Last updated: Dec 12. 2023

Coinsellor is committed to safeguarding your privacy and personal data, adhering to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as "the Regulation," along with other legal requirements of the European Union and the Republic of Poland, recommendations of the financial sector, and guidelines of good practice. This Privacy Protection Policy outlines our practices regarding the processing of your personal data, which includes any information directly or indirectly related to you, respecting your right to privacy and its protection.

Coinsellor processes the personal data of the Data Subject in accordance with the Regulation, following these principles:

In accordance with the purposes specified in the Terms and to the extent necessary, Coinsellor processes the following Personal Data:

Coinsellor processes your Personal Data on the following grounds:

We will continue to process your Personal Data as long as you receive our services. Depending on the services provided, this basis may be combined with other grounds for processing Personal Data.

Main goals include:

Sub-purposes include:

With the purpose of ensuring safety, Coinsellor employs camera surveillance at its premises. The processed Personal Data includes images and videos of clients inside and outside the office premises, along with sound recordings within the office. The legal basis for camera surveillance is the legitimate interest of ensuring the security of employees, clients, and assets.

Recordings are retained for a maximum of 60 days from the recording date. Access to Personal Data is restricted to authorized employees for security purposes.

We transfer your Personal Data to:

Access to your Personal Data is restricted to authorized employees and partners who process it in line with the specified purposes and legal requirements.

Coinsellor may make automated individual decisions and perform Profiling when establishing or providing services to you. Profiling aims to evaluate and forecast personal wishes, interests, reliability, and behavior for marketing and service suitability assessment. You have the right to object to automated decision-making, except when necessary for the agreement or based on your Consent.

Your Personal Data is stored within the EU / EEA territory.

Storage duration is based on the purposes of processing, legal obligations, and protection of interests. The criteria include the need for service performance, legal requirements, protection of interests, and evidence of lawful processing. Your Personal Data is deleted or anonymized when one or more criteria are met.

As part of privacy laws compliance, you have the right to:

Submit your request to compliance@coinsellor.com, signed with a secure electronic signature. We will respond within one month, with a possible two-month extension for extensive requests. The response will be provided by encrypted email. Processing of your request is free unless it is recurring, manifestly unfounded, or excessive.

Coinsellor applies organizational, physical, and technological measures to protect Personal Data according to risk. Employees processing Personal Data receive appropriate training. Processors adhering to our instructions and applicable laws implement security measures.

Terms may be unilaterally changed or supplemented in connection with regulatory amendments or operational changes. Changes not related to regulatory requirements will be notified 60 days in advance.For more information on changes, visit our website coinsellor.com.

Last updated: Dec 12. 2023

The Coinsellor Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) aim to prevent and mitigate the risks of Coinsellor being involved in illegal activities. International and local regulations require Coinsellor to establish effective internal procedures and mechanisms to deter money laundering, terrorist financing, and other illicit activities.For Law Enforcement requests, please direct your official document to our compliance team here.

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Coinsellor establishes its verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).

Coinsellor’s identity verification procedure requires the User to provide reliable, independent source documents, data, or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, Coinsellor reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

Coinsellor will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used, and Coinsellor reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Coinsellor reserves the right to verify User’s identity on an ongoing basis, especially when their identification information has changed, or their activity seems to be suspicious (unusual for the particular User). In addition, Coinsellor reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared, and protected strictly in accordance with Coinsellor’s Privacy Policy and related regulations.

Once the User’s identity has been verified, Coinsellor can remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

Coinsellor is prohibited from transacting with individuals, companies, and countries that are on prescribed sanctions lists. Coinsellor will therefore screen against United Nations, European Union, UK Treasury, and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

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

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing, and other illegal activity.

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Coinsellor relies on data analysis as a risk-assessment and suspicion detection tool. Coinsellor performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

With regard to the AML/KYC Policy, Coinsellor will monitor all transactions and it reserves the right to:

The above list is not exhaustive, and the Compliance Officer will monitor Users’ transactions on a day-to-day basis to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

Coinsellor, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Coinsellor ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.