Privacy Policy

Our Privacy Policy

Below is a brief summary of how we process your personal data. For more detailed information, please read our full Privacy Policy.

DATA COLLECTION

Bit4Me is responsible for the means and purposes of processing of the personal data you provide to us. We collect identity, job-related, financial, and usage information about you.

PURPOSES OF COLLECTION

We will use your personal data to, among other things, process your transactions, manage and administer your customer account, personalize content, analyze how to improve our services, protect you from fraud, and comply with legal and regulatory obligations. With your consent, we’d like to keep in touch with you about the work we’re doing, including feature changes and product updates.

SHARING

We will share your data within the Bit4Me group, with vendors and service providers, and with other organizations as required by law.

YOUR CHOICES

You can exercise your privacy rights at any time by visiting your Privacy Rights dashboard in Settings. Your privacy rights include access, correction, erasure, restriction, objection, and data portability.

 

Legal

Bit4Me User Agreement


This agreement (the “Agreement”) is for all customers, except those who reside in the United States.

Bit4Me Estonia Limited is regulated by the Central Bank of Estonia.

This is a contract between you and each of:

  1. Bit4Me Estonia Limited (“Bit4Me Estonia“), a private limited company incorporated in Estonia with company number 16442094, whose registered office address is Väike-Paala, 2 Tallinn, Harjumaa – 11415 – ESTONIA.

References in this Agreement to “Bit4Me”, “we”, “our” or “us”, are to Bit4Me Estonia and/or Bit4Me Europe depending on the services being discussed, and references to “you” or “your” are to the person with whom Bit4Me enters into this Agreement.

By signing up to use an account through bit4me.net or pro.bit4me.net, or any of our associated websites, application programming interfaces (“APIs”), or mobile applications (collectively the “Site“), you agree that you have read, understood, and accept all of the terms and conditions contained in this Agreement, as well as our Privacy Policy and Cookie Policy.

We refer to the E-Money Services, Digital Currency Services and Additional Services (all defined below) collectively as the “Bit4Me Services“, which can be accessed via the platform operated by Bit4Me (the “Bit4Me Platform”) (including the online platform which is accessible via the Site or at such location as may be prescribed by Bit4Me from time to time). Each of the Bit4Me Services is provided by either Bit4Me Estonia or Bit4Me Europe, as set out in clause 2 below.

You should be aware that the risk of loss in trading or holding Digital Currencies can be substantial. As with any asset, the value of Digital Currencies can go up or down and there can be a substantial risk that you lose money buying, selling, holding, or investing in digital currencies. Digital Currency Services are not currently regulated by the Central Bank of Estonia, or any other regulator in Estonia. You should carefully consider whether trading or holding Digital Currencies is suitable for you in light of your financial condition.


1. ELIGIBILITY.

To be eligible to use any of the Bit4Me Services, you must be at least 18 years old and reside in a country in which the relevant Bit4Me Services are accessible. Please note that not all Bit4Me Services are available in every country.

2. SERVICES.

2.1 E-Money Services.

The following services (the “E-Money Services“) may be provided to you by Bit4Me Estonia:

(A) a hosted digital wallet (“E-Money Wallet”) enabling you to store electronic money issued by Bit4Me Estonia, which is denominated in fiat currency (“E-Money“); and

(B) certain payment services enabling you to send and receive E-Money (as set out below).

The E-Money Services are regulated by the Central Bank of Estonia. Bit4Me Estonia is an authorised electronic money institution authorised and regulated by the Central Bank of Estonia with register number 16442094 and listed on the Central Bank of Estonia’s register

2.2 Digital Currency Services.

The following services (the “Digital Currency Services“) may be provided to you by Bit4Me Europe:

   (A) one or more hosted digital currency wallets (the “Digital Currency Wallets“) enabling you to store, track, transfer, and manage your balances of certain supported digital currencies like Bitcoin or Ethereum (collectively “Digital Currency” or “Digital Currencies”); and

   (B) a Digital Currency exchange service enabling you to obtain prices for your purchases and sales of Digital Currencies, and (subject to certain restrictions) carry out any such purchases or sales on the Site (the “Digital Currency Exchange Service”).

Unlike E-Money Services, Digital Currency Services are not regulated by the Central Bank of Estonia. Bit4Me Europe is not a regulated financial services provider. Bit4Me Europe is based in, and provides its services from, Estonia.

IMPORTANT NOTE: Bit4Me Europe is not a regulated financial service provider and is not registered with or regulated or authorised by the Central Bank of Estonia, the Competition Consumer and Protection Commission or any other regulatory body in Estonia for financial services and so you will not be able to avail of regulatory protections associated with such regulated entities such as investor or deposit protection schemes or access to the Financial Services and Pensions Ombudsman in relation to the Digital Currency Services.

2.3 Additional Bit4Me Services.

In addition to the core services (i.e. the E-Money Services and the Digital Currency Services), the following services (“Additional Services“) may be made available by Bit4Me Europe (or another member of the Bit4Me Group, as defined at Section 2.6 below) to users that fulfil certain eligibility criteria:

   (A) an order book exchange platform for Digital Currencies (as further described in Appendix 4) (“Bit4Me Pro”);

   (B) development applications provided by Bit4Me (as further described in Appendix 5) (“Developer’s Tools”); and

   (C) staking services (as further described in Appendix 6) (“Staking Services”).

2.4 Several Liability. You agree that the liability of each of Bit4Me Estonia and Bit4Me Europe under this Agreement is several and not joint, and each of Bit4Me Estonia and Bit4Me Europe shall be liable only for their own respective obligations under this Agreement, and any breaches by them of those obligations. This means that each of them are responsible to you for their own breaches of this Agreement, and not for each other’s breaches.

2.5 Fees. You agree to be responsible for the payment of and pay all fees. A full list of fees for Bit4Me Services, as amended from time to time, can be found on the Site at the ‘Pricing and Fees Disclosures’ and ‘Trading Fees’ pages, which shall form part of this Agreement.

2.6 Bit4Me Group. In this Agreement, “Bit4Me Group” means Bit4Me Europe and its corporate affiliates, including Bit4Me, Inc., a Delaware corporation, which provide Digital Currency storage and wallet services. Excluded from this definition are all corporate affiliates that solely provide electronic money services, including, but not limited to, Bit4Me Estonia.

3. ACCOUNT SETUP.

3.1 Registration of Bit4Me Account. To use the Bit4Me Services, you will need to register for a Bit4Me account (a “Bit4Me Account“) by providing your details, including your name, email address and a password and accepting the terms of this Agreement. By using a Bit4Me Account, you agree and represent that you will use the Bit4Me Services only for yourself, and not on behalf of any third party, unless you have obtained prior approval from Bit4Me in accordance with Section 3.2 and 4.10 of this Agreement. Each customer may register only one Bit4Me account. You are fully responsible for all activity that occurs under your Bit4Me Account. We may, in our sole discretion, refuse to open a Bit4Me Account for you, or suspend or terminate any Bit4Me Accounts (including but not limited to duplicate accounts) or suspend or terminate the trading of specific Digital Currency in your account.

3.2 Third party Access. If, to the extent permitted by Section 4.10, you grant express permission to a Regulated Third Party to access or connect to your Bit4Me Account(s), either through the Regulated Third Party’s product or service or through the Site, you acknowledge that granting permission to a Regulated Third Party to take specific actions on your behalf does not relieve you of any of your responsibilities under this Agreement. You are fully responsible for all acts or omissions of any Regulated Third Party with access to your Bit4Me Account(s) and any action of such Regulated Third Party shall be considered to be an action authorised by you. Further, you acknowledge and agree that you will not hold Bit4Me responsible for, and will indemnify Bit4Me from, any liability arising out of or related to any act or omission of any Regulated Third Party with access to your Bit4Me Account(s).

You may change or remove permissions granted by you to a Regulated Third Party with respect to your Bit4Me Account(s) at any time through the tabs on the ‘Settings’ page on the Site.

3.3 Identity Verification. You agree to provide us with the information we request (which we may request at any time deemed necessary) for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime, including as set out in Appendix 2 (Verification Procedures and Limits) and permit us to keep a record of such information. You will need to complete certain verification procedures before you are permitted to start using the Bit4Me Services and to access specific Bit4Me Services, including certain transfers of E-Money and Digital Currency, and the limits that apply to your use of the Bit4Me Services may be altered as a result of information collected on an ongoing basis.

The information we request may include (but is not limited to) personal information such as your name, residential address, telephone number, email address, date of birth, taxpayer identification number, government identification number, information regarding your bank account (such as the name of the bank, the account type, routing number, and account number) network status, customer type, customer role, billing type, mobile device identifiers (e.g. international mobile subscriber identity and international mobile equipment identity) and other subscriber status details, and any such information that Bit4Me is required to collect from time to time under applicable law.

You may also be required to undergo “Enhanced Due Diligence” (see Section 6.2 below), where Bit4Me may request that you submit additional information about yourself or your business, provide relevant records, and arrange for meetings with Bit4Me staff so that Bit4Me may, among other things, establish the source of your wealth and source of funds for any transactions carried out in the course of your use of Bit4Me Services.

In providing us with this or any other information that may be required, you confirm that the information is true, accurate and complete, and you have not withheld any information that may influence Bit4Me’s evaluation of you for the purposes of your registration for a Bit4Me Account or the provision of Bit4Me Services to you. You undertake to promptly notify in writing and provide Bit4Me with information regarding any changes in circumstances that may cause any such information provided to become false, inaccurate or incomplete and also undertake to provide any other additional documents, records and information as may be required by Bit4Me and/or applicable law. You permit us to keep records of such information. We will treat this information in accordance with Section 11 (Data Protection).

You authorise us to make enquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such enquiries. When we carry out these enquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our enquiries in full. This is an identity check only and should have no adverse effect on your credit rating. Additionally, we may require you to wait some amount of time after completion of a transaction before permitting you to use further Bit4Me Services and/or before permitting you to engage in transactions beyond certain volume limits.

4. E-MONEY SERVICES.

4.1 Loading. You can load funds into your E-Money Wallet using bank transfer (or other payment methods available on the Site for your location), and your E-Money Wallet will show loaded funds once we have received them. Loading of funds may be done manually, or as part of a recurring transaction that you set up on your Bit4Me Account (see Section 5.12 below for more details). You may only load your own funds, from your own account, and not from any joint, pooled or third party account. When funds are loaded into the E-Money Wallet you will be issued with E-Money by Bit4Me Estonia that represents the funds you have loaded. The E-Money Wallet is not a deposit or investment account which means that your E-Money will not be protected by the Deposit Guarantee Scheme or the Investor Compensation Scheme. Bit4Me Estonia will only hold funds received from users in a designated safekeeping account with a regulated financial institution. E-Money held in an E-Money Wallet will not earn any interest. Your E-Money Wallet may hold E-Money denominated in different currencies and we will show the E-Money balance for each currency that you hold.

4.2 Purchase or Sale of Digital Currency. You may purchase supported Digital Currency by using E-Money credited to your E-Money Wallet. To carry out a Digital Currency Transaction using E-Money, you must follow the relevant instructions on the Site. A Digital Currency Transaction using E-Money should normally be settled no later than one business day after we receive your instructions. You authorise us to debit E-Money from your E-Money Wallet. Although we will attempt to deliver Digital Currency to you as promptly as possible, E-Money may be debited from your E-Money Wallet before Digital Currency is delivered to your Digital Currency Wallet.

You may sell Digital Currency in exchange for E-Money. You authorise us to debit your Digital Currency Wallet and credit your E-Money Wallet with the relevant amount of E-Money.

4.3 Receipt of Instructions. If we receive instructions from you to purchase Digital Currency using E-Money on a non-business day or after 4:30 pm (Dublin time) on a business day, we may treat those instructions as if they were received by us on the following business day.

4.4 Revocation. When you give us instructions to carry out a Digital Currency Transaction using E-Money, you cannot withdraw your consent to that Digital Currency Transaction unless the Digital Currency Transaction is not due to occur until an agreed date in the future e.g. if you have set up Future Transactions (see Section 5.11 below for more details). In the case of a Future Transaction, you may withdraw your consent up until the end of the business day before the date that the Future Transaction is due to take place. To withdraw your consent to a Future Transaction, follow the instructions on the Site.

4.5 Unsuccessful Payments. If a payment to load funds into your E-Money Wallet is not successful, you authorise Bit4Me Estonia, in its sole discretion, either to cancel any related Digital Currency Transactions or to debit your other payment methods, including Bit4Me balances or other linked accounts, in any amount necessary to complete the Digital Currency Transactions in question. You are responsible for maintaining an adequate balance and/or sufficient credit limits in order to avoid overdraft, or similar fees charged by your payment provider.

4.6 Account Information. You will be able to see your E-Money Wallet balance and your transaction history using the Site, including (i) the amount (and currency) of each Digital Currency Purchase, (ii) a reference to identify the payer and / or payee (as appropriate), (iii) any fees charged (including a breakdown of the fees), (iv) where there has been a currency exchange, the rate of exchange, and the amount (in the new currency) after exchange (where you are the payer) or the amount (in the original currency) before the exchange (where you are the payee), and (v) the debit or credit date of each Digital Currency Purchase (as appropriate).

4.7 Redeeming E-Money. You may redeem all or part of any E-Money held in your E-Money Wallet at any time by selecting the relevant option in the Site and following the instructions. Unless agreed otherwise, funds will be transferred to the bank account you have registered with us. If this Agreement is terminated, we will redeem any E-Money remaining in your E-Money Wallet and attempt to transfer funds to the bank account you have registered with us. Prior to redeeming E-Money from your E-Money Wallet, we may conduct checks for the purposes of preventing fraud, money laundering, terrorist financing and other financial crimes, and as required by applicable law. This may mean you are prevented or delayed from withdrawing E-Money until those checks are completed to our reasonable satisfaction in order to comply with our regulatory requirements.

4.8 Unauthorised and Incorrect Transactions. Where a purchase of Digital Currency and / or redemption of E-Money is initiated from your E-Money Wallet using your credentials, we will assume that you authorised such transaction, unless you notify us otherwise.

If you believe that a transaction using your E-Money Wallet has been carried out that you did not authorise (an “Unauthorised Transaction”), or if you have reason to believe that a transaction using your E-Money Wallet has been incorrectly carried out or is not complete (an “Incorrect Transaction”), you must contact us as soon as possible, and in any case no later than 13 months after the Unauthorised Transaction or Incorrect Transaction occurred.

It is important that you regularly check your E-Money Wallet balance and your transaction history to ensure any Unauthorised Transactions or Incorrect Transactions are identified and notified to us at the earliest possible opportunity.

We are not responsible for any claim for Unauthorised Transactions or Incorrect Transactions unless you have notified us in accordance with this Section 4.8, in which case Section 4.9 below sets out our respective responsibilities. As further described in Section 4.9 below, we are not responsible for any claim for Unauthorised Transactions or Incorrect Transactions if you have acted fraudulently, intentionally or with negligence and this has resulted in the Unauthorised Transactions or Incorrect Transactions.

During any investigation of any actual or potential Unauthorised Transactions or Incorrect Transactions, we reserve the right to suspend your Bit4Me Account to avoid further losses.

4.9 Refund Rights.

(A) Unauthorised Transactions – E-Money Wallet.

If an Unauthorised Transaction occurs in your E-Money Wallet as a result of our failure, we will refund you the amount of that transaction by no later than the end of the next business day after becoming aware of the Unauthorised Transaction and restore your E-Money Wallet to the state it would have been in had the Unauthorised Transaction not taken place. Generally, you will not be liable for losses incurred after you have notified us of the Unauthorised Transaction or if we have failed at any time to provide you with the means for notifying us.

You will be liable for the first EUR 50 of any losses you incur in respect of an Unauthorised Transaction in your E-Money Wallet which arises from the use of lost or stolen credentials (for example when you have failed to keep the login details for your Bit4Me Account secure), and if you are fraudulent, or you intentionally or negligently fail to carry out your obligations under this Agreement and this results in Unauthorised Transactions in your E-Money Wallet (for example, if you deliberately share your email and password with a third party, or are grossly negligent in keeping your email and password secure, in both cases other than in accordance with Sections 3.2 and/or 4.10), you will be liable for all resultant losses incurred as a result of any such Unauthorised Transactions, not just the first EUR 50.

Where there is a dispute between us and you regarding whether or not a transaction is an Unauthorised Transaction, we may (but are not obliged to) temporarily credit your E-Money Wallet whilst we settle the dispute. Where we determine that the transaction was authorised, we may reverse that credit and correct errors made in any statement of E-Money Wallet without prior notice to you, although please note that during this period your E-Money Wallet may be temporarily locked to avoid further Unauthorised Transactions. You will also be liable to us (as a debt) for any E-Money you have transferred which was temporarily credited to your E-Money Wallet.

(B) Incorrect Transactions – E-Money Wallet.

Where an Incorrect Transaction is made in your E-Money Wallet as a result of our action or error we shall refund to you the amount of that transaction without undue delay and restore your E-Money Wallet to the state in which it would have been had the Incorrect Transaction not taken place. We will also endeavour to provide you with reasonable notice where possible. We will also pay any charges for which we are responsible, and for any interest which you can show that you have had to pay as a consequence of any Incorrect Transaction. Irrespective of our liability, on your request, we shall try to trace any Incorrect Transaction initiated by you free of charge. However, we cannot guarantee that we will be able to trace such transactions.

4.10 Appointment of Regulated Third Parties. You may, as set out in Section 3.2, appoint appropriately licensed third parties to access your E-Money Wallet (“Regulated Third Parties”). If you do so, you should be aware that by virtue of such access, that Regulated Third Party may access your transactional and other data, and / or may initiate transfers from your E-Money Wallet. You will be liable for any actions that any Regulated Third Parties take on your Bit4Me Account, as further set out in Section 3.2 above. We reserve the right to refuse access to any Regulated Third Parties, as set out in Section 4.11 below.

4.11 Refusing to deal with Regulated Third Parties. We may refuse access to Regulated Third Parties for objectively justified and duly evidenced reasons relating to unauthorised or fraudulent access to your E-Money Wallet, money laundering, terrorist financing, fraud, or any other financial crime, and as required by applicable law. In such cases, unless we are prohibited by applicable law, we will inform you that that Regulated Third Party’s access has been denied and the reasons why. We will permit access again once we are satisfied that the reasons for refusing access no longer exist.

4.12 Consent. By opening a Bit4Me Account you provide your explicit consent to us providing E-Money Services to you. You can withdraw this consent at any time by closing your Bit4Me Account.

For the avoidance of doubt, this consent does not relate to our processing of your personal information or your rights under and in accordance with data protection law and regulations. Please see Section 11 (Data Protection) below and our Privacy Policy for information about how we process your personal data, and the rights you have in respect of this.

5. DIGITAL CURRENCY SERVICES.

5.1 In General. Your Digital Currency Wallet enables you to send Digital Currency to, and request, receive, and store Digital Currency from, other users or third parties outside the Bit4Me Platform, by giving instructions through the Site (each such transaction is a “Digital Currency Transaction“).

The Digital Currency Exchange Service enables you to buy Digital Currency on the Bit4Me Platform using:

   (A) E-Money from your E-Money Wallet held with Bit4Me Estonia;

   (B) Central bank issued currency (such as EUR or GBP) supported by Bit4Me; and/or

   (C) Other types of Digital Currency in your Digital Currency Wallet.

Conversely, when you sell Digital Currency on the Bit4Me Platform, you may elect to receive:

   (D) E-Money into your E-Money Wallet held with Bit4Me Estonia;

   (E) Central bank issued currency (such as EUR or GBP) supported by Bit4Me; and/or

   (F) Other types of Digital Currency in your Digital Currency Wallet.

Bit4Me facilitates and enables the purchase and sale of Digital Currency between its customers on the Bit4Me Platform.

5.2 Fiat Currency Transactions (not using your E-Money Wallet) You may purchase supported Digital Currency by linking a valid payment method to your Digital Currency Wallet. You authorise us to debit funds using your selected payment method(s) to complete your purchase.

Although we will attempt to deliver Digital Currency to you as promptly as possible, funds may be debited from your selected payment method before the status of your Digital Currency Transaction is shown as complete, and the Digital Currency is delivered to your Digital Currency Wallet. You may sell Digital Currency in exchange for fiat currency (such as EUR and USD) supported by Bit4Me. In such circumstances, you authorise us to debit your Digital Currency Wallet and to send instructions to credit your selected payment method(s) in settlement of sell transactions. We will send these instructions as soon as reasonably possible. Any fiat currency should be credited to your selected payment method(s) by the end of the business day after we send such instructions.

5.3 Transaction Fulfilment. We will make reasonable efforts to fulfil all purchases of Digital Currency, but in some circumstances, we may be unable to. If this is the case, we will notify you and seek your approval to re-attempt the purchase at the current Exchange Rate (as defined below).

5.4 Availability of Payment Methods. The availability of a method of payment depends on a number of factors including, for example, where you are located, the identification information you have provided to us, and limitations imposed by third party payment processors.

5.5 Conversion Fees. Each purchase or sale of Digital Currency is subject to a fee (a “Conversion Fee“). The applicable Conversion Fee will be displayed to you on the Site prior to each transaction and is stated in each receipt we issue to you. We may adjust our Conversion Fees at any time. We will not process a transaction if the Conversion Fee and any other associated fees would, together, exceed the value of your transaction.

5.6 Exchange Rates. Each purchase or sale of Digital Currency is also subject to the Exchange Rate for the given transaction. The “Exchange Rate” means the price of a given supported Digital Currency in fiat currency as quoted on the Site. The Exchange Rate is stated either as a “Buy Price” or as a “Sell Price”, which is the price at which you may buy or sell Digital Currency, respectively.

You acknowledge that the Buy Price Exchange Rate may not be the same as the Sell Price Exchange Rate at any given time, and that we may add a margin or ‘spread’ to the quoted Exchange Rate. You agree to accept the Exchange Rate when you authorise a transaction. You can learn more about Bit4Me Europe’s Exchange Rates on our ‘Pricing and Fees Disclosures’ page on the Site. We do not guarantee the availability of any Exchange Rate. We do not guarantee that you will be able to buy and / or sell your Digital Currency on the open market at any particular price or time.

5.7 Authorisations; Reversals; Cancellations. By clicking the ‘Buy’ or ‘Sell’ button on the Site, you are authorising Bit4Me to initiate the transaction at the quoted Buy Price or Sell Price and agree to any associated Conversion Fees and Exchange Fees and any other fees.

You cannot cancel, reverse, or change any transaction marked as complete or pending. If your payment is not successful or if your payment method has insufficient funds, you authorise us, in our sole discretion, either to cancel the transaction or to debit your other payment methods, including balances on your E-Money Wallet and/or Digital Currency Wallets, in any amount necessary to complete the transaction. You are responsible for maintaining an adequate balance and/or sufficient credit limits in order to avoid overdraft, insufficient funds, or similar fees charged by your payment provider. Bit4Me reserves the right to suspend access to Bit4Me Services (including Bit4Me Consumer, Bit4Me Pro) until such insufficient payment is addressed.

5.8 Digital Currency Transactions. We will process Digital Currency Transactions in accordance with the instructions we receive from you. You should verify all transaction information prior to submitting instructions to us. We do not guarantee the identity of any user, receiver, requestee or other third party and we will have no liability or responsibility for ensuring that the information you provide is accurate and complete.

Digital Currency Transactions cannot be reversed once they have been broadcast to the relevant Digital Currency network. If you initiate a Digital Currency Transaction by entering the recipient’s email address or mobile phone number and the recipient does not have an existing Bit4Me Account, we will invite the recipient to open a Bit4Me Account. If the recipient does not open a Bit4Me Account within 30 days, we will return the relevant Digital Currency to your Digital Currency Wallet.

We may charge network fees (“miner fees”) to process a Digital Currency Transaction on your behalf. We will calculate the miner fees at our discretion, although we will always notify you of the miner fees at (or before) the time you authorise the Digital Currency Transaction. A full list of Bit4Me Europe’s miner fees can be found on our ‘Pricing and Fees Disclosures’ page on the Site. Miner fees for each individual transaction will be disclosed to you at the time of purchase on the checkout page. When you or a third party sends Digital Currency to a Bit4Me Digital Currency Wallet from an external wallet not hosted on Bit4Me, the person initiating the transaction is solely responsible for executing the transaction properly, which may include, among other things, payment of miner fees in order for the transaction to be completed successfully. Non-payment of miner fees may cause your transaction to remain in a pending state outside of Bit4Me Europe’s control and we are not responsible for delays or loss incurred as a result of an error in the initiation of the transaction and have no obligation to assist in the remediation of such transactions.

Once submitted to a Digital Currency network, a Digital Currency Transaction will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the Digital Currency network. A Digital Currency Transaction is not complete while it is in a pending state. Digital Currency associated with Digital Currency Transactions that are in a pending state will be designated accordingly and will not be included in your Digital Currency Wallet balance or be available to conduct Digital Currency Transactions until confirmed by the network.

We may also refuse to process or cancel any pending Digital Currency Transaction as required by law, regulation or any court or other authority to which Bit4Me is subject in any jurisdiction, for instance, if there is suspicion of money laundering, terrorist financing, fraud, or any other financial crime.

5.9 Supported Digital Currencies. Our Digital Currency Services are available only in connection with those digital currencies that Bit4Me supports (“Supported Digital Currencies”), and this may change from time to time.

Under no circumstances should you attempt to use your Digital Currency Wallet to store, send, request, or receive digital currencies in any form that we do not support. We assume no responsibility or liability in connection with any attempt to use your Digital Currency Wallet for digital currencies that we do not support. You acknowledge and agree that Bit4Me bears no responsibility and is not liable for any unsupported asset that is sent to a wallet associated with your Bit4Me Account.

If you have any questions about which Digital Currencies we currently support, please contact us at info@bit4me.net.

5.10 Ending support of a Digital Currency. Bit4Me may in its sole discretion terminate support for any Digital Currency. Bit4Me will provide you no less than 10 days notice (unless a shorter period is required by applicable law or a regulatory authority) via email to the email address associated with your Bit4Me account to announce the end of such support. If you do not sell or send such Digital Currency off platform during this time, Bit4Me reserves the right to withdraw such Digital Currencies from your account and credit your Bit4Me account with the market value of a supported Digital Currency or a fiat currency (which denomination will be selected in our reasonable discretion).

5.11 Recurring Digital Currency Transactions. If you set up a recurring purchase of Digital1 Currency (a “Future Transaction“), you authorise us to initiate recurring electronic payments in accordance with your selected Digital Currency Transaction and any corresponding payment accounts, such as direct debits from, or credits to, your linked bank account. Your Future Transactions will occur in identical, periodic instalments, based on your period selection (e.g., daily, weekly, monthly), until either you or Bit4Me cancels the Future Transaction.

If you select a bank account as your payment method for a Future Transaction, and such transaction falls on a weekend or public holiday in the location in which the relevant bank is located, or after the relevant bank’s business hours, the credit or debit will be executed on the next business day, although the Digital Currency fees at the time of the regularly-scheduled transaction will apply. If your bank is unable to process any payment to Bit4Me, we will notify you of cancellation of the transaction and may avail ourselves of remedies set forth in this Agreement to recover any amount owed to Bit4Me.

Bit4Me may, at any time, terminate Future Transactions by providing notice to you.

5.12 Supplemental Protocols Excluded. Unless specifically announced on the Site or via an official public statement of Bit4Me, Supported Digital Currencies excludes all other protocols and/or functionality which supplement or interact with the Supported Digital Currency. This exclusion includes but is not limited to: metacoins, colored coins, side chains, or other derivative, enhanced, or forked protocols, tokens, or coins or other functionality, such as staking, protocol governance, and/or any smart contract functionality, which may supplement or interact with a Supported Digital Currency (collectively, “Supplemental Protocols”). Do not use your Bit4Me Account to attempt to receive, request, send, store, or engage in any other type of transaction or functionality involving any such Supplemental Protocols, as the Bit4Me Platform is not configured to detect, secure, or process these transactions and functionalities. Any attempted transactions in such items will result in loss of the item.

You acknowledge and agree that Supplemental Protocols are excluded from Supported Digital Currency and that Bit4Me has no liability for any losses related to Supplemental Protocols.

5.1 Operation of Digital Currency Protocols. We do not own or control the underlying software protocols which govern the operation of Digital Currencies supported on our platform. Generally, the underlying protocols are ‘open source’ and anyone can use, copy, modify, and distribute them.

We assume no responsibility for the operation of the underlying protocols and we are not able to guarantee the functionality or security of network operations. You acknowledge and accept the risk that underlying software protocols relating to any Digital Currency you store in your Digital Currency Wallet may change.

In particular, the underlying protocols are likely to be subject to sudden changes in operating rules (including “forks”). Any such material operating changes may materially affect the availability, value, functionality, and/or the name of the Digital Currency you store in your Digital Currency Wallet. Bit4Me does not control the timing and features of these material operating changes. It is your responsibility to make yourself aware of upcoming operating changes and you must carefully consider publicly available information and information that may be provided by Bit4Me in determining whether to continue to transact in the affected Digital Currency using your Bit4Me Account. In the event of any such operational change, Bit4Me reserves the right to takes such steps as may be necessary to protect the security and safety of assets held on the Bit4Me Platform, including temporarily suspending operations for the involved digital currency(ies), and other necessary steps; Bit4Me will use its best efforts to provide you notice of its response to any material operating change; however, such changes are outside of Bit4Me’s control and may occur without notice to Bit4Me. Bit4Me’s response to any material operating change is subject to its sole discretion and includes deciding not to support any new digital currency, fork, or other actions.

You acknowledge and accept the risks of operating changes to Digital Currency protocols and agree that Bit4Me is not responsible for such operating changes and not liable for any loss of value you may experience as a result of such changes in operating rules. You acknowledge and accept that Bit4Me has sole discretion to determine its response to any operating change and that we have no responsibility to assist you with unsupported currencies or protocols

5.14Digital Currency Storage & Transmission Delays. The Bit4Me Group securely stores Digital Currency private keys, in a combination of online and offline storage. Our security protocols may delay the initiation or crediting of a Digital Currency Transaction.

5.15 Third party Payments. We have no control over, or liability for, the delivery, quality, safety, legality or any other aspect of any goods or services that you may purchase or receive from, or sell or transfer to, any third party (including other users of the Digital Currency Services). We are not responsible for ensuring that a third party buyer or a seller you transact with will complete the transaction or is authorised to do so. If you experience a problem with any goods or services purchased from, or sold to, any third party using Digital Currency transferred using the Digital Currency Services, or if you have a dispute with such third party, you should resolve the dispute directly with that third party.

If you believe a third party has behaved in a fraudulent, misleading, or inappropriate manner, or if you cannot adequately resolve a dispute with a third party, you may notify Bit4Me Support at: so that we may consider what action to take, if any.

5.16 Digital Currency Title. All Digital Currencies held in your Digital Currency Wallet are assets held by the Bit4Me Group for your benefit on a custodial basis. Among other things, this means:

   (A) Title to Digital Currency shall at all times remain with you and shall not transfer to any company in the Bit4Me Group. As the owner of Digital Currency in your Digital Currency Wallet, you shall bear all risk of loss of such Digital Currency. No company within the Bit4Me Group shall have any liability for fluctuations in the fiat currency value of Digital Currency held in your Digital Currency Wallet.

   (B) None of the Digital Currencies in your Digital Currency Wallet are the property of, or shall or may be loaned to, Bit4Me; Bit4Me does not represent or treat assets in a user’s Digital Currency Wallets as belonging to Bit4Me. Bit4Me may not grant a security interest in the Digital Currency held in your Digital Currency Wallet. Except as required by a facially valid court order, or except as provided herein, Bit4Me will not sell, transfer, loan, hypothecate, or otherwise alienate Digital Currency in your Digital Currency Wallet unless instructed by you or compelled by a court of competent jurisdiction to do so.

   (C) You control the Digital Currencies held in your Digital Currency Wallet. At any time, subject to outages, downtime, and other applicable policies, you may withdraw your Digital Currency by sending it to a different blockchain address controlled by you or a third party.

   (D) In order to more securely hold customer Digital Currency, the Bit4Me Group may use shared blockchain addresses, controlled by a member of the Bit4Me Group, to hold Digital Currencies held on behalf of customers and/or held on behalf of Bit4Me Europe. Customers’ Digital Currency is segregated from the Bit4Me Group’s (including Bit4Me Europe’s) own Digital Currency or funds by way of separate ledger accounting entries for customer and Bit4Me Group accounts. Notwithstanding the foregoing, the Bit4Me Group shall not have any obligation to use different blockchain addresses to store Digital Currencies owned by you and Digital Currencies owned by other customers or by the Bit4Me Group.

Bit4Me is under no obligation to issue any replacement Digital Currency in the event that any Digital Currency, password or private key is lost, stolen, malfunctioning, destroyed or otherwise inaccessible.

6. TRANSACTIONS LIMITS AND ENHANCED DUE DILIGENCE.

6.1 Transactions Limits. The use of all Bit4Me Services is subject to a limit on the volume, stated in EUR, GBP or other fiat currency or Digital Currency, you may transact or transfer in a given period (e.g. daily). Please see Appendix 2 (Verification Procedures and Limits) for further details. Your transaction limits may vary depending on your payment method, verification steps you have completed, and other factors. We reserve the right to change applicable limits as we deem necessary. If you wish to raise your limits beyond the posted amounts, you may contact us at info@bit4me.net.

6.2 Enhanced Due Diligence. We may require you to submit additional information about yourself or your business, provide records, and arrange for meetings with Bit4Me staff if you wish to raise your limits (“Enhanced Due Diligence“). We reserve the right to charge you costs and fees associated with such Enhanced Due Diligence although if we intend to do so, we will notify you in advance so that you can decide whether you wish to proceed with the request. In our discretion, we may refuse to raise your limits, or we may lower your limits at a subsequent time even if you have completed Enhanced Due Diligence.

7. SUSPENSION, TERMINATION, AND CANCELLATION.

7.1 Suspension, Termination and Cancellation. We may: (a) refuse to complete, or place on hold, block, cancel or reverse a transaction you have authorised (even after funds have been debited from your Bit4Me Account), (b) suspend, restrict, or terminate your access to any or all of the Bit4Me Services, and/or (c) deactivate or cancel your Bit4Me Account with immediate effect for any reason, including but not limited to where:

   (A) we reasonably believe that we need to do so in order to protect our reputation;

   (B) we are, in our reasonable opinion, required to do so by applicable law, regulation or any court or other authority to which we are subject in any jurisdiction;

   (C) we reasonably suspect you of acting in breach of this Agreement;

   (D) we reasonably suspect you to have breached our ‘Behaviour Policy’ or our ‘Policy on Prohibited Use, Prohibited Businesses and Conditional Use’ (as set out in Appendix 1);

   (E) we have concerns that a transaction is erroneous or about the security of your Bit4Me Account or we suspect that the Bit4Me Services are being used in a fraudulent or unauthorised manner;

   (F) we suspect money laundering, terrorist financing, fraud, or any other financial crime;

   (G) use of your Bit4Me Account is subject to any pending litigation, investigation, or government proceeding and / or we perceive a heightened risk of legal or regulatory non-compliance associated with your Bit4Me Account activity; and / or

   (H) you take any action that may circumvent our controls such as opening multiple Bit4Me Accounts or abusing promotions which we may offer from time to time.

We may also refuse to complete or block, cancel or reverse a transaction you have authorised where there is insufficient E-Money in your E-Money Wallet and / or insufficient Digital Currency in your Digital Currency Wallet to cover the transaction and (where applicable) associated fees at the time that we receive notification of the transaction or if your credit or debit card or any other valid payment method linked to your Bit4Me Account or Digital Currency Wallet is declined.

7.2 If we refuse to complete a transaction and / or suspend, restrict or close your Bit4Me Account, and / or terminate your use of Bit4Me Services, we will (unless it would be unlawful for us to do so) provide you with notice of our actions and the reasons for refusal, suspension or closure, and where appropriate, with the procedure for correcting any factual errors that led to the refusal, suspension or closure of your Bit4Me Account. In the event that we refuse to complete a transaction and / or suspend your Bit4Me Account we will lift the suspension or complete the transaction as soon as reasonably practicable once the reasons for refusal and / or suspension no longer exist. However, we are under no obligation to allow you to reinstate a transaction at the same price or on the same terms as the suspended, reversed or cancelled transaction.

We may suspend, restrict, or terminate your access to any or all of the Bit4Me Services and/or deactivate or cancel your Bit4Me Account, without reason by giving you two months’ notice. You acknowledge that our decision to take certain actions, including limiting access to, suspending, or closing your Bit4Me Account, may be based on confidential criteria that are essential for the purposes of our risk management and security protocols. You agree that Bit4Me is under no obligation to disclose the details of its risk management and security procedures to you.

7.3 Consequences of Termination or Suspension. On termination of this Agreement for any reason, unless prohibited by applicable law or by any court or other order to which Bit4Me is subject in any jurisdiction, you are permitted to access your Bit4Me Account:

   (A) for ninety (90) days thereafter for the purposes of transferring Digital Currency out of your Digital Currency Wallet(s) and/or out of the Bit4Me Platform; and/or

   (B) at any point in the six-year period commencing with the date of the termination of this Agreement for the purposes of transferring E-Money out of your E-Money Wallet and/or out of the Bit4Me Platform.

You are not permitted to use the Bit4Me Services or your Bit4Me Account for any other purposes during these periods and we may, at our discretion, limit the functionality of the Bit4Me Platform or access to the Site for you accordingly.

If we suspend or close your Bit4Me Account or terminate your use of Bit4Me Services for any reason, we reserve the right to require you to re-complete the procedures outlined at Section 3.3 (Identity Verification) before permitting you to transfer or withdraw Digital Currency or E-Money. You may cancel your Bit4Me Account at any time by withdrawing all balances in your E-Money Wallet(s) and Digital Currency Wallet(s) and visiting: https://www.bit4me.net. You will not be charged for cancelling your Bit4Me Account, although you will be required to pay any outstanding amounts owed to us. You authorise us to cancel or suspend any pending transactions at the time of cancellation.

8. LIABILITY

8.1 Release of Bit4Me. If you have a dispute with one or more users of the Bit4Me Services (other than Bit4Me), you agree that neither we nor our affiliates or service providers, nor any of our respective officers, directors, agents, joint venturers, employees and representatives, will be liable for any claims, demands and damages (actual and consequential, direct or indirect) of any kind or nature arising out of or in any way connected with such disputes.

8.2 Indemnification. You agree to indemnify us, our affiliates and service providers, and each of our, or their, respective officers, directors, agents, employees and representatives, in respect of any costs (including attorneys’ fees and any fines, fees or penalties imposed by any regulatory authority) that have been reasonably incurred in connection with any claims, demands or damages arising out of or related to your breach and / or our enforcement of this Agreement (including without limitation your breach of our ‘Behaviour Policy’ or our ‘Policy on Prohibited Use, Prohibited Businesses and Conditional Use’ (as set out in Appendix 1)) or your violation of any law, rule or regulation, or the rights of any third party.

8.3 Limitations of Liability. Bit4Me’s total aggregate liability to you for any individual claim or series of connected claims for losses, costs, liabilities or expenses which you may suffer arising out of, or in connection with, any breach by Bit4Me of this Agreement shall be limited to a maximum aggregate value of the combined value of the Digital Currency and E-Money on deposit in your E-Money Wallet and your Digital Currency Wallet at the time of the relevant breach by Bit4Me. Where we are considering a specific claim relating to a specific transaction this sum shall be further limited to the purchase / sale amount (as relevant) of the transaction in dispute.

8.4 Limitation of loss. In addition to the liability cap at Section 8.3 (Limitations of Liability) above, in no event shall we, our affiliates or service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any of the following types of loss or damage arising under or in connection with this Agreement or otherwise:

   (A) any loss of profits or loss of expected revenue or gains, including any loss of anticipated trading profits and / or any actual or hypothetical trading losses, whether direct or indirect, even if we are advised of or knew or should have known of the possibility of the same. This means, by way of example only (and without limiting the scope of the preceding sentence), that if you claim that we failed to process a Digital Currency Transaction properly, your damages are limited to no more than the combined value of the supported Digital Currency and E-Money at issue in the transaction, and that you may not recover for any “loss” of anticipated trading profits or for any actual trading losses made as a result of the failure to buy or sell the Digital Currency;

   (B) any loss of, or damage to, reputation or goodwill; any loss of business or opportunity, customers or contracts; any loss or waste of overheads, management or other staff time; or any other loss of revenue or actual or anticipated savings, whether direct or indirect, even if we are advised of or knew or should have known of the possibility of the same;

   (C) any loss of use of hardware, software or data and / or any corruption of data; including but not limited to any losses or damages arising out of or relating to any inaccuracy, defect or omission of digital currency price data; any error or delay in the transmission of such data; and / or any interruption in any such data; and

   (D) any loss or damage whatsoever which does not arise directly as a result of our breach of this Agreement (whether or not you are able to prove such loss or damage).

8.5 Applicable law. The limitation of liability in this Section 8 (Liability) is subject to any obligations that we have under applicable law and regulation, including our obligation to exercise reasonable care and skill in our provision of the Bit4Me Services. Nothing in this Agreement shall limit our liability resulting from our fraud or fraudulent misrepresentation, gross negligence, deliberate misconduct, for death or personal injury resulting from either our or our subcontractors’ negligence.

8.6 No Warranties. The Bit4Me Services, the Bit4Me Platform and the Site are provided on an “as is” and “as available” basis, with no further promises made by us around availability of the Bit4Me Services. Specifically, we do not give any implied warranties of title, merchantability, fitness for a particular purpose and/or non-infringement. We do not make any promises that access to the Site, any of the Bit4Me Services, or any of the materials contained therein, will be continuous, uninterrupted, timely, or error-free.

We make no representations about the accuracy, order, timeliness or completeness of historical Digital Currency price data available on the Site. Any materials, information, view, opinion, projection or estimate presented via the Site is made available by Bit4Me for informational purposes only, and is subject to change without notice. You must make your own assessment of the relevance, timeliness, accuracy, adequacy, commercial value, completeness and reliability of the materials, information, view opinion, projection or estimate provided on the Site and/or the Site. Accordingly, no warranty whatsoever is given by Bit4Me and no liability whatsoever is accepted by Bit4Me for any loss arising whether directly or indirectly as a result of you acting on any materials, information, view, opinion, projection or estimate provided in or made available through the Site and/or the Site.

The Bit4Me Services, Bit4Me Platform and Site are not intended to provide specific investment, tax or legal advice or to make any recommendations about the suitability of any investments or products for any particular investor. You should seek your own independent financial, legal, regulatory, tax or other advice before making an investment in the investments or products. In the event that you choose not to seek advice from a relevant adviser, you should consider whether the investment or product is suitable for you.

We will make reasonable efforts to ensure that Digital Currency Transactions, requests for debits and credits involving Digital Currency Wallets, E-Money Wallets, bank accounts, credit and debit cards are processed in a timely manner but Bit4Me makes no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control. We will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts, credit cards, and cheque issuances are processed in a timely manner, but we make no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control.

Except for the express statements set forth in this Agreement, you hereby acknowledge and agree that you have not relied upon any other statement or understanding, whether written or oral, with respect to your use and access of the Bit4Me Services and Site.

8.7 No Liability for Breach. We are not liable for any breach of the Agreement, including delays, failure in performance or interruption of service, where they arise directly or indirectly from abnormal and unforeseeable circumstances beyond our control, the consequences of which would have been unavoidable despite all effects to the contrary, nor are we liable where the breach is due to the application of mandatory legal rules.

9. SITE AVAILABILITY AND ACCURACY

9.1 Access & Availability. Access to Bit4Me Services may become degraded or unavailable during times of significant volatility or volume. This could result in limitations on access to your Bit4Me Account or the Bit4Me Services, including the inability to initiate or complete transactions and may also lead to support response time delays.

   (A) although we strive to provide you with excellent service, we do not guarantee that the Site or other Bit4Me Services will be available without interruption and we do not guarantee that any order will be executed, accepted, recorded, or remain open or that your Bit4Me Account will be accessible; and

   (B) please note that our customer support response times may be delayed, including during times of significant volatility or volume, especially for non-trust and safety issues.

Under no circumstances shall Bit4Me be liable for any alleged damages arising from service interruptions, delays in processing transactions, or lack of timely response from Bit4Me customer support.

9.2 Website Accuracy. Although we intend to provide accurate and timely information on the Site, the Site (including, without limitation, the Content (as defined below)) may not always be entirely accurate, complete or current and may also include technical inaccuracies or typographical errors.

In an effort to continue to provide you with as complete and accurate information as possible, information may, to the extent permitted by applicable law, be changed or updated from time to time without notice, including without limitation information regarding our policies, products and services. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the Site are your sole responsibility and we shall have no liability for such decisions.

Links to third party materials (including without limitation any websites) may be provided as a convenience but are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any such third party materials accessible or linked to from the Site.

10. CUSTOMER FEEDBACK, QUERIES, COMPLAINTS, AND DISPUTE RESOLUTION

10.1 Contact Bit4Me. If you have any feedback, questions, or complaints, contact us via email at info@bit4me.net. When you contact us please provide us with your name, email address, and any other information that we may need to identify you, your Bit4Me Account, and the transaction on which you have feedback, questions, or complaints.

10.2 Complaints. If you have a dispute with Bit4Me, you agree to contact our support team in the first instance to attempt to resolve such dispute. If we cannot resolve the dispute through our support team, you and we agree to use the complaints process set out in this Section 10.2. You agree to use this process before commencing any action as set out in Section 10.4. If you do not follow the procedures set out in this Section 10.2 before pursuing action under Section 10.4, we shall have the right to ask the relevant court/authority to dismiss your action/application unless and until you complete the following steps:

In the event of a complaint which has not been resolved through your contact with Bit4Me Support, please use our complaint form to set out the cause of your complaint, how you would like us to resolve the complaint and any other information you believe to be relevant. The complaint form can be found on the Bit4Me contact info@bit4me.net or can be requested from Bit4Me Customer Support. We will acknowledge receipt of your complaint form after you submit it. A customer complaints officer (an “Officer“) will consider your complaint. The Officer will consider your complaint without prejudice based on the information you have provided, and any information provided by Bit4Me.

Within 15 business days of our receipt of your complaint the Officer will address all points raised in your complaint by sending you an email (“Resolution Notice“) in which the Officer will: (i) offer to resolve your complaint in the way you requested; (ii) make a determination rejecting your complaint and set out the reasons for the rejection; or (iii) offer to resolve your complaint with an alternative solution. In certain circumstances, if the Officer is unable to respond to your complaint within 15 business days, the Officer will (unless prohibited by applicable law) send you a holding reply indicating the reasons for a delay in answering your complaint and specifying the deadline by which the Officer will respond to your complaint (which will be no later than 35 business days from our receipt of your complaint).

Any offer of resolution made to you will only become binding on us if accepted by you. An offer of resolution will not constitute any admission by us of any wrongdoing or liability regarding the subject matter of the complaint.

10.3 If we have not been able to resolve your complaint via the complaint process set out in Section 10.2 above, you may escalate your complaint via the dispute processes set out in Sections 10.4(A) to 10.4(B) below as applicable to you.

10.4 Both you and we agree that we shall not commence any of the dispute processes set out at Sections 10.4(A) to 10.4(B) below in relation to the whole or part of your complaint until the complaint process set out in Section 10.2 has been completed, although nothing in Section 10.2 or in this Section 10.4 shall be construed as preventing either party from seeking conservatory or similar interim relief in any court of competent jurisdiction:

   (A) E-Money Services. If your complaint relates to any E-Money Services, you may be entitled to take that complaint to the FSPO as further described in Section 4.13.

   (B) For complaints or disputes arising out of or in connection with this Agreement or the provision of Bit4Me Services, the Bit4Me Platform or the Site, that cannot be resolved via the complaint process set out in Section 10.2 above, you submit to the non-exclusive jurisdiction of the courts of Estonia without prejudice to any mandatory rights available to consumers (being individuals not engaged in conduct related to their trade, business or profession, “Consumers”) to commence proceedings against Bit4Me before the courts of the jurisdiction in which they are domiciled.

11. DATA PROTECTION.

11.1 Personal Data. You acknowledge that we may process personal data in relation to you (if you are an individual), and personal data that you have provided (or in the future provide) to us in relation to your employees and other associates, or other individuals (if you are not an individual), in connection with this Agreement, or the Bit4Me Services. We will process this personal data in accordance with the Privacy Policy, which shall form part of this Agreement. Accordingly, you represent and warrant that:

   (A) your disclosure to us of any personal data relating to individuals other than yourself was or will be made in accordance with all applicable data protection and data privacy laws, and those data are accurate, up to date and relevant when disclosed;

   (B) before providing any such personal data to us, you acknowledge that you have read and understood our Privacy Policy, a copy of which is available here: Privacy Policy, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided the individual with a copy of, or directed the individual towards a webpage containing that Privacy Policy (as amended from time to time); and

   (C) if from time to time we provide you with a replacement version of the Privacy Policy, you will promptly read that notice and provide updated copies of the Privacy Policy to, or re-direct towards a webpage containing the updated Privacy Policy, any individual whose personal data you have provided to us.

12. SECURITY

12.1 Password Security. In order to access Bit4Me Services, you will be required to create or will be given security details, including a username and password. You are responsible for keeping the electronic device through which you access Bit4Me Services safe and maintaining adequate security and control of any and all security details that you use to access the Bit4Me Services. This includes taking all reasonable steps to avoid the loss, theft or misuse of such electronic device and ensuring that such electronic device is both encrypted and password protected.

Any loss or compromise of your electronic device or your security details may result in unauthorised access to your Bit4Me Account by third-parties and the loss or theft of any E-Money, Digital Currency and/or funds held in your Bit4Me Account and any associated accounts, including your linked bank account(s) and credit card(s). You must keep your security details safe at all times. For example, you should not write them down or otherwise make them visible to others.

You should never allow remote access or share your computer and/or computer screen with someone else when you are logged on to your Bit4Me Account. Bit4Me will never under any circumstances ask you for your IDs, passwords, or 2-factor authentication codes or to screen share or otherwise seek to access your computer or account. You should not provide your details to any third party for the purposes of remotely accessing your account unless specifically authorised in accordance with Sections 3.2 and 4.10. Always log into your Bit4Me Account through the Site to review any transactions or required actions if you have any uncertainty regarding the authenticity of any communication or notice.

We assume no responsibility for any loss that you may sustain due to compromise of account login credentials due to no fault of Bit4Me and/or failure to follow the requirements set out in this Section 12.1, or follow or act on any notices or alerts that we may send to you.

12.2 Authentication and Verification. In order to access Bit4Me Services users are required to provide an email address and create a password. Bit4Me offers two-factor authentication via a user’s mobile device (Short Message Service (“SMS”) or a supported Time-based One Time Password application. A verified phone number is required to enable two-factor authentication via SMS. Users are responsible for keeping electronic devices through which Bit4Me Services are accessed safe and maintaining adequate security and control of any and all security details that are used to access the Bit4Me Services. This includes taking all reasonable steps to avoid the loss, theft or misuse of said electronic devices and ensuring that said electronic devices are password protected. Any loss or compromise of personal electronic devices or security details may result in unauthorised access of a user’s Bit4Me Account by third-parties and the loss or theft of any E-Money, Digital Currency and/or funds held in your Bit4Me Account and the misuse of any associated accounts, including linked bank account(s) and credit/debit card(s).

12.3 Security Breach If you suspect that your Bit4Me Account or any of your security details have been compromised or if you become aware of any fraud or attempted fraud or any other security incident (including a cyber-security attack) affecting you and / or Bit4Me (together a “Security Breach”), you must:

   (A) notify Bit4Me Support as soon as possible by email free of charge at: info@bit4me.net.

   (B) continue to provide accurate and up to date information throughout the duration of the Security Breach; and

   (C)you must take any steps that we reasonably require to reduce, manage or report any Security Breach.

Failure to provide prompt notification of any Security Breach may be taken into account in our determination of the appropriate resolution of the matter.

12.4 Safety and Security of Your Computer and Devices. Bit4Me is not liable for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from us.

13. GENERAL

13.1 Your Compliance with Applicable Law. You must comply with all applicable laws, regulations, licensing requirements and third party rights (including, without limitation, data privacy laws and anti-money laundering and countering the financing of terrorism laws) in your use of the Bit4Me Services, the Bit4Me Platform and the Site.

13.2 Limited Licence. We grant you a limited, non-exclusive, non-transferable licence, subject to the terms of this Agreement, to access and use the Site, and related content, materials, information (collectively, the “Content“) solely for approved purposes as permitted by us from time to time. Any other use of the Site or Content is expressly prohibited and all other right, title, and interest in the Site or Content is exclusively the property of Bit4Me and its licensors. You agree not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part.

“bit4me.net”, “Bit4Me”, “Bit4Me Pro”, “Pro.bit4me.net” and all logos related to the Bit4Me Services or displayed on the Site are trade marks or registered marks of Bit4Me or its licensors. You may not copy, imitate or use them without our prior written consent.

13.3 Prohibited and Conditional Use. In connection with your use of the Bit4Me Services, and your interactions with other users and third parties, you agree to comply with the ‘Policy on Prohibited Use, Prohibited Businesses and Conditional Use’ (as set out in Appendix 1). Nothing contained herein should be construed as granting, by implication, estoppel or otherwise, any licence or right for the E-Money or Digital Currency to be used for illegal, unlawful, fraudulent, unethical, or unauthorised purposes or to promote or facilitate any illegal, unlawful, fraudulent, unethical or unauthorised activities. We reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request.

13.4 Export Controls & Sanctions. Your use of the Bit4Me Services and the Site is subject to international export controls and economic sanctions requirements. By sending, receiving, buying, selling, trading or storing Digital Currency through the Site or Bit4Me Services, you agree that you will comply with those requirements. You are not permitted to acquire Digital Currency or use any of the Bit4Me Services through the Site if:

   (A) you are in, under the control of, or a national or resident of Cuba, Iran, North Korea, Sudan, or Syria or any other country subject to United States embargo, UN sanctions, the European Union or HM Treasury’s financial sanctions regimes (each a “Sanctioned Country“), or if you are a person on the economic sanctions lists as published from time to time by applicable authorities (including, but not limited to the U.S. Commerce Department’s Denied Persons List, Unverified List, or Entity List, or the EU financial sanctions regime (a “Sanctioned Person”); or

   (B) you intend to supply any acquired or stored Digital Currency or E-Money or Bit4Me Services to a Sanctioned Country (or a national or resident of a Sanctioned Country) or Sanctioned Person.

13.5 Amendments. We will notify you of any change to the Agreement relating to E-Money Services by email at least two months in advance. In such circumstances, you will be deemed to have accepted the change if you do not notify us otherwise prior to the date the change takes effect and continue to use the Bit4Me Services. If you do not accept the change you should let us know, and the Agreement will terminate at the end of the two-month notice. You may also end the Agreement immediately and free of charge with effect at any time before the expiry of the two-month notice.

We may make all other amendments to the Agreement (including in relation to any other Bit4Me Services) by posting the revised Agreement on the Site or by emailing it to you, indicating when the revised Agreement becomes effective. Although we will endeavour to provide you with advance notice where possible, where lawful we may indicate that the revised Agreement shall be effective immediately and if you do not agree with any such modification, you should close your Bit4Me Account and cease using the Bit4Me Services. You agree that any notification of amendments in the manner as aforesaid shall be sufficient notice to you, and your continued access and/or use of Bit4Me Services and/or the Site shall constitute an affirmative acknowledgement by you of the amendments and shall be deemed to be your acceptance of the revised Agreement.

Copies of the most up-to-date version of the Agreement will be made available in the Site at all times.

13.6 Relationship of the Parties. Nothing in this Agreement shall be deemed or is intended to be deemed, nor shall it cause, either you or Bit4Me to be treated as partners or joint ventures, or either you or Bit4Me to be treated as the agent of the other.

13.7 Privacy of Others. If you receive information about another user through the Bit4Me Services, you must keep the information confidential and only use it in connection with the Bit4Me Services. You may not disclose or distribute a user’s information to a third party or use the information except as reasonably necessary to carry out a transaction and other functions reasonably incidental thereto such as support, reconciliation and accounting unless you receive the user’s express consent to do so. You may not send unsolicited communications to another user through the Bit4Me Services.

13.8 Contact Information.You are responsible for keeping your contact details (including your email address and telephone number) up to date in your Bit4Me Account profile in order to receive any notices or alerts that we may send to you (including notices or alerts of actual or suspected Security Breaches). Please see Appendix 3 for more detail in relation to how we will communicate with you.

13.9 Taxes. It is your sole responsibility to determine whether, and to what extent, any taxes apply to any transactions you conduct through the Bit4Me Services, and to withhold, collect, report and remit the correct amount of tax to the appropriate tax authorities. Your transaction history is available through your Bit4Me Account.

13.10 Unclaimed Property. If we hold E-Money or Digital Currency on your behalf, and we are unable to contact you and have no record of your use of the Bit4Me Services for several years, applicable law may require us to report the E-Money or Digital Currency as unclaimed property to the authorities in certain jurisdictions. We will try to locate you at the address shown in our records, but if we are unable to, we may be required to deliver any such E-Money or Digital Currency to the authorities in certain jurisdictions as unclaimed property. We reserve the right to deduct a dormancy fee or other administrative charges from such unclaimed funds, as permitted by applicable law.

13.11 Death of Account Holder. For security reasons, if we receive legal documentation confirming your death or other information leading us to believe you have died, we will freeze your Bit4Me Account and during this time, no transactions may be completed until: (i) your designated executor / trustee has opened a new Bit4Me Account or informed Bit4Me about another, existing, Bit4Me Account in their name, as further described below, and the entirety of your Bit4Me Account has been transferred to such new account, or (ii) we have received proof in a form satisfactory to us that you have not died. If we have reason to believe you may have died but we do not have proof of your death in a form satisfactory to us, you authorize us to make inquiries, whether directly or through third parties, that we consider necessary to ascertain whether you have died. Upon receipt by us of proof satisfactory to us that you have died, the executor / trustee you have designated in a valid Will or similar testamentary document will be required to open a new Bit4Me Account or inform Bit4Me of another, existing Bit4Me Account in their name, to which the entirety of the funds in your Bit4Me Account shall be transferred. If you have not designated an executor / trustee, then we reserve the right to (i) treat as your executor / trustee any person entitled to inherit your Bit4Me Account, as determined by us upon receipt and review of the documentation we, in our sole and absolute discretion, deem necessary or appropriate, including (but not limited to) a Will or similar document, or (ii) require an order designating an executor / trustee from a court having competent jurisdiction over your estate. In the event we determine, in our sole and absolute discretion, that there is uncertainty regarding the validity of the executor / trustee designation, we reserve the right to require an order resolving such issue from a court of competent jurisdiction before taking any action relating to your Bit4Me Account. Pursuant to the above, unless your designated executor / trustee already holds a Bit4Me Account (in which case they may still be required to undergo additional identity verification procedures), the opening of a new Bit4Me Account by a designated executor / trustee is mandatory following the death of a Bit4Me Account owner, and you hereby agree that your executor / trustee will be required to open a new Bit4Me Account and provide the information required under Section 3 of this Agreement in order to gain access to the contents of your Bit4Me Account.

13.12 Entire Agreement. This Agreement (including documents incorporated by reference herein) comprise the entire understanding and agreement between you and Bit4Me as to the subject matter hereof, and it supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), and every nature between and among you and Bit4Me.

13.13 Interpretation. Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.

13.14 Transfer and Assignment. This Agreement is personal to you and you cannot transfer or assign your rights, licenses, interests and/or obligations to anyone else. We may transfer or assign our rights licenses, interests and / or our obligations at any time, including as part of a merger, acquisition or other corporate reorganisation involving Bit4Me, provided that this transfer or assignment does not materially impact the quality of the Bit4Me Services you receive. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns. You reserve the right to terminate the agreement with immediate effect in the event we transfer and/or assign the Agreement.

13.15 Security Interests. You must not create security over your E-Money or Digital Currency unless you have obtained our prior approval in writing.

13.16 Invalidity. If any provision of this Agreement is determined to be invalid or unenforceable under any applicable law, this will not affect the validity of any other provision. If any provision is found unenforceable, the unenforceable provision will be severed, and the remaining provisions will be enforced.

13.17 Enforcement of Our Rights. We may not always strictly enforce our rights under this Agreement. If we do choose not to enforce our rights at any time, this is a temporary measure and we may enforce our rights strictly again at any time.

13.18 Language. This Agreement and any information or notifications that you or we are to provide should be in English. Any translation of this Agreement or other documents is provided for your convenience only and may not accurately represent the information in the original English. In the event of any inconsistency, the English language version of this Agreement or other documents shall prevail.

13.19 Change of Control. In the event that Bit4Me is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you and our relationship with you (including this Agreement) as part of such merger, acquisition, sale, or other change of control.

13.20 Survival. All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, the Sections relating to suspension or termination, Bit4Me Account cancellation, debts owed to Bit4Me, general use of the Bit4Me Platform or Site, disputes with Bit4Me, and general provisions will continue to be binding and operate after the termination or expiration of this Agreement.

13.21 Governing Law and Jurisdiction. This Agreement and the relationship between us shall be governed by the laws of Estonia and the non-exclusive jurisdiction of the Irish courts, subject to any local mandatory law, or rights available to Consumers.


APPENDICES

Appendix 1 : PROHIBITED USE, PROHIBITED BUSINESSES AND CONDITIONAL USE

1. Prohibited Use. You may not use your Bit4Me Account to engage in the following categories of activity (“Prohibited Uses“). The specific types of use listed below are representative, but not exhaustive. If you are uncertain as to whether or not your use of Bit4Me Services or the Bit4Me Platform involves a Prohibited Use or have questions about how these requirements apply to you, contact us at info@bit4me.net

By opening a Bit4Me Account, you represent and warrant that you will not use your Bit4Me Account, any Bit4Me Services and/or the Bit4Me Platform to do any of the following:

   (A) Unlawful Activity: Activity which would violate, or assist in violation of, any law, statute, ordinance, or regulation or sanctions programs administered in the countries where Bit4Me conducts business, including but not limited to regulatory regimes administered by the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC“), or which would involve proceeds of any unlawful activity; publish, distribute or disseminate any unlawful material or information.

   (B) Abusive Activity: Actions which impose an unreasonable or disproportionately large load on our infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information; transmit or upload any material to the Site that contains viruses, trojan horses, worms, or any other harmful or deleterious programs; attempt to gain unauthorised access to the Site, other Bit4Me Accounts, computer systems or networks connected to the Site, through password mining or any other means; use Bit4Me Account information of another party to access or use the Site, except in the case of specific merchants and / or applications which are specifically authorised by a user to access such user’s Bit4Me Account and information; or transfer your account access or rights to your account to a third party, unless by operation of law or with the express permission of Bit4Me.

   (C) Abuse Other Users: Interfere with another individual’s or entity’s access to or use of any Bit4Me Services; defame, abuse, extort, harass, stalk, threaten or otherwise violate or infringe the legal rights (such as, but not limited to, rights of privacy, publicity and intellectual property) of others; harvest or otherwise collect information from the Site about others, including without limitation email addresses, without proper consent.

   (D) Fraud: Activity which operates to defraud Bit4Me, Bit4Me users, or any other person; provide any false, inaccurate, or misleading information to Bit4Me.

   (E) Gambling: Lotteries; bidding fee auctions; sports forecasting or odds making; fantasy sports leagues with cash prizes; internet gaming; contests; sweepstakes; games of chance.

   (F) Intellectual Property Infringement: Engage in transactions involving items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the law, including but not limited to sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorisation from the rights holder; use of Bit4Me intellectual property, name, or logo, including use of Bit4Me trade or service marks, without express consent from Bit4Me or in a manner that otherwise harms Bit4Me or the Bit4Me brand; any action that implies an untrue endorsement by or affiliation with Bit4Me.

2 Prohibited Businesses. In addition to the Prohibited Uses described above, the following categories of businesses, business practices, and sale items are barred from being carried out using Bit4Me Services or the Bit4Me Platform (“Prohibited Businesses“). Most Prohibited Businesses categories are imposed by card network rules or the requirements of our banking providers or processors. The specific types of use listed below are representative, but not exhaustive. If you are uncertain as to whether or not your use of Bit4Me Services or the Bit4Me Platform involves a Prohibited Business, or have questions about how these requirements apply to you, please contact us at: info@bit4me.net

By opening a Bit4Me Account, you represent and warrant that you will not use Bit4Me Services or the Bit4Me Platform in connection with any of the following businesses, activities, practices, or items:

   (A) Investment and Credit Services: securities brokers; mortgage consulting or debt reduction services; credit counselling or repair; real estate opportunities; investment schemes;

   (B) Restricted Financial Services: check cashing, bail bonds; collections agencies;

   (C) Intellectual Property or Proprietary Rights Infringement: sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorisation from the rights holder;

   (D) Counterfeit or Unauthorised Goods: unauthorised sale or resale of brand name or designer products or services; sale of goods or services that are illegally imported or exported or which are stolen;

   (E) Regulated Products and Services: marijuana dispensaries and related businesses; sale of tobacco, e-cigarettes, and e-liquid; online prescription or pharmaceutical services; age restricted goods or services; weapons and munitions; gunpowder and other explosives; fireworks and related goods; toxic, flammable, and radioactive materials;

   (F) Drugs and Drug Paraphernalia: sale of narcotics, controlled substances, and any equipment designed for making or using drugs, such as bongs, vaporisers, and hookahs;

   (G) Pseudo-Pharmaceuticals: pharmaceuticals and other products that make health claims that have not been approved or verified by the applicable local and/or national regulatory body;

   (H) Substances designed to mimic illegal drugs: sale of a legal substance that provides the same effect as an illegal drug (e.g. salvia, kratom);

   (I) Adult Content and Services: pornography and other obscene materials (including literature, imagery and other media); sites offering any sexually-related services such as prostitution, escorts, pay-per view, adult live chat features;

   (J) Multi-level Marketing: pyramid schemes, network marketing, and referral marketing programs;

   (K) Unfair, predatory or deceptive practices: investment opportunities or other services that promise high rewards; sale or resale of a service without added benefit to the buyer; resale of government offerings without authorisation or added value; sites that we determine in our sole discretion to be unfair, deceptive, or predatory towards consumers; and

   (L) High-risk businesses: any businesses that we believe poses elevated financial risk, legal liability, or violates card network or bank policies.

3. Conditional Use. Express written consent and approval from Bit4Me must be obtained prior to using Bit4Me Services for the following categories of business and/or use (“Conditional Uses“). Consent may be requested by contacting us at: info@bit4me.net.

Bit4Me may also require you to agree to additional conditions, make supplemental representations and warranties, complete enhanced on-boarding procedures, and operate subject to restrictions if you use Bit4Me Services in connection with any of the following businesses, activities, or practices:

   (A) Money Services: Money transmitters, Digital Currency transmitters; currency or Digital Currency exchanges or dealers; gift cards; prepaid cards; sale of in-game currency unless the merchant is the operator of the virtual world; act as a payment intermediary or aggregator or otherwise resell any of the Bit4Me Services;

   (B) Charities: Acceptance of donations for non-profit enterprise;

   (C) Games of Skill: Games which are not defined as gambling under this Agreement or by law, but which require an entry fee and award a prize; and

   (D) Religious/Spiritual Organisations: Operation of a for-profit religious or spiritual organisation.

Appendix 2: VERIFICATION PROCEDURES AND LIMITS

Bit4Me uses multi-level systems and procedures to collect and verify information about you in order to protect Bit4Me and the community from fraudulent users, and to keep appropriate records of Bit4Me’s customers. Your access to one or more Bit4Me Services or the Bit4Me Platform, and limits imposed on your use of Bit4Me Services (including but not limited to daily or weekly conversion limits, Bit4Me Pro deposit, withdrawal and trading limits, instant buy limits, Digital Currency Wallet transfer limits, and limits on transactions from a linked payment method), and any changes to such limits from time to time, may be based on the identifying information and/or proof of identity you provide to Bit4Me.

Bit4Me may require you to provide or verify additional information, or to wait some amount of time after completion of a transaction, before permitting you to use any Bit4Me Services and/or before permitting you to engage in transactions beyond certain volume limits. You may determine the volume limits associated with your level of identity verification by visiting your account’s ‘Limits’ page on the Site.

You may submit a request at info@bit4me.net to request larger limits. Bit4Me will require you to submit to Enhanced Due Diligence. Additional fees and costs may apply, and Bit4Me does not guarantee that we will raise your limits.

Appendix 3 : COMMUNICATIONS

1. Electronic Delivery of Communications. You agree and consent to receive electronically all communications, agreements, documents, notices and disclosures (collectively, “Communications“) that we provide in connection with your Bit4Me Account and your use of Bit4Me Services. Communications include:

   (A) terms of use and policies you agree to (e.g. the Agreement and Privacy Policy), including updates to these agreements or policies;

   (B) account details, history, transaction receipts, confirmations, and any other account or transaction information;

   (C) legal, regulatory, and tax disclosures or statements we may be required to make available to you; and

   (D) responses to claims or customer support inquiries filed in connection with your Bit4Me Account.

Unless otherwise specified in this Agreement, we will provide these Communications to you by posting them on the Site, emailing them to you at the primary email address listed in your Bit4Me Account, communicating to you via instant chat, and/or through other electronic communication such as text message or mobile push notification, and you agree that such Communications will constitute sufficient notice of the subject matter therein.

2. How to Withdraw Your Consent. You may withdraw your consent to receive Communications electronically by contacting us at: info@bit4me.net. If you fail to provide or if you withdraw your consent to receive Communications in the specified manners, Bit4Me reserves the right to immediately close your Bit4Me Account or charge you additional fees for paper copies of the Communications.

3. Updating your Information. It is your responsibility to provide us with a true, accurate and complete email address and your contact information, and to keep such information up to date. You understand and agree that if Bit4Me sends you an electronic Communication but you do not receive it because your primary email address you have provided is incorrect, out-of-date, blocked by your service provider, or you are otherwise unable to receive electronic Communications, Bit4Me will be deemed to have provided the Communication to you. You may update your information by logging into your Bit4Me Account and visiting settings or by contacting our support team at: info@bit4me.net.

Appendix 4 : DEVELOPER’S TOOLS LICENSE

Developer’s Tools. Eligible users may establish an account for the use of the Bit4Me application programming interface and any accompanying or related documentation, source code, executable applications and other materials (the “Bit4Me API“), the ‘Bit4Me Sandbox’, available at bit4me.net, and any other resources or services available at .bit4me.net, (collectively, the Developer’s Tools).

The Bit4Me Developer Agreement, which shall form part of this Agreement and is set out at bit4me.net (which may be amended from time to time), shall apply to your use of the Developer’s Tools in addition to the other provisions of this Agreement including without limitation the releases, indemnities, disclaimers, limitations of liability, prohibited use, dispute resolution, and cancellation policies set forth above. Bit4Me does not offer the Developer’s Tools to customers in all jurisdictions.

Bit4Me Global Privacy Policy

We at Bit4Me (defined below) respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the websites located at bit4me.net, custody.bit4me.net, or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”).

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request via our Support Portal at www.bit4me.net.

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

1. ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

 

. THE PERSONAL INFORMATION WE COLLECT

Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

Information you provide to us. To establish an account and access our Services, we’ll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you’d like to link that account to CB), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.

If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.

We may collect the following types of information from you:

  • Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
  • Formal Identification Information: Government issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
  • Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
  • Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
  • Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • Employment Information: Office location, job title, and/or description of role.
  • Correspondence: Survey responses, information provided to our support team or user research team.
  • Audio, electronic, visual and similar information, such as call and video recordings.

Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

  • Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
  • Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

  • How you came to and use the Services;
  • Device type and unique device identification numbers;
  • Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
  • How your device interacts with our Sites and Services, including pages accessed and links clicked;
  • Broad geographic location (e.g. country or city-level location); and
  • Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.

Information we collect from our affiliates and third parties. From time to time, we may obtain information about you from our affiliates or third party sources as required or permitted by applicable law. These sources may include:

  • Our Bit4Me Family of Companies: Our “family of companies” is the group of companies related to us by common control or ownership (“Affiliates”). In accordance with applicable law, we may obtain information about you from our Affiliates as a normal part of conducting business, if you link your various Bit4Me accounts (e.g., Bit4Me Wallet account or Bit4Me Commerce account in order to convert cryptocurrency into fiat and make withdrawals into your bank account), so that we may offer our Affiliates’ Services to you.
  • Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners like World-Check use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others. World-Check’s Privacy Policy, available at https://www.refinitiv.com/en/products/world-check-kyc-screening/privacy-statement/, describes its collection and use of personal data.
  • Blockchain Data: We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
  • Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.
  • Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation. For more information on how you can manage collection of this data, please see our Cookie Policy.

4. ANONYMIZED AND AGGREGATED DATA

Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).

Bit4Me may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.

Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.

5. HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

1) To maintain legal and regulatory compliance

Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, CB must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. This includes collection and storage of your photo identification. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your CB Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we will have to close your account.

2) To enforce our terms in our user agreement and other agreements

CB handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.

3) To detect and prevent fraud and/or funds loss

We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.

4) To provide Bit4Me’s Services

We process your personal information to provide the Services to you. For example, when you want to store funds on our platform, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.

5) To provide Service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

6) To provide customer service

We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

7) To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.

8) To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

9) For research and development purposes

We process your personal information to better understand the way you use and interact with Bit4Me’s Services. In addition, we use such information to customize, measure, and improve Bit4Me’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

10) To enhance your experience

We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

11) To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.

12) To engage in marketing activities

Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.

13) To protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our locations, to maintain security at such locations you may be photographed or videotaped.

14) For any purpose that you provide your consent. 

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or CB Services may not be available to you.

For individuals who are located in the European Economic Area, the United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal information is collected, our legal bases for processing your information under the EU General Data Protection Regulation (“GDPR”) will depend on the personal information at issue, the specific context in the which the personal information is collected and the purposes for which it is used. We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms, or where we have obtained your consent to do so. In some rare instances, we may need to process your personal information to protect your vital interests or those of another person. Below is a list of how CB uses your personal information, as described above in Section 5, with the corresponding legal bases for processing. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

 

Section & Purpose of Processing Legal Bases for Processing
(2) To enforce our terms in our user agreement and other agreements (4) To provide Bit4Me’s Services (5) To provide Service communications (6) To provide customer service (7) To ensure quality control Based on our contract with you or to take steps at your request prior to entering into a contract.
(9) For research and development purposes (10) To enhance your experience (11) To facilitate corporate acquisitions, mergers, or transactions (12) To engage in direct marketing activities Based on our legitimate interests. When we process your personal data for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.
(1) To maintain legal and regulatory compliance (3) To detect and prevent fraud and/or funds loss (8) To ensure network and information security (13) To protect your or our’s vital interests Based on our legal obligations, the public interest, or in your vital interests.
(10) To enhance your experience (12) To engage in third party marketing activities (14) For any purpose to which you consent Based on your consent.

 

How to lodge a complaint

If you believe that we have infringed your rights, we encourage you to submit a request via our info@bit4me.net so that we can try to resolve the issue or dispute informally.

Do Not Track

Some Internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, we do not currently process or respond to “DNT” signals.

16. HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, a contact us at info@bit4me.net, or by writing to us at the address of your operating entity (provided above).

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