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About Us

Recognized as a global leader in RegTech for blockchain, Coinfirm serves as a foundation for the safe adoption and use of blockchain. The Coinfirm AML/CTF Platform uses proprietary algorithms and big data analysis to provide structured, actionable data that solves compliance and transaction risk issues in blockchain and cryptocurrencies. The blockchain agnostic platform is currently used by anyone ranging from major financial institutions to exchanges. In addition, Coinfirm develops dedicated blockchain solutions such as the data provenance platform Trudatum that was recently integrated by the largest bank in CE.


Notice on data processing

Data Controller

We inform you that, pursuant to art. 13 of EU 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, "GDPR"),

we, Coinfirm Limited,
a company incorporated under the laws of England and Wales, with company number 10027965 whose registered office is at Lansdowne House 5th Floor, 57 Berkeley Square, W1J 6ER, London, United Kingdom process your personal data.

Contact Details

You may contact us via e-mail address: contact@coinfirm.com or just call us: +44 203 608 6249.

Purpose and legal basis of the processing

We may use your personal data to take steps into entering a contract with you and, if it successes, we will further process your data to perform a concluded contract. The legal basis of processing of your personal data: processing is necessary in order to take steps at the request of the data subject prior to entering into a contract or for further performance of concluded contract (article 6.1.b) GDPR.

Furthermore, we may use your personal data to send you our marketing materials, if you agree to it on the grounds of The Privacy and Electronic Communications Regulations (PECR).

The legal basis of processing of your personal data: processing is necessary for the purposes of the legitimate interests pursued by the controller (article 6.1.f) GDPR.

Furthermore, we may use your personal data if it is necessary for the establishment, exercise or defence of potential legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In case of the need of the establishment, exercise or defence of potential legal claims, whether in court proceedings or in an administrative or out-of-court procedure, the legal basis is article 6.1.f GDPR.

Recipients and transfer of personal data

Your data may be shared with the entitled personnel within the Coinfirm group, which includes:

  • Coinfirm Blockchain Lab sp. z o. o., a company incorporated and operating under laws of Poland, whose registered office is at Warszawska 4/4, 87-100 Toruń, Poland, registered with the National Court Register maintained by the District Court of Toruń, Commercial Court VII Commercial Division under the entry KRS number 0000653593

Contact: contact@coinfirm.com or +44 203 608 6249;

  • AMLT Limited, a company operating under laws of Gibraltar with its registered address at Suite 23 Portland House, Glacis Road, Gibraltar GX11 1AA, Gibraltar, company no. 116373,

Contact: amlt@coinfirm.com.

We also may share your personal information with third parties if we are under a duty to disclose or share your personal information:

  • in order to comply with any legal obligation, or;
  • in order to enforce or apply our agreements with you, or;
  • to protect the rights, property, or safety of us, our customers, or others or;
  • where we have another legitimate interest in doing so – this may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We also may need to share your personal information for third-party service providers (including contractors and designated agents) so that they can carry out their services, which includes:

  • Atlassian Pty Ltd.,
  • Atlassian, Inc.,
  • Dogwood Labs, Inc.,
  • Trello, Inc.,
  • OpsGenie, Inc.,
  • Agile Craft LLC,
  • Kroll Associates U.K. Limited.

We will exercise appropriate due diligence in the selection of our third-party service providers and require that such providers maintain adequate technical and organizational security measures to safeguard your data, and to process your data only as instructed by us and for no other purposes.

How long do we store your data?

We will retain your data until:

  • you object to processing, or;
  • in case of not entering successfully entering into a contract with you – for 6 years from the moment of failure entering into an agreement, or;
  • in case of successfully entering into a contract with you – for 6 years from the moment of expiration of a contract, which performance was the basis of the processing.

After those time periods your personal data will be deleted.

Transfer of data outside the EU

Some of recipients of your data may be located in countries (including the United States) that do not provide a level of data protection equivalent to that set forth by the law in your home country. We will take appropriate steps to make sure that such recipients act in accordance with applicable law. To the extent that we transfer your data to the recipients which are located outside the European Union or the European Economic Area, we will provide an adequate level of protection of your data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law. The Company uses standard contractual clauses in the form approved by the European Commission.

How long do we store your data?

We will retain your data until:

  • in case of not entering successfully into a contract with you – for 6 years from the moment of failure entering into an agreement, or;
  • in case of successfully entering into a contract with you – for 6 years from the moment of expiration of a contract, which performance was the basis of the processing.

After those time periods your personal data will be deleted.

YOUR RIGHTS

Data protection law gives you a number of rights when it comes to personal information, we hold about you. The key rights are set out below. Under certain circumstances, by law you have the right to:

Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. Therefore, we are providing you with the information in this notice. If you require any further information about how we use your personal information, please contact us.

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.

Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.

Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

If you want to obtain more details about processing information you have provided to us or you have a question connected with this processing, please visit our website and read the Privacy Policy placed in the footer or contact us directly via e-mail indicated above.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

Do you have to provide your personal data?

We require you to provide your personal data in order to enable you to conclude the contract with you and you must provide this in order to enter into a contract with us (or as required under that contract).

If you do not provide your personal data, we will not be able to conclude a contract with you.

Automated decision-making

We do not use automated decision-making, including profiling, referred to in article 22 GDPR.

Reclaim Crypto Terms and Conditions

Last updated: 29th October 2019

I. DEFINITIONS

1. “Client” – Participant of Programme, chosen by Confirm (as defined below) and Kroll (as defined below), whose claim is a Feasible Claim (as defined below), and who is entitled to sign Commercial Agreement (as defined below) with Coinfirm and Kroll and to grant Coinfirm and Kroll Power of Attorney (as defined below);

2. “Coinfirm”, “Company”, “we” – Coinfirm Limited, a company operating under laws of England and Wales with its registered address at Lansdowne House 5th Floor, 57 Berkeley Square, W1J 6ER London, United Kingdom;

3. “Commercial Agreement” – agreement signed between Coinfirm, Kroll and Client, which provides for and regulates all rights and obligations concerning the process of recovering funds within the Feasible Claim;

4. “Company Website” – website at https://www.coinfirm.com/

5. “Consumer” – an individual acting for purposes that are wholly or mainly outside that individual's trade, business, craft or profession;

6. “Effective Date” – the date when these Terms become binding, set out the Section II Clause 3 of the document herein;

7. “Feasible Claim” – claim chosen by Coinfirm and Kroll from all of submitted Initial Claims, which is highly feasible to recover, and which met all prescribed requirements set by Coinfirm;

8. “Initial Claim” – description of Participant claim, containing, the minimum, the following details of the case:

8.1. Name;

8.2. Surname;

8.3. Email address;

8.4. Amount of funds lost, with specification of type of currencies and assets (chosen from dropdown list);

8.5. Evidence (any data or files concerning claim, which makes claim plausible);

9. “Initial Feasibility Assessment” – assessment conducted by Coinfirm, which allows to find out if Initial Claim is a Feasible Claim;

10. “Kroll” – Kroll Associates U.K. Limited a company incorporated in England, whose registered address is at The Shard, 32 London Bridge Street, London, England, SE1 9SG;

11. “Legal Office” – suitable legal office or legal entity, with expertise in recovering lost funds and/or class action lawsuits;

12. “Letter of intent” – agreement signed between Coinfirm and Participant, which provides for and regulates intention of parties to conclude Commercial Agreement in future, and in which Participant agrees to perform the Initial Feasibility Assessment;

13. “Minimum Threshold” – minimal amount of funds lost, required to take further actions aimed at emerging Feasible Claims from Initial Claims; required amount of Minimum Threshold is specified in the Section V Clause 3 hereinbelow;

14. “Participant” or “you” or “your” – any person applying to join or taking part in the Programme;

15. “Power of Attorney” – is a written authorization, given by you to Kroll, to represent you in process of recovering lost funds;

16. “Programme” – Coinfirm’s Reclaim Crypto Programme;

17. “Programme Website” – website at https://www.coinfirm.com/reclaimcrypto/ and http://reclaimcrypto.com/

18. “Referral Link” – the URL link unique for every Participant, which leads directly to form, which allows submitting Initial Claim;

19. “Fee” – amount payable for services provided under the Commercial Contract;

20. “Terms” – Reclaim Crypto General Terms and Conditions.

II. THIS AGREEMENT

1. This Terms provide for and regulate all rights and obligations between the Coinfirm and Participant.

2. These Terms apply to the Programme. You will be required to confirm that you agree to be bound by these Terms during the registration process. Please read them carefully and make sure that you understand them before you accept it.

III. PURPOSE OF THE PROGRAMME

1. The Programme is designed to emerge Feasible Claims, which are highly feasible to recover.

2. After emerging Feasible Claim Coinfirm and Kroll may sign the Commercial Agreement with Client and Client shall grant Coinfirm and Kroll the Power of Attorney.

3. Coinfirm and Kroll reserve the right to sign the Commercial Agreement only with chosen Participants.

IV. PARTICIPATION

1. Participant may be a physical or legal person or other entity with capability to undertake legal actions.

2. To take part in Programme a Participant is required to successfully complete all stages specified hereinabove:

2.1. Open the Programme Website.

2.2. Insert his/her email address and provide the type of claim, which the best specifies his/her claim, and accept the Terms and Privacy Notice.

2.3. Refer to the instructions contained in Coinfirm’s replies.

2.4. Submit the Initial Claim by filling up form sent in Coinfirm’s replies.

V. MINIMUM THRESHOLD

1. All amounts of successfully submitted Initial Claims, concerning same case, are summing up.

2. When sum of related Initial Claims, reaches required threshold set individually by Coinfirm for each investigated case, Coinfirm is entitled to send Letter of Intent to chosen Participants.

VI. LETTER OF INTENT

1. After receiving Letter of Intent Participant shall print it out, sign it and send the scan to Coinfirm

2. Receipt of signed Letter of Intent entitles Coinfirm and Kroll to begin Initial Feasibility Assessment.

VII. INITIAL FEASIBILITY ASSESSMENT

1. During Initial Feasibility Assessment Coinfirm and Kroll briefly examine the chosen Initial Claim and prepare description of the case for Legal Office, if result of the assessment indicates that chosen Initial Claim is Feasible Claim.

2. Coinfirm and Kroll refer the description of the chosen Feasible Claim to the suitable Legal Office.

VIII. COMMERCIAL AGREEMENT

1. Based on description of the Feasible Claim, Legal Office prepares a Commercial Agreement and the Power of Attorney and send it to Clients.

2. Commercial Agreement shall provide for and regulate all rights and obligations concerning full process of recovering funds, including determination of Fee.

3. These Terms indicate only overall description of recovering process. Commercial Agreement shall, in details, provide for and regulate all rights and obligations concerning full process of recovering funds within the Feasible Claim.

4. If there is a conflict or inconsistency between these Terms and Commercial Agreement in relation to process of recovering, then the Commercial Agreement shall take priority.

IX. CONSORTIUM OF CLIENTS

1. After conclusion of Commercial Agreement with Clients, Coinfirm and Kroll may connect Clients and appoint Consortium of Clients connected with same case and set up case files.

2. Coinfirm may update on Programme Website with the information on progress on appointing Consortium of Clients for each case.

X. INTELLECTUAL PROPERTY

1. Coinfirm and other Coinfirm capital group companies are owners of the intellectual property related to the Programme (“Programme Intellectual Property”), including any trademarks, tradenames.

2. You are not granted any licence to use any of the Programme Intellectual Property.

3. Any unauthorized use of the Programme Intellectual Property shall be strictly prohibited and shall be subject to legal proceeding as well constitutes a condition for cancellation of your participation to the Programme.

XI. CANCELLATION OF MEMBERSHIP

1. You are obliged to provide true information.

2. Any manipulation, misrepresentation or any other misconduct shall be strictly prohibited.

3. When the Company finds out you have committed any of acts mentioned in Clause 2 above or that you have provided untrue information or you have infringed any of the Programme Intellectual Property (as provided for in Section X above) you will be deprived any and all rights of participation to the Programme and you will be no longer able to participate. You also will be liable to the Company and any other Person for any damage arisen out of your behaviour.

XII. COMPLAINTS

1. All complaints regarding the Programme, including technical problems or complaints on our decisions should be reported at reclaimcrypto@coinfirm.com

2. We will analyse each and any complaint thoroughly and give you a proper answer during a reasonable time.

XIII. LIABILITY AND INDEMNITY

1. EXCEPT AS EXPRESSLY STATED HEREIN, THE COMPANY MAKES NO REPRESENTATIONS OR WARRANTIES EXPRESS OR IMPLIED, IN RESPECT OF ANY SERVICE, BENEFIT, AMLT OR C-SCORE REPORT OR INTELLECTUAL PROPERTY RIGHTS PROVIDED HEREUNDER. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY DISCLAIMS ALL EXPRESS OR IMPLIED WARRANTIES, INCLUDING WARRANTIES OF SATISFACTORY QUALITY AND FITNESS FOR A PARTICULAR PURPOSE, WHICH MAY BE IMPLIED IN RESPECT OF ANY SERVICE, BENEFIT OR INTELLECTUAL PROPERTY RIGHTS PROVIDED HEREUNDER, OR (IN EACH CASE) THEIR USE AND THE RESULTS OF SUCH USE. LIMITATION OF CONDITIONS OF SATISFACTORY QUALITY OR FITNESS FOR A PARTICULAR PURPOSE INDICATED HEREINABOVE DOES NOT INCLUDE PARTICIPANTS THAT ARE CONSUMERS.

2. To the fullest extent permitted by applicable law you agree to indemnify, defend and hold harmless the Company and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns (the “Company Indemnified Parties”) from and against any and all claims, demands, actions, damages, losses, costs and expenses (including reasonable professional and legal fees) that arise from or relate to:

2.1. your participation to the Programme;

2.2. the performance or non-performance of your responsibilities, representations, warranties or obligations under these Terms, or;

2.3. your breach of any of the provisions set out in these Terms, or;

2.4. your breach of any rights of any other Person.

XIV. TAXATION

1. You are solely responsible for any taxes in any jurisdiction arising out of your participation to the Programme.

2. The Company provides no tax or legal advice nor shall be liable for your legal or tax obligations.

XV. PERSONAL DATA PROTECTION

1. The Company shall be the Controller of your personal data.

2. Your provision of your personal data is essential and necessary to execute agreement between us and you.

3. Your personal data will be processed in order to manage your participation to the Programme unless you give us your consent to process in other purposes which shall be communicated to you.

4. For further information please read our Privacy Notice and Privacy Policy at the Company’s Website.

XVI. ANTI-BRIBERY COMPLIANCE

1. Each Party to these Terms, in its own capacity, warrants and represents that:

1.1. such Party, and its subsidiaries and its and their respective directors, officers, employees, agents and any other persons acting on its or their behalf has not, directly or indirectly, made any bribes, rebates, payoffs, influence payments, kickbacks, illegal payments, illegal political contributions, or other payments, in the form of cash, gifts, or otherwise, or taken any other action, in violation of the UK Bribery Act of 2010 or any other anti-bribery or anti-corruption Law (collectively the “Anti-Bribery Laws”), and;

1.2. such Party (nor any of its subsidiaries) is or has been the subject of any investigation or inquiry by any governmental body with respect to potential violations of Anti-Bribery Laws.

XVII. TERM AND TERMINATION

1. The Programme is designed to continue for indefinite period of time until terminated by the Company. The termination notice shall be published on the Company Website and the notice period is 30 (thirty) days.

2. If you want to terminate your participation, send us a signed, written notice or an electronic scan to the addresses set forth in Section XVIII Clause 10 of the Terms.

XVIII. GENERAL PROVISIONS

1. We may amend these Terms from time to time, including where there are changes to the intended process or as may be otherwise required by any laws or regulatory requirements to which we are subject. If we make any amendments to these Terms, we will publish a notice together with the updated Terms on the Company’s Website and we will change the “Last Updated” date at the top of these Terms. Any amended Terms shall become effective in three (3) days upon the publication of such notice and updated Terms on the Company’s Website (not applicab le to amendments on reward pool or significance criteria).

2. It is your responsibility to regularly check the Company’s Website for any such notices and updated Terms. You may not agree to the amended Terms. If you do not agree you may terminate your participation by giving us an appropriate notice by email or in writing in accordance with provisions of Clause 2 Section XVII of the Terms. If you are a Consumer and you do not agree to any amendment you may withdraw from the Programme with immediate effect during 14 days from the effective date of amendment.

3. If any term, clause or provision of these Terms is found to be illegal, void or unenforceable (in whole or in part), then such term, clause or provision shall be severable from these Terms without affecting the validity or enforceability of any remaining part of that term, clause or provision, or any other term, clause or provision of these Terms, which shall remain in full force and effect.

4. These Terms constitute the entire agreement between the parties in relation to its subject matter. These Terms supersede any and all prior agreements, draft agreements, arrangements, warranties, statements, assurances, representations and undertakings of any nature made by, or on behalf of the parties, whether oral or written, public or private, in relation to that subject matter.

5. You acknowledge that by accepting these Terms, you have not relied on any oral or written statements, warranties, assurances, representations or undertakings which were or may have been made by the Company or on the Company’s behalf by any of the Company Indemnified Parties and/or a related entity or undertaking in relation to the subject matter of these Terms at any time before your acceptance of them (“PreContractual Statements”), other than those set out in these Terms. You hereby waive any and all rights and remedies which might otherwise be available in relation to such Pre-Contractual Statements.

6. Nothing in these Terms shall be deemed to create any form of partnership, joint venture or any other similar relationship between you and the Company, Coinfirm or other individuals or entities involved with the Programme.

7. These Terms and any dispute or claim arising out of or in connection with their subject matter or formation (including non-contractual disputes and claims) shall be governed by and construed in accordance with law of England.

8. Unless you are a Consumer the Parties irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with these Terms or their subject matter or formation (including noncontractual disputes and claims). If you are a Consumer general provisions of applicable law shall apply.

9. Any mail correspondence to us should be sent at: Coinfirm, West Station II, Al. Jerozolimskie 142B, 02-305 Warsaw, Poland

    9. “Initial Feasibility Assessment” – assessment conducted by Coinfirm, which allows to find out if Initial Claim is a Feasible Claim;