1. Definition of Personal Data
2. Data Controller and Data Protection Officer
The Data Controller and Data Protection Officer can be contacted by email at [email protected].
3. Collection of Personal Data during Registration and Authentication
4. Account Verification
During the account verification process, we collect the user's mobile phone number and photos or scans of their identity documents. We also collect data such as document type, issuing country, document number, expiry date, MRZ (Machine Readable Zone), information embedded in the document barcode, and security features. Additionally, we collect photos and scans of the user's face, as well as videos and audio recordings. Biometric data related to facial features is also collected.
5. Bank Transfers
To initiate or receive a bank transfer, users may be required to provide documents and information such as proof of address, documents confirming citizenship or residence permit, documents required to prove the source of funds, and details of the bank account including account number, sort code, IBAN, and payment-related information like amount, currency, and time.
6. Transaction Verification to Prevent Fraud
To prevent fraud and misuse of user accounts, we may request additional information including bank statements, verbal explanations, screenshots, and a questionnaire to confirm that users are acting voluntarily and fully understand the consequences of their actions.
7. Communication with Us
When users communicate with us, we collect their contact email, the content of their messages, any attached files, a unique ticket system identifier, and technical data related to messages including date, time zone, and environment.
8. Transaction Information
We collect information about payments made within user accounts, including date, time, amount, currencies, participating parties, messages sent and received, merchant information, payment methods used, technical usage data, and geolocation information. We also collect details of user wallets and unique identifiers on the Enigma platform, as well as bank card information such as cardholder name, expiry date, and the first 6 and last 4 digits of the card number.
9. Device Information
We collect information from user devices, including the name of their internet service provider (IP address), environment, login information, browser type and settings, time zone, operating system, device type, unique device identifier, screen size, mobile network information, mobile operating system, and type of mobile browser used, as well as the date, time, and duration of visits to the website.
Terms & Conditions
1. Account Creation
In order to utilize our Service, you must first register an account with us. By doing so, you agree to provide accurate and complete information during the registration process. It is your responsibility to maintain the confidentiality of your account and password, as well as to oversee any activities carried out under your account.
2. Service Usage
You are granted permission to use our Service strictly for lawful purposes and in accordance with these Terms. You hereby undertake not to employ the Service in any manner that:
- Violates relevant local, state, federal, or international laws or regulations.
- Seeks to exploit or cause harm to minors, such as exposing them to inappropriate content or soliciting their personal information.
- Facilitates the transmission or solicitation of unsolicited advertising or similar communications, including spam.
- Involves impersonating our company, our employees, other users, or any other individual or entity.
- Impairs or hinders the use or enjoyment of the Service by others, or that may potentially harm us, our users, or expose them to liability, as determined by us.
The usage of our Service may incur charges, for which you acknowledge your responsibility to promptly settle.
3. Intellectual Property
All content included in our Service, including text, graphics, logos, images, and software, is either owned by us or licensed to us. Any reproduction, modification, distribution, display, or exploitation of such content requires our prior written consent.
4. Disclaimer of Warranties
The Service is provided on an "as is" and "as available" basis. We make no express or implied representations or warranties regarding the operation of the Service or the accuracy, completeness, reliability, or availability of any information, content, materials, or products included in the Service. Your use of the Service is entirely at your own risk.
5. Limitation of Liability
We shall not be held liable for any damages, whether direct, indirect, incidental, punitive, or consequential, arising from your use of the Service or any content or materials provided through the Service.
We reserve the right to terminate or suspend your account and access to the Service at any time, without prior notice and for any reason.
7. Governing Law
These Terms shall be governed by and construed in accordance with the laws of [State/Country], without regard to conflicts of law principles.
AML Policy: Committed to Combating Financial Crime
Customer Due Diligence: Thorough Screening and Verification
We prioritize customer due diligence (CDD) by conducting thorough screenings on all customers to ensure compliance with anti-money laundering (AML) laws and regulations. This includes verifying customer identities and assessing the source of their funds.
Ongoing Monitoring: Vigilant Detection of Suspicious Activity
To detect any suspicious activities, we continuously monitor customer transactions. Our monitoring system is designed to identify transactions that deviate from a customer's regular business or personal activity, as well as transactions involving high-risk entities or individuals, or significant monetary amounts.
Reporting Obligations: Prompt Action and Cooperation
In compliance with legal requirements, if we uncover any suspicious activities, we promptly report them to the appropriate authorities.
Employee Training: Ensuring AML Compliance
Our employees receive regular training on AML laws, regulations, and our specific AML policy and procedures. This ensures they are equipped with the necessary knowledge to identify and prevent money laundering and terrorist financing risks.
Record Keeping: Diligent Maintenance of Records
Our company diligently maintains comprehensive records of all customer transactions and CDD information, adhering to the regulations and laws governing record-keeping practices.
Risk Assessment: Regular Evaluation and Adaptation
We conduct regular risk assessments to evaluate and mitigate potential risks associated with our Service. Accordingly, we update our AML policy and procedures to align them with the evolving landscape of money laundering and terrorist financing threats.