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Gemini Singapore Disclosures

Last updated: October 4, 2023

Pursuant to our obligations under the Payment Services Act 2019 (as amended) and the Monetary Authority of Singapore’s guidelines for Digital Payment Token Service Providers (DPTSP) operating in Singapore and servicing Singapore customers, we are required to provide the following notifications to you regarding our obligations to you as a Gemini customer. None of the below change our relationship with you or alter any of your rights or privileges with respect to your accounts with Gemini or any transactions you conduct on the Gemini Exchange.

i. Your Use of Gemini’s Products and Services are Subject to Certain Terms and Conditions

The terms and conditions that apply to your relationship with Gemini are described in the linked Gemini User Agreement. This agreement is always available at the bottom of the Gemini.com homepage, under “Legal Agreements.”  The fees and costs associated with your use of the Gemini Exchange are similarly found on the Gemini.com homepage, under “Marketplace & Fees.” 

ii. Gemini Safeguards Your Assets at All Times

At all times, all of your assets held with Gemini, whether fiat currency or Digital Payment Tokens, are deposited in designated customer funds accounts exclusively for your benefit and segregated from Gemini’s own business, operating, and reserve accounts, are fully available for your withdrawal. We do not do anything with your fiat funds or your Digital Payment Tokens unless explicitly authorized and directed to do so by you. Further details describing Gemini’s adherence to and these obligations can be found on the Gemini Trust Center, which is updated on a daily basis.

iii. Your Assets May Be Commingled with Assets of Other Gemini Customers

The designated customer funds accounts in which your fiat currency and Digital Payment tokens are stored may contain the assets of other customers as well. The fiat currency and Digital Payment Tokens that are allocated to your Gemini account are maintained on the Gemini Exchange Ledger that is updated in real time, and is always visible to you on the Gemini webpage or in the Gemini app. The fact that your funds may be held in the same Gemini Exchange wallet as those of other Gemini users does not impact your ownership or control over those funds.

iv. Your Digital Payment Tokens Are Stored in both Hot Wallets and Cold Wallets

Your assets with Gemini are stored in both hot wallets, which are connected to the internet and allow for immediate access for trading and withdrawals, and cold wallets, which are off-line and secure against any online attacks. Gemini secures insurance to protect the Digital Payment Tokens in both hot wallets and cold wallets from theft or loss, and no more than 5% of our customers’ Digital Payment Tokens are kept in hot wallets. This does not change either your access to or your right to withdraw any or all of your assets at any time, nor does it change or impact Gemini’s obligations to fully safeguard all of your funds. 

v. Disposition of Your Assets in the Event of Gemini’s Bankruptcy

All of your Digital Payment Tokens are held in trust for your benefit by our New York incorporated entity, Gemini Trust Company, LLC. Gemini Trust Company, LLC, is a limited purpose trust company subject to New York Banking Law and supervised by the New York Department of Financial Services (the “DFS”). In the event that Gemini becomes insolvent, law and practice suggests that your Digital Payment Tokens would be returned back to a wallet under your control or transferred to another custodian to also be held in trust for your benefit, without being subject to claims from Gemini's creditors.
Please feel free to contact us should you have any questions or concerns about these disclosures.

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