Last updated: 23rd October 2025

These Terms of Business (Terms) are made between Private Crypto Management (PCM, we, us) and you. By clicking “I Agree”, creating an account with us, or using our services, you agree to be bound by these Terms.

1.1 By accessing or using our services you agree to these Terms. If you do not agree, do not use the services.
1.2 We may update these Terms from time to time by posting a notice on our website privatecryptomanagement.com (Website). Changes take effect when posted. Your continued use constitutes acceptance.
1.3 These Terms operate alongside our Website Terms of Use and Privacy Policy (together, the PCM Terms). If another written agreement between you and us expressly applies to a specific product or service, that agreement prevails for that subject matter.

2.1 PCM provides broking and advisory services that introduce and refer clients to regulated third-party exchanges, brokers, and managed funds (Third-Party Providers). We may also provide education, market commentary, and general information about digital assets.
2.2 We do not:
(a) execute trades for you or on your behalf;
(b) hold, control, or take possession of your fiat currency or digital assets; or
(c) operate an exchange, custodian, or wallet service.
2.3 All account opening, onboarding, KYC/AML checks, funding, trading, custody, redemptions and withdrawals occur directly between you and the relevant Third-Party Provider under that provider’s terms, policies, and fees.
2.4 Information we provide is general in nature and is not personal financial advice. We do not consider your objectives, financial situation, or needs. You should consider independent legal, tax and financial advice before acting.
2.5 If at any time we provide a service that is a financial service under the Corporations Act 2001 (Cth) (for example, an introduction that constitutes “arranging” a financial product), we will do so only where permitted by law and (if applicable) under the authorisation of the relevant AFSL holder. We will disclose those details to you before providing that service.

Account means any profile or details you register with us to receive introductions or communications (not a trading or custody account).
Digital Assets means cryptocurrencies, tokens or other digital representations of value.
Third-Party Provider has the meaning in clause 2.

4.1 The relationship between you and us is that of independent contractors. Nothing creates a fiduciary duty, partnership, joint venture or agency between you and us.
4.2 We may act as a referrer or introducing broker. We do not have authority to bind you or any Third-Party Provider.

5.1 You are solely responsible for: (a) selecting any Third-Party Provider; (b) reviewing and accepting their terms, fees and disclosures; (c) opening and maintaining your accounts; and (d) all decisions to acquire, hold or dispose of Digital Assets or interests in managed funds.
5.2 You warrant that any information you provide to us is true, accurate and complete and you will promptly update it if it changes.

6.1 You may ask us to introduce you to one or more Third-Party Providers or to pass your contact details to them. We may rely on instructions that appear to come from your registered email or phone.
6.2 We are not a party to and do not execute your transactions. Sending us a message about a desired trade does not constitute a trade instruction to a Third-Party Provider.

7.1 We are not a digital currency exchange and we do not perform trading or custody. However, we may collect limited identification details to facilitate referrals or to meet legal obligations (e.g., sanctions screening).
7.2 Primary KYC/AML verification is conducted by the relevant Third-Party Provider in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
7.3 We handle personal information in accordance with our Privacy Policy. By using our services, you consent to us sharing necessary information with Third-Party Providers to facilitate an introduction.

8.1 Third-Party Providers are independent of PCM. We do not control, endorse, or guarantee their systems, pricing, availability, performance, or compliance.
8.2 Their terms and fees apply to your relationship with them. You are responsible for reviewing those documents.
8.3 Referral fees/commissions. We may receive fees or other benefits from Third-Party Providers for referrals or introductions. By using our services, you consent to us receiving and retaining such benefits. We may disclose details on request and/or as required by law.
8.4 We may, acting reasonably, decline to introduce you to a provider or suggest alternatives.

9.1 Digital Assets are volatile and may result in partial or total loss of capital. Prices can change rapidly, markets may be illiquid, and technology and regulatory risks exist.
9.2 Past performance is not indicative of future results. You should carefully assess whether Digital Assets or managed funds are suitable for you and seek professional advice.

10.1 Our fees. We may charge you a fee for broking/advisory or education services, agreed with you in writing before we provide them.
10.2 Referral benefits. As per clause 8.3, we may receive fees/benefits from Third-Party Providers.
10.3 Taxes. You are responsible for all taxes arising from your activities and for making any required filings.

We do not accept deposits, hold client money or Digital Assets, operate wallets, or provide any trust/nominee or custodial service. Do not send fiat or Digital Assets to us. Any transfer instructions must be executed directly with the Third-Party Provider.

12.1 We may modify, suspend or discontinue any part of our services at any time.
12.2 We do not guarantee uninterrupted access to our Website or communications.

13.1 To the maximum extent permitted by law, PCM is not liable for any loss arising from or connected to:
(a) actions/omissions of any Third-Party Provider;
(b) market movements, outages, forks, airdrops, or protocol changes;
(c) reliance on general information or education we provide;
(d) cyber incidents or service interruptions outside our reasonable control.
13.2 Australian Consumer Law. Nothing in these Terms excludes any non-excludable guarantees or rights. Where permitted, our liability is limited to re-supply of services or the cost of re-supply.
13.3 Subject to non-excludable rights, our aggregate liability to you is limited to the fees you paid to us in the 12 months before the event giving rise to the claim. We are not liable for indirect, special, consequential or punitive loss, or loss of profits, revenue, goodwill or data.

14.1 You may terminate these Terms at any time by notifying us in writing.
14.2 We may suspend or terminate your access where required by law, to protect our systems or customers, or for a material breach of these Terms.
14.3 Termination does not affect accrued rights and obligations.

15.1 Governing law. These Terms are governed by the laws of Victoria, Australia. You submit to the non-exclusive jurisdiction of its courts.
15.2 Dispute resolution. Before starting proceedings, the parties will use reasonable efforts to resolve disputes through good-faith discussions.
15.3 Severability. If any provision is invalid, the remainder remains in force.
15.4 Notices. We may notify you via the Website, email or your registered contact details.