Coinify Legal Information

This page provides you with all legal information and resources related to Coinify products and services. Associated documents (Terms of Service, AML/KYC Policy, Privacy Policy, and Virtual Currency Risk Warning) govern the use of the products, services, platforms, websites or any other features, technologies or functionalities provided by Coinify or as part of the Coinify brand, through Coinify’s website(s) (including mobile services), API or through any other means (collectively the “Services”). (Last modified in October 2018)

The following Terms of Service (the “Terms”) govern the use of the products, services, platforms, websites or any other features, technologies or functionalities provided by Coinify ApS Herlev Hovedgade 15B, 2730, Herlev, Denmark +45 36 93 49 94 (“Coinify”) or as part of the Coinify brand, through Coinify’s website(s) (including mobile services), API or through any other means (collectively the “Services”).

We may use the expressions “you” and “yours” which refer to you as a Coinify Service user (being e.g. a buyer, trader, merchant, enterprise or person agreeing to the Terms on the behalf of such). Before creating an account to be able to use Coinify’s Services or using Coinify in any related manner, you must read the following carefully and acknowledge that you accept the Terms of Service.

Coinify reserves the right to modify these Terms of Service at any time. The most current version, and therefore the active Terms, is always available on coinify.com. If we change the Terms substantially, we will notify you via e-mail or when you use our Services. However, it is always your responsibility to check the Terms when using our Services and that you agree with its content.

 

 

Account

Coinify Currency Exchange Services

Coinify Trade

“Coinify Trade Services” provides individuals and businesses with currency exchange services that allow customers to place orders for buying and selling virtual currencies.

Coinify Trade Services are available in a limited geographical area. If you reside in the SEPA (Single Euro Payment Area), you are eligible for registering an account with Coinify. Please find out more information on which residents can buy and sell virtual currencies with Coinify in this article.

 

Creating a Coinify Trade account

If you want to use Coinify Trade Services, you must first create an account. As every new Coinify customer, you need to provide an email address and your country of residence to create an account.

Accounts can be created for both personal and business use. However, it is very important that the Coinify account owner is the same as the bank account owner.

In cases where the owner of the bank account (from where the money originates from) does not match the user name of the trade account, Coinify is unable to process the order and will therefore issue a refund to return the funds to the original account. Coinify reserves the right to charge an administration fee for this refund.

The same applies for a reverse transaction, where the incoming funds owner does not match the outgoing bank account owner name. Coinify reserves the right to charge an administration fee for such reverse transaction.

Traders are responsible for sending the correct payments for the orders they place, plus the necessary extra amount to cover the Payment Fee for Buy Orders and the BTC Transaction fee for Sell Orders. It is important to notice that, in the case of Sell Orders, Coinify will refund the surplus BTC received if a trader sends coins over the amount of the order to be processed as long as this amount is over 18.200 satoshis. Coinify reserves the right to update this limit when considered necessary.

 

Coinify Trade Levels

Level 1: Once signed up, you will be automatically eligible for trading at Level 1 with your credit card.

Level 2: Enables trading via bank transfer. Coinifys AML/KYC Policy requires an additional verification procedure for upgrading to Level 2. You will need to provide us with identification document(s) so that we can verify your identity and account ownership.

Level 3: Advancing to this level will increase your buy order limit for bank transfers and card orders. No changes for sell orders.

Please find the specifications for all three Coinify Trade Levels and associated fees in this article.

 

Eligibility   

By accepting these Terms, you acknowledge that you, as a physical entity:

  1. Are of legal age to agree to these Terms;
  2. Have not previously been suspended or removed from using our services;
  3. Do not intend to use our services with any criminal or fraudulent intent.

If approved by the Compliance department, it is possible to use Coinify Trade services on behalf of a legal entity, provided that:

  1. The legal entity is duly organized and validly existing under the applicable laws of the jurisdiction of its organization;
  2. You are duly authorized by such legal entity to act on its behalf.

 

Recurring orders

At Coinify’s discretion, certain partners will be offered the option of subscribing to recurring card orders. This service consists in scheduling a card order by setting an amount, currency,  frequency, and expiration date. Each card order created within the recurring option will be charged to the card entered at the moment of subscribing. The trader accepts all charges made for these orders until the recurring subscription expires. The trader may withdraw this consent up until the end of the business day (CET) before the date that the scheduled transaction is due to take place. Recurring subscriptions can be cancelled by the trader by following the instructions on Coinify’s Help Centre and/or by Coinify if deemed necessary.

 

Coinify Payment Processing Solutions

Coinify Merchant

The Coinify Payment Processing Solution, a merchant partnership, will allow your business to offer virtual currencies as a payment method. The Coinify Payment Processing Solution is not a virtual currency wallet or a place to sell or buy virtual currencies.

Coinify provides merchants accepting cryptocurrency payments with an option to receive payouts in fiat currencies or Bitcoin. This is decided by the merchant within their own account settings. Account verification for both payout-options is mandatory.

The Coinify Payment Processing Solution is only for businesses that offer products and/or services for sale. All businesses using the The Coinify Payment Processing Solution must agree and adhere to the Coinify Ethics Policy.

The refund option is not to be used for any other purpose other than to conduct refunds of specific payments back to the merchant’s customer who made the payment. Any other use of the refund option, will cause a suspension or termination of the account in question.

 

Buy-API

In addition, depending on the merchant’s industry, Coinify’s Buy-API can be enabled upon request. The Buy-API allows for example gambling/betting/FX trading entities to withdraw bitcoin to their clients, by using available funds on their merchant account. The Buy-API is to be used only for this purpose, and any misuse will cause a suspension or termination of the account.

 

Transaction Limits   

Coinify imposes transaction processing limits on single payments and on an annual basis for all merchants. For all merchants the upper limit for a single transactions is €10.000. If a merchant wishes to accept payments via Coinify for more than €10.000, additional KYC documentation on the client shall be forwarded to Coinify, prior to the transaction. The documentation may vary from time to time and depending on the legal entity receiving the payment. Coinify will review the documentation and give written consent for the transaction as soon as possible (aiming at no later than 48 hours, after receiving the documents, weekends not included). It is solely the merchant’s responsibility to make sure no payment above €10.000 is completed, without written consent from Coinify Compliance Team. If such a payment is made without consent from Coinify, funds will not be paid out until Coinify management decides how to proceed. Coinify will also reserve the right to hold part of the funds from such transactions, to cover cost related to a potential refund.

 

Merchant Levels

Level 1: Once you complete the merchant account set-up and get approved and verified by the Coinify Compliance Team, you will be able to transact at the Merchant level 1. Level 1 allows you to make transactions up to €10.000 in single payments and a volume of €30.000 annually.

Level 2: If you expect or wish to be enabled to process a larger transaction volume, Merchant Level 2 will allow you to conduct single transactions of up to €10.000 and a volume of €100.000 annually. Before Coinify can enable Level 2, we will ask for additional documentation stating how your business conducts KYC and AML procedures. This information needs to be reviewed and approved by Coinify. Once approved, you will be enabled for Level 2 which also gives you access to the Buy-API.

Level 3: Should you wish to process larger transaction volumes, Merchant level 3 will enable an annual volume of €+100.000. Level 3 will have no upper limit for single payments, but for payments of more than €10.000, we will require KYC documentation on the client making the payment/sending the bitcoin.

Upon your request and at Coinify’s discretion, our management will make a risk assessment of your business and enable Merchant Level 3, if approved.

At any time, Coinify reserves the right to decline transactions that are under suspicion of not being compliant with these Terms and/or Coinify’s AML/KYC Policy.

 

Creating Coinify Merchant Account

To use our solutions, you need to sign up for a Coinify Merchant account. When signing up for a Merchant account, Coinify will make a discrete risk assessment of the company attached to the account. The risk assessment is based on a review of the following Company Registration Documents uploaded in the account dashboard:

  • Shareholder registry;
  • Government issued photo ID of shareholders with +10% ownership;
  • Company URL;
  • Proof of address (utility bill from the address of merchant, no later than 3 months old);
    Bank letter statement.

 

For entities providing gambling/betting, trade, investment and/or prepaid-value/e-currency products or services, the following documents need to be uploaded as a supplement to the above:

  • KYC documentation (document describing the merchants internal KYC procedures);
  • AML documentation (document describing the merchants internal AML procedures).

 

Note that Merchants incorporated outside the EU will be required to provide certified translations of the aforementioned documents.

If approved, the KYC and AML documentation will give access to the Buy-API, if relevant for and requested by the merchant.

 

Eligibility       

By accepting these Terms, you acknowledge that:

  1. You have/represent a registered business within the business area in accordance with Coinify AML/KYC Policy;
  2. The markets where you operate and want to use Coinify’s solutions are not affected by the US embargo/ blacklisted by the UN.

 

Coinify Enterprise Solutions

Coinify Enterprise

The Coinify Enterprise partnership allows Payment Service Providers (“PSPs”) and other partners, who integrate with Coinfy APIs to:

  1. Offer virtual currencies as a payment method for their own business and/or entities/merchants other than themselves via Coinify Merchant API integration (Coinify Payment Processing Solution);
  2. Offer virtual currency trading on own domain/platform via Coinify Trade API integration (Coinify Currency Exchange Services);
  3. Offer combination of the above Services via Coinify API integration (Coinify Payment Processing Solution and Coinify Currency Exchange Services).

 

On the payment processing side, Coinify provides PSPs and other Enterprise partners with an option to receive payouts in fiat currencies or Bitcoin. This is decided by the PSP within own account settings if they work as a collector. If the PSP works as a proxy and have their merchant’s sign-up directly with Coinify, the individual merchant will be able to control these settings from their account dashboard. For PSP-merchants that are signed up directly with Coinify, verification is completed via normal merchant sign-up procedures.

The terms stated for Coinify Merchants (Payment Processing Solution) apply to PSPs and the merchants they enable with the Coinify Payment Processing Solution, unless stated differently here in this section or separately negotiated differently via a Strategic Partner Agreement.

The Coinify Payment Processing Solution is solely for PSPs or similar businesses that offer payment processing services to their merchants. PSP’s merchants need to have legitimate registered businesses that offer products and/or services for sale. The Partner must adhere and agree to the Coinify Ethics Policy, and make sure their enabled merchants comply.

A proxy PSP-merchant has the option to request the Buy-API to be enabled, directly through their contact at either Coinify or the PSP.

If a collector PSP has a merchant that is interested in the Buy-API, the PSP can send a request to the Coinify Sales Team.

 

Creating a Coinify Enterprise Account

To use the Coinify Enterprise Solution, you need to register for a Coinify Enterprise account. PSPs enabling virtual currency payments via the Coinify Payment Processing Solution for entities/merchants other than themselves, needs to sign a Strategic Partner Agreement, before any transaction can be processed. The Strategic Partner Agreement is discretely negotiated via the Coinify Sales Team.

When signing up for an Enterprise account, Coinify will make a risk assessment of the company attached to the account. The risk assessment is based on a review of the following Company Registration Documents uploaded in the account dashboard:

  • Shareholder registry;
  • Government issued photo ID of shareholders with +10% ownership;
  • Company URL;
  • Proof of address (utility bill from the address of merchant, no later than 3 months old);
  • Bank letter statement;
  • KYC documentation (document describing the Partners internal KYC procedures);
  • AML documentation (document describing the Partners internal AML procedures);
  • Other documentation may be requested on a case by case basis.

Note that Enterprise partners incorporated outside the EU will be required to provide certified translations of the aforementioned documents.

 

Transaction and Merchant limits

Coinify imposes transaction processing limits on single payments and no monthly or annual limits as such for PSP and partners integrated with our API. However, extreme high volumes need to be communicated as early as possible by the PSP/Enterprise partner, and accepted by Coinify.

For PSP-merchants, the upper limit for a single transaction is €10.000. In case of collector PSPs, PSP is responsible for ensuring that no single transaction exceeds €10.000. In case of proxy PSPs, individual merchant is responsible for ensuring that no single transaction exceeds €10.000.

 

Eligibility
By accepting these Terms, you acknowledge that:

  1. You represent a PSP serving merchants or a partner/s integrated with our API within the business areas in accordance with Coinify AML/KYC Policy;
  2. The markets where you operate and want to use Coinify’s solutions are not affected by the US embargo/ blacklisted by the UN.

 

Abuse of Coinify Account

You are responsible for maintaining the secrecy of your account information, including username and password. In the event of misuse or suspected misuse of your account, you must immediately notify Coinify. Coinify can, on suspicion of abuse, block your account. 

You assume all liabilities arising from unauthorized access of your account.

Coinify recommends that you maintain a high standard of safety adhering to at least the following:

  • Enable a two-factor authentication where applicable;
  • Change your password regularly, at least once a month;
  • Never share your username and password with anyone;
  • Make sure that your password is too complex to guess (contains at least 8 figures, uppercase and lowercase letters and numbers);
  • Always log out when you are finished using Coinify.

 

Deleting Coinify Account

You as a Coinify customer have right to choose to terminate your account upon request. Please note that Coinify cannot delete your account upon request instantly, but rather to disable it for period of 5 years, until it can be deleted. This is due to regulatory requirements related to Coinify AML/KYC Policy. Likewise, Coinify accounts inactive for the past 5 years will be automatically disabled and deleted.

Coinify reserves the right to unilaterally block, suspend and/or terminate your use of Services, either temporarily or permanently, in the event of:

  1. If we suspect that you have failed to comply with these Terms,
  2. You pose an unacceptable fraud risk to us, or if you provide any false, incomplete, inaccurate or misleading information.

We will not be liable to you for any losses that you incur in connection with closure of our Services or suspension of your account.

 

Operations

While we aim for 100% server up-time, we realise this is not always possible. We are constantly working on improvements and performing upgrades, which may occasionally result in server outages.

Coinify reserves the right to perform maintenance or changes to the Services at any time it sees fit. This may result in periods during which the services may be temporarily unavailable. Coinify will, to the extent that it is possible, announce such interruptions in advance. However, it is not required to do so and is not responsible for any damages or losses resulting from server outages.

 

Payment by Bank Transfer

When you pay by bank transfer, you accept that bitcoins will be traded at the current available exchange rate at the time Coinify processes your order, which might differ from the rate displayed when you confirm you order on Coinify.com.

 

Delivery

The bitcoins are delivered to your bitcoin wallet by using the information provided by you. You are responsible for providing us with the correct information about your bitcoin wallet. If you pay by credit/debit card, the bitcoins will be delivered within a couple of hours after the transaction is completed. If you pay by bank transfer, the bitcoins will be delivered when Coinify has processed your order.

 

No Cancellation Right

WHEN YOU COMPLETE A PURCHASE, YOU ACCEPT THAT YOU HAVE NO CANCELLATION RIGHT IN RELATION TO THE PURCHASE.

 

Sale of Goods Act

The Danish Sale of Goods Act (“købeloven”) applies to the products you have purchased from Coinify.

 

Liability

Coinify is committed to the high standard of data security and precision. However, Coinify shall not be liable for any loss that you may incur as a result of malfunctions, errors, security breaches or any other reason.

Coinify will not be responsible or liable to you for any loss and take no responsibility for and will not be liable to you for any use of our Services and/or solutions, including but not limited to any losses, damages or claims arising from:

  • User error such as forgotten passwords, incorrectly constructed transactions, or mistyped Bitcoin addresses or similar;
  • Server failure or data loss;
  • Corrupted Wallet files;
  • Unauthorized access to applications;
  • Any unauthorized third party activities, including without limitation the use of viruses, phishing or other means of attack against the Coinify website or Coinify services or solutions.

Once you create your Coinify account, you are responsible for the activities performed. Likewise, it is solely your responsibility to guard your password, and track any activity that occur with the use of your password and/or in your account. Please notify us immediately if you suspect any security breach, caused by you or other parties. Coinify cannot be held responsible or liable for losses or damages relating to account settings, or security breaches caused by you.

Coinify shall not be liable for your or other users’ content. If you come across content that is not correct, offensive or against the Terms, you should report this to Coinify (feedback@coinify.com) immediately. Coinify reserves the right to delete content at any time it deems necessary.

In no event shall Coinify be liable for indirect losses and/or an amount larger than the amount you have paid to Coinify.

 

 

Copyright

Coinify is the owner of all intellectual rights and branded elements (including logos, portraits and other visual identity elements) and content (including blog posts, articles, images, videos, tips and advice) available on the Coinify platforms (including website, mobile applications, Newsroom, Help Centre, social media and other registered domains) unless otherwise stated.

You accept and acknowledge that the material and content contained within the Coinify website and other domains is made available for your personal, lawful, non-commercial use only. You further acknowledge that any other use of content from the Coinify website and related domains is strictly prohibited and you agree not to infringe or enable others to infringe our intellectual property rights.

 

Complaints

If you have any complaints, you may contact compliance@coinify.com.

A complaint concerning a product purchased from Coinify can also be submitted to the European Consumer Centre Denmark (“Center for Klageløsning”), Carl Jacobsens Vej 35, 2500 Valby, via https://www.forbrug.dk/.    

Complaints can also be sent via the European Commission’s Online Dispute Resolution: http://ec.europa.eu/odr.

 

Miscellaneous Provisions

Waiver: No delay or failure to take action or decisions pursuant to these Terms shall be a waiver of any provision or right under these Terms.

Separate provisions: If any provision of these Terms is invalid or unenforceable under applicable law, such provision, and the rest of these Terms enforced to the fullest extent permitted by applicable law and the remaining provisions of these Terms continue in full force.

Transferability: These Terms and the rights which you obtain below are personal to you and may not be transferred, assigned or delegated to others. Any attempt to assign, transfer or assign these Terms or any rights hereunder shall be deemed invalid.

 

  1. Government-issued photo ID;
  2. Proof of residential or business address;
  3. Corporate documentation;
  4. Business registration information;
  5. Tax Identification Document;
  6. Employer Identification Number;
  7. Any other applicable documentation.

 

Furthermore, we reserve the right to conduct enhanced due diligence on all clients given worldwide approved risk-based policies. Please note that Coinify reserves the right to refuse a transaction or deny operation on a client or account at any time should suspicion arise that it may be connected to money laundering, criminal activity or any other predicate offense to money laundering. Coinify will not enter into any business arrangement with anyone or group suspected of or directly involved in money laundering, or where funds have been sources or ends of an illegal activity.

In the event that Coinify receives, during its request for documentation, deceptive documentation, contact details, business description or other false information, Coinify will terminate the offending account. Coinify is legally bound to report such misdemeanors to the relevant authorities, and as such the subject, business and its owners may be the subject to a criminal investigation.

Providing false, doctored, or deceptive documents is considered as fraud and will be treated as such. Tax Evasion and Fraud is a predicate offense to money laundering, and therefore, all assets derived from fraudulent transactions or suspicious activity may be seized and forfeited.

 

As part of the information that is collected during our verification and AML procedures, Coinify conducts verification through worldwide databases. At the forefront, they will include global sanctions reports and government watch lists and rigorous screening processes. At any time, due to a requirement to satisfy any of the above verification methods, a client, business entity or any of the business entity owners or affiliates may be asked a specific document or piece of information to confirm their identity or provide additional information regarding any transaction, operations or even business dealings with certain individuals, institutions and dealings in geographical locations.

The intention of this Virtual Currency Risk Warning is to inform you on the significant risk of loss involved with transactions of trading or holding virtual currencies, as well as the limitations Coinify ApS (“we”) holds on the liability and indemnity of your actions with our services.

 

  1. Be aware that trading or holding virtual currencies such as Bitcoin carries significant risk. All currencies, virtual and fiat, may be subject to large swings in value, and may even lose their value completely. Virtual currencies are still developing, both technologically and financially, and therefore prices are volatile and fluctuate very dramatically within a short span of time. Virtual currencies like Bitcoin are susceptible to pricing bubbles or loss of confidence which could lead to a sharp decline in demand, thus leading to a loss in value. This means you stand to either gain or lose your assets at any given moment. Therefore, you understand and accept that losses can and do occur–with the risk of losing your entire investment–when trading or holding virtual currencies.
  2. You should not deal with virtual currencies unless you fully understand the nature of the transactions you are entering into and the extent of your exposure to the risks. You should also consider with caution if the transactions you perform are suitable for you, your personal circumstances and financial position.
  3. Virtual currencies also involve their own unique risks compared to other established currencies on the market. For one, virtual currencies are decentralized and remain unregulated by central governments or other legal entities, nor are they tied to any commodity of value, such as gold. Virtual currencies are built on technology with a trust-based, partially anonymous peer-to-peer network that still lacks the regulatory measures for protection and it relies on its cryptography for security. This means that by trading and holding virtual currencies, you will not be able to enforce any guarantees or safeguards expected with regulated financial services. Similarly, EU law currently does not offer direct legal protection from losses incurred from failure or disruption of our platform, failure or disruption of our integrated partner platforms, cyber-attacks, embezzlement of funds, business failure, asset forfeiture, scams, such as phishing websites, phony support or fake social media pages; nor are will you be granted any guarantees or safeguards for regaining access to your virtual currency accounts or holdings within these circumstances.
  4. Coinify ApS does not and will not provide any advice regarding your investments or purchases in relation to your transactions or trading strategy. You are responsible for your decisions made on our platform and we will not make any personal recommendations for your trading activity, or advise on the buying, selling, or overall trading in particular virtual currencies or performance of certain transactions related to our services; nor will we discuss any tax-related consequences,  reveal the composition of accounts, or any other obligations relating to such transactions of trading and holding virtual currencies. You must use your own careful judgement when deciding to transact with our service, and be completely aware that by doing so, you may incur losses that we are not responsible for.
  5. By entering into a transaction, you understand and accept the risks associated in dealing with an internet-based virtual currency service which include but are not limited to: operational interferences; failure or disruption of hardware, software or internet connection; threat or attack of malicious software; or unauthorized access of information stored on your Trade account or wallet. As with everything on the internet, there is risk that your account or virtual currency wallet can be compromised by persons or organizations for malicious reasons. Depending on your wallet provider of choice, we cannot guarantee the option or possibility of insuring or claiming back any virtual currency funds lost in this manner.
  6. By trading virtual currencies, you understand and accept that you are at risk for not being able to trade or exchange them for fiat currencies for potentially long periods of time due to various reasons–both foreseen and unforeseen, therefore placing you at risk for incurring losses in the meantime.
  7. By utilizing our services, you understand and accept the risks associated with involvement of a virtual currency network, which includes but is not limited to multiple known and unknown vulnerabilities within the network, including regular or irregular changes to the network protocol. Coinify has no control over any virtual currency network and therefore takes no responsibility over any harm caused by the risks these networks hold.
  8. Coinify does not take responsibility for loss, claims or damages related to our services which include but may not be limited to: user error (lost passwords, provision of incorrect information, sending virtual currency to the the wrong address), server failure or data loss, corrupted pages on the Coinify platform, corrupted files from your wallet service provider, unauthorized access to our applications, unauthorized third party access and activities (including but not limited to malware, viruses, phishing, and other website attacks).

 

Introduction

This policy shall be implemented in all parts of Coinify ApS (the “Company”), taking local rules into account, when relevant. The Company’s products and services may only be used for lawful purposes. In addition, we want to prevent our products and services from being used in an unethical way.

 

 

Principles for Ethical Behaviour and Practices

All actions and decisions within the Company shall meet high requirements with regards to ethical behaviour. This will inspire confidence for the Company among the general public, customers and others. In certain cases, this may mean that the Company must live up to higher requirements than those prescribed by laws and other rules.

The Company’s corporate culture is based on the following common core values:

1. The Company shall comply with relevant external and internal restrictions (observing transparency and appropriateness) regarding giving and receiving gifts as well as unacceptable benefits, in order to avoid any allegation of bribery or corruption.

2. The Company shall at all times conduct its business in such a manner as to enhance the reputation and credibility of the Company and the Payments Platform. The Company shall:

a. Refrain from participating in any unlawful, unfair, deceitful or immoral practice and refrain from selling the Payments Platform to any other partner, customer, or organisation, which has recourse to such practices.

b. Present the Payments Platform in a fair and appropriate manner. For such purpose, the partner and customer shall not disparage the Company and the Payments Platform and shall not make statements concerning the characteristics or capabilities of the Payments Platform which may not be in accordance with those described in this documentation; nor shall the partner and customer market the Payments Platform by correspondence.

3. Each action or decision in the Company shall be carried out in such manner that it can be scrutinised by others.

Policies, instructions and routines that supplement and clarify the principles in this Ethics Policy.

Sanctions. If the Company’s partners or a customer fails to comply with this Ethics Policy, the Company shall terminate the cooperation. The Company may give the partner or customer an opportunity to improve, if no immediate improvement is recognised the policy is to terminate with zero tolerance.

Procedure. Coinify will examine the products and services within three months after the first transaction of new merchants through Coinify Website. PSP ́s will be asked to verify that their products and services are neither unlawful, unfair, deceitful or immoral. Each Merchant will be re-examined within 15 months from signup and after the elapse of each 12 months period. Each PSP will be asked to repeat their verification that their products and services are neither unlawful, unfair, deceitful or immoral, within 12 months after signup and after the elapse of each new 12 months period.

 

 

Unethical Business

Methods and Practices

The Company shall not cooperate with partners and customers, which sell products or carry out services with means and methods that can be regarded as intrusive, misleading, abusive, and disadvantageous to end-customers or in any other way unethical. Examples of unethical Methods and Practices follow below:

1. Marketing, distribution or other handling of products or services in illegal products or services.

2. Products that encourage crime or may provide support to illegal activities.

3. Unlicensed copies and other products infringing intellectual property rights.

4. Sexual or pornographic services, such as:

a. Prostitution

b. Live web cam

5. The sale of a product or service, including an image, which is patently offensive and lacks serious artistic value (such as, by way of example and not limitation, images of non-consensual sexual behaviour, sexual exploitation of a minor, non-consensual mutilation of a person or body part, and bestiality).

Products and Services

The Company shall not cooperate with partners and customers, providing products or services, which the Company considers as unethical. Examples of unethical Products and Services follow below:

1. Illegal products or services.

2. Products that encourage crime or may provide support to illegal activities.

3. Illegal substances, such as drugs, and products typically used for manufacturing or using such.

4. Unlicensed copies and other products infringing intellectual property rights.

5. Content encouraging or in other ways inappropriately related to hate, violence, racism or discrimination.

6. Sexual or pornographic services, such as:

a. Prostitution

b. Live web cam

7. The sale of a product or service, including an image, which is patently offensive and lacks serious artistic value (such as, by way of example and not limitation, images of non-consensual sexual behaviour, sexual exploitation of a minor, non-consensual mutilation of a person or body part, and bestiality).

 

 

 

Anti-Bribery and Corruption

At Coinify ApS (‘Coinify’), we are committed to operating lawfully, ethically and with integrity in all business activities. As part of this commitment, Coinify will not tolerate any form of bribery or corruption in our business or in those we do business with.

As an organisation we strive for the highest level of compliance with respect to all legislation. To that end, Coinify will uphold all anti-bribery and corruption laws and regulations in all the jurisdictions in which we operate. As a Danish company with operations throughout the EU and beyond, Coinify is bound by the Danish Criminal Code legislation and wider European Union best practices related to bribery and corruption.

Coinify would rather walk away from a business opportunity than be involved in any activity that could be construed to be a bribe. We expect all contractors, suppliers, counterparties, agents and others associated with Coinify (“Business Partners”) to adopt a similar zero tolerance approach to bribery and corruption.

This ethos is endorsed by Coinify’s management team and board. We expect that a similar commitment is taken by our Business Partners to mitigate the risks of bribery and corruption in Denmark, the EU and overseas.

All forms of bribery are strictly prohibited, including facilitation payments.

 

 

Countering the Risks of Bribery & Corruption

Coinify mitigates bribery risks by adhering to a control framework and maintaining an awareness of higher risk activities to help identify areas of potential concern. This approach is based on a framework outlined by the European Union and known as ‘Adequate Procedures’, they are summarised below:

1. Risk assessment

2. Communication and training

3. Tone from the top

4. Due Diligence

5. Monitoring and review

6. Proportionate procedures

We expect Business Partners to have adopted this approach, regardless of their jurisdiction and document their risk- based controls and procedures accordingly. Business Partners based overseas are also encouraged to adopt a similar framework to ensure their governance framework contains suitable bribery prevention measures. We recommend the following are recorded as risks and managed accordingly with adequate controls.

Third party intermediaries (TPI’s)

Many companies use an agent, finder or consultant to help them identify, win or retain business in certain countries in which they operate. TPI’s can carry bribery risks, often because of personal connections with local officials or the government of that country. TPI’s have also been used to facilitate payments of bribes.

Foreign Public Officials (FPO’s)

FPO’s represent a heightened risk of bribery, with public records revealing instances of bribes made or received both in the EU and abroad. Coinify operates controls to mitigate our exposure to this risk, which includes a restriction on the giving or receiving of gifts or hospitality without senior management approval.

Overseas payments

When a bribe is made through a financial institution, this can involve monies going to an overseas jurisdiction with weak financial controls. Many organisations operate in multiple jurisdictions and this creates the legitimate need to make overseas payments. However, particular attention should be paid to transactions in overseas and high-risk jurisdictions.

Sponsorships and donations

Coinify only makes charitable donations which are ethical and legal under local laws and practices. We do not make payments to political parties, organisations or their representatives. Additionally, no sponsorship or charitable donation will be made if it could be perceived to be a bribe and we have similar expectations of our business partners.

Gifts & Hospitality

Coinify recognises that giving and receiving gifts or hospitality can be part of building normal business relationships or maintaining cordial relations. The problem arises when the gifts or hospitality are considered to be disproportionate, unduly lavish, extravagant, or could be seen as an inducement or reward for preferential treatment (e.g. during contractual negotiations or a tender process). To avoid any uncertainty all gifts and hospitality (except low value items such as corporate promotional items), including any offers which are declined are entered on a Gift Register and regularly reviewed.

Facilitation Payments

A facilitation payment (or grease payment) is a sum of money typically paid to an FPO or another person to expedite a routine or necessary administrative process. It’s generally a small sum used to speed up a process such as goods through customs. Although a facilitation payment is legal in some jurisdictions, European legislation takes precedence and classifies them as a bribe. Facilitation payments must not be paid on Coinify’s behalf unless refusal to pay creates a health and safety situation.

Slavery

Modern slavery is criminal activity and a violation of human rights. The deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain is unacceptable. Coinify recognises it has a responsibility to take a robust approach to slavery and human trafficking and has zero tolerance for this activity from any staff, or suppliers of the group.

Training

We encourage our Business Partners to identify employees working with Coinify who may benefit from anti-bribery training. Coinify has designed an anti-bribery awareness module that can be made available to the employees of its Business Partners in the event they do not have their own.

Speak-Up

Coinify operates with transparency and encourages its own employees to report improper behaviour or suspicions of impropriety. We have an independent and confidential reporting hotline which can also be used by our Business Partners to report suspicious activity. We would encourage our Business Partners to have a similar policy for their employees to report suspicions of actual or potential bribery or other dishonest behaviours to their management.

Certification

Suppliers will certify compliance with this policy and their adherence to the relevant human trafficking, slavery, anti-bribery and corruption laws in the jurisdictions in which they operate. Suppliers who are found to be engaged in any of activity prohibited in this policy or who refuse to co-operate with Coinify in auditing their compliance with this policy will be liable to have any supply agreement, arrangement or other contract with Coinify terminated immediately with no notice or compensation. Coinify has zero tolerance.

Any questions regarding this policy should be emailed to compliance@coinify.com