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INTRODUCTION GREEK COIN OÜ P.L.C (the “Company”), is a company incorporated under the Estonian Commercial Code, with registration number 14787392 and authorized by the Estonian Financial Supervisory Authority to operate as a Private Limited Company which offers Financial Services, and that includes: a) Providing a virtual currency wallet service (Activity License FRK001080) and b) Providing services of exchanging a virtual currency against a fiat currency (Activity license FVR001195).

LEGAL FRAMEWORK

The Company understands that as a Virtual Currency (VC) service provider, is treated equally to a financial Institution, which is operating under the following legal basis: Estonian Law Money Laundering and Terrorist Financing Prevention Act issued by Riigikogu (the unicameral parliament of Estonia) which entered into force on the 10th of March 2020 (hereinafter ‘The Act’), with their office, Management and AML officer situating in Estonia, namely, Harju Maakond, Tallinn, Kesklinna linaosa, Roseni tn 13, Personal Data Protection Act issued by Riigikogu which entered into force in 15th of January 2019. Identity Documents Act which entered into force by Riigikogu in the 1st of January 2000 and as amended until the 15th of September 2013. Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC. Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments (MiFID II) and amending Directive 2002/92/EC and Directive 2011/61/EU Text with EEA relevance. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). The Company recognizes that a strong AML & CTF manual is essential for the apt operation of the Company and its protection from being used to launder money or to finance terrorism. Thus, the Company has adopted a series of principles and procedures against money laundering and terrorism financing based on specific risk profile of its activities, and geographic location. This is a short version of the company’s AML/CFT and Risk Assessment manual explaining the procedures and the bases on which personal information are collected and used.

COLLECTION OF INFORMATION

The Company needs to comply with global regulatory standards including Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Know-Your-Customer (KYC) requirements. These regulatory standards require formal identification and thus we collect such a wide range of information to fulfil the binding legal provisions regarding the obligation to identify the client, to monitor the transactions, combat and assess the risks of fraud, money laundering and financing of terrorism. Therefore, it is crucial for our clients to provide the data requested during the registration and verification procedure. The obligation for such an identification and verification does not allow the Company to proceed with the establishment of a business relationship if the data proves to be false, or if you object to its processing. In order to verify the accuracy of the data provided by you and to assess the risk of fraud, we also monitor your transaction history by analyzing the course, volume, currency and type of transactions. The Company has either a regulatory obligation to collect those types of data or the legitimate interest of having them in order to provide the Services or a contractual agreement between you and the company. The Company processes the required personal data based on your consent and any further information you provide to us without the need to do so, the Company deems that you provide such data voluntarily, but will be deleted if deemed not useful for the operation of the company’s business. The Company keeps all the information strictly confidential and uses it only for the purposes of compliance with the Law and the execution of internal and communication procedures. For any other use, the Client is informed prior to the retrieval of any information. Find more in the Privacy Policy of the Website.

As part of the compliance to the relevant Act and Regulations, the Client may be asked to provide us with the following personal data: name date of birth address and country of residence nationality phone number information concerning the identity document (passport or identity card) photo bank account number Personal (national) Identification Number e-mail address Bitcoin Address or other cryptocurrencies addresses Further data necessary for the identification of the new Client or the identification of the source of wealth, for verification and AML compliance purposes. other data such as – request URL, domain name, device ID, browser type, browser language, number of clicks, amount of time spent on individual pages, date and time stamp of using the Website, type and version of the operating system, screen resolution, data collected in the server logs, and other similar information to develop statistical data for the optimization of services rendered, including displaying content that complies with your preferences.

DEFINITIONS

The following definitions of this Policy derive from and must be read according to the definitions of the Estonian Law (Money Laundering and Terrorist Financing Prevention Act issued by Riigikogu (the unicameral parliament of Estonia) which entered into force on the 10th of March 2020) (hereinafter ‘The Act’), with their office, Management and AML officer situating in Estonia, namely, Harju Maakond, Tallinn, Kesklinna linaosa, Roseni tn 13, Any word or phrase not defined in this section shall be interpreted according to the Definitions of the Estonian Law and according to that meaning and reading. Where the Definitions refer to an Act or Regulation, they refer to the relevant Act of the Estonian Law.

‘Beneficial owner’

(1) For the purposes of this Act, ‘beneficial owner’ means a natural person who, taking advantage of their influence, makes a transaction, act, action, operation or step or otherwise exercises control over a transaction, act, action, operation or step or over another person and in whose interests or favour or on whose account a transaction or act, action, operation or step is made.

(2) In the case of companies, a beneficial owner is the natural person who ultimately owns or controls a legal person through direct or indirect ownership of a sufficient percentage of the shares or voting rights or ownership interest in that person, including through bearer shareholdings, or through control via other means.

(3) Direct ownership is a manner of exercising control whereby a natural person holds a shareholding of 25 per cent plus one share or an ownership interest of more than 25 per cent in a company. Indirect ownership is a manner of exercising control whereby a company which is under the control of a natural person holds or multiple companies which are under the control of the same natural person hold a shareholding of 25 per cent plus one share or an ownership interest of more than 25 per cent in a company.

(4) Where, after all possible means of identification have been exhausted, the person specified in subsection 2 of this section cannot be identified and there is no doubt that such person exists or where there are doubts as to whether the identified person is a beneficial owner, the natural person who holds the position of a senior managing official is deemed as a beneficial owner.

(5) The obliged entity registers and keeps records of all actions taken in order to identify the beneficial owner under subsections 2 and 4 of this section.

(6) In the case of a trust, civil law partnership, community or legal arrangement, the beneficial owner is the natural person who ultimately controls the association via direct or indirect ownership or otherwise and is such associations’: a. settlor or person who has handed over property to the asset pool; b. trustee or manager or possessor of the property; c. person ensuring and controlling the preservation of property, where such person has been appointed, or the beneficiary, or where the beneficiary or beneficiaries have yet to be determined, the class of persons in whose main interest such association is set up or operates.

(7) In the case of a person or an association of persons not specified in subsections 2 and 6 of this section, a member or members of the management board may be designated as a beneficial owner.

(8) ‘Control via other means’ means the exercising of dominant influence in accordance with the criteria set out in subsection 1 of § 27 of the Accounting Act.

(9) This section does not apply to a company listed on a regulated market that is subject to disclosure requirements consistent with European Union law or subject to equivalent international standards which ensure adequate transparency of ownership information.

4.1 ‘Business relationship’ means a relationship that is established upon conclusion of a long-term contract by an obliged entity in economic or professional activities for the purpose of provision of a service or sale of goods or distribution thereof in another manner or that is not based on a long-term contract, but whereby a certain duration could be reasonably expected at the time of establishment of the contact and during which the obliged entity repeatedly makes separate transactions in the course of economic or professional activities while providing a service or professional service, performing professional acts or offering goods.

4.2 ‘Customer or Client’ means a person who has a business relationship with the Company.

4.3 ‘Criminal activity’ means any kind of criminal involvement in the commission of the following crimes:

4.3.1 terrorist offences, offences related to a terrorist group and offences related to terrorist activities as set out in Titles II and III of Directive (EU) 2017/541; 4.3.2 any of the offences referred in Article 3(1)(a) of the 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances;

4.3.3 the activities of criminal organizations as defined in Article 1 of Council Framework Decision 2008/841/JHA; 4.3.4 fraud affecting the Union's financial interests, where it is at least serious, as defined in Article 1(1) and Article 2(1) of DIRECTIVE (EU) 2017/1371 on the fight against fraud to the Union's financial interests by means of criminal law;

4.3.5 corruption (“the abuse of power for private gain. Corruption takes many forms, such as bribery, trading in influence, abuse of functions, but can also hide behind nepotism, conflicts of interest, or revolving doors between the public and the private sectors.”);

4.3.6 all offences, including tax crimes relating to direct taxes and indirect taxes and as defined in the national law of the EU Member States, which are punishable by deprivation of liberty or a detention order for a maximum of more than one year or, as regards EU Member States that have a minimum threshold for offences in their legal system, all offences punishable by deprivation of liberty or a detention order for a minimum of more than six months.

4.4 ‘Custodian wallet provider’ means an entity that provides services to safeguard private cryptographic keys on behalf of its customers, to hold, store and transfer virtual currencies.

4.5 ‘High-risk Third Country’ means a country specified in a delegated act adopted on the basis of Article 9(2) of Directive (EU) 2015/849 of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (OJ L 141/73, 05.06.2015, pp 73–117).

4.6 ‘Joint Guidelines’ means the guidelines on the risk factors issued by the European Securities and Markets Authority, the European Insurance and Occupational Pensions Authority and the European Banking Authority under Articles 17 and 18(4) of Directive (EU) 2015/849 on simplified and enhanced customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions, as amended.

4.7 ‘Politically exposed person’ means a natural person who is or who has been entrusted with prominent public functions and includes the following: (a) heads of State, heads of government, ministers and deputy or assistant ministers; (b) members of parliament or of similar legislative bodies; (c) members of the governing bodies of political parties; (d) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances; (e) members of courts of auditors or of the boards of central banks; (f) ambassadors, chargés d'affaires and high-ranking officers in the armed forces; (g) members of the administrative, management or supervisory bodies of State-owned enterprises; (h) directors, deputy directors and members of the board or equivalent function of an international organization. No public function referred to in points (a) to (h) shall be understood as covering middle-ranking or more junior officials.

4.8 ‘Persons known to be close associates’ means: (a) natural persons who are known to have joint beneficial ownership of legal entities or legal arrangements, or any other close business relations, with a politically exposed person; (b) natural persons who have sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a politically exposed person.

4.9 ‘Senior management of obliged entity’ means an officer or employee with sufficient knowledge of the institution's money laundering and terrorist financing risk exposure and sufficient seniority to take decisions affecting its risk exposure, and need not, in all cases, be a member of the management of the Company.

4.10 ‘Virtual currencies’ means a value represented in the digital form, which is digitally transferable, preservable or tradable and which natural persons or legal persons accept as a payment instrument, but that is not the legal tender of any country or funds for the purposes of Article 4(25) of Directive (EU) 2015/2366 of the European Parliament and of the Council on payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/3