We use third parties to undertake identity verification checks in order to prevent fraud. In some cases, our third-party service providers may create derivative data based on your personal data that can be used in connection with the provision of identity verification and fraud prevention services. For example:
• ID verification. We may use third parties to verify your identity by matching the photo you take on your phone with the photo in your national identity. The information collected from your photo may include biometric data. We may use Jumio Corporation or Jumio UK, Limited (collectively “Jumio”) for these services. For further information about the way Jumio collects and processes personal data please see its privacy notice at https://www.jumio.com/legal-information/privacy-policy/jumio-inc-privacy-policy-for-online-services/.
• Fraud monitoring. We carry out real time monitoring on the Exchange to detect and prevent fraudulent activity. We use third parties such as Coinfirm for these services. Information collected during this monitoring will be used by Coinfirm in accordance with its privacy notice at https://www.coinfirm.com/privacy-policy/
These identity verification service providers may create derivative data based on your personal data that can be used in connection with the provision of identity verification and fraud prevention services. Please read their privacy notices to understand further how they may process your personal data.]
In addition to the above, we may also disclose personal data in to the following third parties:
(a) Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the services.
(b) Third party(ies) as a result of any restructure, sale or acquisition of our group or any affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.
(c) Regulatory and law enforcement authorities, whether they are outside or inside of the United Kingdom, where the law allows or requires us to do so.
As we continue to develop our business we may sell assets that currently form part of our business. In those circumstances, we may include information collected about you, or control of that personal data, as a business asset in any such sale. Also, in the unlikely event that we, or substantially all of our assets, are acquired, information about you, or control of such information, may be one of the transferred assets.
European Banking Partners
The following additional rules apply to Users or Members in the territory of the Member States of European Union, including, in addition to other conditions as set forth in other parts of these Terms and Conditions and/or their annexes, the Republic of Italy, as well as to any transactions being carried out within the above referred territories.
1. In the above referred territories, payment services are provided by Easy Payment and Finance, EP, S.A. (“Easy”) that provides services in the European Economic Area (“EEA”).
2. Easy is a company incorporated in Spain with Tax Identification Number A85785905, registered in the Commercial Register of Madrid, Volume 27111, folio 157, page M-488476, registration 1/A 1º, which registered office is at Calle Gran Vía 57, 8ª E – 28013 – Madrid, with its website https://easy-ep.com/, and a Spanish licensed payment services institution, supervised by the Bank of Spain (www.bde.es) with Bank of Spain registration number 6849.
3. If you, a corporate entity or natural person, is a legal subject of any of the Member States of the European Union, your wallet services infrastructure will be provided by Easy.
4. Easy also provides safeguard capabilities to your funds that are kept at segregated custody accounts with the Bank of Lithuania.
5. Although Easy is regulated by the Bank of Spain and has safeguard custody capabilities provided and guaranteed by the Bank of Lithuania, the aforementioned Wallet service and the related payment services are not covered by any Financial Services Compensation Scheme.
6. No other compensation scheme exists to cover losses claimed in connection with the Wallet.
7. Your Wallet is not issued by a bank and therefore no interest will accrue or be paid on balances held on your Wallet
8. At its own behest and in order to comply with laws and regulations to which Easy is bound, and unless when waived by Easy in writing, to apply for and/or use the Wallet under the specific situations ruled by this annex you must ne:
(i) If a natural person, be at least 18 years old;
(ii) If a corporate entity, be legally registered and able to prove such registration according to what may be demanded by their jurisdiction of incorporation;
(iii) not be listed in any sanction and/or restriction list that be required and enforced by the European Union, its offices and agencies, and its Member States and respective offices and agencies;
(iv) if a natural person, not be a resident of any country or jurisdiction restricted under Financial Action Task Force (“FATF”) restriction lists;
(v) if a corporate entity, not be registered in any country or jurisdiction restricted under Financial Action Task Force (“FATF”) restriction lists and/or have any of its Ultimate Beneficial Owners being a resident of any country or jurisdiction restricted under Financial Action Task Force (“FATF”) restriction lists;
(vi) be able to furnish all the mandatory information and documentation as per what may be requested by Easy;
9. You must not use the Wallet services to which payment services are provided by Easy if such use would violate the applicable laws and regulations of your country of residence, the European Union of any of its Member States, or the country where you are physically present at the time of completing any your transaction.
10. When funding your wallet for the first time your funding must come from a bank account under the same tax identification number as the one belonging to the User or Member that created the Wallet account.
11. You must not attempt to link a Funding Source that is not in your name or which does not belong to you.
12. If a transaction amount or the cumulative amount of the transactions made by you exceeds a threshold established by Easy from time to time, you will have to provide Easy with some additional documents and information to Easy's full satisfaction, as will be determined in Easy's sole discretion.
13. Such documents and information will include, without limitation, clear color photos or scan copies of your identification documents, the documents confirming your residence address, and such other documents as Easy may request in Easy's sole discretion.
14. For customers of Spanish nationality, Easy will request your National Identity Document (DNI) as a valid form of documentation for the purposes of verifying your identity but not a Spanish passport.
15. For customers of other nationalities than Spanish, Easy will accept the following valid documents for the purposes of verifying your identity:
(i) a current and valid residence card issued by the relevant national authorities;
(ii) a current and valid Foreigner’s Identity Card or equivalent residence permit;
(iii) current and valid passport;
(iv) in the case of citizens of the European Union or the European Economic Area, an official personal identity document, letter or card issued by the authorities of origin;
(v) an identity document issued by the Ministry of Foreign Affairs and Cooperation for the personnel of the diplomatic and consular representations of third countries in Spain; or
(vi) such other document as specified by Easy and/or accepted by Easy in writing.
16. Easy will accept the following valid documents for the purposes of verification of your residence address:
(i) utility bill (gas, electric, satellite, television, landline phone bill) issued within the last three months;
(ii) local authority council tax bill for the current council tax year;
(iii) bank, building society or credit card statement or passbook dated not older than three months, verified by the issuing organization;
(iv) current EU Driving license (if not used as proof of identity);
(v) original mortgage statement from a recognized lender for the last full year;
(vi) council or housing association rent card or tenancy agreement for the current year; or
(vii) such other document as specified by Easy and/or accepted by Easy.
17. Easy retains the right to request any additional documents and/or information regarding you, your transaction(s) and/or sender and/or recipient of funds of your transaction.
18. Easy will decide in its sole discretion whether the documents and/or information provided are sufficient to allow you to use our services or any part thereof.
19. Easy may request an update and/or confirmation of any information and documentation you have provided to Easy as frequently as needed for Easy to follow our internal policies and to comply with the applicable laws and regulations.
20. You are prohibited from using your Wallet for the purposes of legalization of the illegal proceeds, illegal activities, illegal trade, and any other transactions made in violation of the applicable laws or in violation of any illegal, harmful or restricted activities as per any of Easy’s own illegal and/or harmful activities’ lists.
21. You will use all reasonable efforts to prevent using your Wallet for illegal trade, illegal financial transactions, or legalization of illegal proceeds.
22. Easy may refuse to process a transaction:
(i) if Easy demands you to provide proof of origin of funds and/or proof of a legal relationship between you and the recipient and you fail to do so; or
(ii) if Easy believes that your transaction is suspicious or potentially illegal (for example, if Easy believes that your transaction is being made fraudulently).
23. In case you are demanded by Easy to provide proof of funds and/or proof of legal relationship between you and the recipient of your transaction(s), we may request any of the following documents at our sole discretion.
(i) For proof of funds:
(a) a bank statement,
(b) a receipt for a payment,
(c) a paystub,
(d) copies of social security and other government refunds/payment checks, or
(e) any other document that Easy, at its sole discretion, may understand as sufficient.
(ii) For proof of legal relationship between you and the recipient:
(a) an invoice for services or goods issued to you by the recipient,
(b) a contract between you and the recipient,
(c) a payment request, donation request, or any other request for funds issued to you by the recipient,
(d) any communication, such as emails, messages and any other we may elect at such a time, from recipient to you with a request for funds, that Easy, at its sole discretion, may understand as sufficient.
24. Unless otherwise provided by these Terms of Service, or by applicable European laws, directives and regulations, all successful transactions will not be refundable under any circumstances, including termination of these Terms of Service for any reason.
25. Easy will not be liable for any damages (including, without limitation, lost profits, business interruption, or loss of use or corruption of software, data or information, loss of goodwill, loss of anticipated savings, loss of business opportunity) rising out of your use of or inability to use the Wallet or any other services provided through Easy or any part of those services thereof, even if Easy have been advised of the possibility of such damages.
26. In no event will Easy be liable for any loss of data or for any indirect, special, incidental, consequential (including lost profit), or other damages whether these are based in contract, tort (including negligence), misrepresentation, restitution or otherwise.
27. Easy will have no liability with respect to the content of the Wallet or any other services provided by Easy or any part thereof, including but not limited to errors or omissions contained therein, libel, infringements of rights of publicity, privacy, trademark rights, business interruption, personal injury, loss of privacy, moral rights, the disclosure of confidential information or damage to tangible property or data (including loss of property or loss of use of tangible property or data.
28. Without prejudice to the generality of the clauses above Easy will not be liable for the goods or services that you purchase with your Wallet.
29. The exclusions in the clauses above shall apply to the fullest extent permissible at law, but Easy will not exclude liability for:
(i) death or personal injury caused by Easy's negligence, or from its officers, employees, contractors or agents;
(ii) fraud or fraudulent misrepresentation; or
(iii) any other liability which may not be excluded by law.
30. Easy has established, implemented and maintain a complaints procedure in accordance with the Bank of Spain and Spanish Consumer Defense and Protection Rules.
31. Concerning any services related to crypto currencies or other blockchain technologies, you acknowledge that Easy is not an exchange or trader of cryptocurrencies, and that Easy does not perform any transactions concerning the safeguard of encrypted blockchain keys and/or conversion of fiduciary money in to blockchain based electronic currencies or vice versa.
32. Therefore, you understand that, when dealing with any matter related to crypto currencies, you will not use Easy's services to perform any of those aforementioned services and processes, and will only Easy's services to carry out payment services and transfers of fiduciary money.
33. As well, you acknowledge and declare that you understand there is no contractual or commercial business relationship between Easy and either crypto currency destination providers and crypto currency exchanges used by your Wallet.
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