1. INTERPRETATION AND DEFINITIONS
    1. As used in these Terms, including the preamble hereof, unless expressly otherwise stated or evident in the context, the following capitalised terms and expressions shall have the following meanings:
      1. Account – the account opened at Fintegri by a User, using which the User can access the Services.
      2. Apps – the Android, web and iOS mobile apps of Fintegri, which give access to the Services.
      3. Fintegri – Fintegri Global OÜ, an Estonian limited liability company registered under registry code 14560487. References to “we”, “us” and “our” mean references to Fintegri.
      4. Party – each of the User and Fintegri.
      5. Services – services provided by Fintegri to the Users on the Website (such as the Wallet Service and the cryptocurrency conversion service, if applicable).
      6. Taxes ‒ taxes, levies, duties or similar governmental assessments of any nature, including, for example, value-added, sales, use or withholding taxes, assessable by any jurisdiction whatsoever.
      7. Terms – these Terms and Conditions, as amended from time to time.
      8. User – anyone who uses the Website, Apps and/or Services provided by Fintegri. References to “you” and “your” mean references to the User.
      9. Wallet ‒ the User’s cryptocurrency wallet, which can be accessed via the Website.
      10. Wallet Service ‒ regulated service of a cryptocurrency wallet.
      11. Website – website located at http:// or https://[...]/ and all subdomains of such website. Reference to “Website” also means a reference to the App. However, the reference to Website shall not mean or include any content from websites linked from Website.
    2. In these Terms, unless the context otherwise requires, a reference to:
      1. a Section is a reference to a section of these Terms;
      2. a person shall include a reference to its legal successors and permitted assigns;
      3. words denoting the singular include the plural and vice versa, words denoting persons include physical as well as legal persons; and
      4. a document is a reference to that document as may be amended or supplemented from time to time.
  2. GENERAL TERMS OF USE
    1. By using or registering on the Website or App by opening a User Account or otherwise, you acknowledge that you have read and understood these Terms, you fully agree to all the terms and conditions contained in these Terms and agree to comply with the Terms.
    2. If a User does not agree to the terms and conditions contained in these Terms, then the User shall abstain use the Website and the Services.
    3. If you have any questions regarding these Terms, Website or the Services, please contact […].
    4. The Website and the Services offered by Fintegri are NOT ADDRESSED TO AND MAY NOT BE USED BY:
      1. persons who are NOT at least 18 years of age;
      2. /PLEASE ADD IF RELEVANT/
    5. The Services are governed by Fintegri’s specific service conditions which apply in addition to these Terms. Some Services are offered by Fintegri’s partners and these services are subject to the partner’s specific conditions and terms. Fintegri has no obligations nor takes it any liability for such Services.
    6. Fintegri has the right to modify the Service descriptions and contents of the Website, and/or the Terms, without prior or any other notice.
    7. Fintegri offers content on the Website on reasonable efforts basis. Fintegri does not guarantee the absence of errors on or availability of the Website and takes no liability for such defects or unavailability. The User uses the Website fully and only at his/her own risk.
    8. Fintegri is not responsible for any damage that may arise in connection with the use of the Website and the information available on the Website, nor does Fintegri issue any guarantees concerning the absence of errors on the Website or in the information available thereon. If User notices an error in the functioning of or information on the Website, the User shall notify this to Fintegri in writing with relevant details, and shall abstain from using such function or information.
    9. All information available on the website, including the page layout and software, is protected with intellectual property rights. The information available on the Website, as well as the data contained therein, may not be reproduced, distributed or otherwise transferred to third parties without Fintegri's prior written permission.
  3. DISCLAIMER NOTICE
    1. Information available on the Website is not an offer or invitation to buy any investment-related advice or other product or service, nor an offer to sell these to the User in a country where such offer or advertisement is not permitted or cannot legally be carried out, or to the persons to whom targeting such an offer or advertisement would be illegal. If you have decided to use the Website, you do so at your own initiative and risk and are responsible for compliance with all laws, rules and regulations which apply to you.
    2. Each User acknowledges that using the Services involves various types of risks, including but not limited to risks relating to the fluctuation of the value of any assets related to the services, technical imperfections of Fintegri’s or other cryptocurrencies, the Website, regulatory uncertainties, and risks related to the operations and financial viability of Fintegri.
    3. It is the obligation of each User to learn about and understand all the risks involved with the Services. Fintegri strongly advises each User not to use the Services or any other referred products without sufficient understanding of the risks involved.
    4. Taking into account the above Fintegri strongly encourages each User to consult with a financial advisor or other appropriate professional prior to starting to use any Services.
  4. USER REGISTRATION (account)
    1. In order to access the content or use the Services offered on or via Website, Fintegri may require the User to open an Account on the Website, pass the identification process and conclude agreement(s) specific to the Service.
    2. Any use of the Services must be carried out by the User exclusively through the Account opened for the User. One digital identity associated with the Account will be used for accessing all Services. If a User represents many principals, the digital identity will be associated with the principal and principal shall be deemed to be the User.
    3. Fintegri has the right to decide whether to open, suspend or close an Account and/or whether to provide Services to any persons, regardless of the reason, and shall have no obligation to justify or outline the reasons for any rejection, suspension or closure.
    4. The User warrants that any information that the User provides to Fintegri at any time (including but not limited to the information provided upon the opening of the Account, at each login to or other access of the Website) is accurate, current, complete, in the lawful possession of the User and is not misleading in any respect. Fintegri may, from time to time, request such information to be updated and/or supplemented, in which case the User shall provide Fintegri with the updated and/or supplemented information without delay. If the User is not able or willing to update such information, Fintegri has the right to suspend or close the User’s Account and/or restrict the User from accessing the Services.
    5. User fully acknowledges that Fintegri does not provide to the User any investment service or advice. Any information provided by Fintegri on its Website or Apps is not an investment advice or recommendation, and independent professional advice should be sought where appropriate.
    6. Information on the fees payable for the Services is accessible through or on the Website.
  5. PRIVACY STATEMENT, COLLECTION OF PERSONAL DATA
      What are Personal Data?
    1. Personal data is information that directly or indirectly identifies you (the User) as an individual, indirectly meaning when combined with other information, for example, your name, username, postal address, email address and phone number, a unique device identifier such as the IMEI or the MAC-address or the IP address.
    2. How do we collect information about you?
    3. We collect information about you in the following ways:
      1. When you register or try to register yourself on the Website as a User;
      2. When you use Services;
      3. When you interact with us;
      4. /…/
    4. We collect the information provided by you:
      1. Name, surname, personal identity number;
      2. Date of birth;
      3. Place of birth;
      4. Nationality;
      5. Phone number;
      6. Address;
      7. E-mail address;
      8. Credit card or other data payment;
      9. Details and data from your passport or other documents of identification;
      10. /PLEASE CHECK AND ADD SERVICE SPECIFIC DATA THAT WILL BE COLLECTED, STORED etc/
    5. What information we collect about you and why?
    6. Fintegri processes the User’s personal data which have been submitted to Fintegri under the Terms, terms of a Service, or obtained by Fintegri by any other means. Such information may include:
      1. the data listed in Section 5.3;
      2. information you have submitted on the Website;
      3. information we get through your interaction with us and your use of Services, such as device information (e. g. hardware model, operating system version, device identifiers or phone number); log information (e. g. IP addresses, system activity, hardware settings, browser type and language, the date and time of your request); cookies (that are small text files that the browser installs on your computer or other device through our website); web beacons (these are tiny images or objects embedded in a web page or email and are usually invisible to you, but allow us to verify whether you have viewed the page or email in question. Web beacons generally function in combination with cookies and we use the two in the same manner); customer behaviour on the website like clicks, scrolling, mouse movements, session tracking;
      4. /NEEDS TO LIST ALL DATA CATEGORIES GOING TO BE PROCESSED/
    7. Please also refer to our Cookies’ Policy for full details regarding cookies and web beacons used at our website, including their management, specific purposes, categories of data they help to store and periods they are active for. This is a separate document that the User can agree to, and withdraw from, independently of these Terms. Acceptance, renewal and withdrawal from Cookies’ Policy shall be separately offered to the User on the Website.
    8. Fintegri is a data controller in respect of your personal data collected on the Website or in relation to the Services and processed in respect of providing content of the Website or Services to the Users.
    9. Fintegri has appointed a Data Protection Officer, who is […] and who can be reached via […]. Fintegri can be reached via email […].
    10. Fintegri is processing Users’ personal data for the performance of or entering into a contract, in the form of the Terms, concluded or to be concluded with the User. Each User’s personal data is processed for the purposes of providing content of the Webpage or the Services to the User. Without processing the User’s personal data, Fintegri would be unable to provide Services to the User.
    11. Depending on your use of the Services, Fintegri may collect and use your personal data for the following purposes:
      1. registering you as a User of the Services and enabling you to use the Website and Services;
      2. ensuring that the Website and Services’ content is presented to you in the most effective manner;
      3. providing Services;
      4. processing and handling complaints or requests;
      5. helping us in evaluating, correcting and improving our products and services;
      6. marketing, including providing you with information that you requested from us (for instance direct marketing, provided you have given respective consent);
      7. notifying you about certain changes to our Website or Services.
    12. For complying with our legal obligations deriving from applicable legislation and for meeting our accounting/financial obligations, we are also processing Users’ personal data on the basis of legislation. For complying with our legal obligations Fintegri may collect and receive data from other sources than the User, e.g. from public and non-public sources.
    13. For entering into a contract and for the performance of a contract between the User and Fintegri, Fintegri is applying certain automated decision-making methods to assess the User’s capability and suitability to enter into a contract between the User and Fintegri. Fintegri is applying the capability of human-intervention into the aforesaid assessment, however, in cases the User is seen as not suitable for entering into the contract, in the form of the Terms, Fintegri has the right not to enter into or stop the performance of the contract.
    14. Whom do we disclose information to?
    15. The personal data of Users is being processed by the following categories of data recipients:
      1. Fintegri’s employees or group enterprises, responsible for specific tasks regarding the Services,
      2. data processors who help Fintegri with providing the Services (e.g. service providers for the maintenance of our IT-systems and for fulfilling our contractual and legal obligations), and
      3. third persons to whom Fintegri is required to transfer data under applicable legislation, e.g. relevant state institutions and sector-specific authorities.
    16. Fintegri has engaged several third-party service providers, to assist ensuring of and improve the quality of Services. Some of these have access to your personal data. While providing services to Fintegri, such third parties process your personal data as data processors, unless you have a separate agreement with such service providers. In such case please acquaint yourself with the relevant data processing activities and read and review the privacy policy of such controllers.
    17. The list of data processors is available at www.[…].
    18. Certain activities of Fintegri may result in the transferring of personal data to third countries, meaning countries located outside the EU/EEA, and to countries in relation to which the EU Commission has not issued an adequacy decision, e.g. the US. For ensuring that the User’s data is protected, Fintegri applies appropriate safeguards in the form of standard data protection clauses adopted by the European Commission for the transfers. In case the User wishes to know more about the safeguards and obtain a relevant copy of them, please contact Fintegri using the details specified in Section 5.7 above.
    19. Fintegri is not responsible for the actions and processing activities of any third parties who act as data controllers. Such third parties are considered to be separate data controllers, whose services can be procured by concluding separate agreements with them. These third parties may transfer Users’ personal data to third countries and process it for independent purposes. Users are free to exercise their rights as data subjects in relation to such data controllers fully and independently.
    20. How long do we store information about you?
    21. Users’ personal data is, generally, retained as long as the User is using the Services. After the User has stopped using the Services and/or the Account of the User has been closed, the User’s personal data shall be retained as long as any claims can be presented on the basis of such data under applicable legislation, plus 1 year. Certain data, e.g. data necessary for accounting purposes, data obtained for the purposes of the fulfilment of obligations related to anti-money laundering and terrorist financing prevention, shall be retained as required under applicable legislation and industry standards.
    22. How do we protect your information?
    23. We maintain physical, technical and administrative safeguards to help protect the privacy of data and personally identifiable information you transmit to us. We update and test our security technology on a regular basis. We restrict access to your personal data only to staff, who need to know that information to provide services to you. We also train our staff about the importance of confidentiality and ensuring the privacy and security of your information. We encrypt the data in our systems and during transfer, as well as maintain high availability solutions to ensure accessibility to your data. If we suspect that any personal data about you has been lost and might be accessed by a third party, you will get a personal notice from us.
    24. What are your rights?
    25. We process your data; therefore, you have the opportunity to find out what we do with it and how, and in some cases ask us to process it to a lesser extent.
    26. As a User and data subject you are, at any time, entitled to exercise the following rights:
      1. the right to request the correction of the User’s personal data;
      2. the right to request access to the User’s personal data;
      3. the right to request the erasure of the User’s personal data;
      4. the right to request the restriction of processing of the User’s personal data;
      5. the right to object to the processing of the User’s personal data;
      6. the right to exercise data portability in cases where such data has been provided for the performance of or entering into a contract or has been provided under the consent; and
      7. the right to lodge a complaint to a supervisory authority: Andmekaitse Inspektsioon (Data Protection Inspectorate), www.aki.ee.
    27. We will try to fulfil your request within 30 days. However, the period may be extended due to specific reasons relating to the specific legal right or the complexity of your request.
    28. In certain situations we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will advise you of the reason for the refusal.
    29. In some cases, we may not be able to clearly identify you on the basis of your personal data due to the identifiers which you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification.
    30. Before you lodge a complaint, we encourage you to contact our Data Protection Officer (see Section ‎5.7) to solve any misunderstandings as quickly as possible.
  6. GEOGRAPHICAL RESTRICTIONS
    1. Fintegri administers and operates the Website from its location in Estonia. Although the Website is accessible worldwide, not all features, products or services discussed, referenced, provided or offered through or on the Website are available to all persons or in all geographic locations, nor are they appropriate or available for use outside Estonia.
    2. Fintegri reserves the right to limit, in its sole discretion and without providing any justification related thereto, the provision and quantity of any feature, product or Service to any person or geographic area.
    3. Content and Services referred to on or offered via the Website are offered under the laws of Estonian Republic and may not be available in certain other countries and/or for residents of certain other countries. Therefore, the Services offered or described on this Website do not constitute an offer to conclude a transaction in any country where such an offer is illegal or is subject to conditions that Fintegri does not comply with in that country (including but not limited to licencing of Fintegri or approval of the transaction by third person, such as authority). The User shall be aware of the requirements of its country to the Services and shall notify Fintegri in writing with relevant details if any Service or content is illegal or is subject to conditions that Fintegri does not comply with in that country, and shall abstain use of such Services. This shall not mean that the content and Services would be subject to any other laws than of the Estonian Republic.
    4. If a User chooses to download or access the Website from outside Estonia, the User is solely responsible for complying with applicable local laws and shall hold Fintegri harmless of and compensate Fintegri any liability that it may incur in relation to this.
  7. SECURITY
    1. Each User is responsible for maintaining adequate security and control of any and all login IDs, passwords, private keys, personal identification numbers (PINs), and any other codes or devices which are intended to or can otherwise be used to access the Account and/or use the Website.
    2. Each User may not exercise and must prevent unauthorized access to the Account and unauthorized or unintended use of the Website, the User’s account credentials or private keys. User shall promptly notify Fintegri of any unauthorized access or use of the Account.
    3. Each User shall fully and timely cooperate with Fintegri in the investigation of any suspected unauthorized access to the Account or use of the Services.
    4. Each User will be solely responsible, and to the maximum extent permissible under applicable legal acts, Fintegri will have no liability, for any activity that takes place with the User’s Account if the Account has been accessed with the User’s account credentials, regardless of whether or not such access has been authorized by the User.
  8. MISCELLANEOUS
    1. Fintegri may unilaterally amend these Terms without providing any advance or other notice or justification thereto. Any amendments to the Terms shall take effect as of uploading them and making of them accessible to the Website.
    2. A failure of Fintegri to exercise or enforce any right or provision of these Terms will not constitute a waiver of that right or provision.
    3. If any part of these Terms is held to be invalid or unenforceable, such determination shall not invalidate any other provision of these Terms.
    4. Fintegri may assign these Terms (either collectively or each right and/or obligation separately, as decided by Fintegri) to its parent company, affiliate or subsidiary without the consent of the Users. The Users may not assign any rights or obligations they have under these Terms without the prior written approval of Fintegri.
    5. These Terms are governed solely by the laws applicable in the Estonian Republic. Any dispute, controversy or claim arising out of or in connection with these Terms, or the breach, termination or invalidity hereof, which the Parties have failed to solve by negotiations will be settled in Harju County Court as the court of first instance.