As used in these Terms, including the preamble hereof, unless expressly
stated or evident in the context, the following capitalised terms and expressions
shall have the following meanings:
Account – the account opened at Fintegri by a User, using which the User
access the Services.
Apps – the Android, web and iOS mobile apps of Fintegri, which give
to the Services.
Fintegri – Fintegri Global OÜ, an Estonian limited liability company
registered under registry code 14560487. References to “we”, “us” and “our”
mean references to Fintegri.
Party – each of the User and Fintegri.
Services – services provided by Fintegri to the Users on the Website
(such as the Wallet Service and the cryptocurrency conversion service, if
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.
Terms – these Terms and Conditions, as amended from time to time.
User – anyone who uses the Website, Apps and/or Services provided by
Fintegri. References to “you” and “your” mean references to the User.
Wallet ‒ the User’s cryptocurrency wallet, which can be accessed via the
Wallet Service ‒ regulated service of a cryptocurrency wallet.
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.
In these Terms, unless the context otherwise requires, a reference to:
a Section is a reference to a section of these Terms;
a person shall include a reference to its legal successors and permitted
words denoting the singular include the plural and vice versa, words
denoting persons include physical as well as legal persons; and
a document is a reference to that document as may be amended or
supplemented from time to time.
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.
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.
If you have any questions regarding these Terms, Website or the Services, please
The Website and the Services offered by Fintegri are NOT ADDRESSED TO AND MAY NOT BE
persons who are NOT at least 18 years of age;
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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.
Fintegri has the right to modify the Service descriptions and contents of the
Website, and/or the Terms, without prior or any other notice.
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.
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.
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
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.
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.
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
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
USER REGISTRATION (account)
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.
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.
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
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.
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.
Information on the fees payable for the Services is accessible through or on the
PRIVACY STATEMENT, COLLECTION OF PERSONAL DATAWhat are Personal Data?
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.
How do we collect information about you?
We collect information about you in the following ways:
When you register or try to register yourself on the Website as a User;
When you use Services;
When you interact with us;
We collect the information provided by you:
Name, surname, personal identity number;
Date of birth;
Place of birth;
Credit card or other data payment;
Details and data from your passport or other documents of identification;
/PLEASE CHECK AND ADD SERVICE SPECIFIC DATA THAT WILL BE COLLECTED, STORED
What information we collect about you and why?
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:
the data listed in Section 5.3;
information you have submitted on the Website;
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
/NEEDS TO LIST ALL DATA CATEGORIES GOING TO BE PROCESSED/
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.
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.
Fintegri has appointed a Data Protection Officer, who is […] and who can be reached
via […]. Fintegri can be reached via email […].
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.
Depending on your use of the Services, Fintegri may collect and use your personal
data for the following purposes:
registering you as a User of the Services and enabling you to use the
Website and Services;
ensuring that the Website and Services’ content is presented to you in the
most effective manner;
processing and handling complaints or requests;
helping us in evaluating, correcting and improving our products and
marketing, including providing you with information that you requested from
us (for instance direct marketing, provided you have given respective
notifying you about certain changes to our Website or Services.
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.
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.
Whom do we disclose information to?
The personal data of Users is being processed by the following categories of data
Fintegri’s employees or group enterprises, responsible for specific tasks
regarding the Services,
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
third persons to whom Fintegri is required to transfer data under applicable
legislation, e.g. relevant state institutions and sector-specific
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
The list of data processors is available at www.[…].
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.
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
How long do we store information about you?
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.
How do we protect your information?
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
What are your rights?
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.
As a User and data subject you are, at any time, entitled to exercise the following
the right to request the correction of the User’s personal data;
the right to request access to the User’s personal data;
the right to request the erasure of the User’s personal data;
the right to request the restriction of processing of the User’s personal
the right to object to the processing of the User’s personal data;
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
the right to lodge a complaint to a supervisory authority: Andmekaitse
Inspektsioon (Data Protection Inspectorate), www.aki.ee.
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.
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.
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.
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.
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.
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.
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
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.
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
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.
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.
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.
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.
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.
If any part of these Terms is held to be invalid or unenforceable, such determination shall not invalidate any other provision of these Terms.
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.
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.