Anti-Money Laundering (AML) Policy

Effective Date: 16/05/2024

Coinsellor sp. z o.o.. is committed to ensuring the transparency of financial transactions and preventing money laundering and terrorist financing in accordance with Polish law, European Union regulations, and international best practices.

Legal Framework

Coinsellor sp. z o.o.. adheres to the provisions of the Act of March 1, 2018, on the Prevention of Money Laundering and Terrorist Financing ("the Act"), which implements Directive (EU) 2018/843 of May 30, 2018 of the European Parliament and the Council, as well as the recommendations of the Financial Action Task Force (FATF).

The Administrator of the coinslr.com website is designated as an obligated institution under this Act and takes all legally required measures to prevent the misuse of its platform for illicit financial activities.

Key Measures for AML Compliance

To ensure compliance with the Act, Coinsellor sp. z o.o.. has adopted the following internal measures:

  • Internal AML Procedure

  • Purpose Limitation – Personal data is collected for specific, legitimate purposes and will not be processed in a way that is incompatible with those purposes.

  • Data Minimization – Personal data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

  • Accuracy – Personal data is accurate and, if necessary, kept up to date. We take all reasonable steps to ensure that inaccurate data is corrected or erased.

  • Storage Limitation – Personal data is stored only for as long as necessary for the purposes of processing.

  • Integrity and Confidentiality – Personal data is processed securely, ensuring protection against unauthorized access, loss, destruction, or damage.

What personal data is processed?

In accordance with the purposes outlined in this policy, we process the following categories of personal data:

  • Identification Data – such as name, surname, personal identification number, date of birth, and other identification details from your identification document (e.g., passport, ID card).

  • Contact Data – such as address, telephone number, and email address.

  • Tax Residence Information – including your country of tax residence, taxpayer number, citizenship, and place of tax residence.

  • Communication Data – information obtained from communications such as letters, emails, phone calls (with or without audio recording), and data related to the devices and technologies used for communication.

  • Investment and Cryptocurrency Data – including information related to your investment portfolio, cryptocurrency balances, transfers, and fees associated with virtual currency transactions.

  • Financial Knowledge – such as your education, financial knowledge, and investment experience.

  • Transaction Data – information related to the services you have used or requested, complaints, and contractual details.

  • Financial Data – including the source of funds, financial liabilities, assets, transactions, income, and expenditures.

  • Employment and Economic Activity Data – including employment details, business activity, income stability, and sources of profit.

  • Audio and Video Surveillance Data – visual and audio data collected from security surveillance when visiting our premises.

Legal basis for processing personal data

The processing of your personal data is lawful if based on at least one of the following grounds:

  • Internal AML Procedure

    • An internal procedure has been established, outlining the rules for compliance with AML obligations.

    The Administrator of coinslr.com is responsible for ensuring that all employees adhere to this procedure.

  • AML Training

    • Employees responsible for AML duties participate in relevant training programs to stay updated on best practices and legal requirements.

  • Risk Identification and Assessment

    • Coinsellor sp. z o.o.. conducts regular risk assessments related to the potential misuse of its platform for money laundering.

    • These assessments are updated as necessary to reflect emerging threats and regulatory changes.

  • Financial Security Measures

    • The company applies financial security measures to users, including identification and verification procedures.

    • The scope of these measures is based on an AML risk assessment, considering user type, business relationships, products, and transactions.

    • Detailed conditions for financial security measures are set forth in § 7 of the Terms of Service, while user identification procedures are outlined in § 4 of the Terms of Service.

  • Record Keeping

    • Transaction records are maintained for a minimum of five years.

    • Personal data storage conditions are detailed in the Privacy Policy of coinslr.com.

  • Reporting to the General Inspector of Financial Information (GIIF)

    • Coinsellor sp. z o.o.. promptly reports any circumstances suggesting potential money laundering or terrorist financing.

    • Transactions exceeding EUR 15,000 (either in a single transaction or through linked transactions) are also reported.

  • Cooperation with Law Enforcement

    • Coinsellor sp. z o.o.. cooperates with law enforcement agencies, particularly the prosecutor's office, in cases of suspected criminal activities beyond money laundering and terrorist financing.

    • If reasonable suspicion arises that a transaction or assets are linked to a crime, relevant authorities are informed.

  • Transaction Monitoring & Blocking

    • Coinsellor sp. z o.o.. cooperates with law enforcement agencies, particularly the prosecutor's office, in cases of suspected criminal activities beyond money laundering and terrorist financing.

  • Compliance with Sanctions

    • Transactions involving entities on sanction lists maintained by the United Nations, the European Union, and other anti-money laundering bodies will not be executed.

User Account Restrictions & Notifications

  • If a competent authority orders the suspension or seizure of virtual currencies on a User’s account, the account may be frozen.

  • The User will be informed of the reason for account restrictions within seven days.

  • Coinsellor sp. z o.o.. reserves the right to share user data with relevant authorities upon presentation of legally required documentation.

Reporting Non-Compliance

Users and stakeholders who suspect any non-compliance with this AML Policy should report their concerns to contact@coinsellor.com.

For further details regarding the operation and security of transactions, please refer to our Terms of Service.

This policy is in force as of May 16 2024 and is subject to periodic updates in line with regulatory changes and best practices.

Coinsellor sp. z o.o.
Administrator of coinslr.com

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