respect the privacy of all users of our website www.coinlion.com and ensure that personal information of the
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that
identifies an individual. Examples of Personal Information we collect include: names, addresses, email
addresses, and phone and facsimile numbers. This Personal Information is obtained in many ways including
correspondence, by telephone and facsimile, by email, via our website, from media and publications, from other
publicly available sources, and from third parties. We don’t guarantee website links or policy of authorized
third parties. We collect your Personal Information for the primary purposes of enabling you to use the
CoinLion Platform. We may also use your Personal Information for secondary purposes closely related to the
primary purpose, in circumstances where you would reasonably expect such use or disclosure. When we collect
Personal Information we will, where appropriate and where possible, explain to you why we are collecting the
information and how we plan to use it.
information includes information or opinion about such things as an individual’s racial or ethnic origin,
political opinions, membership of a political association, religious or philosophical beliefs, membership of a
trade union or other professional body, criminal record, or health information. Sensitive information will be
used by us (if at all) only:
- For the primary purpose for which it was obtained;
- For a secondary purpose that is directly related to the primary purpose; and
- With your consent or where required or authorized by law.
reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some
circumstances we may be provided with information by third parties. In such a case we will take reasonable
steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal
Personal Information may be disclosed in a number of circumstances including the following:
- Third parties where you consent to the use or disclosure; and
- Where required or authorized by law.
Security of Personal
Personal Information is stored in a manner that reasonably protects it from misuse and loss and from
unauthorized access, modification, or disclosure. When your Personal Information is no longer needed for the
purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your
Personal Information. However, most of the Personal Information is or will be stored in client files which will
be kept by us for a minimum of 5 years.
Access to your
access the Personal Information we hold about you to update or correct it, subject to certain exceptions. If
you wish to access your Personal Information, please contact us in writing. We will not charge any fee for your
access request, but may charge an administrative fee for providing a copy of your Personal Information. In
order to protect your Personal Information, we may require identification from you before releasing the
Quality of your Personal Information
It is an
important to us that your Personal Information is up to date. We will take reasonable steps to make sure that
your Personal Information is accurate, complete, and up-to-date. If you find that the information we have is
not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and
ensure we can continue to provide quality services to you.
Policy may change from time to time and is available on our website.
Complaints and Inquiries
Know Your Customer
(KYC) & Anti-Money Laundering (AML) Policy
Company protects itself from involvement in money laundering or suspicious activity by the following:
- Performing an enterprise-wide risk assessment to determine the risk profile of
- Establishing AML policies and procedures
- Implementing internal controls throughout its operations that are designed to
mitigate risks of money laundering
- Performing know your customer (“KYC”) procedures on all users
- Designating a Compliance Officer with full responsibility for the AML Program
- Conducting an annual AML audit
- Providing AML training to all employees
Policies & Procedures
launch of the CoinLion Platform, the KYC & AMC Policies will be written and approved by the Company’s (Coin
Lion, LLC) owners. Once approved, the policies will be provided to all employees. Each employee will
acknowledge the Policy in writing. All policies and procedures will be reviewed and updated or revised as
needed, but no less often than annually.
Company has developed and implemented internal controls to ensure that all of its operations comply with all
AML legal requirements and that all required reports are made on a timely basis. Some of those internal
controls are listed within this document and include, but are not limited to, the Customer Identification
Program, the Suspicious Activity Reporting system, and the required reports on the Program’s effectiveness to
the Company’s Owners.
officers and employees of the Company are required to receive AML training at least annually. New employees
will receive appropriate AML training within 30 days of their hire date. Training for all employees will
include not only the legal elements of AML laws and regulations but will also cover job specific applications
of these laws. Ongoing training will be provided and updated regularly to reflect current developments and
changes to laws and regulations.
It is the
Company’s policy to ensure that it has reasonably identified each customer who uses the CoinLion Platform.
Users may be identified using a variety of methods.
User opens an account to begin using the CoinLion Platform, the Company will, as part of its account-opening
process: (i) cross-check the names of users against compliance databases such as the OFAC Specially Designated
Nationals list and other governmental watch lists; (ii) require users to provide proof of identification; and
(iii) not permit any payment in USD to be made with incomplete account-opening information.
Individual Proof of
- Date of birth
- Residence address and mailing address if different (PO Box alone will not be
- Official issued identification number (e.g., passport number, social security
number, employee identification number or individual taxpayer identification number)
- Copy of valid photo identification of the principal(s) involved with the account
(e.g., driver’s license, passport, alien identification card)
used in opening an account relationship must be verified prior to establishing the account. Verification of
identity will require multi-factor authentication, layered security, and other controls to ensure a meaningful
user identity confirmation process based on account size or other factors.
and Activity Reports
Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be
carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful
purpose. Internal controls will be implemented so that an ongoing monitoring system is in place to detect such
activity as it occurs. When such suspicious activity is detected, the Company will determine whether a filing
with any law enforcement authority is necessary. Suspicious activity can include more than just suspected money
laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law
enforcement authority, even if no money is lost because of the transaction. The Company will initially make the
decision of whether a transaction is potentially suspicious. Once the Company has finished the review of the
transaction details, it will consult with the Company’s senior management to make the decision as to whether
the transaction meets the definition of suspicious transaction or activity and whether any filings with law
enforcement authorities should be filed. The Company will maintain a copy of the filing as well as all backup
documentation. The fact that a filing has been made is confidential. No one, other than those involved in the
investigation and reporting should be told of its existence. In no event should the parties involved in the
suspicious activity be told of the filing. The Company may inform the Company’s Board of the filing and the
procedures for maintaining records of the information used to verify a person’s name, address, and other
identifying information are required under this Policy. The following are required steps in the record keeping
- The Company is required to maintain a record of identifying information provided
by the customer.
- Where the Company relies upon a document to verify identity, the Company must
maintain a copy of the document that the Company relied on that clearly evidences the type of document and
any identifying information it may contain.
- The Company must also record the methods and result of any additional measures
undertaken to verify the identity of the customer.
- The Company must record the resolution of any discrepancy in the identifying
- All transaction and identification records will be maintained for a minimum
period of five years.
Company is responsible for directing the annual AML audit of the Company’s operations. The independent audit
will be conducted by an independent third party with working knowledge of BSA requirements, or by Company
personnel with working knowledge of BSA requirements. The Company will develop corrective action plans for all
issues that are raised in the audit and will provide the audit report and all corrective action plans to the
Company’s senior management for review. Reports of the corrective action will continue until all issues are