Legal

Privacy Policy

INTRODUCTION

We respect your privacy.

This section describes the ways your personal information is collected, used and protected when you visit or login to LordOfCoins` platform. Use of this platform constitutes consent to the data collection and use and security practices detailed herein. 

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we change how we use your Personal Information (as defined below), we will notify you here, by email, or by means of a notice on our home page.

The legal basis for data processing based on consent is Art. 6 Para. 1 a) GDPR.
You have the right to object at any time on grounds arising from your particular situation to the processing of personal data concerning you on the basis of Article 6(1)(e) GDPR and Article 6(1)(f) GDPR. If you object, we will no longer process your personal data unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

INFORMATION WE COLLECT

While completing our online registration form, we will require you to provide us with personal information, such as your name and contact details. You must provide complete, accurate and correct details and you hereby confirm the details you provided are correct. You are not required by law to provide the Company with your personal details. However, if you provide false, incorrect, or out dated information, or only partial information, it may impair our ability to contact you. When you provide the Company with personal details of another person, you represent and warrant that you received the other person’s explicit written consent to provide these details to the Company and use them according to this Privacy Policy. The Company may collect information pertaining to your activity on the Website, including information or content that you have read, your session durations, the web pages you watched, services that were of interest to you, the location of the computer and the Internet Protocol (IP) address through which you had access to the Website and more. Additionally, the Company may collect or use the assistance of third parties to collect and analyze anonymous, statistic or aggregative information related to your use of the Website.

USE OF COLLECTED INFORMATION

We will store the information you provide and the information we collect about your activity on the Website in our database (the “Database“). We will use the information in accordance with this Privacy Policy and any applicable law, including for the following purposes:

1) To provide the services on the Website and to enable you to use them;

2) To develop and improve our products and services as a whole, and to improve and expand the services and content offered on the Website, to create new services and content which correspond to the requirements and expectations of the users of the Website and our customers and to modify or cancel existing services and content. The information used by the Company for this purpose will be mainly statistical information, and will not identify you personally;

3) To contact you occasionally, either by the Company or by anyone on our behalf, including by sending email messages, SMS messages and information related to our services and products;

4) To conduct researches and surveys and other similar activities related to products and services development;

5) To analyze and provide statistical information to third parties. This information will not identify you personally;

6) For the orderly and proper operation and development of the Website;

7) To any other purpose specified in this Policy or in the Website’s Terms of Use.

TRANSFER OF INFORMATION TO THIRD PARTIES

We may share personal information outlined in this policy, with others, in any of the following instances: 1) With our service providers in order to operate, maintain and enhance the Website and facilitate our email communications with you; 2) If you abused your rights to use the Website, or violated any applicable law, your information may be shared with authorities or other third parties, if we believe it is necessary or justified; 3) With attorneys, courts and relevant third parties, in any case of dispute, or legal proceeding of any kind involving you with respect to the Website; 4) If the operation of the Website is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this policy, with reasonably necessary changes taken into consideration; and 5) We may share personal information with our corporate group entities (companies that we control, control us, or are under common control with us, whether directly or indirectly), but their use of such information must comply with the policy. 6) In any case other than above, your personal information will be shared with others only if you provide your explicit prior consent.

ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION AND OBTAINING A COPY OF IT

We respect your privacy rights and therefore you may contact us at any time and request: 1) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted); or 2) that we will cease any further use of your personal information (for example, you may ask that we will stop using or sharing your personal information with third parties) or that we shall remove your personal information (subject to any other legal obligation that may require us to keep the information). Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the services and to comply with our legal obligations, resolve disputes and enforce our agreements. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. If you wish to raise a complaint on how we have handled your personal information, please contact us directly at support@LordOfCoins.com. If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.

COOKIE AND OTHER TRACKERS

We use various types of cookies and other types of web trackers, which help us to administer and operate the Website. These trackers are used mainly to collect statistical information about your use of the Website; We use cookies for Website analytics purposes, as explained above. If you wish to block cookies, you may do so through your browser’s settings. You can delete cookies that are already on your computer and you can set your browser to prevent them from being placed going forward. Please refer to the browser’s help menu for further information. Please also bear in mind that disabling cookies may adversely affect your user experience on the website. We do not respond to browsers’ “Do Not Track” requests. You may have a right to submit a complaint to the relevant supervisory data protection authority, pursuant to the law.

CONTACT US

You may contact us with any questions or comments, at: support@LordOfCoins.com.

PRIVACY INFORMATION

You may contact us with any privacy or GDPR information, at: support@LordOfCoins.com.

Anti-Money Laundering

PulsarTech OÜ (“we” or “our”) has developed an Anti-Money Laundering and counter-terrorism financing Policy (“AML/CTF Program”) for our digital virtual currencies exchange, available at https://LordOfCoins.com, in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in Estonia and the European Union and other countries where we conduct business. This includes, but is not limited to: Establishing robust internal policies, procedures and controls that combat any attempted use of LordOfCoins for illegal or illicit purposes and that are designed to ensure our customer's basic protections under consumer protection laws; Maintaining comprehensive records of orders and other transfers; Executing Know Your Customer (“KYC”) procedures on all customers; Performing regular, independent audits of our AML/CTF Program; and Implementing a formal and ongoing compliance training program for all new and existing employees.

GENERAL

LordOfCoins does not tolerate money laundering and supports the fight against money launderers.

Money laundering is the act of concealing the transformation of profits from illegal activities and corruption into ostensibly "legitimate" assets. Money laundering occurs when funds from an illegal/criminal activity are moved through the financial system in such a way as to make it appear that the funds have come from legitimate sources.

POLICIES AND PROCEDURES

We have adopted a risk-based approach during the customer due to diligence procedures in line with the current AML/KYC regulations. Below you can find how we process the registration of customers` accounts, what information is collected, and how it is verified.

PulsarTech OÜ identifies the customer by obtaining a range of information about him/her. The verification of the identity consists of verifying some of this information against documents or information obtained from a reliable source that is independent of the customer. At least the following information must be received for identification purposes: name and surname; personal identity number (if such exists); date of birth; photograph on an official document which confirms his/her identity; residential address; the number of the personal identification document; the expiry date of the identification document.

Once a customer is identified and his/her identity is verified, PulsarTech OÜ must conduct a certain level of due diligence based on a risk-based approach. For some business relationships, determined by the firm to present a low degree of risk of ML/TF, simplified due diligence (SDD) may be applied; in the case of higher-risk situations, and specifically in relation to PEPs, enhanced due diligence (EDD) measures must be applied on a risk-sensitive basis.

LordOfCoins has policies in the field of counteraction of laundering money. These policies include:

• ensuring clients have a valid proof of identification;

• requiring the client to provide valid utility bills for proof of residence;

• maintaining records of identification information;

• determining that clients are not offenders or terrorists by checking special lists;

• informing clients that the information they provide may be used to verify their identity;

• following clients’ money transactions;

• maintaining records of identification information.

The AML measures which the Company generally will take:

• collect sufficient information from each Customer who has opened an account to enable the Customer to be identified;

• utilize risk-based measures to verify the identity of each Customer who has opened an account;

• record Customers’ information and the verification methods and results; provide the required adequate notice to Customers that we will seek identification information to verify their identities;

• compare Customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government. 

CUSTOMER IDENTIFICATION

The KYC process is an important part of our AML/CTF Program, and helps us detect suspicious activity in a timely manner and prevent fraud.

Account opening process:

In order to open an account and use LordOfCoins, your identity must be verified, authenticated, and checked against governmental watch lists. Failure to complete any of these steps will result in your inability to use our Services.

Individual customer — Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information: Email address; Mobile phone number; Full legal name; Tax ID Number; Date of birth (“DOB”); Occupation; Proof of identity (e.g., driver’s license, passport); Home address (not a mailing address or P.O. Box); and Additional information or documentation at the discretion of our Compliance Team, such as utility bills or bank account statements. If you successfully meet and complete our KYC requirements and do not appear on any government watch list, then we will provide you with account opening agreements electronically.

Corporate customer — Prior to opening an account for an corporate customer, we attempt to collect, verify, and authenticate the following information: Company’s legal name; Registered company number; Full legal name (of all account signatories and beneficial owners); Email address (of all account signatories); Mobile phone number (of all account signatories); Address (principal place of business and/or other physical location); Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable); Contract information of owners, principals, and executive management (as applicable); Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 25% or more, as well as all account signatories; and Identifying information for each entity beneficial owner that owns 25% or more (see individual customer information collected above for more details). If your institution successfully meets and completes our KYB requirements and neither it nor any of its owners, principals, executive, or managers appear any governmental watch list, we will provide you with account opening agreements electronically.

SUSPICIOUS ACTIVITY/ CURRENCY TRANSACTION REPORTS

Broad categories of reason for suspicion and examples of suspicious transactions are indicated as under: 

Identity of client:

a) False identification documents.

b) Identification documents which could not be verified within reasonable time.

c) Accounts opened with names very close to other established business entities.

d) Background of Client: suspicious background or links with known criminals.

e) Multiple Accounts: large number of accounts having a common account holder.

Activity in accounts:

a) Unusual activity compared with past transactions.

b) Sudden activity in dormant accounts.

Nature of transactions:

a) Unusual or unjustified complexity;

b) No economic rationale or bonafide purpose;

c) Nature of transactions inconsistent with what would be expected from particular Customer.

We may freeze or suspend your account, as well as report to applicable authorities, if we know, suspect or have reason to suspect suspicious activities have occurred on LordOfCoins. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our compliance team reviews and investigates suspicious activity to determine if sufficient information has been collected to justify any action from our side.

RECORDS KEEPING

All records are retained for five (5) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

AML related data processing consent

By registering the account on LordOfCoins users (clients) agree, that their personal data can be processed with World-check software in order to receive detailed information on the user that may be related to them being a Politically Exposed Person (PEP), person affiliated to PEP or any other anti-money laundering legislation compliance flags that may arise.

AML documentation

During account registration user (client) must prove their identity by submitting a photocopy of their valid identification document (passport, ID card, driver’s license etc.) User (client) also must submit proof of address (bill of fixed service, bank statement etc.) LordOfCoins may ask for extra documentation according to it’s risk assessement and AML/KYC policies.

KYC Policy

Know Your Customer (KYC) Protocols

Protecting consumers from fraudulent activity has become a major objective for banks and financial institutions worldwide. This is why we have implemented Know Your Customer (KYC) processes, which protect you from identity theft, money laundering, financial fraud and more. KYC policies also address the possibility of terrorist activities.

We have a zero-tolerance policy with regards to fraudulent or illegal activities on our platform. We have gone out of our way to take all possible precautions. All accounts related to fraudulent activities will immediately be shut down.

Prevention of fraud

Our strategy to combat fraudulent and illegal activities is proactive and comprehensive. Our security measures protect your personal information that you have provided. You can be sure that the Lord of Coins will do everything within our power to stop fraudulent activity before it even starts. This is why all users are required to verify their identity. In this way, we know who is using our platform and this in turn, ensures the exchange is safe for everybody to use.

Definition of ‘Customer’

We define ‘Customer’ for purposes of KYC implementation like the following:

• An individual with an account with the specified Company and/or one who maintains business relationships with said Company;
• An individual account holder with the Company who has engaged in a financial activity or any financial transactions with the Company;
• An individual who is the beneficiary and the owner of a registered Account which is maintained;
• Any other party or individual connected with any financial transaction which poses potential risks to the Company’s reputation or other risks that could harm the Company.

The standards related to relationships between the Customer and the Company are the following:

Using a fictitious name to open an account or opening an account anonymously is prohibited;

We only accept new Customers after they have completed the identity verification process. Users must also declare themselves to be 18 (eighteen) years of age or older. Also, the Company will verify the identity of a Customer to ensure he or she does not have a criminal history or have relationships with prohibited entities;

Customers are classified via various categories of perceived risk, with criteria to meet each category of risk. If necessary, Politically Exposed Individuals may be classified as part of the High-Risk Category, which will result in extraordinarily higher scrutiny and monitoring of the Customer.

The Company will require identifying documents as well as other information, which the Company will collect according to various Customer perceived risk categories and Anti-Money Laundering regulations.

In the case of an identity of the Customer not being able to be verified, no accounts are to be opened or closed. If information or documents cannot be confirmed according to relevant risk categories, due to non-cooperation from the Customer or unreliability of information submitted, no account will be permitted to be opened or closed.

In cases of Politically Exposed Persons (PEP), decisions regarding whether or not to open new accounts will be made by senior management. Some cases will require the implementation of harassment safeguards of the said account holder. For example, a Customer’s account may be closed after he or she has been provided due notice including an explanation of the reasoning for making such determination.

No Customer will be allowed, under any circumstances whatsoever, to act on behalf of any other individual.

Know Your Customer (KYC) and Anti-Money Laundering (AML) measures to ensure that before acceptance of funds from the Customer, all reasonable and pragmatic protocols have been implemented to verify Customer identity. Additionally, the Company will verify any third party, which the Company relies upon for Customer identification, such as a financial services company or banking firm, is also in compliance with the same rules as the Company.

These Customer identification protocols assume the Company will accept funds received from an existing and a new Customer only if he or she has met the following criteria:

The Company has confirmed the identity of the individual and has verified the individual is not acting on the behalf of a third party without specifically disclosing such relationship to the Company;

or:

If the Customer is acting on behalf of, or in order to benefit a third party, and the Company has confirmed the identities of any and all third parties.

Identity of a Natural Person

The Company will take actions necessary and reasonable to ascertain satisfactory evidence that provides verification of a Customer’s full name, place and date of birth, location of employer and source of deposited funds. The Company, for confirmation of Customer identity, will require the Customer to submit copies of specified documents listed as follows:

• Passport or other identifying document issued by an applicable government;
• Power of attorney documents (if relevant, along with contact details of entity or individual who granted the power of attorney).
• Declaration of Application Form including Due Diligence along with the following:
• Identifying details of the applicant
• Applicant’s Address
• Source of income, annual income, occupation and shareholder category
• Banking details
• Settlement, custody and clearing agent
• Photograph of individual along with a handwritten note with identification documentation

• The following documentation may be required:

  • Utility bills or bank statements; or other documents that identify the residence of Customer
  • Banking references

   The Company’s Compliance Officer permanently retains a right to request additional documentation from the Customer to comply with KYC and AML standards as well as to carry out further investigation of any potentially suspicious activities, such as identity theft or money laundering. The Company has the right to discontinue cooperating with the Customer or to decide against entering a relationship with the Customer if the Customer fails to refute or disprove any suspicion. The Company reserves the right to report to appropriate authorities any and all illegal activities.

Identification of Entity

Reasonable actions will be taken by the Company to verify satisfactory evidence that proves the accuracy of the entity Customer’s name, address and authority to make investment decisions. The Company will obtain from the Customer the following documents:

• Declaration over Application Form along with Basic Due Diligence which includes:

1. Entity name
2. Description of the entity’s economic activities
3. Entity’s address
4. Relevant registration number(s)
5. List of directors, executives and shareholders
6. Ultimate beneficiary’s identifying information and details
7. Tax ID number(s)
8. Applicable license information
9. Supporting documents including:

• Copy of resolution granting Directors/Principals the authority to act;
• Articles of Memorandum and Articles of Association;
• Certificate of Incorporation;
• List of Principals/Directors
• Complete list of the authorized signatories
• Publicly available information from law enforcement and regulatory agencies;
• If applicable, annual report, or banking references;
• Applicable license(s);
• Passport or other documents issued by a relevant government, bank references, bank statements, utility bills and curriculum vitae of the final beneficiary owner.

The Company’s Compliance Officer permanently retains the right to request additional documents from the Customer in accordance with KYC and AML rules and to aid in the investigation of any possible suspicious activities, such as identity theft or money laundering. The Company has the right to discontinue any cooperation with the Customer or to decline to enter into a relationship with the Customer if the Customer does not refute any suspicion of illicit activity. The Company retains the right to report suspicious activities to law enforcement or other appropriate agencies or regulators.

Definition of High-Risk Customers

An updated list of types of Customers categorized as “high-risk,” requiring additional due diligence procedures in comparison to normal procedures for Customer identification, shall be maintained by the Company.

This is a list of examples of types of Customers categorized as high-risk:

• High-Level Foreign Political Figure or Official or an immediate family member of the official or figure (Politically Exposed Persons, also known as PEPs, defined by recommendations from FATF are also included);
• High-Level Domestic Political Official or Figure, any immediate family of High-Level Domestic Political Official or Figure, and any Close Associates of Senior Domestic Political Official or Figure (Politically Exposed Persons, also known as PEPs, defined by recommendations from FATF (Financial Action Task Force) are also included);
• Any Customer who is a resident in, or chartered or organized under laws of, any Non-Cooperative Jurisdiction;

Note: Non-Cooperative Jurisdiction is a reference to any foreign nation which has been designated as non-cooperative in relation with anti-money laundering (AML) standards or procedures of an intergovernmental organization or group, such as the FATF.

• Any Customer giving the Company’s Compliance Officer reason to believe Client funds are originating from, or are being routed via, an account at an “offshore bank,” or bank chartered or organized under laws of any Non-Cooperative Jurisdiction; and
• Any Customer giving the Company’s Compliance Officer reason to suspect the source of Client funds may be illegal or may potentially aid terrorism.

The Company may reject cooperating with the Customer due to association with the following Non-Cooperative Jurisdiction countries and territories:

United States

New York (NY)

Georgia (GA)

Connecticut (CT)

New Mexico (NM)

Washington (WA)

Hawaii (HI)

Afghanistan

Bosnia and Herzegovina

Cuba

Ethiopia

Iran

Iraq

Democratic People’s Republic of Korea

Lao People's Democratic Republic

Sri Lanka

Sudan

Syrian Arab Republic

Trinidad and Tobago

Tunisia

Uganda

Vanuatu

Yemen

Lebanon

Serbia

Algeria

Bangladesh

Bolivia

Cambodia

China

Kyrgyzstan

Macedonia

Nepal

Nigeria

Thailand

High-Risk Client Identification

The Company will take any action which is reasonable and necessary to verify the evidence of the full name and residential address of any High-Risk Customer. The Company will confirm the following, in a manner that is appropriate for relevant circumstances. The Company may subject High-Risk Customers to enhanced due diligence processes, including increased compliance requirements.

Additionally, for all required documents, which verify the identity of an entity or natural person through basic requirements for due diligence, increased requirements for due diligence will include but are not limited to the below:

• Assessment of Client’s business history and reputation through an examination of professional and financial references, media reports which are publicly available or through other means;
• Scrutinizing source of wealth of Customer, including economic activity which generates wealth and income and source of specified funds intended to be used for investments;
• Reviewing information publicly available, such as media reports, to determine if any civil or criminal enforcement actions have been taken against Customer in relation to violations of anti-money laundering laws or
• if Client has been subject to any investigation, indictment, conviction or civil enforcement action in relation to the financing of terrorist activities;
• Requiring a meeting in-person with Customer to discuss and confirm submitted documents to open a new account;
• Review of any recent changes in ownership or senior management of entity;
• Requiring a visit to the place of business of Customer in order to conduct a meeting in-person to verify account application, the source of assets and the purpose of opening a new account

The Company’s Compliance Officer permanently retains rights to request additional documents from the Customer in accordance with KYC and AML rules and to aid in the investigation of any possible suspicious activities such as identity theft or money laundering. The Company has the right to discontinue any cooperation with the Customer or to decline entering into a relationship with the Customer if Customer does not refute any suspicion of illicit activity. The Company retains the right to report suspicious activities to law enforcement or other appropriate agencies or regulators.

Requirements for Identification for Transactions

The Company has the right to request documentation to comply with AML/KYC measures. The list of documents required may vary and will depend upon the total sum of transactions.

Please pay attention that Client is obliged to provide all the documents requested by the Company. Client is obliged to provide all requested KYC documents within 72 hours after he made Bitcoin purchase from LordOfCoins. If Client failed/refused to provide requested documents to the Company and does not cooperate with LordOfCoins, the Client shall be imposed to pay liquidated damages in the amount of 2,500 EUR without any proof of damage. In addition, the Company will be able to file a lawsuit and initiate legal actions against Client.

KYC Requirements for Credit Cards:

• Identifying Documentation - Any amount.
• Copy of front and back of credit card - For transactions higher than 750 euros (EUR).
• Proof of Address of Residence - For transactions higher than 750 euros (EUR).
• Declaration of Purchase - Any amount (Signed online).
• Photograph of self along with ID and handwritten note - For transactions higher than 5,000 euros (EUR).
• For transactions totaling more than 30,000 euros (EUR), the Company may require verification via phone as well as verification of funding source.

KYC Requirements Related to Bank Transfers:

• Identifying Documentation - Any amount
• Copy of front and back of credit card - Any amount
• Proof of Address of Residence - Any amount
• Declaration of Purchase - Any amount (Signed online)
• Photograph of ID along with self and handwritten note - For transactions higher than 5000 euros (EUR).
• For transactions totaling more than 30,000 euros (EUR), the Company may require verification via phone as well as verification of funding source.

NOTE: CLIENTS WILL RECEIVE PURCHASED BITCOIN AFTER THE FULL VERIFICATION PROCESS HAS BEEN COMPLETED WITH LORD OF COINS.

KYC Policy updates

Lord of Coins may adjust, change or update KYC policies and measures in order to comply with current rules and international laws. 

If you have questions or concerns, we will be ready to help find solutions. Simply contact our customer service team by sending an email to support@LordofCoins.com.