Legal

Newsroom

This agreement was written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.Date of Last Revision: May 1, 2020

Introduction:


The mission of PAIBLOCK is provide users with a mobile wallet, and services providers, governments and card issuers a means to service it.

We adhere to the following principles to protect your privacy:
We do not rent, sell, or otherwise provide your personally identifiable information to third parties without your consent, except as described in this policy or as required by law. We do not share any information you have not chosen to display on your PAIBLOCK profile to other parties, unless compelled by law, or as necessary to enforce our User Agreement or protect the rights, property, or personal safety of PAIBLOCK, its Users, and the public. All information that you provide will be protected with industry standard protocols and technology. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by means of a notice on our home page so that you may access and review the changes to this document in advance of your continued use of the service. If you object to any changes, you may close your account. By continuing to use the PAIBLOCK service after notice of changes has been sent to you or published on the PAIBLOCK website, you are consenting to the changes.

1. Information Collected


PAIBLOCK makes features and functionality available through our website, including our mobile applications, basic and premium services, and other information provided as part of the PAIBLOCK services (“Services”). By joining PAIBLOCK, you voluntarily and willingly provide PAIBLOCK Technologies in Denmark, certain information, including personally identifiable information, which we collect in order to provide the Services. If you have any hesitation about providing information to us and/or having your information displayed on the PAIBLOCK website or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a member of the PAIBLOCK; and, if you are already a member, you should close your account.
We collect your personal information in the following ways:

A Registration


In order to become a User, you must provide us the following information to create an account: name, email address, country, and password. Without this minimal amount of information, you cannot create a PAIBLOCK account. Like other passwords, you should choose one that is known only by you. PAIBLOCK requests other information from you during the registration process, (e.g., gender, location, etc.) that PAIBLOCK uses to provide better, more customised services such as language-specific profile pages and updates.

B. Profile Information


Once you become a User, you may provide additional information to your PAIBLOCK Profile. Providing additional information about yourself beyond what is minimally required at registration is entirely up to you,

C. Financial account


For In-app banking users we collect the following types of identifiers, commercial information, and other personal information from your financial product and service providers:
. Account information, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, and account and routing number;
. Information about an account balance, including current and available balance;
. Information about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
. Information about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
. Information about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
. Identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information;
. Information about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and
. Professional information, including information about your employer, in limited cases where you’ve connected your payroll accounts.

The data collected from your financial accounts includes information from all your accounts (e.g., checking, savings, and credit card) accessible through a single set of account credentials.


D. Personally identifiable information


Paiblock operates in compliance with anti-money laundering and know your customer rules and regulations. In order to access certain type of services, we collect the following information: full name, telephone, mail address, residential address copy, date of birth, Nationality, copy of government ID, personal photograph (with ID in Hand), description of Source of Funds (tax return, salary slips).

E. Contacts Information


In order to connect with others on PAIBLOCK, you may use the Services to send invitations either to their PAIBLOCK profiles or email addresses of people you know if they have not registered with PAIBLOCK. The names and email addresses of people whom you invite will be used to send your invitations and reminders. Please note that when you send an invitation to connect to another User, that User will have access to your email address because it is displayed in the invitation.

F. Customer Service


We collect information when you interact with PAIBLOCK’s customer service website in order to accurately categorize and respond to customer inquiries and investigate breaches of our terms.

G. Using the PAIBLOCK Site and Applications


We receive information when you interact with and use the PAIBLOCK website, PAIBLOCK Applications (e.g. PAIBLOCK for iPhone, Android, etc.), and PAIBLOCK platform technology (such as “Puut API”).

H. Cookies


We use cookies and web log files to track site usage and trends, to improve the quality of our service, to customise your experience on PAIBLOCK, as well as to deliver PAIBLOCK and third-party advertising to Users both on and off the PAIBLOCK site. A cookie is a tiny data file that resides on your computer, mobile phone, or other device, and allows us to recognize you as a User when you return to the PAIBLOCK website using the same computer and web browser. You can remove or block cookies using the settings in your browser, but in some cases doing so may impact your ability to use PAIBLOCK. One type of cookie, known as a “persistent” cookie, is set once you’ve logged in to your PAIBLOCK account. The next time you visit the PAIBLOCK website, the persistent cookie will allow us to recognize you as an existing User so you will not need to log in before using the Services. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the PAIBLOCK website. Session cookies expire after a short time or when you close your web browser.

I. Log files,


Due to the communications standards on the internet, when you visit the PAIBLOCK website we automatically receive the URL of the site from which you came and the site to which you are going when you leave PAIBLOCK. PAIBLOCK also receives the internet protocol (“IP”) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, your mobile device (including your UDID) and mobile operating system (if you are accessing PAIBLOCK using a mobile device), as well as the name of your ISP or your mobile carrier. PAIBLOCK may also receive location data passed to it from third-party services or GPS-enabled devices that you have enabled.

J. Rights to Access


You have a right to access, modify, correct and eliminate the data you supplied to PAIBLOCK. If you update any of your information, we may keep a copy of the information that you originally provided to us in our archives for uses documented in this policy. You may request deletion of your information at any time by contacting PAIBLOCK customer service. We will respond to your request within 30 days. Please note, however that information you have shared with others, or that other Users have copied, may also remain visible even if you request its deletion.

K. Data Retention


PAIBLOCK will retain your information for so long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this Agreement.

2. Uses of personal information



A. Consent


The information you provide to PAIBLOCK may reveal, or allow others to identify, your nationality, ethnic origin, gender, age, and other aspects of your life. By providing information to us for the purposes of creating your User account or adding any additional details to your PAIBLOCK profile, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and PAIBLOCK’s User Agreement that allow PAIBLOCK to process information about you. Supplying information to PAIBLOCK, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part. You have the right to withdraw your consent to PAIBLOCK’s collection and processing of your information at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your preferences, or by closing your account, but please note that your withdrawal of consent will not be retroactive.

B. PAIBLOCK Communications


As described in the User Agreement, we will communicate with you through email, notices posted on the PAIBLOCK website, messages to your PAIBLOCK inbox, or through other means available through the service, including mobile text messages. We may send you a series of emails that help inform new Users about the features of the Services, and we will also send you service messages relating to the functioning of the Services. We may also send you messages with promotional information directly or on behalf of our partners, unless you have opted out of receiving promotional information.
You can change your e-mail and contact preferences at any time by logging into your account. If you wish, you can also opt-out of receiving promotional emails by sending a request to PAIBLOCK customer service through our customer service site.
Please be aware that you cannot opt-out of receiving service messages from PAIBLOCK. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges).

C. User Communications


Many communications you initiate through will list your primary email address and name in the header of the message. Your contact information will only be shared with another User if both of you have indicated that you would like to establish contact with each other.

D. Customised Content


We use information you provide to us (or to third parties with whom PAIBLOCK offers remote services) to customise your experience on our website.

E. Sharing Information


We do not sell, rent, or otherwise provide your personally identifiable information to third parties, except as described in this policy. We will also not share other personal information without your explicit consent or to carry out your instructions (for example, to process payment information) unless, disclosure is reasonably necessary in our opinion to: (1) comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Agreement; (3) respond to claims of a violation of the rights of third parties, whether or not the third party is a User, individual, or government agency; (4) respond to customer service inquiries; or (5) protect the rights, property, or personal safety of PAIBLOCK, our Users or the public.
We may provide aggregated anonymous data about the usage of the Services to third parties for purposes that we deem, in our sole discretion, to be appropriate, including to prospective advertisers on PAIBLOCK.

F. Services providers


We collaborate with and allow third parties to use PAIBLOCK’s platform to offer services and functionality in conjunction with and outside of PAIBLOCK. These third parties are partners (“Puut Partners”) with whom we have negotiated an agreement to provide services (“Remote Services”). These partners have accepted our API terms and conditions and includes services providers governments and card issuers.
Despite our agreements and technical steps taken to restrict access to and avoid possible misuse of information, we may not screen or audit all Remote Services. We also cannot guarantee that any PAIBLOCK Partner will abide by our agreement. You agree that your use of Remote Services is on an “as is” basis and without any warranty.
If you use any Remote Service, the PAIBLOCK Partner may access and share certain information about you, such as non-public profile. This includes information about your wallet number.

G. Polls and Surveys


Polls and Surveys may be conducted by PAIBLOCK, PAIBLOCK Users or third parties. As a User, you may be invited to participate in polls and surveys from the PAIBLOCK website. Your selection may be random, or it may be based on your non-personally identifiable information, such as job title, geography, company size and/or industry. Whether or not you decide to participate in a poll or survey is completely up to you.
After you complete a poll, you will be given access to the aggregate responses of the poll on a results page. Some third parties may target advertisements to you on the results page based on your answers in the poll
We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personally identifiable information to the third party fulfilling the incentive offer, which will only be used for the purpose of delivering incentives and/or verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive.
We will not disclose any personally identifiable information to any third parties in connection with the conduct of any polls or surveys. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

H. Search


We offer search services solely for finding a user you are likely to know and to send a friendship request.

I. Compliance


It is possible that we may need to disclose personal information, profile information and/or information about your activities as a PAIBLOCK User when required by subpoena or other legal process, or if PAIBLOCK has a good faith belief that disclosure is necessary to (a) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) to enforce the User Agreement, to investigate and defend ourselves against any third party claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property or personal safety of PAIBLOCK, our Users, employees, or others.

J. Disclosures to Others as the Result of a Change in Control or Paiblock A/S


We may also disclose your personal information and other information you provide to another third party as part of a sale of the assets of Paiblock A/S, a subsidiary or division, or as the result of a change in control of the company. Any third party to which PAIBLOCK transfers or sells PAIBLOCK’s assets will have the right to continue to use the personal and other information that you provide to us.

3. Your Information Choices



A. Accessing Your Account


You can review the personal information you provided to us and make any desired changes to the information you publish, or to the settings for your PAIBLOCK account including your email and contact preferences, at any time by logging in to your account on the PAIBLOCK website. Please be aware that even after your request for a change is processed, PAIBLOCK may, for a time, retain residual information about you in its backup and/or archival copies of its database.

B. Closing Your Account


You can close your account through the PAIBLOCK customer service site. If you close your PAIBLOCK account, we will remove your name and other personally identifiable information from our publicly viewable database. If you close your account, we have no obligation to retain your information, and may delete any or all of your account information without liability. However, we may retain certain data contributed by you if PAIBLOCK believes it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. PAIBLOCK may also retain and use your information if necessary to provide the Services to other Users. Similarly, other information you have shared with others, or that other Users have copied, may also remain visible. PAIBLOCK disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information. PAIBLOCK does not control when search engines update their cache, which may contain certain public profile information that has since been removed from PAIBLOCK’s publicly viewable database.

C. Memorializing Accounts


If we learn that a User is deceased, we may memorialize the User’s account. In these cases we may restrict profile access, remove messaging functionality, and close an account if we receive a formal request from the User’s next of kin or other proper legal request to do so.

4. Your Obligations


As a User, you have certain obligations to other Users. Some of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members such as PAIBLOCK:

You must, at all times, abide by the terms and conditions of the then-current Privacy Policy and User Agreement. This includes respecting all intellectual property rights that may belong to third parties (such as trademarks or photographs). You must not download or otherwise disseminate any information that may be deemed to be injurious, violent, offensive, racist or xenophobic, or which may otherwise violate the purpose and spirit of PAIBLOCK and its community of Users. You must not provide to PAIBLOCK and/or other Users information that you believe might be injurious or detrimental to your person or to your professional or social status. You must keep your username and password confidential and not share it with others. Any violation of these guidelines may lead to the restriction, suspension or termination of your account at the sole discretion of PAIBLOCK.

5. Security


In order to help secure your personal information, access to your data on PAIBLOCK is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the PAIBLOCK website. To protect any data you store on our servers, PAIBLOCK also regularly audits its system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to PAIBLOCK. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Users of PAIBLOCK are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

6. How to contact us


If you have questions or comments about this Privacy Policy, please contact us at:

Paiblock A/S
Attn: Legal Department, Privacy Policy Issues
Engager 2-4
DK-2605 Broenby
Denmark

This agreement was written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.Date of Last Revision: May 1, 2020

Please read the terms and conditions of this license agreement (the “License”) before installing and/or using the computer and mobile software (the “Software”). By installing and using the Software you accept and agree to the terms of this License. This License constitutes the entire agreement concerning the Software between you and Paiblock A/S (“Paiblock”) and it supersedes any prior proposal or representation. If you do not agree with these terms and conditions, promptly un-install the Software and.

The term “Software” includes, and these terms and conditions also apply to, any updates, modifications and upgrades to the Software that you may receive from time to time.

1. License Grant


This License permits you, as user of the Software, to use one copy of the Software solely for your use on one wireless device per copy of the software. You agree that you will not sub-license, assign, transfer, distribute, pledge, lease, rent or share your rights under this License except with prior written permission from “Paiblock”. You agree that you will not modify, adapt or translate, disassemble, decompile, reverse engineer or otherwise attempt to discover the source code of the Software.

2. Standard Maintenance and Support


All updates and technical support for your Software are free of charge for the license duration.

3. “Paiblock”’s Rights


You acknowledge and agree that the Software and Documentation (the “Licensed Products”) are proprietary products of “Paiblock” under international copyright law and disclosed to you by “Paiblock” in confidence. You shall take all reasonable steps to safeguard the Licensed Products. “Paiblock” owns and retains all copyright-, trademark-, trade secret- and other proprietary rights in and to the Licensed Products. This License conveys only a non-exclusive and limited right of use to you, revocable in accordance with the terms and conditions of this License.

4. Service Level Agreements


PAIBLOCK provides online support and email support for all licensed software for the duration of the license. Support services for enterprise products may be purchased under separate agreement with “Paiblock”.

5. Disclaimers


“Paiblock” does not warrant that the Software, its use, operation or your ability to use the Software will be uninterrupted or error-free or that all Software errors will be corrected. “Paiblock” does not warrant that the Software or service will meet your requirements or that the operation of the Software will be uninterrupted or error free.

6. Refund Policy


All fees and charges are nonrefundable and there are no refunds or credits for partially used periods. All features acquired as part of your account, expire immediately upon cancellation or termination of your account.

7. Limitations of Liability


In no event shall “Paiblock” be liable for any damages to you or any other party whether arising out of contract or from tort including loss of data, profits or business, or other special, incidental, exemplary or consequential damages, even if “Paiblock” has been advised of the possibility of such loss or damages. “Paiblock”’s cumulative liability shall not exceed the license fee paid, if any, for use of this Software and Documentation. This section shall survive termination of this License.

8. Termination


This agreement is in effect until terminated. You may terminate the agreement at any time by destroying all copies of the Software and Documentation and erasing any copies on storage media, and closing your account. The agreement also terminates if you fail to comply with any terms and conditions of this agreement. In such an event, you agree to destroy and erase all copies of the Software and Documentation.

9. General


This agreement is governed by the laws of Denmark.

10. Contract


Use of the Software other than for your internal operations on a single computer or mobile device requires that you enter into a separate license agreement with “Paiblock”.

11. Communication

For purposes of service messages and notices about the Services to you, PAIBLOCK may place a banner notice across its pages to alert you to certain changes such as modifications to this Agreement. Alternatively, notice may consist of an email from PAIBLOCK to an email address associated with your account, even if we have other contact information. You also agree that PAIBLOCK may communicate with you through your PAIBLOCK account or through other means including email, mobile number, telephone, or delivery services including the postal service about your PAIBLOCK account or services associated with PAIBLOCK.

This agreement was written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.Date of Last Revision: May 1, 2020



The following guidelines are provided for the use of certain copyrighted materials, such as images, box shots, screen shots, and text; and for the use of certain trademarked materials, such as logos, marks, and icons. These materials are owned by Paiblock A/S (“Paiblock”) and provided under license. To use such materials, you must first agree to the following license terms:

1. The materials available for download on this site are subject to these license terms, as well as any specific guidelines contained herein. If you download any materials from this site, you agree to be bound by these license terms as well as the specific guidelines related to the materials you wish to download.

2. You may not sell, alter, modify, license, sublicense, copy, or use the materials in any way other than has been specifically authorized by PAIBLOCK in the permissions and trademark guidelines described herein.

3. You acknowledge that PAIBLOCK reserves the right to revoke the authorization to view, download, and print the materials available on this site at any time, and for any reason; and such authorization shall be deemed to be discontinued immediately upon the removal of these materials from the site.

4. You acknowledge that any rights granted to you constitute a license and not a transfer of title. You do not obtain any ownership right, title, or other interest in PAIBLOCK copyrighted materials or trademarks by downloading, copying, or otherwise using these materials.

5. PAIBLOCK SHALL NOT BE LIABLE TO YOU OR ANY OTHER PARTY FOR ANY LOSS OF REVENUE OR  PROFIT OR FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR OTHER  SIMILAR DAMAGES, WHETHER BASED ON TORT (INCLUDING, WITHOUT LIMITATION, NEGLIGENCE OR STRICT LIABILITY), CONTRACT, OR OTHER LEGAL OR EQUITABLE GROUNDS EVEN IF PAIBLOCK HAS BEEN ADVISED OR HAD REASON TO KNOW OF THE POSSIBILITY OF SUCH DAMAGES. ANY MATERIALS ARE PROVIDED ON AN “AS IS” BASIS. PAIBLOCK SPECIFICALLY DISCLAIMS ALL EXPRESS, STATUTORY, OR IMPLIED WARRANTIES RELATING TO THESE MATERIALS, INCLUDING BUT NOT LIMITED TO THOSE CONCERNING MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF ANY THIRD-PARTY RIGHTS REGARDING THE MATERIALS.

This agreement was written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.Date of Last Revision: May 1, 2020



WHEREAS

•PAIBLOCK has developed and distributes PAIBLOCK App and PAIBLOCK APIs, and owns the copyright in all Components thereof;
•You develop and distribute a software or hardware product that works with a PAIBLOCK API;
•PAIBLOCK is willing to allow You to use certain Components of PAIBLOCK App in order to ensure coherent user experience throughout PAIBLOCK App and the Products;

NOW THEREFORE, PAIBLOCK enters into this License Agreement with You as follows:

0. Definitions



Component - Icon or UI String.

Component Archive - an archive file created by PAIBLOCK containing individual Components, list of their associated Use Cases, and this License.

Icon - a graphical representation of an Use Case.

Product - a software or hardware product designed by You to work with a PAIBLOCK API.

Paiblock - a software application created by PAIBLOCK

PAIBLOCK API - any computer program created by PAIBLOCK.

Use Case - requirements and/or specifications describing an action or a state of PAIBLOCK App are or a Product. The names of Components in the Component Archive shall be relied on as Use Cases, unless there is a more detailed specification/description in the Component Archive, in which case the more detail description shall be relied on as the prevailing Use Case.

You - the individual or legal entity who owns the copyright in a Product.

1. Grant of License


Subject to the restrictions set forth in Article 2 below, PAIBLOCK grants You a personal, non-exclusive, non-transferable, non-assignable, worldwide, revocable royalty-free license to incorporate individual Components into your Products and to distribute the Components along with your Products.

2. Restrictions


You must:
use each Component to represent an action in, or a state of the Product that is consistent with the Use Case associated with this Component in the Component Archive;

not modify the Components in any way (except if Your Product, development tools or operating environment require the icons to be stored in file formats other than PNG, then You may perform the most lossless conversion to Your required file format);
•never use the name or any other trademarks of PAIBLOCK to endorse or promote your product without prior written permission from PAIBLOCK.

Your Product must:
•be designed to work with PAIBLOCK APIs;
be developed and distributed according to any then-current terms and conditions covering the use of any PAIBLOCK APIs concerned;
•not be reasonably considered to adversely affect the performance of PAIBLOCK App or PAIBLOCK Services, or to otherwise harm PAIBLOCK’s brand or good name;
reasonably allow its user to find Your contact details (Puut name or e-mail address under which You can be reached when necessary) from the user interface or documentation of the Product;
•reproduce, in the reasonable location of its user interface or documentation, the entire disclaimer set forth in Article 4 below.
If You distribute Your Product under an open-source license or any other license that permits making derivative works of the Product, then You must include the complete unmodified Component Archive with the source code of your Product.

3. Termination


If PAIBLOCK becomes aware that Your Product violates any of the restrictions above or breaches any of the terms of this liencse, PAIBLOCK will notify You of the violation and/or breach. If You fail to bring the Product into compliance with the above terms within 30days from the date of notification, this license will automatically terminate with regard to that Product. Upon termination you agree to immediately stop any further use and distribution of the icons. No party will be liable to any other for compensation, indemnity or damages of any sort solely as a result of terminating this license in accordance with its terms, and termination of this license will be without prejudice to any other right or remedy of any party.

4. Disclaimer


Portions copyright © 2011-2020 Paiblock A/S. All rights reserved.

This product contains certain non-functional components that are property of Paiblock A/S (Puut). PAIBLOCK has licensed these components to the creator of this product “as is” and disclaims any express or implied warranties, including but not limited to the implied warranties of merchantability and fitness for a particular purpose. In no event shall PAIBLOCK or its contributors be liable for any direct, indirect, incidental, special, exemplary, or consequential damages (including, but not limited to, procurement of substitute goods or services; loss of use, data, or profits; or business interruption) however caused and on any theory of liability, whether in contract, strict liability, or tort (including negligence or otherwise) arising in any way out of the use of this product, even if advised of the possibility of such damage).

Know your Customer (KYC) and Anti-Money Laundering (AML) Policy and Procedures


These procedures were written in English. To the extent any translated version of these procedures conflicts with the English version, the English version controls. Date of Last Revision: January 6, 2020

The Paiblock (the “Company”) is supervised by the Danish Financial Supervisory Authority (Finantilsynet). As a regulated entity, the Company has in place policy and procedures to prevent money laundering and any activity that facilitates money laundering and/or the funding of terrorist or criminal activities in accordance with all applicable laws.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations, rules and laws and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The Company operates in compliance with ‘anti-money laundering (“AML”) and ‘know your customer’ (“KYC”) rules and regulations in the jurisdictions it operates in or sells products or services to and has developed this KYC and AML Policy to protect itself from involvement in money laundering or suspicious activity as follows:

- The Company is performing an enterprise-wide risk assessment to determine the risk profile of the Company.
- The Company has established KYC and AML policies and procedures that have been reviewed and approved by the Company’s Board of Directors (the “Board”).
- The Company is implementing internal controls throughout its operations designed to reduce risks of money laundering.
-The Company performs know your customer (“KYC”) procedures on all virtual and/or exchange wallet holders.

POLICIES AND PROCEDURES


1.Virtual and exchange wallet holders Identification (Know Your Customer)



The Company shall collect the following information about each virtual and exchange wallet holders:

i. Private Transactions up to 50.00 Euro.


For contributions up to 50.00 Euro the virtual and exchange wallet holder’s profile must contains the following information:
 - First and last name of the contributor
 - Telephone number
 - Email address.

ii. Private Transactions up to 400.00 Euro/day and 1.000.00 Euro/year.


For contributions up to 400.00 Euro/day and 1.000,00 Euro/year the virtual and exchange wallet holder’s profile must contain the following information:
 - Name of the contributor
 - Social security number
 - Residential address
 - Date of birth
 - Nationality
 - Telephone number
 - Email address

iii. Private Transactions up to 1.350,00 Euro/day and 20.000,00 Euro/year (optional).


For the contributions up to 1.350,00 Euro/day and 20.000,00 Euro/year the virtual and exchange wallet holder’s profile must contain below information. In addition the virtual and exchange wallet holder should complete digital identity verification.
 - Name of the contributor
 - Social security number
 - Residential address
 - Date of birth
 - Nationality
 - Telephone number
 - Email address.

iv. Private Transactions up to 3.000,00 Euro/day and 40.000,00 Euro/year


 - Full Name
 - Telephone
 - Email address
 - Residential Address
 - Copy (front and back) of ID
 - Data collected from ID: Date of birth, Nationality, ID scan
 - Personal photograph (with ID in Hand)
 - Proof of address (utility bill)

v. Any Transactions equal to or above 3.000,00 Euro/day and 40.000,00 Euro/year


1.1.Individuals


 - Full Name
 - Telephone
 - Email address
 - Residential Address
 - Copy (front and back) of ID
 - Data collected from ID: Date of birth, Nationality, ID scan
 - Personal photograph (with ID in Hand)
 - A Description of Source of Funds

1.2. Companies Summary of information requested/gathered


 - Company Name
 - Company Address
 - Description of Business Activities
 - Government-issued business registration number or tax identification number
 - Copy of a recent trade register extract or similar document
 - Authorised Representative (Individual KYC process)

2. AML Screening


The Company shall screen each virtual and exchange wallet holder for matches in the following categories:
 - Global Sanctions List
 - OFAC Sanctions List.
PEPs - Screening virtual and exchange wallet holders for identification as a "politically exposed person". A PEP is a term describing someone who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they could hold.
Adverse Media - Screening virtual and exchange wallet holders against adverse media involves looking for any negative mentions of them in traditional news media and publicly available information more broadly. Any virtual and exchange wallet holder that has a match on any of the above categories shall be flagged and blocked pending review by the Company of the red flag. Virtual and exchange wallet holders will receive an email informing them that their wallets are under review. A follow-up email further inform them of the outcome of the review

3. Dispositions of AML Flags


Global Sanctions List - If the flag is a match on the Global Sanctions List, the Company shall deny virtual and exchange wallet holders access to virtual and exchange wallet service and promptly inform them about the status of their wallets.
PEPs - If the flag is a match on PEPs, the Company shall review the AML report and may request additional verification information.
 - After receiving any additional verification information, the Company shall provide the virtual and exchange wallet holders with notice of disposition.
 - Adverse Media - If the flag is a match on Adverse Media, the Company shall review the adverse media and make a determination on whether to allow the virtual and exchange wallet holder.