Legal Disclaimer

In this page you can find all our contracts and personal data processing policies.

Terms of Service

Privacy Policy

Cookie Policy

Information on risks related to the services offered by CoinPlaza

  Anti-Money Laundering and Anti-terrorism Reporting

To use an Account through,,,, or one of our associated Websites, APIs or mobile applications (the "CoinPlaza Services"), you acknowledge that you have read, understood and accepted all terms and conditions contained in this Contract, as well as our Privacy Policy.

Please be aware that there is a significant risk of loss of the digital currencies held.

CoinPlaza S.r.l. ("CoinPlaza") Website and Services and their use in connection with exchanges involving legal currencies are not offered, nor can they be used to/by natural or non-natural persons having their residence or registered office in the United States of America and in all the countries indicated by the European authorities as "blacklisted": Samoa; Bahrain; Guam Marshall Islands; Namibia; Palau; Saint Lucia; Trinidad and Tobago;

and those indicated by the Italian Revenue Agency: Bahamas; Barbuda and Brunei; Djibouti; Grenada and Guatemala; Cook Islands; Marshall Islands and US Virgin Islands; Kiribati; Lebanon and Liberia; Macau and the Maldives; Nauru; Nevis and New Caledonia; Oman; French Polynesia; Solomon; Samoa; Saint Lucia; Saint Vincent and the Grenadines; St. Helena; Sark; Saint Kitts; Tonga; Tuvalu; Vanuatu.

The User acknowledges that the computer registration of the confirmation of clicks of acceptance of these General Contract Conditions (or "Terms of Service") and of the Privacy Policy are evidence of the User's acceptance of the Services offered by CoinPlaza through the Website.

The CoinPlaza Platform configured in the domains,, and, any second level domains, accessible from the individual pages of the Website and the contents published therein, with the exception of network Services offered by third parties, as well as any API (Application Programming Interface) to access specific contents of the Website or the widgets with the data of the Website itself are owned by CoinPlaza, with registered office in Via Luigi Dari, 31, 63074 San Benedetto del Tronto, Tax ID and VAT number: IT02319260440, REA Register no. AP - 204690.

Users undertake to inform CoinPlaza of any unauthorized or improper uses of the Website, also in violation of these Terms and Conditions, by sending an email to, specifying the data enabling the identification of the unauthorized or improper Website content, or of the subject who has used the Website in an unauthorized or improper manner.

1. CoinPlaza Services

1.1 The Services of the Website are subject to Italian and European law, without prejudice to the provision of the hosting service or other Services necessary for using the Website, provided by third parties, to which the conditions of use referable to such Services apply.

1.2 The User may use the Website exclusively for personal or business purposes related to one of the activities performed by CoinPlaza and within the limits specified in these General Contract Conditions. In the event that the User, through the use of the Website or through other behavior, endangers, voluntarily or involuntarily, the functionality of the Website itself, CoinPlaza will have the right to take all necessary measures to protect the Website and its systems.

1.3 The Website is reserved for use by natural or non-natural persons (entities and companies) regularly established, respectively residents or having their registered office outside the "Blacklisted" countries specified above.

1.4 These General Contract Conditions govern the relationship between the Customer, to whom the Services are provided (as defined in the following paragraph) and CoinPlaza. The General Conditions also regulate the individual orders given by the Customer to CoinPlaza, as well as the performance of a series of connected Services.

The service provided by CoinPlaza to the Customer allows the same to:

  • Buy cryptocurrencies using legal tender currency;
  • Sell cryptocurrencies for countervalue in legal tender currency;
  • Exchange cryptocurrencies between them.

The exchange will be possible only for the cryptocurrencies from time to time supported by the Platform against Euro or other currencies in legal tender, through the use of the Website, API or mobile applications made available by CoinPlaza.

1.5 CoinPlaza, as remuneration for the activity provided, will receive a foreign exchange fee which will be shown to the User at the time of the order of the exchange transaction.

1.6 The contractual regulation applicable to the relationship between CoinPlaza and the Customer consists of:

  1. these General Contract Conditions;
  2. the Data Processing Policy and the Cookies Policy;
  3. the Customer's registration/subscription to the Service, including personal data and other Customer data.

1.7 Registration is free. All costs relating to the network services required to be able to use the Services are to be borne exclusively by the Customer.

1.8 The framework Contract governed by these Terms and Conditions shall be perfectioned only once the Customer has successfully created an Account on the CoinPlaza Platform and has stated that he has read, understood and accepted all the terms and conditions contained herein, as well as the Privacy Policy and Cookie Policy.

2. CoinPlaza Account and access

2.1 From the moment in which the Customer has successfully completed the registration procedure for the Service, he/she will be the holder of a personal Account. The Customer undertakes not to disclose any information regarding the Account to any third party. In this context, the Customer acknowledges that the only person responsible for maintaining the confidentiality and security of the Account and all the activities that take place on the Account or through it is the Customer himself/herself. Any breach of the security of the Account must be reported immediately to CoinPlaza, which will not be liable for damages, costs or expenses arising from or resulting from the failure or delay in communicating said breaches.

2.2 The Service is designed and intended for personal use on an individual basis exclusively for personal or business purposes related to any of the activities performed by CoinPlaza and within the limits specified in these General Contract Conditions. For security reasons, in no case may the details of the Account and/or passwords necessary to access them be shared with third parties.

2.3 The User is responsible for any activity arising from any error or negligence in keeping the password and other personal information related to the Account confidential. The User will be held responsible for any loss or damage resulting from errors or carelessness.

2.4 The User undertakes to immediately inform CoinPlaza in writing at the following email address:, should he/she become aware of unauthorized use of his/her Account or of any disclosure of his/her password or other information which could lead to an abusive use of the Account. The User is also obliged to immediately notify CoinPlaza in writing of any other security breach.

2.5 The Customer undertakes to provide truthful, accurate and complete information during the registration and use of the Service, and agrees to periodically update such data to ensure that the same is always true, accurate and complete. Any damage resulting from the inaccuracy and/or completeness of the information provided shall not be attributed to CoinPlaza; further violations of the above provisions may result in suspension and/or cancellation of the Account.

2.6 CoinPlaza reserves the right to request, at any time and at its own unquestionable discretion, further information regarding the Customer to allow for the correct operation and provision of the Services. In case of refusal CoinPlaza may suspend the operation of the Account, or proceed with its cancellation. In case of failure or incorrect verification of the identity of the Customer, CoinPlaza will be unable to proceed with the purchase or sale of cryptocurrencies (and therefore shall not be held responsible for the non-performance thereof).

2.7 The Service that involves currencies with legal tender is reserved exclusively for individuals of legal age.

2.8 CoinPlaza Website, Services and their use in connection with exchanges involving legal currencies are not offered, nor may they be used by/for natural or non-natural persons having their residence or registered office in the United States of America and in all the countries indicated by the European authorities as "blacklisted": Samoa; Bahrain; Guam Marshall Islands; Namibia; Palau; Saint Lucia; Trinidad and Tobago; and those indicated by the Italian Revenue Agency: Bahamas; Barbuda and Brunei; Djibouti; Grenada and Guatemala; Cook Islands; Marshall Islands and US Virgin Islands; Kiribati; Lebanon and Liberia; Macau and the Maldives; Nauru; Nevis and New Caledonia; Oman; French Polynesia; Solomon; Samoa; Saint Lucia; Saint Vincent and the Grenadines; St. Helena; Sark; Saint Kitts; Tonga; Tuvalu; Vanuatu.

2.9 Use of the Service requires the use of compatible devices owned by the Customer and access to an Internet connection; the Service may request periodic updates of the device and may be affected by the performance of these factors. CoinPlaza reserves the right to limit the number of Accounts that can be created by a device and the number of devices associated with an Account. The Customer acknowledges that the fulfillment of these obligations is its full and exclusive responsibility and, therefore, CoinPlaza can not be held responsible.

2.10 The Customer, in order to be able to issue purchase or sale orders of cryptocurrencies, must adhere to and/or possess (for example in the case of bank transfer or credit card) one of the payment systems accepted by CoinPlaza for the use of the Service with the cash necessary to proceed with the Order (as defined below). The payment systems accepted by CoinPlaza are indicated on the Platform. All payments must be made to CoinPlaza; any amounts paid to the operator of the means of payment chosen by the Customer will not settle the Customer's debt with CoinPlaza.

2.11 The Customer undertakes to use the Service solely for the purposes permitted by this Contract. In the event that the Customer, through the use of the Website or through other behavior, endangers, voluntarily or involuntarily, the functionality of the Platform itself, CoinPlaza will have the right to take all necessary measures to protect the Platform and its systems. Measures that CoinPlaza may take include the suspension of access to the Service and cancellation of the Account.

2.12 The Service, or any feature or part thereof, may not be available in all languages or in all countries and Coinplaza makes no representation that the Service, or any feature or part thereof, is appropriate or available for use in any particular location.

2.13 CoinPlaza reserves the right, at any time, to modify the procedures and operation of the Website, to introduce new methods of use, new conditions of use and additional obligations relating to the use of the Service. These changes will be communicated through the Website and any subsequent changes to the General Conditions will be made and communicated in accordance with article 6 below. The changes to the Services will have immediate effect and will become an integral and substantial part of these General Conditions. The Customer will have a term of 30 days, starting from the communication of change, within which to accept the changes. During this period of time, in the absence of acceptance, the Services can not be provided. Once the aforementioned term has elapsed, in the case of non-acceptance, CoinPlaza will have a right to automatic and immediate termination of this Contract and to close the related Account(s).

3. Services for the purchase, sale and exchange of cryptocurrencies

3.1 To exchange, purchase or sell the cryptocurrencies supported by the Platform, the Customer must place an order to CoinPlaza in this regard. To this end, the Customer, once he has accessed the Website on his Device, must follow the instructions provided on the order setting screen, indicating the currency (virtual or legal) he wants to send and the one he wants to receive.

3.2 The maximum amount of the Order is limited to the amount that CoinPlaza will indicate from time to time on the Platform as the maximum limit for the Orders: in no case may this amount exceed any limits established by law for exchange operations of the type of those offered by CoinPlaza.

3.3 The Platform, referring to the quotes detectable through the consultation of the major online exchanges and applying a Fee in favor of CoinPlaza, will indicate the quote that will be applied for the exchange of currencies including the Fee itself and if the data provided by the Customer comply with the requirements on the Limit and the related procedure has been followed correctly, it will elaborate an Order proposal.

3.4 The exchange rates indicated on the Platform are rates obtained in real time also through access to the prices of the major online exchanges and are, of course, subject to continuous changes.

3.5 The exchange rate and the corresponding amount of currency that are shown at the time of the Order are however to be considered provisional as the exchange rate will be recalculated as soon as the Customer's funds will be received by CoinPlaza. In particular, for all those means of payment that require long management times (such as bank transfer), it may differ substantially from what is shown in the Order proposal. Before confirming the order, the Customer will receive a specific warning about the high risk of exchange rate fluctuations.

3.6 Given the high volatility of cryptocurrencies, CoinPlaza will calculate the actual exchange only when the Customer's funds will be available (ie expendable) by CoinPlaza. The exchange rate could therefore be substantially different from that which had been indicated to the Customer at the time of the order proposal (even with fluctuations exceeding 10%). The exchange rate fluctuation risk is always fully borne by the Customer. Only in this case may the Customer request the cancellation of the order through the Website customer support but only until CoinPlaza has received the funds and in any case has not yet begun the exchange transaction on the market. All costs related to the refund will be charged to the Customer who will receive it with the same payment method that was used net of expenses.

3.7 By accepting the proposal, the Customer gives an order and at the same time confirms under his/her sole responsibility that:

  • the details contained in the summary screen are correct in every aspect;
  • the economic conditions elaborated by the Platform have been understood, judged fair and accepted by the Customer.

3.8 The placement of the Order, together with these General Conditions, has the value of a contractual proposal that will be considered accepted by CoinPlaza through the explicit confirmation by email informing the Client that the Transaction has been accepted. The Order will be considered accepted and binding, therefore, only when the Customer becomes aware of the Confirmation by CoinPlaza. In any case, it is understood that CoinPlaza, even after having sent the Confirmation, can refuse to follow up the Order in case of significant misalignment of market quotes, in case of exceeding the maximum limit for the Order, of mismatch between the personal data provided by the Customer and the holder of the payment/collection method used (where applicable), or in case of technical difficulties of any kind. In this case, CoinPlaza will inform the Customer immediately that the Order has not been completed and will specify the reasons.

3.9 CoinPlaza reserves the right to request, at any time, further information regarding the Order to allow it to be completed or to comply with any regulatory requirements. In case of refusal to provide such information, CoinPlaza may not proceed with the order given.

3.10 CoinPlaza declines all responsibility for any access, impediment, malfunction or difficulty concerning the technical instruments, the telephone line, the cables, the electronics, the hardware on which the Platform resides, the transmission and connection, the internet connection, the mobile and fixed telephone network that can prevent and/or delay the Customer Order or CoinPlaza Confirmation, which also declines all responsibility for problems caused by the configuration of the device to access the Customer Platform that could affect the speed of processing of the Order given by the Customer.

3.11 After the Order, immediately after receiving any currency sent by the Customer and sending the relative receipt email of the Order by CoinPlaza, the funds received will be converted to the currency indicated by the Customer at the market exchange rate and then CoinPlaza will send it to the Customer.

3.12 The Client agrees to pay the amounts due for all cryptocurrencies purchased or sold through the Platform, together with the Services Fees for the Services used and any other additional sum (including taxes and late fees, if applicable) that may accrue for or in connection with the use of the Account, through the payment method provided for during registration (or as subsequently amended in accordance with the provisions of these General Contract Conditions).

3.13 The Customer remains solely responsible for the timely payment of all fees in the manner accepted by CoinPlaza.

3.14 The use of the Service, by its very nature, is based on the need to carry out legal transactions, enter into contracts and make purchases electronically. The Customer declares to be fully aware that his/her acceptance via electronic means constitutes a valid and binding act of consent. Any consent expressed through the use of any electronic means is valid and binding for the acceptance of any contract proposed in accordance with the law. The same applies to any expression of consent or acknowledgment relating to notifications by CoinPlaza of cancellation, change of policies, of contracts, etc..

3.15 If the User violates even one of the previous provisions, CoinPlaza may proceed with the suspension and subsequent closure of the Account, and the User will be held responsible for any losses incurred by CoinPlaza or any other User of the Website.

4. Anti-money Laundering Obligations

4.1 When registering on the Website, the User is required to provide all the necessary information and/or documents that CoinPlaza considers to be, in its sole discretion, suitable to maintain compliance with any law, regulation and internal policy (see the Anti-Money Laundering Policy adopted by CoinPlaza).

4.2 During the verification process of an Account, the User must provide all the documents requested. In particular, by registering an Account on the Website, the User agrees to provide CoinPlaza, or another person delegated to perform the anti-money laundering requirements prescribed by the law on behalf of CoinPlaza, with updated, accurate and complete information as required by the process of registration and to keep this information up-to-date.

4.3 In the event of an anomalous or non completely transparent operation of the User's Account, CoinPlaza may ask the same User for further information, including but not limited to the authentication of documents, and may also freeze all transactions while the appropriate checks on the Account are pending.

4.4 CoinPlaza reserves the right to block, suspend and terminate User Accounts for which proper verification has not been carried out, despite any useful efforts by CoinPlaza to contact the User and request completion of the due process.

4.5 The documents, data, photos and other informative material collected during the registration and verification procedures of an Account are subject to the conservation obligation to which CoinPlaza is held pursuant to the anti-money laundering regulations, also making use of the Services offered by a third party supplier.

4.6 CoinPlaza applies regular checks on User Accounts also through a request to provide information on the origin of Funds if and when expressed or converted into virtual currency or currency having legal tender.

4.7 CoinPlaza reserves the right to block or freeze the Account of any User, at their discretion and without prior notice, in case of suspected illegal origin of the Funds.

5. Communications with the Customer

5.1 The Customer expressly accepts to receive all communications (including accounting ones) in electronic format, including email. Any communication relating to this Contract will be sent to the address indicated by the Customer during the registration phase, or to the different address communicated by the Customer.

5.2 The Customer agrees that all communications are also carried out by means of remote communication means ("RCM"), such as e-mail, messaging services and notifications via the App. The Customer also agrees to CoinPlaza use of short message scripts (SMS) to the telephone number provided during registration for all communications relating to the Contract. The SMS are to be considered in all respects RCMs. CoinPlaza will not be held responsible in the event that non-legitimate third parties have access to the content of the communications sent by SMS or other RCM.

5.3 The Client authorizes CoinPlaza to record in full, without any prior notice, all the phases of the direct telephone calls made to it, either by an automatic answering machine or by an operator, using an automatic registration system; these records will be full evidence of the relationship between CoinPlaza and the Customer.

5.4 The communications provided for by the Contract will be addressed only to the Customer.

5.5 The communication will be considered received by the Customer on the day of the notification on the Website that the same is available in the appropriate section.

6. Unilateral Change Of Contractual Conditions.

CoinPlaza reserves the right, at any time, to modify this Contract and to impose new terms or conditions relating to the use of the Service and to vary the commission levels and procedures also in an unfavorable manner to the Customer. Both the changes and the new conditions will be communicated via RCM. If accepted, the changes will have immediate effect and will immediately become an integral and substantial part of these General Conditions.

In case of refusal or delay in accepting them, CoinPlaza will have the right to terminate the Contract with immediate effect and to not proceed with any Transaction. The Customer accepts and acknowledges from now on that CoinPlaza can not in any way be held responsible towards the Customer and/or third parties for the suspension or termination of the Service due to the Customer's failure to adhere to the new versions of the General Conditions. As per art. 2.13, including in the case of non-acceptance of the unilateral changes proposed by CoinPlaza.

7. Security, Closure, Suspension And Blocking Of An Account

7.1 The Customer undertakes not to access the Service by any means other than the Platform or other software provided for this purpose by CoinPlaza or the other affiliate companies of the group. Furthermore, the Customer expressly undertakes not to make any changes to the software provided by CoinPlaza to access the Service and not to use modified versions of the software.

7.2 The Customer agrees not to access or attempt to access an Account to which access is not authorized. Violations of system or network security may result in civil or criminal liability.

7.3 CoinPlaza reserves the right, at its sole discretion, to suspend or cancel the Client's Account in the event that the Device used for the provision of the Services has been subjected to the so-called "jailbreaking" and/or "rooting".

7.4 In order to provide a better service, CoinPlaza records information relating to the use of the Service in an anonymous and aggregate form. This information includes, but is not limited to, the frequency of transactions, their volumes, prices and timelines. CoinPlaza may also collect information about devices, such as the IP address, device type, type and version of the operating system, and unique device identifiers

7.5 Without prejudice to the General Contract Conditions, CoinPlaza may, at any time, at its sole discretion, without notice or explanation, including, without limitation, in case of attempts to obtain unauthorized access to the Website, for other security reasons or for violations of the General Contract Conditions or other document referred to therein:

  1. suspend, limit, interrupt or terminate a User's Account or Services to which he or she has access;
  2. freeze an Account, block the use of the deposits therein and the functionality of the Platform, also upon instruction of the Judicial Authority or the financial administration;
  3. proceed with the final closure of the Account, without prejudice to the possibility, where permitted by law, for the User to transfer his/her Funds to other Accounts;
  4. prohibit access to the Platform and/or a User Account;
  5. adopt any technical measure or legal action to inhibit the use of the Platform and the Services to the User held responsible for violations.

8. Term of the Contract

The Contract between CoinPlaza and the Customer shall be of unlimited duration.

The Customer may withdraw from this Contract by giving notice to CoinPlaza, with at least 15 days advance, by registered letter with return receipt to CoinPlaza Srl, Via L. Dari 31, 63074 San Benedetto del Tronto (AP) - Italy.

9. Liability

9.1 CoinPlaza shall not be held liable towards the Customer in case of non-compliance with the obligations set forth in this Contract, if the non-fulfillment is caused by third parties, computer systems malfunctions not under the direct control of CoinPlaza, or other events beyond CoinPlaza's control. In particular, CoinPlaza declines any responsibility for any problem related to the malfunctioning of cryptocurrency networks, impediment, dysfunction or difficulty that prevents the provision of the Services and that derives or may derive from technical tools, telephone line, cables, electronics, the software and hardware, the transmission and the connection, the internet connection, the mobile and fixed telephone network that do not fall under the direct control of CoinPlaza. CoinPlaza also declines all responsibility for problems caused by the configuration of the device to access the Platform that could affect the provision of the Services.

9.2 Moreover, CoinPlaza will not be liable in the event of non-acceptance of orders for sending and/or receiving cryptocurrencies not supported by the Customer's Wallet for losses and/or damages (both direct and indirect and with regard to emerging damage and/or loss of profit) that could occur in the event of errors committed by the Customer in the use of any software or service related to the use of the Platform and/or the use of cryptocurrencies purchased through the Platform, for example forgotten passwords or private keys, payments sent to incorrect addresses, loss of password, password disclosure, corrupt files, incorrect and/or incomplete transactions, cyber attacks, inefficiencies of CoinPlaza external wallet providers, etc.

9.3 In no case will CoinPlaza be held liable for non-compliance due to slight negligence of the same. The Customer agrees to hold CoinPlaza harmless from any damage or loss that it may incur in connection with the proper provision of the Services to the Customer and that are not the result of malicious or grossly negligent conduct of CoinPlaza.

10. Assignment of the Contract/Credit

The Client consents from now to the assignment by CoinPlaza of the Contract or the rights deriving therefrom, without this leading to a reduction in the protection of the Client's interests.

CoinPlaza shall notify the Customer of the assignment, including via RCM, in a timely manner.

The Customer may always raise against the assignee all the objections that he could have raised against CoinPlaza, including set-off, also by way of derogation from art. 1248 of the Italian Civil Code.

The Customer cannot assign to third parties all or part of his/her rights arising from the Contract.

11. Intellectual Property Rights

11.1 The Client accepts and acknowledges that the Service, the Platform, the Website, the brands, the logos and all the materials to which he has access in connection with the Service, which include or may include, by way of example, graphics, User interfaces, audio-clips, video-clips, editorial content, as well as the scripts and software used to provide the Services, are subject to intellectual property rights whose ownership is CoinPlaza's and/or its suppliers'. Such materials are protected by intellectual property laws, and by other applicable legal provisions, including, by way of example, copyright, trademark and patent law. The Customer agrees to access such materials solely for the use of the Service and in compliance with the provisions of these General Conditions. No part of the Platform, the Website or the Service may be reproduced in any form or by any means. The Customer agrees not to modify, rent, lease, loan, sell, distribute, or create derivative works based on the Service.

11.2 CoinPlaza, the CoinPlaza logo and other CoinPlaza trademarks, service marks, graphic signs and logos used in connection with the Service constitute trademarks or registered trademarks of the CoinPlaza group.

12. Processing of Personal Data

12.1 Access to the Service is allowed on the assumption, guaranteed by the Customer, that he/she is the holder of the payment method indicated at registration and that all information provided therein is true and exact, in particular with reference to personal data, his/her residence and the authenticity of the documents sent to CoinPlaza.

12.2 The Holder declares to have received the information pursuant to Article 13 of Legislative Decree. 196/2003 and the GDPR by CoinPlaza as the Data Controller by means of remote communication means ("RCM") and that he is therefore aware that the nature of the Service - also for reasons related to the security of the Account - necessarily requires the disclosure of personal data - and the related processing - to external companies, as well as the transfer of data abroad and their communication within the CoinPlaza company and that, in case of non-disclosure of the data, access to the Service cannot be granted.

13. Filing of the General Conditions

The original copy of the General Conditions will be filed at the premises of CoinPlaza and their updated version will also be available for consultation in the appropriate section on the Platform.

14. Disputes and Competent Court

14.1 Any dispute that arises between CoinPlaza and the Customer relating to the interpretation, validity, effectiveness, performance or dissolution of this Contract will be governed by Italian law and will be subject to the exclusive jurisdiction of the Court of Ascoli Piceno.

14.2 The Customer has, in any case, the right to file a complaint with CoinPlaza by means of a written notice, by registered letter with return receipt sent to CoinPlaza Srl, Via L. Dari 31, 63074 San Benedetto del Tronto (AP) - Italy.

14.3 Users residing in an EU State, for all disputes or claims arising from or in connection with these General Contract Conditions, including disputes relating to their validity, violation, resolution or invalidity, and for any dispute or claim arising from or in connection with the use of the Website, can benefit from online dispute resolution through the use of the ODR Platform, provided by the European Commission, which will allow, within 30 days, with CoinPlaza agreement, to identify the out-of-court resolution body competent for Italy, as well as to use the procedure made available by the aforementioned body directly through the said platform available in all EU languages.

14.4 Before accessing the out-of-court dispute resolution procedure referred to in the previous paragraph, the User undertakes to lodge a complaint directly with CoinPlaza via email to the address CoinPlaza reserves the right to reply within 60 days of the date of receipt of the complaint by the User.

Last edit: 03/01/2019 12:28:26
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We wish to inform you that Regulation (EU) 2016/679 (hereafter "GDPR") establishes rules concerning the protection of individuals with regard to personal data processing, as well as rules on the free movement of such data, and protects fundamental rights and freedoms of individuals, with particular reference to the right to personal data protection. The free movement of personal data within the Union shall be neither restricted nor prohibited for reasons connected with the protection of individuals with regard to the processing of personal data. We therefore point out that "personal data" means, according to the aforesaid GDPR, any information that directly or indirectly regards you as a Data Subject, with particular reference to any identifier such as name, an identification number, data relating to location, an online identifier or one or more characteristic identifying elements of you from a physical, physiological, genetic, psychological, economic, cultural or social perspective. The Website's management methods are described in relation to the processing of personal data of Users who browse it and who have access to the reserved area.

This information is also provided pursuant to art. 13 of the GDPR to those who interact with the web Services of CoinPlaza S.r.l. ("CoinPlaza").

This Privacy Policy is provided exclusively for Websites related to CoinPlaza and not for other Websites that may be browsed by the User through links. After looking at this Website, data relating to identified or identifiable persons may be processed.

1. Name and Contact Details of the Data Controller

Following is the identity of the Data Controller and its contact details:

CoinPlaza S.r.l.
Via Luigi Dari, 31
63074 San Benedetto del Tronto (AP)
(+39) 0735 430558

2. Purpose of the Data Processing

Data processing related to the Services of the Platform (the "Services") takes place at the aforesaid offices of the Data Controller and is exclusively handled by staff authorized to the processing, or by staff in charge of occasional maintenance operations. No data deriving from the web service will be disclosed. The personal data provided by Users who send requests for the sending of material regarding the requested service (or even information only) are used to follow up the User's requests and can be communicated to third parties provided that such parties are necessary, involved and functional to satisfy the aforementioned requests.

The collection and processing of the User's personal data shall be in compliance with the general principles of necessity, correctness, relevance and non-excess, and in particular the processing of data will take place for:

  1. answering questions and providing the information requested by the User (the optional, explicit and voluntary sending of emails to the addresses indicated on this Website entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message) and to contact the User about the Services provided by CoinPlaza
  2. as a provider of Services relating to the use of virtual currency, to fulfil the obligations provided for by Italian Legislative Decree no. 231/2007 on anti-money laundering for the purposes of preventing and combating the use of the economic and financial system for the purpose of money laundering and terrorist financing (hereinafter "Consolidated Anti-Money Laundering Act");
  3. allow the User to access, through registration and creation of their own User Profile, the reserved area and the subsequent and autonomous management of their User profile from the control panel;
  4. the "Newsletter" service to which the User has the right to register. If the personal data provided by Users has been provided by registering with the aforementioned service, the same will be used for the sole purpose of sending the newsletter and will not be disclosed to third parties;
  5. the necessary and indispensable processing of operational, management, Accounting and other nature, specifically, some data will be used to allow the effective execution of Customer orders and for the registrations and communications required by law;

The legal basis of the processing is identifiable in the Italian Civil Code, Consumer Code and Consolidated Anti-Money Laundering Act.

3. Lawfulness of processing

The processing is lawful as long as at least one of the provisions envisaged by Article 6, paragraph 1, letters b), c) and f) apply:

  • b) processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
  • c) processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
  • f) processing is necessary for the pursuit of the legitimate interest of the Data Controller (such as, for example, the prevention of fraud or abuse of our Website: it may be considered as a legitimate interest to process personal data for direct marketing purposes (such as highlighted in point no. 47 of the GDPR) or by third parties, unless the interests or the fundamental rights and freedoms of the Data Subject who requests the protection of personal data prevail, in particular if the Data Subject is a minor.

4. Recipients of Personal Data

Communication to the identified recipients shall occur only if they are involved and functional to achieve the purposes referred to in point 2 herein, therefore personal data collected and processed may be:

  1. used anonymously for statistical purposes;
  2. made available to the Data Controller's Collaborators, as Data Officers or persons authorized to process personal data;
  3. communicated to third parties, individuals or companies, public administrations, professionals, law enforcement agencies, government agencies, regulatory bodies, courts or other public authorities authorized by the law;
  4. if necessary, transferred to another Data Controller in accordance with the provisions of the GDPR, including with regard to the right to data portability;

The list of personal Data Protection Officers is available at the Data Controller's headquarters.

5. Disclosure and Transfer of Personal Data

We may disclose your Personal Data to third parties and legal and regulatory authorities and transfer Personal Data outside the European Economic Area (EEA), as described below.

Information to third parties

There are certain circumstances in which we may transfer your personal data to employees, contractors and other parties.

  1. We may share information about you with other members of our group of companies so that we can provide the best service to our group. They are required to keep your information in accordance with this Privacy Policy;
  2. We may also share your information with certain suppliers or service providers. They can process your personal data for us, for example, if we use a marketing agency. Other recipients/service providers include ad agencies, IT specialists, database vendors, backup and disaster recovery specialists, email providers or outsourced call centres. Our suppliers and service providers will be asked to meet our standards on information processing and security. The information we provide, including your information, will be provided only in relation to the performance of their function;
  3. We may also share your information with certain other third parties. We will do so when we receive your consent or because we need to share your information with them in order to provide you with products or Services. These include credit reference agencies, anti-fraud databases, screening agencies and other partners with whom we do business.

Your personal data may be transferred to other third-party organizations in specific scenarios:

  1. If we are discussing the sale or transfer of part or all of our business, information may be transferred to potential buyers according to the appropriate terms of confidentiality;
  2. If we are reorganized or sold, the information can be transferred to a buyer who can continue to provide Services to the User;
  3. If required by law, or by any legal code or practice that we follow, or if requested by a public or regulatory authority, such as the police;
  4. If we are defending a lawsuit, your information may be transferred as required in connection with the defence of that lawsuit.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Your information will not be sold, exchanged or shared with third parties without your consent, except to provide CoinPlaza Services or as required by law.

CoinPlaza's third-party service providers are contractually obliged to protect and use such information only for the purposes for which it was disclosed, unless otherwise required or permitted by law. We guarantee that such third parties will be bound by terms that comply with our section on the GDPR.

Communications to Legal Authorities

We may share your personal data with law enforcement agencies, data protection authorities, government officials and other authorities when:

  1. Obligated by court order or other legal procedure.
  2. Disclosure is necessary to report suspected illegal activity.
  3. Disclosure is required to investigate violations of this Privacy Policy or our Terms of Use.

6. Information on the processing of data in connection with the transfer of funds

In order to carry out national and international financial transactions (e.g. bank transfers) requested by the Data Subject, CoinPlaza will have to inform the bank of the data necessary for the execution of the transactions (e.g. the names of the originator, beneficiary and the respective banks, bank details and amount).

7. Categories of Personal Data

No particular categories of personal data are dealt with (those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, data concerning health or sexual life or sexual orientation of the person). The personal data processed is only and exclusively that necessary and functional to the correct achievement of the purposes indicated in point 2 which, by way of example, include name, surname, address and email address.

With regard to the purposes of fulfilling the obligations set out in the Consolidated Anti-Money Laundering Act, the personal data requested is that necessary for the identification of the Customer, for example:

  1. Contact information, such as name, surname, residence or domicile address (if different from residence) and email address;
  2. Account information, such as Username, password, Account settings and preferences;
  3. Financial information, such as bank Account numbers, bank statements, credit/debit card details and business information;
  4. Identity verification information, such as images of the identity document, passport, identity card or driver's licence issued by the government, date and place of birth, tax code, details of the identification document and date of issue and expiry, profession, sector of activity, etc.
  5. Information on residence verification, such as bill details or similar information;
  6. Information on how we use our Services, for example when using our Services and the specific Services used;
  7. Information relating to communications with us, through the CoinPlaza Website or via email, by telephone or by any other means.

The Services offered by CoinPlaza are offered to Users in compliance with the General Data Protection Regulation (GDPR).

8. Data Retention

The data provided for the purposes referred to in point 2 herein, shall be kept:

  • for administrative/Accounting purposes: for the period prescribed by tax laws, civil law;
  • for marketing and profiling purposes and sending newsletters: up to the revocation of the consent given, up to the exercise of the right to opposition and in any case not longer than ten years from the date of collection;
  • for purposes referred to in the Consolidated Anti-Money Laundering Act: ten years from the termination of the continuous relationship, the professional service or the execution of the occasional transaction.

Personal data will not be disseminated and will be destroyed when no longer needed or we are under no obligation to keep them.

CoinPlaza processes and stores the personal data of the Data Subject for the entire duration of the contractual relationship, for the execution of the obligations related to it and deriving from it, for compliance with the applicable legal and regulatory obligations, as well as for its own or third-party defense purposes, until the end of the data retention period. The retention period of the Data Subject's personal data starts from the termination of the contract relating to the Services of the CoinPlaza Platform;

CoinPlaza is obliged to inform other Data Controllers who process the personal data for which the Data Subject has requested cancellation of such cancellation request.

At the end of the applicable retention period, personal data relating to the Data Subjects will be deleted or stored in a form that does not allow identification of the Data Subject, unless its further processing is necessary for one or more of the following purposes:

  • resolution of pre-litigation and/or litigation initiated before the expiry of the retention period;
  • to follow up investigations/inspections by internal control functions and/or external authorities which initiated before the expiry of the retention period;
  • resolution of pre-litigation and/or litigation initiated before the expiry of the retention period;

During their normal operation, the computer systems and software procedures used to operate the Platform of this Website will acquire some personal data, whose transmission is implicit in the use of internet communication protocols. This information is aggregated to provide statistical data on the actions and browsing behavior of our Users and does not personally identify people.

This information can include:

  • Information about a computer or mobile device, including IP address, operating system, network system, browser type and settings;
  • Information on the use of the Website: the Uniform Resource Identifier (URI) of requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.).

Finally, we may collect Personal Data from third-party partners and public sources, which includes:

  • Reputation information;
  • Financial information;
  • Business activities of corporate clients.

It is important to note that the Personal Data we collect about you when you create an Account will be retained for the mandatory retention period established by applicable law and, if necessary, to maintain a comprehensive record of our operations as required by applicable regulations, even if your Account has not been successfully activated (e.g. if the Account verification has not been completed) or no transaction has been carried out.

9. Processing Methods

The personal data subject to the processing shall be processed:

  • manually and/or electronically and shall be stored in appropriate paper and/or electronic archives. The paper and electronic documentation will be correctly maintained and protected for as long as necessary for the processing using appropriate security measures, so as to minimize the risk of destruction or loss, unauthorized access or any processing that is not in accordance with the purposes of collection;
  • There is an automated decision-making process and profiling is carried out for the sole purpose of fulfilling the obligations set out in the Consolidated Anti-Money Laundering Act on risk assessment. In this regard, the Data Subject has the right to oppose such processing if he believes that the same produces undesirable legal effects or has a significant effect on his person in which case, however, it will be impossible to continue the relationship.

10. Cookies

The CoinPlaza Platform uses cookies. Cookies are small text files that are stored on your computer by the Websites you visit and are used to provide Services and/or information. Most cookies are "session cookies" and are then deleted from the hard disk at the end of the session (when you log out or close the browser). Persistent cookies can also be present on some pages of the Website in order to analyze access to web pages, customize their Services, contents and advertising messages, measure the effectiveness of promotions and ensure trust and security.

The session cookies used on this Website avoid using other computer techniques which may jeopardize the confidentiality of Users’ browsing data and not allow the acquisition of the User's personal identification data.

Our policy on the use of cookies on our Website is available in the dedicated section.

11. Data Provision

Besides what is specified for browsing data, the User is free to provide their personal data requested through special forms relating to Services, products and any other kind of request that the Website administrator, or their business partners, can offer.

With regard to the data necessary to fulfil the obligations set out in the Consolidated Anti-Money Laundering Act, its non-conferment will make it impossible to use the Services or products that the Website manager, or its business partners, can offer.

The personal data collected between the User and CoinPlaza for the use of the Services are of two distinct categories depending on whether you want to use the Services only for the exchange and negotiation of virtual currencies between them, or if you also want to access the Services for the conversion, purchase and sale of virtual currencies in exchange for currencies having legal tender or vice versa.

Failure to provide this data may render it impossible to authenticate yourself in the reserved area.

Registration in the reserved area involves the automatic acquisition of data (mandatory), such as:

  • time, date, page views and dwell time;
  • IP protocol and internet domain;
  • the "referrer" (if applicable) through which access to the Website has occurred;
  • User's operating system and type of browser.

12. Rights of the Data Subject

We hereby inform you that, as a Data Subject, you have all the rights foreseen by Articles 15-16-17-18-20-21-22 of the GDPR, among which:

  • The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  • the existence of the data subject's right to request the data controller to access personal data and to correct or delete it or limit its processing or to oppose its processing, in addition to the right to data portability, including all available information on its origin; to obtain, moreover, the erasure of their personal data without unjustified delay pursuant to Article 17 ("right to be forgotten").
  • where the processing is based on Article 6, paragraph 1, letter a) or Article 9, paragraph 2, letter a), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent prior to such withdrawal;
  • the right to lodge a complaint with a supervisory authority;
  • to receive a copy of the personal data being processed from the data controller, as long as this does not damage the rights and freedoms of others; in case of further copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. Should the data subject make the request by electronic means, and unless otherwise requested, the information shall be provided in a commonly used electronic form;

The above information will be provided:

  • within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data is processed;
  • in the event that the personal data is intended for communication with the data subject, at the latest at the time of the first communication to the data subject; or if communication to another recipient is envisaged, no later than the first communication of personal data.

All rights of the data subject provided for by the GDPR are exercised by request without formalities to the Data Controller, also through a Data Processing Officer, who is provided with appropriate feedback without delay.

Last edit: 03/01/2019 12:28:26
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Please be aware that there is a significant risk of loss of the digital currencies held.

Before finalizing any transaction in Cryptocurrencies, the Customer should consult a legally qualified financial advisor. Purchasing and investing in Cryptocurrencies can lead to the loss of the investment both in the short and on the long term due to possible significant price fluctuations.

It is expressly understood that the Customers will be the sole responsible for determining the tax regime applicable to them with regard to the acquisition, transfer and possession of Cryptocurrencies.

The exchange of real or virtual goods and products, as well as virtual currencies, involves significant risks. Prices fluctuate significantly even in a few hours on a given day. Due to such price fluctuations, you may increase or lose value in your assets at any given moment. Any currency - virtual or not - may be subject to significant value fluctuations and may even become worthless. There is an inherent risk of loss as a result of buying, selling or trading any currency - as with any commodity - on a market.

The sale of cryptocurrencies also presents special risks not generally shared with official currencies or goods in a market. Unlike most currencies, which are supported by governments or other legal entities, or commodities such as gold or silver, cryptocurrencies are a special type of currency, backed by technology and trust. There is no central bank like for legal currencies (FIAT currencies) that can take corrective measures to protect the value of cryptocurrencies in the event of a crisis or to issue more currency.

Bitcoin and other cryptocurrencies each constitute a self-contained and largely unregulated world system of monetary corporations and individuals. Traders trust a decentralized, partially anonymous digital system that relies on the peer-to-peer network and cryptography to maintain its integrity.

Cryptocurrencies trading is likely to be susceptible to irrational (or rational) bubbles or to loss of confidence, which could cause demand to drop relative to supply. For example, confidence might collapse in Bitcoin because of unexpected changes imposed by the software developers or others, a government crackdown, the creation of superior competing alternative currencies, or a deflationary or inflationary spiral. Trust could also collapse due to technical problems: if the anonymity of the system is compromised, if money is lost or stolen, or if hackers or governments are able to prevent any transaction.

There may be additional risks that we have not foreseen or identified in our Terms of Use.

You should carefully consider whether your financial situation and risk tolerance are suitable for buying, selling or exchanging Bitcoins and other cryptocurrencies.

Last edit: 03/01/2019 12:28:26
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CoinPlaza S.r.l. ("CoinPlaza"), as a provider of Services relating to the use of virtual currency and in compliance with the provisions on anti-money laundering and international terrorism financing (see Italian Legislative Decree No. 231/2007 - "Anti-Money Laundering Decree"), has implemented appropriate safeguards to manage the relative risk aimed at preventing CoinPlaza's involvement in criminal events that may have negative consequences on its stability and reputation on the market.

Money laundering from illegal actions is one of the most serious criminal phenomena and constitutes a major source of pollution for the entire economic system: the reinvestment of illicit proceeds in legal activities profoundly alters market mechanisms and pollutes the financial system by undermining the efficiency and correctness of the economic system in general.

CoinPlaza is committed to avoiding that its products and Services offered are used for the criminal purposes of money laundering and terrorist financing.

CoinPlaza has drafted the "Anti-Money Laundering and Anti-Terrorism Policy", which is part of CoinPlaza's broader internal control system aimed at ensuring compliance with current legislation, constituting the base document of CoinPlaza's entire anti-money laundering system.

The Policy also contains an explanatory introduction to the general legislation, the circulars and the communications issued by CoinPlaza itself.

CoinPlaza provides Users: with an Internet platform that lets them buy and sell tokens or any other existing "virtual" currency, as well as allowing the conversion of virtual currencies between them or against currencies having legal tender and vice versa. In this context, transactions are protected through cryptography and are potentially vulnerable, for their anonymity, to money laundering and international terrorist financing infiltration, as indicated by the FATF (Financial Action Task Force).

The action to prevent and combat money laundering and terrorist financing by CoinPlaza is carried out through the introduction of safeguards aimed at guaranteeing adequate customer verification, traceability of financial transactions, identification of suspicious transactions and the conservation of customer data and documents. In particular, this document ("Anti-Money Laundering and Anti-Terrorism Policy") describes the general principles and criteria - in turn subject to further and precise internal regulation - implemented and managed by CoinPlaza for the fulfilment of the obligations imposed by the Anti-Money Laundering Decree because of its characteristic activity, to which employees, collaborators, customers, business exponents and business partners are required to abide.

Definition of "money laundering" and "terrorist financing"

The definition of the term "money laundering" adopted by our legislator (Italian Legislative Decree no. 231/2007, art. 2, par. 1.), as indicated at Community level, incorporates the one given by the 1998 United Nations Convention against Illicit Drug Trafficking, and consists of each of the following activities:

  1. the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
  2. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
  3. the acquisition, possession or use of property, knowing at the time of receipt that such property was derived from criminal activity or from an act of participation in such activity;
  4. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.

"Terrorist financing" is intended as any direct activity, by any means, for the collection, funding, intermediation, deposit, custody or disbursement of funds or economic resources, in any way realized, intended to be, in whole or in part, used for the purpose of carrying out one or more crimes for the purpose of terrorism or in any case aimed at encouraging the completion of one or more crimes for the purposes of terrorism provided for by the Italian Criminal Code, and this regardless of the actual use of funds and economic resources for the commission of the aforementioned crimes (Italian Legislative Decree no. 109/2007, art. 1, par. 1)

Regulatory sources

Following the implementation of the EU Directive 2015/849 (known as the IV Anti-money Laundering Directive), the national legislation on the matter has been substantially amended, extending its scope also to service providers related to the use of virtual currency, limited to the carrying out of the activity of converting virtual currencies from or into legal tender currencies.

The IV Anti-Money Laundering Directive was implemented in our legal system with Italian Legislative Decree no. 90/2017, which amended and integrated the Anti-Money Laundering Decree.

The Anti-Money Laundering Decree is based on three main pillars:

  • customer due diligence;
  • conservation of customer data and information;
  • reports of suspicious transactions.

The regulatory provisions of the Anti-Money Laundering Decree provide for the accurate census of customer information and introduce the concept of "risk-based approach" according to customer "sensitivity", bringing customer due diligence obligations in line with the risk associated with the customer, the product and the geographical area.

The national authorities called to monitor compliance with the regulations are the Ministry of Finance, the Office of Financial Information (UIF) at the Bank of Italy, the Supervisory Authorities of the individual sectors in which the subjects subject to the application of the law operate, the Anti-Mafia Investigation Department (DIA) and the Italian Finance Police (Guardia di Finanza).

Customer due diligence

Know your customer (KYC) is an essential theme of national and European legislation in the field of financial relationships between operators and customers.

Adequate due diligence of customers, in addition to setting up a valid instrument to combat money laundering and terrorist financing, protects operators from exposure to commercial and reputational risks as well as from the application of administrative, civil and criminal sanctions.

CoinPlaza carries out adequate customer due diligence and monitors activities by analyzing the following parameters:

  1. identification data/general information;
  2. legal status (for institutions);
  3. main business conducted;
  4. origin of the funds;
  5. behavior when the continuous relationship began or at the completion of the transaction;
  6. geographical area of belonging;
  7. purpose of beginning the relationship;
  8. type of transaction or relationship;
  9. amount of the transaction;
  10. reasonableness of the operation and of the relationship.

In the acquisition of customer information, CoinPlaza may also avail itself of third parties to whom the due diligence can be delegated. In particular, the delegated subject acquires at least the customer identification document and verifies its identity. In any case, the acquisition of internal and external data for each customer allows CoinPlaza to be able to determine their relative money-laundering risk profile, which will be subject to periodic monitoring based on the aforementioned risk profile.

During the relationship with the customer, CoinPlaza constantly updates the customer due diligence both during the review phase (scheduled according to the level of risk) and the occurrence of possible events such as, but not limited to, the generation of anomalies detected by the IT applications in use, reporting by the Authorities, the recognition of transactions carried out by the customer that are not consistent with the nature of the underlying relationship.

Main obligations on anti-money laundering and terrorist financing: what does CoinPlaza do?

The Anti-Money Laundering Policy adopted by CoinPlaza is inspired by the principles of the "risk-based approach". In particular, CoinPlaza:

  1. does not carry out transactions, does not accept payment orders, nor funds in legal currency from or to individuals or otherwise (companies, public or private entities) residing in all countries indicated by the European authorities as "blacklisted": Samoa; Bahrain; Guam Marshall Islands; Namibia; Palau; Saint Lucia; Trinidad and Tobago; and those indicated by the Italian Revenue Agency: the Bahamas; Barbuda and Brunei; Djibouti; Grenada and Guatemala; Cook Islands; Marshall Islands and US Virgin Islands; Kiribati; Lebanon and Liberia; Macau and the Maldives; Nauru; Nevis and New Caledonia; Oman; French Polynesia; Solomon; Samoa; Saint Lucia; Saint Vincent and the Grenadines; St Helena; Sark; Saint Kitts; Tonga; Tuvalu; Vanuatu.
  2. does not carry out transactions with banking companies that do not have a physical presence in the country in which they are established and authorized to perform the activity (shell bank);
  3. dedicates more attention and adopts enhanced measures in situations where there is a greater risk of money laundering or in the verification of persons holding or having held major public positions (politically exposed persons);
  4. does not carry out transactions involving, for whatever reason (presenters, orderers or beneficiaries) subjects registered in judicial authorities' orders; monitors outgoing and incoming operations (checks on beneficiaries and originators) and evaluates the rejected movements following similarity indices with the anti-terrorist lists;
  5. performs personal checks and makes comparisons with the names on the lists provided by the UN and the CE Regulations and other international and national agencies.

Retention of information

In order to comply with retention obligations, CoinPlaza has set up an IT register which ensures that the data management is carried out with clarity and completeness, guaranteeing the immediacy of information and ease in consulting it. CoinPlaza has identified a person to which it has entrusted the keeping of the register.

The information and data obtained are kept for ten years, as required by the current Italian Legislative Decree no. 231/2007.

Anti-Money Laundering Function Officer

CoinPlaza has appointed an Anti-Money Laundering Officer.

However, the CoinPlaza internal control system involves the entire corporate structure, from corporate bodies to control functions. CoinPlaza ensures that adequate internal controls are maintained to protect the integrity of the money-laundering risk management process and the associated reputational risk through the drafting of strict guidelines on the subject, as well as through an adequate internal organizational structure.

The updating of the Anti-Money Laundering Policy, as well as the verification of compliance with the procedures and internal provisions adopted by CoinPlaza, is entrusted to the Anti-Money Laundering Monitoring Officer who, in collaboration with other internal functions or external professionals, is called to guarantee the effectiveness of activities implemented to mitigate risks related to money laundering and terrorist financing.

Organizational/regulatory measures

CoinPlaza has implemented specific organizational/regulatory measures for the fulfillment of the obligations imposed by the Anti-Money Laundering Decree. In particular, adequate internal regulatory procedures have been set up to regulate the formalities required in order to provide CoinPlaza's corporate functions with organic consultation and support tools useful for understanding the subject.

Furthermore, CoinPlaza has equipped itself with specific IT tools both for the analysis of the anti-money laundering risk profiles to be attributed to customers and for the monitoring of "anomalous" transactions for which an analysis is carried out by the competent structures for the purpose of evaluating the same.

Reporting suspicious transactions

In order to cooperate with the Authorities to ensure the stability of the financial system and to avoid its involvement in the phenomenon of money laundering and terrorist financing, Coinplaza has adopted a structured process for the reporting of operations that give rise to suspicion about the illicit origin of the funds transferred. For this purpose, CoinPlaza has appointed a subject to report suspicious transactions, who is required to submit to the Financial Intelligence Unit (UIF) the reports in the forms and in the manner prescribed by the Authority.

Last edit: 03/01/2019 12:28:26
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