consumer Rights & Unfair Terms Directives | Consumer protection (Dojiq) | 2011/83/EU · 93/13/EEC |
| EU e-Commerce Directive 2000/31/EC | Online-service obligations (Dojiq) | EUR-Lex |
| Dutch data-protection supervision | Privacy complaints & guidance | Autoriteit Persoonsgegevens · EDPB |
| EU Standard Contractual Clauses | Safeguard for international data transfers | European Commission |
| EU Online Dispute Resolution | Consumer dispute resolution | ODR platform |
A.5 — Source documents (authoritative third-party terms)
Your relationship with each Broker and service provider is governed by that party’s own documents. Review them; they control over any summary in Dojiq’s documents.
Alpaca (U.S. securities & crypto): Disclosures index · Customer Agreement · Terms & Conditions · Privacy Policy · Crypto Customer Agreement · Crypto Risk Disclosures · Form CRS.
Bitvavo (EU crypto-assets): Terms · User Agreement · Risk Disclosure · Privacy Statement · Cookie Statement · Imprint · Developer Agreement.
Other providers: Stripe Privacy Policy (payments) · Google Privacy Policy (transactional email).
A.6 — Dojiq’s own documents
These three documents together form the whole agreement between you and Dojiq and cross-reference one another:
- Terms of Service — the master service agreement.
- End User License Agreement — the software licence, custody division, risk disclosures, warranties, liability, and indemnity.
- Privacy Policy — how we process personal data under the GDPR.
The current version identifier and last-updated date appear at the top of each document. When we make material changes we update the version, and we notify you through the Service or by email as described in each document’s “changes” section.