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Introduction

CoinStore24 is the trading name of Venture Asset Management Ltd, (“Coinstore24.com”), Lusaka, Zambia

Coinstore24 is a platform that allows users to purchase various digital assets.

These Terms and Conditions (“Terms”) govern the use of the CoinStore24 (“CoinStore24”, “we”, “us”, or “our”) website located at https://www.coinstore24.com (“website”) and the services provided by CoinStore24 through the website. By using our website, you (“User”, “you”, or “your”) agree to be bound by these Terms.

Registration and Account

To use our services, if required, you and create an account on our website. During registration, you will be required to provide accurate and complete information. You are responsible for maintaining the security of your account and keeping your login credentials confidential.

Eligibility

By using our services, you represent and warrant that you are at least 18 years old and have the legal capacity to enter into these Terms. You also confirm that you are not a resident of any country or jurisdiction where the use of our services is prohibited by law.

Purchase and Fees

CoinStore24 enables users to purchase cryptocurrencies and other digital assets. We charge trading fees for executing transactions on our platform. The specific fees and fee structure will be disclosed on our website and may be subject to change with prior notice.

Risks

Purchasing cryptocurrencies and other digital assets involves significant risks, including price volatility, regulatory changes, and potential technological failures. By using our services, you acknowledge and accept these risks and agree that CoinStore24 is not responsible for any losses that may occur as a result of your purchasing activities.

Prohibited Activities

You agree not to engage in any illegal or fraudulent activities while using our services, including but not limited to money laundering, terrorist financing, or market manipulation. CoinStore24 reserves the right to monitor and investigate any suspicious activities and report them to the appropriate authorities.

Limitation of Liability

To the maximum extent permitted by law, CoinStore24, its directors, employees, and affiliates shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising out of or in connection with the use of the website, services, or these Terms.

Indemnification

You agree to indemnify, defend, and hold harmless CoinStore24, its directors, employees, and affiliates from and against any claims, liabilities, damages, losses, or expenses, including reasonable attorneys’ fees, arising out of or in connection with your access to or use of the website, services, or violation of these Terms.

Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the jurisdiction in which CoinStore24 operates. Any disputes arising out of or in connection with these Terms or your use of the website or services shall be subject to the exclusive jurisdiction of the courts of the aforementioned jurisdiction.

Acceptance of Policies

By use of the website, you agree to bound by the following Policies:

1. Legal & Privacy Policy

2. Security Policy

3. AML, CTF & KYC Policy

Changes to Terms

CoinStore24 reserves the right to amend or update these Terms and Policies at any time, with or without notice. By continuing to use the website and our services after any changes to the Terms, you agree to be bound by the modified Terms and Policies

Licenses

Coinstore24 is the trading name of Venture Asset Management Ltd, ______________, Lusaka Zambia and operates under License number _______________ issued by the Zambian Ministry of Finance.

This Policy is applicable to the Coinstore24 website.

The privacy of our Users is important to us, and we are committed to safeguarding it. Hence, this Policy explains your Personal Information which we collect, why we collect it, and what we do with it.

This Policy applies to Coinstore24 only. We do not exercise control over sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins or other files on your computer, collect data or solicit personal information from you. Coinstore24 does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements.

For any access request, questions, or inquiries about how we use your Personal Information, please contact us at info@www.coinstore24.com

Data Acquisition & Storage Procedures

The Personal Information we have about you is directly made available to us when you:

1 Register with Coinstore24.

2 Use any of our services.

3 Fill in our online forms.

4 Contact us.

Categories of personal Information we may collect:

Identity Data: Information that is needed to enable us to verify your identity in order to offer our services to you, such as your full name(s), passport or any Government-issued identity card, or date of birth.

Contact Data: Information that is needed to reach out to you, such as your contact address, email address, telephone number, or billing details.

Log/Technical Data: Information that your browser sends whenever you visit our Platform, such as links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location, or other device details.

Transactional Data: Information relating to a purchase that you make as a customer, such as the transaction amount, currencies sold, or currencies purchased. We do not store sensitive data related to your credit or debit card.

Marketing and Communications Data: Information relating to your decision to subscribe or to withdraw from receiving marketing materials from us or from third parties.

Records of your communication with us, if we contact you and if you contact us.

We may also collect, store, use and transfer non-personal information or anonymized data such as statistical or demographic data.

As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with applicable law.

The lawful basis we rely on for processing your Personal Information are:

1. Your Consent: Where you agree to us collecting your Personal Information by using our Services.

2. We have a contractual obligation: Without your Personal Information, we cannot provide our Services to you.

3. We have a legal obligation: To ensure we are fully compliant with all applicable financial legislation such as Anti-Money Laundering and Counter Terrorist Financing Laws, we must collect and store your Personal Information. We mitigate fraud by checking your identity with your Personal Information.

How we use your Personal Information

We may use your Personal Information we collect to:

1 Create and manage any accounts you may have with us, verify your identity, provide our services, and respond to your inquiries.

2 Process your purchases.

3 Protect against and prevent fraud, unauthorized transactions, claims and other liabilities.

4 Provide, administer and communicate with you about products, services, offers, programs and promotions of Coinstore24 and partners.

5 Evaluate and improve our business, including developing new products and services.

6 To target advertisements, newsletter and service updates.

7 As necessary to establish, exercise and defend legal rights.

8 As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Coinstore24.

9 To use data analytics to improve our website, products or services, and user experiences.

10 For other purposes for which we provide specific notice at the time of collection.

Marketing & Advertisement

Coinstore24 may process your Personal Information in order to contact you or send you marketing content and communication about our products, services or surveys. You may exercise your right to object to such contact from us or opt out from the marketing content. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services related to our ongoing business relationship.

We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

Data Protection Rights

Based on your location and applicable laws, below are the rights you have as a user in relation to your Personal Information:

1. Right to be informed

2. Right to request access or copies to your Personal Information by signing into your Account or contacting us

3. Right to request that Coinstore24 erase your Personal Information. You have the right to ask us to erase your Personal Information. Please note that this is a limited right which applies where the data is no longer required, or the processing has no legal justification. The exceptions to this right are where the applicable law requires us to retain a historical archive or where we retain a core set of your personal data to ensure we do not inadvertently contact you in future where you object to your data being used for marketing purposes.

4. Right to correct or rectify any Personal Information that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to provide information you think is incomplete.

5. Right to object to the processing of your Personal Information for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send you.

6. Right to object to processing: You have the right to object to the processing of your Personal Information in certain circumstances. Please note that if you object to us processing your Personal Information, we might be unable to provide the services to you.

7. To target advertisements, newsletter and service updates.

8. As necessary to establish, exercise and defend legal rights.

As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Coinstore24.

To use data analytics to improve our website, products or services, and user experiences.

For other purposes for which we provide specific notice at the time of collection.

The basis of Coinstore24   processing your Personal Information is your consent. You also have the choice at any time to withdraw consent which you have provided.

The merchant also has a choice to deactivate their Account at any time. You may contact us should you wish to de-activate your account by sending an email to info@www.coinstore24.com

We may request additional details from you regarding your complaints and keep records of your requests and resolutions.

Data Security & Retention Controls

The security of your Personal Information is important to Coinstore24. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.

Other security measures include but are not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfil their job responsibilities.

When you use a password for any of your Accounts, please ensure you do not share this with anyone, and the password is kept confidential at all times.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Information is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We will take all reasonable steps to ensure that your Personal Information is secure and well protected.

We will only retain personal information on our servers for as long as is reasonably necessary as long as we are providing Services to you. Where you close your Account, your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Data, we do so in compliance with limitation periods under the applicable law.

Disclosure of Personal Information

We may disclose or share your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy.

Coinstore24 only shares personal information with External Third parties in the following limited circumstances:

1 We have your consent. We require opt-in consent for the sharing of any personal information; We share Personal Information with third parties directly authorized by you to receive Personal Information, such as when you authorize a third-party application provider to access your account. The use of your Personal Information by an authorized third party is subject to the third party’s privacy policy and Coinstore24 shall bear no liability for any breach which may arise from such authorization by you.

2 We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

Disclosure Without Consent

Exceptional circumstances might override the duty to maintain confidentiality. Where possible, we will inform the patient of requests to share personal information. The decision to disclose information must only be taken by senior staff. Examples include:

1 Situations where there is a serious public risk.

2 When information is required by the police to prevent or detect crime or to apprehend or prosecute offenders (if not providing the information would 3 prejudice these purposes).

4 In response to a court order.

Introduction & Purpose

In a global marketplace, there is always an attempt to use Banks or Financial Institutions to launder Money and for Terrorist financing that has caused great concern in the international community and has resulted in the passage of stricter laws and increased penalties for money laundering.

Keeping in view the global menace of Money Laundering and Terrorist Financing, CoinStore24 is stringently focusing on core Compliance functions to administer AML & CTF Policies and Procedures.

The Compliance policies – Anti Money Laundering / Combating the Financing of Terrorism (‘AML/CFT’), Know Your Customer (‘KYC’) and Sanctions policies have to be adhered to by all employees of CoinStore24.

 Adherence to the Guidelines

These Guidelines are a summary of the detailed AML policy of CoinStore24 that is applicable to ALL staff (including top management and all associate third parties if any) across the company.

These Guidelines set out the Compliance structure, and the broader procedures in relation to regulatory compliance that pertain to employees at CoinStore24. Also includes an overview of the responsibilities of the employees and how the affairs of CoinStore24 remain unified under the policies and procedures of the company.

Regular review of the Guidelines

These guidelines shall be subject to review and update whenever necessary and all any amendments will be made with a register maintained to record updated versions.

Customer Identification (KYC)

CoinStore24 follows a strong identity verification process for all our customers as per local and international AML/CTF regulations.

Robust KYC (Know Your Customer) as per the requirements of the regulatory authorities are adhered to at all levels of the organization.

Identifying and conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) wherever required.

Prohibition to enter into a business relationship.

CoinStore24 has a detailed risk assessment process that it follows. CoinStore24 doesn’t not entertain any customer that falls into a prohibited risk category which could include reasons but not limited to the ones listed below:

1 Customers who reside in FATF black-listed countries such as North Korea and Iran; or any other further countries deemed to be black-listed for financial transactions.

2 Customer fails to submit the data confirming his identity.

3 The customer submits not all the data or where the data are incorrect.

4 Customer avoids submitting the information required for establishing his identity.

5 Customer is identified as a Russian citizen.

 

Sanctions

To ensure compliance with the applicable sanctions against persons and entities, has an automated systems to screen the names of the customers against the sanctions lists issued by the local regulatory authorities, the UN Security Council (UNSC), The Office of Foreign Assets Control (OFAC), The Office of Financial Sanctions Implementation (OFSI), The sanctions country list issued by Financial Actions Task Force (FATF) and the list issued by European Union (EU).

CDD, EDD and SSD

In our CDD process, we obtain relevant details of every customer to ensure that the transactions they perform are in line with their profile or business activities. The Customer’s Due Diligence (“DD”) process entails collecting, processing, verifying and keep the information about the Customer in order to minimize the possible and potential ML/TF risks.

CoinStore24 follows Know Your Customer (“KYC”) principle in its activities. The KYC principle is in full scope applied in all Customer DD processes performed in its daily activities.

EDD (Enhanced Due Diligence) is carried out according to the risk assessment and management procedures established by Coinstore24 while establishing that customer bears a higher risk of money laundering and / or terrorist financing.

With EDD additional measures are taken, besides the usual CDD, to know more about the customer, his source of funds and to confirm that the transactions are within its means. To verify that funds are legitimate and not related to any criminal proceeds by obtaining authentic and genuine documents which must support both the underlying and stated purpose.

Transaction monitoring is an activity that comprises scrutiny of transactions undertaken throughout the course of a business relationship to ensure that ML/TF risk levels are kept to a minimum.

CoinStore24 uses appropriate tools for transaction monitoring (such as Chainalysis) that are reviewed and approved by its compliance team. Transaction Monitoring shall be conducted through:

Online monitoring, where transactions are monitored and stopped (if needed) in real time.

Retrospective monitoring, which involves analysis of transactions that have already been processed, while simultaneously continuously screening the profile of the customer for any sanctions that might have been applied post the establishment of business relationships.

Data storage and Retention

All records including the customer’s identification documents, related data, transaction data and any other relevant document are maintained and retained as per the regulatory requirements. CoinStore24 shall always maintain the confidentiality of information provided by its customers and their transaction records.

Reporting suspicious transactions

All systems are programmed to identify and alert them to unusual or potentially suspicious transactions to the MLRO.

Training

Effective AML training courses help the company develop good AML/CTF governance at different levels within the organization.

All employees are trained in AML policy & procedures within 30 days of joining and, with follow-up trainings conducted annually.