Terms of Use

ACCEPTANCE OF TERMS OF USE – DigitalfFinpay

By using this website (“Site”), registering for a Digitalfinpay Account (“Account”) or using any other DigitalfFinpay Services, you (“you, your, or yourself”) are agreeing to accept and comply with the terms and conditions of use stated below (“Terms of Use”). You should read the entire Terms of Use carefully before using this Site or any of the DigitalfFinpay Services.

As used in this Terms of Use, “DigitalfFinpay” refers to the company DigitalfFinpay OU, with its registered with the Registrar of Companies for Estonia, Talin under the number 14407627, and with registered office Parda tn 4, 411-1, Tallinn city, Harju county, 10151, its owners, directors, investors, employees. Depending upon the context, “DigitalfFinpay” may also refer to the services, products, website, content or other materials (collectively “DigitalfFinpay “Services”) provided by DigitalfFinpay.

The Service operated by DigitalfFinpay allows buyers (“Buyers”) and sellers (“Sellers”) to buy and sell Virtual Assets, including cryptocurrencies and other Digital Assets.

The Service operated by DigitalfFinpay also allows all registered users of the Service (“Members”) to:
Store Virtual Assets and Digital Assets listed on the DigitalfFinpay Site;

Transfer Virtual Assets to other Members or other users of such Virtual Assets inside the DigitalfFinpay Site;

Use Virtual Assets for purchasing goods;

Access and use the Ripple protocol.

Depending on your country of residence, you may not be able to use all the functions of the Site. It is your responsibility to follow those rules and laws in your country of residence and/or country from which you access this Site and Services. As long as you agree to and comply with these Terms of Use, DigitalfFinpay grants you the personal, non-exclusive, non-transferable, non-sublicensable and limited right to enter and use the Site and the Service.

IF YOU DO NOT ACCEPT THE TERMS OF USE AND CONDITIONS OUTLINED IN THIS AGREEMENT, DO NOT ACCESS THIS SITE AND DO NOT USE THIS SERVICE.

By opening an Account, you expressly represent and warrant:

That you have accepted these Terms; and

That you are at least 18 years of age and have the full capacity to accept these Terms and enter into a transaction involving Virtual Assets and other Digital Assets.

RISKS

The trading of goods and products, real or virtual, as well as virtual currencies involves significant risk. Prices can and do fluctuate on any given day. Such price fluctuations may increase or decrease the value of your assets at any given moment. Any currency – virtual or not – may be subject to large swings in value and may even become worthless. There is an inherent risk that losses will occur as a result of buying, selling, or trading anything on a market.

Virtual Asset and Digital Asset trading also has special risks not generally shared with official currencies or goods or commodities in a market. Unlike most currencies, which are backed by governments or other legal entities, or by commodities such as gold or silver, Virtual Assets are a unique type of “fiat” currency, backed by technology and trust. There is no central bank that can issue more currency or take corrective measures to protect the value of Virtual Assets in a crisis.

Instead, Virtual Assets are an as-yet autonomous and largely unregulated global system of currency firms and individuals. Traders put their trust in a digital, decentralised and partially anonymous system that relies on peer-to-peer networking and cryptography to maintain its integrity.

The trading of Virtual Assets is often susceptible to irrational (or rational) bubbles or loss of confidence, which could collapse demand relative to supply. For example, confidence in Virtual Assets might collapse because of unexpected changes imposed by software developers or others, a government crackdown, the creation of superior competing alternative currencies, or a deflationary or inflationary spiral. Confidence might also collapse because of technical problems: if the anonymity of the system is compromised, if money is lost or stolen, or if hackers or governments are able to prevent any transactions from settling.

There may be additional risks that we have not foreseen or identified in our Terms of Use.

You should carefully assess whether your financial situation and tolerance for risk is suitable for buying, selling or trading Virtual Assets or Digital Assets.

We use our banking providers in order to receive funds from Members and make payments to Members. Our banking providers DO NOT transfer, exchange, or provide any services in connection with Virtual Assets or Digital Assets.

LIMITED RIGHT OF USE

Unless otherwise specified, all Materials on this Site are the property of DigitalfFinpay and are protected by copyright, trademark and other applicable laws. You may view, print and/or download a copy of the Materials from this Site on any single computer solely for your personal, informational and/or non-commercial use, provided you comply with all copyright and other proprietary notices.

The trademarks, service marks and logos of DigitalfFinpay and others used in this Site (“Trademarks”) are the property of DigitalfFinpay and their respective owners. The software, text, images, graphics, data, prices, trades, charts, graphs, video and audio used on this Site belong to DigitalfFinpay. The Trademarks and Material should not be copied, reproduced, modified, republished, uploaded, posted, transmitted, scraped, collected or distributed in any form or by any means, whether manual or automated. The use of any such Materials on any other Site or networked computer environment for any other purpose is strictly prohibited; any such unauthorised use may violate copyright, trademark and other applicable laws and could result in criminal or civil penalties.

MAINTAINING YOUR ACCOUNT: OUR RULES

This Site is for your personal use only. We are vigilant in maintaining the security of our Site and the Service. By registering with us, you agree to provide DigitalfFinpay with current, accurate and complete information about yourself, as prompted by the registration process, and to keep such information updated. You further agree that you will not use any Account other than your own or access the Account of any other Member at any time or assist others in obtaining unauthorised access.

The creation or use of Accounts without obtaining prior express permission from DigitalfFinpay will result in the immediate suspension of all said Accounts, as well as all pending purchase/sale offers. Any attempt to do so or to assist others (Members or otherwise), or the distribution of instructions, software or tools for that purpose, will result in the Accounts of such Members being terminated. Termination is not the exclusive remedy for such a violation, and DigitalfFinpay may elect to take further action against you.

You are also responsible for maintaining the confidentiality of your Account information, including your password, safeguarding your own Virtual Assets and Digital Assets, and all activity including Transactions that are posted to your Account. Any actions on the Site, transactions, orders and operations initiated from your Account or using your password (1) will be considered to have been made by you, and (2) is irrevocable once validated using your password or made through your Account. If there is suspicious activity related to your Account, we may, but are not obligated to, request additional information from you, including authenticating documents, and to freeze any transactions pending our review. You are obligated to comply with these security requests or accept termination of your Account. You are required to notify DigitalfFinpay immediately of any unauthorised use of your Account or password, or any other breach of security, by email to [email protected] . Any Member who violates these rules may be terminated, and thereafter held liable for losses incurred by DigitalfFinpay or any user of the Site.

DigitalfFinpay similarly reserves the right to freeze Ripple accounts in accordance with the Ripple Labs policy, which took effect on 15 September 2014. Please see the explanation provided by Ripple Labs below: The freeze protocol extension gives gateways the ability to 1) globally freeze all their issued funds or 2) freeze funds issued to a specific user. Frozen funds may only be sent back to the issuing gateway. The global freeze feature allows a gateway to freeze all balances it issues. The gateway may still issue payments. Accounts holding frozen balances may return the funds to the gateway. This feature is useful for migrating users from one account to another and to safeguard users in the event that the gateway account is compromised. The individual freeze is primarily intended for compliance with regulatory requirements, which may vary from one jurisdiction to another. It also allows gateways to freeze individual accounts issuances in order to investigate suspicious activity. These features allow gateways to better operate in compliance with laws and regulations.

You will not take, directly or indirectly, any action designed, or that might reasonably be expected, to cause or result in destabilization or manipulation of the price of Virtual Assets, which are available on the DigitalfFinpay platform.

DigitalfFinpay reserves the right to suspend, delay or cancel an instruction or series of instructions issued by a user or colluding users which if executed would result in a price swing of 5% or more of the value of a crypto-currency available on the DigitalfFinpay Platform.

WASH TRADING

We do not allow you to cross trade, either alone or in collusion with others or to place an order, which would result in a self-execution—i.e., where the same trader or group of traders would act as both the maker and taker for the trade.

If two orders of opposing sides would result in a crossed trade, both orders are subject to specific measures, ranging from scrutiny, cancellation, suspension or prohibition to trade on our platform. If two orders of the same quantity would result in self-execution, both orders are subject to specific measures, ranging from scrutiny, cancellation, suspension or prohibition to trade on our platform.

MARKET MANIPULATION

You are prohibited from engaging or attempting to engage in Market Manipulation. This prohibition applies to any kind of activity that results in or has the purpose of:

Artificially controlling or manipulating the price or trading volume of any of the virtual currencies listed on our platform;

Manipulating of a benchmark including but not limited to the transmission of false or misleading inputs, or any other action that manipulates the calculation of a benchmark.

Market manipulation will trigger specific measures, ranging from scrutiny, cancellation of orders, suspension or prohibition to trade on our platform, disclosure to third parties including full disclosure to competent authorities.

Lastly, you agree that you will not use the Service to perform criminal activity of any sort, including but not limited to, money laundering, illegal gambling operations, terrorist financing, malicious hacking or any criminal or illegal activity.

The minimum trade size is defined by our Fee Schedule .

The accounts that were or will be funded did not and will not earn interests.

COMMISSIONS

DigitalfFinpay Commissions are available in our Fee Schedule. DigitalfFinpay reserves the right to change its Commissions at any time and at its sole discretion. You will be notified of any changes in advance through your Account or Email. Upon such notification, it is your responsibility to review the amended Fee Schedule. Your continued use of the Site following the posting of a notice of Commission changes signifies that you accept and agree to the changes.

VERIFICATION OF ACCOUNTS

The creation and use of your Account are subject to verifications, as required by statutory and regulatory obligations incumbent on DigitalfFinpay. You agree to provide us with the information we request for the purposes of identity verification, compliance with know-your-customer rules, as well as detection of money laundering, terrorism financing, fraud or any other financial crime. The requested information may include Personal Data (please refer to our Privacy Policy ). By providing us with the information we request, you confirm that it is true and accurate, and agree to inform us in case of change concerning such information. Your Account will be blocked until we will satisfied with the information you have provided and determine in our sole discretion that it is sufficient to validate your Account. In the meantime, you will not be allowed to terminate your Account or request the deletion of the Personal Data processed in the course of verification operations.

TERMINATION AND ESCROW OF UNVERIFIED ACCOUNTS

You may terminate this agreement with DigitalfFinpay, and close your Account at any time, following settlement of any pending transactions. You also agree that DigitalfFinpay may, by giving notice, in its sole discretion terminate your access to the Site and to your Account, including without limitation, its right to: limit, suspend or terminate the service and Members' Accounts, prohibit access to the Site and its content, services and tools, delay or remove hosted content, and take technical and legal steps to keep Members off the Site if we suspect that they are creating problems or possible legal liabilities, infringing the intellectual property rights of third parties, or acting inconsistently with the letter or spirit of these Terms. Additionally, we may, in appropriate circumstances and at our discretion, suspend or terminate Accounts of Members for any reason, including without limitation: (1) attempts to gain unauthorised access to the Site or another Member's account or providing assistance to others' attempting to do so, (2) overcoming software security features limiting use of or protecting any content, (3) usage of the Service to perform illegal activities such as money laundering, illegal gambling operations, financing terrorism, or other criminal activities, (4) violations of these Terms of Use, (5) a failure to pay or a fraudulent payment for Transactions, (6) unexpected operational difficulties, or (7) upon the request of law enforcement or other government agencies.

We expressly reserve the right to cancel and/or terminate Accounts that have not been verified by the Member despite efforts made in good faith by DigitalfFinpay to contact you to obtain such verification (“Unverified Accounts”). All Unverified Accounts which have been inactive for a period of 6 months or more are further subject to transfer to a third-party escrow (the “Unverified Escrow”), and will no longer be maintained or under the legal responsibility of DigitalfFinpay. The administrator/trustee of the Unverified Escrow shall make any and all additional reasonable efforts required by law to determine and contact each Unverified Account owner and, after suitable effort and time has been expended, we may be required to convert the residual Virtual Assets or other Digital Assets into fiat and send it to a national authority responsible for the safekeeping of such funds.

The suspension or escrow of an Account shall not affect the payment of commissions due for past Transactions. Upon termination, Members shall send details of a valid bank account to allow for the transfer of any currencies credited to their account. This bank account must be held by the Member. Virtual Assets or other Digital Assets may be transferred to a valid bank account only after conversion into a fiat currency. DigitalfFinpay shall transfer the currencies as soon as possible following the Member's request and within the time frames specified by DigitalfFinpay. DigitalfFinpay will send you the credit balance of your Account; however, in certain circumstances a number of intermediaries may be involved in an international payment and these or the beneficiary bank may deduct charges. We will make all reasonable efforts to ensure that such charges are disclosed to you prior to sending your payment; however, where they cannot be avoided, you acknowledge that these charges cannot always be calculated in advance, and that you agree to be responsible for such charges.

Upon Account closure, any amount less than 25 USD/EUR in value will not be returned.

DigitalfFinpay reserves the right to not convert Virtual Assets or other Digital Assets into fiat and to return them to a Wallet that belongs to the Customer.

AVAILABILITY OF SERVICES

All services are provided without warranty of any kind, either express or implied, and in particular without implied warranties of merchantability and fitness for a particular purpose. We do not represent that this Site will be available 100% of the time to meet your needs. We will strive to provide you with the Service as soon as possible, but there are no guarantees that access will not be interrupted, or that there will be no delays, failures, errors, omissions or a loss of transmitted information.

We will use reasonable endeavours to ensure that the Site can be accessed by you in accordance with these Terms of Use. However, we may suspend use of the Site for maintenance and will make reasonable efforts to give you notice of this. You acknowledge that this may not be possible in an emergency, and accept the risks associated with the fact that you may not always be able to use the Site or carry out urgent transactions using your Account.

APIS AND WIDGETS

We may provide access to certain parties to access specific data and information through our API (Application Programming Interface) or widgets. We also may provide widgets for your use to enter our data on your Site. You are free to use these in their original unmodified and un-altered state.

EXTERNAL WEBSITES

DigitalfFinpay makes no representations whatsoever about any external or third-party website you may access through the Site. Occasionally, the DigitalfFinpay website may provide references or links to other websites ("External Websites"). We do not control these External Websites or third-party sites or any of the content contained therein. You agree that we are in no way responsible or liable for the External Websites referenced or linked from the DigitalfFinpay website, including, but not limited to, website content, policies, failures, promotions, products, opinions, advice, statements, prices, activities and advertisements, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. You shall bear all risks associated with the use of such content.

External Websites have separate and independent terms of use and related policies. We request that you review the policies, rules, terms and regulations of each site that you visit. It is up to you to take precautions to ensure that whatever you select for your use is free of items such as viruses, worms, Trojan horses and other items of a destructive nature.

FINANCIAL ADVICE

For the avoidance of doubt, we do not provide any investment advice in connection with the Services described in these Terms of Use. We may provide information on the price, range and volatility of Virtual Assets and other Digital Assets that are available on our platform and events that have affected the price of such Virtual Assets and Digital Assets, but this must not be considered investment advice nor should it be construed as such. Any decision to purchase or sell Virtual Assets and other Digital Assets is solely your decision and we shall not be liable for any loss suffered.

FINANCIAL REGULATION

Our business model and our Service facilitate the buying, selling and trading of Virtual Assets and other Digital Assets and their use to purchase goods in an unregulated, international open payment system. The Services we provide are currently unregulated within the UK.

DigitalfFinpay APPROACH TO DIGITAL FORKS IN VIRTUAL ASSETS

DigitalfFinpay has no control over the software protocols which govern or constitute the framework of virtual currencies. Therefore, the Company assumes no responsibility for the update or any modification of the underlying protocols, and DigitalfFinpay is not able to guarantee their functionality, security or availability.

By accepting the present Terms of Use, you acknowledge and accept the risk that underlying software protocols relating to any of the virtual currencies available on the platform are likely to be subject to sudden changes in operating rules (hereafter “fork”), and such forks may materially affect the value, function and/or the name of the virtual currencies that are exchanged or acquired on the platform.

Where possible, DigitalfFinpay may provide you with notices or alerts on forks and you agree that you will read such notices in order to make a decision in that respect.

However, it is your responsibility to make yourself aware of, and consider how to deal with, upcoming forks. In the event of a fork, there is a risk that DigitalfFinpay may need to temporarily suspend operations in relation to that fork without providing advance notice to you. The Company may, in the Company’s reasonable discretion, decline to support either or both branches of a fork.

By agreeing to the present Terms of Use, you acknowledge the risks presented by forks and you accept that DigitalfFinpay has no responsibility to assist you to move or sell Virtual Assets of an unsupported branch of a forked protocol.

EMAIL

Unencrypted email messages sent over the Internet are not secure and DigitalfFinpay is not responsible for any damages incurred by the result of sending email messages in this way. We suggest sending email in encrypted formats; you are welcome to send PGP encrypted emails to us. The instructions and keys to do so are available upon request.

If you send unencrypted or unsecured email or other types of communications to us, we may respond using the same channels and you hereby accept the risks associated therewith.

DATA PROTECTION

Privacy is very important to us. Full details of our Privacy Policy can be found at Privacy Policy . We recommend that you read the Privacy Policy carefully, so that you know the data that we collect, how we use the data and who we share your data with.

DISCLOSURES TO LEGAL AUTHORITIES AND AUTHORIZED FINANCIAL INSTITUTIONS

We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:

Required by law;

Compelled by subpoena, court order, or other legal procedure;

We believe that disclosure is necessary to prevent damage or financial loss;

Disclosure is necessary to report suspected illegal activity; or

Disclosure is necessary to investigate violations of our Terms of Use or Privacy Policy .

We may also share information concerning US citizens who are DigitalfFinpay customers with other financial institutions, as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal Revenue Service, pursuant to the Foreign Account Tax Compliance Act (“FATCA”), to the extent that this statute may be determined to apply to.

For further information on how we process your Personal Data, please refer to the Privacy Policy.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We store and process your Personal Data in data centres around the world, wherever DigitalfFinpay facilities or service providers are located. As such, we may transfer your Personal Data outside of the European Economic Area (“EEA”). Such transfers are undertaken in accordance with our legal and regulatory obligations.

Please refer to our Privacy Policy for furtherdetails.

JURISDICTION

The Terms of Use shall be governed and construed in accordance with the law of England and Wales. The parties hereto agree to irrevocably submit to the exclusive jurisdiction of the courts of England and Wales.

LIMITATION OF LIABILITY

To the extent permitted by law, DigitalfFinpay will not be held liable for any damages, loss of profit, loss of revenue, loss of business, loss of opportunity, loss of data, indirect or consequential loss unless the loss suffered arose from gross negligence or wilful deceit or fraud. Nothing in these terms excludes or limits the liability of either party for fraud, death or personal injury caused by its gross negligence, breach of terms implied by operation of law or any other liability which may not be limited or excluded by law. Although DigitalfFinpay endeavours to provide accurate and timely information on the Site, the Site may not always be entirely accurate, complete or current and may include errors. We may change or update the Site at any time without notice, and you should accordingly verify with independent sources all information before relying on it to take decisions or actions. You remain entirely responsible for your decisions and actions.

Subject to the foregoing, DigitalfFinpay ‘s aggregate liability for claims based on events arising out of or in connection with any single Member's use of the Site and/or Service, whether in contract or tort (including gross negligence) or otherwise, shall in no circumstances exceed the greater of either (a) the total amount held on Account for the Member making a claim less any amount of Commission that may be due and payable in respect of such Account; or (b) 125% of the amount of the Transaction(s) that are the subject of the claim less any amount of Commission that may be due and payable in respect of such Transaction(s).

INDEMNITY

To the full extent permitted by applicable law, you hereby agree to indemnify DigitalfFinpay and its partners against any action, liability, cost, claim, loss, damage, proceeding or expense suffered or incurred if direct or not directly arising from your use of DigitalfFinpay ‘s Sites, your use of the Service or from your violation of these Terms of Use.

TAXES

It is your responsibility to determine whether, and to what extent, any taxes apply to any transactions you and your Company conduct through DigitalfFinpay services, and to withhold, collect, report and remit the correct amounts of taxes to the appropriate tax authorities. Your transaction history is available through your account.

MISCELLANEOUS

If we are unable to perform the Services outlined in the Terms of Use due to factors beyond our control including but not limited to an event of Force Majeure, change of law or change in sanctions policy, we shall not be liable for the Services provided under this agreement during the time period coincident with the event.

MODIFICATION OF TERMS

DigitalfFinpay reserves the right to change, add or remove parts of these Terms at any time and at its sole discretion. You will be notified of any changes in advance through your Account. Upon such notification, it is your responsibility to review the amended Terms. Your continued use of the Site following the posting of a notice of changes to the Terms signifies that you accept and agree to the changes, and that all subsequent transactions by you will be subject to the amended Terms.

DEFINITIONS

Account. The contractual arrangement wherein a DigitalfFinpay Member has accepted our Terms of Use, Fee Schedule and Privacy Policy, and received approval to use the DigitalfFinpay Services, including the purchase and sale of Virtual Assets and other Digital Assets, and to perform associated Transactions.

Buyer(s). Member(s) that submit an offer to buy Virtual Assets or other Digital Assets through the Service.

Commission. Refers to the fee which is payable to DigitalfFinpay on each Transaction, such as a Purchase Transaction and further defined in our Fee Schedule.

Member(s). Refers to Buyers and Sellers as well as any holder of an Account.

Digital Asset. Digitalized right to use in a binary format. External Websites. Websites not owned or owned by DigitalfFinpay.

Member(s). Refers to Buyers and Sellers as well as any registered holders of an Account.

Personal Data. Information that identifies an individual, such as name, address, e-mail address, trading information, and banking details. “Personal Data” does not include anonymised and/or aggregated data that does not identify a specific user.

Price. The “price per coin” for which Members are willing to buy or sell Virtual Assets or other Digital Assets. The Price may be expressed in any of the currencies deposited by Members in their Account and supported by the Service. See our Site for a full list of currencies.

Seller(s). Member(s) that submit an offer to sell Virtual Assets or other Digital Assets through the Service.

Service(s). The technological platform, functional rules and market managed by DigitalfFinpay to permit Sellers and Buyers to purchase and sell Virtual Assets.

Site. DigitalfFinpay exchange platform as made available on websites www.digitalfinpay.com and www.ex.digitalfinpay.com

Transaction. Includes the following:

The agreement between the Buyer and the Seller to exchange currencies, Virtual Assets, or Other Digital Assets through the Service for currencies at a commonly agreed rate (“Purchase Transaction”);

The conversion of currencies into Virtual Assets deposited by Members on their Account (“Conversion Transaction”);

The transfer of Virtual Assets among Members (“Transfer Transaction”);

The transfer of currencies among Members (“Currency Transfer Transaction”); and

The purchase of ancillary products (“Purchase Transactions”).

DigitalfFinpay may not offer all these transaction types at this time or in all locations.

Transaction Price. The total price paid by the Buyer for each Transaction performed through the Service.

Virtual Assets. Digital representation of value that can be digitally traded, or transferred, and can be used for payment or investment purposes. Virtual Assets such as cryptocurrencies are a form of Virtual Asset designed to work as a medium of exchange that uses strong cryptography to secure financial transactions, control the creation of additional units, and verify the transfer of assets. Virtual Assets use decentralized control as opposed to centralized digital currencies and central banking systems.

CONTACT US

If you have any questions relating to these Terms of Use, your rights and obligations arising from these Terms and/or your use of the Site and the Service, your Account or any other matter, please contact [email protected] .

1. Parties

1.1 DigitalFinpay OU. (hereinafter referred to as“Digitalfinpay”or 'the Company') is a company incorporated in the Republic of Estonia under the laws of the Republic of Estonia, and operates the Website https://www.digitalfinpay.com (hereinafter referred to as 'this Website' or 'the Website'), which is a platform dedicated to the transaction of digital assets and the provision of related services (hereinafter referred to as 'the Services'). For the convenience of wording in this Privacy Policy, the Company and the Website are referred to collectively as 'we' or other applicable forms of first person pronouns in this Privacy Policy.

1.2 All natural persons or other subjects who log onto this Website shall be users of this Website. For the convenience of wording in this Privacy Policy, the users are referred to as 'you' or any other applicable forms of the second-person pronouns.

1.3 For the convenience of wording in this Privacy Policy, you and we are collectively referred to as “both parties”, and individually as “one party”.

2. Purposes of the Privacy Policy

The Privacy Policy stipulates the types of information of yours (“Personal Data”) that we may collect through your log into this Website, your registration with this Website, and/or use the Services we offer, as well as how we shall use and protect the information so collected.

3. Your consent

To ensure that you have full confidence in our handling of Personal Data, you are advised to read and understand the terms of this Privacy Policy in detail. In particular, upon your log into our Website, regardless of whether you register with this Website, you shall be deemed to accept, agree, undertake and confirm that:

3.1 You, on the basis of your own free will and your requisite consent, agree to disclose your Personal Data to us;

3.2 You will comply with all the terms and limitations of this Privacy Policy;

3.3 You agree that we may collect your information through your log into this Website, your registration with this Website, and/or your using the Services offered by us; you agree to any changes and modifications that we may make to our Privacy Policy in the future;

3.4 You agree that our branches, affiliates and employees may contact you in connection with the products and Services that you may be interested in (unless you have indicated in written that you do not want to receive such information).

4. Information Collected

4.1 When you use this Website, you agree to permit us to use cookies to track each of your actions and collect and keep all the information that you leave on this Website, including but not limited to your IP address, location, and other information.

4.2 If you are willing to use the Services offered by this Website, you will be required to fill in and provide the following two categories of information:

4.2.1 Identity Information. Such information can help us verify whether you are eligible to be registered as a member of this Website. It includes but is not limited to your name, residence address, mailing address, other certificates and corresponding numbers thereof that are issued by your country or government to certify your identity information, as well as all other information that can help us to verify your identity (hereinafter referred to as 'Identity information').

4.2.2 Service information. Such information helps us to contact you and provide you with the Services, including but not limited to your phone number, fax number, valid email address, mailing address, and information concerning your debit card and/or other accounts (hereinafter collectively referred to as 'Service information').

4.3 When you use this Website or the Services this Website offers, we may collect more information necessary from our exclusive mailboxes or in other manners that we consider as in compliance with relevant requirements, for the purpose of improving the functions of this Website, enhancing your experience of using this Website and its Services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.

4.4 If you visit any of links to third-party websites as are listed on this Website or any link of any of our third-party partners, you shall agree to and comply with the separate and independent Privacy Policy of such third party website. We will not bear any liability for the contents and activities of such websites or the partners.

4.5 If your Personal Data is located within European Economic Area（“EEA”）. For the Personal Data protected by General Data Protection Regulation (“GDPR”), You have a series of legal rights related to the Personal Data you keep in our Website, including:

1. Obtain information about your processing Personal Data and access the Personal Data you have left in our Website. Please note that in some cases, we have right to refuse requests for access to copies of Personal Data. (Especially information subject to legal professional privileges)
2. If your Personal Date is inaccurate or incomplete, you may ask us to make corrections, but if you need to provide a copy of valid identity documents to prove the authenticity of your Identity Information, please cooperate with us.
3. In some cases we can be asked to delete your Personal Date. Please note that under certain circumstances (e.g. for purposes of public interest, public health or scientific and historical research), we have the right to retain your Personal Date even if you ask us to delete it.
4. In some cases, you can loge an objection to the processing of your Personal Date and ask us to limit the processing of your Personal Date. Similarly, in some cases, we have the right to refuse your request even if you raise objections or ask us to restrict the processing of your Personal Date.
5. Withdraw your Personal Date license. If there are other legitimate reasons, we also have the right to continue using or processing without your permission.

According to the GDPR, in addition to providing systematic Personal Data protection measures, there will be a Data Protection Officer (DPO) to take full responsibility for your Personal Data protection .

We will assess all requests and complaints we have received and provide you with timely responses. We may ask you to provide a valid copy of the identity document so that we can fulfill our security obligations and prevent unauthorized data disclosure. We have the right to charge you a reasonable administrative fee if your request for access to data is clearly unfounded or out of our obligation, or if you request us to provide additional copies of your Personal Data.

To facilitate the Services, we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to outside of the area.If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use DigitalFinpay and our Services. You will have the ability to withdraw your digital assets and fiat currency; however, all other functionalities will be disabled.

5. Cookies

5.1 When you visit our Website, we use Google stats via cookies to record our performance and check the effect of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer hard drive. Only when you use your computer to access our Website can the cookies be sent to your computer hard drive.

5.2 Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website. The information collected by cookies is non-registered and collective statistical data and does not involve Personal Data.

5.3 Cookies, which enable the Website or Services provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your Personal Data. Most browsers are designed to accept cookies. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. However, if you set your browser to disable cookies, it is possible that you may not be able to launch or use some functions of our Website.

6. Purposes of Information

6.1 We will use your information that we collect for the following purposes or in the following ways:

6.1.1 to provide you with our Services through our Website;

6.1.2 to identify and confirm your identity when you use our Website;

6.1.3 to improve and upgrade the Services of the Website (your information and feedback received by us can help us improve the Services of the Website, so that we can more effectively respond to your Services requests and support needs);

6.1.4 to keep statistics relating to the use of our Website and to be used for data analysis carried out in cooperation with government agencies, public affairs institutions;

6.1.5 to personalize your experience (your information will help us to better respond to your personalized needs);

6.1.6 to facilitate transactions (your information, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other company on any grounds without your consent, except for where doing so is expressly for the purpose of completing the transaction you require);

6.1.7 to send e-mail regularly (the email address that you provide for the purpose of processing orders may be used to receive information on and updates to your orders, in addition to newsletters, updates, related products or Services information, etc.,that we may send to you from time to time)

6.1.8 to meet other purposes as specified in the User Agreement of this Website and all legal means adopted for satisfying such purposes.

6.2 We do not sell, trade, or otherwise transfer information or allow others to collect, use information; however, such information does not involve the following parties and does not include the following information: our affiliates, trusted third parties who help us operate our websites, manage our business, or provide Services to you, provided that such parties agree to keep such information confidential; When we believe that information disclosure is appropriate, or it is required by any of the applicable laws, regulations, rules or by any order of courts or other competent authorities, and is necessary for executing the strategy of our Website and ensuring the proper functioning of the Website, or as may be necessary for the related parties to provide Services, or for the protection of the rights, property or safety of us or other persons. However, your information will not be provided to other parties for marketing, advertising or other purposes.

6.3 We have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions, which requires us to undertake due diligence on our customers. This may include the use of third-party data and services providers which we will cross-reference with your Personal Data.

6.4 You agree that Digitalfinpay has the right to share your Personal Data with: Member of our group, which includes our subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives;

Our service providers and other third parties who assist us in providing service to you;

Entities in connection with any financing, acquisition or dissolution proceedings which involve disclosing certain portion or all of our business or assets; and

Law enforcement agencies and authorities, officers, regulators or other third parties to comply with any law, court order, subpoenas or government requests;

7. Protection of Personal Data

7.1 We adopt appropriate physical, electronic, management and technical measures so as to protect and safeguard the security of your Personal Data. We will, to the greatest extent possible, ensure that any Personal Data collected through our Website shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:

7.1.1 Physical measures: records of your Personal Data will be stored in a properly locked place.

7.1.2 Electronic measures: The computer data that contain your Personal Data will be stored in computer systems and storage medias that are subject to strict login restrictions.

7.1.3 Management measures: only staff members duly authorized by us can access your Personal Data, and these staff members shall comply with our internal code concerning Personal Data confidentiality.

7.1.4 Technical measures: such encryption techniques as Secure Socket Layer Encryption may be used to convey your Personal Data.

7.1.5 Other measures: our network servers are protected by proper 'firewall '.

7.2 If you are aware of any security flaws in our Website, please contact us immediately so that we can take appropriate action as soon as possible.

7.3 Despite of the above-mentioned technical and security measures, we cannot guarantee that the information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the Personal Data that you provide to us through our Website will be safe at any time. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your Personal Data, and we shall not be held liable for compensation for such loss or damage.

8. Modification to the Privacy Policy

We reserve the right to amend the Privacy Policy from time to time and at any time. We will inform you of the modifications made to the Privacy Policy by updating and publishing the effective date of the release of new versions hereof and highlighting the amendments. Sometimes, we may issue a notice to inform you of the modification made in the Privacy Policy, which, however, is not an obligation for us. You shall regularly review the Privacy Policy and focus on its modifications, and if you do not agree to such modifications, you shall immediately stop accessing this Website. When an updated version of this Privacy Policy is released, your continued visit to this Website shall indicate and show that you agree to the update and agree to comply with the updated Privacy Policy.

9. Communication with Us

9.1 If you have any requests and comments, you can send an email to , which is the only valid and official email through which we communicate with you, so we will not bear any liability for your failure to using effective contact information, any act or omission.

9.2 We only publish announcements and information on the basis of the valid and effective contact information on this Website or post announcements on this Website; therefore, we shall not be held liable for any loss arising from your trust in the information that has not been obtained through the above-mentioned means.

9.3 If you have any questions regarding our Privacy Policy, you are welcome to contact us at any time.

General Information.

DigitalFinPay Know Your Customer Policy and Anti-Money Laundering (“KYC/AML”) Policy covers the following matters:

• Verification procedures.
• Compliance Officer.
• Monitoring Transactions.

1. Verification procedures

1.1. Identity verification

DigitalFinPay identity verification procedure requires each User to provide DigitalFinPay with reliable, independent source documents, data or information (e.g., national ID, international passport, proof of adress). DigitalFinpay reserves the right to collect User’s identification information for KYC/AML Policy purposes.

User acknowledges and agrees that DigitalFinpay may confirm the authenticity of documents and information provided by the Users and DigitalFInpay reserves the right to investigate certain Users further at any time, verify User’s identity in an on-going basis and request up-to-date documents from the Users, even if User passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with DigitalFInpay Privacy Policy and applicable law.

1.2. Card verification

If the User uses payment cards in connection with DIgitalFInPAy Services, DigitalFinPay may require the User to provide additional documentation and information in accordance with instructions available on DigitalFinPay Site.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by DigitalFinPay, whose duty is to ensure the effective implementation and enforcement of the KYC/AML Policy. It is the Compliance Officer’s responsibility to supervise all aspects of DigitalFinPay anti-money laundering and counter-terrorist financing, including but not limited to:

• Collecting Users’ identification information.
• Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
• Monitoring transactions and investigating any significant deviations from normal activity.
• Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
• Updating risk assessment regularly.
• Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

3. Monitoring Transactions

User acknowledges that DigitalFinPay may monitor and analyze transactional patterns. DigitalFinPay performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting, including:

• Regular check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
• Case and document management.

DigitalFinPay reserves the right to:

• ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
• request the User to provide any additional information and documents in case of suspicious transactions;
• suspend or terminate User’s Account when Beaxy has reasonable suspicion that such User engaged in illegal activity.

The above list is not exhaustive and the Compliance Officer may monitor User’s transactions on a day-to-day basis for any purpose, including to determine whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.