Legal Documents

Terms and Conditions

Effective Date: July 1st, 2021

Please read this Terms and Conditions (the “Terms”) carefully as they form a binding legal agreement between you and Purecoin OU, an Estonian company with the address at Harju maakond, Kesklinna linnaosa, Roseni tn 13, 10111 Tallinn, Estonia (“Purecoin” or “we” and its derivatives).

This site of Purecoin (collectively, the “Site”) and the information on it are controlled by Purecoin. These terms govern the use of the site and apply to all visitors to the site and those who use the currency management software (the “Software”), as well as other services and resources available via the site.

The term “You” refers to you individually or the legal entity on whose behalf the services are used, as applicable.

These are the general terms and conditions of using the services of Purecoin. By signing up through our website you agree that you have read, understood, and accept all of the Terms so in compliance with Terms and with applicable laws and regulations. You are solely responsible for understanding and complying with any and all laws, rules and regulations of Your specific jurisdiction that may be applicable to You in connection with the use of any and all Services. If you do not agree or fail to adhere to the terms and conditions or any other rules of any of the services, you are not entitled to use the services.

You undertakes not to use the Service to perform criminal activity of any sort, including but not limited to, money laundering, illegal gambling operations, financing terrorist organizations, or malicious hacking. You are responsible for any and all damages caused and all liability actions brought against Purecoin for infringement of any third party rights or violation of any applicable laws.

You should therefore carefully consider whether trading or holding digital assets is suitable for you in light of your financial condition.

By using the Purecoin Services, you agree to comply with these terms of use. Please check this page each time you use our website, as we may update these terms from time to time. The use of certain Purecoin Services may be subject to additional terms and conditions which you will be asked to read and accept at the relevant time. To the extent of any inconsistency with these terms, the terms of those Purecoin Services will apply to those Services and any matters connected with them. These terms, together with any additional terms and conditions, set out the basis of which Purecoin provides access to the Purecoin Services.

 

  1. REGISTRATION

You are required to register a Purecoin Account in order to have access to the Purecoin Platform.

  • For natural persons intending to register on the Purecoin Platform as a private user, by signing up to the Purecoin Platform, you certify that you are 18 years of age or older, you have sufficient capacity to understand and accept these terms and to trade digital assets, that your access to or use of the Purecoin Platform does not violate any laws applicable to you.
  • For legal persons intending to register on the Purecoin Platform as an institutional user, you must designate a representative who is a natural person aged 18 years of age or older with sufficient capacity and authority to accept these terms. You certify that your or your institution’s access to or use of the Purecoin Platform does not violate any laws applicable to you or your institution.

We reserve the right to unilaterally decide whether to open an Account and/or whether to provide Services to any persons and shall have no obligation to justify or outline the reasons for any rejection.

All information that you provide to us at any time (including but not limited to the information provided upon the opening of the Account) must be accurate, current and complete and may not be misleading in any respect. We may, from time to time, request such information to be provided and/or updated, in which case you are required to provide us with the information without delay. If you are unable or unwilling to provide or update such information or it is incorrect, we have the right to deny opening the Account, close the Account and/or restrict the usage of the Services.

 

  1. PURECOIN PLATFORM

The Purecoin Platform provides you access to and use the Software for the purposes of storing, tracking, transferring, managing and trading balances of supported digital assets as well as certain types of funds as specified by Purecoin from time to time.

Purecoin provides you an informational and order-matching exchange service by displaying prices for digital assets being traded on the Purecoin Platform at any given time.

Before transferring digital assets or funds into your Purecoin software, you must ensure that the digital assets in question are supported by the Purecoin softwares. You should not use the Purecoin softwares to store unsupported digital assets or funds and doing so may result in the forfeiture of your digital assets. Purecoin does not take any responsibility for any attempted use or storage of unsupported digital assets in a Purecoin software.

Purecoin does not own or control the underlying software protocols which govern the operation of digital assets. Generally, the underlying protocols are open source, and anyone can use, copy, modify and distribute them. Purecoin assumes no responsibility for the operation of the underlying protocols and Purecoin is not able to guarantee either the accuracy of the information provided or the functionality, security, legality or availability of the underlying protocols. You acknowledge and accept the risk that underlying software protocols relating to any digital assets you store in any Purecoin software may change.

You may withdraw digital assets from your Purecoin software by transferring them to an external digital asset wallet. The withdrawal of digital assets may be subject to periodic withdrawal limits.

Purecoin will process the orders you place on the Purecoin Platform in accordance with the instructions received from you. We are entitled to operate on the basis that each order is correct and does not contain any errors (including in the case of manifest errors). Before you place an order, you must carefully confirm all of the information specified, including the type, price and quantity of digital assets, buying or selling instructions, applicable fees and other important matters in connection with the order.

You acknowledge that using the Services is limited to the amounts as described in Fees and Limits.

 

  1. FEES, EXTRA CHARGE AND LIMITS

To use any of the Services, which might be provided for a fee as stated in Fees and Limits, you must open the Account and any such use must be done through the Account. One digital identity associated with the Account will be used for accessing all Services.

We may charge you for any reasonable costs that we incur in taking action to stop you using your mobile or account and to recover any monies owed as a result of your activities if you:

3.1 use your mobile or account fraudulently.

3.2 do not use your mobile or account in accordance with these Terms & Conditions; or

3.3 have been grossly negligent, for example by failing to keep your mobile or PIN secure or by failing to notify us without delay after your mobile is lost, stolen, or used by someone else or where your account has been compromised.

In these circumstances we will not refund transactions and we reserve the right to charge you for any reasonable costs that we incur in taking action to stop you from using your account and to recover any monies owed as a result of your activities. 

If you have not been fraudulent, or grossly negligent, and have used your mobile and account in accordance with these Terms & Conditions, your maximum liability for any unauthorised transaction resulting from the use of a lost or stolen mobile or details before you notify us will be 50 euro.

We may also charge you an Administration Fee if we have to manually intervene to complete a payment or rectify an error on the account caused by an error or omission on your part.

 

  1. REPRESENTATION AND WARRANTIES

Each time you place an order on the Purecoin Platform, you represent and warrant to Purecoin that:

1.you have the full power and authority to trade on the Purecoin Platform, you are the legal owner of all digital assets or currencies being traded and the digital assets and currencies are free from any charge or encumbrance.

2.you have relied only on information provided on the Purecoin Platform in creating orders and have not relied upon any representation or warranty given by any other person (including without limitation Purecoin);

In addition, you represent and warrant to Purecoin that:

1.you shall only use the Purecoin Platform to store or trade funds and digital assets;

2.you will not attempt to store, sell or buy unsupported digital assets, coins, other tokens or currencies or post information related to such unsupported digital assets, coins, other tokens or currencies;

3.you will not disguise or attempt to disguise your location through IP proxying or other methods;

4.you will not use the Purecoin Services:

(a)in contravention of any applicable laws;

(b)in any way (including without limitation posting information on the Purecoin Platform where this facility is available) which is defamatory, obscene, abusive, indecent or menacing or which infringes any intellectual property rights or breaches obligations of confidence or which is otherwise illegal or unlawful;

(c)to interfere with or attempt to interfere with the normal operations, trading order and/or activities of the Purecoin Platform and introducing a software virus or other disruptive program or do any act which would cause the Purecoin Platform to become unavailable for use by others; and

(d)in any way which is not authorised or in breach of the terms.

The site, services and software are provided on an “as is” and “as available” basis, with all faults, and Purecoin expressly disclaims all warranties, representations, and conditions of any kind arising from or related to these terms or your use of the site, services, and software, including the implied warranties of merchantability and fitness for a particular purpose. You acknowledge that, to the extent allowed by applicable law, all risk of use of the site, services, and software rests entirely with you.

You are responsible for maintaining adequate security and control of any and all login IDs, passwords, private keys, personal identification numbers (PINs), and any other codes or devices which are intended to or can otherwise be used to access the Account and/or use the Services.

You must prevent unauthorized access to the Account and unauthorized use of the Services, your account credentials or private keys, and must promptly notify us of any such unauthorized access or use.

In the event of an investigation of any suspected unauthorized access to the Account or use of the Services you must fully and timely cooperate with us in order to successfully solve the issue.

You are solely responsible, and to the maximum extent permissible under applicable legal acts, and we will have no liability, for any activity that takes place on your Account if the Account has been accessed with your account credentials, regardless of whether or not you authorized such access.

 

  1. ANTI-MONEY LAUNDERING AND SANCTIONS

Upon registration, Purecoin will conduct an user identification verification process to the extent required to comply with all applicable anti-money laundering, sanctions and other relevant related regulations. Your use of the services of the Purecoin Platform is conditional on the successful completion of this process. Where appropriate, Purecoin may ask you to provide additional personal information to determine your eligibility to use the services of the Purecoin Platform. Purecoin may ask you to wait for some time after the completion of a transaction before permitting you to use the Purecoin Platform and/or permitting you to engage in transactions beyond certain volume limits.

You authorise Purecoin to make inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect either you or Purecoin against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference, fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full. This is only an identity check and should not have any adverse effect on your credit rating.

You warrant that you will not use the Purecoin Platform to hold or trade in funds or digital assets which you know or suspect to be in violation of anti-money laundering laws, sanctions or other relevant related regulations. These include, but are not limited to, supplying the services of the Purecoin Platform or digital assets to individuals or countries subject to any financial sanctions regimes. In the event that you receive any funds or digital assets from other users in the course of your use of the Purecoin Platform which you know or suspect to contravene applicable anti-money laundering laws, sanctions and other relevant related regulations, you warrant that you will immediately notify Purecoin by e-mail at [email protected]  by including all relevant details and further warrant that you will not transfer any such funds or digital assets out of your Purecoin Account or any other digital asset wallet under your control without Purecoin’s permission.

Any offer for any feature, product or Service made through or on our Website or Service is void where prohibited.

By choosing to access the Website or download any Software from outside Estonia, you are solely responsible for complying with applicable local laws.

 

  1. LIMITATION OF OUR LIABILITY

Purecoin shall only be liable to you for loss or damage caused directly and reasonably foreseeable by our breach of these terms and our liability in these circumstances is limited as set out below.

Except as otherwise provided for in these terms, neither we, nor our affiliates or service providers, nor any of our or their respective officers, directors, agents, employees or representatives, will be liable for any amount greater than the combined value of the digital assets or funds in your Purecoin Account at any given time. Where we are considering a specific claim relating to a specific transaction, this sum shall be further limited to the amount of the transaction in dispute.

In addition to the liability cap above, to the maximum extent permitted by any applicable law, in no event shall we, our affiliates or service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any of the following types of loss or damage arising under or in connection with these terms or otherwise:

  1. any loss of profits or loss of expected revenue or gains, including any loss of anticipated trading profits and or any actual or hypothetical trading losses, even if we are advised of or knew or should have known of the possibility of the same. This means, by way of example only (and without limiting the scope of the preceding sentence), that if you claim that we failed to process a buy or sell transaction properly, your damages are limited to no more than the combined value of the digital assets or funds at issue in the transaction, and that you may not recover for any “loss” of anticipated trading profits or for any actual trading losses made as a result of the failure to buy or sell;
  2. any loss of or damage to reputation or goodwill; any loss of business or opportunity, customers or contracts; any loss or waste of overheads, management or other staff time; or any other loss of revenue or actual or anticipated savings, even if we are advised of or knew or should have known of the possibility of the same;
  3. any loss of use of hardware, software or data and or any corruption of data; including but not limited to any losses or damages arising out of or relating to any inaccuracy, defect or omission of digital currency price data; any error or delay in the transmission of such data; and or any interruption in any such data;
  4. any loss or damage whatsoever which does not stem directly from our breach of these terms; and or
  5. any loss or damage whatsoever which is in excess of that which was caused as a direct result of our breach of these terms (whether or not you are able to prove such loss or damage).

To the extent we are unable by law to exclude any implied condition, representation, warranty or statutory guarantee in relation to the provision of goods or services through our website, we limit our liability for a breach to the re-supply of those goods or services, or payment for such re-supply.

To the maximum extent permitted by any applicable law, Purecoin makes no warranties of any kind, whether express or implied, in relation to the website or the services on the Purecoin Platform, including but not limited to, implied warranties of satisfactory quality, functionality, fitness for a particular purpose, non-infringement, compatibility, security, accuracy, title, condition or completeness, merchantability, or any implied warranty arising from course of dealing or usage or trade. Purecoin does not represent or warrant that access to the Purecoin Platform or any of Purecoin’s services will be continuous, uninterrupted, timely or error-free. In any such event, Purecoin does not guarantee that any open orders can be executed, accepted, recorded or remain open.

Purecoin is not associated with and does not itself support or claim to be in partnership with any of services or companies which may appear visible in the provision of Purecoin Services.

Purecoin reserves the right to modify or discontinue, temporarily or permanently, all or any part of this site and/or any software, facilities and services on this site, with or without notice, and/or to establish general guidelines and limitations on their use.

Nothing in these terms shall exclude or limit our liability based on our fraud or fraudulent misrepresentation, deliberate misconduct, gross negligence or for death or personal injury arising from either our or our subcontractor’s negligence. If and to the extent applicable law does not allow the above limitations of warranty and liability, such limitations shall not apply to you.

Purecoin is not liable for any breach of these terms where the breach is due to abnormal and unforeseeable circumstances beyond Purecoin’s control, the consequences of which would have been unavoidable despite all effects to the contrary, nor are we liable where the breach is due to the application of mandatory legal rules.

Notwithstanding any other provision in these terms, nothing shall limit your rights as a consumer under mandatory provisions of applicable consumer protection legislation.

Purecoin is not a bank or financial institution and does not provide investment or financial advice or consulting services to users of the Services. We are solely the provider of the Services.

 

  1. GENERAL RISK AND RISK ASSOCIATED IN CRYPROASSETS

Since cryptoasset markets are decentralized and not regulated to the degree of investment services then customers using the services provided by Change will not fully benefit from the protections available to clients receiving regulated investment services under the so-called MiFID regime. This also means that there is no central bank that can take corrective measure to protect the value of cryptoasset in a crisis or issue more currency.

Cryptoasset market is determined only by supply and demand and is often highly unpredictable and volatile. The price of a cryptoasset is usually not transparent and highly speculative and susceptible to market manipulation. In the worst case scenario the product could be rendered worthless.

It is important to make a distinction between indicative prices which are displayed on charts and dealable prices which are displayed in the Apps. Indicative quotes only give an indication of where the market is. Because the cryptoasset markets are decentralized, meaning it lacks a single central exchange where all transactions are conducted, each market maker may quote slightly different prices. Therefore, any prices displayed on any chart made available by us or by a third party will only reflect indicative prices and not necessarily actual dealing prices where trades can be executed.

Cryptoasset trading is prone to being misused for illegal activities due to the pseudonymity or even anonymity of transactions and investors would be adversely affected if law enforcement agencies investigate any alleged illicit activities.

Accordingly, cryptoassets should be seen as an asset class with extremely high risks and you should never invest money that you cannot afford to lose. Given the foregoing, cryptoasset are not appropriate for all investors. You should not deal in these products unless you have the necessary knowledge and expertise, you understand these products’ characteristics and your exposure to risk. You should also be satisfied that the product is suitable for you in light of your circumstances and financial position. In addition, use of our Services can never be considered a safe investment rather only an investment with a high risk of loss inherently associated with it. Furthermore, our own fee is added to online quotes, if applicable, which makes trading with the Apps even more volatile.

The risk of loss in trading cryptoasset can be substantial. You should, therefore, carefully consider whether such trading is suitable for you in light of your circumstances and financial resources. You should be aware that you may sustain a total loss of the money deposited.

Since blockchain is an independent public or private peer-to peer network and is not controlled in any way or manner by us, we 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 cryptoasset 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.

 

  1. YOUR LIABILITY

You shall be fully responsible for any losses, expenses or other costs, including legal fees, incurred by Purecoin and its affiliates (as well as our respective officers, directors, agents, employees and representatives) which are caused by your conduct in relation to or arising out of your use of the Purecoin Services, your Purecoin Account or a breach of these terms whether by you or another person, where this conduct is intentional, reckless or negligent.

If we, or any of our affiliates or group companies, are subject to a claim by any third party due to your conduct, we may recover against you any and all losses, expenses or other costs incurred by us as a result of any such claim.

Nothing in these Terms and Conditions shall operate to exclude liability for death or personal injury due to negligence or for fraud or fraudulent misrepresentation or for any statutory liability that cannot be excluded or amended by agreement between the parties.

 

  1. YOUR RIGHTS AND RESPONSIBILITIES 

You have the right to use the Services, as long as you agree to and actually complies with these Terms. You undertakes to monitor all and any changes on Your Wallet and immediately inform Purecoin about any unusual, suspicious, unclear or abnormal changes on your Wallet or/and any unauthorized use of your Account or password, or any other breach of security. Otherwise, you will be responsible for any loss or damage You, Purecoin or/and third parties may incur as a result. 

 

  1. TERM AND TERMINATION

If you wish to cancel your Purecoin Account, please e-mail to [email protected] with the wording “Please cancel my account and password” in the subject line.

Once Purecoin has received your e-mail, we will within a reasonable time period cancel your account and password and delete, save as required by law or regulation, from our records the information you submitted to us as a part of the registration process.

Purecoin retains the absolute right to prevent you from accessing the Purecoin Services, including by deleting your account, without prejudice to any of Purecoin’s accrued rights, where we so choose, at our sole discretion, by giving you two months’ notice. You acknowledge that any such decision may be based on confidential criteria that are essential to our risk management and security protocols and you agree that Purecoin is under no obligation to disclose the details of its risk management and security procedures to you.

Purecoin reserves the right to suspend, terminate or block your access to the Purecoin Services at any time and without prior notice to you in the event of your breach of any of these terms.

Subject to clause 11.2 below, in the event that your access to the Purecoin Services is terminated by Purecoin, these terms shall be terminated on the date of the cancellation of your access to the Purecoin Services.

We have right to cancel your orders, restricting or terminating your access:

IF:

  1. we reasonably believe that your use of the Purecoin Services is in violation of any applicable law, these terms, any other terms or policies as set out by us or our customers’ legitimate interests;
  2. it becomes or may become (in our reasonable opinion) contrary to applicable law for us to maintain or give effect to all or any of the obligations under these terms or otherwise provide access to the Purecoin Services;
  3. we are requested to remove a listing (or any part thereof) by any regulatory or other governmental authority (whether or not the request is legally binding);
  4. we are requested to close out or cancel a any order (or any part thereof) by any regulatory or other governmental authority (whether or not the request is legally binding);
  5. we consider it desirable or necessary to remove a listing or an order (or any part thereof) to maintain the trading order and trading safety of the Purecoin Platform, in our sole and absolute discretion; or
  6. in the event that you become unable to meet your obligations as they become due or have a bankruptcy petition presented against you or you propose a form of composition or arrangement to its creditors or if you cease or threatens to cease all or part of its business,

We may without notice:

  1. terminate, cancel or reverse any order created or entered into by you;
  2. restrict or freeze your Purecoin Account and any of your funds and digital assets;
  3. immediately delete and/or amend any information published by you on the Purecoin Services, where relevant, in violation of any applicable law and / or of these terms, in addition to monitoring any other information which you publish on the Purecoin Services;
  4. restrict, freeze or terminate your access to the Purecoin Platform; and or
  5. take any other measures which in our reasonable opinion is necessary to prevent any adverse consequences to Purecoin, the Purecoin Services, any other users of the Purecoin Services and any other third party.

If you become aware of the occurrence of any event referred to in Clause 10.1 above, you must give us notice of such event as soon as is reasonably practicable.

If we terminate any order, or restrict your use of the Purecoin Services in accordance with this Clause 10, we shall not be liable for any losses, expenses or other costs incurred to you, any other user of the Purecoin Services and / or any other third party.

 

  1. DISPUTE POLICIES

Purecoin will use its best endeavours to resolve any disputes arising out of trading on the Purecoin platform fairly. Nevertheless, you agree that Purecoin retains the right to absolute discretion in resolving any such disputes.

Where we, in our sole discretion, reasonably believe that any user is or may be engaging or attempting to engage in fraudulent or unlawful activity, we may take any steps (or we may request you to take any steps) we consider necessary or desirable, to prevent, mitigate or investigate such activity. You agree to comply with such requests, including any requests to provide us with information, to the maximum extent permitted by applicable law.

IF YOU AGREE TO ARBITRATION WITH PURECOIN, YOU ARE AGREEING IN ADVANCE THAT YOU WILL NOT PARTICIPATE IN OR SEEK TO RECOVER MONETARY OR OTHER RELIEF IN ANY LAWSUIT FILED AGAINST PURECOIN ALLEGING CLASS, COLLECTIVE, AND/OR REPRESENTATIVE CLAIMS ON YOUR BEHALF. INSTEAD, YOU MAY BRING YOUR CLAIMS AGAINST PURECOIN IN AN INDIVIDUAL ARBITRATION PROCEEDING. IF SUCCESSFUL ON SUCH CLAIMS, YOU COULD BE AWARDED MONEY OR OTHER RELIEF BY AN ARBITRATOR. YOU ACKNOWLEDGE THAT YOU HAVE BEEN ADVISED THAT YOU MAY CONSULT WITH AN ATTORNEY IN DECIDING WHETHER TO ACCEPT THESE TERMS, INCLUDING THIS ARBITRATION AGREEMENT.

  1. MISCELLANIOUS
  2. You agree that we may assign these Terms (either collectively or each right and/or obligation separately, as decided by us) to our parent company, affiliate or subsidiary without your consent. You may not assign any rights or obligations you have under these Terms without our prior written approval.
  3. Survival: All provisions of these terms which by their nature extend beyond the expiration or termination of these terms will continue to be binding and operate after the termination or expiration of these terms.
  4. If any portion of these Terms is held invalid or unenforceable, that portion will be construed in a manner to reflect, as nearly as possible, the original intention of the parties, and the remaining portions will remain in full force and effect.

General and Wallet

These are the general terms and conditions of using the services of Purecoin. By signing up through our Website or Apps you agree that you have read, understood, and accept all of the Terms. If you do not agree or fail to adhere to the terms and conditions or any other rules of any of the services, you are not entitled to use the services.

The Website and the Services offered by Purecoin are NOT ADDRESSED TO AND MAY NOT BE USED BY:

persons who DO NOT have their citizenship or their legal place of residence in any of the contracting states of the European Economic Area, except the Netherlands; and
natural persons who are NOT at least 18 years of age.
1. What terms and definitions do we use?
As used in these Terms, including the preamble hereof, unless expressly otherwise stated or evident in the context, the following capitalized terms and expressions shall have the following meanings:

Account – the account opened with Purecoin by a User, using which the User can access the Services;

Apps – the web, Android and iOS mobile apps of Purecoin, which give access to the Services;

Cash Management – cryptoasset service for Purecoin account and card holders provided by Purecoin, whereby the eligible User is rewarded for buying supported cryptocurrencies from Purecoin and allowing these to be deposited on Crypto Interest Account;

Purecoin – Purecoin OÜ, an Estonian public limited company registered under registry code 14929082, Harju maakond, Tallinn, Kesklinna linnaosa, Roseni tn 13, 10111. References to “we”, “us” and “our” mean references to Purecoin and/or if applicable Indexa B.V.;

Purecoin Tokens or Tokens – cryptographic ERC-20 tokens issued by Purecoin, which are at the date of these Terms and Conditions trading on the cryptocurrency market KuCoin (https://www.kucoin.com/) as Purecoin tokens (CAG) and in Apps as Purecoin equity-like tokens (CNG). The list of cryptocurrency markets on which the Tokens are tradable may be amended by Purecoin at its full discretion at any time without providing any prior notification thereof;

Conversion Rate – the price or exchange rate of one unit of a given supported cryptocurrency quoted in the Apps and on the Website in terms of a specified Fiat currency or another supported cryptocurrency composing of Rate Reference and conversion fee as described in Fees and Limits;

Conversion Service – regulated service of cryptocurrency conversion (for which Purecoin has been issued a license by the Estonian Financial Intelligence Unit, no FVT000059) through which Users can buy supported cryptocurrencies from Purecoin, in exchange for specified Fiat currencies and other supported cryptocurrencies and specified Fiat currencies from Purecoin, in exchange for supported cryptocurrencies, including the services of Market Order, Limit Order and Stop Order, and Cash Management;

Crypto Interest Account – custodial omnibus wallet operated either by BlockFi, Inc. or Payward, Inc. where Purecoin deposits supported cryptocurrencies on behalf of customers for the purpose of earning and redistributing staking reward, i.e. interest;

Custodian – the person who holds and is responsible for the safekeeping of the cryptocurrencies and/or tokens (including the Tokens) transferred to or held in the Wallet by the User, who at the date of these terms and conditions is Bitgo Inc.;

Debit Card – VISA debit card connected to the Purecoin Account as described in chapter Purecoin Account and Debit Card;

Fees and Limits – full list of fees and limits of Services as described in chapter Fees and Limits;

Fiat – currency that has been declared as legal tender by a government and is regulated by a central financial institution, i.e. the euro;

Purecoin Account – electronic money account as described in chapter Purecoin Account and Debit Card;

Instant Deposit – Service allowing Users to add funds to their Fiat Account instantly by using their EEA-issued credit or debit card (limited up to 3 different cards) with the fee described in Fees and Limits;

Limit Order – Service, whereby User submits an instruction to complete the transaction in the future when the price of the supported cryptocurrency has been risen above the Rate Reference set by the User has been reached;

Market Order – Service, whereby User submits an instruction to complete the transaction immediately;

Party – each of the User and Purecoin;

Rate Reference – the price of one unit of a supported cryptocurrency in terms of a specified Fiat currency or another supported cryptocurrency, which is based on the lowest ask price for buying or the highest bid price for selling a cryptocurrency on the exchange operated by Payward, Inc., adjusted by market depth.

Services – services provided by Purecoin and/or Purecoin OÜ to the Users, including the Wallet and the Conversion services;

Stop Order – Service, whereby User submits an instruction to complete the transaction in the future when the price of the supported cryptocurrency has been fallen below the Rate Reference set by the User;

Taxes ‒ taxes, levies, duties or similar governmental assessments of any nature, including, for example, value-added, sales, use or withholding taxes, assessable by any jurisdiction whatsoever;

Terms – these Terms and Conditions including all the chapters, as amended from time to time;

Token Swap – exchanging CAG Tokens to CNG Tokens as described in chapter Token Swap;

User – anyone who uses the Website, Apps and/or Services provided by Purecoin. References to “you” and “your” mean references to the User;

Wallet ‒ User’s cryptocurrency wallet, which can be accessed via the Website or the Apps, and which is a regulated service (for which Purecoin has been issued a license by the Estonian Financial Intelligence Unit, no FVT000059), as further described in section 6 below, including the Services of Cryptocurrency withdrawal and Cryptocurrency deposit;

Website – websites located at www.purecoin.app and at all subdomains.

2. What are the conditions for opening the Account?
2.1. To use any of the Services, which might be provided for a fee as stated in Fees and Limits, you must open the Account and any such use must be done through the Account. One digital identity associated with the Account will be used for accessing all Services.

2.2. Each User must be at least 18 years of age to register for an Account or to use any of the Services.

2.3. We reserve the right to unilaterally decide whether to open an Account and/or whether to provide Services to any persons and shall have no obligation to justify or outline the reasons for any rejection.

2.4. All information that you provide to us at any time (including but not limited to the information provided upon the opening of the Account) must be accurate, current and complete and may not be misleading in any respect. We may, from time to time, request such information to be provided and/or updated, in which case you are required to provide us with the information without delay. If you are unable or unwilling to provide or update such information or it is incorrect, we have the right to deny opening the Account, close the Account and/or restrict the usage of the Services.

2.5. You acknowledge that using the Services is limited to the amounts as described in Fees and Limits.

2.6. By opening an Account and using the Services, each User fully acknowledges that Purecoin does not provide to the User any investment service or advice. Each User fully acknowledges that any information, product or service provided by us on our Website or Apps is not considered investment advice or recommendation, and independent professional advice should be sought where appropriate.

3. What are the risks?
3.1. By using the Services you acknowledge that various types of risks are involved, including but not limited to risks relating to the fluctuation of the value of any assets related to the Services (including Purecoin Tokens), technical imperfections of Purecoin Tokens, other cryptocurrencies, the Website and the Apps, regulatory uncertainties, and risks related to our operations and financial viability. As our Users are taking risks and are exposed to them through our Services, we strongly recommend and encourage you to learn and gain a sufficient understanding of the risks involved prior to using our Services.

3.2. We encourage you to consult with a financial advisor or other appropriate professional prior to starting to use the Services.

4. What are the geographical restrictions of using the Services?
4.1. Purecoin administers and operates the Website and Apps from its location in Estonia. Although the Website and Apps are accessible worldwide, not all features, products or services discussed, referenced, provided or offered through or on our Website or Apps are available to all persons or in all geographic locations, nor are they appropriate or available for use outside Estonia.

4.2. We reserve the right to limit, in our sole discretion and without providing any justification related thereto, the provision and quantity of any feature, product or Service to any person or geographic area.

4.3. Any offer for any feature, product or Service made through or on our Website or Apps is void where prohibited.

4.4. By choosing to access the Website or download or access any of the Apps from outside Estonia, you are solely responsible for complying with applicable local laws.

5. How to keep the Account safe and secure?
5.1. You are responsible for maintaining adequate security and control of any and all login IDs, passwords, private keys, personal identification numbers (PINs), and any other codes or devices which are intended to or can otherwise be used to access the Account and/or use the Services.

5.2. You must prevent unauthorized access to the Account and unauthorized use of the Services, your account credentials or private keys, and must promptly notify us of any such unauthorized access or use.

5.3. In the event of an investigation of any suspected unauthorized access to the Account or use of the Services you must fully and timely cooperate with us in order to successfully solve the issue.

5.4. You are solely responsible, and to the maximum extent permissible under applicable legal acts, and we will have no liability, for any activity that takes place on your Account if the Account has been accessed with your account credentials, regardless of whether or not you authorized such access.

6. What is the Wallet service?
6.1. We provide the service of a cryptocurrency wallet pertaining to your Wallet. The Wallet service entails enabling you to interface with certain cryptocurrency networks listed in the Apps and on our Website, and if applicable to view and transmit information about public cryptographic keys. We have the right to unilaterally decide and change the cryptocurrencies which can be stored in the Wallet using the Wallet service or converted using the Conversion Service.

6.2. Upon using the Wallet service in addition to adhering to these Terms you agree to fully abide by the terms and conditions of the Custodian.

6.3. We are not a custodian of any cryptocurrency and/or tokens (including the Tokens) transferred to or held in the Wallet. All cryptocurrencies and tokens (including the Tokens) are held by the Custodian. We reserve the right to change the Custodian at any time, without prior notification or justification thereto. To the maximum extent permissible under applicable legal acts, we assume no liability for any possible damages caused by the Custodian.

6.4. Upon the creation of the Account, the Wallet is automatically created for you, together with a public key, which serves as the address of the Wallet. We have the sole right to decide at our own discretion whether or not to disclose that public key to you and we may at any time, and without any prior notice, not disclose the public key to you.

6.5. To transmit information concerning the Account to the relevant cryptocurrency network (i.e. to carry out a transaction with cryptocurrency), two private keys (out of three private keys in total) are required. One of such private keys is held by us, the other by the Custodian and the third is held by a third-party backup service provider.

6.6. You are solely responsible for the safekeeping of the third private key. Should you appoint a third party to control your private key, whether or not such appointment is made through the Website or the Apps, we will not be responsible for the actions or omissions of such third party.

6.7. We do not own or control the underlying software protocols which govern the operation of cryptocurrencies held in the Wallet. Such protocols are subject to changes in protocol rules, which are outside our control and may materially affect the value, function, or name of the relevant cryptocurrency. You acknowledge and agree that:

6.7.1. we are not responsible for operation of the underlying cryptocurrency protocols and that we make no guarantee of their functionality, security, or availability; and

6.7.2. if a change in the software protocol related to the cryptocurrency occurs, we may suspend the Wallet service, and may decide not to provide Wallet service for the cryptocurrency being affected or may configure the Wallet service to enable you to transfer the affected cryptocurrency.

6.8. While using the services of Cryptocurrency withdrawal and Cryptocurrency Deposit, you are only able to transfer supported cryptocurrencies, which are stated in the Apps and on the Website, e.g. BTC and ETH.

6.9. Due to the nature of distributed ledger technology and blockchains you acknowledge that while using the services of Cryptocurrency withdrawal and Cryptocurrency deposit none of the transactions, which have been confirmed and added to the respective main ledger, cannot be reversed and you are fully liable for the transactions you have confirmed and ordered us to process.

6.10 Due to the nature of blockchain protocols and the lack of advance knowledge of the network, gas or similar fees, Purecoin is unable to determine the exact Cryptocurrency withdrawal fee before the specific transaction has been confirmed by miners. The Cryptocurrency withdrawal fee shown to you in the Apps is automatically calculated by Purecoin after every 5 minutes by taking into account the concurrent price of the specific network, gas or similar fee and the relevant price predictions, regardless of the priority in the memory, transaction or other similar pool. While using the service of Cryptocurrency withdrawal, you agree to pay the specific Cryptocurrency withdrawal fee shown to you in the Apps by confirming the Cryptocurrency withdrawal in your email or in the Apps.

7. What are the customer due diligence measures?
7.1. In order to manage the risk of money laundering and terrorist financing, and to abide by the statutory obligations applicable to us and to you for using our Services, we and you are obliged to follow certain principles of customer due diligence, as further specified in this section.

7.2. You are not allowed to use the Services nor the Wallet for any activities which are related to or facilitate money laundering, terrorist financing or any illegal activity whatsoever.

7.3. We reserve the right to, at any time:

7.3.1. identify you;

7.3.2. request from you any documents, either as originals or as copies and information (including personal), which we consider appropriate and/or relevant for the identification or for the mitigation of money laundering and terrorist financing risks;

7.3.3. regularly control your data and documents which are used for identification and/or for the mitigation of money laundering and terrorist financing risks;

7.3.4. transfer and disclose any information and documents received in accordance with this section to any and all governmental authorities and other persons to whom we are obliged to transfer and disclose information and documents in accordance with applicable legal acts;

7.3.5. transfer and disclose any information and documents received in accordance with this section to any and all third-party service providers, which we use to fulfil our obligations related to client identification and money laundering and terrorist financing prevention; and

7.3.6. transfer and disclose any information and documents received in accordance with this section to the Custodian.

7.4. You acknowledge that we may upon the fulfilment of our obligations related to client identification and money laundering and terrorist financing prevention use the services of third-party service providers, and you hereby grant an irrevocable and unconditional consent to such use of third-party service providers and the transfer and disclosure of information to such third-party service providers.

7.5. You acknowledge that we may transfer and disclose to the Custodian any information and documents referred to in this section for the purpose of allowing the Custodian to fulfil their obligations related to client identification and money laundering and terrorist financing prevention, and you hereby grant an irrevocable and unconditional consent to such transfer and disclosure of information.

7.6. You are obliged to immediately inform us in writing of any information that might be relevant in accordance with this section and/or changes to the provided information and documents, inter alia:

7.6.1. change of your name, address or other contact information;

7.6.2. change of data regarding your identity document;

7.6.3. the fact that you are or no longer are a politically exposed person and/or a relative or a close associate of one; and

7.6.4. loss or theft of your identity document or credentials used for Purecoin Account or Services.

7.7. You are obliged to inform us in writing of any other information which might be relevant in relation to client identification and money laundering and terrorist financing prevention, immediately after becoming aware of such information.

7.8. You are obliged to fully and timely cooperate with us upon the gathering of information and documents referred to in this section, as well as the fulfilment of any other obligations we have in relation to client identification and money laundering and terrorist financing prevention under applicable legal acts. Should you refrain from cooperation with us in accordance with this section, we have the right or legal obligation to:

7.8.1. stop the provision of any Services;

7.8.2. block the Account and limit your access to the Website and the Apps;

7.8.3. withhold any payments made by or to you in relation to the Services; and/or

7.8.4. close the Account.

7.9. In addition to clause 7.8, we reserve the right to block the usage of your Account and limit your access to the Website and the Apps, when we suspect that:

7.9.1. the Account is being used by any person other than you;

7.9.2. an offence is being committed, using the Account; and/or

7.9.3. any of the information or documents provided by you to us or our third-party service providers may be untrue, and you do not provide sufficient and/or satisfactory evidence, proving the correctness of the information and documents.

7.10. To the maximum extent permissible under applicable legal acts, we assume no liability for any losses or damages caused to you or any other persons by the actions provided for in this section.

8. How to close the Account?
8.1. You have the right to close your Account at any time, provided that you have no obligations towards us nor the Custodian. From the moment of closing the Account, you shall not be entitled to use any of the Services.

8.2. In addition to specific circumstances described elsewhere in these Terms, we reserve the right to close your Account:

8.2.1. without any justification, by giving you an advance notice of at least 14 days and refunding you the market value of any assets which you have in the Wallet, for which such services have not yet been provided and cannot be provided after the closing of the Account;

8.2.2. in case you breach: (i) these Terms; (ii) the terms and conditions of the Wallet Custodian; or (iii) any other terms and conditions of the Services or otherwise binding on you, without giving any notice in advance; and/or

8.2.3. in case closure of the Account is required by a competent authority, without giving any notice in advance.

8.3. If we have closed your Account without giving any notice in advance the cryptocurrencies held at your Account shall be automatically converted into specified Fiat funds by us and transferred to your bank account from which a payment had been previously made in accordance with the law.

8.4. Once an Account has been closed, it cannot be re-opened in the future.

9. What are the liabilities of the Parties?
9.1. You are liable for and shall compensate Purecoin any and all damages (including the loss of profits), which arise from your activities.

9.2. We are liable for and shall compensate you only direct monetary damages (and for the avoidance of doubt, no indirect damages or loss of profits) and only on the condition that such damages are caused to you by us either intentionally or due to gross negligence.

9.3. Our liability is reduced by the amount equal to the damages which you could have been avoided by taking reasonable efforts.

9.4. In addition to the limitations described elsewhere in these Terms, to the maximum extent permissible under applicable legal acts, we assume no liability for any damages caused by third parties (including but not limited to the Custodian) or by circumstances outside our control (including but not limited to volatility of cryptocurrencies).

10. What about information technology and intellectual property?
10.1. Unless otherwise stated, all materials including, but not limited to, logos, brand names, designs, images, photographs, video clips, written are copyrights, trademarks, service marks, and any other forms of intellectual property present in the Services or displayed in connection with the Services (e.g. in the Website), protected by registration or not, are owned by or licensed to us. The foregoing also applies towards any software solutions or parts of it, programs and code present in the Service.

10.2. We grant you a limited, non-exclusive, not sub-licensable licence to access and use the materials, as specified in this section of these Terms, for your personal use, as required for the use of Services.

10.3. You are not allowed to sell, distribute, publicly display, modify, otherwise alter or make any derivative use of the materials, as specified in this section, or any portion thereof, unless you have been granted an express and written prior permission to do so by us.

10.4. The licence granted under this section will automatically terminate upon the closing of the Account. Thereafter you are no longer allowed to access or use any part of the material belonging to us.

10.5. In case your actions or activities conducted in connection with the Service or while using the Service (including but not limited, through providing us feedback or leaving any comments addressed us) amount to copyright protected work under applicable legislation, you will automatically grant to us, from the moment of the creation of such work, a non-exclusive, world-wide, sub-licensable, free-of-charge licence, which is valid until the copyright is protected under applicable legislation, in relation to such work.

10.6. As stated in this section, we retain full ownership and/or exclusive licence of any software, program, code or parts of it. The foregoing might be protected by security measures, which you are not authorized to change, disseminate, hack or alter in any way.

11. Are there any other legal matters you should consider?
11.1. It is your sole responsibility to determine whether, and to what extent, any Taxes apply to any transactions you conduct through the Apps and Website or are associated with the Services, and to withhold, collect, report and remit the correct amounts of Taxes to the appropriate tax authorities. Your transaction history is available through the Apps. The fees collected by us do not include any Taxes.

11.2. We may unilaterally amend these Terms without providing any advance notice or justification thereto. Any amendments to the Terms shall take effect as of uploading them to the Website and making them accessible in the Apps.

11.3. Our failure to exercise or enforce any right or provision of these Terms will not constitute a waiver of that right or provision.

11.4. If any part of these Terms is held to be invalid or unenforceable, such determination shall not invalidate any other provision of these Terms.

11.5. You agree that we may assign these Terms (either collectively or each right and/or obligation separately, as decided by us) to our parent company, affiliate or subsidiary without your consent. You may not assign any rights or obligations you have under these Terms without our prior written approval.

11.6. These Terms are governed by the laws of Estonia. Any dispute, controversy or claim arising out of or in connection with these Terms, or the breach, termination or invalidity hereof, which the Parties have failed to solve by negotiations will be settled in Harju County Court.

Fiat account and Conversion Service

1. What terms and definitions we use?
As used in these Terms, including the preamble hereof, unless expressly otherwise stated or evident in the context, capitalized terms and expressions shall have the meanings as stipulated under “General and wallet” chapter.

2. How to add Fiat funds to your Account?
2.1. In order to add Fiat funds to your Account you must transfer at least 10 euros to the account provided by us, which will be added to your Account, from an account opened under your name in a credit or financial institution, registered or having its place of business in a contracting state of the European Economic Area. Any following transaction may be made from a different account, provided it is opened in your name, or by using the Service of Instant Deposit.

2.2. You acknowledge that all of the Fiat funds described in these Terms must belong to you and all the accounts described in these Terms must be opened under your name.

2.3. We reserve the right to decline accepting Fiat transfers to our account from any account due to any reason or decline transferring funds to an account that was not used to make a transfer in accordance with clause 2.1 by notifying you thereof. We have also reserved the right to decline accepting any payments while using the Service of Instant Deposit, e.g. to prevent fraud or in case more than 3 different cards have been used.

2.4. In case we decline accepting Fiat transfers, the funds will be immediately returned to your account opened in a credit institution in accordance with the law.

3. How to withdraw Fiat funds from your Account?
3.1. You are entitled at all times to instruct us to withdraw any Fiat funds from your Account by instructing us to transfer them to an account you previously transferred funds from as described in clause 2.1.

3.2. We reserve the right to decline to perform a withdrawal, if the withdrawal amount is lower than 10 euros.

3.3. In the case of Account closing you must instruct us to transfer all of the fiat funds to an account you previously transferred funds from as described in clause 2.1 and we will transfer it to your account in accordance with the law.

4. How to buy cryptocurrency?
4.1. In order to buy a supported cryptocurrency with the Conversion Rate in exchange for a specified Fiat currency in accordance with these Terms, you must have had transferred the Fiat funds required for the transaction, as shown to you in the Apps or Website, to our account in accordance with clause 2.1.

4.2. In order to buy a supported cryptocurrency in exchange for another supported cryptocurrency in accordance with these Terms you must have had transferred to us the equivalent amount of supported cryptocurrency, which is to be used in exchange for the requested supported cryptocurrency and will be automatically debited from your Wallet.

4.3. In order to buy a supported cryptocurrency with the Conversion Rate in exchange for a specified Fiat currency or supported cryptocurrency, but not having transferred the required amount of the specified Fiat currency or supported cryptocurrency to us, the required specified Fiat currency or supported cryptocurrency must be held at your account or Wallet during the time of buying the supported cryptocurrency as a result of using the Conversion Service.

4.4. In case you have requested to buy a supported cryptocurrency, the amount of supported cryptocurrency bought by you will be transferred to your Wallet after the completion of the relevant transaction.

5. How to sell cryptocurrency?
5.1. In order to sell a supported cryptocurrency with the Conversion Rate in exchange for a specified Fiat currency in accordance with these Terms, you must have had transferred to us the equivalent amount of supported cryptocurrency, which is to be used in exchange for the requested Fiat currency and will be automatically debited from your Wallet.

5.2. In case you have requested to sell a supported cryptocurrency in exchange for a specified Fiat currency, the amount of specified Fiat currency will be transferred to your Account after the completion of the relevant transaction specified in your instruction.

6. How are the transactions carried out?
6.1. We carry out the transactions described in these Terms on the basis of irrevocable instructions from you, which can be submitted through the Apps or Website.

6.2. You are not allowed to cancel, reverse, or change any transaction marked as complete after the submission of an instruction in accordance with these Terms. We may unilaterally decline to carry out the transaction by notifying you thereof on the Website and/or in the Apps, and return you the relevant instruments, and shall assume no liability for any damages which arise to you as a result thereof. You may only cancel a pending instruction, if you have submitted it by using the services of Limit Order or Stop Order, provided the estimated rate you set has not been reached and the transaction has not yet marked as complete.

6.3. You are displayed all supported cryptocurrencies with the estimated Conversion Rate prior to submitting the instructions in accordance with these Terms and/or exact Conversion Rate for transaction(s) marked as complete. By submitting the instructions in accordance with these Terms you irrevocably confirm to carry out the transaction without certainty of the Conversion Rate.

6.4. After receiving the instructions in accordance with these Terms, we will complete the requested transaction within 5 business days after receiving the payment (whereas a business day is considered to be a day when banks are open for business in Estonia), unless we decline to carry out the transaction in accordance with clause 6.2. We reserve the right to delay any transaction without notifying you thereof, should we perceive a risk of fraud or illegal activity.

7. What are your liabilities?
7.1. Should you breach any obligations described in these Terms, we have the right to refuse to carry out the requested transactions by notifying you thereof on the Website and/or in the Apps, and we shall assume no liability for any damages which arise to you as a result thereof.

7.2. We cannot guarantee and are not liable for the availability of the Conversion Service, and the act of buying supported cryptocurrency is not and may not be considered a guarantee from us that you could sell the cryptocurrencies or Fiat currencies obtained using the Conversion Service back to us nor with the set Reference Rate, while using the services of Limit Order or Stop Order.

Purecoin Account and Debit Card

These Terms & Conditions apply to your Purecoin account and Visa debit card. Please read them carefully. You can download a copy of these Terms & Conditions at any time from within your online account portal. Log in via our website www.purecoin.app.

The Purecoin account and Visa debit card are e-money services provided by UAB Finansinės paslaugos “Contis“. Your distributor may transfer funds from a wallet you hold directly with them to cover the value of transactions you make using your Visa card.

In these Terms & Conditions:

“Distributor” means a third party, Purecoin, who will distribute the account and card to you on our behalf.
“You” means the named account holder being the authorised user of the Purecoin account and Visa debit card and any additional cardholder.
“We”, “us” or “our” means UAB Finansinės paslaugos “Contis“ or the Distributor acting on our behalf.
If you have any questions you can contact us by:

email: [email protected];
mobile application: log in to your Purecoin account through the Apps and send us a secure message;
post: Mėnulio g. 11-101, Vilnius, Lithuania.
Your Purecoin account and Visa debit card is issued by UAB Finansinės paslaugos “Contis“, company code 304406236, registered in the Register of Legal Entities of the Republic of Lithuania, having a head office at Mėnulio g. 11-101, Vilnius, Lithuania.

We hold the electronic money institution license no 53, dated 2019-07-23, issued by the Bank of Lithuania, who is our supervisory authority located at Gedimino pr. 6, LT-01103, Vilnius, Lithuania, telephone no. +370 800 50 500. You may find more information about the Bank of Lithuania at https://www.lb.lt/en/.

Please note that Purecoin Visa account and debit card is an electronic money product and although we are supervised by the Bank of Lithuania, it is not covered by the Deposit Insurance System of the Republic of Lithuania. We ensure that any funds received from you are held in a segregated account so that in the unlikely event that UAB Finansinės paslaugos “Contis“ becomes insolvent your funds will be protected against claims made by creditors.

Your Purecoin account and Visa debit card is distributed by Purecoin OÜ, a public limited company incorporated in Estonia with registry code 14929082 and whose registered office is Harju maakond, Tallinn, Kesklinna linnaosa, Roseni tn 13, 10111, on behalf of UAB Finansinės paslaugos “Contis“.

1. What is a Purecoin account and debit card?
1.1. A Purecoin Account is an electronic money account from which you can make and receive payments. You can use your account to make transfers to other accounts and set up standing orders.

1.2. A Purecoin card is a Visa debit card that can be used worldwide wherever Visa is accepted. It can be used online, in shops, over the phone or to withdraw cash from an ATM.

1.3. You can only spend money that you have paid into your account, so before making transfers or using your card you need to make sure there are enough funds in the Purecoin account. Monies in the Purecoin account are not bank deposits and do not earn interest.

2. Who can apply for a Purecoin account and card?
2.1. You must be at least 18 years old and a UK or EEA resident to be issued with a Purecoin account and card. You must provide an email address and mobile phone number to open an account so that we can communicate with you.

2.2. There is a maximum of five accounts at each residential address.

3. How can I apply for the Purecoin account?
3.1. You can apply on our website www.purecoin.app or you can apply through the Apps.

3.2. Before we can open an account for you and issue you with a card, we will require evidence of your identity and we may require evidence of your residential address. You may need to provide us with documents such as passport, driving licence, national identity documents, utility bills, bank statements or other documents to confirm your identity. We will also need to carry out checks on you electronically.

4. How do I get started?
4.1. As soon as you receive your card you must sign the signature strip on the back.

4.2. You will then need to activate your card. You can do this by logging into your Purecoin account.

4.3. You also need to obtain your PIN to authorise chip-and-pin transactions and ATM withdrawals. You can get your PIN through your online account or the Apps.

4.4. By activating your card you are agreeing to these Terms & Conditions. Your card must be activated within 3 months of it being issued or it may be automatically cancelled and your account may be closed.

5. What if I want to change my Personal Identification Number (PIN)?
5.1. If you want to change your PIN, you can do so at any ATM with PIN management functionality, locate ATMs with the “PIN change” attribute at https://www.visa.com/atmlocator/#(page:home).

5.2. You can get a reminder of your PIN through the Apps.

6. How do I add funds to the Purecoin account?
6.1. You may pay into your account via Change, and any other method notified by us. The time taken to credit funds to your account will depend on the method of deposit used. You cannot pay into your account by a balance transfer from a credit card. You may only pay in funds up to your maximum account balance.

6.2. Certain minimum and maximum limits and usage requirements apply to your account and card; such limits and requirements are detailed in the chapter Fees and Limits. We reserve the right to refuse to accept any particular payment if we suspect any fraudulent activity or in the event of other exceptional circumstances, e.g. the payment does not originate from an account opened in your name.

6.3. As soon as we receive the funds that you have paid in, they will be on your account and ready to use. There may be occasions when we delay the funds reaching your account for up to three working days, this may happen when we need to confirm the transaction with the sending bank.

6.4. Where an overpayment has been made to your account in error, we reserve the right to debit the account with the excess amount to correct the payment transaction.

7. How do transactions work?
7.1. You can use your Visa card to authorise the following transactions to merchants that accept Visa Debit card payments:

7.1.1. Chip and PIN card payments by inserting your Purecoin card in the terminal and inputting your PIN;

7.1.2. Magnetic Stripe card payments to any merchant that cannot accept Chip and PIN cards by signing the sales voucher;

7.1.3. contactless card payments by waving the Purecoin card over the contactless card reader;

7.1.4. Internet card payments to online merchants by providing the Purecoin card details and any other security details such as your secure code credentials as requested by the online merchant;

7.1.5. mail order or telephone order card payments to merchants by providing the Purecoin card details as requested by the merchant;

7.1.6. ATM cash withdrawals at ATMs displaying the Visa logo by inserting your Purecoin card at the ATM, inputting your PIN and following the instructions at the ATM;

7.1.7. e-wallet payments by adding your card to the Samsung Pay, Google Pay or Apple Pay (when available) wallets in your mobile phone and waving your mobile phone over the contactless card reader or checking the e-wallet option online. You authorise the e-wallet transaction using your mobile phone security protocol which may include biometric information such as fingerprint or face ID on your mobile phone.

7.2. Like other payment cards, we cannot guarantee a third party or ATM will accept your card.

7.3. You may, in addition, be required to enter a one-time passcode or other security information including, if available and you opt for this type of identification, biometric information to authorise a transaction or make account amendments. One-time passcodes will be sent to the mobile phone number registered to your account.

7.4. As soon as a transaction is authorised we will deduct the value of your transaction from the available balance on your account. Fees may be deducted at the time of authorisation or when the transaction has been confirmed through the Visa system. A full breakdown of each transaction, including charges, will be available to view on your online account portal.

7.5. Once we have received authorisation for a transaction we will transfer funds to the retailer within 3 days, or to a bank or financial institution on the day we receive the authorisation or the day you requested the payment to be made for future dated transactions. A transaction will be received at the time we receive the transaction instruction from the retailer or ATM operator.

8. Can I cancel a transaction?
8.1. Generally, authorisation for a transaction may not be withdrawn by you. However, you may be able to withdraw your authorisation where you have authorised a transaction which will take place on a future date. However, where a specific date is agreed, you may not revoke a payment order after the end of the business day preceding the agreed date.

8.2. To withdraw your authorisation of a Visa debit card continuous payment authority, you must notify the retailer before the close of business on the business day before the day on which the transaction was due to take place and provide us with a copy of the notice if requested.

8.3. We may charge you an Administration Fee if a transaction is revoked by you under this paragraph (see chapter Fees and Limits).

9. Can I pay for things in a foreign currency?
9.1. Your card is denominated in Euro. If you make a purchase or an ATM withdrawal in any other currency we will convert the sum into pounds sterling using the exchange rate set by Visa on the day they process the transaction, this may differ from the actual date of the transaction.

9.2. A transaction fee will apply to each of these transactions (see chapter Fees and Limits). Any changes to the exchange rate used to convert foreign transactions will be made immediately. You can find the exchange rate for a transaction made in a currency other than euro on a given date at: https://www.visaeurope.com/making-payments/exchange-rates.

10. Is there anything I can’t buy with my Purecoin card?
10.1. You may not use your card for illegal purposes. It also cannot be used for a limited number of specified transactions. Please see our website for details.

11. How can I check my Purecoin account?
11.1. You can check your account by accessing it securely through the Apps. Your statement will show:

11.1.1 information on the payee of each transaction and a reference enabling you to identify each payment transaction;

11.1.2 the amount of the transaction shown in the currency in which the transaction was paid or debited to the account;

11.1.3 the amount of charges for the transaction;

11.1.4 the exchange rate used in the payment transaction (where applicable); and

11.1.5 the date the transaction is authorised or posted on to the account.

11.2. This information is accessible at all times via the Apps, is available free of charge, and can be stored and reproduced as necessary. Paper statements are available on request and are subject to a fee (see chapter Fees and Limits).

11.3. You may, in addition, be required to enter a one-time passcode or other security information including, if available and you opt for this type of identification, biometric information to access your account. One time passcodes will be sent to the mobile phone number registered to your account.

12. How long will the Purecoin card last?
12.1. Your card will be valid for 3 years. You will not be able to use your card after its expiry date. This agreement shall terminate when your card is cancelled or expires and is not replaced.

13. Does the Purecoin account and card have spending limits?
13.1. You can only spend the money that is paid into your account. Limits also apply to daily ATM withdrawals, and other limits may be applied to the amount of spend and the number of transactions you can perform. See chapter Fees and Limits and the Apps for further details.

13.2. If, for any reason, the transaction is completed when there are insufficient funds in your account then you will have to reimburse the shortfall to us, unless it is due to an error by the retailer with whom you made the transaction.

13.3. We may collect this shortfall from any card you have with us or from any funds which you subsequently pay into your account. We may suspend your cards until the negative balance is restored and charge you an Administration Fee (see chapter Fees and Limits) for transactions that you make using your card that results in a negative balance or increases the negative balance on your account.

14. What if I have been overcharged or charged for transactions I didn’t make?
14.1. If you dispute a transaction that has been processed on your card you should contact the merchant first as this may lead to the quickest resolution. If the dispute cannot be resolved with the merchant or you dispute any other account transaction you should contact us without undue delay and in any event within 13 months on becoming aware of any unauthorised or incorrectly executed payment transaction.

14.2. Where you have informed us that an executed payment was not authorised by you in accordance with these Terms and Conditions, and you have taken all reasonable steps to keep safe personalised security information, keep your card secure, not disclosed your PIN or security information to anyone else and not acted fraudulently, we will:

14.2.1. refund the amount of the unauthorised payment to you; and

14.2.2. restore the debited payment account to the state it would have been in had the unauthorised payment not taken place.

14.3. Beyond this, we will have no further liability to you. Where payee details provided by you are incorrect, we are not liable for non-execution or defective execution of the payment transaction, but we will make reasonable efforts to recover the funds involved in the payment transaction and notify you of the outcome.

14.4. You may be entitled to claim a refund in relation to transactions where:

14.4.1. the transaction was not authorised under these Terms and Conditions;

14.4.2. we are responsible for a transaction which we fail to execute or incorrectly execute. In these circumstances, we will refund to you the amount of the non-executed or defective payment transaction and restore the debited payment account to the state in which it would have been had the defective payment transaction not taken place. We will also refund to you: (a) any direct charges for which you are responsible; and (b) any interest which you must pay, as a consequence of the non-execution or defective execution of the payment transaction; or

14.4.3. a pre-authorised transaction did not specify the exact amount at the time of its authorisation and the amount charged is more than could reasonably be expected, taking into account previous spending patterns on the card and the circumstances of the transaction. We will either refund the full amount of the payment transaction; or provide justification for refusing to refund the payment transaction. Any refund or justification for refusing a refund will be provided within 10 business days of receiving a request for a refund or, where applicable, within 10 business days of receiving any further information requested. A claim for a refund in these circumstances will not be accepted if the amount of the transaction was made available to you at least 4 weeks before the transaction date or if the claim is made more than 8 weeks after being charged to your account.

15. What about security?
15.1 You must keep your card and security credentials safe and not let anyone else know or use them. You must keep your security information secret at all times; never disclose your PIN or security information to anyone and do not store details of your PIN with your card. Security information includes your login and password details used to access your account or any other website where your card or account details are stored. We also recommend that you check the balance on your account regularly through the Apps.

16. What if my Purecoin card is lost or stolen or my account details are compromised?
16.1. If you lose your card or it is stolen, or you suspect that someone else has found out your PIN or security information or accessed your account without your permission, you must tell us without undue delay by calling us or logging onto your account through Apps or website and notifying us. Your card will be cancelled immediately and your account may be blocked. We run a dedicated line for lost or stolen cards; the number is +44 (0)1756 693 275 and calls are charged at the standard geographical rate. If, after reporting a lost card, you subsequently find the card you must not use it. Cut it in half through the signature box, magnetic strip and chip.

16.2. If you ask us to do so, and provided that you provide information and assistance that we request from you, we will investigate any disputed transaction or misuse of your card or account.

16.3. If the investigations show that any disputed transaction was authorised by you, or you have acted fraudulently or with gross negligence (for example by failing to keep your card, security information or PIN secure or by failing to notify us without delay on becoming aware of the loss, theft, misappropriation or unauthorised use of the card or account), then we will not refund the transaction amount and you will be fully liable for all losses incurred because of the unauthorised use of the card or account.

16.4. If the investigations show that you have not acted fraudulently or with gross negligence, your maximum loss or liability to us for any unauthorised transaction will be limited to 50 euro and we will process a refund as soon as practicable, and in any event no later than the end of the business day following the day after we receive your notification.

17. Will a transaction be ever blocked without you asking?
17.1. We may refuse to pay a transaction:

17.1.1. if we are concerned about security of your card or account or we suspect your card or account is being used in an unauthorised or fraudulent manner;

17.1.2. if sufficient funds are not paid into your account at the time of a transaction to cover the amount of the transaction and any applicable fees;

17.1.3. if there is negative balance on your account;

17.1.4. if we have reasonable grounds to believe that you are not using the card or account in accordance with these Terms & Conditions;

17.1.5. if we believe that a transaction is potentially suspicious or illegal (for example, if we believe that a transaction is being made fraudulently); or

17.1.6. because of errors, failures (whether mechanical or otherwise) or refusal to process a transaction by merchants, payment processors or payment schemes such as Visa.

17.2. If we refuse a transaction, we will tell you why immediately, if we can, unless it would be unlawful for us to do so. You may correct any information we hold and which may have caused us to refuse a transaction by contacting Customer Services.

18. Can I cancel my Purecoin account and card?
18.1. You have a legal right to cancel your account and card up to 14 days from the date your account is opened without incurring any penalty and we will refund any card issue fees. We may charge you a Card Cancellation Fee if we have already incurred costs by ordering a card in your name. You can also cancel your card any time after the 14 day period subject to a Redemption Fee (see chapter Fees and Limits) by contacting Customer Services. You should also cut your cancelled card in half through the signature box, magnetic strip and chip.

18.2. All fees and charges will be apportioned up until the time of the termination of the contract, and any fees and charges paid in advance will be reimbursed proportionally. You will not be entitled to a refund of money you have already spent on transactions authorised, or pending or any fees for use of the card or account before the card or account is cancelled or expires.

19. Could my Purecoin account be cancelled?
19.1. We may cancel your account and this agreement by giving you at least two months’ notice.

19.2. Reasons for immediate cancellation may include:

19.2.1. if this agreement or your card expires;

19.2.2. if you break an important part of these Terms & Conditions, or repeatedly break these Terms & Conditions and fail to resolve the matter in a timely manner;

19.2.3. if you act in a manner that is threatening or abusive to our staff, or any of our representatives;

19.2.4. if you fail to pay fees or charges that you have incurred or fail to pay back any negative balance on your card; or

19.2.5. your card has not been used for 3 consecutive months.

19.3. We may also cancel your account immediately if we:

19.3.1. suspect unauthorised or fraudulent use of your card or account;

19.3.2. have any other security concerns; or

19.3.3. need to do so to comply with the law.

19.4. We may also deny access to your card and/ or account where we consider it to be at risk of money laundering or terrorism financing, fraud or other criminal activity. Should we need to take these actions and where possible, we will give reasons for doing so except where restricted by law.

19.5. In these circumstances, you must tell us what you want us to do with any unused funds. You must do this within 3 months of the date we tell you that your account is cancelled.

20. Can I get money back once I have put it into the account?
20.1. You can clear the balance on your account through spending or ATM withdrawals. The fees that would apply are described in chapter Fees and Limits.

20.2. Alternatively, you may request a refund of the funds on your account by contacting Customer Services and confirming that your card has been destroyed by cutting it up. We will transfer your funds back to you at no cost to you, unless:

20.2.1. you are requesting redemption before termination or expiry of this agreement;

20.2.2. you cancel this agreement before any agreed termination or expiry date; or

20.2.3. you request redemption more than one year after the date of termination or expiry of this agreement.

20.3. We will not redeem the value of the funds on your account to you if your request for redemption of the funds is more than six years after the date of termination or expiry of this agreement.

20.4. All funds will be returned to a bank account of your choice. We reserve the right to see proof of your ownership of the bank account before transferring funds to it. To enable us to comply with our legal obligations, we may ask you to provide us with certain information such as identification documents before we can process your refund request.

20.5. Please also refer to section 27 below for the circumstances in which we do not give you a refund.

21. Is money on my Purecoin account protected like my bank account?
21.1. The account and associated card is an electronic money product and although we are supervised by the Bank of Lithuania, it is not covered by the Deposit Insurance System of the Republic of Lithuania. No other compensation scheme exists to cover losses claimed in connection with the account and associated card. We will however ensure that any funds received by you are held in a segregated account so that should we become insolvent your funds will be protected against claims made by our creditors.

22. What if I have a complaint?
22.1. If you are unhappy in any way with your card and account or the way it is managed, you can contact Customer Services so we can investigate the circumstances for you. Any complaints you have will be dealt with quickly and fairly.

22.2. We will make every possible effort to address all points of complaint by email. We will respond within 15 business days upon receiving the complaint. If a full response cannot be provided within these timeframes, we will send a holding reply with a full response to follow within 35 business days.

22.3. If we are unable to resolve your complaint to your satisfaction and provided you are a consumer you may apply to the consumers disputes resolutions institution – the Bank of Lithuania, (https://www.lb.lt/en/dbc-settle-a-dispute-with-a-financial-service-provider) by filing out a free-form application and sending it to the Supervision Service, Žirmūnų g. 151, LT-09128 Vilnius, email: [email protected]

23. What if I change my details?
23.1. You must let us know as soon as possible if you change name, address, telephone number, mobile number or e-mail address. If we contact you in relation to your account we will use the most recent contact details you have provided to us. Any e-mail or SMS text message sent to you will be treated as being received as soon as it is sent by us. We will not be liable to you if your contact details have changed and you have not told us.

24. What will happen to my personal information?
24.1. We are the controller of your personal data which we will use in order to open, administer and run your account and provide payment services to you. You hereby consent to us accessing, processing, and retaining any information you provide to us, for the purposes of providing payment services to you or otherwise to fulfil this agreement. For further information about how we will process your personal data, please view our Privacy Policy. You may withdraw your consent to the processing of this data by closing your account.

25. Will these terms ever change?
25.1. We may change these Terms & Conditions by notifying you by e-mail or other agreed means at least two months before the change is due to happen. We will assume that you agree with the change. If you do not agree with the change you must tell us before the change happens and we will cancel your account immediately. If you cancel your account in this way then we will return any balance on the account to you and you will not be charged a Redemption Fee.

25.2. An up-to-date version of these Terms & Conditions, as well as any notices of future changes will always be available via our website, www.purecoin.app. You should check our website and the Apps regularly for such notices and changes.

26. When may the use of the Purecoin card and account be interrupted?
26.1. From time to time, your ability to use your card or account may be interrupted, e.g. when we carry out systems maintenance. If this happens, you may be unable (a) to use your card to pay for purchases or obtain cash from ATMs and/or (b) to obtain information about the funds available in your account and/or about your recent transactions.

26.2. In addition, like other payment cards, we cannot guarantee a merchant will accept your card, or that we will necessarily authorise any particular transaction. This may be because of a systems problem, something outside our reasonable control, to comply with legal and regulatory requirements, or because we have suspended, restricted or cancelled your account or refused to replace it in accordance with these Terms & Conditions.

27. What is our responsibility?
27.1. If we incorrectly deduct funds from your account, we will refund them. If we subsequently establish that the refunded amount had in fact been correctly deducted, we may deduct it from your available balance and may charge you a fee. If you do not have sufficient available balance, you must repay us the amount immediately on demand.

27.2. If unauthorised transactions occur after you have notified us of the loss, theft, compromise or unauthorised use of your card or account, and you have not acted fraudulently or in breach of these Terms and Conditions, then we will be liable.

27.3. We will not be liable:

27.3.1. in any event that a merchant refuses to accept your card;

27.3.2. for any interruption, disruption or impairment of our service or any third party services on which we rely for the performance of our obligations hereunder;

27.3.3. for refusing to authorise a transaction;

27.3.4. for cancelling or suspending use of your card or account;

27.3.5. for any loss arising from your inability to use your card or access your account due to interruptions;

27.3.6. or any direct or indirect loss or damage you may suffer including loss of revenue, loss of reputation, goodwill, opportunity or anticipated savings as a result of your total or partial use or inability to use your card, the Apps, website or account or the use of your card or account by any third party (unless otherwise required by law);

27.3.7. for the quality, safety, legality or any other aspect of any goods or services purchased with your card; and

27.3.8. any abnormal and unforeseeable circumstances beyond our control, however so caused.

27.4. For the SMS services we offer, we are not responsible for lost, late or undelivered text messages, notifications or communications. We accept no responsibility for any technical, computer, online, telephone, cable, electronic, software, hardware, transmission, connection, internet, website or other access issue which may hinder your ability to access the SMS services.

27.5. Nothing in these Terms and Conditions shall operate to exclude liability for death or personal injury due to negligence or for fraud or fraudulent misrepresentation or for any statutory liability that cannot be excluded or amended by agreement between the parties.

28. When can I be charged (other than the fees in chapter Fees and Limits)?
28.1. We may charge you for any reasonable costs that we incur in taking action to stop you using your card or account and to recover any monies owed as a result of your activities if you:

28.1.1. use your card or account fraudulently;

28.1.2. do not use your card or account in accordance with these Terms & Conditions; or

28.1.3. have been grossly negligent, for example by failing to keep your card or PIN secure or by failing to notify us without delay after your card is lost, stolen, or used by someone else or where your account has been compromised.

28.2. In these circumstances we will not refund transactions and we reserve the right to charge you for any reasonable costs that we incur in taking action to stop you from using your account and to recover any monies owed as a result of your activities.

28.3. If you have not been fraudulent, or grossly negligent, and have used your card and account in accordance with these Terms & Conditions, your maximum liability for any unauthorised transaction resulting from the use of a lost or stolen card or details before you notify us will be 50 euro.

28.4. We may also charge you an Administration Fee if we have to manually intervene to complete a payment or rectify an error on the account caused by an error or omission on your part.

29. Am I permitted to give access to third party providers?
29.1. You may allow regulated Third Party Providers (“TPPs”) (including Account Information Service Providers (“AISPs”) and Payment Initiation Service Providers (“PISPs”)) access to your online account; either to make payments, obtain account balances or obtain information on previous transactions.

29.2. Before giving consent to a TPP, you should:

29.2.1. ensure that the TPP is authorised and holds the correct regulatory permissions;

29.2.2. check what level of access you are consenting to, how your account will be used and the extent to which your data will be shared with third parties; and

29.2.3. familiarise yourself with your obligations and rights under the TPP agreement, in particular your right to withdraw consent to access your account.

29.3. We may refuse to allow a TPP access to your account where we are concerned about fraudulent or unauthorised access.

29.4. We are not party to, or responsible for, any agreements between you and a TPP. Subject to any rights to refund you may have under these Terms and Conditions, we shall have no liability for:

29.4.1. any loss whatsoever, as a result of using a TPP and entering into a TPP agreement; and

29.4.2. any actions that the TPP takes in relation to suspending or terminating your use of their service or for any resulting losses.

30. Can I assign my rights or obligations under these terms?
30.1. You may not transfer or assign any rights or obligations you may have under these Terms & Conditions to any other person without our prior written consent. We may assign the benefit and burden of these Terms & Conditions to any other person at any time on giving you two months prior notice of this. If we do this, your rights will not be affected.

31. What is the governing law?
31.1. This Agreement is concluded in English or Lithuanian. All communications with you will be in English or Lithuanian. These Terms & Conditions will be construed in accordance with laws of the Republic of Lithuania and subject to the exclusive jurisdiction of the courts of the Republic of Lithuanian.

32. What are the fees and limits?
32.1. All the information is available in chapter Fees and Limits and can be downloaded from this link.‍

Cash Management

These are the terms for using Cash Management – a cryptocurrency service, which allows you to earn interest on the supported cryptocurrencies held on your Account.

1. How Cash Management works?
1.1. In order to start using Cash Management you have to have opened and activated the Getchange account and debit card.

1.2. While using Cash Management you have to use the Conversion Service, whereby you buy the supported cryptocurrencies, which are shown to you in the Apps, i.e. stablecoins, e.g. USDC, from us, in exchange for specified Fiat currencies, and vice versa. You are entitled to at all times buy specified Fiat currencies from us, in exchange for the supported cryptocurrencies, however interest is exclusively and at all times calculated on the current outstanding balance of the supported cryptocurrencies.

1.3. After having bought the supported cryptocurrencies, with Cash Management your cryptocurrencies are deposited on your behalf to Crypto Interest Accounts operated by third-party custodians, e.g. BlockFi, Inc. or Payward, Inc.

1.4. Interest is calculated on an hourly basis on the current outstanding balance of the supported cryptocurrencies held on your Account, and rewarded by the first day of the following calendar month at 12:00 EET in the same supported cryptocurrency, and consecutively converted into specified Fiat currency.

1.5. All fees, including network fees for the aforementioned transfers, have already been deducted from the interest offered.

2. What are the risks?
2.1. Since Cash Management is in its entirety a cryptocurrency service, your supported cryptocurrencies are not subject to statutory or voluntary deposit guarantee schemes or deposit insurance.

2.2. By using Cash Management you acknowledge that various types of risks are involved, including but not limited to risks relating to the changes in the operating rules or other features, e.g. forks, and the fluctuation of the value of any supported cryptocurrencies, including the fiat currency it is pegged to, counterparty risks, including but not limited to the sustainability, insolvency, liquidation and bankruptcy of one of our partners and their partners, regulatory risks and uncertainties. Should any of the risks realise, you hereby understand and consent that you are solely liable for the consequences, and we shall not assume any liability nor obligations thereof.

2.3. By using Cash Management you understand and agree that rewarding you with the interest is in our sole discretion, not an obligation, and it is not a guarantee that you will receive the reward by the due date. We have reserved the right to from time to time change the interest rate, which is shown to you in the Apps, and These terms, and temporarily or permanently terminate or discontinue providing the service of Cash Management at any time, without giving you a prior notice thereof. If that is the case, we will buy back the supported cryptocurrencies from you, in exchange for specified Fiat currencies, and the interest calculation shall be terminated as of that moment, and the interest shall be rewarded by the first day of the following month.

2.4. In addition to agreeing to these terms, when using Cash Management you also consent and agree to abide by the terms of our partners. Please also pay extra attention to the risk disclosure sections. Relevant documents are available at https://blockfi.com/terms/?ref=7fd50399 and https://www.kraken.com/en-us/legal.

3. How is the security of the supported cryptocurrencies ensured?
3.1. Purecoin has performed and is constantly re-performing relevant due diligence on its partners and the financial, reputational and regulatory risks surrounding them. If it becomes known or Purecoin deems the counterparty risk, including any security risk to your supported cryptocurrencies, to be unacceptable, we will immediately terminate the partnership and/or the service, and inform you thereof in the Apps.

3.2. Your cryptocurrencies deposited on Crypto Interest Accounts are securely backed by third-party custodians Gemini Trust LLC (Gemini) or Circle Internet Financial, Inc. (Circle). Gemini is a New York trust company licensed by the New York State Department of Financial Services. Gemini is a fiduciary and subject to the capital reserve requirements, cybersecurity requirements, and banking compliance standards set forth by the NYSDFS and the New York Banking Law. Circle is a Boston, US based company registered as Money Services Business with FinCEN and has relevant money transmitter licenses.

3.3. Once the cryptocurrencies are transferred into a cold storage system, the offline storage can only be accessed in a secure, access-controlled facility that is protected from cyber attacks.

Complaints Handling Procedure

This procedure applies to CFD Trading service. You can access and download a copy of this document at any time from www.purecoin.app.

This is a specific procedure that will apply when you use CFD Trading Service i.e. trade CFDs directly with Indexa B.V. using Purecoin Apps and lodged a Complaint. In this procedure:

“Apps” mean the web, Android and iOS mobile apps of Purecoin, which give access to the Services;
Purecoin” means third party Purecoin OÜ, an Estonian public limited company registered under registry code 14428150, Rävala pst 4, 10143 Tallinn to whom Indexa B.V. relies on to comply with requirements included in the Dutch Wet ter voorkoming van witwassen en financieren van terrorisme and the Santiewet 1977, namely the application of due diligence measures, identification of politically exposed persons and customer data retention, but also customer support;
“Company” means Indexa B.V. (Chamber of Commerce no. 50755854, previously Optieclub.nl B.V.), De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands, who provides CFD Trading service on a cross-border basis and is authorised and regulated by the Dutch Authority for the Financial Markets (AFM);
“Complaint” means a statement or an expression of dissatisfaction addressed to the Company by a Complainant regarding the provision of investment and/or ancillary services provided by the Company to the Complainant;
“Complaint Form” means electronic document available on the Website that must be filled out by you to lodge a Complaint;
“Complainant” or “you” means the named natural person account holder, who has read, agreed with and accepted all the Terms and Conditions, being the authorised user of CFD Trading and owner of the Margin Account and Open CFD Positions, and has lodged a Complaint.
If you have any questions you can contact the Company by:

email: [email protected];
mobile application: log in to the App and send us a secure message;
post: Harju maakond, Tallinn, Kesklinna linnaosa, Roseni tn 13, 10111.
All of the terms and definitions not stipulated in this document are stipulated in the various chapters of the Terms and Conditions available on the Website.

1. Scope and purpose of the procedure
1.1. Under the law the Company is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of Complaints or grievances received from Complainants and keep records of each Complaint as well as any actions taken by the Company to remedy the situation in accordance with the provisions of the competent authorities.

1.2. This procedure sets out the method for the submission of Complaints with the Company from its clients and the processes followed by the Company when dealing with such Complaints.

1.3. The Company considers having a Complaint when the Complainant has filled out the relevant Complaint Form, available on the Website, and submitted it to the Company via the following methods:

1.3.1. by email at [email protected]; or

1.3.2. by post Harju maakond, Tallinn, Kesklinna linnaosa, Roseni tn 13, 10111.

1.4. In case the Company receives a notification through the line of communication established by the Company, but which does not fall within the definition of clause 1.3 and can be characterised not as Complaint, this shall be categorised as an enquiry and will be forwarded to the relevant contact within Company to be handled accordingly. The Complainant maintains the right to request for the reclassification of the enquiry as a Complaint.

2. Addressee of the Complaint
2.1. The customer support and if necessary, member of the compliance staff, shall efficiently handle any Complaint received by a Complainant. In the case that the Complaint is against the compliance staff, the Complaint shall be handled by a director of the Company.

3. Procedure to be followed for verbal Complaint
3.1. It is the Company’s policy not to accept any verbal complaints or grievances. Should any of the Company’s employees (regardless of department) receive a verbal Complaint or grievance, the procedure stipulated in the following clauses 3.2-3.3 must be followed.

3.2. The member of the staff receiving the verbal complaint or grievance shall take all the necessary actions so that the Complaint or grievance is properly addressed. The person will inform the Complainant that all the Complaints or grievances must be made in writing by completing the relevant Complaint Form as stipulated in clause 1.3. Once the Complainant completes and submits the Complaint Form the procedure for written Complaints shall be followed as described in section 4.

3.3. The member of the staff, in addition to the above, should make all best efforts to ensure that in the case of the Complaint or grievance being of such nature that can be resolved immediately, to do so that the Complainant will not have to fill out the Complaint Form. The member of staff in such a case shall not do the following:

3.3.1. commit on behalf of the Company in taking any action prior to examining the issues in a formal manner;

3.3.2. commit in any way to the Complainant;

3.3.3. address any issues in relation to best execution; nor

3.3.4. address any issues relating to legal, compliance or regulatory issues.

4. Procedure to be followed for written Complaint
4.1. If the complaint was received in the manner not fulfilling the conditions stipulated in section 1, i.e. the complaint was received through internal channels of communication such as chat, client correspondence, on other Company’s email addresses, or by any other Company’s member of the staff, then the complaint, in the form that has been received, must be forwarded, in the form it has been received to [email protected] within the same working day.

4.2. Once the Complainant submits a written complaint, customer support will send an electronic acknowledgment of receipt to the Complainant’s registered email address within five (5) working days following receipt, to verify that the Company has received the written Complaint and will request the Complainant to complete the relevant Complaint Form.

4.3. Upon completion and submission of the Complaint Form, customer support will investigate the grounds of the Complaint and if, based on the information provided, the grievance does not fall within the definition of Complaint or is not considered to be a Complaint it will be categorised as an enquiry and will be forwarded to the relevant member of the staff to be handled appropriately.

4.4. If the grievance falls within the definition of Complaint or is considered to be a Complaint, then the member of the staff will register the Complaint to an internal registry by giving it a unique reference number and by categorising it accordingly (e.g. technical, operational, compliance, legal) for the purpose of handling the Complaint most effectively.

4.5. In addition, within five (5) working days customer support shall inform the Complainant of the following:

4.5.1. that the Complainant must use the given reference number in all future correspondence with the Company regarding the submitted Complaint;

4.5.2. the process which is followed when handling a Complaint;

4.5.3. who is the member of the staff that is dealing with the Complaint and their contact details;

4.5.4. what is the indicative handling time (as a standard 20 working days); and

4.5.5. that the Complaint handling procedure is free of charge.

4.6. Moreover, the customer support must make sure that the following information is obtained from the Complainant, to the extent possible on the Complaint Form, and recorded:

4.6.1. full name and surname;

4.6.2. email address;

4.6.3. affected transactions (if applicable);

4.6.4. the date that the issue arose and a description of the issue;

4.6.5. the Service provided by the Company related to the Complaint;

4.6.6. member of the staff responsible for the provision of this Service (if applicable);

4.6.7. Complainant’s own description of the facts related to the Complaint, i.e. the content; and

4.6.8. reference of any correspondence exchanged between the Company and the Complainant (if applicable).

4.7. The Company will thoroughly examine and assess the facts and the information provided by the Complainant and the relevant members of the staff. Compare these facts with the information and data which have been retrieved from the Company’s archive (i.e. the Complainant’s transactions, trading history, correspondence, other electronic records). This investigation will also include the events preceding or leading to the Complaint.

4.8. The Company will not handle or investigate a Complaint if the Complainant does not complete the Complaint Form or does not provide the information requested in clause 4.6. of this procedure. In such an event the Company shall revert back to the Complainant and request to send any additional information. In any event, a member of senior management may contact the Complainant directly in order to obtain further clarifications and information relating to the Complaint. The Company shall need the Complainant’s cooperation in order to handle the Complaint.

4.9. The Company upon examining the complaint and reaching a decision to this respect shall inform the Complainant about the Company’s decision, in writing and in plain language which is clearly understood, together with the reasoning of the Company’s decision and any remedial measures it intends to take.

4.10. The Company shall make every effort to resolve the complaint within fifteen (15) working days. When deemed necessary, customer support or a member of the compliance staff shall convey the complaint to the senior management for further investigation. In this case, the Company might take additional five (5) working days to finalise the reply. The senior management shall investigate further and coordinate with relevant members of the staff to attend to the subject of the Complaint.

4.11. In the event that the Company cannot provide a response to the Complainant within the handling time given to the complainant, it will keep the Complainant informed about reasons of delay and indicate when the investigation is expected to be completed. This period of time cannot exceed two (2) months from the submission of the Complaint.

4.12. Once the Complaint is concluded and Company has reached final decision customer support will be responsible of keeping an full electronic record of the Complaint received, detailing the course of action which was taken, including what information, data and evidence were gathered, what measures were taken for the resolution, whether any conflicts of interest between the Company and its clients and between other clients were identified, what was the outcome and how that outcome was reached.

4.13. The Company shall maintain record of all complaints for a minimum period of five years after the closure of the Customer’s Margin Account.

5. Alternative ways to resolve a Complaint
5.1. If the Complainant is not fully satisfied with the Company’s final decision the case can be referred to the Dutch Financial Services Complaints Tribunal (Kifid) using Company’s relevant registration number 400.000422. The Kifid consists of the Financial Services Ombudsman and the Financial Services Disputes Committee.

5.2. Ultimately the Complainant may turn to the Dutch Authority for the Financial Markets (AFM) or to relevant courts.

6. Follow-up measures
6.1. Customer support will analyse, on an on-going basis, Complaints handling data, in order to identify and address the causes of the individual Complaints and/or any recurring or systematic problems and/or any potential legal and operational risks. Subsequently the relevant member of the staff or senior management should be informed and if necessary, take corrective action.

6.2. This Complaints Handling Procedure will be made available on the Website.

6.3. The Complaints Handling Procedure is available to all the members of the staff through email and an internal folder in the Company’s channels of communication which can be accessed at any time without any restrictions.

Complaint Form

This form is an electronic document that must be filled out by you to lodge a formal Complaint about CFD Trading service provided by Indexa B.V. This form is part of the formal Complaints Handling Procedure regarding the investment or ancillary services provided to you.

Please note that it is Company’s policy not to accept any verbal complaints or grievances.

If you have any questions please contact the Company by email [email protected] or through mobile application.

Fees and Limits

1. What are the limits of Services?

 

LIMIT VALUE COMMENT
Minimum single Fiat deposit €10.00 Purecoin shall not accept transfers that are lower than the specific value.
Minimum single Fiat deposit €10,000.00 Purecoin shall not accept transfers that are lower than the specific value.
Minimum single Instant deposit €10.00 Purecoin shall not accept Instant Deposits that are lower than the specific value./td>
Minimum single Instant deposit €1,000.00 Purecoin shall not accept Instant Deposits, that are higher than the specified value.
Monthly total Instant Deposits €2,000.00 Purecoin shall not accept Instant Deposits, that in total are higher than the specific value in a calendar month.
Minimum single Fiat withdrawal €5.00 Purecoin shall not process Fiat withdrawals that are lower than the specific value.
Monthly total withdrawals €15,000.00 Due to regulatory restrictions Purecoin can not process withdrawals, that in total are higher than the specific value in a calendar month, including Fiat and cryptocurrency withdrawals.
Maximum Fiat and cryptocurrency balance unlimited There is no limit on the total Fiat and cryptocurrency balances, although the monthly total withdrawal limit applies regardless.
Maximum Purecoin Account and Debit Card balance €8,000.00 Debit Card balance shall not be higher than the specific value at any given moment.
Minimum amount to buy cryptocurrencies in exchange for Fiat €5.00 You cannot buy cryptocurrencies in exchange for fiat for lower than the specific value, however the limit is not applicable for buying cryptocurrencies in exchange for other cryptocurrencies or for selling cryptocurrencies.
Maximum daily ATM withdrawals €250.00 Debit Card card shall not allow cash withdrawals, which in total are higher than the specific value per day.
Validity of Debit Card 36 months Debit Card card is valid for the specific number of months.

 

2. What are the conversion fees?

Conversion Rate is comprised of Rate Reference and the specified conversion fee.
No additional fees, slippage or extended spread apply.

CRYPTOCURRENCY VALUE COMMENT
Bitcoin (BTC) 0.00% Purecoin shall not charge any fee on buying or selling BTC for Fiat or when converting from or to USDT or DAI.
Augur (REP), Algorand (ALGO), Basic Attention Token (BAT), Bitcoin Cash (BCH), Cardano (ADA), Chainlink (LINK), Compound (COMP), Cosmos (ATOM), Dash (DASH), EOS (EOS), Ethereum (ETH), Litecoin (LTC), Polkadot (DOT), Stellar (XLM), Tezos (XTZ), XRP (XRP) 0.50% Purecoin shall charge a fee on buying or selling a specified cryptocurrency for Fiat or when converting from or to USDT or DAI that is not higher than the specific percentage.

Augur (REP), Algorand (ALGO), Basic Attention Token (BAT), Bitcoin (BTC), Bitcoin Cash (BCH), Cardano (ADA), Chainlink (LINK), Compound (COMP), Cosmos (ATOM), Dash (DASH), EOS (EOS), Ethereum (ETH), Litecoin (LTC), Polkadot (DOT), Stellar (XLM), Tezos (XTZ), XRP (XRP)/td>

1.00% Purecoin shall charge a specific percentage on converting to or from any specified cryptocurrencies that is not higher than the specific percentage.

3. What are the transfer fees?

TRANSACTION VALUE COMMENT
Fiat transfer 0% Purecoin shall not charge any percentage for transferring Fiat from a bank account to the Fiat Account.
Fiat withdrawal 0% Purecoin shall not charge any percentage for transferring Fiat to a bank account from the Fiat Account.
Instant Deposit

0%* / 2.50%

* As of 24.11.2020
until 31.12.2020

Purecoin shall charge a specific percentage for using the Service of Instant Deposit in order to add to and to dispose the Fiat on the Fiat Account instantly.
Cryptocurrency deposit 0% Purecoin shall not charge any percentage for transferring cryptocurrencies to the Wallet.
Cryptocurrency withdrawal Reasonable concurrently general network, gas or similar fee The Cryptocurrency withdrawal fee is displayed in the Apps before the confirmation and calculated in accordance with General and Wallet section 6.

4. What are the Debit Card fees?

TRANSACTION VALUE COMMENT
Ordering and shipping €4.95 One-off fee for Debit Card delivered within 10 business days to the registered address.
Debit Card replacement €4.95 Applies to replacing Debit Card that is lost, stolen, or damaged. Replacing expired Debit Card is for free.
Monthly maintenance €0.00 No monthly maintenance fee applies.
Euro purchases €0.00 No fee applies to purchases made in euros.
Non-euro purchases in Europe €0.50 plus 1% of the transaction value Any transaction in a foreign currency will be converted into euros at the rate of exchange provided by Visa Europe on the date they process the transaction which may differ from the actual transaction date. See more information on exchange rates on the Visa Europe website.
International purchases €0.50 plus 1.50% of the transaction value Any transaction in a foreign currency will be converted into euros at the rate of exchange provided by Visa Europe on the date they process the transaction which may differ from the actual transaction date. See more information on exchange rates on the Visa Europe website.
Euro ATM withdrawals €1.10
Non-euro ATM withdrawals in Europe €1.10 plus 1% of the transaction value Any transaction in a foreign currency will be converted into euros at the rate of exchange provided by Visa Europe on the date they process the transaction which may differ from the actual transaction date. See more information on exchange rates on the Visa Europe website.
Non-euro ATM withdrawals international €1.75 plus 1.5% of the transaction value Any transaction in a foreign currency will be converted into euros at the rate of exchange provided by Visa Europe on the date they process the transaction which may differ from the actual transaction date. See more information on exchange rates on the Visa Europe website.
ATM balance enquiry €0.00
Paper statements €2.00 Paper statements per 62 days can be requested by contacting Customer Support.
Online statements (per 62 days) €0.00 Online statements per at least 62 days can be downloaded from the Apps.
Redemption fee €0.00 The fee for transfer of funds during the account closure.

Bug Bounty

We are taking utmost care of users’ funds and data security. In order for the community to help us maintain the highest standard of security, we’ve created a Bug Bounty Programme. Under this Programme, we kindly ask our community members to help us find vulnerabilities and report them to us.

If a vulnerability is found, please report the vulnerability by sending us an email to [email protected], describing in detail the essence of the bug and an attack scenario. After having received the email one of our team members will assess the scope of the vulnerability and the report, and if appropriate will contact you whether you have been qualified to receive a reward and to which extent. The rewards will be paid in CAG tokens.

Rewards are paid out in the following ways based on the scope of the vulnerability:

High risk: up to 10 000 CAG
Medium risk: up to 5 000 CAG
Low risk: up to 1 000 CAG
Assessing the risk level of a vulnerability or a risk report, and assessing whether it is appropriate to pay out the reward and to which extent are in the full discretion of the Purecoin Team.

CNG Token and Token Swap

Token Swap Terms constitute a legally binding agreement between the SPV and each Tokenholder or holder of CNG Tokens. Accepting the Terms and/or acquiring CNG Tokens means that you have fully agreed to all the terms and conditions. In addition to the Terms, each Tokenholder or holder of CNG Tokens is obliged to comply with the technical rules associated with the relevant smart contract.

Token Swap Terms are available on this link.

If you have any questions regarding the Terms or such technical rules, please contact us at [email protected]

Privacy Policy

This Privacy Policy describes the general principles on how Purecoin and Indexa B.V. process your personal data and is applicable to any person who uses, has used or has expressed their intent to use the services of Change or Indexa. All of the definitions used in and all circumstances not covered by this Privacy Policy shall be regulated by the terms and conditions of Purecoin and Indexa and/or Regulation (EU) 2016/679.

The policy concerning the processing of cookies is described in Cookie Policy and is accessible on the Website.

Purecoin has appointed a data protection officer, who can be reached via [email protected] All of the inquiries and complaints concerning the processing of personal data should be addressed to said email address.

1. How is personal data collected?
1.1. Purecoin is to be considered a data controller in respect of personal data collected and processed in respect of providing Services to you.

1.2. In the case of CFD Trading Indexa is to be considered a data controller in respect of personal data collected and processed in respect of providing services to you, in which case Change is considered either a data processor or a data controller. If the purpose and means of processing of personal data has been jointly determined by Indexa and Change, the parties are considered joint controllers, e.g. in cases where the purpose of processing your data is to notify you of amendments in terms and conditions, including this Privacy Policy, or marketing under our legitimate interest.

1.3. In the case of Purecoin account and debit card UAB Finansinės paslaugos “Contis“ is to be considered a data controller, the terms stipulated in clause 1.2 respectively apply, and Change is considered either a data processor, data controller or a joint controller, provided the purpose and means of processing of personal data has been jointly determined by the parties. More information about the processing of personal data in respect of providing payment services to you can be found from this link.

1.4. In the context of this Privacy Policy references to “we”, “us”, “our” means Purecoin, including all of its affiliates, and Indexa, provided the parties are separate data controllers or joint controllers.

1.5. Generally personal data is collected directly from you, and from the information and documents you have provided. However, in order to comply with the legal obligations personal data, e.g. identification, identity document and financial data, is also collected from other sources, e.g. from third parties and public sources.

2. Which categories of personal data we are processing?
2.1. We are processing the following categories of personal data:

2.1.1. identification data, e.g. your photo, name, date and place of birth, address;

2.1.2. identity document data, e.g. photo of the document, number and validity;

2.1.3. contact data, e.g. phone number, email address;

2.1.4. financial data, e.g. ownership and source of funds and/or wealth;

2.1.5. transaction data and the nature of using the service, e.g. transaction sums, counter-parties, bank account and card number(s) and account holders;

2.1.6. other data used for performing customer due diligence measures, assessing trustworthiness and to prevent fraud, e.g. media coverage, occupation and connection to other persons, and device information and location; and

2.1.7. correspondence between you and us.

3. For which purposes personal data is processed?
3.1. In general we are processing your personal data for the performance of or entering into a contract with you, i.e. personal data is processed for the purposes of providing the services. Without processing personal data, we would be unable to provide services to you, including due to regulatory restrictions.

3.2. The purposes for which we are processing personal data are the following:

3.2.1. fulfilling a contractual obligation, e.g. executing your transaction orders and ensuring the safety of your assets;

3.2.2. fulfilling a legal obligation, e.g. ensuring the security of accessing the Account and the transactions and using the data for accounting and reporting purposes;

3.2.3. public interest, e.g. by performing necessary acts in order to prevent money laundering and the financing of terrorism and thus to ensure the proper identity verification;

3.2.4. sending informative and promotional notifications, or collecting, processing storing and disclosing personal information, e.g. name and contact information, with our partners in order to conduct campaigns and ship the rewards, under a revocable consent received from you; and

3.2.5. our legitimate interest to prevent fraud and to improve our products and services, as well as to promote the launch and usage of new functionalities and features and to illustrate the benefits and possibilities of cryptocurrencies and investing, e.g. by identifying concurrently used app versions and by sending promotional content regarding new features and products, and to conduct campaigns, including in co-operation with third-parties, and ship the rewards.

3.3. For entering into and for the performance of the contractual agreement between you and us and for public interests, Purecoin is applying certain automated decision-making methods to assess your capability, suitability, behaviour and reputation, whether to enter into or to continue a contractual relationship. The aforesaid assessment is accompanied by human-intervention by an employee of Purecoin, who will perform the final assessment.

3.4. For entering into and for the performance of a legal obligation Indexa is obliged to assess your capability, suitability, behaviour, reputation and financial situation, whether to enter into or to continue a contractual relationship with you, in which case the personal data is processed by Purecoin as a data processor on behalf of Indexa.

4. Which persons have access to the personal data?
4.1. Your personal data is being processed by the following categories of data recipients:

4.1.1. our employees responsible for specific tasks regarding the Services;

4.1.2. data processors who help us with providing the services, e.g. service providers for the maintenance of our IT-systems and for fulfilling our legal obligations;

4.1.3. third parties to whom we are required to transfer data under applicable legislation, e.g. relevant state institutions and sector-specific authorities.

4.1.4. third parties who help us in developing and promoting the services.

4.2. Purecoin has engaged a third-party service provider, Onfido Ltd, a company located and registered in the United Kingdom, for obtaining certain information required in relation to the fulfilment of its obligations under anti-money laundering and terrorist financing prevention rules. While providing services to Purecoin, Onfido Ltd processes your personal data as a data processor, however, for enhancing its machine learning capabilities Onfido Ltd is also processing your personal data as a data controller. To acquaint yourself with the relevant data processing activities which Onfido Ltd undertakes as a data controller we advise your to read and review the privacy policy located on https://onfido.com/privacy. You should be aware that Purecoin takes no responsibility in relation to processing activities Onfido Ltd undertakes as a data controller and you are free to exercise their rights as data subjects in relation to Onfido Ltd fully and independently.

4.3. We are not responsible for the actions and processing activities of any third parties. Third parties are considered to be separate data controllers, whose services can be procured by concluding separate agreements with them. Third parties may transfer your personal data to Third Countries and process it for independent purposes.

4.4. Although generally the personal data is processed within the European Economic Area, certain activities may result in the transferring of personal data to Third Countries, meaning countries located outside the EU/EEA, and to countries in relation to which the EU Commission has not issued an adequacy decision, e.g. the US. For ensuring that your personal data is protected, we have committed to applying appropriate safeguards, including but not limited to assessing the security and due diligence measures and regulatory compliance of these persons, concluding relevant data processing agreements and standard data protection clauses adopted by the European Commission for the transfers. In case you wish to know more about the safeguards and obtain a relevant copy of them, please contact us using the details specified above.

4.5. We shall maintain the confidentiality of all information of which we become aware on the basis of the relationship with you, including information concerning you and the Payment Account and Payment Transactions thereof, unless the right or obligation to disclose information arises from legislation.

4.6. We shall be released from the obligation to maintain confidentiality to the extent that you have granted consent to the disclosure of information in writing or in the Apps or our Website or to the extent a disclosure of confidential information is allowed or required under applicable laws and/or mandatory orders by regulatory authorities.

5. How long is personal data stored?
5.1. Your personal data is generally retained as long as you are using the Services. After you have stopped using the Services and your Account has been closed, your personal data shall be retained as long as any claims can be presented on the basis of such data under applicable legislation.

5.2. Certain data, e.g. data obtained for the purposes of the fulfilment of obligations related to anti-money laundering and terrorist financing prevention, or data necessary for accounting purposes, shall be retained as required under applicable legislation and industry standards. Generally, respectively at least for 5 or 7 years since the date of closing the Account, but not longer than 10 years.

5.3. We shall immediately terminate processing the data that is processed under your consent, if the consent is revoked, and the processing of personal data under legitimate interest, if you have declared objection to such processing.

6. What are your rights regarding data processing?
6.1. You, as a data subject, are, at any time, entitled to exercise the following rights:

6.1.1. The right to request the correction of your personal data;

6.1.2. The right to request access to your personal data;

6.1.3. The right to request the erasure of your personal data;

6.1.4. The right to withdraw the consent on which the processing is based;

6.1.5. The right to request the restriction of processing your personal data;

6.1.6. The right to object to the processing of your personal data;

6.1.7. The right to exercise data portability in cases where such data has been provided by you for the performance of or entering into a contractual relationship by accepting the Terms or under the consent; and

6.1.8. The right to lodge a complaint respectively to Estonian Data Protection Inspectorate at www.aki.ee or Dutch Data Protection Authority at https://autoriteitpersoonsgegevens.nl/en.

This Cookie Policy describes the use of cookies on our Website. By using our Website, you agree to the usage of cookies. All of the terms not covered in this Cookie Policy are described elsewhere in the terms of Purecoin accessible on our Website.

Purecoin has appointed a data protection officer, who can be reached via [email protected] All of the inquiries and complaints concerning the processing of personal data should be addressed to said email address.

1. What are cookies?
1.1. Cookies are small text files that are stored on your computer or mobile device when visiting a website. Cookies allow our Website to distinguish you from other users and, thus providing you a better user-experience. Cookies facilitate Purecoin in improving our Website.

2. Which cookies are used by Purecoin?
2.1. Purecoin uses session cookies for the duration of visiting our Website.

3. What are the purposes of using cookies?
3.1. Using essential cookies is required for the operation of our Website. The purposes of using such cookies include enabling you to log into the secure areas of our Website and to enter into transactions and assisting you should you request assistance from us.

3.2. Analytical/performance cookies allow us to count the number of visitors and identify their aggregate locations and their habits in using our Website. This helps us to improve the structure of our Website, e.g. by ensuring that visitors are finding what they are looking for easily. We use Google Analytics cookies that collects anonymous information by reporting website trends without identifying individual visitors. You can opt out of Google Analytics without affecting the experience on our Website by clicking this link.

3.3. Targeting cookies record your visit on 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.

4. What about third parties?
4.1. Third parties, e.g. advertising networks and providers of external services like web traffic analysis services, may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

5. How to reject using cookies?
5.1. You can block the usage of cookies by changing the security settings of your browser by disabling the cookies in whole or in part. However, if you choose to block cookies, including essential cookies, you may not be able to access all or parts of our Website.

General Risk Disclosure

This document applies to all Services provided via Purecoin Apps. You can access and download a copy of this document at any time from www.purecoin.app.

This notice provides you with information about the risks associated with cryptoasset services provided by Purecoin and investment services provided by Indexa. In this document:

“Apps” mean the web, Android and iOS mobile apps of Change, which give access to the Services;
“Purecoin” means Purecoin OÜ, an Estonian public limited company registered under registry code14929082Harju maakond, Tallinn which provides cryptoasset services under virtual currency exchange license no FVR000034 and wallet service provider license no FRK000026 issued by Estonian FIU, and to whom Indexa B.V. relies on to comply with requirements included in the Dutch Wet ter voorkoming van witwassen en financieren van terrorisme and the Santiewet 1977, namely the application of due diligence measures, identification of politically exposed persons and customer data retention, but also customer support;
“Indexa” means Indexa B.V. (Chamber of Commerce no. 50755854, previously Optieclub.nl B.V.), De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands, who provides CFD Trading service on a cross-border basis and is authorised and regulated by the Dutch Authority for the Financial Markets (AFM);
“We”, “us” or “our” means Purecoin and/or Indexa depending on the specific context.
If you have any questions you can contact the Company by:

email: [email protected];
mobile application: log in to the App and send us a secure message.
All of the terms and definitions not stipulated in this document are stipulated in the various chapters of the Terms and Conditions available on the Website.

You gain ownership of the underlying asset when using the Conversion Service offered by Purecoin. In addition, Indexa offers contracts for difference (CFDs) that provide exposure to cryptoassets, stocks, ETFs and indices.

Any transactions relating to cryptoassets, stocks, ETFs and indices where leverage is offered or which allow you to enter into short-selling transactions shall be considered CFD Trading provided by Indexa.

Since cryptoasset markets are decentralized and not regulated to the degree of investment services then customers using the services provided by Purecoin will not fully benefit from the protections available to clients receiving regulated investment services such as the access to the Dutch investor compensation scheme (ICS) operated by the Dutch central bank and the Dutch Financial Services Complaints Tribunal (Kifid) for dispute resolution. Customers of Indexa will continue to benefit from the rules relating to best execution and client money and safekeeping of client assets.

All these products carry a high degree of risk and are not suitable for many investors. This notice provides you with information about the risks associated with these products but it cannot explain all of the risks nor how such risks relate to your personal circumstances. If you are in doubt you should seek professional advice. It is important that you fully understand the risks involved before deciding to use the Services and that you have adequate financial resources to bear such risks and that you monitor your positions carefully. Trading involves risk to your capital. You should not invest money that you cannot afford to lose, however you cannot lose more than the equity in your account.

Risks associated with CFDs
CFD stands for “Contract For Difference”, meaning you are not buying the underlying asset, but rather purchasing a contract to settle the difference in the initial and ending price of the asset. When trading CFDs, you generally trade on margin, which means you only have to deposit a small percentage of the overall value of your position. This is known as “leverage”, and even small market movements may have great impact, negative or positive on your trading account.

If the market moves against you, you may sustain a total loss greater than the funds invested in a specific position. You are responsible for all losses on your account up to the equity in your account.

Before deciding to trade on margin you should carefully consider your investment objectives, level of experience, and risk appetite. Indexa’s CFDs are not listed on any exchange. CFDs involve greater risk than investing in on-exchange products, as market liquidity cannot be guaranteed and it may be more difficult to liquidate an existing position. The prices and other conditions are set by us in accordance with our obligation to provide best execution as set out in our order execution policy, to act reasonably and in accordance with the applicable Terms and Conditions. The characteristics of our CFDs can vary substantially from the actual underlying market or instrument. Full details of all of our CFDs are set out on our website. In respect of corporate events with respect to the underlying assets, We do not aim to make a profit from our clients from the outcome of corporate events such as rights issues, takeovers, mergers, share distributions or consolidations and open offers. We aim to reflect the treatment we receive, or, would receive if we were hedging our exposure to you in the underlying market. Ultimately however, you are not dealing in the underlying market and therefore in relation to our CFDs the treatment you receive may be less advantageous than if you owned the underlying instrument.

CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. Between 74-89% of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work, and whether you can afford to take the high risk of losing your money.

CFDs are not suited to the long term investor. If you hold a CFD open over a long period of time the associated costs increase (such as overnight fees), and it may be more beneficial to buy the underlying asset instead. Sudden market movements, known as “gapping” may occur, causing a dramatic shift in the price of an underlying asset. Gapping may occur when the underlying market is closed, meaning the price on the underlying market may open at a significantly different level, and at a less advantageous price for you.

At all times during which you have open positions, you must ensure that your account meets margin requirements, which may change from time to time. Therefore, if the price moves against you or if margin requirements have changed, you may need to provide a significant amount of additional funds to meet your margin requirement, at short notice, to maintain your open positions. If you do not do this, Indexa will be entitled to close one or more or all of your positions and you alone will be responsible for any losses incurred as a result.

Before we open a Margin 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 a Margin Account with us, you are confirming that you are aware of and understand the risks.

You should further ensure you are able to monitor positions on your account at all times, as you are solely responsible for this. We are not responsible for monitoring positions on your account.

Although the CFD trading 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 favour or against you.

To limit losses, we require you to choose or set ourselves “stop-loss” limits. These set limits to automatically close your position when it reaches a price limit of your choice. There are however circumstances in which a “stop-loss” limit is not fully effective – for example, where there are rapid price movements, or market closure.

In addition, there are risks associated with use of online deal execution and trading systems including, but not limited to, software and hardware failure and internet disconnection.

Risks associated with cryptoasset
Since cryptoasset markets are decentralized and not regulated to the degree of investment services then customers using the services provided by Purecoin will not fully benefit from the protections available to clients receiving regulated investment services under the so-called MiFID regime. This also means that there is no central bank that can take corrective measure to protect the value of cryptoasset in a crisis or issue more currency.

Cryptoasset market is determined only by supply and demand and is often highly unpredictable and volatile. The price of a cryptoasset is usually not transparent and highly speculative and susceptible to market manipulation. In the worst case scenario the product could be rendered worthless.

It is important to make a distinction between indicative prices which are displayed on charts and dealable prices which are displayed in the Apps. Indicative quotes only give an indication of where the market is. Because the cryptoasset markets are decentralized, meaning it lacks a single central exchange where all transactions are conducted, each market maker may quote slightly different prices. Therefore, any prices displayed on any chart made available by us or by a third party will only reflect indicative prices and not necessarily actual dealing prices where trades can be executed.

Cryptoasset trading is prone to being misused for illegal activities due to the pseudonymity or even anonymity of transactions and investors would be adversely affected if law enforcement agencies investigate any alleged illicit activities.

Accordingly, cryptoassets should be seen as an asset class with extremely high risks and you should never invest money that you cannot afford to lose. Given the foregoing, cryptoasset are not appropriate for all investors. You should not deal in these products unless you have the necessary knowledge and expertise, you understand these products’ characteristics and your exposure to risk. You should also be satisfied that the product is suitable for you in light of your circumstances and financial position. In addition, use of our Services can never be considered a safe investment rather only an investment with a high risk of loss inherently associated with it. Furthermore, our own fee is added to online quotes, if applicable, which makes trading with the Apps even more volatile.

The risk of loss in trading cryptoasset can be substantial. You should, therefore, carefully consider whether such trading is suitable for you in light of your circumstances and financial resources. You should be aware that you may sustain a total loss of the money deposited.

Since blockchain is an independent public or private peer-to peer network and is not controlled in any way or manner by us, we 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 cryptoasset 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.

 Purecoin does not own or control the underlying software protocols which govern the operation of cryptoasset available for trading in the Apps. In general, the underlying protocols are open source and anyone can use, copy, modify, and distribute them. Purecoin is not responsible for operation of the underlying protocols and makes no guarantee of their functionality, security, or availability. The underlying protocols are subject to sudden changes in operating rules (so-called forks), and such events may materially affect the value, function, and/or even the name of the cryptoasset Purecoin holds on your behalf. In the event of a fork, we may temporarily suspend operations (with or without advance notice to you) and that Purecoin may (a) configure or reconfigure its systems or (b) decide not to support (or cease supporting) the forked protocol entirely. Purecoin may, but is not obligated to do so, adjust your account in respect of a fork depending on the circumstances of each event attributable to any specific cryptoasset held by you.

We may elect to execute any order and/or hold any fiat money and cryptoasset via third parties. Such third parties are not banks that guarantee the deposits made to them. 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 or cryptoassets you may have held with such third party, even when such party is registered with a competent authority. Depending on the structure and security of the digital wallet, some may be vulnerable to hacks, resulting in the theft or loss of customer assets. Purecoin will not be responsible in the event of losses caused by those third parties.

If at any time any of the cryptoasset that forms the subject of your order is delisted and/or we no longer support the trading in such cryptoasset for any reason, then the applicable order will be immediately closed. If Purecoin is notified that a cryptoasset you hold is likely to be delisted and/or removed and/or canceled from any of the exchanges (some of them or all) and we believes that it shall not be able to trade in such cryptoasset, we shall make an effort to sell the cryptoasset on your behalf at such time and price, and in such manner, as it determines.

General risks
While trading using the Apps, 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 a mobile-based trading system over the internet 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 (including your cryptoasset) stored on your behalf, cyber-attack, the cryptoasset 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 attack. 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 us.

Our fees and charges are set out on the Website and in the Apps. Please be aware of all costs and charges that apply to you, because such costs and charges will affect your profitability.

Any opinions, news, research, analyses, prices, or other information contained on the Website or in the Apps are provided as general market commentary, and do not constitute investment advice. We shall not be responsible for any loss arising from any investment based on any recommendation, forecast or other information provided.

Past performance is not an indication of future performance. The value of investments can go down as well as up.

All balances related to your Account with us are held in euros which may be different from the currency you used to deposit, accordingly you should be aware of currency fluctuations.

© 2021 by Purecoin OÜ. All rights reserved.

Purecoin OÜ is incorporated in Tallinn, Estonia (company number 14929082) with its registered office at Harju maakond, Tallinn, Kesklinna linnaosa, Roseni tn 13, 10111.
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