Terms of Use

1. Introduction
‍These Terms of Use contain an electronic agreement (“Agreement” or “User Agreement”) between you (also referred to herein as “User”) and Blockbrdge.com, ("Blockbrdge", “we”, “us”, and “our”) governing the User's use of this website and all services, products, and content (“Blockbrdge Services” or “Services”) provided by Blockbrdge described below and that may be provided from time to time.

1.2 By signing up to use an Account through Blockbrdge or any associated websites, APIs, or mobile applications (collectively the “Site”), you agree that you have read, understood, and accept all of the Terms and Conditions contained in this document, as well as the Privacy Policy and AML/KYC Policy.

1.2 This document will govern the use of the Services provided by Blockbrdge. By using the Services, you agree to be bound by the Terms of Use set out on this website. This Agreement will come into effect when you confirm electronically that you agree to it. Blockbrdge recommends that you retain a copy of this Agreement and all transaction records.

1.4 Use of the Services and cryptocurrency may not be available to certain jurisdictions due to potential or actual regulatory restrictions. It is your responsibility to know the regulatory requirements concerning transactions with cryptocurrency in your jurisdiction before using the Services.

DISCLAIMER: The risk of loss in trading or holding cryptocurrency can be substantial. You should therefore carefully consider whether trading or holding cryptocurrency is suitable for you in light of your financial condition. In considering whether to trade or hold cryptocurrency, you should be aware that the price or value of cryptocurrency can change rapidly, decrease, and potentially even fall to zero.

2. Eligibility
To be eligible to use any of the Services, you must be at least 18 years old, have the capacity to enter into a legally binding contract, and reside in a country in which the relevant Services are accessible.

3. Services provided to you
3.1 Blockbrdge will act as your commercial agent and by agreeing with these Terms of Use you are explicitly giving Blockbrdge permission to act on your behalf and fulfill your order for cryptocurrency as instructed.

3.1.1 As your commercial agent, Blockbrdge will purchase cryptocurrency on your behalf and send/deliver it to the address indicated at the time of the order subject to the conditions of these Terms of Use.
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3.1.2 At no point during the purchase, will Blockbrdge be in possession or in control of User funds.
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3.2 Purchases/orders through Blockbrdge are one-offs and executed individually, one-by-one.

3.3 Together, the Services set out in clause 3 are referred to in this Agreement as the “Services”.

DISCLAIMER: Blockbrdge DOES NOT facilitate or provide trading or investment or brokerage accounts or facilities, nor does Blockbrdge provide investment or any other financial advice.

4. Customer registration process
4.1 To use the Services, you will need to register for an Account by providing your name, email address and accepting the Terms of Use. By using Blockbrdge, you agree and represent that you will use the Services only for yourself, and not on behalf of any third party. You are fully responsible for all activity that occurs under your Blockbrdge Account. Blockbrdge may, in its sole discretion, refuse to open an Account for you, or limit the number of Accounts that you may hold, or suspend, or terminate any Account, for any reason.

4.2 To become a User you must also provide Blockbrdge with the information that is requested as part of the Account opening process to verify your identity and for the detection of anti-money laundering, counter-terrorist financing, fraud, or any other financial crime and permit Blockbrdge to keep a record of such information as required by applicable law.

4.3 You will need to complete certain verification procedures before you are permitted to start using the Blockbrdge Account and Services.

4.4 The information requested may include certain personal information including, but not limited to, your name, address, telephone number, email address, date of birth, taxpayer identification number, government identification number, information regarding your bank account (such as the name of the bank, the account type, routing number, and account number) network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details. In providing this or any other information that may be required, you confirm that the information is accurate and correct and you agree to provide updates if any of the information changes. All information will be treated in accordance with the Data Protection provisions of this Agreement and EU law.

4.5 You authorise Blockbrdge to make enquiries, whether directly or through third parties, considered necessary to verify your identity or protect you and/or Blockbrdge against fraud or other financial crime, and to take action deemed reasonable and necessary based on the results of such inquiries. When Blockbrdge carries out these enquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to these enquiries in full. This is an identity check only and should have no adverse effect on your credit rating. Additionally, Blockbrdge may require you to wait some amount of time after completion of a transaction before permitting you to use further Services and/or before permitting you to engage in transactions beyond certain volume limits.

4.6 Failure to provide any information that Blockbrdge reasonably requests from you pursuant to applicable money laundering laws and regulations after you have become a User shall be grounds for the suspension of the provision of Services to you (including access to your Account) and/or the termination of this Agreement. The nature and extent of the information you are required to provide may differ, for example, based on the Services provided to you under this Agreement and/or the means of payment you use.

5. Transactions limits
5.1 The use of all Services is subject to Transaction Limits on volume (stated in CAD, EUR, etc.) that a User may transact with in a given period (e.g. daily). Transaction Limits are visible in your Account. Transaction Limits are determined by many factors, including payment method, verification steps completed, transaction history, payment type and more. Some features may require additional document verification of information by you to verify your identity.

5.2 Transaction Limits may change dynamically over time based on many factors, including, but not limited to, account activity, transaction history, region, and payment type. Limit change requests may require Users to submit additional information as part of the Enhanced Due Diligence (“EDD”) process. Blockbrdge reserves the right to refuse limit change requests or to modify them at a subsequent time, even if a User has successfully completed the EDD process. Users wishing to modify their Transaction Limits may send a request to: support@blockbrdge.com

6. Cryptocurrency purchase
6.1 Users will be able to purchase or sell cryptocurrencies from Blockbrdge and through Blockbrdge’s partner mobile applications and websites subject to the applicable fees displayed during the order flow. The price, exchange rate, and amount of the cryptocurrency that a User may wish to purchase or sell will be confirmed at the time of successful payment of the cryptocurrency order.

6.2 Acceptance by Blockbrdge of an order for a cryptocurrency purchase/sale does not guarantee that the User will receive the corresponding amount of cryptocurrency/fiat. The cryptocurrency order is conditional upon actual receipt of the funds from your bank, financial institution, wallet, credit or debit card, or other relevant party, as well as payment of any applicable fees.

6.3 Subject to clause 6.2 and the transaction being honoured by the User’s bank, card provider, or other relevant party, cryptocurrency orders shall be credited to any cryptocurrency wallet or address, as provided by you at the time of the order, and as soon as possible, once the cryptocurrency purchase/sale has been confirmed by the cryptocurrency network. Once submitted to a cryptocurrency network, a cryptocurrency purchase/sale will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the cryptocurrency network. Cryptocurrency transactions that are in a pending state will not be credited.

6.4 Blockbrdge may use a third-party payment processor to process any fiat payment between you and Blockbrdge.

7.Cancellations and refunds
7.1 Once a cryptocurrency order has been made it cannot be cancelled or recalled.

7.2 All cryptocurrency orders are final and cannot be refunded once the cryptocurrency has been sent to the cryptocurrency wallet or address indicated at the time of the order.

7.3 Once a cryptocurrency order has been sent to the cryptocurrency wallet or address indicated at the time of purchase/sale, it cannot be recalled or retrieved under any circumstances.

7.4 All cryptocurrency purchases or sales are considered final. Users are not entitled to any credit, or refund. Blockbrdge’s obligation towards the User will be absolutely discharged upon delivery of the cryptocurrency order. Users shall have no claim or right against Blockbrdge.

8. Suspension, termination and cancellation
8.1 Blockbrdge may:
(a) refuse to complete, or block or cancel your order;
(b) suspend, restrict, or terminate your access to any or all of the Services and/or;
(c) deactivate or cancel your Account with immediate effect for any reason, including but not limited to where:

8.1.1 we reasonably believe that we need to do so in order to protect our reputation;
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8.1.2 we are, in our reasonable opinion, required to do so by applicable law, regulation or any court or other authority to which we are subject in any jurisdiction;
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8.1.3 we reasonably suspect you of acting in breach of this Agreement;
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8.1.4 we have concerns that a transaction is erroneous or about the security of your Account or we suspect the Services are being used in a fraudulent or unauthorised manner;
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8.1.5 we suspect money laundering, terrorist financing, fraud, or any other financial crime;
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8.1.6 use of your Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Account activity;
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8.1.7 you take any action that may circumvent our controls such as opening multiple Accounts or abusing promotions which may be offered from time to time;
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8.1.8 you fail to provide on request such documentation as Blockbrdge (or any third party whose services we use in providing the Services to you under this Agreement) reasonably requires in order to comply with its obligations under applicable money laundering laws and regulations or otherwise to ensure the verification of your identity and/or funding sources to Blockbrdge satisfaction.
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8.1.9 any cryptocurrency order (purchase/sell) that is significantly larger in size compared to previous orders;
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8.1.10 we reasonably believe that it is necessary or desirable to do so in order to protect the security of the Account, including circumstances where any Account details may have been lost or stolen;

8.2 In the case of any such suspension, Blockbrdge shall make reasonable efforts to inform you about the withholding or suspension, provided that such disclosure:

8.2.1 is not in breach of any applicable law or regulation and does not contravene the instruction of any competent authority or regulator; and
8.2.2 would not compromise Blockbrdge’s reasonable security measures.

8.3 Blockbrdge shall not be liable to you for any losses you may suffer as a result of any reasonable action it takes to suspend the Account or withhold settlement of a cryptocurrency order in accordance with clause 8.

8.4 Where the reasons for Blockbrdge’s actions under clause 8 cease to exist, Blockbrdge may, at its discretion, either reinstate access to the Account and the Services and/or issue the User with new Account details and reserves the right to ask you to re-complete the Account opening procedures as outlined in these Terms and to resolve any open issues with your Account before a restriction can be removed.

8.5 We may suspend, restrict, or terminate your access to any or all of the Services and/or deactivate or cancel your Account, without reason. You acknowledge that our decision to take certain actions, including limiting access to, suspending, or closing your Account, may be based on confidential criteria that are essential for the purposes of risk management and security protocols. You agree that Blockbrdge is under no obligation to disclose the details of its risk management and security procedures to you.

9. Fees
9.1 All fees payable under this Agreement are displayed during the order flow and shall be paid in CAD, EUR or any other currency that is agreed between Blockbrdge and the User.

9.2 Blockbrdge reserves the right to pursue any financial losses suffered due to you filing a chargeback procedure with your bank or financial institution. These can include administration fees levied by the card acquirer and card schemes as well as the monetary value of the cryptocurrency order (purchase/sale).

10. Data Protection Law
10.1 You acknowledge that we may process personal data in relation to you, in connection with this Agreement, or the Services provided under The General Data Protection Regulation (GDPR) 2016. We will process and sometimes update this personal data in accordance with the Terms of Use and/or Privacy Policy. Accordingly, you represent and warrant that:

10.1.1 your disclosure to us of any personal data 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;
10.1.2 before providing any such personal data to us, you acknowledge that you have read and understood our Privacy Policy and AML/KYC Policy;
10.1.3 from time to time, we provide you with a replacement version of the Privacy Policy and AML/KYC Policy, or re-direct towards a website containing the updated Privacy Policy and AML/KYC Policy, you will promptly read that notice and provide updated data.

11. Liability
11.1 Clause 11 sets out Blockbrdge’s entire financial liability (including any liability for the acts or omissions of its employees, agents and subcontractors) to the User:

11.1.1 arising under or in connection with this Agreement;
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11.1.2 in respect of any use made by the User of the Services or any part of them; and
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11.1.3 in respect of any representation, misrepresentation (whether innocent or negligent), statement or tortious act or omission (including negligence) arising under or in connection with this Agreement.

11.2 Except as expressly and specifically provided in this Agreement, Blockbrdge disclaims all warranties and conditions express or implied, including, but not limited to, implied warranties of satisfactory quality and fitness for a particular purpose, in relation to the Services, their use and the results of such use.

11.3 All warranties, representations, conditions and all other terms of any kind whatsoever implied by statute or common law are excluded from this Agreement to the fullest extent permitted by applicable law.

11.4 Whilst Blockbrdge takes every care to ensure that the standard of the website remains high and to maintain the continuity of it, the Internet is not always a stable medium, and errors, omissions, interruptions of service, and delays may occur at any time. As a result, we do not accept any ongoing obligation or responsibility to operate the Blockbrdge API.

11.5 Blockbrdge disclaims all liability associated with the use of cryptocurrency, including:

11.5.1 unknown inherent technical defects;
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11.5.2 regulatory or legislative changes; and
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11.5.3 currency fluctuation.

11.6 Nothing in this Agreement excludes the liability of Blockbrdge:

11.6.1 for death or personal injury caused by Blockbrdge negligence;
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11.6.2 for fraud, fraudulent misrepresentation, or fraudulent misstatement; or
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11.6.3 any statutory liability not capable of limitation.

11.7 Subject to clause 11.6, Blockbrdge will not be liable whether in tort (including for negligence or breach of statutory duty), contract, misrepresentation (whether innocent or negligent), restitution or otherwise for any loss of profits, loss of business, loss or corruption of data, depletion of goodwill and/or similar losses, or pure economic loss, or for any special, punitive, indirect or consequential loss costs, damages, charges or expenses however arising under this Agreement or for any loss, damage or corruption of any cryptocurrency as a result of the instructions, acts or omissions of the User. This shall include any losses attributable to a failure by the User to keep secure any security or other information relating to the Account and access to it.

DISCLAIMER: Except for the express statements set forth in this Agreement, you hereby acknowledge and agree that you have not relied upon any other statement or understanding, whether written or oral, with respect to your use and access of the Blockbrdge Services and Site.

12. Warranties and representations
12.1 By agreeing to this Agreement, you represent, warrant and undertake to us that:

12.1.1 you have full power and authority to enter into this Agreement;
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12.1.2 you understand and acknowledge that we do not warrant that any of the Services available through the Blockbrdge API are suitable or appropriate for your needs and that you must take your own independent legal and other advice on such Services;
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12.1.3 you are entering into this Agreement as principal and not on behalf of any third party;
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12.1.4 you will not violate any applicable laws by entering into this Agreement or receiving the Services provided under it;
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12.1.5 you will not provide false, misleading, or inaccurate information;
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12.1.6 you will not facilitate any viruses, malware, worms, trojan horses or some other computer programming routines that may damage, corrupt, disrupt, misuse or gain unauthorized access to any data, system information or Blockbrdge;
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12.1.7 funds or cryptocurrencies transferred to the Account or any wallet or address have been acquired lawfully;
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12.1.8 you will not use an anonymizing proxy; use any other automatic devices, spider or manual process to copy or monitor our websites without our prior written permission;
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12.1.9 you will not harass and/or threaten our employees, agents, or other Users;
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12.1.10 you understand and acknowledge that while we make reasonable endeavours to ensure the accuracy of the information that we provide, and which in turn, is provided to you, neither we nor any of our directors, employees or agents make any representation or warranty, express or implied, as to the accuracy or completeness of such information;
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12.1.11 any information provided by you to Blockbrdge under this Agreement is true, complete, accurate, up to date and not misleading; and
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12.1.12 you shall provide all assistance reasonably requested by Blockbrdge to enable Blockbrdge to comply with its obligations under this Agreement.

12.2 Blockbrdge warrants, represents, and undertakes that it shall provide the Services with reasonable care and skill.

12.3 No Warranties. Services are provided on an “as is” and “as available” basis, with no further promises made by us around availability of the Services. Specifically, we do not give any implied warranties of title, merchantability, fitness for a particular purpose and/or non-infringement. We do not make any promises that access to the Site, any of the Services, or any of the materials contained therein, will be continuous, uninterrupted, timely, or error-free.

12.4 Blockbrdge makes no representation or warranty that the Services are applicable or appropriate for use by Users in all jurisdictions and it is your responsibility to ensure compliance with the laws of any relevant jurisdiction of your residence.

13. Right of withdrawal
13.1 You have 14 (fourteen) calendar days to exercise your right of withdrawal from this Agreement, without having to justify any reason or pay any penalty. This withdrawal period begins on the day after the date that your application is accepted by us.

13.2 We will not normally provide the Services during the withdrawal period. Any Services, orders or purchases which are fully performed before a withdrawal cannot be reversed.

13.3 You must notify your withdrawal request to us within the allotted period in writing or by email to support@blockbrdge.com.

13.4 If you exercise your right of withdrawal, this Agreement will be terminated at no cost to you.

14. Term
14.1 This Agreement will commence in the manner set out in clause 1 and will continue unless either party notifies the other of termination, in writing, in accordance with this Agreement.

14.2 This Agreement can be terminated immediately by the User providing written notice to Blockbrdge.

15. Force Majeure
15.1 No party will be in breach of this Agreement nor liable for any failure to perform its obligations under this Agreement if that failure results from circumstances beyond its reasonable control.

16. Notices
16.1 We may (where allowed to do so by law) communicate with you by posting information in your Account or on the website, in which case the information will be treated as received by you when it is posted by us.

16.2 We may also contact you at the postal or email address you provide us with when applying to open your Account. Notices sent by email will be deemed to have been received at the time of transmission as shown by the sender’s records (or if sent outside business hours, at 9 am on the first Business Day following dispatch). Notice sent by post will be deemed to have been received on the second business day after posting.

17. Complaints
17.1 For any complaint relating to the Services, you are advised to contact support@blockbrdge.com

18. General
18.1 Your Compliance with Applicable Law. You must comply with all applicable laws, regulations, licensing requirements and third-party rights (including, without limitation, data privacy laws) in your use of the Services.

18.2 We grant you a limited, non-exclusive, non-transferable licence, subject to the terms of this Agreement, to access and use the Site, and related content, materials, information (collectively, the “Content”) solely for approved purposes as permitted by us from time to time. Any other use of the Site or Content is expressly prohibited and all other right, title, and interest in the Site or Content is exclusively the property of Blockbrdge and its licensors. You agree not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part.

18.3 “Blockbrdge”, blockbrdge.io and all logos related to Blockbrdge or displayed on the Site are trademarks or registered marks of Blockbrdge or its licensors. You may not copy, imitate or use them without our prior written consent or any third party’s copyright, trade secret, patent or other intellectual property rights, or rights of publicity or privacy.

18.4 Your use of the Blockbrdge Services and the Site is subject to international export controls and economic sanctions requirements. By sending, buying, or selling cryptocurrencies through the Site or Blockbrdge, you agree that you will comply with those requirements. You are not permitted to acquire cryptocurrency or use any of the Blockbrdge Services through the Site if:

18.4.1 you are in, under the control of, or a national or resident of Cuba, Iran, North Korea, Sudan, or Syria or any other country subject to United States embargo, UN sanctions, the European Union or HM Treasury’s financial sanctions regimes (each a “Sanctioned Country”), or if you are a person on the U.S. Treasury Department’s Specially Designated Nationals List or the U.S. Commerce Department’s Denied Persons List, Unverified List, Entity List, or the EU or HM Treasury’s financial sanctions regime (a “Sanctioned Person”); or
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18.4.2 you intend to supply any acquired or stored cryptocurrency to a Sanctioned Country (or a national or resident of a Sanctioned Country) or Sanctioned Person.

18.5 We will notify you of any change to the Agreement on your first use of the Services after any amendment. You will be deemed to have accepted the change if you continue to use the Services. If you do not accept the change, you should let us know, and the Agreement will terminate. You may also end the Agreement immediately and free of charge with effect at any time.

18.6 We may make all other amendments to the Agreement by posting the revised Agreement on the Site or by emailing it to you, indicating when the revised Agreement becomes effective. Although we will endeavour to provide you with advance notice where possible, where lawful we may indicate that the revised Agreement shall be effective immediately and if you do not agree with any such modification, you should close your Account and cease using Blockbrdge.

18.7 Copies of the most up-to-date version of the Agreement will be made available in the Site at all times and will be provided to you by email on your request.

18.8 Nothing in this Agreement shall be deemed or is intended to be deemed, nor shall it cause, either you or Blockbrdge to be treated as partners or joint ventures, or either you or Blockbrdge to be treated as the agent of the other.

18.9 If you receive information about another User through the Blockbrdge Services, you must keep the information confidential and only use it in connection with Blockbrdge. You may not disclose or distribute a User’s information to a third party or use the information except as reasonably necessary to carry out a transaction and other functions reasonably incidental thereto such as support, reconciliation, and accounting unless you receive the User’s express consent to do so. You may not send unsolicited communications to another User through Blockbrdge.

18.10 Contact Information. You are responsible for keeping your email address and telephone number up to date in your Account profile in order to receive any notices or alerts that we may send you (including notices or alerts of actual or suspected security breaches).

18.11 Entire Agreement. This Agreement (including documents incorporated by reference herein) comprise the entire understanding and agreement between you and Blockbrdge as to the subject matter hereof, and it supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), and every nature between and among you and Blockbrdge.

18.12 Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.

18.13 This Agreement is personal to you and you cannot transfer or assign your rights, licenses, interests and/or obligations to anyone else. We may transfer or assign our rights licenses, interests and/or our obligations at any time, including as part of a merger, acquisition or other corporate reorganisation involving Blockbrdge, provided that this transfer or assignment does not materially impact the quality of the Services you receive. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns.

18.14 If any provision of this Agreement is determined to be invalid or unenforceable under any applicable law, this will not affect the validity of any other provision. If any provision is found unenforceable, the unenforceable provision will be severed, and the remaining provisions will be enforced.

18.15 We may not always strictly enforce our rights under this Agreement. If we do choose not to enforce our rights at any time, this is a temporary measure and we may enforce our rights strictly again at any time.

18.16 This Agreement and any information or notifications that you or we are to provide should be in English. Any translation of this Agreement or other documents is provided for your convenience only and may not accurately represent the information in the original English. In the event of any inconsistency, the English language version of this Agreement or other documents shall prevail.

18.17 Change of Control. In the event that Blockbrdge is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you and our relationship with you (including this Agreement) as part of such merger, acquisition, sale, or other change of control.

18.18 All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, the sections relating to suspension or termination, Blockbrdge Account cancellation, debts owed to Blockbrdge, general use of the Site, disputes with Blockbrdge, and general provisions will continue to be binding and operate after the termination or expiration of this Agreement.

18.19 This Agreement will be governed by, and construed in accordance with, the laws of Lithuania and, subject to any overriding legal requirements, the parties irrevocably submit to the exclusive jurisdiction of the Lithuania courts. This Agreement and any information or notifications that you or we are to provide should be in English.

18.20 If you have any feedback, questions, or complaints, you may contact us via our customer support webpage or at support@blockbrdge.com

Privacy

Blockbridge.com (defined below under “our entities and relationship to you”) is committed to protecting the privacy of those Users (referred to “you” and “your” herein) who create Accounts for the purposes of accessing our Services. This Privacy Policy describes how we collect, use and share your personal data when you access Blockbridge Services, which include content on the websites located at blockbridge.io, any other websites, pages, features, or content we own or operate (collectively the “Site(s)”), or any application programming interface (“API”) or third-party applications relying on such an API, and related services (referred to collectively hereinafter as “Blockbridge Services” or “Services”).

If you reside outside of the UK and the European Economic Area, accessing and using our Services means that you accept this Privacy Policy and its terms.

Contact Us
If you have any questions about this Privacy Policy, you can contact us:
By email: support@blockbridge.com  
By visiting this page: blockbridge.com  

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected
2.1.1 Personal Data
Personal data means any data which relates to a living individual who can be identified from that data, or from that data and other information which is in the possession of, or is likely to come into the possession of, Blockbridge (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Blockbridge or any other person in respect of an individual. The definition of personal data depends on the relevant law applicable to your physical location.

2.1.2 Usage Data
Usage Data is collected automatically when using the Service.

Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

2.1.3 Data from Third-Parties
This includes information Blockbridge may obtain about you from third party sources. The main types of third parties we receive your personal data from are:

• Public Databases, Credit Bureaus & ID Verification Partners in order to verify your identity in accordance with applicable law. ID verification partners such as Shufti Pro, AcuityTec, and MerkleScience use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction’s lists maintained by public authorities, and other relevant data.
• Blockchain Data to ensure parties using our Services are not engaged in illegal or prohibited activity and to analyse transaction trends for research and development purposes.
• Marketing Partners & Resellers so that we can better understand which of our Services may be of interest to you.
• Your financial services providers. For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.

2.1.4 Tracking Technologies and Cookies
Blockbridge uses Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. The technologies we use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on your service. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

2.2 Use of Your Personal Data
2.2.1 How We Use Your Personal Data
Blockbridge may use your personal data in the following ways and for the following purposes:

• To provide and maintain our Services, including to monitor the usage of our Services.
• To maintain legal and regulatory compliance, we need to process your personal data in order to comply with anti-money laundering and security laws. We also process your personal data in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss.
• For the performance of a contract, the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
• To contact you via email, telephone calls, SMS, or other equivalent forms of electronic communication, such as service updates regarding administrative or account-related information, security issues, or other transaction-related information. These communications are important to share developments that may affect how you can use our Services. You cannot opt-out of receiving critical service communications.
• To provide communications and customer services according to your preferences and in compliance with applicable law, we may send you marketing communications to inform you about events, to deliver targeted marketing and to share promotional offers. If you are a new client or partner, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please submit a request via email at support@blockbridge.com.
• We also process your personal information when you contact us to resolve any questions, disputes, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
• For business transfers, we may use your data to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
• For other purposes: We may use your data for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing and your experience.

2.2.2 Disclosing your Personal Data to Third Parties
Blockbridge may share your personal data in the following situations:

• With Service Providers: We may share your personal data with Service Providers to monitor and analyse the use of our Service, to contact you.
• With Affiliates: We may share your data with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us. Our contracts require these service providers to only use your data in connection with the services they perform for us and prohibit them from sharing your data with anyone else.
• With Business Partners: We may share your data with our business partners to offer you certain products, services or promotions. This includes financial institutions which we partner with to process payments you have authorised.
• With other Users: When you share personal data or otherwise interact in the public areas with other Users, such information may be viewed by all Users and may be publicly distributed outside. If you interact with other Users, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other Users will be able to view descriptions of your activity, communicate with you and view your profile.
• Business Transfers: If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.
• Law Enforcement: Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
• Other legal requirements: We may disclose your personal data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
• With your consent: We may disclose your personal data for any other purpose with your consent.

3. Transfer of Your Personal Data
Your personal data is processed at Blockbridge’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you reside in the EEA or the UK, we rely upon a variety of legal mechanisms to facilitate these transfers of your personal information.

In addition, we may rely on certain exemptions provided for under data protection law for our international transfers. For example, because Blockbridge operates and provides its Services globally, we need to share information with our Affiliates and to data centers outside the EEA in order to develop, offer, and improve our Services (Article 49(1)(b) GDPR). In addition, we may rely on certain exemptions for sharing personal information with law enforcement outside of the EEA in emergency situations (Article 49(1)(f) GDPR).

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Blockbridge will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

4. Retention of Your Personal Data
Blockbridge will retain your personal data only for as long as is necessary for the purposes set out in our Privacy Policy and AML/KYC Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

5. Security of Your Personal Data
The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Blockbridge implements and maintains reasonable measures to protect our information and information systems. Customer files are protected with safeguards according to the sensitivity of the relevant information. Reasonable controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorised employees.

We may store and process all or part of your personal data and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, anywhere in the world where our facilities or service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

As a condition of employment, Blockbridge’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal information is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential customer information by a Blockbridge employee is prohibited and may result in disciplinary measures.

When you contact a Blockbridge employee about your file, you may be asked for some personal details. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file. You also play a vital role in protecting your own personal information; do not reveal personal data to any third-parties and immediately notify us if you become aware of any unauthorised access to or use of your Account.

6. Children’s Personal Data
Blockbridge does not knowingly request to collect personal data from any person under the age of 18. If a User submitting personal information is suspected of being younger than 18 years of age, Blockbridge will require the User to close his or her Account and will not allow the User to continue using our Services. We will also take steps to delete the data as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

7. Cross Border Transfers
Blockbridge is an international business with operations in regions and countries. This means we may transfer to locations outside of your country. When we transfer your personal information to another country, we will ensure that any transfer of your personal information is compliant with applicable data protection law.

8. Your Privacy Rights
Depending on applicable law of where you reside, you may be able to assert certain rights related to your personal data These rights include:

• The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• The right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation.
• In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to Blockbridge;
• The right to request that we rectify your personal data if it is inaccurate or incomplete;
• The right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;
• The right to object to, or request that we restrict, our processing of your personal data in certain circumstances. There may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
• The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us via email at support@blockbridge.io. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.

9. Links to Other Websites
Our Service may contain links to other websites that are not operated by Blockbridge. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

Blockbridge has no control over and assumes no responsibility for the content, privacy policies or practices of any third-party sites or services.

1. Changes to this Privacy Policy
   We constantly try to improve our Services. As such, Blockbridge may need to update or change this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and where appropriate, provide you with reasonable notice of any material changes prior to the change becoming effective or as otherwise required by law and update the “Last Updated” date at the top of this Privacy Policy. Otherwise, we will let you know via email and/or a prominent notice on our Service. You are advised to review this Privacy Policy periodically for any changes. We may provide additional "just-in-time" disclosures or information about how we collect or use your data in certain services.

AML/KYC Policy

Blockbrdge Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Blockbrdge being involved in any kind of illegal activity.

Both international and local regulations require Blockbrdge to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in case of any form of suspicious activity from its Users.

For Law Enforcement requests please direct your official document to our compliance team here.

The AML/KYC Policy covers the following matters:

• Verification procedures
• Compliance Officer
• Monitoring transactions
• Risk assessment
• Transaction rights

1. Verification Procedures
One of the international standards for preventing illegal activity is Customer Due Diligence (“CDD”). According to CDD, Blockbrdge establishes its own verification procedures within the standards of anti-money laundering and Know Your Customer “KYC” frameworks, including Enhanced Due Diligence “EDD” for Users presenting a higher risk, such as Politically Exposed Persons “PEPs”.

Blockbrdge’s identity verification procedure requires the User to provide Blockbrdge with reliable, independent source documents, data, or information e.g., national ID, international passport, bank statement, utility bill. For such purposes, Blockbrdge reserves the right to collect User’s identification information as determined by its Terms of Use and Privacy Policy.

Blockbrdge will take steps to confirm the authenticity of documents and information provided by Users of all Services as defined under the Terms of Use and Privacy Policy. All legal methods for double-checking identification information will be used, and Blockbrdge reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Blockbrdge reserves the right to verify User’s identity on an ongoing basis, especially when their identification information has been changed or User activity is deemed to be suspicious (unusual for the particular User). In addition, Blockbrdge reserves the right to request up-to-date documents from Users despite having passed identity verification in the past.

User’s identification information will be collected, stored, shared, and protected strictly in accordance with Blockbrdge’s Privacy Policy and related regulations.

Once the User’s identity has been verified, Blockbrdge is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

Blockbrdge is prohibited from transacting with individuals, companies, and countries that are on prescribed sanctions lists. Blockbrdge will therefore screen against United Nations, European Union, UK Treasury, FATF, and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which it operates.

2. Compliance Officer
The Compliance Officer is the person, duly authorized by Blockbrdge, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Blockbrdge’s anti-money laundering and counter-terrorist financing, including but not limited to:

2.1 collecting Users’ identification information;
2.2 establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations;
2.3 monitoring transactions and investigating any significant deviations from normal activity;
2.4 implementing a records management system for appropriate storage and retrieval of documents, files, forms, and logs;
2.5 updating risk assessment regularly;
2.6 providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in the prevention of money laundering, terrorist financing, and any other illegal activity.

3. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Blockbrdge relies on data analysis as a risk-assessment and suspicion detection tool(s). Blockbrdge performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

3.1 daily check of Users against recognized “black lists” (e.g. OFAC);
3.2 aggregating transfers by multiple data points;
3.3 placing Users on watch and service denial lists;
3.4 opening cases for investigation where needed;
3.5 sending internal communications and filling out statutory reports;
3.6 case and document management.

With regard to the AML/KYC Policy, Blockbrdge will monitor all transactions and it reserves the right to:

3.7 ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
3.8 request the User to provide any additional information and documents in case of suspicious transactions;
3.9 suspend or terminate a User’s Account when Blockbrdge has reasonably determined suspicion that such User(s) are engaged or have engaged in illegal activity.
The above list is not exhaustive, and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

4. Risk Assessment
Blockbrdge, in line with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Blockbrdge is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

5. Transaction Rights
Blockbrdge reserves the absolute right to refuse to process, or to cancel, correct, clawback, hold, or reverse, any cryptocurrency order (purchase/sell) at its sole discretion, even after funds have been debited from your Account in response to a subpoena, court order, or other government order, or if the Compliance Officer suspects that a transaction may involve:

5.1 money laundering;
5.2 terrorist financing;
5.3 human trafficking or sexual exploitation;
5.4 fraud; or
5.5 any other type of financial crime.
In such instances, Blockbrdge will cancel, correct, clawback, hold, or reverse the transaction with no obligation to reinstate a cryptocurrency order (purchase/sell) at the same price or on the same terms as the affected transaction in question.