1. Introduction
By accessing www.trilliondigital.io (the "Website"), you agree to the Website Terms and Conditions. Additionally, by engaging Trillion Capital Markets Inc. ("Trillion Digital," "we," "us," or "our") for trading or liquidity services, you agree to be bound by these Terms of Service. These terms apply to Trillion Capital Markets Inc. only. Services provided by Trillion Capital Markets AG are subject to its separate Swiss Terms of Service.
Trillion Digital provides services exclusively to approved counterparties who have entered into a signed agreement (the "Master Trade Agreement"). Accessing the Website does not establish a counterparty relationship or imply the existence of a Master Trade Agreement.
Prior to becoming an approved counterparty, all parties must complete our onboarding process, including satisfactory completion of counterparty due diligence and Know Your Customer/Anti-Money Laundering ("KYC/AML") procedures. By accessing the Website and entering into transactions with Trillion Digital, you agree to be bound by these Terms of Service.
Trillion Digital is a global trading firm operating as a dealer, counterparty, and liquidity provider in digital asset markets where such activities are permissible. We engage in price discovery, price quoting, order taking, trade execution, and other related activities. Unless expressly agreed otherwise in writing, Trillion Digital acts as principal for its own account and does not serve as an agent, fiduciary, or financial advisor on behalf of clients or counterparties. As detailed in Section 4 (Conflicts of Interest), Trillion Digital and its counterparties may have divergent or conflicting interests.
These Terms of Service supplement any other applicable terms agreed between you and Trillion Digital, as well as any laws or regulations governing our trading activities. Interactions with Trillion Digital will be based on these terms unless expressly agreed otherwise (i) between you and Trillion Digital, (ii) provided in other applicable Trillion Digital terms of dealing, or (iii) required by law or regulation. These Terms of Service may be updated periodically to reflect regulatory, industry, or other developments.
Nothing in this document constitutes an offer to sell, a solicitation to buy, or a recommendation of any products or services described herein in jurisdictions where such activities are prohibited.
2. Intended Audience
Services are offered only to approved counterparties that are high-net-worth individuals, qualified institutional buyers or well-capitalized companies, each acting for business or investment purposes. Services are not offered to retail customers or for personal, family or household purposes.
By accepting these Terms of Service, you confirm that you fall within these client categories and possess sufficient experience and understanding of the transactions and services provided to assess their suitability and associated risks. Prospective counterparties should consult their legal, accounting, or financial advisors before engaging in transactions or services described herein.
3. No Investment Advice
Unless expressly agreed otherwise in writing, Trillion Digital does not provide investment advice. All counterparties are responsible for making their own investment decisions and for understanding the risks associated with trading digital assets.
4. Conflicts of Interest
Unless explicitly agreed otherwise, Trillion Digital acts as principal in transactions with counterparties and does not act as an agent. As a liquidity provider, we manage a portfolio of positions for multiple counterparties with competing interests and engage in proprietary trading activities.
Trillion Digital may trade prior to or alongside counterparty transactions to manage risk, source liquidity, or facilitate order execution. These activities may include entering into pre-hedging transactions executed before, during, or after the pricing or execution of related transactions. While these activities are intended to facilitate counterparty transactions and manage risk, they may impact pricing and liquidity.
We maintain policies and procedures designed to manage potential conflicts of interest, ensuring that counterparties are treated fairly and that transactions are executed in accordance with agreed terms.
5. Best Execution and Order Internalization
Digital assets are subject to significant price volatility and lack a centralized pricing authority. Trillion Digital determines transaction pricing at its sole discretion, taking into account market conditions and other relevant factors. We do not guarantee that our prices represent the best available price in the market.
When appropriate, Trillion Digital may execute transactions by crossing counterparty orders with internal orders or with orders from other counterparties on an over-the-counter basis. Such transactions will be priced fairly and in accordance with the terms agreed upon with the counterparties.
6. No Offer of Securities
This document and the information contained herein are provided for informational purposes only and do not constitute an offer to sell or a solicitation to buy any securities or other financial instruments.
7. Risks Associated with Digital Assets
Trading digital assets involves significant risks, including the potential for substantial financial loss. Prices can be highly volatile and may fluctuate dramatically within short periods. Trading digital assets may not be suitable for all investors. You are encouraged to fully educate yourself about the risks associated with digital assets and to consider your own financial circumstances before engaging in such transactions.
For additional information, read our Risks & Disclosures, Licenses, and Complaints pages.
8. Amendments
Amendments will be posted on the Website. We will give active clients at least 30 days’ advance notice by email before material changes take effect. The notice will describe the material changes and their effective date. The signed Master Trade Agreement prevails in the event of any conflict with these Terms of Service. Posting changes to these Terms does not amend the signed Master Trade Agreement; amendments to that agreement follow its own provisions.
Change history
- January 1, 2025 — Original effective date.
- September 9, 2026 — Clarified the U.S. contracting entity and linked separate Swiss terms.
- October 9, 2026 — Clarified client eligibility and the retail exclusion, and added material-change notice, agreement precedence, and complaint and disclosure links.
Contact Information
For any questions regarding these Terms of Service, please contact us at compliance@trilliondigital.io.
For complaints and escalation details, see Complaints. You can also review our Risks & Disclosures and Licenses.