This policy is part of our general terms and conditions, concerning the prevention against identity theft, financing of terrorism, organized crime, asset laundering and money laundering enforced in the countries of operation of our platform, so that both guarantee the deconfiguration of illegal activities and the obtention of funds through illegitimate means.

Our users can be sure that, from our experience, the standards required by international regulations in this regard are met, so that security and compliance with the law prevail in our transactions, therefore our accessibility requirements are simple but rigorous, preserving the necessary regulatory compliance to guarantee efficient security in said operations. Users are responsible for abiding by the applicable laws in relation to the legal use of the Platform in their local jurisdiction, as well as being in compliance with other laws and regulations applicable to them by connection. 

These policies and any terms incorporated herein apply to THE USER, whether he is a natural person or legal entity, the use of the Services, including those offered at https://ccoins.io, the technology and any platform integrated into it. As well as any related applications associated with it, which are operated and maintained by Ccoins or a third party, are subject to such conditions. For Colombia, the procedures for the prevention and risk control of Money Laundering and Terrorist Financing are contained in our complete and updated SARLAFT Manual (Sistema de Administración del Riesgo de Lavado de Activos y Financiación del Terrorismo).

COMPLIANCE AND REPRESENTATIONS

This policy constitutes a binding and comprehensive agreement between Ccoins and the user, therefore, as soon as the user visits the website and uses the services, he confirms that he has read and accepted these Terms of Use and the policies present in full, before completing the registration procedure.

The user accepts that the current Terms may be updated by Ccoins at any time. If the user does not read and accept these conditions in their entirety, they must not use or continue to use the Services. We reserve the right to amend or modify these policies, adapting them to the continuous legislative changes, which will always be in force on our website home page.

The user understands and declares to know that our Services offer the possibility of exchanging crypto-assets, therefore, it will be processed through the service with third parties and they will be considered as a type of assets that can be transmitted solely and exclusively through block chain technology. , including, but not limited to, digital currencies and digital tokens and any other type of digital exchange medium.

Users are responsible for verifying that they have the legal right to make transactions under the applicable laws in their territory. The Platform disclaims any responsibility in the event of any illegality of User transactions occurring or foreseeing, Ccoins has the discretion to verify transactions to verify illegalities as the case may be and take actions in accordance with laws and regulatory authorities, in the following cases:

• We have a reasonable suspicion that the policy has been or could be violated and fraud has or could be committed in our ID Verification process.
• We detected that the User uses multiple accounts, which is prohibited in our current policies.
• We consider the protection of other users necessary, therefore the services will be denied. 
• We determine that the User is using our Platform in such a way that it negatively affects or prevents other Users from making use of our Services.

The user, with access to the platform, accepts our discretionary decision to take measures that range from limitation, suspension and closure of the account, if any previously exposed circumstances are noticed, due to the need to apply security and verification protocols, withdrawing said measures if the circumstances that caused them are corrected.

Said measures will persist if:

1. The risk control system detects irregularities, and the Users involved explicitly refuse to collaborate with the Platform, or do not actively do so, to carry out subsequent verification regarding money laundering and terrorist financing.
2.  User Accounts are detected as suspected fraud (or attempted fraud), withdrawals to high-risk platforms (such as unlicensed cryptocurrency dealer platforms, online gambling platforms, platforms suspected of being involved in money laundering or fraud, or other high risk entities) or other high risk asset transfers.
3. An Account is not being used by the Registered User, or is being used illegally to purchase digital assets for third parties. It is detected that the User sells, lends or rents his Account to third parties, or illegally purchases digital assets for third parties.
4. Reception or introduction of digital assets or funds from illegal sources. Users know or can reasonably infer from their common sense that the funds received from other platforms are of an illegal origin or nature, and even so they allow their flow to the Accounts of other Users of the Platform.
5. Users identified as involved in money laundering: the risk control system detects, or risk control personnel confirm, that a User is directly participating or collaborating in money laundering activities.
6. Freeze of the Account authorized by court order: an Account has been frozen at the request of a judicial institution.
7. Investigation for legal compliance: Users are requested through a judicial institution to retrieve information from their Account on the Platform, for judicial investigation and consulting purposes, among others.

SECURITY VERIFICATIONS

In order to use the functionalities of the platform in Ccoins, the user must pass the following registration processes, and identity verification, in order to collect the user’s personal information, including data such as their full name, place of residence, date of birth and address, so that they are compared with the official documentation provided by the user, verification of the proof of real residence and the identity of the user in competent official databases, in order of residence factors and jurisdiction. 

KYC VERIFICATION STEPS

Identify users.

This process begins from the provision of user data, whether a natural, legal or moral person; collecting your personally identifiable information, full name, place of residence, date of birth and address:

• Email. 

The age and existence of said account is verified as well as a behavioral risk assessment based on the email address.

• Phone number. 

The number is verified by sending an SMS message with a verification code to the owner of the phone number.

• Official Identity Verification.

The user must deliver an official identity document (s) of the country where he is located (front and back), among which are: national identifications, driver’s licenses, tax cards, voter ID, Passports among others.

The uploaded document must contain at least the following information:

1. Full name
2. Issue date 
3. Issuing authority
4. Date of birth. (for a natural person), for verifications of legal age.
5. Date of Expiry.

The upload of said document(s) in image is necessary to carry out specific verifications to determine if the document is valid, belongs to the user and is reliable, as well as if said document was subject to alterations or manipulation, or the creation of other accounts in the platform with the identity document, which would effectively make the opening of the user account unfeasible. 

Delimitation with government databases to verify the report in said databases and proof of the existence of said document, for which Ccoins reserves the right to request an additional document that effectively verifies the proof of existence of the person.

This verification is carried out with specialized verification platforms, redirecting the data to said platform, in such a way that it offers extreme security in said verification.

Ccoins reserves the right to request a video or other additional documents that allow full certainty of said identity.

Verification with biometric data, only for natural or physical persons, so that the physical characteristics of the images delivered by the user match, in correspondence with the official identity document, it also verifies if the user who interacts with the application is the intended person and authorized.

Among other features of biometric verification is:

1. The video or selfie delivered by the user shows that he is a real human being.
2. It is verified that the photo or video matches the identification document uploaded as part of the document verification block.
3. The user’s video or selfie is verified to match the government database specified as part of the Government Verification block.
4. Age accessory control. It is verified that their physical characteristics meet the age requirements.

1. Residence address verification.

The existence of a real address and proof of the existence of said address are verified by means of GPS location, and validation of postal codes.

In the case of a legal or moral person, the review of adoption of AML policies or risk management in asset laundering and money laundering in order to the competence and jurisdiction of the user, under platforms attached to Ccoins. The watch lists against money laundering (AML) are issued by national and international organizations such as the FBI, Interpol and the United Nations, in which the names of individuals and companies that have participated in criminal activities rest. For this reason, our AML verification checks the user against over a thousand international watch lists, sanctions lists, and lists of politically exposed persons (PEPs).

If a user is found on any list, verification will be subject to a second review, either at the AU Government Department of Foreign Affairs and Trade, Inter-American Development Bank, GB Consolidated Target List His Majesty’s Treasury Sanctions List – Persons of Interest Swiss SECO Sanctions, UK Bank of England Sanctions List, UN Consolidated Sanctions, US Bureau of Industry and Security Denied Persons in US, US OFAC PEP Leaders CIA, Parliamentary Assembly of the Council of Europe, EU MPs, Colombian SARLAFT, US DEA, US FBI, INTERPOL Red and Black Notices, US Marshals Service. 

PROCEDURE AND ELIGIBILITY

After said internal verification procedures were carried out, in order to give rise to the effective creation of a user account accessible after the registration process and through the Platform Ccoins, therefore it is clear that you must go through all the AML/KYC procedures without inconvenience, which may be applied to you in accordance with our internal AML/KYC policies. As part of such procedures, Ccoins reserves the right to request additional information and documents, which are intended, among others, to identify our user and prove the origin of the funds;

The user must manage and maintain only one account Ccoins, for which it is forced to:

1. Change the password from the automatically generated one, for a secure password.
2. Provide an exact email. Access to the services provided by Ccoins without email verification is not accepted.
3. Maintain the security of your Account and notify us immediately if you discover any suspicious activity related to your account.
4. Take responsibility for all activities that occur in your Ccoins account.

We strive to protect our users from fraudulent activities in the field of crypto assets. Some crypto assets may be intended for illegal seizure of property, or construed as fraud, scam, or any other activity recognized by law as illegal and/or not in compliance with legal requirements. Ccoins cooperates with law enforcement agencies and other competent authorities to determine and disclose such crypto assets. We reserve the right to prohibit and discontinue any Exchange through our Services with such crypto assets at our sole discretion, without prior notice and without publishing the reason for such decision, provided that we are aware of it. Upon entering the platform, the user INDEMNIFIES AND RELEASES Ccoins FROM LIABILITY AGAINST ANY CLAIM, DEMAND AND DAMAGES, WHETHER DIRECT, INDIRECT, CONSEQUENTIAL OR SPECIAL for said security reason and verification in these policies.

CCoins Labs SAS