Trading Rules
PT Bina Loka IndonesiaPT Bina Loka Indonesia, an Indonesian limited liability company with its registered office at Sequis Tower, Level 17, Jl. Jend. Sudirman No. 71, Senayan, Kebayoran Baru, South Jakarta, DKI Jakarta, duly established under the laws of the Republic of Indonesia (“Bina Loka”).

Bina Loka is an independent Indonesian company, strongly supported by reputable shareholders with leading market experience and good corporate governance and compliance

These Trading Rules provide you with the Terms and Conditions of Bina Loka regarding the use of products, services, technology, and/or features provided by Bina Loka through the Bina Loka Platform (“Trading Rules”). The Bina Loka Platform (as defined below) provides you with several services, including but not limited to Crypto Asset trading, based on the list of tradable Crypto Assets and their prices. These Crypto Assets may be accessed by Users and/or Customers, through the Bina Loka Platform. The following are the Trading Rules that govern all Transactions (as defined below) made by the Users through the Bina Loka Platform.

These Trading Rules shall constitute one and the same instrument as, and shall form an integral and inseparable part of, Bina Loka’s Customer Agreement, Terms and Conditions as well as other Bina Loka Policies. Bina Loka encourages you to carefully read the aforementioned agreements and policies prior to using any Bina Loka Services (as defined below).

Definitions and Terms
In these Trading Rules, unless the context otherwise requires, the following words and expressions shall bear the following meanings:

Bina Loka refers to the meaning of it as given in the Preamble section above.

Bina Loka Account refers to the meaning of it as given in the Preamble section above.

Bina Loka Platform refers to the platform in which Bina Loka will provide its services to Users. This Platform may be in the form of Bina Loka’s website and its applications.Bina Loka Services refers to various services provided to you by Bina Loka that are based on Internet and/or blockchain technologies and offered via Bina Loka websites, mobile applications, and other forms (including new ones enabled by future technological development). Bina Loka Services include but are not limited to Crypto Asset Trading Platforms and novel services to be provided by Bina Loka.

Coin refers to a form of Crypto Asset that has its own blockchain configuration and has characteristics like the Crypto Asset that first appeared, namely bitcoin.

Crypto Assets refer to intangible commodities in a digital form using cryptography, information technology networks, and distributed ledgers, to regulate the creation of new units, verify Transactions, and secure Transactions without the intervention of other parties.

Customer Agreement refers to an agreement between Users and PT Bina Loka Indonesia prior to the use of any Bina Loka Services.

CDD refers to “Customer Due Diligence”, which is an activity in the form of identification, verification and monitoring carried out to ensure that Transactions are in accordance with the profile, characteristic and/or pattern of Transaction of Bina Loka Users.

Digital Assets refer to digital currencies, Crypto Assets (as defined above) or other types of digitalized assets with a certain value.

Fee refers to the meaning given to it in Clause VII below.

Fiat Deposit refers to the buying of Digital Assets and/or Crypto Assets where Users can credit their accounts via bank transfers. Such deposit will allow Users to pay for the purchase and purchased Digital Assets/Crypto Asset.

Fiat Withdrawal refers to the selling of Digital Assets/Crypto Assets based on the spot market price.

KYC refers to the “Know-Your-Customer” process that Bina Loka has put in place before entering a business relationship or conducting Transactions with its Users. As part of this process, Bina Loka may do anything that it deems necessary to identify Users, verify their identity, scrutinize and investigate User Transactions, to comply with any applicable laws and regulations.

Order refers to an instruction from Users for the use of Bina Loka Services regarding Crypto-to- crypto Trading.

Order Book efers to a list of the currently open buy and sell Orders for an asset, organized by price.

Spot Trading refers to the trading facilities provided by Bina Loka to trade with other users on the market through an Order Book, at the current market price.

Terms and Conditions refers to an agreement between PT Bina Loka Indonesia and its Users, which governs the use of the Bina Loka Platform and Services.
Token refers to a form of Crypto Asset created as a derivative product of Coins.

Transaction refers to the trade of Digital Assets and/or Crypto Assets by Users on the Bina Loka Platform.

Users refer to all individuals that access, download or use Bina Loka Services and who meet the eligibility criteria and conditions stipulated by Bina Loka and applicable laws and regulations. For the avoidance of doubt, any reference made to “Customers” herewith shall have the same meaning as Users in these Trading Rules

Wallet refers to a medium used to store a Crypto Asset whether in the form of Coin or Token.

Registration Process of Customers/Users
- All Transactions conducted on the Bina Loka Platform are Transactions that have been conducted by registered Users of Bina Loka.
- The User registration process will be conducted as follows:
  - Go to www.binaloka.id then click Register;
  - Fill in the field with the name of the e-mail, then a password combination of at least 8 characters (capital/lowercase, symbols, and numbers), Reference ID (Optional), and select where the Customer knows Bina Loka. After that click if you have read and agree to the User Terms. Then click Register;
  - Please confirm your email to get a confirmation code. This is to validate your e-mail;
  - If the verification has been successful, it will appear, display of Basic Info of the Customer's account;
  - If you want to login, please go to our main page at www.binaloka.id, then click Login;
  - Please enter the appropriate email address and password used in Bina Loka. Then click Sign In; and
  - Input the OTP Code if the Customer has activated the security used. The choice to the next Account Page 2-Factor- Authentication (2FA), consists of 2 options, namely Google authentication (Google Authenticator) and SMS authentication
- For all Users, CDD is a mandatory process and includes collecting key identification information and verification documents. As part of verification, a copy of acceptable identification document or proof of address in accordance with a tier-based KYC process.
- To illustrate, acceptable ID documents for individual Customer verification includes national ID where applicable, valid passport, Driver’s License, or other government issued photographic ID card, as stated in the points below.
  
  Acceptable types of identification documents:
  - National Identity Cards (i.e., Kartu Tanda Penduduk or “KTP” );
  - Valid Passport;
  - Driver’s License; or
  - Other government issued photographic ID cards.
  Checklist for an acceptable identification documents:
  - Full Name;
  - Date of Birth;
  - Nationality;
  - Issuing Country;
  - Issue Date; and
  - Expiry Date (if applicable - must not be an expired document).
- Users will be able to login and view the pricing of the various pairings, but they will not be able to use other Bina Loka Services and Transactions until they have reached the account tier of “Verified”.
- Bina Loka has adopted a tier-based KYC process to ensure the authenticity of Customer’s identity and prevent the creation of anonymous or fictitious accounts. By doing so, the Customers’ assets are all reflected in the accounts tied to their profile, effectively improving transparency of the ecosystem and increasing the difficulty of money laundering/terrorism financing/proliferation financing and corruption.
- The User KYC verification process will be conducted as follows:
  - Login to your Bina Loka Account via Mobile Apps;
  - Click on your account logo in the top right corner;
  - Select authentication identification and select basic identification verification;
  - Click the KYC level 1 verification button;
  - A page will appear where you choose a nationality, if Indonesia prepares personal data in the form of an ID card and if a foreign national prepares personal data in the form of KITAS;
  - Upload your ID card in JPEG or JPG form, make sure the ID card is clearly visible (not blurry and all data information can be read properly);
  - Fill in your personal data according to your ID card on the data filling page;
  - After that, you will be directed to the Liveness page to do face verification, make sure your room has enough light and the face is clearly visible on the camera;
  - The system will record your face for biometric data verification by analyzing and comparing data references. When performing this face verification process, do not use any accessories on your face (for example: glasses, masks, etc.);
  - Click the record button and follow the given instructions, making sure your eyes are level with your camera;
  - Click submit after the face verification is successful and complete; and
  - The KYC verification process will be approved in less than 1x24 hours by the system if your verification data complies with the conditions provided. If there is unclear or opaque data, additional verification will be carried out. Within 7 (seven) days we will notify you whether your KYC is rejected or approved.
Representations and Warranties
- Bina Loka will not provide any guarantees that the Bina Loka Platform will always be accessible at any time, as there may be hindrances such as disturbances or periodic system and network maintenance.
- Bina Loka has provided sufficient information and explanation regarding Bina Loka Services which will be accessed by its registered and verified Users. In accordance with the provisions of Bina Loka’s Customer Agreement, Terms and Conditions, and Risk Notice, the User has read, understood, comprehended, observed, agreed to the provisions stated therein, and is willing to bear all the consequences that may arise in connection with the provisions of the Bina Loka Services including the benefits, risks, and Fees attached to such services.
- To the maximum extent permitted by applicable laws and regulations, under no circumstances shall any of Bina Loka, Bina Loka’s shareholders, joint venture parties, affiliates and related corporations and entities, and the officers, directors, employees, representatives, agents, suppliers and service providers of all of the persons and entities described herein be responsible or liable for any direct or indirect losses (including loss of profits, business or opportunities), damages or costs suffered by any User or any other person or entity, arising from or in connection with any act, omission, negligence, breach, offence or default committed by or attributable to any User, including, without limitation, any failure of any Users in the completion of their Orders and/or Transactions whether this failure is attributable to Bina Loka or otherwise.
- The User hereby represents and warrants that all data, information and documents provided by the Customer to Bina Loka are true, legal, honest, transparent, complete and accurate data, information and documents. The User states that they are willing to be prosecuted in a criminal or civil suit if Bina Loka knows or obtains information from any party that the data, information and documents provided by the User are not true/not completely true/false. Users are willing to update data/information if at any time requested by Bina Loka and all documents that have been provided become the full property of Bina Loka.
- The User hereby agrees and authorizes Bina Loka to use all data, information and information obtained by Bina Loka regarding the User, including but not limited to the User’s personal means of communication for all other purposes as long as it is possible and permitted by applicable laws and regulations, including those for the purpose of the marketing of Bina Loka Services, or other for parties in cooperation with Bina Loka. For the use of data that requires the consent of another party, the User hereby declares that it has obtained written approval from any third party for the use of such data and information.
- The User hereby represents and warrants to not use Bina Loka Services for the trade Crypto Assets related to: (i) narcotics, materials and/or chemical substances for research; (ii) money and anything similar to money, including derivatives; (iii) goods and/or services that violate any Intellectual Property Rights; (iv) ammunition, firearms, explosives, sharp weapons in accordance with the applicable legal provisions; (v) goods and/or services that reveal personal information from a third party that violates the law; (vi) goods and/or services related to lottery purchases, lay-aways; (vii) services related to banking outside the territory of the Republic of Indonesia; (viii) card payments; (ix) credit settlement; and/or (x) support of prohibited organizations or organizations prohibited by the government.
- The User hereby represents and warrants that Transactions made using the Bina Loka Services are Transactions that do not violate the provisions of the applicable laws and regulations and the provisions regarding the implementation of Transactions as stipulated in the Customer Agreement and Terms and Conditions. In the event that Bina Loka discovers indications of the implementation of Transactions that are not in accordance with the provisions of applicable laws and regulations and/or the provisions regarding the acceptance of the implementation of Transactions as regulated therein, Bina Loka has the full right to terminate or suspend the User’s Bina Loka Account by disabling the User’s access to the Bina Loka Service, and the User hereby agree that Bina Loka hereby will not provide compensation and/or assume liability in any form to the User.
- The User represents and warrants not to use the Bina Loka Services for acts that are involved in gambling practices and/or other activities that charge entry fees and promise prizes, including but not limited to casino games, gambling in sports, businesses that facilitate gambling and lottery methods.
- The User hereby represents and warrants that the risk of using third party services, products and promotions with the User (if any), is borne by the User, and the User acknowledges that Bina Loka is not responsible for the services and performance of third party services.
- The User hereby represents and warrants to Bina Loka that the User will not reproduce and/or create, provide, rent, sell, transfer, assign, and/or switch the Services either partially or completely to other parties for any reason, including but not limited to misuse of the Bina Loka Platform to conduct Transactions other than those specified in the Customer Agreement and Terms and Conditions for any purpose, including but not limited to crime/fraud/cheating. If the User violates these provisions, the User shall be responsible for all losses, demands and/or claims arising from the violation and hereby agrees that Bina Loka will not provide compensation and/or liability in any form to the Customer or any party for any claims and/or demands and/or lawsuits arising from the violation.
- The User has considered and shall abide by any and all aspects of any scheme of taxation applicable to you and your use of the Bina Loka Services, including any duty in respect to withholding, collection, reporting and remittance to appropriate tax authorities (if applicable).
- The User acknowledges that the legal and regulatory treatment of the products commonly known as cryptographic Tokens, digital Tokens or cryptographic currencies is not settled, can differ between jurisdictions, and may alter frequently, and it is your responsibility to continually review the permissibility of dealing in or with such products under the legal and regulatory frameworks applicable to you and your usage of the Bina Loka Services in the Republic of Indonesia.
- The User represents and warrants that he will use the Service properly and responsibly and not take any actions that are contrary to the laws and regulations of the Republic of Indonesia.
- The User represents and warrants that they have carefully read and understood these Trading Rules, as well as any other agreements provided by Bina Loka, including but not limited to the Customer Agreement, Terms and Conditions, Privacy Policy or other information provided by Bina Loka prior to making a Crypto Asset and/or Digital Asset Transaction.
Obligations and Responsibilities
- The User agrees to bear any risks, losses or consequences suffered by the User caused by damage, delay, loss or error in sending Orders and communications, electronically caused by the Users.
- The User agrees to bear any risks associated with Bina Loka Account reports or notifications of the use of Bina Loka services sent to Users are received or read or misused by parties who are not authorized to the Bina Loka Account, and the Bina Loka Account Password is known by other people/parties due to User’s mistake.
- The User hereby is fully responsible and agrees that Bina Loka will not provide compensation and/or liability of any kind to the User or any party for any losses and/or claims and/or demands that arise or may be experienced by Bina Loka as a result of the User’s negligence or failure to comply when conducting Transactions.
- The User hereby is fully responsible and agrees that Bina Loka will not provide compensation and/or liability of any kind to the User or any party for any losses and/or claims and/or demands that arise or may be experienced by Bina Loka as a result of the User’s negligence or failure in terms of the security of the password or credentials of the User’s Bina Loka Account.
- The User understands and agrees that the User will use the Bina Loka Account and Services for Transactions that do not conflict with the provisions of the applicable laws and/or Bina Loka’s internal policies and/or other regulations that apply nationally and internationally related to the implementation the Transaction either directly or indirectly, and Bina Loka will not provide compensation and/or liability of any kind to the User or any party for any claims and/or demands and/or losses that arise in connection with the use of the Service by the User for Transactions involving categorized as suspicious Transactions and/or Transactions that are prohibited by the provisions of applicable laws and regulations and/or Bina Loka internal policies and/or other applicable national and international regulations related to Transaction activities carried out by the User directly or indirectly.
- All Users of Bina Loka and any of its services understands and agrees that the source of their funds is legitimate economic activity and their funds are not derived from illegal activities. Bina Loka reserves the right to request a proof of source of wealth or source of funds from any of its registered Users, both personal and institutional. Bina Loka maintains a stance of cooperation with law enforcement authorities globally and will not hesitate to seize, freeze, terminate the account and funds of users which are flagged out or investigated by legal mandate.
- In conducting Transactions using the Bina Loka Platform, the User understands and agrees that there are certain sanctions imposed by the government, including the government of other countries, and/or other authorized agencies against several countries, entities and individuals. Referring to this, Bina Loka has the right not to carry out/process Transactions that are a violation of the provisions of the sanctions, and the competent authority may require the disclosure of related information. Bina Loka is not responsible if Bina Loka or other parties fail or delay the execution of Transactions, or there is disclosure of information as a result of direct or indirect violations of the provisions of these sanctions.
- It is the User’s responsibility to review and understand the legal and regulatory frameworks applicable to you and your usage of the Bina Loka Services in the Republic of Indonesia, and you as the User, represent and warrant that your usage of the Bina Loka Services is permissible under such legal and regulatory regimes.
Data Update
- Users of the Bina Loka Platform agree to update their personal information provided to Bina Loka for the purposes of data verification.
- Customer data updating activities aim to achieve the following objectives:
  - Analyze and determine the risk that Customer's activities, for the period since the last inspection, are generally deemed to fit the Customer's profile;
  - Ensure that explanations are sought and/or further information is obtained in the event of a Transaction or activity that is inappropriate/unnatural; and
  - Ensure the accuracy of the latest profile of the Customer.
Transaction Procedures
- Sale and Purchase Transactions
  - Enter your Bina Loka Account, then select Exchange.
  - To see the types of crypto, it can be seen in this menu.
  - Enter the amount you want to buy in the Buy option.
  - Click the green button to Buy.
  - Wait until the notification “Success” appears and enter the Order Book.
  - Then if you have successfully bought it will go into my order history.
  - Enter your Bina Loka Account, then select Exchange.
  - Enter the amount you want to sell in the Sale option
  - Click the pink button to Sell.
  - Wait until the notification "Success" appears and enter the Order Book.
  - Then if you have successfully bought it will go into my order history.
  - Ending balance can be checked in the Wallet menu.
- Fiat Deposit
  - The process for Fiat Deposits through banks on the Bina Loka Platform, will be conducted as follows:
    - Users visits Bina Loka’s website;
    - Users select the option to make a deposit via banking channels (supported by payment service providers);
    - User activates the banking channel payment service and its digital Wallet which is linked to Bina Loka’s website;
    - User enters the amount to deposit and confirms the Transaction; and
    - The balance will be updated on the User’s digital Wallet hosted by the payment partner. The User can utilise the balances in the digital Wallet to make purchase of Digital Assets/Crypto Asset.
  - The process for Electronic Wallet Deposits on the Bina Loka Platform, will be conducted as follows:
    - User visits Bina Loka’s website;
    - User selects the option to make a deposit via electronic Wallet (supported by payment service providers that is in cooperation with Bina Loka);
    - Bina Loka’s payment service provider will credit the amount from the electronic Wallet to the digital Wallet hosted by the payment service provider on Bina Loka’s webpage.
- Fiat Withdrawal
  
  In contrast to the purchase of Crypto Assets, Users may want to sell their Digital Assets/Crypto Assets directly to the Bina Loka. In such circumstances Bina Loka will purchase these assets at an executable price (which will be based on the spot market price).
  - Once successfully logged into the account, please select wallet.
  - Then select Withdraw. In this menu, there are two options on how to make a withdrawal, namely IDR and Crypto. Select the Crypto columns for Crypto Asset Withdrawal and select IDR column for Fiat Withdrawal
  - For Fiat Withdrawal, select add account and complete the bank data you want to enter.
  - Click the bank account you want to select and make sure the name of the account holder matches the name of the Customer. Then, click “Next”.
  - Enter the withdrawal amount with a minimum of Rp100,000, then click “Submit”.
  - For Crypto Asset Withdrawal, click the Crypto column and select the type of Crypto Asset to be withdrawn.
  - Click “Select Network” and pay attention to the Minimum and Maximum Withdrawal of each Crypto Asset.
  - Enter the recipient’s address and the amount of the Crypto Asset to be sent. Make sure the destination address is correct.
  - Click “Send”. The withdrawal will be process as soon as possible with a 1x24 hour limit. All withdrawals will be recorded in the Fiat or Crypto Withdrawal History.
- Spot Trading
  
  Spot Trading allows Users to access the trading facility that trades with other Users on the market via the Order Book at the current market rate (also known as spot price). The trade takes place immediately when the Order is fulfilled.
- Delivery of Crypto Assets to Other Wallets
  - Click Crypto.
  - Select Crypto Asset type.
  - Identify the intended network for delivery of Customer.
  - Click copy address/memo (this feature is intended to enable Customers to copy the intended wallet address).
  - Fill out the details of intended wallet address.
  - Ensure you check first the Transaction details including the intended address/memo and network. Upon checking completion, Customers can wait for the Crypto Assets to enter the Bina Loka Wallet and the Customer may check the transaction history.
Transaction Fees and Withdrawal Limits
- The following are the processes for the implementation of Transaction Fees by Bina Loka:
  - Sales fee of Cypto Asset amounts to 0,1%.
  - Purchase fee of Crypto Asset amounts to 0.1%.
  - Withdrawal BIDR to Rupiah (fiat) fee amounts to Rp5,500.
  - Fee is deducted by debiting the Available Balance of the Customer for the amount as submitted on the Order Book.
  - Fee varies from Order Book, in accordance with volume of sale and purchase of the Customer on each respective month.
- The following are the withdrawal limits implemented by Bina Loka:
  - Fiat Withdrawal Limit
    - KYC Level 0 = Unable to proceed with any Withdrawal
    - KYC Level 1 = Withdrawal Limit is limited to Rp250,000,000 (Cumulative transaction in 1 x 24 hours)
    - KYC Level 2 = Withdrawal Limit is limited to Rp5,000,000,000 (Cumulative ransaction in 1 x 24 hours)
  - Crypto Withdrawal Limit
    - KYC Level 0 = Unable to proceed with any Withdrawal
    - KYC Level 1 = Withdrawal Limit is limited to 3 BTC (Cumulative transaction in 1 x 24 hours)
    - KYC Level 2 = Withdrawal Limit is limited to 100 BTC (Cumulative transaction in 1 x 24 hours)
Transaction Security

For transaction security, Customers have the option to activate 2FA (Two Factor Factor Authentication). 2FA is a feature whereby Customers provide identity verification 2 (two) times. For example, if Customers implement log in to Bina Loka Account after inputting password, customers are quired to input special code which is sent out through SMS or Google Authenticator. Customers are able to activate 2FA SMS or 2FA Google Authenticator in Bina Loka. The use of 2FA security feature provides greater security for account, data, asset and transaction history from breach from external parties.
Complaint Service and Dispute Resolution
- In the event of any complaints or concerns regarding the use of any Bina Loka Services or the Bina Loka Platform, Users will be referred to Bina Loka’s Customer Service Team.
- The procedures for resolving any complaints at Bina Loka are as follows:
  - Users may submit any complaints to Bina Loka through Bina Loka’s Support Center, Bina Loka’s Social Media channels, and Bina Loka’s Community Feedback;
  - Upon receipt of User complaints, the complaint will be escalated to the Customer Support Team;
  - Bina Loka will provide a written acknowledgement of the complaint within 5 (five) business days of its receipt;
  - The complaint will be forwarded to the Complaint Team, where it will be allocated a tracking case number;
  - The complaint will then be investigated by the Complaint Team.
  - A final response will be provided by Bina Loka to its Users within 35 (thirty-five) business days of the receipt of complaint.
- Any User or Customer disputes arising from the use of Bina Loka Services will be conducted through the following procedures:
  - Mutual deliberation to reach a consensus between Users and Bina Loka;
  - If no consensus is reached on point (a), then the dispute resolution shall be carried out through the Crypto Asset Exchange; and
  - If no consensus is reached on point (b), then the dispute resolution shall be carried out through the Commodity Futures Trading Arbitration Board (BAKTI).
Force Majeure
- Bina Loka will not be liable for any delay or failure to perform as required by these Trading Rules because of any cause or condition beyond Bina Loka’s reasonable control.
- The events that are considered force majeure are any circumstances beyond the reasonable control, directly or indirectly, include but are not limited to:
  - atural disasters, wars, insurrections, strikes, riots, earthquakes, storms, floods or bad weather, explosions, fires, lightning strike, disturbance, blockade, armed conflict, or serious threat thereof, hostilities, mobilization, detention, revolutions, commotion, looting, closure of workplaces, disease outbreaks, pandemics, epidemics, or other natural disasters provided that there is a statement from the government or the competent authority declaring that the situation is an emergency; or
  - changes to laws, regulations, government decisions and/or policies and/or non-performance of this Trading Rules by one of the Parties caused by the implementation of this Trading Rules contrary to any existing laws and regulations which the said Party shall comply with.
Implementation of the Anti-Money Laundering Program and Counter Terrorism Funding and the Proliferation of Weapons of Mass Destruction (“AML- CTF”)
- Bina Loka has formulated its internal policies in order to ensure compliance with the laws and regulations as stipulated in Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi or “Bappebti”) Regulation No. 8 of 2021 dated October 29, 2021 regarding Guidelines for Organizing Crypto Asset Physical Trading Market on the Future Exchange, and any future amendments of such regulation.
- Bina Loka will ensure that its Platform and Services are subject to Indonesian laws and regulations, including but not limited to the following:
  - Law No. 8 of 2010 regarding the Prevention and Eradication of Money Laundering Crimes;
  - Law No. 9 of 2013 regarding the Prevention and Eradication of Criminal Acts of Terrorism Financing;
  - Regulation of the Head of the Indonesian Financial Transaction Reports and Analysis Centre (Pusat Pelaporan Analisis dan Transaksi Keuangan “PPATK”) No. PER- 02/1.02/PPATK/02/2014 regarding Intergrated Service User Information Systems; and
  - PPATK Regulation No. 2 of 2021 regarding the Procedures for Submission of Transaction Reports and Suspicious Financial Transaction Reports Through the GOAML Application for Providers of Other Goods and/or Services.
- To implement the abovementioned regulations, Bina Loka’s policies at minimum include:
  - Customer segregation;
  - CDD and retail Customer name verification (PEPs, sanctions lists and media);
  - Risk-based CDD and the verification of Customers; and
  - A Customer Risk Matrix where Users scored according to a risk matrix, which includes components such as PEP, Age, Sanctions.
- Bina Loka has implemented its own Legal and Compliance Division, who are designated to take an active role in the implementation of AML-CTF monitoring which is made possible through the implementation of RegTech to assist in Know-Your-Transaction (“KYT”)evaluation.
Scheduled Downtime
- From time to time, Bina Loka may suspend trading temporarily for maintenance or upgrades. Absent extenuating circumstances, the Bina Loka Platform will use reasonable endeavors for closing and re- opening trading.
- Any temporary suspension of trading will be informed to Users and announced through e- mail and social media account, with the following procedures
  
  Step 1: Announce Downtime Schedule
  - Announce downtime schedule through social media and e-mail.
  Step 2: Ongoing Downtime Schedule
  - The Bina Loka exchange will cease temporarily. Transaction and other features will not be able to be used.
  Step 3: After Downtime Schedule is Completed
  - Ensure that trades resume normally.
  - Announce in Telegram and/or Twitter that the downtime is completed.
Miscellaneous
- The terms and conditions stated in these Trading Rules may be amended and/or supplemented from time to time, at Bina Loka's sole discretion.
- In the event that there is any conflict between these Trading Rules and any other statement whether written or oral made by Bina Loka at any time (excluding the statements in the any other Bina Loka Agreements), the terms of these Trading Rules shall prevail.
- Except where these Trading Rules express to the contrary, the Trading Rules shall be construed in accordance with, and governed by, the laws of the Republic of Indonesia.
- Bina Loka shall not be liable for anything done or omitted in accordance with these Trading Rules.
- Users declare that they have read, understood, comprehended, observed, agreed and accepted these Trading Rules.
- These Trading Rules is made in the Indonesian and English language.

You hereby declare that you have received and read these Trading Rules and understand and agree to its contents therein.

DISCLAIMER: Perdagangan bitcoin dan aset kripto memiliki peluang dan resiko yang tinggi. Pastikan Anda menggunakan pertimbangan yang matang dalam membuat keputusan jual dan beli aset Anda. Binaloka tidak memaksakan pengguna untuk melakukan transaksi jual beli dan semua keputusan jual beli aset uang digital Anda adalah keputusan Anda sendiri dan tidak dipengaruhi oleh pihak manapun.