Privacy Policy

GOLDFORT sincerely respects the privacy of Visitors and Users of our website and is fully committed to protecting their Personal Information and its fair use. This Regulation contains information on how we can collect and use personal data, as well as describes our Visitors' and Users' rights and opportunities related to it.

We urge you to read this document and make sure that you fully understand and agree with it before you visit our website or use any of our services. If you did not read it completely, did not understand anything and do not accept the terms of this Privacy Policy, then you must immediately leave this website, application, or service, and avoid or stop using any of our services.

This Privacy Policy (hereinafter referred to as the "Policy") is an official document of Goldfort OÜ (Legal address: Vana-Narva maantee 24, Maardu, 74114 Harju maakond, Estonia Registration code: 14748334;) (hereinafter referred to as the "Company"/"Operator") that determines the procedure for processing and protecting information about individuals (hereinafter referred to as "Users") who use the Company's services, information, services, programs, and products located on the following website https://bitexfin.com/, on the domain name: bitexfin.com (as well as its subdomains) (hereinafter referred to as the "Website").

The privacy policy is a legally binding and strictly enforceable agreement between GOLDFORT OÜ and you, so please read it carefully.

You may visit the Website and/or use the Services only if you completely agree with this Privacy Policy. By visiting the Website and/or using any of the Services, you express and confirm your awareness and unconditional consent to this Privacy Policy, including the collection and processing of your Personal Data, as defined and described below.

We pay special attention to the fact that according to the current legislation you are not obliged to provide us with any information. You hereby acknowledge, warrant and agree that any data that you provide to us is provided by your own will and consent for use for the purposes described herein.

1. Terms and Definitions: 1.1. "Website Administration" (hereinafter referred to as the "Administration") is employees authorized for managing the website, acting on behalf of the Company, who organize and (or) carry out the processing of personal data, as well as set the purposes of processing personal data, the composition of personal data subject to processing, acts (operations) performed with personal data.

1.2. "Personal Data" means any information related to an individual who is determined directly or indirectly, or being determined (subject of personal data).

1.3. "Personal Data Processing" means any action (operation) or set of actions (operations) performed with the use of automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, refining (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

1.4. "Personal Data Confidentiality" is a mandatory requirement for the Operator or other person who has access to a personal data to prevent their dissemination without the consent of the subject of personal data or other legal basis.

1.5. "Website" is a collection of interconnected web pages hosted on the Internet at a unique URL address (URL): bitexfin.com, as well as its subdomains.

1.6. "Subdomains" are pages or a set of pages located on third-level domains belonging to the Website https://bitexfin.com/, as well as other temporary pages with the contact information of the Administration at the bottom of the page.

1.7. "Website User" (hereinafter referred to as the "User") is a person who has access to the website https://bitexfin.com/, via the Internet and use information, materials, and products of the Website.

1.8. "Cookies" is a small piece of data sent by a web-server and stored on a user's computer that the web-client or web-browser sends to the web-server each time in an HTTP request when there is an attempt to open the page of the corresponding site.

1.9. "IP address" is a unique network address of a node in a computer network via which the User accesses the Site.

2. General Provisions 2.1. This Policy is an integral part of the User Agreement (hereinafter referred to as the "Agreement") posted on the Company Website, as well as other agreements concluded with the User, when expressly provided by their terms.

2.2. The processing of personal data is carried out on a legal and fair basis, acting reasonably and in good faith and on the basis of the following principles:

- the legitimacy of the purposes and methods of processing personal data;

- good faith;

- the correspondence of the purposes of processing personal data to the purposes predetermined and claimed during the collection of personal data, as well as by the powers of the Company;

- the correspondence of the volume and nature of the personal data that is processed, the methods of processing personal data to the purposes of processing personal data.

2.3. This Policy applies only to the information processed during the use of the Website. The Administration does not control and is not responsible for the processing of information by third-party websites and services to which the User can switch to via a link that is available within the service.

2.4. This Policy covers the processing of private, personal data collected by any means, both active and passive, both online and without its use, from individuals located anywhere in the world.

The company collects two types of information about Visitors and Users:

Unidentified and non-identifying information related to Visitors or unidentified Users that we may access or collect automatically through his/her use of the Services ("Anonymized Information"). Such Anonymized Information does not allow us to identify the Visitor or the User from whom it was collected. The Anonymized Information collected by us is mainly composed of technical or summary usage information such as Visitor and User views and sequence of clicks when using the Services, heat maps of the use of the Website or Services and the scrolling of the page, unidentified information relating to the Visitor's or User's devices, operating system, Internet browser, screen resolution, language and keyboard settings, Internet provider, referring pages/pages of exit, date and time, etc.

Individual identifying information, namely the information that identifies an individual or may be of a private or sensitive nature ("Personal Data"). Personal data collected by us, mainly consists of contact information (i.e. e-mail address or phone number), payment information (name, actual address, billing, payment method and transaction details), details of the work session or the session of the use of Services (IP addresses, geo-location and/or individual device identifier), details regarding connected user accounts of third-party resources (for example, e-mail or user name for connected user accounts), scanned identity documents (such as identity card, driving license, passport or official company registration documents) provided to us, correspondence (including the one that was committed by or uploaded to our services), and any other personal information, provided to us by Visitors and/or Users during their access to and/or use of the Services. To avoid discretionary interpretation, any anonymized information that relates to or connected with Personal Data (for example, to improve the quality of the Services that we offer) is considered and treated by us as Personal Data as long as such relation or connection exists.

2.5. Processing of personal data of users shall be carried out only with the consent of the subject of personal data to the processing of their personal data.

By putting a tick in the appropriate box and pressing the "Register" button, including any stage of such registration and (or) at any time using the Website, Users give their voluntary, motivated and informed consent to the provisions of this Policy in electronic form.

2.6. The company does not collect personal data about minors. In case of revealing the fact of obtaining personal data about a minor, the Administration will take measures to remove such information as soon as possible.

The company strongly recommends parents and other persons who are responsible for supervising minors (legal representatives, i.e. parents, adoptive parents or guardians) to monitor the minors using websites.

3. Subject 3.1. This Policy establishes the Company's obligations not to disclose and protect the privacy of personal data that the User provides upon the request of the Administration when registering on the Website, when subscribing to an e-mail newsletter or other actions performed on the Website.

3.2. Personal data permitted for processing under this Privacy Policy is provided by the User by filling in the forms on the Website. The information provided by the User, when registering and verifying an account on the Website, may include, but not limited to, the following personal data of the User:

3.2.1.Personal information – Surname, Name, Patronymic (in full), sex, date of birth, passport data, e-mail address, telephone number, address of primary registration at the place of residence/stay;

3.2.2. Financial information: bank details / requisites of payment documents; address of the blockchain e-wallet to store intangible electronic assets;

3.2.3. Documents required for verification: scan-copy of the passport, allowing to identify the User's identity. The Administration is entitled, in particular, to request from the User a copy of the identity document or other document containing the User's name, surname, photo, as well as other additional data that, at the discretion of the Administration, will be necessary and sufficient to identify such a User and to prevent abuse and violation of the rights of third parties.

3.3. The Website protects data that is automatically transmitted during the use of the Website, with the help of the software installed on the User's device, including:

- IP address (this information is used to prevent, identify and solve technical problems);

- cookie data (disabling cookies may result in inability to access parts of the Website that require authorization);

- information about the user's browser (or other program, through which access to the Website is provided);

- technical characteristics of the equipment and software used by the User, the date and time of access to the Services, the addresses of the requested pages and other similar information.

3.4. The Administration does not have the ability to estimate the User's legal capacity. However, it is based on the fact that the User provides reliable and sufficient personal information and maintains this information up to date.

4. Objectives of Collecting User's Personal Data 4.1. The Company can use the User's personal data for the following purposes:

4.1.1. To identify the User who was registered on the Website for their further authorization, execution of agreements and contracts with the User and other actions.

4.1.2. To provide the User with an access to personalized Website data and execution of agreements, and contracts.

4.1.3. To get feedback from the User, including sending notifications, requests regarding the use of the Website, rendering services and processing requests and inquiries from the User.

4.1.4. To determine the location of the User for security purpose and fraud prevention.

4.1.5. To confirm the authenticity and completeness of the personal data provided by the User.

4.1.6. To create an account to use parts of the Website, if the User has agreed to create an account.

4.1.7. To inform the User by e-mail.

4.1.8. To provide the User with effective technical support in case of problems related to the use of the Website.

4.1.9. To provide the User, with his/her consent, with special offers, information on different offers, newsletters, and other information on behalf of the Company.

4.1.10. To implement advertising activities with the consent of the User.

5. Methods and Terms of Processing and Storing Personal Data 5.1. The processing of the User's personal data is carried out without any time limit, in any legal way, including personal data information systems with the use of automation tools or without using such means.

5.2. The User agrees that the Company has the right to transfer personal data to third parties, namely, to courier services, postal communication organizations (including electronic communications), telecommunication operators, solely for the purpose of fulfilling the agreement/contract with the User, including the delivery of documentation or e-mail messages.

GOLDFORT also has a partnership with a number of Service Providers, whose services and solutions complete, facilitate and improve the Company's Services. They include hosting and co-location services for the server, communications and delivery network (and distribution) of content (CDNs), data protection and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention, web analytics, e-mail distribution and monitoring services, recording work sessions and remote access services, performance measurement and optimization services, marketing services, content providers and legal and financial counsellors (collectively referred to as the "Service Providers)").

Such Service Providers may receive or somehow have access to the Personal Data of Visitors and Users of the Website, in full or in part, depending on the role and objectives of each Service Provider in the process of promoting and improving the Company's Services and business; Moreover, they can use the information that they received only for the specified purposes.

5.3. The User agrees that in some cases, provided by the law, the Administration may have to disclose personal information at the request of government agencies, including the purposes of national security or for law enforcement.

5.4. With the loss or disclosure of personal data, the Administration has the right not to inform the User about the loss or disclosure of the personal data.

5.5. The Administration takes security measures designed to protect personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties, including physical, electronic and procedural measures. Among other things, the Company offers secure access to most of the Services through the HTTPS protocol; transfer of confidential payment information (for example, a credit card number) through our specially designed payment forms, which are protected by an SSL / TLS encrypted connection; and the Company regularly passes the PCI DSS (Payment Card Industry Data Security Standards) certification. The Administration also regularly monitors all systems for possible vulnerable spots and attacks, and is constantly looking for new ways and service providers to further improve the security of the Services and protect the Visitors' and Users' privacy.

However, despite the measures and efforts undertaken by GOLDFORT, it cannot and does not guarantee the absolute protection and security of Personal Data or any other User's content. Therefore, the Company encourages Users to insert reliable passwords for the User's Account and avoid providing the Administration with any sensitive information as its disclosure may cause the User substantial or irreparable harm.

5.6. Localization obligations: If the User lives in a jurisdiction that imposes obligations of "data localization" or "residence information" (i.e. it is required that the Personal Data of its residents be contained within the territorial boundaries of that jurisdiction), and the Administration becomes aware of this fact , the Administration can ensure the storage of the Personal Data of Users within such territorial boundaries, if such a legal duty is rested on the Company. For example, if the Administration finds out that the User resides in the Russian Federation, we may have to store Personal Data on its territory, either on our own or through local data centers and suppliers.

The User acknowledges and agrees that acting so, the Company may continue to collect, store and use the Personal Data of Users elsewhere, including the United States of America.

6. Rights and Liabilities of Parties 6.1. The User has the right:

6.1.1. To make a free decision to provide his/her personal data that is necessary for using the Website and consent to its processing.

6.1.2. To update, enlarge the provided information about personal data in case of any changes of this information.

6.1.3. The User has the right to receive information from the Administration concerning the processing of his/her personal data, if such right is not restricted in accordance with the law. The User has the right to demand from the Administration the specification of his/her personal data, the blocking or destruction in the event that personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take legal measures to protect their rights.

6.2. The Administration is obliged to: 6.2.1. Use the information received solely for the purposes specified in clause 4 of this Privacy Policy.

6.2.2. Ensure that confidential information is kept secret, not to disclose without the prior written permission of the User, as well as not to sell, exchange, publish or disclose other personal data of the User, except for clause 5.2 and 5.3. of this Policy.

6.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure normally used to protect such information in the existing business.

6.2.4. To block personal data related to the appropriate User from the moment of request or inquiry of the User, or his legal representative or authorized body for protection of the rights of subjects of personal data for the verification period, in case of revealing unreliable personal data or illegal actions.

7. Liabilities of Parties 7.1. If the Administration has not fulfilled its obligations, it shall be liable for losses incurred by the User in connection with the misuse of personal data, except for the cases provided in clause 5.2., 5.3. and 7.2. of this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, the Administration is not liable if:

7.2.1. this confidential information became public property before its loss or disclosure.

7.2.2. this confidential information was received from a third party until it was received by the Administration.

7.2.3. this confidential information was disclosed with the consent of the User.

7.3. The User is fully responsible for compliance with the requirements of the legislation of the country in which he resides, including advertising laws, the protection of copyright and related rights, the protection of trademarks and service marks, but not limited to, including full responsibility for the content and form of materials.

7.4. The User acknowledges that the person who provided any information (including but not limited to data files, texts, etc.) to which he can access as part of the Website, is responsible for it.

7.5. The User agrees that the information provided to him/her as part of the Website may be an object of intellectual property, the rights to which are protected and belong to other Users, partners or advertisers who post such information on the Website.

The User has no right to make changes, lease, transfer, loan, sell, distribute or create derivative projects on the basis of such Content (in whole or in part), unless such actions have been expressly authorized in writing by the owners of such Content in accordance with terms of a separate agreement.

7.6. As for text materials (articles, publications that are freely available on the Website), their distribution is allowed, if a link to the Website is given.

7.7. The Administration shall not be liable to the User for any loss or damage incurred by the User because of the removal, malfunction or inability to preserve any Content and other communication data contained on or transmitted via the Website.

7.8. The Administration is not responsible for any direct or indirect damages caused by: the use or inability to use the website, or individual services; unauthorized access to the User's communications; statements or behavior of any third party on the website.

7.9. The Administration is not responsible for any information posted by the User on the Website, including but not limited to: copyrighted information, without the express consent of the copyright owner.

8. Dispute Settlement 8.1. Before applying to the court with a claim for disputes arising from the relationship between the User and the Administration, it is mandatory to present a claim (a written offer or an offer in electronic form on the voluntary settlement of the dispute).

8.2. Within 30 calendar days from the date of receipt of the claim the receiver of the claim shall notify, in writing or in electronic form, the applicant of the claim about the results of the examination of the claim.

8.3. In the case of failure to settle disputes in the pre-trial order, the dispute is finally resolved through arbitration in the Vilnius Commercial Arbitration Court under the Rules of Arbitration Procedure. All procedural documents shall be delivered to the parties via e-mail.

9. Additional Terms 9.1. The Administration has the right to make changes to this Privacy Policy without the consent of the User.

9.2. The new Privacy Policy comes into effect from the moment when it is posted on the website, unless otherwise provided in the new edition of the Privacy Policy.

9.3. Any suggestions or questions regarding this Privacy Policy should be sent to: support@custodianfund.io

9.4. This Privacy Policy is in English and may be translated into other languages for the Users' convenience. If the translated (not English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.

9.4. The current Privacy Policy is available at http://bitexfin.com/politika.html

Money Laundering (Legalization) Prevention 1. What the concept of money laundering includes

Today, the problem of counteracting the legalization (laundering) of money obtained through criminal means, that is, giving a legitimate form to the possession, use or disposal of funds or other property obtained as a result of committing a crime, as well as the problem of financing terrorism, providing or collecting funds or providing financial services with the knowledge that they are intended to finance the organization, preparation and/or terrorist acts, or to ensure the criminal community (criminal organization) created or being created to commit terrorist acts. Individuals and legal entities whose income is obtained by criminal means make various attempts to legalize this income. To achieve this goal, they can use other people's personal data, including the one that was fraudulently obtained, which can be a problem for people who are victims of fraud activities and not involved in the criminal activities of these individuals.

2. Legislation on combating money laundering (laundering)

To prevent money laundering, organizations that carry out transactions with money or other property are obliged to comply with the requirements of the legislation on combating the legalization (laundering) of money obtained by criminal means and carry out identification of clients, as well as assisting state authorities and financial organizations that are responsible for counteracting the legalization of money obtained by criminal means. GOLDFORT takes all the necessary measures to ensure compliance with the legislation on combating the legalization (laundering) of proceeds from crime and financing terrorism.

3. Procedure of Identification of Clients

As part of compliance with the requirements of the law on client identification, this procedure is carried out at the registration stage, in cases of various types of transactions and within the framework of monitoring carried out by the company's specialists. For the purpose of client identification, GOLDFORT is entitled to request personal data from customers and to implement measures to confirm the reliability of this information using the verification system developed by the company's specialists. This procedure can take several working days.

4. Compliance with the Privacy Policy

The received personal data shall be processed by the company in accordance with the provisions of the Privacy Policy. We draw the attention of our Users to the fact that the basis for the request of the company to carry out the identification procedure shall comply with the legal norms on combating the legalization (laundering) of money received from crime, and financing terrorism, rather than suspecting customers in committing illegal actions. Therefore, the understanding of the actions and cooperation of each client of the company is necessary for the successful fight against money legalization and financing terrorism.