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USER AGREEMENT

1. Parties

1.1 This agreement is a contract between you and Koinal:

a) Koinal is part of SG VETERIS LIMITED, a private limited company incorporated in England and with a registered office at 9th Floor, The Shard, London Bridge Street, London, England, SE1 9SG and operating on https://www.koinal.io

b) You, 'your', person, user or customer are the person with whom enters Koinal and its website and into this Agreement.

2. Definitions and References

2.1 References and definitions in this Agreement are as follows:

a) Koinal refers to SG VETERIS LIMITED, a private limited company with company number: 10539075 and a registered office located at 9th Floor, The Shard, London Bridge Street, London, SE1 9SG.

b) Website, and/or Site is operated under the domain name of www.koinal.io and its subdomain under this domain name. (unless it is stated otherwise)

c) User, customer, you or 'your' are used to define a person with whom enters Koinal and its website and into this Agreement.

d) Buyers refer to the person whom buy digital currencies (crypto assets) that are supported by the Site.

e) User Agreement (also "Terms of Use") refers to this Agreement

f) Crypto asset is a digital asset that exists on blockchain and protects its integrity and functionality through special encryption systems. Examples of crypto assets are Bitcoin, Bitcoin Cash, Ripple and Litecoin. 'Coin' phrase and/or Digital Currency phrase will be used to describe all the digital assets that are on the Website and in this Agreement.

g) Blockchain, in this context, is a shared account ledger and record keeping database, whose integrity and correctness are maintained by means of mathematical formulas.

h) Wallet address is public key of digital assets where transactions can be sent.

i) Account refers to account opening and usage on Koinal Website and Services.

3. Scope of this Agreement and Purpose

3.1 The rules that are covered by this agreement are applicable to you from the first entrance to Koinal and is implemented throughout your membership. Users are obliged to read and accept these rules individually and collectively. From the moment your membership is created, the users are committed to accepting all of these rules individually.

3.2 Users acknowledge, declare and undertake that they will act in accordance with all matters stated in this Agreement. You should read the entire Terms of Use carefully before You use the Site or any of the services offered on the Site (the "Services"). If You do not agree to any terms of these Terms of Use, You are required not to use Koinal, the Website and the Services. 3.3 Please read the terms of use carefully before using the Website or any Service offered within. By using the Site and accessing or using our Services, You agree to act upon the Terms of Use. If You don't accept the Terms of Use or any provision therein, do not access the Site or use the Services.

3.4 Buy opening an account to use the Website or the Services, You expressly agree and warrant:

3.4.1 You have accepted these Terms of Use

3.4.2 You are at least 18 years of age and have full legal capacity to accept these Terms of Use and enter into a transaction involving Digital Currencies or Crypto Assets ('Coins').

4. Terms of Membership and Use of Account Services

4.1 Depending on Your country of residence, You may not be eligible to use all the Services of the Site. It is your responsibility to follow these rules and laws in your country of residence and/or country from which You access this Site and Services.

4.2 In regard to executing any transactions, User promise to provide a wallet address that is owned by the user and is under full control and authorisation of the user to which Digital assets, coins, will be transferred to. The control of wallet address is solely under the user control and Koinal has no right to claim ownership of the wallet address nor is responsible of managing the wallet address. Users acknowledge that Koinal will not be liable for any error with respect to your instructions of wallet address that you provided.

4.3 Koinal reserves the right to deny processing any pending transaction if required to do by law, regulations, competent court order or other competent authority in the event of any Digital Currency transaction is in violation of any provision of these Terms of use or puts Koinal's operation, good name or reputation at risk. In addition, Koinal may take any additional actions as available to it under any laws or regulations and these Terms of Use with respect to such transaction.

4.4 Koinal is for User's own personal and non-commercial usage only. Koinal is prone to maintain the security of the Website and Services that are available. By registering to us, You agree to provide us with the most current, accurate and complete information of You as prompted by the registration process, ID verification and Card Verification processes. The information that is requested in the registration process are, included but not limited to, your name, email address, your assurance of your acceptance of these Terms and Conditions. Prior to the identity verification process, you are required to complete your full name, date of birth, phone number, email address, postal address and national ID number (If applicable). In the identity verification process, it is required to submit your ID verification documents such as National ID Card, Passport or Driving License, utility bills, and your selfie holding your written consent and your Id document. In the card verification process, you are required to submit a selfie of you holding your physical card and your written consent. At the card verification process, you are required to submit first 6 and last 4 digits of your card number. You further agree to update and provide such information at all times. You authorise Koinal to make the inquires, whether directly or through third parties, to verify your identity or protect you against fraud or other financial crime and to take action we reasonably deem necessary based on the results of such inquiries. You can refer to our privacy policy on how your personal data is stored and used. You are obliged to read and accept the privacy policy as a part of this agreement. 4.5 You guarantee to use only one account of your own and promise not to use or access any other member or real person's account at any time or assist others in gaining unauthorised access.

4.6 The creation or use of the User account without obtaining our prior express permission will result in the immediate suspension of all mentioned Accounts, as well as pending transactions or account approvals. Any attempt to do so or to assist others (members or otherwise) or the distribution of instructions, any tools for that purpose, will result in the accounts of such users being terminated, without derogating from any other remedy to which Koinal may be entitled for such violation and Koinal may take further actions against You.

4.7 A user is allowed to open one account only. The responsibility of maintaining confidentiality and security of that User's account, including but not limited to, password, safeguarding its own Digital Assets, currency, coins and for all activity and transactions that are located on that account are on User's own responsibility. Koinal may request further information where it's necessary, including in the event of any suspicious activity related to User's account, including ID and authenticating documents, and may freeze any transactions that is pending while reviewing a User's account. User is obligated to comply with these security measurements or accept termination of its' account. Any loss or gain regarding the account related to this matter are subject to the account review and may be confiscated and a User will notify about the matter after the investigation is over.

4.8 User are obligated to notify Koinal immediately of any unauthorised use of its' account or password, or any other breach of security by email to contact@koinal.io. Any user who violates these rules may be terminated and hereafter held liable for losses incurred by Koinal or another user of Koinal and services.

4.9 It is forbidden and against Koinal policies to use the Services and the Website to perform criminal activity of any kind, including but not limited to, money laundering, illegal gambling operations, terrorist financing or malicious hacking. User agrees, guarantees and warrant not to use Koinal to perform the activities that are pointed out in this rule.

4.10 Due to the nature of coin wallet addresses, it is not possible to get a refund or re-enter a different address once a transaction is initiated. Users are obliged to understand this and agree on the terms prior to initiating any transactions.

5. Compliance

5.1 User must be in compliant with all laws, regulations, anti-money laundering provisions and KYC regulations that are applicable where user based in locally. It is users' sole responsibility to ensure that the use of Koinal and its services is compliant with laws and regulations in users' current base.

5.2 Koinal does not accept any user which has the following conditions and that is users' own responsibility to acknowledge and confirm that are not the case for them:

a) A person who are national or resident of Iran, North Korea, Cuba, Syria or Sudan or any other country included in the United States embargo, UN Sanctions, HM Treasury's financial sanctions regime (the 'Restricted Territories') or intends to distribute or provide the acquired Digital currency or the services to restricted territories;

b) A person name appears on the U.S Treasury Department's Specially Designated Nationals List, Unverified List HM Treasury's financial sanctions regime (the 'Restricted Persons') or a person who intend to distribute or provide the Services to any person of the 'Restricted Persons'

c) A person on prescribed Sanction lists. The screening on Koinal is subjected on United Nations, European Union, UK Treasury and UK Office of Financial Sanctions Implementation (OFSI)

d) A person who are a Politically Exposed Person (PEP).



5.3 It is Users' own and sole responsibility to pay and inquire with respect to the taxes applicable to Users' transactions on the website. It is Users' own and sole responsibility to report or remit the taxes payable to the appropriate tax authorities.

5.4 In connection with the use of Koinal website and services, you agree to comply with Koinal Compliance Policy and Prohibited Use conditions stated hereby.

6. Account Suspension, Termination and Cancellation

6.1 Hereby you are given knowledge that any time, Koinal, subject to its sole discretion is entitled to terminate your access to Website, its services and your account, including without limitation, Koinal's rights to the following actions:

a) Right to refuse processing, to cancel and reverse any transaction of Digital currencies, regardless if corresponding funds have been debited from your payment method; Or,

b) Right to suspend, restrict or terminate your account; Or,

c) Right to prohibit access to the Site, its content, tools, delay or remove hosted content and take technical and legal measures to keep users off the Site due to any reason subjected to Koinal's sole discretion, including without limitation as a result of: (i) Violation of these Terms of Use, including without limitations, failure to pay for any Transaction; or (ii) Attempts to gain unauthorised access to the Site or another User's account or providing assistance to others' attempting to do so; or (iii) Koinal has reasonable suspicion that a Transaction involves illegal activity, including without limitations, money laundering, terrorist financing, fraud, or any other crime; or (iv) Koinal reasonably suspects that Your Account or any Transaction is related to prohibited use or is non-compliant with any applicable laws or regulations; or (v) Koinal is requested to do so by a court order, law enforcement or other government or regulatory order or if Your Account is subject to litigation or investigation; or (vi) subject to Company's discretion, You abuse the Services provided by Koinal, including Koinal's by opening multiple accounts and/or taking advantages of promotions in bad faith; or (vii) Any of Koinal's third party providers denies providing You the Services; or (viii) if Koinal believes such Users are creating problems or possible legal liabilities; or (ix) force majeure events, including operational and technical errors. Linking to the terms above mentioned, Koinal, may subject to its sole discretion terminate the Services or refuse to open an account to any user or terminate any use by You to Koinal.



6.2 Upon any suspension, termination or cancellation of a Transaction, Koinal is under no obligation to allow You to reinstate such transaction and may not provide You the same price or same terms as any cancelled transaction.

6.3 As a part of our security protocol, User agrees to receive email notifications for transactions and logins. The options on unsubscribing such emails is available in any such emails.

6.4 Users may terminate their account at any time by giving written request and notice to contact@koinal.io. No termination fee shall apply, except User will be responsible for fulfilling any outstanding payment obligations to Koinal existing as of the effective date of termination and to settle any pending transactions. Koinal reserves the right to suspend any pending transactions at the time of cancellation.

7. Intellectual Property Rights

7.1 All Koinal Website and Services, content, design, images, text, software and trademarks (including Koinal name and the Koinal logo) are owned and licenced by Koinal. Therefore, all mentioned hereby are protected by intellectual property rights

7.2 Domain and subdomain names, trademarks, design and patterns on Koinal Website and Services are the exclusive property of Koinal.

8. Risks

8.1 Trading in Digital Currencies, just like fiat trading in real or virtual trading, involves significant risks. Prices can fluctuate and change on any given time or day. Due to such volatility, your digital assets may increase and decrease in value and may even become worthless.

8.2 Koinal does not guarantee any profit or loss from purchasing or selling your digital assets on Koinal Website. You are solely responsible and agree to take all the responsibility when it comes to purchase, selling or trading in Digital Currencies.

8.3 Koinal will make all efforts in reasonable grounds to ensure your requests on payments with instant card or bank transfers in time manner but Koinal makes no representations or warranty on time needed to complete processing Digital assets which is dependent upon many other dependencies' such as mining time or hard-fork instances.

9. Feedback, Queries, Complaints and Dispute Resolution

9.1 Customer Support team is available on contact@koinal.io or through the Live Chat button on our Website, and is ready to help you on any feedback, questions or complaints.

9.2 In the event of a complaint, please notify us on the cause of your complaint and give us any information that is relevant to your complaint. A Customer Complaint Officer will consider and respond to your complaint within 15 business days. Customer Complaint Officer will consider your complaint without prejudice based on the information you have provided, and any information provided by Koinal. Within 15 business days of our receipt of your complaint the Officer will address all points raised in your complaint by sending you an e-mail ("Resolution Notice") in which the Officer will: (i) offer to resolve your complaint in the way your requested; (ii) make a determination rejecting your complaint and set out the reasons for the rejection; or (iii) offer to resolve your complaint with an alternative solution. In exceptional circumstances, if the Officer is unable to respond to your complaint within 15 business days for reasons beyond Koinal's control, the Officer will send you a holding reply indicating the reasons for a delay in answering your complaint and specifying the deadline by which the Officer will respond to your complaint (which will be no later than 35 business days from our receipt of your complaint.

9.3 Offers. Any offer of resolution made to you will only become binding on us if accepted by you. An offer of resolution will not constitute any admission by us of any wrongdoing or liability regarding the subject matter of the complaint.

9.4 Financial Ombudsman Service. You may be able to take unresolved complaints to the Financial Ombudsman Service ("FOS"). You can find further information about the FOS and the types of complainants eligible to submit matters to the FOS using the following details:

Address: Financial Ombudsman Service, Exchange Tower, London E14 9SR.

Telephone: 0800 023 4567 or 0300 123 9 123.

Email: complaint.info@financial-ombudsman.org.uk

Website: www.financial-ombudsman.org.uk

10. Data Protection

10.1 You hereby acknowledge that Koinal may process your personal data that you have provided or in the future provide to us in relation to your account and in connection to this Agreement or the Koinal Services. Accordingly, you represent and warrant that:

a) your disclosure to us of any personal data relating to you was or will be made in accordance with all applicable data protection and data privacy laws, and those data are accurate, up to date and relevant when disclosed;

b) before providing any such personal data to us, you have read and understood our Privacy Policy, attached to this Agreement and a copy of which is also available at Privacy Policy, and, in the case of personal data relating to yourself, have (or will at the time of disclosure have) provided a copy of that Privacy Policy (as amended from time to time), to that individual; and

c) if from time to time we provide you with a replacement version of the Privacy Policy, you will promptly read that notice and provide a copy to any individual whose personal data you have provided to us.

Privacy Policy

SG VETERIS LIMITED therefore Koinal, ("Koinal", "we", "us" and "our" "SG VETERIS LIMITED") protect and respect the privacy of visitors to our website (www.koinal.io) and our customers ("Customer", "User", "you", "yourself") who use our services. To ensure transparency on our Privacy Policy, this Piracy Policy describes data handling practices when you access content that we own or operate on the website that is located on www.koinal.io and its subdomains or third-party applications that are in use.

Please take as long as you want to read this Privacy Policy carefully. If you have any questions regarding our Privacy Policy, please contact us on contact@koinal.io

Acceptance of Privacy Policy

By accessing and using our Services, you hereby declare your acceptance to the terms of this Piracy Policy as a part of User Agreement.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue to access or use of our Services and Website.

Changes on This Privacy Policy

Koinal reserves the right of change and modify this Privacy Policy at any time and when required by law, Koinal will notify you of any changes to this Privacy Policy. Koinal will notify Users by email for any changes by means of notice on our Privacy Policy. Visitors of the Website are required to check Privacy Policy on the website for any changes.

Purpose of Collecting Personal Information

Personal information is the data that can be used to identify you directly or indirectly, or to be used to contact you. Our Privacy Policy is gathered by all the personal information that you willingly submitted to us and also obtained from our partners. This Piracy Policy does not apply to any anonymised data, as it cannot be used to identify you.

You may be asked to provide personal information anytime you are in contact with any Koinal Services. The information that we gathered, may also be combined with other information to provide and improve our services and content.

Hereby, Koinal assures you that it will not give, sell, rent or loan any personal information to any third party.

Scope of Personal Information Collected

Koinal collects personal information to provide you with its Services and Website. It may be required by law to require certain personal information from Users or it is required to eliminate fraudulent use of personal data. Any information that you provide to us that is not required is voluntary. You are not obliged to provide any personal information when its requested, however, Koinal may not be able to serve you as expected or offer you all the Services when you do choose not to share the requested information.

Koinal collects the following types of personal information:

a) In regard to Personal Identification information, Koinal collects your full name, date of birth, photograph, phone number, email, national ID number and postal address.

b) In regard to identification processes, Koinal gathers National Identity card details, Passport Number, Driver's license details, photographic identification card and utiliy bill.

c) In regard to card verification process, Koinal collects, first 6 digits and last 4 digits of a card number and your bank account information.

d) In regard to transaction history, Koinal gathers, your coin transaction history, transaction amount and wallet addresses that you provide.

e) In regard to online identifiers, Koinal gathers, Geo location/ tracking details, browser fingerprint, browser name and versions and personal IP addresses.

f) In regard to usage data, Koinal gathers, information that you provide to our support team and your public social networking posts (if you address Koinal in your public post).

Usage of Personal Information

Primary purpose in collecting personal information is to provide secure and customised service experience. Overall, the personal information that are gathered, are mainly to use on creating and delivering our Services and contents and most importantly prevention of any fraudulent activities. We shall or may use personal information in the following ways:

a) Compliance purposes:
In order to comply with Anti-Money Laundering or terrorist financing laws, Koinal must identify and verify each user by checking them on third party applications such as third-party database and public records. The consequences of not processing or receiving your personal information for such purposes are the termination of your account as we cannot perform the Services accordance with legal and regulatory requirements.

EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information to comply with our legal obligations.

b) Assurance of User Agreement
In order to prevent any illegal activities or fraudulent behaviour and in order to comply with our User Agreement, Koinal needs to perform monitoring, investigating on personal data and financial data that are related to Users' accounts. The consequences of not processing your personal data such purposes are the termination of your account as Koinal cannot perform the Services in accordance with our terms.

c) Service Continuity
In order to provide Koinal's services, e.g buying digital currency, Koinal requires to collect information such as identification, contact information, wallet addresses and payment information. Koinal cannot perform its Services without this necessary information.

d) Communication related to Services
In order to keep you updated for the Services that we provide to you, such as login attempts to your accounts, your transaction-related information, account verifications, security issues and update on your accounts, we send administrative and account related information to you via your email address. Without such communications, you may not be aware of important notes related to your account that may affect the services that we provide to you.

e) Customer Service Duties
In order to contact you regarding your questions, disputes and provide services to you, your personal information needs to be processed by Customer Service Department. Without processing your personal information for such purposes, Koinal cannot respond to your request and ensure uninterrupted Use of the Services.

f) Security Performances
Koinal process your personal information in order to perform within security measurements, monitor and verify identity or service accessibility, eliminate spam, malware or security risks and to comply with applicable security laws and regulations. Without processing your personal information, Koinal may not be able to ensure the security of its Services.

EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legal obligations.

Koinal will not use your personal information for purposes other than those purposes that have been disclosed to you, without your permission. From time to time Koinal may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or Services may not be available to you.

Third Party Services

It might be necessary to obtain information regarding you, such as identity verifications. Your data might be checked within public databases, Id verification partners. It also might be necessary to perform checks against social media platforms.

Koinal obtains information about you from public databases and ID verification partners for purposes of verifying your identity (if applicable). ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. Pursuant to EEA Data Protection Law, our lawful basis for processing such data is compliance with legal obligations. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others.

Automatic Data Capture

Certain types of information may be received automatically, such as whenever you interact with The Website or use the Services. This information does not necessarily reveal your personal identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.

For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. How your device has interacted with our website, including pages accessed and links clicked may be automatically collected. Koinal may use identifiers to recognise you when you arrive at the Site via an external link, such as a link appearing on a third-party site.

Changes on Your Personal Information

You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

Contact Us

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should contact us at contact@koinal.io
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CONTACT
European Headquarter:

SG VETERIS LIMITED
9th Floor, The Shard 32 London Bridge St.
London, SE1 9SG, United Kingdom

+44(0) 203 457 0569
contact@koinal.io