Home Page / 7/24 Support

Our Priority is always For our customers

PayeCards has hundreds of full-time, dedicated Customer Support  specialists who are knowledgeable of crypto and financial services, as well as trained on our products and services.

 

PayeCards support team we are active in supporting your problems 24/7 with a multi-language  support team that dominates the global market audience and experience.

 

If you’re awake, we are too. When you need help with your account, our team of experts will work directly with you via our 24/7 live chat to reach a quick and efficient resolution.

Home Page / Account Management

Upgraded support for advanced traders

Our mission at PayeCards is to provide an exceptional cryptocurrency exchange experience for all of our clients. In service of that, our always-on live chat and extensive Help Center resolve issues efficiently around the clock.

For advanced traders, we offer an exclusive additional layer of near real-time, hyper-personalized support through our PayeCards Account Management program.

Next level trading deserves next level service Clients who consistently trade on our platform will be assigned their own personal account representative. As your main point of contact at PayeCards, your account manager personally handles your questions and requests, ensuring you can focus on trading, not dealing with headaches.

Home Page / About Us

Who is PayeCards ?

Payecards is a trusted provider for instant, secure, and simple payment solutions

Our solution integrated with all Crypto Currency with real flat currency , include banking ,exchange , buy/sell crypto , sent instant money any time and any country and more than better digital bank solution

When we launched , we thinked new technology than all world real bank for better solution and better rate for all exchange , new trend crypto integrated all our solution , Future will be come for finance industry at Payecards , Our platform has become one of the most reliable and trusted e-wallets and digital bank used globally , Our highly sought after range of solutions continue to grow and evolve due to the needs of our diverse , international consumer and business customer base,

If you would like to find out more about which PayeCards entity you receive services from, or if you have any other questions, please reach out to us via the in-dashboard ticket in the PayeCards account., welcome@payecards.com
legal@payecards.com
finance@payecards.com
merchant@payecards.com
developer@payecards.com

Home Page / Solutions

E-WALLET

PayeCards new tecnology than all world real bank for better solution and better rate for all exchange, new trend cyrpto integrated all our solution , Future will be come for finance industry at Payecards, Our platform has become one of the most reliable and trusted e-wallets and digital bank used globally, Our highly sought after range of solutions continue to grow and evolve due to the needs of our diverse, international consumer and business customer base.

Multi-Currency wallets

Fund your account and make payments using the 25+ fiat currency and 40+ crypto currency

Crypto Exchange

PayeCards is of the best places to buy and sell crypto online, thanks to our excellent service, low fees, versatile funding options and rigorous security standards

Transfer to 160+ Countries WorldWide

Transfer to 160+ Countries WorldWide

High-Security Wallet

Your card transactions are protected by MasterCard SecureCode and Verified by VISA. We apply PCI DSS Level 1 security standards to process your personal data. Your private key is safely stored and fully restorable thanks to customer verification. Cryptocurrency is stored in safe offline wallets.

Friendly Interface

Simple and intuitive app to mana- ge your transactions in a few taps.

Know Your Customer

Verification takes no longer than 15 minutes.

Support 24/7

Dedicated multi-language support.

PAYE PLASTIC CARD

The prepaid card you can use anywhere anytime

PAYE CRYPTO EXCHANGE

Lower Maker Fees

Attractive to the most powerful trading makers, creating high liquidity while also saving trade costs and improving trade efficiency.

Advanced PayeCards API

PayeCard's APIs are designed to offer an easy and efficient way to develop secure and programmatic trading strategy.

Reliable Security Solutions

Multiple security mechanisms to protect user information and funds are our first priority, e.g SMS authentication and device trust syste

Excellent Customer Support

Our support team is available 24 hours a day to assist you with any issues or questions you may have

Financial SPA for Your Business

Payment services offered by Payecards completely simplify financial management of any online and offline business.

All you need is just basic document pack-age fort he company and applicant,the person who will manage Payecards account to comply with Anti-Money Laundering (AML) and Know Your Customer(KYC) international requirements.

Payecards is an ideal solution for cross-border payments and global payouts to bank account, e-currencies and credit/debit cards at very low fees.

BUY BITCOIN WITH VISA, MASTERCARD
OR ANY OTHER CARDS

Buy with Debit and Credit Cards

Use a debit or credit card in any currency. All transactions are protected with the 3D Secure technology, so you can rest easy

Use CryptoCurrency Right Away

The coins are credited to your account immediately after the purchase. Leverage the exchange and take advantage of the zero withdrawal fee

Simple Verification

One document is all you need and you’re ready to buy. No more unnecessary hurdles that get in between you and your cryptocurrency

Transparency in Fees

No hidden fees tacked on the end of each transaction, what you see is what you get. We charge a one-time fee of more less that’s it

Everything in One Secure Place

There’s no need for you to transfer your money to another wallet. With PayeCards, you can buy, exchange, send, and store your money, all in one place

Assistance at Every Step

Our team of qualified specialists is ready to help you every step of the way. If you run into any problems or just have some questions you always receive a prompt response

Easy-to-follow process

Create Account

Upload Your Id

Buy Bitcoins

Paye Global Money Transfer

Transfer money online to over 70 countries around the world for only low fees

*Free transfers to bank accounts in the selected countries

Instant transfers

Safe and Secure

You Send From USD

189.25

165.86

They Recieve in EUR

189.25

165.86

Deliver To

Bank Account

Pay With

Credit Card

Debit Card

Fee

0.00 TRY

Total Pay

1000.00 TRY

Get Started

PayeCard Benefits

Global Coverage

We are delivering money into 70 countries and regularly opening new countries

Fixed Fee +
Best Exchange Rate

We display the FX rate, the transfer fee and the amount they will receive, before you make a transfer

Instant Delivery

All transfers are processed by PayeCards within seconds

Bank Level Security

All money transfers are certified by Visa, MasterCard, China Union Pay, FCA (Financial Conduct Authority UK) and are PCI DSS certified

Information Required - Minimal

Only the card number and receiver's name are rquired for the transfer

24/7 Customer Support

We are always there for you, day or night

Paye Voucher

Paye Card is the safest and most efective medhod to make online payments

Deposits & withdrawals

Pay and withdraw money in the blink of an eye. Let our completely transactional payment platform impress you.

DEPOSIT NOW

100% Safe

Strong encryption, authentication and privacy, end-to-end, not only to use resplendent beautiful word phrases, but worthy of your trust

REGISTER NOW

Flexsible & Limit

Completely flexible and smooth. AstroPay Card makes payment as easy as possible

DEPOSIT NOW

Home Page / Fee Schedule

Home Page / Cards

Paye Cards

Fast, easy, minimal fees

Plastic and virtual cards in a selection of currencies. Pay easily all over the world.

Open an account in minutes

With our prepaid cards you can spend your money how you want, at millions of locations worldwide. Whether you use it to help you budget, shop securely or for foreign travel, it’s free and quick to apply for with no credit checks.*

The prepaid card you can use anywhere anytime

Quick and easy to apply

Get your one-use Paye-Card through your PayeAccount and use it immediately

Worlwide acceptence

Use worldwide online and over the phone

Versatile

Available in 3 different currencies – € Euro, £ GBP and $ USD

Convenient

Home Page / Security

Privacy Policy

1. PREAMBLE

Valuing Customers’ trust and understanding the importance of ensuring the confidentiality of Customers’ Personal Data, as well as that of the Informational Materials posted by Customers on the Website in the course of fulfilling the provisions of the Terms and Conditions, the Administrator puts into effect this Policy to define the order for performing operations involving the Parties’ Confidential Information when using the Website and the System’s Services.

Every Customer should be familiar with the terms of this Policy before starting to use the System's Services.

The Privacy Policy was last updated on: March 8th, 2017 

2. DEFINITIONS OF TERMS

Unless it is otherwise explicitly stated in or follows from the main text of the Terms and Conditions, the following words and phrases shall be used in the meanings as specified below:

2.1.  Cookie  is a piece of Data that does not contain any Personal Data, which is created by the Website and stored on the Customer’s computer as one file or multiple files. If the Customer chooses to block a Cookie file, the Customer may experience difficulty or find it impossible to use the Website.

2.2.  Informational Materials   (Data)  are any text, graphic, audio, video, and mixed-type materials of informational nature.

2.3.  Confidential Information  is any information that is not Public Data, which is considered confidential under the Parties’ agreement or in accordance with the applicable laws.

2.4.  Confidentiality  is accessibility of information solely to its owner, as well as any parties to which such information can and/or must be provided under law and/or under agreement with this party.

2.5.  Public Data  is any data (including Personal Data) to which the owner of such data provides access to an unlimited number of parties (including by means of publishing data on any website without restricting access to such data) or to which, in accordance with this Appendix and/or the effective laws, confidentiality requirements do not apply.

2.6.  Personal Data  is any information related, directly or indirectly, to a specific or identifiable individual person (the subject of personal data).

2.7.  Receiving Party  is the Party receiving Confidential Information.

2.8.  Compromise of Confidential Information  is one of the Parties’ actions or inaction resulting in the Confidential Information becoming known or available to third parties without the permission of the owner of such confidential information. The format of the information compromise (orally, in writing, via any technical devices, etc.) is immaterial.

2.9.  Disclosing Party  is a Member, in relation to the Confidential Information disclosed by the Administrator; and, it is the Administrator, in relation to the Confidential Information disclosed by a Member.

2.10.  Disclosure of Confidential Information  is transfer to any third party of any Confidential Information in compliance with the requirements of this Appendix, including leaking, stealing, losing, distorting, corrupting, destroying, modifying, copying, or blocking Confidential Information resulting from failure to comply or improper compliance with the terms of this Appendix by the Receiving Party.

2.11. The terms that are not defined in this section shall be used further in the text in the meanings as specified (in the order of priority) in bilateral agreements signed by the Parties and in the current version of the Terms and Conditions approved by the Administrator and all Appendixes thereto.

3. GENERAL PROVISIONS

3.1. By using any part of the Website and/or the Services, the Customer gives the Administrator the right to receive, store, process, and use the Customer’s Personal Data and other Informational Materials in compliance with the terms of this Appendix.

3.2. This Appendix does not apply to, nor is the Administrator responsible for, any methods of receiving, storing, processing, using, and disclosing the Customer’s Personal Data and other Informational Materials by external companies and organizations that are not owned or managed by the Administrator and by individuals that are not the Administrator’s employees, even though the Customer may obtain access to such parties’ and persons’ websites, software and/or GWS via the Website.

3.3. The main purpose of receiving, storing, processing, and using the Customer’s Personal Data, Public Data, and other data is to protect the Customer’s interests, as well as to improve the quality of the personalized and general services provided by the Administrator to the Customer.

3.4. This Policy is not an independent document and serves only as an addition to the Terms and Conditions; it does not supersede or nullify any of the provisions included in the main text of the Terms and Conditions, in particular, Sections 10-14 of the Terms and Conditions related to the subject of this Policy.

3.5. The provisions contained in this document and the term ‘Confidential Information’ shall not apply to the information that:

3.5.1. was, is or is made available to the Receiving Party on the non-confidential basis from a party that, to the Receiving Party’s knowledge, is not bound by any confidentiality agreement with the other Party or by any other restriction related to disclosing confidential information to the Receiving Party, or

3.5.2. was in lawful possession of the Receiving Party prior to the other Party’s disclosing it as Confidential Information, or

3.5.3. is developed by or for the Receiving Party;

3.5.4. is not in any way protected by the Disclosing Party to ensure confidentiality;

3.5.5. is made available due to the requirements of the effective laws and regulations;

3.5.6. is publicly available and known due to the Disclosing Party’s actions and decisions;

3.5.7. was available to the Receiving Party on the non-confidential basis prior to the other Party’s disclosing such information, or

3.5.8. has to be disclosed in accordance with the effective laws or under orders issued by the governmental agencies or any other competent authorities.

4. COLLECTION OF INFORMATION

4.1. The Administrator can gather and process the following information about the Customer:

• Customer’s full first name and last name, occupation, address, email address, phone number, date of birth, bank or payment card details, as well as the documents confirming the Customer’s identity and residence address, to be provided on our request;

• information related to the Transactions performed by the Customer through the System with the use of the Wallet and to the execution of the Customer’s Orders;

4.2. For the purpose of fulfilling mandatory legal obligations related to anti-fraud and anti-money laundering requirements, the Administrator will receive information related to the Customer from third parties, including information about the Customer’s financial history, any decisions of local district courts, bankruptcy, information provided by credit bureaus and anti-fraud agencies, when the Customer opens a Wallet or at any other time when the Administrator may deem it necessary to prevent fraud and minimize financial risks. More detailed information can be found in Appendix 02 to these Terms and Conditions.

4.3. During the Customer’s Registration in the System and when the Customer is creating a Wallet, the Customer has to provide their Authorization Data, as well as other details (mandatory or optional). After the Customer has created and used their Wallet, the Administrator is able to identify the Customer every time this Customer uses the System and visits the Website.

4.4. The Administrator may install cookies to Customers’ computers (unless the Customer purposely restricts this option in their browser), as well as receive, store, process, and use the information created through cookies.

4.5. When the Customer visits the Website, the Administrator automatically stores, processes, and uses the Customer’s data that is not their Personal Data, for example: Customer’s IP address, Customer’s location identifiable with their IP address, Customer’s computer’s technical parameters, presence or absence of specific software on the Customer’s computer, such software’s settings, cookies, as well as statistics on the Customer’s activities.

4.6. Besides visiting the Website, the Customer also provides information to the Administrator when using the System (if possible) via applications for mobile devices, social media applications, payment terminals, etc., contacting and submitting requests by phone, mail, email, or via other means of communication; the Administrator also receives information about the Customer from other sources when verifying the information previously provided by the Customer.

5. USE OF INFORMATION

The Administrator shall use the available information related to Customers for the following purposes:

• rendering services related to Customers’ Wallets and providing services requested by Customers;

• executing Customers’ Orders related to Money Transfers and receiving Payments, as well as making Transactions using the Services;

• notifying Customers of changes in the Services, the System, the Terms and Conditions, the Software, etc.;

• fulfilling the requirements of the applicable laws and regulations, in particular, those related to anti-money laundering laws and KYC (Know Your Customer) procedures;

• verifying the Customer’s financial status, identity, and sol;

• carrying out verification procedures to prevent fraud and money laundering;

• providing services to Customers, including responding to Customers’ questions, requests, comments, and Complaints;

• increasing the security of the Services;

• providing the Website’s content (including its interactive features) in a way that is most efficient for Customers and their computers;

• providing to Customers products and services requested, or products and services that the Administrator believes may interest Customers;

• providing assistance in the development, provision, and improvement of the System’s Services, as well as providing the Website’s content and informing Customers;

• carrying out the Administrator’s internal procedures and processes, such as audits, analytical data processing, quality assessment as to the Services provided, etc.

6. DISCLOSURE OF INFORMATION

6.1. The Administrator shall not provide any Personal Data to any third parties for commercial purposes without the permission of the Customer to whom this information is related.

6.2. Personal Data can be disclosed to such third parties in the following circumstances:

• disclosing information upon receiving the permission of the Customer to whom this information is related;

• disclosing information on substantiated requests from the government agencies with the authority to obtain such information;

• disclosing information to agents and third parties acting under an agreement with the Administrator to fulfill obligations to the Customer (including, but not limited to, acquirers, payment card issuing banks, international card systems, telecommunication service providers, billing companies and delivery companies, the Administrator’s affiliated parties, etc.) and on the following conditions: 1) they are aware of the confidential nature of such information; 2) they take adequate measures to protect confidential information from unauthorized access and use;

• disclosing information to the Administrator’s potential creditors, investors, acquirers, Partners, shareholders, and auditors;

• disclosing information to companies that may offer their products and services to Customers;

• disclosing information in the course of information exchange with other companies and organizations for the purposes of anti-fraud protection and financial risk minimization;

• disclosing information when the Administrator believes that the Customer violates the terms of this Appendix and/or other agreements and contracts between the Administrator and the Customer, and/or the Administrator’s internal regulations and rules; or, when the Administrator deems such information disclosure necessary to investigate, prevent, or take measures against unlawful activities, suspected fraudulent activities, potential threats to any person’s physical security, violations of the Terms and Conditions or any bilateral agreements, or if it is required by law;

• disclosing information in other circumstances in accordance with the provisions of these Terms and Conditions and the applicable laws.

6.3. Unless otherwise agreed upon in writing with a specific Customer, the Administrator can publicly disclose the fact of the existence of the Administrator’s business relationship with this Customer.

6.4. The Administrator reserves the right to disclose confidential information when it is required by the business conduct practices.

6.5 No provision contained in this Appendix shall restrict either Party’s right to disclose any Confidential Information in accordance with any court order or decision, any other legitimate obligation or requirement under the effective laws and regulations if such information disclosure is mandatory and on the condition that, if possible, the other Party is notified of such information disclosure in advance.

6.6. All Confidential Information shall remain the property of the Party disclosing such information; no rights or licenses are granted with regard to such Confidential Information, unless otherwise specifically stipulated in this Appendix.

6.7. Either Party shall return to the other Party and/or securely destroy all Confidential Information (including any part of it that may be undergoing processing, analysis, or translation, including also all copies, written notes, drawings, charts, computer programs in any and all formats, on any type of a data storage device) on the other Party’s written request, unless such documents have to be stored under the effective laws and regulations, and, if required, shall confirm in writing, with the authorized person’s signature, that such Confidential Information was duly returned or securely destroyed.

6.8. The Customer has the right to request that the Administrator restrict third parties’ access to the Customer’s Personal Data for marketing purposes, provided that it does not contradict the applicable laws and the Terms and Conditions, by sending a relevant written request to the Administrator using the Administrator’s Contact Details.

7. PROCESSING OF INFORMATION

7.1. By providing their Personal Data during the Registration in the System, the Customer agrees to data processing, with or without the use of automation technology and/or devices, in particular, information gathering, storage, transfer to third parties, and use by the Administrator for the purpose of providing the Services to the Customer and for other purposes specified in the Terms and Conditions.

7.2. If the Customer does not wish for their Personal Data to be processed, the Customer should contact the Administrator using the Administrator’s Contact Details or the feedback form on the Website. In this case, all the information received from the Customer will be deleted from the Administrator’s client database, and the Customer will not be able to use the Services.

8. ACCESS TO INFORMATION

8.1. For the purpose of exercising Customers’ rights and the Administrator’s proper fulfillment of its obligations under the Terms and Conditions and the agreements signed by the Parties, the Administrator may review Customers’ Informational Materials (for the purpose of timely resolution of technical problems and prevention of unlawful activities that violate the rights of either Party, other Customers, etc.).

8.2. The Administrator provides limited access to Customers’ information only to the employees that, in the Administrator’s opinion, need to use such information to provide services to the Customers or perform their professional duties.

8.3. The Customer has the right to request, edit, or delete their Personal Data stored by the Administrator and/or on the Website. The Customer may independently edit, change, or delete their Personal Data using the relevant features of the Website and their Wallet.

8.4. The applicable laws on personal data protection give the Customer the right of access to any information related to the Customer. Any request for access to information may result in charges to cover any and all expenses involved in providing the Customer with detailed information stored by the Administrator and/or third parties.

9. SENDING MESSAGES TO PUBLICLY ACCESSIBLE PAGES

9.1. A publicly accessible page is any page of the Website to which unlimited access is open to any party and which can be indexed by search engine systems.

9.2. The Administrator allows the Customers to send messages and exchange Data on publicly accessible pages.

9.3. The Customer should exercise caution and common sense when disclosing their information that allows identifying the Customer on publicly accessible pages. It is important to remember that this information may remain on publicly accessible pages of the Website for an indefinite period of time. Besides, depending on a specific Service, other Customers may also view such information.

9.4. The Customer is solely responsible for any information that the Customer discloses and distributes on publicly accessible pages.

9.5. If the Customer has any concerns regarding information that allows identifying the Customer which the Customer provided on any publicly accessible page, the Customer cannot delete or edit such information; in such cases, the Customer should contact the Customer Support Service.

10. PROTECTION OF INFORMATION

10.1. The Parties acknowledge and confirm that they shall ensure confidentiality of any and all information received in the course of fulfilling obligations under the Terms and Conditions, with the exception of the cases explicitly provided for in the Terms and Conditions and the Parties’ other agreements.

10.2. The Customer violating the obligations pertaining to information confidentiality shall cover all expenses and losses (including loss of profits) incurred by any third parties and/or the Administrator as a result of such actions of the part of this Customer.

10.4. The confidentiality terms are included in these Terms and Conditions and accepted by the Customer when the Customer confirms accepting the Terms and Conditions.

10.5. The Parties shall NOT disclose information pertaining to the System’s operating conditions, as well as other information received by the Parties in the course of fulfilling the obligations under the Terms and Conditions, with the exception of the cases when either Party is obligated to disclose such information in accordance with the applicable laws.

10.6. The Parties shall notify each other within 1 (one) business day of the occurrence or knowledge that they may have about any disclosure or threat of disclosure, unlawful obtainment or unlawful use of the Confidential Information by any third parties.

10.7. The Parties shall not unilaterally suspend or terminate measures aimed at protecting confidential information as specified in these Terms and Conditions, including in cases of their reorganization (merger, acquisition, division, separation, transformation, or any other type of the legal status change) or (when stipulated by the law) liquidation.

10.9. Disclosing Confidential Information on legally valid requests from law enforcement agencies or other competent government authorities and/or officials in accordance with procedures specified by the applicable laws shall not constitute a violation of the Parties’ confidentiality obligations.

10.10. In the event of disclosing Confidential Information to the authorities and/or parties stated above, the Party disclosing Confidential Information shall notify the owner of such Confidential Information in writing of the fact of information disclosure, as well as of the content of such information and the name of the agency or authority to which such Confidential Information was disclosed within 1 (one) business day after disclosing Confidential Information.

10.11. As stipulated in other sections of these Terms and Conditions, Customers are responsible for ensuring confidentiality of their Authentication Data. The Administrator is not responsible for transactions made as a result of improper storage or loss of information on the part of the Customer.

11. MISCELLANEOUS PROVISIONS

11.1. The Administrator has the right to store the Customer’s Personal Data and other data for as long as it is necessary to achieve the objective specified in this Appendix, or for a period of time required by the applicable laws, or until the Customer chooses to delete such data.

11.2. The Customer is responsible for providing accurate and true information, as well as for updating their information provided previously in the event of any changes in the information.

11.3. The Customer allows the Administrator to give permission to other parties with which the Administrator signs relevant agreements to receive, store, and process information about the Customer (except the Customer’s Personal Data and Informational Materials), such as the Customer’s IP address, cookies, and statistics on the Customer’s activities, for the purpose of improving the quality of the services provided by such parties and providing promotional information.

11.4. The Customer agrees that the confidentiality of any information transferred via the Internet is not guaranteed; if any third party gains access to such information outside the technical communication means area managed by the Administrator, the latter shall bear no responsibility for any possible damages caused by such access to information.

11.5. If, in the course of using the Website and/or the System, any information becomes available to the Customer regarding the Administrator and/or any third parties, which, in accordance with the applicable laws, constitutes confidential information and/or trade secrets, the Customer shall not store, use, or distribute such information.

11.6. When you click links on our Website, you may be redirected to third party sites. We do not assume any responsibility for content of third party Sites and for the information third party Sites collect from you, including the ways these third party Sites process, store, and manage such information. Third party service providers may have their own Privacy Policies. We strongly recommend that you familiarise yourself with these Policies to understand how your personal information is handled. Once you leave our Website, the terms of this Privacy Policy no longer define how your personal information may be collected and managed.

Home Page / KYC - AML Policy

KYC Compliance Procedure

Know Your Customer policy has become increasingly important worldwide, especially among banks and financial institutions in order to prevent identity theft, money laundering and financial fraud. Clients both Individuals and Non- Individuals need to complete the KYC application form. PayeCards Global LTD holds a zero-tolerance fraud policy and is taking all measures possible to prevent it. Any fraudulent activity will be documented and all related accounts to it will be immediately closed. All funds in these accounts will be forfeited.

This is a one-time, free of cost exercise to enable Clients to comply with onboarding with the KYC Procedure. The list of documents to be submitted for the KYC procedure is given below:

1. ID proof:

   1. National ID Card with photo, or

   2. National Passport with photo

2. Address proof:

   1. Bank Statement, or

   2. Government Tax Return, or

   3. Utility Bill

 

Who all need to be KYC Compliant?

 

1. Any individual(s) or non-individual(s)

2. Guardian transacting on behalf of minor

3. Constituted as Power of Attorney (POA) holder(s), in case of investments through POA

4. If an individual becomes a Client due to an operation of law, e.g., transmission of units upon death of a Client, the claimant / person(s) entering the Register of unit holders of the Fund will be required to be KYC compliant before such transfer can take place.

KYC (Know Your Customer) checks are done for all new customers on-boarded at a PayeCards Global LTD and for existing customers on a periodic basis, as the profile of the customer and the risk associated could change based on the activities of the customer. PayeCards Global LTD will perform this exercise once annually for high risk customers.

Customer Due Diligence

 

Customer Due Diligence (CDD) is a critical element of effectively managing your risks and protecting yourself against criminals, terrorists, and Politically Exposed Persons (PEPs) who might present a risk. There are three levels of due diligence:

1. Simplified Due Diligence (“SDD”) are situations where the risk for money laundering or terrorist funding is low and a full CDD is not necessary. For example, low value accounts or accounts.

2. Basic Customer Due Diligence (“CDD”) is information obtained for all customers to verify the identity of a customer and asses the risks associated with that customer.

3. Enhanced Due Diligence (“EDD”) is additional information collected for any account that exceeds 50,000 EUR. EDD provides a deeper understanding of customer activity to mitigate associated risks. In the end, while some EDD factors are specifically enshrined in a country’s legislations, it’s up to a financial institution to determine their risk and take measures to ensure that their customers are not bad actors. EDD is additional KYC process to be followed, until further notice we will be locking each customer down to €500 per day in the first instance, whilst we build an internal risk profile on each client.
   

PayeCards Global LTD supports clients in the fields of KYC/CDD/EDD by performing the following activities based on the Risk level of the customer.

1. Customer Due diligence (CDD)

2. OFAC/Sanction Checks & Credit Checks

3. Customer Identification Program (CIP)

4. Enhanced Due diligence (EDD)

5. Politically Exposed Person (PEP) Checks

6. Probabilistic & Deterministic algorithm m implementation for various name checks

7. Setting up a Watchlist that is continuously updated against various sanctions and non- sanctions databases like PEPs, SDNs, OFAC Sanctions etc

8. Defining and implementing a name matching tolerance process

9. Setting up exclusion criteria for the rules and scenarios implemented

10. Through our 3^rd party KYC and anti-fraud provider we check our users through the following lists:

    1. Office of Foreign Assets Control (‘OFAC’)

    2. European Union (‘EU’) Sanctions

    3. United Nations (‘UN’) Sanctions

    4. Her Majesty Treasury (‘HMT’) Sanctions Prohibited Countries and Industries

With and ever evolving world and technology and embargos changing rapidly the company will follow advice from the lists below:

https://www.gov.uk/guidance/current-arms-embargoes-and-other-restrictions  https://data.gov.uk/dataset/a424169b-a2c9-4809-9ccd-a68411e5cf51/consolidated-list-of-financial-sanctions-targets

 

Anti-Money Laundering Policy

Policy on Anti-Money Laundering and combating the Financing of Criminal or Terrorist Acts

 

PART I – GENERAL

Introduction

 

1. This Policy on Anti-Money Laundering and combating the Financing of Criminal or Terrorist Acts (“AML Policy” or this “Policy”) is adopted by PayeCards Global LTD, a company incorporated under the laws of England a, registry code 12932019, 91 Battersea Park Road, London, England, SW8 4DU, (the “Company” or “PayeCards Global LTD”), as of the date written above, to be executed and observed by the Company, its employees, affiliates and service providers.

 

The Company is committed to implement effective controls for the detection and prevention of illicit activities, which may be executed using its services, and to allocate substantial efforts and resources for that end.

 

We at PayeCards Global LTD believe that the adoption and adherence to this Policy will embed a compliance culture throughout the Company, provide solid and effective controls, and demonstrate that PayeCards Global LTD has committed itself and its resources to maintain and support the principles laid out within this Policy to uphold the Company’s integrity, both internally and externally.

 

This Policy was written and adopted under the understanding that, as noted by authorities and organisations worldwide, the field of cryptographic assets, in which the Company is engaged, has an inherent level of risks of money laundering and terrorism financing (“ML/TF”). As such, this Policy includes, in addition to the procedures required under applicable laws, specific mechanisms and procedures aimed at mitigating such unique risks related to payment platforms.

 

2. Framework

The Company is a provider of Neobank services, holding an Electronic Sub White Label Money Institution License (EMI).

Licensed financial activities providers are subject to AML and KYC (Know Your Client) requirements, set forth in the England Money Laundering and Terrorist Financing Prevention Act which came into force on 26 January 2020. This Policy should be read in conjunction with these Instruments, in any conflict between the contents of this Policy and said Instruments, the latter shall prevail.

All sums denominated in this Policy in Euros shall be read to include the equivalent amounts in any other currency or digital currency, as traded at the date of the relevant transaction.

3. AML/CTF Policy

This Policy aims to provide specific instructions on how personnel of the Company should perform actions, mandate internal procedures, and provide general guidelines for the instruction, control and training within the Company and its affiliates, in connection with the mitigation and handling of ML/TF risks.

This Policy shall act as binding guidelines to all relevant Company personnel, and all such personnel must be aware of, and adhere to, this Policy.

This Policy aims to present the Company’s AML and KYC procedures:

 

1. The Company’s risk appetite;

2. The criteria which are used to asses risk levels of business relationships and transactions;

3. The criteria which are used to identify increased risk transactions;

4. The essential features of transaction monitoring;

5. The cases in which the Compliance Officer and Management Board shall be involved;

6. The cases in which the designated Company personnel must report to the England Financial Intelligence Unit;

7. Providing AML training to relevant Company employees;

8. The Company’s policy regarding politically exposed persons;

9. The methods which the Company’s personnel uses to identify, limit and monitor increased risks;

10. AML and KYC documents retention periods. 4

.Responsibilities under this policy

 

1. Management Board

The Company’s board of directors, which is the most senior body of management of the Company (the “Board”), shall bear the ultimate responsibility for the execution of the procedures under this Policy, and for amending it as necessary.

Member of the Board, as appointed by relevant Board decision, shall oversee the implementation of this policy, according to the AML/CTF requirements of the Instruments mentioned above (the “AML Board Member”).

In addition to any other duty under this Policy, the Board shall be responsible for the following:

 

1. Risk Appetite

 

The Board shall establish the total ML/TF risks exposure level and types that the Company is prepared to assume in pursuing its business objectives (“Risk Appetite”).

2. Annual Compliance Review

The Board shall convene on an annual basis to review and assess the effectiveness of this Policy, the procedures taken under it, and the efficiency of the Compliance Function (as defined below) in general.

3. Supervision of AML Personnel

 

The Board shall be responsible to supervise the Compliance Officer and other office holders listed below and shall have the authority and responsibility for their appointment, removal and replacement.

2. Compliance Officer

The Board shall appoint a company official to head the Company’s AML efforts, who shall be responsible for the effectiveness, adherence and compliance of this Policy, and serve as contact person between the Company and the England Financial Intelligence Unit (the “Compliance Officer”).

The Compliance Officer must be a qualified person, who has the education, professional suitability, abilities, personal qualities, experience and impeccable reputation required for the performance of these duties.

In addition to any other duty under this Policy, the Compliance Officer has the following responsibilities:

 

1. To ensure compliance with all duties under all applicable laws and regulations;

2. To plan, supervise and document the ongoing basic and advanced training of all relevant personnel (Training Officer).

 

3. To prepare, and subject to the Board’s approval, any modification to this Policy.

4. To act as contact to the England Financial Intelligence Unit and the authorities.

5. To review possible ML/TF aspects of the development of new products or business practices, or from the use of new or enhanced technologies, assess their effect on the Foundation and provide recommendations to management.

6. To prepare, and periodically review and update, the Risk Analysis.

7. To present the Board the update on risks and controls.
   

8. To submit Suspicious Activity Reports to the AML authorities.

9. To prepare amendment to this Policy, when needed, and to present it to the Board for adoption.

3. Compliance Function

The compliance function is a department within the Foundation responsible for the implementation of this Policy and the mitigation of ML/TF risks in general, in its ongoing work process (the “Compliance Function”), subject to the direct supervision of the AML Officer. The responsibilities of the Compliance Function shall include the following:

1. Executing AML related ongoing controls, including onboarding and ongoing customers activities;

2. Advisory to senior management and business teams, covering current and expected level of Financial Crime risks.

 

3. Implementation of this Policy and procedures cross the operational activities, verifying these procedures are up to date and aligned with the most updated regulation;

4. Direct report to the Compliance Officer;

5. Supporting the compliance culture of the foundation, including training materials and training programs to employees in accordance with the risk exposure of their role;

6. Implementation of Sanctions screening methods and alerts investigations;

7. Supporting the governance activities and preparing the relevant Management Information to senior management to ensure appropriate decision- making process;

8. Responsible for engagement with local regulators upon need; and

9. Supporting law enforcement enquiries and ensuring the relevant and accurate information is provided.

PART II – KYC PROCESS

Each person who applies to become a user of the Company’s services (“Client”) shall undergo an onboarding process comprised of a questionnaire, which shall include the Client’s identification as well as certain additional information about the Client and its planned business relationship with the Company (the “KYC Questionnaire”), of an external review, flagging possible reputational ML/TF risks associated with the Client (the “Screening”) and of an identification through documentation submitted by the Client (the “Identification”) (together the “KYC Process”).

The Company shall document and preserve any information and documents gathered in the KYC process, in a manner making it possible to respond fully and without unreasonable delay to relevant inquiries from competent authorities.

The KYC Process shall be accomplished following the KYC principle, according to which the operating profile, purpose of operation, beneficial owner of the Client and, if necessary, the source and origin of the funds used in the transaction and other similar information essential for the establishment of a business relationship shall be identified in addition to the identity of the Client itself. The KYC shall provide the necessary information for determining the Client’s initial risk profile.

5. KYC Questionnaire

Any person applying to become a Client shall complete a short questionnaire to provide the Company with the basic information about itself, as the Company shall determine required considering the client’s circumstances (the “KYC Questionnaire”), including regarding section (a) applies to Natural Persons and Legal Entities:

1. General Information

   1. Client’s purpose and intent in the establishment of the business relationship;

   2. Client’s anticipated size of transactions;

   3. Client’s sources of income, fortune and assets;

   4. Client’s occupation or field of activity;

   5. Client’s permanent seat (place of residence/place of business);

   6. Client’s main contracting partners (if relevant);

   7. Identity of the beneficial owner (if necessary);

   8. Client’s telecommunication contact details;

   9. Any additional information which seems relevant in connection to a specific Client or group of Clients

 

2. For Natural Persons

   1. Full name;

   2. Personal identification code, or, if none, the date and place of birth;

   3. Whether the Client is himself a politically exposed person or related to one (“PEP”);

   4. Proof of addresses through utility bill or bank statement that is not less than 3 months old.

 

3. For Legal Entities

   1. Entity’s name;

   2. Entity’s registry code or registration number and date of registration;

   3. Information about the entity’s legal form;

   4. Entity’s passive legal capacity;

   5. Entity’s legal representatives and those authorized to represent the entity before the Company names.

An example of the information required from our corporate clients can be found here https://docs.google.com/document/d/14TkAPpJZ-7Xoyfni_tZsllLnHOiyNver/edit?usp=sharing&ouid=103985411050498563273&rtpof=true&sd=true 

6. Screening

The details of the Client, as provided in the KYC Questionnaire, shall be screened against updated ‘watchlists’ (the “Screening”). The specific watchlists to be used for the Screening shall be determined by the Compliance Officer, and shall include, inter alia, sanction lists published by national and international authorities, lists of ML/TF suspicious persons published or held by third parties, and lists of identified PEPs.

7. Identification

Prior to entering into a business relationship, the Client must be identified by providing the Company with the information detailed in the KYC Questionnaire, backed with a copy of the following documents (the “Identifying Documents”):

1. Individuals

Any individual who must be identified under this Policy shall present one of the following identifying documents:

A document issued by the United Kingdom for digital identification of a person;

1. Another electronic identification system with assurance level ‘high’ which has been added to the list published in the Official Journal of the European Union based on Article 9 of Regulation (EC) No 910/2014 of the European Parliament and of the Council on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257, 28.08.2014, pp 73–114);

   1. Valid travel document issued in a foreign country; or-

   2. Valid driver’s license, that meets the requirements provided for in subsection 1 of § 4 of the Identity Documents Act .

2. Legal Entities

Any legal entity, which must be identified under this Policy, shall be identified using the following documents:

 

1. Registry card of the relevant register; and-

2. Registration certificate of the relevant register; or-

3. A document equal to a registration certificate (for instance, in countries where there is no national register, foundation documents certified by a notary are considered equivalent).

8. Establishing the Identity of Relevant Persons

Where the Client is a legal entity, the identities of the following persons (the “Relevant Persons”) must be established, through the measures prescribed in subsection 7(a) above, in addition to the identity of the Client itself:

1. Beneficial Owners

The Client shall provide the Company with the information required to identify its beneficial owner. The following persons shall be considered as “beneficial owners”, whose identity must be established in addition to the identity of the Client itself, for the purposes of this Policy:

1. A natural person who, taking advantage of their influence, makes a transaction, act, action, operation or step or otherwise exercises control over a transaction, act, action, operation or step or over another person and in whose interests or favour or on whose account a transaction or act, action, operation or step is made;

2. Any person holding, alone or in concert, at least 25% of the voting rights or equity participation in the Client, or otherwise demonstrating effective control over the Client (each, a “Controlling Person”);

3. If any Controlling Person is not a natural person, any natural person who is to be regarded as controlling (in the sense given in paragraph (b) above) is such a Controlling Person;

4. If no Controlling Persons can be determined in accordance with paragraphs (b) and (c) above, the highest managing director or officer of the Client.

2. Representative

 

Where a person who is not the Client (e.g. signatory or representative) establishes the business relationship, the Client shall provide the Company with the following:

1. The identity of the natural person(s) who establish the business relationship (the “Representative”), in addition to that of the Client;
   

2. Documents setting the Representative’s authority (e.g. Power of Attorney, corporate resolution appointing the Representative) must be obtained and documented.

3. Where the business relationship is established by a trustee, nominee, protector, receiver, etc., all relevant documents establishing or confirming such person carrying out such a position must also be obtained and documented.

4. If there is any doubt regarding the authenticity or the legal force of a relationship referred to under this Section, further information, documents and/or proof should be obtained, and the business relationship shall not commence prior to such relationship being clarified.

Based on the information gathered via the KYC Process, the Company shall assemble an individual profile of the Client upon entry into a business relationship (the “Client Profile”). The Client Profile shall allow the Company to understand the Client’s financial background, the origin of the Assets, and the purpose of the business relationship, as well as to check their plausibility in terms of legitimacy, or to identify circumstances that require particular clarification. Based on the Client Profile the Company shall perform a risk assessment, to determine the Client’s risk profile and the necessary corresponding mitigating due diligence measures to be taken (the “Risk Profile”).

PART III –DUE-DILIGENCE

The Company is committed to recognising, assessing and understanding ML/TF risks it may face in connection with its Clients and their transactions, and to take appropriate measures to mitigate these risks using a risk-based approach.

The Company shall apply Client Due Diligence (‘DD’) measures, to ensure the proper identification and verification of the Client or Client representatives participating in the transaction, as well as ongoing monitoring of business relationships, including transactions carried out during business relationships, regular verification of data used for identification, update of relevant documents, data or information and, when necessary, identification of the source and origins of funds used in transactions .

Depending on the Client Risk Profile level and depending on whether the business relationship is an existing one or about to be established, the Company shall apply varying DD measures. For this reason, not all the procedures contained in this Part III shall be applicable to all Clients. Whenever the Company is unable to complete a DD measure, or doubt is arising during the application of a DD measure, the Company shall automatically raise the Client’s Risk Profile Level and apply a more stringent DD measure.

DD shall include the following procedures:

 

9. Risk Assessment

 

When determining the risk profile and the corresponding due diligence mitigating measures, the Company shall take account, when relevant, the information detailed in subsection (a) and the risk assessment detailed in subsection (b):

1. Information affecting the risk profile

1. Provisions of the National Risk Assessment, as published on the website of the Ministry of Finance;

2. Information regarding the nature of the business relationship and/or occasional transaction, as gathered in the KYC Process;
   

3. The volume of the property deposited by the customer or the proprietary volume of the transaction or of transactions made during a professional act;

4. The estimated duration of the business relationship;

 

2. Risk assessment

 

The risk assessment shall take into account the following risk categories, the probability and consequences of their realisation and the probability of an increase in the risk:

1. Client associated risks, whose factors arise from the person or client participating in a transaction. These factors may include:

   1. The legal form, management structure and field of activity of the client, including whether it is a trust fund, civil law partnership or another similar contractual legal entity or a legal person with bearer shares;

   2. Whether the client is a PEP;

   3. Whether the client is a Shell Bank;

   4. Whether the client is represented by a legal person;

   5. Whether a third party (individual) is the beneficial owner;

   6. Whether the identity of the beneficial owner is impeded by complex and non- transparent ownership relations;

   7. The residency of the client, including whether the client is registered in a low tax rate jurisdiction;

   8. Whether the client is included in international sanctions lists ;

   9. Circumstances (including those identified in the course of a prior business relationship) resulting from the experience of communicating with the client, its business partners, owners, representatives and any other such persons;

   10. Whether the origin of the client’s assets or the source and origin of the funds used for a transaction can be easily identified;

   11. The type and characteristics of the client’s business;

   12. The possibility of classifying the client as a “typical client”; and-

   13. Problems during the client’s identification procedures.

 

2. Transaction associated risks, whose factors result from the Client’s economic activities or the exposure of a specific product or service to potential money laundering risks. These factors may include:

   1. The transaction involves currency exchange or purchase of precious metals;

   2. The transaction involves a private bank;

   3. The transaction involves alternative payment methods;

   4. The transaction involves gambling;

   5. The transaction involves rarities or exclusive goods;

   6. The transaction involves innovations;

   7. The transaction involves commercials; and-

   8. The transaction involves company establishment or management.

 

3. Country or geographical associated risks, whose factors arise from differences in the legal environment of various countries, these factors may include:

   1. Whether the transaction involves low tax rate jurisdictions, entailing a company registered to such jurisdiction or services provided at such jurisdictions ;

   2. Whether the jurisdictions involved apply legal provisions that are in compliance with the international standards of AML/CTF ;
      

   3. Whether the transaction involves a jurisdiction with a high crime rate (including drug- related crime rate);

   4. Whether the transaction involves a jurisdiction that is included in international sanction lists; and –

   5. Whether the transaction involves a jurisdiction with high levels of corruption according to the Corruption Perceptions Index (“CPI”) published by Transparency International.

 

4. Interface associated risks, whose factors arise from the channels (mainly the Internet) through which the business relationship is established, and the transactions are carried out, these factors may include:

   1. Whether the client is identified face-to-face;

   2. Whether the channel facilitates anonymity; and-

   3. Whether the channel facilitates third party funding.

10. Risk profile

The conducted risk assessment shall result in a risk profile, identified through the risk factors mentioned above, and according to the following scale:

1. Low Risk Profile: risk is considered low when there are no influential risk factors in any category. The client and the transaction can be described as “typical” and transparent, and there is no suspicion that the combination of risk factors may lead to the risk of ML/TF.

2. Medium Risk Profile: risk is considered medium when there are one or more risk factors that differ from the sphere of the “typical” client, but the transaction itself is clear (i.e. there are no risk factors in the transaction associated risks category). At the same time, there is no suspicions that a combination of the risk factors may indicate of ML/TF;

3. High Risk Profile: risk is considered high when there are multiple risk factors and the transaction itself is not clear. The combination of these factors casts doubt on the transparency of the client’s identity and transactions, indicating of ML/TF.

1. Any Client identified as a PEP shall be classified as High Risk Profile; Examples of risk indicators applicable to the above categorisation is attached hereto as Annex 1.

2. The Company shall document the determination of the risk profile, update it and make the data available to competent authorities, if necessary.

11. Verification

The Company shall verify the identity of the Client and, in the case of legal entities, the Client’s representatives and beneficial owners, as provided through the KYC Questionnaire and Identification Documents, applying the following measures:

1. Individuals

1. Where the Client’s Risk Profile is low – A document submitted to the Company for identification shall be assessed by the Compliance Function as follows:

   1. –Validity of the document based on the expiry date;

   2. The outward likeness and age of the person match the appearance of the person represented on the document;
      

   3. When relevant, the personal identification code matches the gender and age of the submitter;

2. Where the Client’s Risk Profile is medium – in addition to the measures described above, The Compliance Officer shall describe and apply additional verification measures, which may include:

   1. Additional documents, data or information originating from a reliable and independent source; or-

   2. Verification on the basis of trust services;

3. Where the Client’s Risk Profile is high – in addition to the measures described above, The Compliance Officer shall obtain the further verification measures, which shall be approved by the AML Board Member, these may include:

   1. Additional documents, data or information originating from a reliable and independent source;

   2. A notarised or officially authenticated copy of the Identification Documents;

2. Legal Entities

1. Where the Client’s Risk Profile is low – A document submitted to the Company for identification shall be assessed by the Compliance Function by accessing the relevant register electronic database;

2. Where the Client’s Risk Profile is medium – in addition to the measures described above, The Compliance Officer shall describe and apply additional verification measures, which may include:

3. Obtaining additional documents, data or information originating from a reliable and independent source;

4. Verification on the basis of trust services;

5. Where the Client’s Risk Profile is high – in addition to the measures described above, The Compliance Officer shall obtain the further verification measures, which shall be approved by the AML Board Member, these may include:

   1. Additional documents, data or information originating from a reliable and independent source;

   2. Obtaining corporate documents certified or authenticated by a notary or officially;

3. Verification of the Identity of Beneficial Owners

The Company shall verify the identity of the Beneficial Owner, applying the following measures:

 

1. Where the Client is a company listed on a regulated market, which is subject to disclosure obligations that establish requirements for ensuring sufficient transparency regarding the beneficial owner – no additional verification measures shall be required;

2. Where the Client’s Risk Profile is low – a written statement must be obtained, confirming such persons being all of the Controlling Persons (or highest managing director or officer, in the case of 10(iv above) of the Client (the “Controlling Persons Statement”). The Controlling Persons Statement must be dated and signed by the person authorised by the Client to do so, on behalf of the Client and approved by the Compliance Function;

3. Where the Client’s Risk Profile is Medium – in addition to the measure detailed in subsection (a)(iii)(b) enquiries to the respective registers shall be made and additional documentation identifying the Controlling Persons must be obtained. The additional documentation may include company records or annual reports
   

clearly identifying the Controlling Persons, as approved by the Compliance Officer;

4. Where the Client’s Risk Profile is High – in addition to the measures detailed in subsection (b)-(c) above, the Company shall obtain additional verification from credible sources. This verification may include information received in a format reproducible in writing from a credit institution (“CI”) registered in the European Economic Area or in an equivalent third country or a branch thereof. The additional verification shall be brought before and approved by the AML Board Member.

5. Whenever the Company establishes that the identification of a Client is insufficient, enhanced verification measures shall be applied.

12. Clarifications and Collection of Additional Information

 

For any risk indicator identified by the Company during the performance of the procedures described above, additional details and information shall be collected for the purpose of understanding and mitigating such risks. As prescribed by the competent Company function (determined in accordance with the Client’s risk level), the following measures shall be applied in connection with each risk factor identified:

1. Where the Client’s Risk Profile is Low – Compliance Function shall contact the Client for further clarifications, provision of documentation and/or proof;

2. Where the Client’s Risk Profile is Medium – in addition to the measure described above, The Compliance Function shall conduct a verification of the further information received from the Client through a reliable and independent source of information;

3. Where the Client’s Risk Profile is High – in addition to the measures described above, the Compliance Function shall conduct a thorough review of each Risk Factor and additional information received regarding it, which may include its verification through an additional second reliable and independent source of information as well as requiring further documentation from the Client, and submit the same for the review and approval of the Compliance Officer.

(a) For example: in the case of a Client’s High Risk Profile due to doubts regarding its source of funds, the Compliance Function may require the Client to submit bank confirmations and tax reports, conduct a verification of the documents filed, and review the plausibility of the Client’s funds in light of the additional information gathered. If the Compliance Function is convinced that the documents provided are complete and accurate and provide sufficient comfort regarding the legitimacy of the Client’s funds, a report of the same shall be submitted to the approval of the Compliance Officer.

4. Where the Client’s is a PEP – in addition to the measures described above, a thorough review into the Client’s source of funds (regardless of any additional risk indicator applicable), and gathering of relevant documentation shall be conducted by the Compliance Officer, the results of which shall be brought for the final approval of the AML Board member.

13. Approval of Client Business Relationship

Upon the completion of the DD measures described above, the business relationship may be approved by the corresponding authority within the Company and established, as follows:

1. Where the Client’s Risk Profile is Low – The Compliance Function shall review the information gathered in the DD process and approve the establishment of a business relationship;

2. Where the Client’s Risk Profile is Medium – The Compliance Officer shall review the information gathered in the DD process and approve the establishment of a business relationship;

3. Where the Client’s Risk Profile is High – The AML Board Member shall review the information gathered in the DD process and approve the establishment of a business relationship.

PART IV – ONGOING AML REQUIREMENTS

14. Ongoing Monitoring

    1. Ongoing Monitoring of Transactions

Every transaction which is undertaken by a Client with the Company shall be electronically monitored and reviewed to ensure that they are in concert with the Client’s initial declared scope and purpose for the establishment of the business relationship and coherent with the Client’s Risk Profile and transactional history (the “IT Monitoring”). Said monitoring shall identify transactions which should be more thoroughly examined, based, among others, on frequency of transactions, forming or breaking of any pattern of behaviour, size of transaction, etc., taking into account the profile of the specific Client, and the observed characteristics of relevant groups of Clients.

Where a transaction is flagged as unusual or suspicious of ML/TF, the Compliance Function shall manually review the findings, assess the risks and operate according to its findings.

After the aforementioned review is undertaken, the Risk Function shall document the transaction and the results of its review in the Client’s AML File.

If the Risk Function determines that a transaction is suspicious of ML/TF, it shall provide a Report of Suspicion as detailed below.

2. Ongoing Monitoring of Business Relationships

i) All Business Relationships

 

3. Screening

The details of Clients (as well as those of their Relevant Persons) shall undergo a daily screening.

 

4. The IT Monitoring procedures shall be conducted on an ongoing basis, identifying not only suspicious transactions, but also other issues related to the Clients and the business relationships which should raise awareness. Once such an issue is flagged by the IT Monitoring, the Compliance Function shall immediately review it manually.

5. The Compliance Function shall periodically review all existing business relationship to identify any changes which seem to have occurred in connection with the Clients, conduct a more overreaching review of the different transactions made with it over the entire business relationship, and identify any unusual or suspicious details which might have been missed in the review of specific transactions as described above.

Such reviews shall take place at least:

1. For Low Risk Profile Clients – once every 9 months;

2. For Medium Risk Profile Clients – once every 6 months;

3. For High Risk Profile Clients – once every 3 months;

6. The Compliance Officer shall perform routine sampling of the AML Files, reviewing the appropriateness and completeness of such Files and the processes documented therein.

Medium Risk Profile Business Relationships

1. In addition to the reviews undertaken in accordance with paragraph (i) above, the Compliance Officer shall review, at least once per year, each business relationship of Medium Risk Profile Clients.

 

High Risk Profile Business Relationships

2. In addition to the reviews undertaken in accordance with paragraphs (i) and (ii) above, the AML Board Member shall annually review and decide on the continuation of any High-Risk Profile business relationship.

7. Identifying ‘Suspicious’ Business Relationships/Transactions The reviews described above shall aim at detecting:

   1. any discrepancies between the information previously gathered (as documented in the Client’s AML File) and any information which is currently known or is available to the

 

Company (e.g. any updates or changes which have occurred in the Client’s details);

2. any discrepancies between the Client Profile and the transactions undertaken by it (e.g. transactions which do not seem to match the Client’s financial status or expected scope of business); and

3. any other suspicious behaviour or pattern (e.g. transactions with no visible business logic, frequent purchase/sell/transfer of funds).

 

If any of the above is detected by an employee, whether as part of a routine review by the Compliance Function, or by any other means, it shall immediately be reported to the Compliance Officer.

 

An employee does not need to have evidence that money laundering is taking place in order to have a suspicion of such money laundering. All employees will be encouraged to seek advice from their manager and/or the Compliance Officer if they have any queries.

 

8. Change in Risk Levels

If, at any time after the establishment of the business relationship, there is a reason to alter the Client’s Risk Level, this issue shall be brought before the Compliance Officer, who may decide on this issue and alter such Risk Level, or bring it before the Board to do the same.

Such reasons may include, inter alia:

1. New information regarding the Client that has come up during Screening;

2. Suspicion regarding the Client has been rising by one of the Company’s employees;

3. The Company becomes aware of any new and relevant information.

 

Inactive Business Relationship

Where a Client does not perform any transaction with the Company for a period exceeding 6 months, such Client will become an ‘inactive client’ and the Company will cease performing all ongoing measures described above. Where an inactive Client wishes to perform another transaction, the Company shall perform the necessary reviews to revalidate its status before completing such transaction.

15. Registration and Storage of Data

 

1. The Company shall register all the Client’s information obtained in the KYC Process and DD procedures in the Company’s Clients database, including all data regarding Company decisions on approval or refusal of establishment of business relationship or a transaction.
   

2. The respective data shall be stored in a format reproducible in writing and, if required, shall be made accessible by all appropriate staff of the Company.

 

3. Documents which serve as the basis for the identification of a Client or Client representative, and documents serving for the establishment of a business relationship shall be kept and stored by the Company for at least five (5) years following the termination of the business relationship, or as otherwise required by applicable law.
   

PART V – REPORTING SUSPICIOUS BUSINESS RELATIONSHIPS/TRANSACTION

16. Report to the Compliance Officer

Internal reporting of any suspicious matters in connection with this Policy shall be made immediately by the individual having such suspicions (regardless of whether such individual part of the Compliance Function) to the Compliance Officer.

The Compliance Officer shall analyse the content of the information received and forward the respective information to the AML Board Member.

1. Evaluation of Suspicion

The Compliance Officer, upon receiving a report (or in any other manner becoming aware of any suspicion of ML/TF), shall immediately review such suspicion, evaluate its merits, and conclude what actions shall be taken in connection therewith. In doing so, the Compliance Officer may consult the Compliance Function, the employee who reported the suspicion, the Board, or any other person within the Company.

The actions which the Compliance Officer may decide to be taken may vary depending on the circumstances, and include any action mentioned in this Policy. These include but are not limited to:

1. no-action;

2. instructing the Compliance Function to conduct further review;

3. reclassification of the Risk Level of the business relationship;

4. immediate termination of negotiations aimed at establishing the business relationship;

5. reporting to the AML Board Member; and

6. reporting to authorities, as further described below.

7. Report to the England Financial Intelligence Unit

 

The Compliance Officer is responsible for determining when a report to the England Financial Intelligence Unit is to be made, and for making the report.

The England Financial Intelligence Unit shall be notified of any suspicious and unusual transactions, including such where the financial obligation exceeds 32.000 Euros or an equivalent amount in another currency is performed in cash, regardless of whether the transaction is made in a single payment or several related payments over the course of a year.

The Client who is reported to the England Financial Intelligence Unit as being suspicious, may not be informed of the same. It is also prohibited to inform any third persons, including other employees, of the fact that information has been reported to the England Financial Intelligence Unit, and the content of the reported information, except for the AML Board Member/Compliance Officer.

a. Duty to Report

 

A report to the England Financial Intelligence Unit must be filed if the Company knows or has reasonable grounds to suspect that assets involved (or which are expected to be involved) in the business relationship, not later than within two (2) business days after discovering any activities or circumstances or arising of suspicion:

1. Are the proceeds of a felony or of an aggravated tax misdemeanour;
   

2. Are connected to money laundering or to a criminal organisation which pursues the objective of committing crimes of violence or which aims at financial gain by criminal means;

3. Serve the financing of terrorism;

4. Are subject to the power of disposal of a criminal organisation; or

5. Are related to persons contained on sanction lists.

 

The abovementioned duty to report to the England Financial Intelligence Unit arises whether such knowledge or suspicion arises before or after a business relationship is established (i.e. whether the Company refuses to establish the relationship or establishes it and gain such knowledge or suspicion at a later date).

A report to the England Financial Intelligence Unit must also be made immediately if any other competent authority, forwards to the Company in any manner the details of a person which they consider to be involved in unlawful activities of any kind, and the Company finds that the information regarding such person matched or is very similar to that of a Client, its controlling person, beneficial owner of the assets or authorised signatory of a business relationship or transaction. In any such event, the Company must immediately freeze the assets entrusted to it which relate to the report, until it receives an order from the competent prosecution authority, but at the most five (5) working days from the time at which the relevant report was filed with the England Financial Intelligence Unit.

PART VI – OTHER REQUIREMENTS

18. Training

All Company employees must undergo AML training in a manner, scope and frequency appropriate to their role in the Company.

Such training shall be conducted, monitored and documented as prescribed by the Compliance Officer, and reviewed by the AML Board Member on an annual basis, together with this Policy.

The Compliance Officer is responsible for ensuring that all employees are aware of their responsibilities under this Policy, including applicable laws and regulations, and are familiar with the procedures of identifying and reporting suspicious transactions, business relationships or activities. All employees must be aware that non-compliance with this matter may result in legal action, including criminal action, being taken against them.

Employees involved with any interaction with customers, operational processes supporting on boarding, customer activity or execution of customers activities will not be allowed to conduct their roles prior to completion of basic AML training.

19. Internal Review and Amendment of this Policy

Compliance with this Policy shall be inspected at least once a year by the Compliance Officer and presented to the Board in a written format. The report on the results of the inspection concerning the compliance with the measures for prevention of ML/TF shall set out the following information:

1. date of the inspection;

2. name and position of the person conducting the inspection;

3. purpose and description of the inspection;

4. analysis of the inspection results, or the conclusions drawn on the basis of the inspection.
   

If the inspection reveals any deficiencies in this Policy or their implementation, the report shall set out the measures to be applied to remedy the deficiencies, as well as the respective time schedule and the time of a follow-up inspection.

If a follow-up inspection is carried out, the results of the follow-up inspection shall be added to the inspection report, which shall state the list of measures to remedy any deficiencies discovered in the course of the follow-up inspection, and the time actually spent on remedying the same. The inspection report shall be presented to the AML Board Member, who shall decide on taking measures to remedy any deficiencies discovered.

Annex 1: Examples of indicators for risk categorisation

1. The following is deemed a situation reducing risks relating to the customer type:

   1. The Client is a company listed on a regulated market, which is subject to disclosure obligations that establish requirements for ensuring sufficient transparency regarding the beneficial owner;

   2. The Client is a legal person governed by public law established in United Kingdom;

   3. The Client is a governmental authority or another authority performing public functions in United Kingdom or a contracting state of the European Economic Area;

   4.  

   5. The Client is an institution of the European Union;

   6. The Client is a person who is a resident of a country or geographic area having the characteristics specified bellow.

 

2. The following may be deemed a factor reducing geographic risks:

   1. A contracting state of the European Economic Area;

   2. A third country that has effective AML/CFT systems;

   3. A third country where, according to credible sources, the level of corruption and other criminal activity is low;

 

3. The following is deemed a situation increasing risks related to the customer as a person:

   1. The business relationship foundations based on unusual factors, including in the event of complex and unusually large transactions and unusual transaction patterns that do not have a reasonable, clear economic or lawful purpose or that are not characteristic of the given business specifics;

   2. The Client is a resident of a higher-risk geographic area as listed below;

   3. The Client is a legal person or a legal arrangement, which is engaged in holding personal assets;

   4. The Client is a cash-intensive business;

   5. The Client is a company that has nominee shareholders or bearer shares or a company whose affiliate has nominee shareholders or bearer shares;

   6. The ownership structure of the Client’s company appears unusual or excessively complex, given the nature of the company’s business.

 

4. The following is deemed a situation increasing risks related to the product, service, transaction or delivery channel:

   1. Private banking;

   2. Provision of a product or making or mediating of a transaction that might favour anonymity;

   3. Payments received from unknown or unassociated third parties;

 

5. Situation where the Client, a person involved in the transaction or the transaction itself is connected with a following country or jurisdiction is deemed as a situation increasing the geographical risk:

   1. Jurisdiction that, according to credible sources such as mutual evaluations, detailed evaluation reports or published follow-up reports, has not established effective AML/CFT systems;

   2. Jurisdiction that, according to credible sources, has significant levels of corruption or other criminal activity;
      

   3. Jurisdiction that is subject to sanctions, embargos or similar measures issued by, for example, the European Union or the United Nations;

   4. Jurisdiction that provides funding or support for terrorist activities, or that has designated terrorist organisations operating within their country, as identified by the European Union or the United Nations.

Home Page / Privacy Policy

Privacy Policy

1. PREAMBLE

Valuing Customers’ trust and understanding the importance of ensuring the confidentiality of Customers’ Personal Data, as well as that of the Informational Materials posted by Customers on the Website in the course of fulfilling the provisions of the Terms and Conditions, the Administrator puts into effect this Policy to define the order for performing operations involving the Parties’ Confidential Information when using the Website and the System’s Services.

Every Customer should be familiar with the terms of this Policy before starting to use the System's Services.

The Privacy Policy was last updated on: March 8th, 2017 

2. DEFINITIONS OF TERMS

Unless it is otherwise explicitly stated in or follows from the main text of the Terms and Conditions, the following words and phrases shall be used in the meanings as specified below:

2.1.  Cookie  is a piece of Data that does not contain any Personal Data, which is created by the Website and stored on the Customer’s computer as one file or multiple files. If the Customer chooses to block a Cookie file, the Customer may experience difficulty or find it impossible to use the Website.

2.2.  Informational Materials   (Data)  are any text, graphic, audio, video, and mixed-type materials of informational nature.

2.3.  Confidential Information  is any information that is not Public Data, which is considered confidential under the Parties’ agreement or in accordance with the applicable laws.

2.4.  Confidentiality  is accessibility of information solely to its owner, as well as any parties to which such information can and/or must be provided under law and/or under agreement with this party.

2.5.  Public Data  is any data (including Personal Data) to which the owner of such data provides access to an unlimited number of parties (including by means of publishing data on any website without restricting access to such data) or to which, in accordance with this Appendix and/or the effective laws, confidentiality requirements do not apply.

2.6.  Personal Data  is any information related, directly or indirectly, to a specific or identifiable individual person (the subject of personal data).

2.7.  Receiving Party  is the Party receiving Confidential Information.

2.8.  Compromise of Confidential Information  is one of the Parties’ actions or inaction resulting in the Confidential Information becoming known or available to third parties without the permission of the owner of such confidential information. The format of the information compromise (orally, in writing, via any technical devices, etc.) is immaterial.

2.9.  Disclosing Party  is a Member, in relation to the Confidential Information disclosed by the Administrator; and, it is the Administrator, in relation to the Confidential Information disclosed by a Member.

2.10.  Disclosure of Confidential Information  is transfer to any third party of any Confidential Information in compliance with the requirements of this Appendix, including leaking, stealing, losing, distorting, corrupting, destroying, modifying, copying, or blocking Confidential Information resulting from failure to comply or improper compliance with the terms of this Appendix by the Receiving Party.

2.11. The terms that are not defined in this section shall be used further in the text in the meanings as specified (in the order of priority) in bilateral agreements signed by the Parties and in the current version of the Terms and Conditions approved by the Administrator and all Appendixes thereto.

3. GENERAL PROVISIONS

3.1. By using any part of the Website and/or the Services, the Customer gives the Administrator the right to receive, store, process, and use the Customer’s Personal Data and other Informational Materials in compliance with the terms of this Appendix.

3.2. This Appendix does not apply to, nor is the Administrator responsible for, any methods of receiving, storing, processing, using, and disclosing the Customer’s Personal Data and other Informational Materials by external companies and organizations that are not owned or managed by the Administrator and by individuals that are not the Administrator’s employees, even though the Customer may obtain access to such parties’ and persons’ websites, software and/or GWS via the Website.

3.3. The main purpose of receiving, storing, processing, and using the Customer’s Personal Data, Public Data, and other data is to protect the Customer’s interests, as well as to improve the quality of the personalized and general services provided by the Administrator to the Customer.

3.4. This Policy is not an independent document and serves only as an addition to the Terms and Conditions; it does not supersede or nullify any of the provisions included in the main text of the Terms and Conditions, in particular, Sections 10-14 of the Terms and Conditions related to the subject of this Policy.

3.5. The provisions contained in this document and the term ‘Confidential Information’ shall not apply to the information that:

3.5.1. was, is or is made available to the Receiving Party on the non-confidential basis from a party that, to the Receiving Party’s knowledge, is not bound by any confidentiality agreement with the other Party or by any other restriction related to disclosing confidential information to the Receiving Party, or

3.5.2. was in lawful possession of the Receiving Party prior to the other Party’s disclosing it as Confidential Information, or

3.5.3. is developed by or for the Receiving Party;

3.5.4. is not in any way protected by the Disclosing Party to ensure confidentiality;

3.5.5. is made available due to the requirements of the effective laws and regulations;

3.5.6. is publicly available and known due to the Disclosing Party’s actions and decisions;

3.5.7. was available to the Receiving Party on the non-confidential basis prior to the other Party’s disclosing such information, or

3.5.8. has to be disclosed in accordance with the effective laws or under orders issued by the governmental agencies or any other competent authorities.

4. COLLECTION OF INFORMATION

4.1. The Administrator can gather and process the following information about the Customer:

• Customer’s full first name and last name, occupation, address, email address, phone number, date of birth, bank or payment card details, as well as the documents confirming the Customer’s identity and residence address, to be provided on our request;
• information related to the Transactions performed by the Customer through the System with the use of the Wallet and to the execution of the Customer’s Orders;

4.2. For the purpose of fulfilling mandatory legal obligations related to anti-fraud and anti-money laundering requirements, the Administrator will receive information related to the Customer from third parties, including information about the Customer’s financial history, any decisions of local district courts, bankruptcy, information provided by credit bureaus and anti-fraud agencies, when the Customer opens a Wallet or at any other time when the Administrator may deem it necessary to prevent fraud and minimize financial risks. More detailed information can be found in Appendix 02 to these Terms and Conditions.

4.3. During the Customer’s Registration in the System and when the Customer is creating a Wallet, the Customer has to provide their Authorization Data, as well as other details (mandatory or optional). After the Customer has created and used their Wallet, the Administrator is able to identify the Customer every time this Customer uses the System and visits the Website.

4.4. The Administrator may install cookies to Customers’ computers (unless the Customer purposely restricts this option in their browser), as well as receive, store, process, and use the information created through cookies.

4.5. When the Customer visits the Website, the Administrator automatically stores, processes, and uses the Customer’s data that is not their Personal Data, for example: Customer’s IP address, Customer’s location identifiable with their IP address, Customer’s computer’s technical parameters, presence or absence of specific software on the Customer’s computer, such software’s settings, cookies, as well as statistics on the Customer’s activities.

4.6. Besides visiting the Website, the Customer also provides information to the Administrator when using the System (if possible) via applications for mobile devices, social media applications, payment terminals, etc., contacting and submitting requests by phone, mail, email, or via other means of communication; the Administrator also receives information about the Customer from other sources when verifying the information previously provided by the Customer.

5. USE OF INFORMATION

The Administrator shall use the available information related to Customers for the following purposes:

• rendering services related to Customers’ Wallets and providing services requested by Customers;
• executing Customers’ Orders related to Money Transfers and receiving Payments, as well as making Transactions using the Services;
• notifying Customers of changes in the Services, the System, the Terms and Conditions, the Software, etc.;
• fulfilling the requirements of the applicable laws and regulations, in particular, those related to anti-money laundering laws and KYC (Know Your Customer) procedures;
• verifying the Customer’s financial status, identity, and sol;
• carrying out verification procedures to prevent fraud and money laundering;
• providing services to Customers, including responding to Customers’ questions, requests, comments, and Complaints;
• increasing the security of the Services;
• providing the Website’s content (including its interactive features) in a way that is most efficient for Customers and their computers;
• providing to Customers products and services requested, or products and services that the Administrator believes may interest Customers;
• providing assistance in the development, provision, and improvement of the System’s Services, as well as providing the Website’s content and informing Customers;
• carrying out the Administrator’s internal procedures and processes, such as audits, analytical data processing, quality assessment as to the Services provided, etc.

6. DISCLOSURE OF INFORMATION

6.1. The Administrator shall not provide any Personal Data to any third parties for commercial purposes without the permission of the Customer to whom this information is related.

6.2. Personal Data can be disclosed to such third parties in the following circumstances:

• disclosing information upon receiving the permission of the Customer to whom this information is related;
• disclosing information on substantiated requests from the government agencies with the authority to obtain such information;
• disclosing information to agents and third parties acting under an agreement with the Administrator to fulfill obligations to the Customer (including, but not limited to, acquirers, payment card issuing banks, international card systems, telecommunication service providers, billing companies and delivery companies, the Administrator’s affiliated parties, etc.) and on the following conditions: 1) they are aware of the confidential nature of such information; 2) they take adequate measures to protect confidential information from unauthorized access and use;
• disclosing information to the Administrator’s potential creditors, investors, acquirers, Partners, shareholders, and auditors;
• disclosing information to companies that may offer their products and services to Customers;
• disclosing information in the course of information exchange with other companies and organizations for the purposes of anti-fraud protection and financial risk minimization;
• disclosing information when the Administrator believes that the Customer violates the terms of this Appendix and/or other agreements and contracts between the Administrator and the Customer, and/or the Administrator’s internal regulations and rules; or, when the Administrator deems such information disclosure necessary to investigate, prevent, or take measures against unlawful activities, suspected fraudulent activities, potential threats to any person’s physical security, violations of the Terms and Conditions or any bilateral agreements, or if it is required by law;
• disclosing information in other circumstances in accordance with the provisions of these Terms and Conditions and the applicable laws.

6.3. Unless otherwise agreed upon in writing with a specific Customer, the Administrator can publicly disclose the fact of the existence of the Administrator’s business relationship with this Customer.

6.4. The Administrator reserves the right to disclose confidential information when it is required by the business conduct practices.

6.5 No provision contained in this Appendix shall restrict either Party’s right to disclose any Confidential Information in accordance with any court order or decision, any other legitimate obligation or requirement under the effective laws and regulations if such information disclosure is mandatory and on the condition that, if possible, the other Party is notified of such information disclosure in advance.

6.6. All Confidential Information shall remain the property of the Party disclosing such information; no rights or licenses are granted with regard to such Confidential Information, unless otherwise specifically stipulated in this Appendix.

6.7. Either Party shall return to the other Party and/or securely destroy all Confidential Information (including any part of it that may be undergoing processing, analysis, or translation, including also all copies, written notes, drawings, charts, computer programs in any and all formats, on any type of a data storage device) on the other Party’s written request, unless such documents have to be stored under the effective laws and regulations, and, if required, shall confirm in writing, with the authorized person’s signature, that such Confidential Information was duly returned or securely destroyed.

6.8. The Customer has the right to request that the Administrator restrict third parties’ access to the Customer’s Personal Data for marketing purposes, provided that it does not contradict the applicable laws and the Terms and Conditions, by sending a relevant written request to the Administrator using the Administrator’s Contact Details.

7. PROCESSING OF INFORMATION

7.1. By providing their Personal Data during the Registration in the System, the Customer agrees to data processing, with or without the use of automation technology and/or devices, in particular, information gathering, storage, transfer to third parties, and use by the Administrator for the purpose of providing the Services to the Customer and for other purposes specified in the Terms and Conditions.

7.2. If the Customer does not wish for their Personal Data to be processed, the Customer should contact the Administrator using the Administrator’s Contact Details or the feedback form on the Website. In this case, all the information received from the Customer will be deleted from the Administrator’s client database, and the Customer will not be able to use the Services.

8. ACCESS TO INFORMATION

8.1. For the purpose of exercising Customers’ rights and the Administrator’s proper fulfillment of its obligations under the Terms and Conditions and the agreements signed by the Parties, the Administrator may review Customers’ Informational Materials (for the purpose of timely resolution of technical problems and prevention of unlawful activities that violate the rights of either Party, other Customers, etc.).

8.2. The Administrator provides limited access to Customers’ information only to the employees that, in the Administrator’s opinion, need to use such information to provide services to the Customers or perform their professional duties.

8.3. The Customer has the right to request, edit, or delete their Personal Data stored by the Administrator and/or on the Website. The Customer may independently edit, change, or delete their Personal Data using the relevant features of the Website and their Wallet.

8.4. The applicable laws on personal data protection give the Customer the right of access to any information related to the Customer. Any request for access to information may result in charges to cover any and all expenses involved in providing the Customer with detailed information stored by the Administrator and/or third parties.

9. SENDING MESSAGES TO PUBLICLY ACCESSIBLE PAGES

9.1. A publicly accessible page is any page of the Website to which unlimited access is open to any party and which can be indexed by search engine systems.

9.2. The Administrator allows the Customers to send messages and exchange Data on publicly accessible pages.

9.3. The Customer should exercise caution and common sense when disclosing their information that allows identifying the Customer on publicly accessible pages. It is important to remember that this information may remain on publicly accessible pages of the Website for an indefinite period of time. Besides, depending on a specific Service, other Customers may also view such information.

9.4. The Customer is solely responsible for any information that the Customer discloses and distributes on publicly accessible pages.

9.5. If the Customer has any concerns regarding information that allows identifying the Customer which the Customer provided on any publicly accessible page, the Customer cannot delete or edit such information; in such cases, the Customer should contact the Customer Support Service.

10. PROTECTION OF INFORMATION

10.1. The Parties acknowledge and confirm that they shall ensure confidentiality of any and all information received in the course of fulfilling obligations under the Terms and Conditions, with the exception of the cases explicitly provided for in the Terms and Conditions and the Parties’ other agreements.

10.2. The Customer violating the obligations pertaining to information confidentiality shall cover all expenses and losses (including loss of profits) incurred by any third parties and/or the Administrator as a result of such actions of the part of this Customer.

10.4. The confidentiality terms are included in these Terms and Conditions and accepted by the Customer when the Customer confirms accepting the Terms and Conditions.

10.5. The Parties shall NOT disclose information pertaining to the System’s operating conditions, as well as other information received by the Parties in the course of fulfilling the obligations under the Terms and Conditions, with the exception of the cases when either Party is obligated to disclose such information in accordance with the applicable laws.

10.6. The Parties shall notify each other within 1 (one) business day of the occurrence or knowledge that they may have about any disclosure or threat of disclosure, unlawful obtainment or unlawful use of the Confidential Information by any third parties.

10.7. The Parties shall not unilaterally suspend or terminate measures aimed at protecting confidential information as specified in these Terms and Conditions, including in cases of their reorganization (merger, acquisition, division, separation, transformation, or any other type of the legal status change) or (when stipulated by the law) liquidation.

10.9. Disclosing Confidential Information on legally valid requests from law enforcement agencies or other competent government authorities and/or officials in accordance with procedures specified by the applicable laws shall not constitute a violation of the Parties’ confidentiality obligations.

10.10. In the event of disclosing Confidential Information to the authorities and/or parties stated above, the Party disclosing Confidential Information shall notify the owner of such Confidential Information in writing of the fact of information disclosure, as well as of the content of such information and the name of the agency or authority to which such Confidential Information was disclosed within 1 (one) business day after disclosing Confidential Information.

10.11. As stipulated in other sections of these Terms and Conditions, Customers are responsible for ensuring confidentiality of their Authentication Data. The Administrator is not responsible for transactions made as a result of improper storage or loss of information on the part of the Customer.

11. MISCELLANEOUS PROVISIONS

11.1. The Administrator has the right to store the Customer’s Personal Data and other data for as long as it is necessary to achieve the objective specified in this Appendix, or for a period of time required by the applicable laws, or until the Customer chooses to delete such data.

11.2. The Customer is responsible for providing accurate and true information, as well as for updating their information provided previously in the event of any changes in the information.

11.3. The Customer allows the Administrator to give permission to other parties with which the Administrator signs relevant agreements to receive, store, and process information about the Customer (except the Customer’s Personal Data and Informational Materials), such as the Customer’s IP address, cookies, and statistics on the Customer’s activities, for the purpose of improving the quality of the services provided by such parties and providing promotional information.

11.4. The Customer agrees that the confidentiality of any information transferred via the Internet is not guaranteed; if any third party gains access to such information outside the technical communication means area managed by the Administrator, the latter shall bear no responsibility for any possible damages caused by such access to information.

11.5. If, in the course of using the Website and/or the System, any information becomes available to the Customer regarding the Administrator and/or any third parties, which, in accordance with the applicable laws, constitutes confidential information and/or trade secrets, the Customer shall not store, use, or distribute such information.

11.6. When you click links on our Website, you may be redirected to third party sites. We do not assume any responsibility for content of third party Sites and for the information third party Sites collect from you, including the ways these third party Sites process, store, and manage such information. Third party service providers may have their own Privacy Policies. We strongly recommend that you familiarise yourself with these Policies to understand how your personal information is handled. Once you leave our Website, the terms of this Privacy Policy no longer define how your personal information may be collected and managed. 

 

 

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