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Terms and Conditions
This document was last updated on September 5, 2018
PlasmaPay services are provided by Plasma Alliance OÜ, an Estonia entity. Plasma Alliance OÜ is not a regulated financial services provider.
1. Basic Services
To be eligible to use the PlasmaPay Services, you must be at least 18 years old. Your eligibility to access certain PlasmaPay Services also depends on the country in which you reside. Before using, learn about possible restrictions in accordance with the laws of your residence country.
Important note: PlasmaPay does not accept any users in the USA (residents and citizens), Afghanistan, Albania, Algeria, Bangladesh, Bahamas, Bolivia, Bosnia and Herzegovina, Botswana, Brunei, Burundi, Canada, Central African Republic, Chad, Congo Republic, Cote D’Ivoire (Ivory Coast), Crimea Region, Cuba, Democratic Republic of Congo, Egypt, El Salvador, Ethiopia, Ghana, Guyana, Guinea, Guinea-Bissau, Iran, Iraq, Japan, Laos (Lao PDR), Lebanon, Lesotho, Libya, Macedonia, Mali, Morocco, Myanmar, Namibia, Nepal, Nicaragua, North Korea (Democratic People’s Republic of Korea), Saudi Arabia, Serbia, Somalia, Sudan, South Sudan, Syria, Tunisia, Turkey, Uganda, Vanuatu, Venezuela, Yemen, Zimbabwe.
If you are traveling to any of these countries, you acknowledge that our services may be unavailable and/or blocked in such countries. PlasmaPay reserves the right to impose additional requirements or conditions before accepting users residing in or from specific countries in its sole discretion.
1.2. Electronic Signatures and Agreement(s)
You acknowledge and agree that by clicking the “I agree” button or similar buttons or links as may be designated by PlasmaPay to show Your approval of any foregoing texts, the use of the Services (as defined below), you are entering into a legally binding contract. You hereby agree to the use of electronic communication in order to enter into contracts, place orders and other records and to the electronic delivery of notices, policies and records of transactions initiated or completed through our websites and platforms. Furthermore, you hereby waive any rights or requirements under any laws or regulations in any jurisdiction which require an original (non-electronic) signature or delivery or retention of non-electronic records, to the extent permitted under applicable mandatory law.
1.3. PlasmaPay Services
Your PlasmaPay account (“PlasmaPay Account”) encompasses the following basic PlasmaPay services: one or more Digital Currency wallets that allow users to store certain supported digital currencies, like Bitcoin, Litecoin or Ethereum (“Digital Currency”), and to track, transfer, and manage their supported Digital Currencies (the “Digital Currency Wallet”); Digital Currency conversion services through which users can buy and sell supported Digital Currencies in transactions with PlasmaPay (the “Exchange Services”); and a Fiat Currency (e.g. USD, EUR, RUB) account for use in connection with other PlasmaPay Services (a “Currency Wallet”) and for eligible users, a Digital Currency exchange service (collectively the “Plasma Pay Services”).
The risk of loss in trading or holding Digital Currency can be substantial. You should therefore carefully consider whether trading or holding Digital Currency is suitable for your financial condition.
2. Creating a PlasmaPay Account
2.1. Registration of PlasmaPay Account
In order to use any of the PlasmaPay Services, you must first register by providing your full name, E-mail address, password, and affirming your acceptance of this Agreement. PlasmaPay may, in our sole discretion, refuse to allow you to establish a PlasmaPay Account or limit the number of PlasmaPay Accounts that a single user may establish and maintain at any time.
2.2. Identity Verification
In order to use certain features of the PlasmaPay Services, including certain transfers of Digital Currency and/or government-issued currency (“Fiat Currency”), you will be required to provide PlasmaPay with certain personal information, including, but not limited to, your full name, address, phone number, E-mail address, date of birth, taxpayer identification number, government identification number, and information regarding your bank account (e.g., financial institution, account type, routing number, and account number). In submitting this or any other personal information as may be required, you verify that the information is accurate and authentic, and you agree to update PlasmaPay if any information changes.
You hereby authorize PlasmaPay to, directly or through third parties make any inquiries we consider necessary to verify your identity and/or protect against fraud, including to query identity information contained in public reports (e.g., your name, address, past addresses, or date of birth), to query account information associated with your linked bank account (e.g., name or account balance), and to take action we reasonably deem necessary based on the results of such inquiries and reports. You further authorize any and all third parties to which such inquiries or requests may be directed to fully respond to such inquiries or requests.
3. Digital Currency Wallet
The Digital Currency Wallet services allow you to deposit, withdrawal and store supported Digital Currency to instructions you provide through the PlasmaPay Site (each such transaction is a “Digital Currency Transaction”).
PlasmaPay reserves the right to refuse to process or to cancel any pending Digital Currency Transaction as required by law or in response to a subpoena, court order, or other binding government order or to enforce transaction limits PlasmaPay cannot reverse a Digital Currency Transaction which has been broadcast to a Digital Currency network. The Digital Currency Wallet services are available only in connection with those Digital Currencies that PlasmaPay, in its sole discretion, decides to support. The Digital Currencies that PlasmaPay supports may change from time to time. If you have any questions about which Digital Currencies PlasmaPay currently supports, please visit support (online chat). Under no circumstances should you attempt to use your Digital Currency Wallet services to store, deposit, or withdrawal digital currencies in any form that are not supported by PlasmaPay. PlasmaPay assumes no responsibility or liability in connection with any attempt to use PlasmaPay Services for digital currencies that PlasmaPay does not support.
3.2. Digital Currency Transactions
PlasmaPay processes supported Digital Currency according to the instructions received from its users and we do not guarantee the identity of any user, or other parties. You should verify all transaction information prior to submitting instructions to PlasmaPay. Once submitted to a Digital Currency network, a Digital Currency Transaction will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the Digital Currency network. A transaction is not complete while it is in a pending state. Funds associated with transactions that are in a pending state will be designated accordingly, and will not be included in your PlasmaPay Account balance or be available to conduct transactions. PlasmaPay may charge network fees (miner fees) to process a Digital Currency transaction on your behalf. PlasmaPay will calculate the network fee in its discretion, although PlasmaPay will always notify you of the network fee at or before the time you authorize the transaction.
3.3. Digital Currency Storage and Transmission Delays
PlasmaPay securely stores Digital Currency Hot Wallets’ private keys in our control in a combination of online and offline storage. As a result, it may be necessary for PlasmaPay to retrieve certain information from offline storage in order to facilitate a Digital Currency Transaction in accordance with your instructions, which may delay the initiation or credit of such Digital Currency Transaction for 48 hours or more. You acknowledge and agree that a Digital Currency Transaction facilitated by PlasmaPay may be delayed.
3.4 Digital Currency Protocols
PlasmaPay does not own or control the underlying software protocols which govern the operation of Digital Currencies supported on our platform. In general, the underlying protocols are open source and anyone can use, copy, modify, and distribute them. By using the PlasmaPay platforms, you acknowledge and agree (i) that PlasmaPay is not responsible for operation of the underlying protocols and that PlasmaPay makes no guarantee of their functionality, security, or availability; and (ii) that the underlying protocols are subject to sudden changes in operating rules (a/k/b “forks”), and that such forks may materially affect the value, function, and/or even the name of the Digital Currency you store in the PlasmaPay platform. In the event of a fork, you agree that PlasmaPay may temporarily suspend PlasmaPay operations (with or without advance notice to you) and that PlasmaPay may, in its sole discretion, decide whether or not to support (or cease supporting) either branch of the forked protocol entirely. You acknowledge and agree that PlasmaPay assumes absolutely no responsibility whatsoever in respect of an unsupported branch of a forked protocol.
4. Exchange Services
4.1. In General
Eligible users in certain jurisdictions may buy or sell supported Digital Currency through the Exchange Services. The Exchange Services are subject to the PlasmaPay “Exchange Rate” for the given transaction. “Exchange Rate” means the price of a given supported Digital Currency amount in terms of Fiat Currency or other Digital Currency as quoted on the PlasmaPay Site. The Exchange Rate is stated either as a “Buy Price” or as a “Sell Price”, which is the price in terms of Fiat Currency or Digital Currency at which you may buy or sell supported Digital Currency to PlasmaPay. You acknowledge that the Buy Price Exchange Rate may not be the same as the Sell Price Exchange Rate at any given time and that PlasmaPay may add a margin or “spread” to the quoted Exchange Rate. You agree, as a condition of using any PlasmaPay Exchange Services, to accept the Exchange Rate as the sole conversion metric. PlasmaPay reserves the right to delay any Exchange Service transaction if it perceives a risk of fraud or illegal activity. PlasmaPay does not guarantee the availability of its Exchange Service, and the act of purchasing supported Digital Currency from PlasmaPay does not result in a guarantee that you may sell your supported Digital Currency to PlasmaPay.
4.2. Purchase Transactions
After successfully completing the verification procedures, you may purchase supported Digital Currency by linking a valid payment method. You authorize PlasmaPay to initiate debits from your selected payment method(s) in settlement of purchase transactions. Exchange Fee (defined below) applies to all purchase transactions. Although PlasmaPay will attempt to deliver supported Digital Currency to you as promptly as possible, funds may be debited from your selected payment method before Digital Currency is delivered to your PlasmaPay Account. We will make best efforts to fulfill all transactions, but in the rare circumstance where PlasmaPay cannot fulfill your purchase order, we will notify you and seek your approval to fulfill the purchase order at the contemporaneous Buy Price Exchange Rate. To secure the performance of your obligations under this Agreement, you grant to PlasmaPay a lien on and security interest in and to the balances in your account.
4.3. Sale Transactions
After successfully completing the verification procedures, you may sell supported Digital Currency by linking a valid payment method. You authorize PlasmaPay to debit your PlasmaPay Account(s) and initiate payments to your selected payment method(s) in settlement of sell transactions. An applicable Exchange Fee (defined below) applies to all sale transactions. Your receipt of funds will depend on the payment type and may take up to three or more business days.
4.4. Exchange Fees
Each Exchange Service transaction is subject to a fee (an “Exchange Fee”). The applicable Exchange Fee is displayed to you on the PlasmaPay Site prior to you completing an Exchange Service transaction. PlasmaPay will not process a conversion transaction if the Exchange Fee and any other associated fees, such as wire transfer fees, would exceed the value of your transaction. Payments using other methods not described below, such as wire (if permitted), are subject to different transaction fees disclosed to you before you authorize the transaction. The availability of each Payment Method depends on a number of factors, including but not limited to your location, the identification information you have provided to us, and limitations imposed by third-party payment processors. PlasmaPay reserves the right to adjust its Exchange Fees and any applicable waivers at any time. We will always notify you of the Exchange Fee which applies to your transaction, both at the time of the transaction and in each receipt we issue to you.
You can view the current fee applicable to your location and payment method at our Fees page.
4.5. Reversals and Cancellations
You cannot cancel, reverse, or change any transaction marked as complete or pending. If your payment is not successful or if your payment method has insufficient funds, you authorize PlasmaPay, in its sole discretion, either to cancel the transaction or to debit your other payment methods, including PlasmaPay balances or other linked accounts, in any amount necessary to complete the transaction. You are responsible for maintaining an adequate balance and/or sufficient credit limits in order to avoid overdraft, insufficient funds, or similar fees charged by your payment provider.
PlasmaPay reserves the right to refuse to process, or to cancel or reverse, any purchases or sales of Digital Currency in its sole discretion, even after funds have been debited from your account(s), if PlasmaPay suspects the transaction involves (or has a high risk of involvement in) money laundering, terrorist financing, fraud, or any other type of financial crime; in response to a subpoena, court order, or other government order; if PlasmaPay reasonably suspects that the transaction is erroneous; or if PlasmaPay suspects the transaction relates to prohibited use or a prohibited Business as set forth below. In such instances, PlasmaPay will reverse the transaction and we are under no obligation to allow you to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction.
4.6. Payment Services Partners
PlasmaPay may use a third-party payment processor to process any Fiat Currency payment between you and PlasmaPay, including but not limited to payments in relation to your use of the Exchange Service or deposits or withdrawals from your Currency Wallet or PlasmaPay Account.
5. Currency Wallet
5.1. Currency Wallets
All registered users may establish and fund only one Currency Wallet to facilitate transactions on the PlasmaPay platform. You are the owner of the balance of your Currency Wallet. PlasmaPay holds the balance of your Currency Wallet in a dedicated custodial account with a financial institution. All funds held in a Currency Wallet are held on trust by PlasmaPay for the benefit of the user, or by a licensed Electronic Money Institution on behalf of the user.
5.2. Deposits and Withdrawals
You may initiate a transfer from your linked credit card or the bank account to fund a Currency Wallet. Fees may apply to deposits and withdrawals from your Currency Wallet. All fees will be clearly disclosed in your PlasmaPay account and at Fees page. For deposits, PlasmaPay will credit your Currency Wallet a corresponding amount of Fiat Currency after funds are delivered to PlasmaPay, typically within two to five business days after you authorize a deposit. For withdrawals, PlasmaPay will immediately debit your Currency Wallet when you authorize a withdrawal and funds will typically settle to you within two to five business days. Bank fees are netted out of transfers to or from PlasmaPay. We will not process a transfer if associated bank fees exceed the value of the transfer.
6. General Use, Prohibited Use, and Termination
6.1. Limited License
We grant you a limited, nonexclusive, nontransferable license, subject to the terms of this Agreement, to access and use the PlasmaPay Site, and related content, materials, information (collectively, the “Content”) solely for approved purposes as permitted by PlasmaPay from time to time. Any other use of the PlasmaPay Site or Content is expressly prohibited and all other rights, title, and interest in the PlasmaPay Site or Content is exclusively the property of PlasmaPay and its licensors. You agree you will not copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part. “PlasmaPay.com”, “PlasmaPay” and all logos related to the PlasmaPay Services or displayed on the PlasmaPay Site are either trademarks or registered marks of PlasmaPay or its licensors. You may not copy, imitate or use them without PlasmaPay’s prior written consent.
6.2. Website Accuracy
Although we intend to provide accurate and timely information on the PlasmaPay Site, the PlasmaPay Site (including, without limitation, the Content) may not always be entirely accurate, complete or current and may also include technical inaccuracies or typographical errors. In an effort to continue to provide you with as complete and accurate information as possible, information may be changed or updated from time to time without notice, including without limitation information regarding our policies, products and services. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the PlasmaPay Site are your sole responsibility and we shall have no liability for such decisions. Links to third-party materials (including without limitation websites) may be provided as a convenience but are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any third-party materials or on any third-party sites accessible or linked to the PlasmaPay Site.
6.3. Third-Party Applications
If, to the extent permitted by PlasmaPay from time to time, you grant express permission to a third party to access or connect to your PlasmaPay Account, either through the third party’s product or service or through the PlasmaPay Site, you acknowledge that granting permission to a third party to take specific actions on your behalf does not relieve you of any of your responsibilities under this Agreement. You are fully responsible for all acts or omissions of any third party with access to your PlasmaPay Account. Further, you acknowledge and agree that you will not hold PlasmaPay responsible for, and will indemnify PlasmaPay from, any liability arising out of or related to any act or omission of any third party with access to your PlasmaPay Account. You may change or remove permissions granted by you to third parties with respect to your PlasmaPay Account at any time through the Account Settings (Integrations) page on the PlasmaPay Site.
6.4. Prohibited Use
In connection with your use of the PlasmaPay Services, and your interactions with other users, and third parties you agree and represent you will not engage in any prohibited business or prohibited use defined herein. We reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request. We reserve the right to cancel and/or suspend your PlasmaPay Account and/or block transactions or freeze funds immediately and without notice, if we determine, in our sole discretion, that your Account is associated with a prohibited use and/or a prohibited business.
6.5. Export Controls & Sanctions
Your use of the PlasmaPay Services and the PlasmaPay Site is subject to international export controls and economic sanctions requirements. By sending, receiving, buying, selling, trading or storing Digital Currency through the PlasmaPay Site or PlasmaPay Services, you represent and warrant that you will comport with those requirements. Without limiting the foregoing, you may not acquire Digital Currency or use any of the PlasmaPay Services through the PlasmaPay Site if: (1) you are in, under the control of, or a national or resident of Cuba, Iran, North Korea, Sudan, or Syria or any other country subject to United States embargo, UN sanctions, HM Treasury’s financial sanctions regime, or if you are on the U.S. Treasury Department’s Specially Designated Nationals List or the U.S. Commerce Department’s Denied Persons List, Unverified List, Entity List HM Treasury’s financial sanctions regime; or (2) you intend to supply any acquired or stored Digital Currency or PlasmaPay Services to Cuba, Iran, North Korea, Sudan or Syria or any other country subject to United States embargo or HM Treasury’s financial sanctions regime (or a national or resident of one of these countries), or to a person on the Specially Designated Nationals List, Denied Persons List, Unverified List, Entity List, or HM Treasury’s financial sanctions regime.
6.6. Transactions Limits
The use of all PlasmaPay Services is subject to a limit on the amount of volume, stated in Fiat Currency terms, you may transact or transfer in a given period (e.g., daily). Your transaction limits may vary depending on your payment method, verification steps you have completed, and other factors. PlasmaPay reserves the right to change applicable limits as we deem necessary in our sole discretion. If you wish to raise your limits beyond the posted amounts, you may submit a request at support (online chat). We may require you to submit additional information about yourself or your business, provide records, and arrange for meetings with PlasmaPay staff (such process, “Advanced Due Diligence”). PlasmaPay reserves the right to charge you costs and fees associated with Advanced Due Diligence provided that we notify you in advance of any such charges accruing. In our sole discretion, we may refuse to raise your limits or we may lower your limits at a subsequent time even if you have completed Advanced Due Diligence.
6.7. Suspension, Termination, and Cancellation
PlasmaPay may: (a) suspend, restrict, or terminate your access to any or all of the PlasmaPay Services, and/or (b) deactivate or cancel your PlasmaPay Account if:
- We are so required by a facially valid subpoena, court order, or binding order of a government authority; or
- We reasonably suspect you of using your PlasmaPay Account in connection with prohibited use or business, or We reasonably suspect you of using your PlasmaPay Account in connection with prohibited use or business; or
- Use of your PlasmaPay Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Account activity; or
- Our service partners are unable to support your use; or
- You take any action that PlasmaPay deems as circumventing PlasmaPay’s controls, including, but not limited to, opening multiple PlasmaPay Accounts or abusing promotions which PlasmaPay may offer from time to time.
- You breach our Legal Agreements.
If PlasmaPay suspends or closes your account, or terminates your use of PlasmaPay Services for any reason, we will provide you with notice of our actions unless a court order or other legal process prohibits PlasmaPay from providing you with such notice. You acknowledge that PlasmaPay’s decision to take certain actions, including limiting access to, suspending, or closing your account, may be based on confidential criteria that are essential to PlasmaPay’s risk management and security protocols. You agree that PlasmaPay is under no obligation to disclose the details of its risk management and security procedures to you. You will be permitted to transfer Digital Currency or funds associated with your Digital Currency Wallet and/or your Currency Wallet for ninety (90) days after Account deactivation or cancellation unless such transfer is otherwise prohibited (i) under the law, including but not limited to applicable sanctions programs, or (ii) by a facially valid subpoena or court order. If PlasmaPay suspends or closes your account or terminates your use of PlasmaPay Services for any reason PlasmaPay reserves the right to require you to complete the verification procedures before permitting you with a transfer or withdraw Digital Currency or Fiat Currency.
You may cancel your PlasmaPay Account at any time by withdrawing all balances and visiting support (online chat) with registering an appropriate request. You will not be charged for canceling your PlasmaPay Account, although you will be required to pay any outstanding amounts owed to PlasmaPay. You authorize us to cancel or suspend any pending transactions at the time of cancellation.
6.8. Relationship of the Parties
PlasmaPay is an independent contractor for all purposes. Nothing in this agreement shall be deemed or is intended to be deemed, nor shall it cause, you and PlasmaPay to be treated as partners, joint ventures, or otherwise as joint associates for profit, or either you or PlasmaPay to be treated as the agent of the other.
6.9. Privacy of Others and Marketing
If you receive information about another user through the PlasmaPay Services, you must keep the information confidential and only use it in connection with the PlasmaPay Services. You may not disclose or distribute a user’s information to a third party or use the information except as reasonably necessary to effectuate a transaction and other functions reasonably incidental thereto such as support, reconciliation and accounting unless you receive the user’s express consent to do so. You may not send unsolicited email to a user through the PlasmaPay Services.
6.10. Password Security and Contact Information
You are responsible for maintaining adequate security and control of any and all IDs, passwords, hints, personal identification numbers (PINs), API keys or any other codes that you use to access the PlasmaPay Services. Any loss or compromise of the foregoing information and/or your personal information may result in unauthorized access to your PlasmaPay Account by third parties and the loss or theft of any Digital Currency and/or funds held in your PlasmaPay Account and any associated accounts, including your linked bank account(s) and credit card(s). You are responsible for keeping your email address and telephone number up to date in your Account Profile in order to receive any notices or alerts that we may send you. We assume no responsibility for any loss that you may sustain due to compromise of account login credentials due to no fault of PlasmaPay and/or failure to follow or act on any notices or alerts that we may send to you. In the event you believe your PlasmaPay Account information has been compromised, contact PlasmaPay Support immediately at [email protected].
It is your sole responsibility to determine whether, and to what extent, any taxes apply to any transactions you conduct through the PlasmaPay 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 PlasmaPay Account.
6.12. Unclaimed Property
If PlasmaPay is holding funds in your account, and PlasmaPay is unable to contact you and has no record of your use of the Services for several years, applicable law may require PlasmaPay to report these funds as unclaimed property to the applicable jurisdiction. If this occurs, PlasmaPay will try to locate you at the address shown in our records, but if PlasmaPay is unable to locate you, it may be required to deliver any such funds to the applicable or jurisdiction as unclaimed property. PlasmaPay reserves the right to deduct a dormancy fee or other administrative charges from such unclaimed funds, as permitted by applicable law.
7. Customer Feedback, Queries, Complaints, and Dispute Resolution
7.1. Contact PlasmaPay
If you have any feedback, questions, or complaints, contact us via our Customer Support webpage at support (online chat) or write to us at PlasmaPay OU, Peterburi tee 47, Lasnamae linnaosa, Tallinn, Harju maakond 11415, Estonia.
When you contact us please provide us with your name, address, and any other information we may need to identify you, your PlasmaPay Account, and the transaction on which you have feedback, questions, or complaints.
In the event of a complaint, please set out the cause of your complaint, how you would like us to resolve the complaint and any other information you believe to be relevant. We will acknowledge your complaint within 24 hours of its receipt if you contact our Customer Support. A Customer Support specialist will consider your complaint without prejudice based on the information you have provided and any information provided by PlasmaPay. Within four weeks of our receipt of your complaint a Customer Support specialist will address your complaint by sending you an e-mail (“Resolution Notice”) in which a Customer Support specialist will: (i) offer to resolve your complaint in the way your request; (ii) make a determination rejecting your complaint and set out the reasons for the rejection; or (iii) offer to resolve your complaint with an alternative solution. Upon receipt of the Resolution Notice, you will have 20 business days to accept or reject the offer or determination, which you must do by following the instructions set out in the Resolution Notice. Failure to respond to a Resolution Notice will be deemed to be a withdrawal of the complaint and an acceptance that we have no liability to you regarding the subject matter of the complaint. If you are late in responding to the Resolution Notice, PlasmaPay may treat your response as if it has been submitted on time.
In the event that you reject an offer or determination (“Rejection”), please set out the reasons for the Rejection and include any additional information that you believe is pertinent to your complaint. Any Rejection will be treated as an application to appeal the offer or determination set out in the Resolution Notice. Our Customer Support Supervisor (“Supervisor”) will impartially consider your complaint (including any additional information provided). We will acknowledge your Rejection within 24 hours of its receipt if you contact us in the prescribed electronic way, and within ten business days if you contact us in any other prescribed way. Within four weeks of our receipt of the Rejection the Supervisor will address your complaint by sending you an e-mail (“Final Notice”) in which the Supervisor will: (i) uphold the Resolution Notice; or (ii) reject the Resolution Notice. Notwithstanding its decision regarding the Resolution Notice, the Supervisor may also make a new offer to resolve the complaint. Upon receipt of the Final Notice, you will have 20 business days to accept or reject the offer or determination, which you must do by following the instructions set out in the Final Notice. PlasmaPay may extend the deadline for you to accept the offer. Failure to respond to a Final Notice will be deemed to be a withdrawal of the complaint and an acceptance that we have no liability to you regarding the subject matter of the complaint. For consumers only: if you fail to respond to a Final Notice and file a claim in a competent court, your failure may be used as evidence of your unwillingness to settle the issue and/or the vexatious nature of the complaint.
Any offer made under this section 7 will only become binding on PlasmaPay if you accept the offer by following the instructions provided by PlasmaPay within the stated timeframe. Any offer under this section 7 will not constitute any admission by PlasmaPay of any wrongdoing or liability regarding the subject matter of the complaint. Any acceptance of an offer by you will constitute an acceptance that the complaint is resolved and an undertaking that you will not file a claim in any competent court against PlasmaPay regarding the subject matter of the complaint. 7.5. Claims. This provision only applies to consumers. You agree to use the complaints procedure of Section 7 before filing any claim in a competent court. Failure to comply with this provision may be used as evidence of your unwillingness to settle the issue and/or the vexatious nature of the complaint.
8. General Provisions
8.1. Computer Viruses
We shall not bear any liability, whatsoever, for any damage or interruptions caused by any computer viruses, spyware, scareware, Trojan horses, worms or other malware that may affect your computer or other equipment, or any phishing, spoofing or other attacks. We advise the regular use of a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from PlasmaPay. Always log into your PlasmaPay Account through the PlasmaPay Site to review any transactions or required actions if you have any uncertainty regarding the authenticity of any communication or notice.
8.2. Limitation of Liability
IN NO EVENT SHALL PLASMAPAY, ITS AFFILIATES AND SERVICE PROVIDERS, OR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES OR REPRESENTATIVES, BE LIABLE (A) FOR ANY AMOUNT GREATER THAN THE VALUE OF THE SUPPORTED DIGITAL CURRENCY ON DEPOSIT IN YOUR PLASMAPAY ACCOUNT OR (B) FOR ANY LOST PROFITS OR ANY SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, OR CONSEQUENTIAL DAMAGES, WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, ARISING OUT OF OR IN CONNECTION WITH AUTHORIZED OR UNAUTHORIZED USE OF THE PLASMAPAY SITE OR THE PLASMAPAY SERVICES, OR THIS AGREEMENT, EVEN IF AN AUTHORIZED REPRESENTATIVE OF PLASMAPAY HAS BEEN ADVISED OF OR KNEW OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES. THIS MEANS, BY WAY OF EXAMPLE ONLY (AND WITHOUT LIMITING THE SCOPE OF THE PRECEDING SENTENCE), THAT IF YOU CLAIM THAT PLASMAPAY FAILED TO PROCESS A BUY OR SELL TRANSACTION PROPERLY, YOUR DAMAGES ARE LIMITED TO NO MORE THAN THE VALUE OF THE SUPPORTED DIGITAL CURRENCY AT ISSUE IN THE TRANSACTION, AND THAT YOU MAY NOT RECOVER FOR LOST PROFITS, LOST BUSINESS OPPORTUNITIES, OR OTHER TYPES OF SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, OR CONSEQUENTIAL DAMAGES IN EXCESS OF THE VALUE OF THE SUPPORTED DIGITAL CURRENCY AT ISSUE IN THE TRANSACTION.SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES SO THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU.
THE PLASMAPAY SERVICES ARE PROVIDED ON AN “ASIS” AND “AS-AVAILABLE” BASIS WITHOUT ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, PLASMAPAY SPECIFICALLY DISCLAIMS ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND/OR NON-INFRINGEMENT. PLASMAPAY DOES NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT ACCESS TO THE SITE, ANY PART OF THE PLASMAPAY SERVICES, OR ANY OF THE MATERIALS CONTAINED THEREIN, WILL BE CONTINUOUS, UNINTERRUPTED, TIMELY, OR ERROR-FREE.
PlasmaPay makes no representations about the accuracy or completeness of historical Digital Currency price data available on the Site. PlasmaPay will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts, credit cards, and check issuances are processed in a timely manner but PlasmaPay makes no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control.
8.3. Entire Agreement
We may amend or modify this Agreement by posting on the PlasmaPay Site or emailing to you the revised Agreement, and the revised Agreement shall be effective at such time. If you do not agree with any such modification, your sole and exclusive remedy is to terminate your use of the Services and close your account. You agree that we shall not be liable to you or any third party for any modification or termination of the PlasmaPay Services, or suspension or termination of your access to the PlasmaPay Services, except to the extent otherwise expressly set forth herein. If the revised Agreement includes a material change, we will endeavor to provide you advanced notice via our website and/or email before the material change becomes effective.
You may not assign any rights and/or licenses granted under this Agreement. We reserve the right to assign our rights without restriction, including without limitation to any PlasmaPay affiliates or subsidiaries, or to any successor in interest of any business associated with the PlasmaPay Services. Any attempted transfer or assignment in violation hereof shall be null and void. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns.
If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law or regulation or any governmental agency, local, state, or federal, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of this Agreement shall not be affected.
8.7 Change of Control
In the event that PlasmaPay is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control.
All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, sections pertaining to suspension or termination, PlasmaPay Account cancellation, debts owed to PlasmaPay, general use of the PlasmaPay Site, disputes with PlasmaPay, and general provisions, shall survive the termination or expiration of this Agreement.
8.9 Governing Law
This Agreement will be governed by Estonian law and the non-exclusive jurisdiction of the Estonian courts.
8.10 Force Majeure
We shall not be liable for delays, failure in performance or interruption of service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to, any delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.
8.11. English Language Controls
Notwithstanding any other provision of this Agreement, any translation of this Agreement is provided for your convenience. The meanings of terms, conditions and representations herein are subject to definitions and interpretations in the English language. Any translation provided may not accurately represent the information in the original English.
APPENDIX 1: PROHIBITED USE
You may not use your PlasmaPay Account to engage in the following categories of activity (“Prohibited Uses”). The specific types of use listed below are representative, but not exhaustive. If you are uncertain as to whether or not your use of PlasmaPay Services involves a Prohibited Use, or have questions about how these requirements apply to you, please submit a request at support (online chat). By opening a PlasmaPay Account, you confirm that you will not use your Account to do any of the following:
- Unlawful Activity: Activity which would violate, or assist in violation of, any law, statute, ordinance, or regulation, sanctions programs administered in the countries where PlasmaPay conducts business, including but not limited to the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), or which would involve proceeds of any unlawful activity; publish, distribute or disseminate any unlawful material or information;
- Abusive Activity: Actions which impose an unreasonable or disproportionately large load on our infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information; transmit or upload any material to the PlasmaPay Site that contains viruses, trojan horses, worms, or any other harmful or deleterious programs; attempt to gain unauthorized access to the PlasmaPay Site, other PlasmaPay Accounts, computer systems or networks connected to the PlasmaPay Site, through password mining or any other means; use PlasmaPay Account information of another party to access or use the PlasmaPay Site, except in the case of specific Merchants and/or applications which are specifically authorized by a user to access such user’s PlasmaPay Account and information; or transfer your account access or rights to your account to a third party, unless by operation of law or with the express permission of PlasmaPay;
- Abuse Other Users: Interfere with another individual’s or entity’s access to or use of any PlasmaPay Services; defame, abuse, extort, harass, stalk, threaten or otherwise violate or infringe the legal rights (such as, but not limited to, rights of privacy, publicity and intellectual property) of others; incite, threaten, facilitate, promote, or encourage hate, racial intolerance, or violent acts against others; harvest or otherwise collect information from the PlasmaPay Site about others, including without limitation email addresses, without proper consent;
- Fraud: Activity which operates to defraud PlasmaPay, PlasmaPay users, or any other person; provide any false, inaccurate, or misleading information to PlasmaPay;
- Intellectual Property Infringement: Engage in transactions involving items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the law, including but not limited to sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorization from the rights holder; use of PlasmaPay intellectual property, name, or logo, including use of PlasmaPay trade or service marks, without express consent from PlasmaPay or in a manner that otherwise harms PlasmaPay or the PlasmaPay brand; any action that implies an untrue endorsement by or affiliation with PlasmaPay.
APPENDIX 2: VERIFICATION PROCEDURES AND LIMITS
PlasmaPay uses multi-level systems and procedures to collect and verify information about you in order to protect PlasmaPay and the community from fraudulent users and to keep appropriate records of PlasmaPay’s customers. Your access to one or more PlasmaPay Services, and limits including daily or weekly exchange limits, deposit, withdrawal and trading limits, and limits on transactions from a linked payment method may be based on the identifying information and/or proof of identity you provide to PlasmaPay.
PlasmaPay may require you to provide additional documents or verify additional information or to wait some amount of time after completion of a transaction, before permitting you to use any PlasmaPay Services and/or before permitting you to engage in transactions beyond certain volume limits. You may determine the volume limits associated with your account by visiting your account’s profile page.
You may submit a request at support to request increase the limits for your account. PlasmaPay may require you to submit to Advanced Due Diligence. Additional fees and costs may apply, and PlasmaPay does not guarantee that we will raise your limits.
APPENDIX 3: DIGITAL (ONLINE) DISCLOSURE AND CONSENT
This policy describes how PlasmaPay delivers communications to you electronically. We may amend this policy at any time by providing a revised version on our website. The revised version will be effective at the time we post it. We will provide you with prior notice of any material changes via our website.
1. Delivery of Communications.
You agree and consent to receive electronically all communications, agreements, documents, notices and disclosures (collectively, “Communications”) that we provide in connection with your PlasmaPay Account and your use of PlasmaPay Services. Communications include:
- Account details, history, transaction receipts, confirmations, and any other Account or transaction information;
- Legal, regulatory, and tax disclosures or statements we may be required to make available to you;
- Responses to claims or customer support inquiries filed in connection with your Account.
We will provide these Communications to you by posting them on the PlasmaPay website, emailing them to you at the primary email address listed in your PlasmaPay profile, communicating to you via instant chat, and/or through other electronic communication such as text message or mobile push notification.
2. Hardware and Software Requirements.
In order to access and retain electronic Communications, you will need the following computer hardware and software:
- A device with an Internet connection;
- A current web browser that includes 128-bit encryption (e.g. Internet Explorer version 9.0 and above, Firefox version 3.6 and above, Chrome version 31.0 and above, or Safari 7.0 and above) with cookies enabled;
- A valid email address (your primary email address with PlasmaPay);
- Sufficient storage space to save past Communications or an installed printer to print them.
3. How to Withdraw Your Consent.
You may withdraw your consent to receive Communications electronically by contacting us at support (online chat). If you fail to provide or if you withdraw your consent to receive Communications electronically, PlasmaPay reserves the right to immediately close your Account or charge you additional fees for paper copies.
4. Updating your Information.
It is your responsibility to provide us with a true, accurate and complete e-mail address and your contact information, and to keep such information up to date. You understand and agree that if PlasmaPay sends you an electronic Communication but you do not receive it because your primary email address on file is incorrect, out of date, blocked by your service provider, or you are otherwise unable to receive electronic Communications, PlasmaPay will be deemed to have provided the Communication to you.
You may update your information by logging into your account and visiting settings or by contacting our support team at support (online chat).
APPENDIX 4. TERMS FOR DEVELOPERS
1. Developers API and License
1.1. Developers API
This Agreement governs your use of any and all development applications provided by PlasmaPay, including, but not limited to PlasmaPay’s application programming interface and any accompanying or related documentation, source code, executable applications and other materials (the “PlasmaPay API”), and any other resources or services available at https://PlasmaPay.com/dev/trade (“PlasmaPay Services”) provided to you pursuant to this Agreement (collectively, the “Developers API”). Use of the Developers API is subject to this Part 4 and is also subject to General Use terms, including without limitation the releases, indemnities, disclaimers, limitations of liability, prohibited use, dispute resolution, and cancellation policies set forth above.
Subject to the terms and restrictions set forth in this Agreement, PlasmaPay provide you a limited, revocable, non-exclusive, non-transferrable and non-sublicensable license solely to use and integrate the Developers API and underlying content into your website or application (your “Application”) so that your Application can interface directly with PlasmaPay devices, applications, or services.
1.3. Restrictions and Responsibilities
By using the Developers API, you agree to the following terms:
1.3.1. You shall:
- Register for a PlasmaPay Account.
- Comply with all applicable laws, regulations, licensing requirements, and third party rights (including, without limitation, data privacy laws).
- Represent and warrant that your Application, including but not limited to the name of the Application and all content in your Application, does not infringe the Intellectual Property rights of PlasmaPay or any third party.
- Use the PlasmaPay marks only as expressly authorized in this Agreement.
- Obtain prior written approval from PlasmaPay prior to releasing any statements, written media releases, public announcements and public disclosures, including promotional or marketing materials, relating to PlasmaPay, the PlasmaPay marks, or this Agreement.
- Comply with additional verification procedures in the event that your Application seeks API Key permissions to transfer Digital Currency in an amount greater than predefined limits.
- Take steps to adequately secure your API Keys, including the measures specified at Developers Page.
1.3.2. You shall not:
- Copy, rent, lease, sell, sublicense, or otherwise transfer your Developer’s API rights to a third party.
- Alter, reproduce, adapt, distribute, display, publish, reverse engineer, translate, disassemble, decompile or otherwise attempt to create any source code that is derived from the Developer’s API.
- Cache, aggregate, or store data or content accessed via the Developer’s API other than for purposes allowed under this Agreement.
- Use the Developer’s API for any Application that constitutes, promotes or is used in connection with spyware, adware, or any other malicious programs or code.
- Use the Developer’s API to encourage, promote, or participate in illegal activity, violate third party rights, including intellectual property rights or privacy rights, or engage in any prohibited use as defined in the Terms.
- Use the Developer’s API in a manner that exceeds reasonable request volume, constitutes excessive or abusive usage, or otherwise impacts the stability of PlasmaPay’s servers or impacts the behavior of other applications using the Developer’s API.
- Display Developer’s API or PlasmaPay Marks in a manner that could reasonably imply an endorsement, relationship or affiliation with or sponsorship between you or a third party and PlasmaPay, other than as expressly permitted in writing by PlasmaPay.
- Attempt to cloak or conceal your identity or your Application’s identity when requesting authorization to the Developer’s API.
1.3.3 Indemnification. To the maximum extent permitted by law, you agree to defend, indemnify and hold harmless PlasmaPay, its affiliates and their respective directors, officers, employees and agents from and against any and all third party claims, actions, suits or proceedings, as well as any and all losses, liabilities, damages, costs and expenses (including reasonable attorney’s fees) arising out of or accruing from (a) your use of the PlasmaPay API or your PlasmaPay Account in violation of this Agreement, (b) your Application that infringes any copyright, trademark, trade secret, trade dress, patent or other intellectual property rights of any person or defames any person or violates their rights of publicity or privacy, or (c) your failure to secure and keep secret your API key(s).
2. Intellectual Property and Ownership and Use of Marks
As between PlasmaPay and you, the Developer’s API, PlasmaPay Marks, and all intellectual property rights therein and thereto are and shall at all times remain the sole and exclusive property of PlasmaPay and are protected by applicable intellectual property laws and treaties. You have no rights with respect to Developer’s API or PlasmaPay Marks except as expressly set forth herein. If you obtain PlasmaPay’s prior written consent, you may use and display PlasmaPay’s name and logo (“PlasmaPay Marks”) solely to attribute the Developer’s API as the source of your Application.
3. API Calls and Compliance
PlasmaPay may set limits on the number of API calls that you can make at its sole discretion, for example in the interest of service stability. If you exceed these limits, PlasmaPay may moderate your activity or cease offering you access to the PlasmaPay APIs altogether in PlasmaPay’s sole discretion. You agree to such limitations and will not attempt to circumvent such limitations. PlasmaPay may immediately suspend or terminate your access to the Developer’s API without notice if PlasmaPay believes, in its sole discretion, that you are in violation of this Agreement or the Terms.
4. Updates and Support
PlasmaPay may elect to provide you with support or modifications for the Developer’s API, in its sole discretion, and may terminate such support at any time without notice. PlasmaPay may change, suspend, or discontinue any aspect of the Developer’s API at any time, including the availability of any Developer’s API.
5. Security and Privacy
You will use all reasonable efforts to protect Customer Data (as defined below) collected by your Application, including without limitation any personally identifiable information, from unauthorized access or use. In the event your systems or infrastructure that is used for storage, processing or hosting Customer Data are breached or compromised, or if Customer Data is inadvertently exposed to non-authorized third parties, you shall notify PlasmaPay promptly of such a breach or exposure including root cause, remediation steps, and compensating controls to ensure such a breach does not occur in the future. You are responsible for providing customer notification under the state breach notification statutes and any other applicable privacy laws and you will bear the costs incurred by PlasmaPay resulting from your breach or exposure. You acknowledge that you are solely responsible for any personal injury or property damage arising from or relating to your use of any Developer’s API or any authorized or unauthorized use of your Application.
5.2. Privacy and Personally Identifiable Information
5.3. Data Use
You will not sell any Customer Data or disclose any Customer Data to any third party. Your Application may use Customer Data only as required for use and access to your Application by the end-user to whom such Customer Data relates. You shall not sublicense the Customer Data to any third party, and you shall not use or disclose any information derived directly or indirectly from the Customer Data for any purpose other than as set forth above. Without limiting the generality of the foregoing, you shall not use any part of the Customer Data to create a database separate from your Application or transmit all or part of the Customer Data to any third party for any use separate from your Application. Any use of Customer Data other than as expressly permitted by this Agreement is strictly prohibited.
Data Protection Policy
This document was last updated on September 5, 2018
1. About this policy
This is a data protection policy adopted by Plasma Alliance OÜ (“PlasmaPay”). The responsibility for the updating and distribution of this policy rests with PlasmaPay Data Protection Officer. This policy is subject to periodic review to ensure that changes to the relevant legislation or the structure or internal PlasmaPay’s policies are reflected in this policy. PlasmaPay’s directors and staff are expected to apply the policy and to seek advice or consultation as appropriate. In the normal course of commercial operations, PlasmaPay needs to collect and retain certain types of personal data (both public & non-public) from a variety of sources including clients, prospective clients, personnel, suppliers, business contacts, financial companies and institutions, and others who PlasmaPay conducts business with. For the purpose of this policy, these will be referred to as (“Data Subjects”).
In addition, to ensure PlasmaPay complies with its regulatory obligations it may be required by law to collect and use certain types of information.
Personal data means data which relates to an individual who can be identified from that data or from that data combined with other information which is in the possession of, or is likely to come into the possession of, the data controller.
All personal data must be dealt with correctly, as provided for by the safeguards in the General Data Protection Regulation (“GDPR”), however, it is ascertained, recorded and used. This applies equally whether the data is held electronically, on paper or by other means.
In addition to any legal consideration, PlasmaPay believes the lawful and correct treatment of all personal data (non-public) is an essential step in building and maintaining confidence to everyone concerned including both staff, clients and business associates alike. We confirm that our company treats personal data in a lawful and correct manner.
2. Data protection principles
In light of this PlasmaPay fully endorses and comply with the principles set out below in the GDPR which govern the processing of personal data.
The data protection principles under the GDPR and some examples of practical steps taken by PlasmaPay to help ensure compliance with the principles (by the application of appropriate management structure and strict use of criteria and controls) are set out below.
- Personal data shall be processed fairly and lawfully. This principle is an overarching one which impacts upon each of the other principles below.
In particular, processing will not be fair and lawful if the data subject has been deceived or misled as to the purpose or purposes for which their personal data will be processed. PlasmaPay will, therefore, ensure that certain information (“Personal Data”) has been provided to the Data Subjects before processing takes place (i.e. on their data collection forms). This information must include the following:
- the identity of PlasmaPay as the data controller;
- the purpose(s) for which the data will be collected by and processed by PlasmaPay; and any other information that is necessary to enable the particular processing to be fair (some of which are required by the other data protection principles as set out below). For example the recipient or categories of recipient of the data including all who process data on PlasmaPay behalf (e.g. to acquirer bank, processing companies, and governmental authorities);
- whether (or not) any of the intended recipients of the data are outside the European Economic Area;
- whether replies to questions asked by PlasmaPay are obligatory for justifiable operational reasons;
- the existence of the right of access to, and the right to rectify the data;
- the use of personal data for direct marketing purposes;
- the security measures implemented by PlasmaPay regarding the processing;
- PlasmaPay policy on record retention (how long records are kept and any steps taken to ensure that records are accurate and kept up to date);
- PlasmaPay contact details;
- explaining how consent, once given, can later be withdrawn, etc.
In addition to providing the Personal Data, to ensure that all processing is fair and lawful PlasmaPay will also ensure that the processing in question can be justified under certain conditions set out under the GDPR. This means that at least one of the following must be met:
- the data subject has given freely given specific and informed consent to the processing;
- the processing is necessary for the performance of a contract to which the data subject is a party, or for the taking of steps at the request of the data subject with a view to entering into a contract;
- the processing is necessary for compliance with any legal obligation to which the PlasmaPay is subject, other than an obligation imposed by contract;
- the processing is necessary in order to protect the vital interests of the data subject;
- the processing is necessary for the administration of justice, the exercise of any functions conferred on any person by or under any enactment, or for the exercise of any other functions of a public nature exercised in the public interest by any person.
In the case of sensitive personal data (i.e. personal data concerning a Data Subject’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health or condition (which will include employee’s health records), sexual life or the commission or alleged commission of any offence or proceedings for any actual or alleged offence, the disposal of such proceedings or the sentence of any court in such proceedings) this may only be collected stored, used, disclosed or otherwise processed if, in addition to the requirements set out above one of the following conditions is met:
- the data subject concerned has given PlasmaPay specific written consent to process the personal data;
- PlasmaPay needs to process the personal data to carry out its obligations under national employment law;
- PlasmaPay needs to process the personal data to protect the individual (or another person) where that individual is physically or legally incapable of giving his consent (e.g. where an individual has been involved in a road accident or develops a health condition); or
- the processing relates to personal data which has been made public by the individual concerned or is necessary for legal claims.
- Personal data shall be obtained only for one or more specified and lawful purposes and shall not be further processed in any manner incompatible with that purpose or those purposes.
To ensure these goals, PlasmaPay adheres to the following standards and rules:
- Has set up internal procedures to identify the collection points of data (e.g. websites, mobile apps, application forms, emails, etc.), the nature of the data collected and the purposes for which such data is processed;
- will give Data Subjects the processing information when data is collected or obtained;
- will ensure that personal data is not used for reasons not set out in this policy without ensuring that the policy’s conditions are met.
- Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed.
In order to process data in a way which is compatible with the purposes for which it is processed PlasmaPay will periodically review data collection procedures to ensure that they are adequate, relevant and not excessive in relation to the purpose for which data is going to be processed; review requests for personal data, to ensure that all data which is supplied is necessary or whether it can be destroyed; periodically review personal data held in manual filing systems and digital filing systems to ensure that PlasmaPay is holding no more than the minimum of data required for the purpose for which the data was collected, and ensure that if employees are allowed to enter free text onto records, training is given to them to ensure its relevance. Personal data shall be accurate and, where necessary, kept up to date.
PlasmaPay will check that personal data is accurate, complete and current by, for example: keeping a record of the dates on which personal data is created and/or obtained both manually and electronically; assessing the accuracy of the personal data at the time of collection when it comes from sources other than the data subject concerned and, in any case, reviewing the accuracy of personal data before it is entered into any filing systems; ensuring that where personal data is duplicated and held separately (e.g. at a different locations or in a different department) any updates or amendments are communicated to all holders of the personal data and that the personal data is updated/amended accordingly; and checking personal data periodically to ensure that it is accurate and up to date and to evaluate the degree of damage to the Data Subject and PlasmaPay which could be caused through inaccurate or out of date personal data being held. This could be done by putting a procedure in place which provides that when a record is accessed, the individual accessing the file has to sign off that they have briefly reviewed the entire file and removed/amended any inaccurate personal data. Personal data processed for any purpose or purposes shall not be kept for longer than necessary for that purpose or those purposes.
PlasmaPay will comply with this principle by reviewing personal data periodically to determine whether retention is justifiably necessary for legitimate business purposes or whether the personal data can be archived or destroyed, and ascertaining whether such personal data could be retained in an anonymous format (e.g. if kept only for historical or statistical purposes).
- Personal data shall be processed in accordance with the rights of Data Subjects under the GDPR.
PlasmaPay will inform Data Subjects of: the obligatory or optional nature of the personal data requested (e.g. optional fields could be marked with a star which indicates that such personal data may be used for future marketing activities; and how Data Subjects can contact PlasmaPay with any inquiries or complaints about the processing of personal data and the choices and the means offered by PlasmaPay for limiting the use and disclosure of personal data.
PlasmaPay has also established suitable procedures to enable an individual to find out whether personal data (of which that individual is the data subject) is being processed by or on behalf of PlasmaPay and if so what such personal data comprises. Such a request by an individual must be in writing and PlasmaPay may be entitled to charge a small fee for responding to such requests. PlasmaPay has trained staff to recognize subject access requests from Data Subjects and to respond to these in accordance with the GDPR and particularly in accordance with the statutory time limits.
PlasmaPay will ensure the rights granted to the people about whom personal data is held are upheld, including such issues as their right to be informed that processing is being undertaken, their rights to access such personal data, and their rights to correct or have deleted personal data that is determined as wrong personal data.
In order to protect personal data stored by PlasmaPay from being lost, misused, accessed without authorisation, disclosed, altered or destroyed, PlasmaPay will, for example: ensure that all necessary technical and structural security measures are undertaken to safeguard personal data; promote awareness of data security among employees and where possible, conduct training in security responsibilities and issues; only authorise individuals to access personal data where they have a business need to do so, where they are reliable and where they have the appropriate knowledge to make decisions concerning how it should be handled (i.e. carry out background checks and conduct training to ensure that individuals understand their responsibilities, particularly surrounding confidential information and special categories of data).
PlasmaPay will also segregate employee duties to ensure that responsibility for sensitive tasks is appropriately controlled, monitor access to personal data to prevent violations, intentional or accidental damage or disclosure, identify potential security risks and exposures within the company and implement appropriate security measures to counter those risks. According to these measures PlasmaPay will: (i) only give employees access to personal data where they are authorized and have a legitimate business need to do so, (ii) maintain a clear desk policy and ensure that: (i) computer servers are set up to optimise security, (ii) all systems passwords/authorization levels etc. are periodically reviewed to ensure that they are assigned to appropriate staff, (iii) where possible, audit trail capabilities of automated systems are used to track who accesses and amends personal data, (iv) implement procedures to stop all employees whose employment has been terminated or transferred who are no longer used, from accessing systems used to process personal data.
- Personal data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless that country or territory ensures an adequate level of protection for the rights and freedoms of Data Subjects in relation to the processing of personal data.
PlasmaPay will ensure that the transfer of personal data abroad is only done once suitable safeguards have been made. This will be where either one or several of the following conditions apply:
- the Data Subject has given specific consent;
- the transfer is to a country that offers an adequate level of protection, such as countries within the EEA, Switzerland, Argentina, Isle of Man, Guernsey, (please note this list is not intended to be exhaustive and is subject to alteration and addition);
- the transfer is to a US-based company which has signed up to the scheme by using Binding Corporate Rules which are aimed at multinational organizations.
3. Storage security and international data transfers
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secure Sockets Layer technology or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our app and/or our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app or our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Certain services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
4. Data Protection Officer
To enable PlasmaPay to achieve its objective of compliance with the principles of the GDPR we have appointed a designated Data Protection Officer with specific responsibility for data protection who will act as the central focus for all issues relating to data protection. Data Protection Officer will be responsible for identifying information, implementing appropriate data protection measures to comply with applicable law and maintaining those measures at appropriate levels.
Data Protection Officer has a number of important responsibilities including:
- monitoring PlasmaPay’s compliance with the GDPR and other data protection laws;
- raising awareness of data protection issues, training PlasmaPay staff and conducting internal audits; and
- cooperating with supervisory authorities such as the ICO on our behalf.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, you can contact Data Protection Officer as follows:
Data Protection Officer: Alexey M.
Plasma Alliance OÜ (14507139)
Harju maakond, Tallinn, Lasnamae linnaosa
Peterburi tee 47, 11415, Estonia.
This document was last updated on September 5, 2018
1. General information
1.1 Plasma Alliance OÜ (“Company,” or “we,” or “us,” or “our”) is committed to safeguarding the privacy of our website, https://plasmapay.com, and service users (“users” or “you”).
1.2 This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of that personal data.
1.3 This Policy defines the procedure of processing and protection of information on individuals and legal entities (further – the Customers) which can be obtained by the Company when the Customers use of:
- services and facilities provided by the website https://plasmapay.com (hereinafter – the Website);
- the PlasmaPay Mobile App (“App”) once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”); and
- any of the services accessible through the App or the Website (the “Services”).
1.4 The purpose of this Policy is a provision of appropriate protection of information about Customers, including personal data from illegal access and disclosure.
1.5 Relations associated with the collection, storage, sharing and protection of information provided by the Customers are governed by this Policy, other official documents of the Company and the acting legislation of Estonia.
1.6 Making registration on the Website and using the services, the Customers agree with the terms of this Policy. In the case of the Customer’s disagreement with the terms of this Policy, the use of the Site and/or any services and facilities available on the Site should be immediately stopped.
1.8 So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
- always keep your data safe and private;
- never sell your data;
- allow you to manage and review your marketing choices.
2. Types and uses of collected information
Company collects two types of information about you:
2.1 Personally Identifiable Information. This is information that identifies a specific person. When you engage in certain activities via the Services by creating an account for the purpose of using our Services or otherwise participating in the Services (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. If you elect to engage in an Identification Activity we may ask you to provide us with certain personal information about yourself, including, but not limited to:
- Information, you provide – during registration as a Customer and by filling in forms on the Website and/or the App, or by corresponding with us (for example, by e-mail or via the chat functions on the Website and/or the App), enter into any transaction on the Website or the App (such as Add funds, Send, Exchange) we ask you to inform certain information we need to identify the party in the framework of agreements with the Company. Also If you contact us for participating in discussion boards or other social media functions on the Website or the App, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device’s phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the masked PAN data, relevant expiry dates, identification document numbers, copies of identification documents (for example, passport, driving license, national id card and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
- Cookies – for collection of information Company can use markers cookies are small pieces of information stored by your browser on the hard drive of your computer at the request of the web site. Our Company cookies do not contain any personal information and are used as follows:
- to monitor temporary information. For example, marker cookies allow us to track what pictures you upload and download;
- to register you in special programs. Cookies allow us to remember you when you log in our Website;
- to remember your preferences concerning country and language;
- to help us understand the scope of your audience and the traffic distribution;
- to collect and record information about what you viewed on our Website and what viewed in our email latter.
- to manage information of the Website and its presentation and to understand which images can be displayed on your computer; to present information according to your interests.
- Information about your device and visits – when you access the Website https://plasmapay.com (and its subdomains) via a browser, App or others our servers automatically record certain information. These server logs may include information such as a web request, date and time of the request, IP-address used to connect your computer to the Internet, your login information, browser type, version and language, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
- Location information – we use GPS technology and your IP address to determine your location – this may be used when you log in to the Website or when the App is running in the foreground and the background of your Device. This is used to prevent fraud when your location and device type is different from what you normally use. Our fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the PlasmaPay Website or App within your device settings.
- The custom message – when you send some messages (email or otherwise), we can save these messages for processing requests, answers the questions and for further development of our services. To contact you regarding our services may use your e-mail address.
3. How we obtain information
Your information is made up of all the financial and personal information we collect and hold about you, which may include, but not be limited to:
- information you give to us;
- information that we receive from third parties who provide services to you or us;
- credit reference, fraud prevention or government agencies and other financial institutions (where permitted by law);
- information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
- information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition); and
- information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.
4. How we use your personal data
4.1 In this section we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the transactions and transfers processing.
4.2 We may process your personal information to carry out our obligations arising from any transactions you enter into with us, for example, Add funds, Send funds, Exchanges, Withdrawals and to provide you with the information, products and services that you request from us
4.3 We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.4 We may process your account data. The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.5 We may process your information included in your personal profile on our website. The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.6 We may process information that you post for publication on our website or through our services. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.7 We may process information contained in any inquiry you submit to us regarding the Services. The inquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.7 We may process your personal information to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services
4.8. Personal data such as email will be used for the authentication process, access control to your account, analytics data collection, actions logging and marketing purposes.
4.9 We may process information relating to transactions, transfers, exchange, and purchase of cryptocurrency, that you enter into with us and/or through our Website or the App. The transaction data may include first and last names, an email address to be used as a login, billing contact information, credit card number, banking information and/or cryptocurrency account information, and a password. The transaction data may be processed for the purpose of processing transfer, payment, and currency exchanges and keeping proper records of those transactions and for determining compliance with Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) regulations, policies and law. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
4.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.11 We may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.13 In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so and/or we have agreed in writing prior to receiving the data from you. Any information that we receive that is not identified shall be notified to you and destroyed immediately.
5. Providing your personal data to others
5.1 Financial transactions relating to our website and services may be handled by our payment services providers (IPSP or acquirer bank). We will share transaction data with our payment services providers only to the extent necessary for the purposes of executing such transactions as you wish to process via the Services and dealing with complaints and queries relating to such payments and refunds.
5.3 In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.4 We may use third party marketing services such as Google AdWords to serve ads when you participate in the Company Service. These companies may use Non-Personally Identifiable Information about your visits and use of the Company Service, and visits to other websites or locations to provide, through the use of network tags, advertisements about services that may be of interest to you. We will obtain your express opt-in consent before we share your personal data with any third party company for marketing or promotional purposes.
6. About cookies
6.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
6.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
7. Cookies used by our service providers
8. Managing cookies
8.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari);
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
8.2 Blocking all cookies will have a negative impact on the usability of our Website.
9. Information security
9.1 You can access your Personally Identifiable Information via the Company Service with your password and username. This password is encrypted. We advise against sharing your password with anyone. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanisms appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. If we believe that the security of your information may have been compromised, we may seek to notify you of that development.
9.3 Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee the protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit card number, you should not send it electronically unless the email is encrypted, or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other parties.
10. Your legal rights
10.1 In this section we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.2 Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
10.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile when logged in.
10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
10.5 In some circumstances you have the right to the erasure of your personal data without undue delay, and at the latest within one month of receiving your valid request. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processing. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
10.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
10.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10.10 To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
10.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11. Automated decision-making and profiling
The Company does not engage in any profiling or automated decision-making in respects of its Customers or individuals whose data it processes.
The Company’s Service is not directed to people under the age of eighteen (18). If you become aware that your child has provided us with personal information without your consent, please contact us at the email address listed below. If we become aware that a child under eighteen (18) has provided us with personal information, we take steps to remove such information and terminate the child’s account.
13. Retaining personal data
13.1 This section sets out information about our data retention policies, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
13.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
13.3 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in connection with any legal claim.
13.4 The Company is obligated under the Money Laundering and Terrorist Financing Prevention Act 2017 to retain personal data about you and your transactions for a period of five years. We, therefore, use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 5 years after the termination of our business relationship.
14. Access to personal data
The company provides access to personal information only those employees of the Company to whom this information is necessary to ensure the functioning of the Website, providing services to the Customers and only under the following circumstances:
- We have enough reason to believe that access, use, storage or disclosure of such information is necessary to (a) compliance with any applicable laws, resolutions , requirements of legal process or the a valid request from public authorities, (b) compliance with applicable terms of service, including investigation of potential violations, (c) detection and prevention of fraud actions and decision of the security issues and resolve technical problems or (d) protection from the threat of damage to the rights, property, or safety of the Website https://plasmapay.com (and its subdomains), its Customers or the public as are required or permitted by law.
15. Personal data protection
We take all necessary measures to protect the data against unauthorized access, modify, disclosure or destruction. These measures are internal review processes and conditions of collection, storage and processing of data and security measures, including appropriate encryption and measures to ensure physical data security to prevent unauthorized access to the system in which we store personal data.
We protect your personal information by using data security technology and using tools such as firewalls and data encryption.
All your personal data is stored on our secure servers in accordance with our Data Protection Policy. In order to provide the highest quality services and due to the technical features of the performance of certain functions of the Website, some personal data, such as email, can be stored on our servers in the open data storage but using the same security standards and access restriction as to the other personal data.
16. Working with personal data and their update
Before processing requests, we ask Customers to identify its own identity and the information, which they want to receive, correct or delete. The Customer when using the Website, confirms and agree that:
- has all the necessary rights, allowing him to register (create an account) and use the services of the Website;
- indicates true information about yourself in the volumes necessary to use the services of the Website, mandatory fields for further provision of services of the Website marked the special way, all other information provided by the Customer at his own discretion;
- familiar with this Policy agrees with it and assumes the specified rights and obligations. Familiarization with the terms of this Policy is the written consent of the Customer for the collection, storage and processing personal data provided by the Customer;
- the Company does not verify the authenticity of received (collected) information about Customers, except for cases when such check is necessary to fulfill obligations to the Customer.
If a privacy complaint or dispute cannot be resolved through Company’s internal processes you have the right to make a complaint at any time to the Data Protection Inspectorate, the Estonian supervisory authority for data protection issues (https://www.aki.ee/en/inspectorate). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
19. Contact us
Data Protection Officer: Alexey M.
Plasma Alliance OÜ (14507139)
Harju maakond, Tallinn, Lasnamae linnaosa
Peterburi tee 47, 11415, Estonia
This document was last updated on September 5, 2018
Plasma Alliance OÜ (hereinafter – we, the Company) strives to make every customer happy with the provided service. The company has therefore created this refund policy in order to prevent disagreement with our customers and inform them that Company does not provide any refunds on usual condition due to the nature of services. At the same time, the Company guarantees to any its customer his right for refund, if any the paid services were not provided. Every refund in such cases is treated by the Company with reasonable care.
The company also draw customers’ attention that is reasonable and justified circumstances and if necessary, the Company may refund payments received from customers through any available payment system, including bank cards.
The company expects the customer to contact it using Company contact details to resolve any problem or issue related to his any previously approved transaction before the customer makes any chargeback request with the issuing bank or credit card company. This section does not affect any rights and/or claims, which the customer may have against the bank, credit card company or any financial institution or payment provider.
Any attempt to requesting chargeback without contacting the Company may be considered as a breach of Terms and Conditions and customer may be held liable in a competent court of applicable law. Company will investigate any chargeback requests made by the customers and in response will inform the customer’s issuing bank whether any service or transaction has been canceled.
If we, however, receive a chargeback for any transaction we reserve the rights to hold chargeback amount from the customer’s current balance for the period of investigation and the dispute cycle of the payment system and credit the funds back after completing this process and charging all applicable fees.
In accordance with the Company’s policy, a refund to the customer is allowed in the following cases:
- when funds were not credited to the account balance after completion of transaction processing due to technical reasons or as a result of an error; or
- funds had been deposited into account balance, but no one operations or orders were executed and no funds were used for the services.
In such cases, if the request for a return is approved by the company, the funds will be refunded back through the same payment method and to the same credit/debit card, bank account or another wallet from which the funds were originally received.
In order to apply for a refund, the customer must complete the respective refund request and send it to the PlasmaPay support address [email protected]. The request must contain the following details:
- Transaction ID;
- Customer name and Email;
- Amount and currency of requested refund;
- Reason and description of the request.
If a customer does not provide the necessary information in the request, including the reason and justification for the refund, or if the customer has already used deposited funds for trading or other services, Company has the right to decline such refund request without further consideration.
To prevent prohibited and unlaw conduct, all payments, and information related to refund may be additionally verified by the Company. In such case, The Company may request the customer to provide certain documents, including, but not limited to, identification documents, copy of the customer’s invoice or/and any other proof of the fact that disputed payment was made. In case if the customer fails to provide appropriate documents or information within three (3) days upon the Company request or in case of any doubts as to the authenticity of provided documents, the Company shall be entitled to decline the user’s refund request.
The refund will be done for the full amount unless other arrangements and fees have been made in accordance with the Terms and Conditions.
Within three (3) business days as of the date of refund request receipt, Company shall contact the customer to request further information (if required) and the customer shall provide such information as soon as reasonably practicable but in any case no later than five (5) days following such request.
Company shall notify the customer by email on its final decision regarding a refund within five (5) business days following the receipt of the last requested additional document or information or within three (3) business days following the receipt and reviewing of a refund request if no further information or document is required.
Refund will be processed without undue delay, and in any event within five (5) days beginning with the day on which the Company agrees that the customer is entitled to a refund. The lead time of processing of refund transaction can take 3-5 business days, excluding funds transfer time from the bank or payment provider.
Confines and policy changes
This refund policy concerns exclusively customer’s deposited/added funds, and it does not refer to any refunds for send or exchange transactions that were processed as Company’s services.
Refunds in excess of the original transaction amount are prohibited for any payment method.
If there is just cause to suspect that the origins of customer’s funds and/or customer’s entire activities are contrary to Company’s Anti-Money Laundering Policy (AML Policy), Company reserve unilateral rights to deny deposit funds into account balance within Company’s systems, or withdrawal to customer account and send to other payment system and also hold such assets and refund them back to the sender’s account. Please be notified that we are obliged to inform the respective government institutions concerning each AML Policy conflict and disclose customer’s personal data.
This refund policy will be amended from time to time if there is any change in the legislation. Terms of this refund policy are subject to change by the Company and in the case of any amendments, Company will make an appropriate announcement before the changes will apply.
In case if the customer does not wish to accept the revised refund policy, he should not continue to use the Company’s services. If the customer continues to use the services after the change comes into effect, the use of the services will be bound by the new refund policy.
Anti-Fraud and Security Policy
PlasmaPay is committed to conducting payment business in accordance with the highest ethical, professional and legal standards. The public, PlasmaPay’s partners and clients have the right to expect that professional, competent and trustworthy specialists are employed by PlasmaPay.
PlasmaPay will comply with applicable legislation and the highest standards of the payment industry. In line with applicable legislation PlasmaPay has a “Zero tolerance” policy towards fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct (jointly “Prohibited Actions”), will identify and thoroughly investigate and seek to take disciplinary and/or legal action against those who perpetrate, are involved in, or assist with fraudulent or other improper actions in all PlasmaPay activity and related transactions.
In its work, PlasmaPay uses adequate and appropriate resources to implement the Anti-fraud and security policy and will ensure its transfer and understanding to customers and partners.
2. Legislation compliance
The Anti-fraud and security policy has been drafted to comply with the current applicable local and international legislation, including, but not limited to applicable EU legislation.
Adherence to the Anti-fraud and security policy PlasmaPay will ensure compliance with all relevant legislation and internal policies by all parties including clients and employees.
In pursuance of the Anti-fraud and security policy, Prohibited Actions includes fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct defined in accordance with the description below.
- Fraud: any action or omission, including a misrepresentation that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.
- Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the action of another party.
- Collusion: an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
- Money laundering:
- the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
- the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
- the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
- participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions mentioned in the foregoing points.
- Terrorist financing: provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offenses within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA of 13 June 2002 on combating terrorism.
- Criminal conduct: conduct, which constitutes an offense in any part of the world or would constitute an offense in any part of the world if it occurred there.
4. Key responsibilities
PlasmaPay performs a “Know-Your-Customer Policy” (KYC) due diligence on all new Clients and due diligence on all transactions in order to detect possible compliance or integrity concern. Such due diligence is performed in accordance with the requirements of the money laundering and terrorist financing activities regulations, pursuant to the terms of KYC.
In view of the Anti-fraud and security policy PlasmaPay is responsible for:
- ensuring efficient and effective systems, procedures and internal controls are in place to enable the prevention and detection of Prohibited Actions;
- ensuring the compliance officer identifies Prohibited Actions risks in their areas of business and that all systems, procedures and internal controls are properly implemented and enforced;
- ensuring all members of the operational anti-fraud department have a duty to report any internal and external suspicions or incidents of Prohibited Actions;
- reviewing continuously its systems, procedures and internal controls through risk management processes and audit arrangements;
- reporting any suspicions regarding Prohibited Actions to the relevant state authorities.
5. Fraud detection and investigation
PlasmaPay’s Anti-Fraud and Compliance Department, in particular, the Compliance officer, is the first line of detection, investigation, and protection in preventing Prohibited Actions through the Clients and transactions appraisal process. The Compliance Officer will be responsible for the proper fulfillment of the Anti-fraud and security policy.
Where reasonable suspicion that Prohibited Actions has taken place, PlasmaPay is entitled to investigate the matter thoroughly using recognized and legitimate investigative techniques.
The Compliance officer, through the Anti-Fraud and Compliance Department, shall be responsible for:
- receiving reports of alleged or suspected Prohibited Actions involving PlasmaPay, its Clients and/or related transactions;
- investigating such matters and determining measures to prevent further situations;
- reporting its findings to the PlasmaPay management and relevant authorities, as well as any other third party on a need-to-know basis.
The Compliance Officer shall have full authority to open, pursue, close and report on any investigation on Prohibited Actions within its remit without prior notice to, the consent of, or interference from any other person or entity. All investigations will be carried out objectively and confidentially.
For situations requiring an urgent response, the Compliance Officer may take any necessary measures required for the investigation, notably to preserve evidence and other details about the case. In certain cases, third-party investigators may be engaged by PlasmaPay in order to gather sufficient evidence to hand the case over to the proper authorities. Responsibility for the management of third parties rests with the Compliance Officer.
The Anti-Fraud and Compliance Department shall enjoy complete independence in the exercise of its responsibilities. The Compliance Officer shall have full authority to open, pursue, close and report on any investigation on Prohibited Actions within its remit without prior notice to, the consent of, or interference from any other person or entity.
5.3. Professional Standards
All Prohibited Actions investigations conducted by the Anti-Fraud and Compliance Department shall be fair and impartial, with due regard to the rights of the Clients and persons or entities involved. The presumption of innocence applies to those alleged to have engaged in misconduct. Those involved in the Prohibited Actions investigation (be those under investigation or those conducting the investigation) should be aware of their rights and obligations and ensure they are fully respected.
All Clients are required to cooperate with the Anti-Fraud and Compliance Department and the Compliance officer promptly, fully, efficiently and in the manner specified by the Anti-Fraud and Compliance Department, including by answering relevant questions and complying with requests for information and records.
In accordance with PlasmaPay internal policies on access to information, all information and documents collected and generated during a Prohibited Actions investigation, not already in the public domain, shall be kept strictly confidential. The confidentiality of the information collected will be respected both in the interests of those concerned and the integrity of the investigation.
In particular, during the Prohibited Actions investigation, the confidentiality will be respected in so far as it would not be contrary to the interests of the investigation.
The Anti-Fraud and Compliance Department shall disclose such information and documents only to those persons or entities authorized to receive them or otherwise on a need-to-know basis.
6. Security framework
The purpose of the PlasmaPay’s security framework is to ensure that there are strict measures and practices in place to protect customer assets against any eventualities and threats. The majority of customer digital assets (e.g., bitcoin) are held in our offline wallet systems (Cold storage) as well as with the industry’s most reputable liquidity providers and crypto custodians. All customer fiat funds are held separately from the company’s operating bank accounts. We are conducting periodical stress tests and security audits to ensure compliance with the strictest security standards.
6.1. Digital asset security is supported by the following solutions:
- Cold Storage. Offline wallet system (Cold storage) provides an important security measure against hacking, theft or loss. Asset transfers from the Cold storage require actions of multiple employees. All private keys are stored in safe deposit boxes and vaults distributed geographically.
- Hot Wallets. The hot wallet keys are generated, stored and managed in HSM (hardware security modules) serviced by Azure Key Vault. HSM’s hardware has been evaluated according to FIPS publication 140-2 with a rating of Level 2.
- Platform security is supported by the following solutions:
- 2FA (provided by Google Auth) provides security to the login/registration processes, as well as executing withdrawals;
- Traffic on our website runs through encrypted SSL (HTTPS);
- We partner with leading vendors to mitigate potential distributed denial-of-service (“DDoS”) attacks;
- All passwords are cryptographically hashed (using bcrypt with a cost factor of 12) while all other sensitive data is encrypted;
- All systems used will ensure the right level of access to authorized personnel with up to date monitoring systems. On-going and proactive security assessments are conducted to keep up to date with new threats and potential vulnerabilities;
- Internal сontrols;
- PlasmaPay‘s staff is educated on cybersecurity awareness and adequately trained to perform their information security-related duties and responsibilities consistent with related policies, procedures, and agreements. All employees undergo criminal and background checks, and are subject to ongoing checks throughout their employment at PlasmaPay;
- PlasmaPay regularly reviews the Anti-fraud and security policy to reflect new legal and regulatory developments and ensure good practice.
7. Client’s statement
USING OUR SERVICE YOU WARRANT AND GUARANTEE THAT YOU HAVE NO INTENTION TO COMMIT ANY OF PROHIBITED CONDUCT ACTS DESCRIBED HEREIN; FURTHERMORE, YOU CONSENT TO ANY CHECKS DUE TO INVESTIGATION UNDER THE ANTI-FRAUD AND SECURITY POLICY AND YOU AGREE TO COOPERATE FULLY AND PROMPTLY WITH THE ANTI-FRAUD COMMISSIONER WITHIN SUCH INVESTIGATION.
8. Amendments and modifications
This Anti-Fraud and Security Policy may be amended or modified at any time, at the sole discretion of PlasmaPay. You acknowledge and agree that it is your own responsibility to review the Anti-Fraud and Security Policy periodically and become aware of amendments and modifications.
If you do not wish to accept the amended/modified Anti-Fraud and Security Policy, you should not continue to use the Service. Your continued use of the Site and/or the Service following the posting of changes to the Anti-Fraud and Security Policy will be deemed as your acceptance of those changes.
Anti-Money Laundering and Know Your Customer Policy
This document was last updated on September 5, 2018
Plasma Alliance OÜ (hereinafter referred as “The Company”) Anti-Money Laundering and Know Your Customer Policy (AML-KCY Policy) is designed to prevent money laundering by meeting the Estonian AML/CFT legislation obligations including the need to have adequate systems and controls to mitigate the risk of being used to promote financial crime. The Company reserves the right to refuse registration to persons from jurisdictions that do not meet international AML-CFT standards.
Money laundering is a process, where money derived from illegal sources are introduced into the legal circulation. The main task of a person involved in the money laundering is a transformation of money into money or other financial instruments to hide as many traces of such illegal operation as possible. The Company takes all possible measures to prevent precedents where any of its customers can use the provided services for similar purposes.
The Company adheres to the following policy in the field of counteracting the legalization of proceeds from crime and the financing of terrorism by taking into account the concerns expressed by regulators of many countries, concerning the potential possibility of using crypto assets for illegal purposes, in particular, for the legalization of proceeds from crime and recognizing complete anonymity in the transactions of money transfers and purchase-sale of crypto assets, which contradicts the interests of its customers.
To monitor compliance with the legislation, the Company develops AML/KYC procedures, which are mandatory for compliance by all employees of the Company and policy-defining interactions with persons who enter into an agreement with the Company and become clients of the Company (hereinafter referred to as the “Customers”).
In order to protect the funds of our Customers and to ensure compliance with the world trade standards the Company works exclusively in accordance with the legislation on combating money laundering, obtained through criminal activity and countering the financing of terrorism and criminal activities:
- Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015;
- Money Laundering and Terrorist Financing Prevention Act;
- Payment Institutions and E-money Institutions Act.
The Company compliance shall ensure that the Company’s activities comply with international standards of Anti-Money Laundering Policy and all documents provided by the Customers are relevant and comply with the requirements of the law.
All questions concerning this Policy please send to the address: Plasma Alliance OÜ, Harju maakond, Tallinn, Lasnam linnaosa, Peterburi tee 47, 11415.
2. Goals and objectives
The goal of this Policy is to comply with relevant legislation and normative legal acts, and demonstrate that the Company takes seriously any attempt to use its services for illegal and unlawful purposes.
Legislation obliges the Company to take the necessary measures to prevent and identify cases of money laundering. The Company, in its turn, makes sure that the internal guidelines, procedures and controls used by competent specialists properly and always comply with the latest requirements and innovations.
The Company applies the verification procedure for all new Customers and can not start business relations until the identification of a new Customer is successfully confirmed.
3. Internal rules and regulations
Regulations require the Company to have:
- Policies and procedures to prevent them from being used by money launderers;
- Employees trained in these procedures and in anti-money laundering law;
- Checks and controls to ensure that the policies and procedures are working;
- Have internal and external measures in place for the disclosure procedures for suspicious transactions.
To comply with the policy of counteracting the legalization and laundering of illegal funds, the Company performs the following:
- Identification of customers (both individuals and legal entities);
- Saving the history of Customers’ transactions for at least for 5 (five) years;
- Establishing the criteria for questionable and unusual transactions as well as methods for determinating them;
- Monitoring and verification of suspicious transactions and their compliance with the criteria of questionable and unusual transactions;
- Suspension of suspicious transactions to ascertain the circumstances and to carry out the investigation with the subsequent return of suspicious funds back to the sender account;
- Waving of any obligations to the Customer if the company becomes aware that the Customer committed in any way to use the Company’s service to carry out illegal activities, including the legalization of proceeds from crime and the financing of terrorism;
- Providing available information about the Customer and his transactions to the law enforcement authorities on the appropriate official request.
In case the Company specialists in the course of monitoring will find out that any of the Customers use the Company’s services for money laundering, the company reserves the right to block the Customer’s account and all stored funds until the end of the internal investigation.
The Company also reserves the right to provide this information to the police, the authorized regulator or any other control body without the consent of the Customer.
According to the existing standards and requirements the Company has implemented the following measures:
- Approved the position of responsible officer (Compliance Officer) for reporting on the suspicious activities related to money laundering;
- Implemented a mandatory training program for all company employees on methods and measures to counter money laundering;
- Established a risk-based approach to the assessment and management of financial risk in business related to money laundering;
- Implemented and applied in practice a prudent approach to Customers, based on risk assessment, personal identification and customer address verification according to the principles of “Know Your Customer” (KYC), providing additional thorough checks of “suspicious” customers, which the Company determines at its sole discretion during the monitoring and verification of operations;
- Implemented a system for monitoring operations (automatic and, if necessary, manual) using systems and methods based on risk assessment of for continuous tracking of current customer activity to prevent the use of the company’s services for illegal purposes;
- Adheres to a special procedure for the detection and reporting of suspicious activities or suspicious transactions when using the company services.
4. Customer identification
Based on Money Laundering and Terrorist Financing Prevention Act we have to identify and verify any person who enters in a business relationship with us or who has an occasional transaction, including any person acting on their behalf and any beneficial owners.
Identification required for all customers who have registered of an account (personal or corporate) at https://plasmapay.com, regardless of the added (deposit) amount or send (withdrawal) amount available on the balance to a bank account or any other payment system. The identification procedure is a prerequisite for any financial and exchange operations, until completion of the identification procedure, Customer account is unverified and has restrictions for making financial transactions and transfers.
The Customer understands that the name, address, telephone number and any other personal information, including documents (such as passport, national identity card, driving license, bank account statement, telephone bills, electricity bills or other utility bills) must be true and valid on the upload date.
- Full name;
- Gender (male/female);
- Date and place of birth;
- Place of residence (thereby identifying risks associated with countries, geographic areas or jurisdictions);
- Contact phone and email.
For legal entities:
- Name of the legal entity and DBA name;
- Registration number;
- Date and country of registration;
- The address of the office in the country of incorporation;
- The same personal data of the director as for a private client;
- Contact phone and email;
- Phone and Email.
The verification process is performed once and can be re-initiated only when the Customer’s registration data or documents are changed. After assigning to the Customer “Verified” status, the re-submission of the verification documents is not required.
To prevent compromising of Customer’s personal data, documents uploading and data entry is done through a secure interface in the Customer’s local area (secure log-in) using encrypted protocol.
5. Requirements for the documents
Under this Policy, any customer who decides to use the services of the Company also agrees to provide identification and verification documents that confirm identity, address and financial status, among them:
- Identity document: a color copy of the passport (the first, second page with photos, as well as a page with registration data), or a color copy of the document that is proper for confirming the identity of the Customer according to the legislation of the country of which the Customer is a resident;
- Copy of the utility bill or bank statement for confirmation of the Customer’s residence (the document shall not be older than 3 months).
For legal entities:
- Copy of the certificate of registration/incorporation;
- Copy of the memorandum and articles of association or equivalent document, duly registered in the appropriate register;
- Copy of extract from the protocol of the general meeting of participants/shareholders, the copy of an extract from the trade register, or equivalent document confirming the registration of the corporate acts and amendments, and powers of the company head;
- Certificate of shareholders or register of members – legalized or apostilled;
- Passport copy of the head of the company (additionally, passport copies may be requested of all individuals who, directly or indirectly, as well as through third parties, own more than 25 percent in the share capital of the company);
- Document confirming the legal entity location or the actual address, where it operates (copy of the utility bill not older than 3 months or copy of the office rental agreement);
- Reference letter from the bank confirming the opening of a current account, or a copy of the contract with the bank about the account opening.
The Company does not accept the following types of documents as proof of address: phone bill (statement), driving license, couriers receipts, documents issued by the pension fund or insurance companies, the invoices from the shops and other companies in the area of trade and service, credit/debit card statements issued by a store or another bank agent.
Corporate customers (legal entities) provide documents certified in established order by themselves or by a notary.
In case if customer wants to make payment using credit and debit cards of international payment systems Visa, MasterCard and others, the Company will require him to pass the card verification process by providing a scan/photo of the front and back sides of the card (for security purposes, it is allowed to partially hide the card number on the front side and validation code CVV2/CVC2 on the backside) or by verifying the payment amount in accordance with the instructions in the personal account.
Copies of supporting documents must be submitted in color, at high resolution (at least 1920×1080), JPEG, JPG, GIF, PDF, max. capacity of each document should not exceed 10 Mb. The Company reserves the right to decline the documents that do not correspond to the above requirements.
6. Additional requirements
According to the existing standards and requirements in anti-money laundering the Company reserves the right at any time to request the customer to present additional documents or any additional information needed for identification.
The Company can freeze (block) the account of any Customer in case of suspicion of fraudulent activity, which may be related to the money laundering, or in case of the customer refuses to provide the requested identification documents.
If the Customer refuses to provide the requested documents and information as a response to a request from the Company without proper justification, the Company will not start a contractual relationship with this Customer, and may also notify this fact to the authorized regulator. This can lead to the suspicion that the Customer is engaged in money laundering and the financing of terrorism.
If the account has been blocked and further investigation and interaction with the Customer cause problems that can not be resolved, the Company can close the account and return all funds from the balance to the source from which they were received.
7. Enhanced due diligence
Extended due diligence is carried out with respect to politically exposed persons, and/or in the presence of the signs specified in the internal Company’s policy and procedures.
If the Company has assessed that the business relationship with the Customer poses a high risk it will apply the following additional measures:
- Additional information on the Customer;
- Additional information about the reasons for choosing a company and on the intended nature of the business relationship;
- Information on the source of funds or source of wealth of the Customer;
- Information on the volume of planned transactions and transfers;
- Additional information on individuals with ownership or control over the account, such as beneficial owners, signatories, guarantors;
- Information about the reasons for the intended or performed transactions;
- Financial statements and banking references;
- Information on the availability of financial assets or property;
- A detailed company structure;
- Business model/business plan;
- Actual domicile of the business;
- Description of the business operations, the anticipated volume of currency and total sales, and a list of major customers and suppliers, contractors, payment providers, etc;
- The explanation for any changes in the corporate structure or account activity;
- Additional screening/negative news research;
- Approval from senior management for establishing/continuing the relationship;
- Enhanced monitoring of the relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further explanation;
- Requiring that the first payment be carried out through an account in the customer’s name with a bank subject to similar customer due diligence standards;
- Introducing enhanced reporting mechanisms/systematic reporting for financial transactions with individuals/legal entities.
The Company will conduct ongoing Customer due diligence and account monitoring for all business relationships with Customers. It particularly involves regularly reviewing and refreshing Company’s view of what its Customers are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Customer. It can also include anything that appears to be a material change in the nature or purpose of the Customer’s business relationship with the Company.
8. Transactions monitoring
The Customer is known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, the Company relies on data analysis as a risk-assessment and suspicion detection tool. The Company performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
- Daily check of Customers against recognized “blacklists” (e.g. OFAC), aggregating transfers by multiple data points, placing Customers 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.
With regard to the AML-KYC Policy, the Company will monitor all transactions and it reserves the right to:
- Ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- Request the Customer to provide any additional information and documents in case of suspicious transactions;
- Suspend or terminate Customer’s account when the Company has reasonable suspicion that such Customer engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Customer’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as conscientious.
9. Risk assessment
The Company, 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, the Company is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to 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.
Please read the following carefully to understand these risks. By visiting https://plasmapay.com/ the User is accepting and consenting to the practices described in this policy.
All defined terms are as defined in the body of the text or in the Terms.
Before we open an account for you, we are required to make an assessment of whether the product(s) and/or services you have chosen are appropriate for you, and to warn you if, on the basis of the information you provide to us, any product or service is not appropriate. If you decide to continue and open an account with us, you are confirming that you are aware of and understand the risks.
Assumption of risk
The trading of financial assets, real or virtual, as well as crypto-currencies, as well as the use of the PlasmaPay Platform, involves significant risk, and the User specifically agrees to assume the risks set out in this disclosure as well as other risks not set out herein which are inherent to online trading and cryptocurrency speculation.
The User agrees to assume the following risks and acknowledges and agrees that PlasmaPay shall not be responsible for or otherwise liable for any direct or indirect loss or damage of any kind whatsoever arising directly or indirectly from the occurrence in full or in part of any and all of the following risk events:
There is an inherent risk that losses will occur as a result of buying, selling or trading anything on a market. Since cryptocurrencies markets are decentralized and non-regulated our cryptocurrencies trading services are unregulated services which are not governed by any specific European regulatory framework (including The Markets in Financial Instruments Directive). This means that there is no central bank that can take corrective measure to protect the value of сryptocurrencies in a crisis or issue more currency. Therefore, when PlasmaPay customers are using our cryptocurrencies trading service they will not benefit from the protections available to clients receiving regulated investment services for dispute resolution. PlasmaPay customers will continue to benefit from the rules relating to best execution and client money and safekeeping of client assets.
Automated and online-based trading
While trading on our website, system errors might occur. You should be aware of the risks that may result from any system failure which could mean that your order may be delayed or fail.
You acknowledge that there are risks associated with utilizing an online-based trading system including, but not limited to, the failure of hardware, software, and internet connections, the risk of malicious software introduction, the risk that third parties may obtain unauthorized access to information and/or assets stored on your behalf, cyber-attack, the cryptocurrency network failure (such as blockchain), computer viruses, communication failures, disruptions, errors, distortions or delays you may experience when trading via the Services, howsoever caused, spyware, scareware, trojan horses, worms or other malware that may affect your computer or other equipment, or any phishing, spoofing or other attacks. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from PlasmaPay.
Cryptocurrency prices can and do fluctuate greatly on any given day and due to such price fluctuations, the User’s cryptographic assets may be subject to large swings in value and may even become worthless.
An order may be incomplete and incorrect, “limit orders” and “stop orders” may not be (and are not guaranteed) executable at the price or amount specified by the User. Orders may be canceled at PlasmaPay’s discretion or for any other reason.
The User, PlasmaPay or any third party (including a Financial or Payment Institution or hacker) may send crypto to the wrong wallet address during the funding or withdrawal of their PlasmaPay account.
The User may inadvertently due to their own error or because of a system or human error place an order for the wrong asset resulting in an unwanted order.
The User may be prevented from sending an order or email may not be received by PlasmaPay or the Services, due to hardware, software or services issues (including, without limitation, Internet and other network connectivity issues).
The transaction request or email to PlasmaPay or the services may be lost, intercepted or altered during transmission.
An order may not place completely, or may be placed at the wrong price or may suffer an unexpected delay for any of a variety of reasons.
Unauthorized third parties may access or use their PlasmaPay account and effect transactions without their knowledge or authorization.
PlasmaPay may refuse to act upon any instruction from a User or any person authorized by the User if PlasmaPay reasonably believes that the transaction, pursuant to the instruction submitted, will be in violation of e.g. market rules, usual market practice, and/or applicable law, including, but not limited to, legislation on money laundering and insider trading.
Although the PlasmaPay Platform is automated and we are giving you the best execution available, it is possible that the market price could have changed between order placement and execution time, and therefore we cannot guarantee that the price requested will be the same as the price that the order is executed, the price you receive can be in your favor or against you.
In addition, there are risks associated with the use of online deal execution and trading systems including, but not limited to, software and hardware failure and internet disconnection.
There may be errors or omissions on the reporting module or otherwise delay, inaccuracy, error, interruption or omissions in providing market quotations or other information provided on the website on which the User might rely in making an order.
A copied trader’s account’s, portfolio’s and/or strategy’s positions shall be copied in an amount equal to the lower of either the minimum position amount as shall be set by PlasmaPay from time to time or the proportional amounts of the copied trade to the realised equity of the copied trader as the basis for the proportions of copied trades. Such positions shall have the same leverage (if any), stop loss and take profit, to the maximum extent possible. Trades below the minimum trade amount shall not be opened. All such positions shall be modified and/or closed automatically if and when modified/closed by the copied trader, for whatsoever reason, without providing any further notice and without any action on the User’s part. The User should be able and prepared to bear the loss of the entire investment the User made in such a copied trader.
If the User places additional trades in the User’s account or the User modify or cancel an order generated by a Social Trading service. The User may achieve a materially different result than the user that the User copied. Unopened copied trades in amounts lower than the minimum trade may also result in different results.
Withdrawal by the copied trade may also generate a materially different result than the user that the User copied as it may affect the copy trading proportions.
The User may sustain as a result of our automatic execution of instructions generated as a result of the utilizing of any of the Social Trading services.
Financial or Payment Institution
Errors, acts or omissions of the Financial or Payment Institution, including delays in sending or receiving funds from the User’s account on PlasmaPay to or from a Financial or Payment Institution.
Exceptional market conditions
Exceptional market conditions, force majeure events, and similar events can cause the booking of funds to be delayed.
Transactions the User completes using the PlasmaPay Platform may be subject to various taxes, such as VAT, sales tax or transfer taxes that are imposed and any profit or loss the User obtain therefrom.
Unauthorized access by third parties of the User’s login credentials to gain access to the User’s PlasmaPay account, including through carelessness or forgetfulness of the User, or the third party obtaining control over another device or account used by the User in connection with any enhanced security measures enabled for its account.
Since blockchain is an independent public peer-to-peer network and is not controlled in any way or manner by the PlasmaPay, PlasmaPay shall not be responsible for any failure and/or mistake and/or error and/or breach which shall occur in blockchain or in any other networks in which the cryptocurrencies are being issued and/or traded. You will be bound and subject to any change and/or amendments in the blockchain system and subject to any applicable law which may apply to the blockchain. We make no representation or warranty of any kind, express or implied, statutory or otherwise, regarding the blockchain functionality nor for any breach of security in the blockchain.
The features, functions, characteristics, operation, use and other properties of any Token (Token Properties) and the software, networks, protocols, systems, and other technology, including, if applicable, any blockchain (Underlying Technology) used to administer, create, issue, transfer, cancel, use or transact in any Token may be complex, technical or difficult to understand or evaluate, and PlasmaPay agrees no obligation to provide individual advice or information in respect of any Token, Token Properties or Underlying Technology.
Any Token and its Underlying Technology may be vulnerable to attacks on the security, integrity or operation of the Token or its Underlying Technology, including Attacks using computing power sufficient to overwhelm the normal operation of a blockchain or other Underlying Technology.
Any Token, Token Properties or Underlying Technology may change or otherwise cease to operate as expected due to a change made to the Underlying Technology, a change made using features or functions built into the Underlying Technology or a change resulting from an attack. These changes may include, without limitation, a “fork” or “rollback” of a Token or blockchain.
Any Token may be canceled, lost or double spent, or otherwise lose all or most of their value, due to forks, rollbacks, attacks, changes to Token Properties or failure of the Token to operate as intended.
PlasmaPay may suspend or cease to support the transfer, storage or trading of any Token at any time at PlasmaPay’s discretion. Other exchanges and service providers may do the same.
PlasmaPay may suspend or reject orders, suspend or cease support for Tokens, or suspend or terminate the User’s access to the services to comply with applicable laws or regulations or order from law enforcement or other governmental authority, for other reasons as specified in these Terms or otherwise at PlasmaPay’s discretion.
The User may be unable to withdraw Tokens prior to PlasmaPay ceasing to support a transfer of any such Tokens, resulting in the loss of any such Tokens remaining in the User’s PlasmaPay account.
Any Token may decrease in value or lose all of its value due to various factors including discovery of wrongful conduct, market manipulation, changes to Token Properties or perceived value of Token Properties, attacks, suspension or cessation of support for a Token by PlasmaPay or other exchanges or service providers, and other factors outside the control of PlasmaPay.
Any Token may decrease in value or lose all of its value due to legislative or regulatory activity, or other government.
Delisting and unsupported cryptocurrencies
If at any time any of the cryptocurrencies that form the subject of your order is delisted and/or we no longer support the trading in such Cryptocurrencies for any reason, then the applicable order will be immediately closed. If PlasmaPay is notified that a cryptocurrency you hold in your account is likely to be delisted and/or removed and/or canceled from any of the exchanges (some of them or all) and PlasmaPay believes that it shall not be able to trade in such cryptocurrencies, PlasmaPay shall make an effort to sell the cryptocurrencies on your behalf at such time and price, and in such manner, as it determines.
We may elect to execute any order and/or hold any fiat money and cryptocurrencies via third parties. Such third parties are not banks that hold their fiat money/virtual currency as a deposit. If any such third party loses any money, fails or goes out of business, there is no specific legal protection that covers you for losses arising from any funds you may have held with such third party, even when such party is registered with national authority. Depending on the structure and security of the digital wallet, some may be vulnerable to hacks, resulting in the theft of virtual currency or loss of customer assets. PlasmaPay will not be responsible in the event of losses caused by those third parties.
Limitation of liability
Except as expressly provided to the contrary in writing by us, the PlasmaPay Platform is provided on an “as is” and “as available” basis. PlasmaPay expressly disclaims, and the User waives, all warranties of any kind, whether express or implied, including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title and non-infringement as to the PlasmaPay Platform, including the information, content and materials contained therein.
PlasmaPay is not liable for any breach of an obligation under the Terms where PlasmaPay is hindered or prevented from carrying out its obligations by any cause outside of our reasonable control. In no event shall PlasmaPay, its directors, shareholders, officers, members, employees, affiliates or agents be liable to the User for any special, direct, indirect or consequential damages, or any other damages of any kind, including but not limited to loss of use, loss of profits or loss of data, whether in an action in contract, tort including but not limited to negligence or otherwise, arising out of or in any way connected with the use of or inability to use the PlasmaPay Platform, including without limitation any damages that result from mistakes, omissions, interruptions, deletion of files or email, errors, defects, viruses, delays in operation or transmission or any failure of performance, whether or not resulting from acts of God, communications failure, theft, destruction or unauthorized access to the PlasmaPay Platform, records, programs or services.
PlasmaPay does not assume any liability for negligent or willful misconduct of PlasmaPay’s directors, shareholders, officers, members, employees, affiliates or agents (or corresponding hierarchical level) and potential Users should not rely upon the PlasmaPay Platform or information provided by the same in deciding whether or not to use the PlasmaPay Platform. The Purchaser hereby holds harmless and indemnifies and keeps indemnified the PlasmaPay Platform and its officers and employees from and against all liabilities, costs and damages of any kind (including, for the avoidance of doubt, all legal expenses incidental thereto) which may be incurred by any of them and all actions or proceedings which may be brought by or against them.
PlasmaPay shall in no event be liable to the User by way of indemnity or by reason of any breach of the Terms or in tort or otherwise for loss of use of the assets or any part thereof or for loss of opportunity, loss of profit, or for any indirect, special or consequential loss or damage that may be suffered by the User in connection with the use of the PlasmaPay Platform or the website or the provision by PlasmaPay of the Services in connection with the same.
In no event shall our aggregate liability, whether in contract, warranty, tort (including negligence, whether active, passive or imputed), product liability, strict liability or other theory, arising out of or relating to the use of and/or inability to use the PlasmaPay Platform exceed the amount of 500 USD (five hundred United States Dollars) during the 6 months immediately preceding the date of any claim giving rise to such liability. This limitation of liability is subject to the maximum liability cap set out in the Terms.
The User agrees to defend, indemnify, and hold us harmless, and each of our officers, directors, shareholders, members, employees, agents and affiliates, from any claim, demand, action, damage, loss, cost, or expense, including without limitation reasonable professional fees, arising out or relating to (a) the User’s use of, or conduct in connection with the PlasmaPay Platform; (b) the User’s violation of the Terms; or (c) the User’s violation of any rights of any other person or entity and we will have the right, in our sole discretion, to control any action or proceeding and determine whether we wish to settle it, and if so, on what terms.
At making a decision to copy a specific trader, account, portfolio and/or strategy, the User have considered the User’s entire financial situation including financial commitments and the User understand that using Social Trading service is highly speculative and that the User could sustain significant losses exceeding the amount used to copy a trader or traders. Information in relation to Social Trading provided by PlasmaPay is provided solely for informational purposes.
If you make investment decisions in reliance on information which is available on the website or as a result of the use of the Social Trading services, you do so at your own risk. PlasmaPay and its affiliates and their employees and agents are not investment or financial advisers and will not be liable for any losses that you may sustain.
You should not make any investment decision without first conducting your own research. you are solely and exclusively responsible for determining whether any investment, or strategy, or any other product or service is appropriate or suitable for you based on your investment objectives and personal financial situation.
Any past performance of our users, risk score, statistics, and any other information with respect to users appearing on our websites and applications are not indicative of future results and should be considered as hypothetical as more fully described below. It is important to understand that risk scores, statistical information and historical performance are not a guarantee of future performance.
When reviewing the portfolio, financial performance information, opinions or advice of another registered user, the User should not assume that the user is unbiased, independent or qualified to provide financial information or opinions. PlasmaPay does not guarantee any order including the placing of stop orders. Accordingly, regardless of the entry or closing designation, PlasmaPay does not guarantee that the trade will be filled at the order price/stop-loss percentage and the User may lose more than the original amount used to copy such trader.
No aspect of the information and/or Social Trading service provided and/or made available on our websites is intended to provide or should be construed as providing, any investment, tax or other financial related advice of any kind. You should not consider any such content and/or any such feature to be a substitute for professional financial and/or investment advice. If you choose to engage in transactions based on content on the website and/or elect to copy specific traders and/or trades, then such decisions and transactions and any consequences flowing therefrom are your sole responsibility. While individual participants may offer investment advice or opinions and/or effect a transaction which may be subsequently copied by other traders, such advice, opinions or trades amount to nothing more than exchanges between persons who may be anonymous or unidentifiable or simply the execution of a trade by such traders.
PlasmaPay and its affiliates do not provide investment advice directly, indirectly, implicitly, or in any manner whatsoever by making such information and/or features available to you.
This privacy and cookies notice applies to the processing of personal data including information we collect and store via cookies, as explained below and references in this policy to PlasmaPay (also “we” “us” or “our”) should be interpreted accordingly.
What are cookies?
Cookies are small amounts of information in the form of text files sent by websites to computers, mobile phones or other devices when you visit a website. They allow companies to do various things, such as tailoring content, personalizing website visits, and ensuring the security of any online experience. Cookies typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Cookies cannot be used to run programs or deliver viruses to your computer.
Cookies may come in different formats. Session cookies are temporary cookies that remain in your browser until you leave a website. Persistent cookies remain in your browser for a longer period of time. Third-party cookies are cookies that are loaded onto your browser by third-parties. Third-party cookies are usually a type of persistent cookie and are stored until you delete them or they expire based on the time period set in each cookie. For more information see http://www.allaboutcookies.org/.
You should be aware that when you access or use our content, products and services, we may collect information from the devices you use to access/receive PlasmaPay content, products and services by using cookies.
If you’d like to learn how to manage these cookies and choose whether or not to receive information of different types, please see the section “How to control cookies” below.
The types of information we process and where it comes from:
- Information you’ve provided to us, including through our website or when you access our services through applications.
- Information about our content, products and services you’ve ordered or enquired about, including call recordings as further described below.
- Information, uploads, user-generated content, and comments you make about or generate in accessing the products and services you use on our platform.
- Information we collect, via cookies and related technology, from the devices you use to access and receive content, products and services, about your use of PlasmaPay, and/or third-party content, products and services. This includes information about your device, machine or browser which can be collected when cookies are turned off. For more information on cookies and how to manage them, please see the section on cookies.
- IP address, MAC address, unique identification number, online identifier, browser information, location data port information, logical network address, and other similar identifying information required for your devices to communicate with websites and applications on the internet.
- Technical information from the devices you use to receive our content, products and services, for example, the collection of diagnostic and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.
We use both “session cookies” and “persistent cookies.” Please be aware that cookies may be used on our platform whether or not you have created an account or submitted information to us. As we feature the products and services of our affiliate partners for sale throughout the website, it is important for us to understand statistics on how many of the visitors to our website actually make a purchase – it is this kind of data that such cookies will track. This is important to you as it means that we and our partners can accurately make business predictions that allow us to monitor our advertising costs and provide you with more relevant and customized product and service recommendations to purchase.
We use adverts to offset the costs of running the website and to provide funding for further development. The behavioral advertising cookies used by this website are designed to ensure that we provide you with the most relevant advertisements where possible by anonymously tracking your interests and presenting similar things that you may like.
These types of cookies simply allow us to provide you with content that we feel may be of interest to you. We use session and persistent cookies for the following reasons:
- Targeting and advertising. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
First-party cookies are the cookies that we set for plasmapay.com, third-party cookies are cookies that come from different domains. When you visit our website, you may also receive cookies from third-parties. The information collected by such third-party cookies is governed by their privacy policies. Additionally, third-parties companies advertise on our behalf and within the website and affiliate tracking cookies allow us to see if website visitors have come to the website through one of our partner websites and let our partner websites know that certain visitors arrived there via the website so that we can credit them appropriately and, where applicable, allow our affiliate partners to provide any bonus that they may provide you for making a purchase.
We may also use “social media” cookies to personalize your interaction with third-party social media platforms such as Twitter and Facebook where our Website uses such features. Such cookies recognize users of these social media sites when you view social media content on our website. They also allow you to quickly share content across media, through the use of simple “sharing” buttons.
We use third-party cookies for the following reasons:
- To allow our business partners to perform analytics and collect information and serve you advertisements.
- To share information with third-parties to gain insights and marketing information based on how you use our website.
- To provide to social networks to better understand how users interact through the Internet.
- To remember your user preferences and logins.
How to control cookies
We respect your right to privacy and are therefore happy to provide you with tools to manage the cookies you receive from our services.
Some cookies are essential to the performance of our platform (you cannot opt-out from these cookies if you wish to use our platform). Below you will find a list of some of the third-party cookies used by PlasmaPay. For those users who would prefer not to receive non-essential cookies, we have provided an “opt-out” option for you to select.
Your browser may also allow you to block the storage of cookies on your computer; For more information related to your cookie settings, please use the “Help” option located within your browser. Generally, you may change your cookie settings within the “options” or “preferences” tab.
Additionally, the following links may be helpful if you wish to opt-out of any cookies:
- Cookie settings in Internet Explorer.
- Cookie settings in Firefox.
- Cookie settings in Chrome.
- Cookie settings in Safari Web and iOS.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
First Party, Third Party
Preserves the visitor’s session state across page requests.
This cookie is used by sites using the .NET technology platform from Microsoft. It is commonly used to identify a logged-in user to enable access to secure areas of a site.
Stores the user’s cookie consent state for the current domain
Stores the user’s cookie consent state for the current domain
This cookie is used for newsletter subscription popup notification.
First Party, Third Party
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
First Party, Third Party
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
First Party, Third Party
Used by Google Analytics to throttle request rate
Used by Google AdWords to re-engage visitors that are likely to convert to users based on the visitor’s online behavior across websites.
Used by the social networking service, LinkedIn, for tracking the use of embedded services.
Used by the social networking service, LinkedIn, for tracking the use of embedded services.
Used by Facebook to deliver a series of advertisement products such as real-time bidding from third-party advertisers.
This cookie is used as part of Google Tag Manager for Google Analytics
Other tracking technologies
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the website to help customize our website and improve your experience. A “web beacon” or “pixel tag” is a tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of a page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.
How long we keep your information
We retain your information in accordance with our data retention, deletion and security policies. These set out the criteria we use to determine how long we keep your information, what measures we put in place to keep your information safe and secure. When deciding what to retain, we consider what information we need to best provide you with products, goods and services, manage your relationship with us, meet our statutory obligations and meet our customers’ and previous customers reasonable expectations. Most of our cookies expire within 30 days, although our analytics cookies may persist for between 2 and 10 years.
Lawful basis for cookies that we use
If you wish to make a complaint about how we use your information, please contact our support team and we will do our best to help.
Changes to this notice
We will occasionally update our privacy and cookies notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. This may include phone, SMS, e-mail, post or interactive social media. We encourage you to periodically review our notice to be informed of how we use your information.
This cookies notice was last updated September 5, 2018.