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Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion.

The policy is based on management of compliance risks arising from customers; and it also oversees:

  • Ongoing compliance with the requirements introduced by the national and international laws, regulations and sanctions.
  • Implementation of the risk-based “Know Your Customer” and “Customer Activity Monitoring” principles, Determination and reporting of the suspicious transactions.
  • Preservation of reputation and brand value of the Bank towards national and international authorities.

 Laundering of proceeds of crime and financing of terrorism may arise diversely from various fields of activity. Risk-based approach enables the measurement of risks for potential laundering of proceeds of crime based on the field of activity, identification of the criteria, also activation of the appropriate means and methods for mitigating and controlling such risks. For the purpose of preventing any transactions with respect to laundering of proceeds of crime and financing of terrorism, Bitzuri arranges and organizes the works required for implementation of adequate procedures in relation to monitoring the customers’ transactions, related reporting, retention of records, organization of the training activities and performance of the internal auditing activities, with a risk-based approach; and ensures that any risks falling under such scope are controlled.


The primary purpose of the risk management policy is to ensure identification, assessment and scoring of risks, action planning and mitigation of the potential risks the exchange may be exposed to, in relation to laundering of proceeds of crime and financing of terrorism. To that end, the Exchange has developed “Know Your Customer” and “Customer Activity Monitoring” risk assessment principles:

1. Know Your Customer

The Exchange performs necessary controls and takes additional measures with respect to:

  • Identification and verification of the valid identity and address details of customers, acceptable to the legal authorities, before performing a transaction and during the course of a continuous business relation.
  • Possibility of the customers being included on national/international sanctions lists.

2. Risk Assessment Methodology

All customers should undergo an assessment process in respect of potential risks of laundering of proceeds of crime and the associated risks as part of the minimum standards set out under International Financial and Economic Crimes Policy. For this purpose, the Exchange implements a customer risk assessment methodology which takes into account:

  • The geographical location where the customer operates (country, region, etc.).
  • Any persons or entities present in national and international sanctions lists.



For the purposes of prevention of laundering of proceeds of crime and financing of terrorism, the Exchange carries out a monitoring and control process, at a minimum, in relation to High-risk customers.


Bitzuri Fintec Limited has designated its Compliance Officer (CO) as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. CO has a working knowledge of compliance requirements and its implementing regulations and is qualified by experience, knowledge and training. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.


3.  AML Recordkeeping

a. Responsibility for Required AML Records and STR – Suspicious Transaction Reporting Filing.
Our AML Compliance Person and his or her designee will be responsible for ensuring that AML records are maintained properly and that STR is filed as required. In addition, as part of our AML program. We will keep other documents according to existing laws and other recordkeeping requirements.

b. SAR Maintenance and Confidentiality
We will hold STR and any supporting documentation confidential. We will not inform anyone outside of law enforcement or regulatory agency about a STR. We will refuse any subpoena requests for information that would disclose that a STR has been prepared or filed.  We will segregate STR filings and copies of supporting documentation from other firm books and records to avoid disclosing STR filings. Our AML Compliance Person will handle all subpoenas or other requests. We may share information with another financial institution about suspicious transactions.

4. Training Programs

We will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. Our training will occur on at least an annual basis. It will be based on our firm’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.

Our training will include, at a minimum:

  • how to identify red flags and signs of money laundering that arise during the course of the employees’ duties;
  • what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis;
  • what employees’ roles are in the firm’s compliance efforts and how to perform them;
  • the firm’s record retention policy;
  • the disciplinary consequences (including civil and criminal penalties) for non-compliance.
  • We will develop training in our firm, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures and explanatory memos. We will maintain records to show the persons trained, the dates of training and the subject matter of their training.
  • We will review our operations to see if certain employees, such as those in compliance, margin and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.


This Privacy Policy governs the manner in which Bitzuri Fintec Ltd. collects, uses, maintains and discloses information collected from users {of the website}

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Personal identification information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, place an order, fill out a form, respond to a survey, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Web browser cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How we use collected information

Bitzuri Ltd. may collect and use Users personal information for the following purposes:

  • To run and operate our Site

We may need your information display content on the Site correctly.

  • To improve customer service

Information you provide helps us respond to your customer service requests and support needs more efficiently.

  • To personalize user experience

We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.

  • To Improve our Site

We may use feedback you provide to improve our products and services.

  • To run a promotion, contest, survey or other Site feature

To send Users information they agreed to receive about topics we think will be of interest to them.

  • To send periodic emails

We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests.

Electronic newsletters

If the User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Compliance with children’s online Privacy Protection Act.

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 18, and no part of our website is structured to attract anyone under 18.

Changes to this Privacy Policy

Bitzuri has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Site, revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at This document was last updated on February 9, 2019

1. Preliminary Provisions

1.1. Through these Terms and Conditions, we are placing legal conditions on your use of the Site, Exchange, and Services and making certain promises to you. By accessing or using the Services, printing or downloading materials from the Site, or otherwise using the Site, you agree to comply with and be legally bound by this Agreement. If you do not agree to any of the terms set forth in this Agreement, please immediately discontinue access to and use of the Site, the Exchange and the Services.

1.1.1. If you are under the age of eighteen (18) or the legal age for entering legally binding contracts under applicable laws, you are not permitted to use this Site, the Exchange, or the other Services at all. Misrepresentation of your age to gain access to our Site or Services is considered a breach of this Agreement and may constitute computer hacking under applicable law. By accessing or using the Services you represent and warrant that you are 18 or older and otherwise are legally competent to enter into this Agreement.

1.1.2. If you do not understand all of the terms in this Agreement, then you should consult with a lawyer before using the Site, Exchange, or the Services.

1.1.3. We may amend or modify this Agreement at any time by posting a revised Agreement on the Site, and such changes or modifications shall be effective at such time. By continuing to access or use the Site or Services after we have posted a revised Agreement, you agree to be bound by the modified Agreement. In the event that you do not agree to be bound by the modified Agreement, you must cancel your Account and otherwise cease accessing or using the Site and Services. You further agree that we may Modify or discontinue any portion of the Services, and

1.1.4. Suspend or terminate your access to the Services, at any time, and from time to time, without notice to you in certain, limited circumstances described herein. You agree that we shall not be liable to you or any third party for any modification or termination of the Services, or suspension or termination of your access to the Services, except to the extent otherwise expressly set forth herein.

2. Registration of Bitzuri Account.

In order to use the Services, you will need to register for an account by providing your name, an email address, password, and accepting the terms of this Agreement and our Privacy Policy. We may, in our sole discretion, refuse to open an Account for you, or limit the number of accounts that you may hold.

3. Electronic Signatures / Assent Required:

3.1. Nobody is authorized to access this Site or use the Services unless they have accepted to be bound this Agreement. You manifest your agreement to this Agreement by taking any act demonstrating your assent thereto. Most likely, you have clicked or will click a button containing the words “I agree” or some similar syntax. You should understand that this has the same legal effect as you placing your physical signature on any other legal contract. If you click any link, button, or other device provided to you in any part of our Site’s interface, then you have legally agreed to all of these Terms and Conditions. Additionally, by using any part of our Site or Services in any manner, including the Exchange, you understand and agree that such use constitutes your affirmation of your complete and unconditional acceptance to all of the terms in this Agreement.

3.2. Even if you fail to sign this Agreement, you understand and agree that you are still bound by the terms of this Agreement by virtue of your viewing the Site or using any portion of the Site or our Services.

3.3. If you are seeking information regarding any illegal activities, or seeking to engage in any illegal or fraudulent financial activity, please leave this Site immediately and do not attempt to use the Services. You acknowledge that you are aware of the legality of using our Services in your relevant local jurisdiction, and you agree that you will not use the Services, including the Exchange, if such use is prohibited or otherwise violates the laws of your state, province, country, or other. jurisdiction.

4. Explanation of Membership and the Exchange.

4.1. Access and limited license – All users may access certain public areas of the Site; however, only Members may use the Exchange or ancillary services. You understand that all we are providing to you is access to our Services as we provide them. You need to provide your own access to the Internet, and any Internet access or other fees that you incur to access our Site and use our Services are your sole responsibility. We are not providing any hardware or software to you – and you need to purchase or license the necessary hardware and software to access the Site and Services. This Agreement covers all public and non-public areas of the Site.

4.2. Your account and any available currency therein are not credit cards, bank accounts, or deposits. Your account with us is not a bank account. Our services are not financial instruments. No interest will be paid on any funds or currency you use to purchase or trade for any other currency, bitcoin, or any other thing with other members, and all assets, including such currency or bitcoin, that are directly held by the company are not insured by the company or any government agency. Please note that Bitzuri Financial Company Ltd will maintain depository accounts with a reputed bank for customer currency. All currency traded or purchased by you will be associated with your account until used to trade with other members or until withdrawn by you.

4.3. We are not responsible for any loss or damage incurred by you as a result of your use of our Services or for your failure to understand the nature of virtual currencies or the market for such currencies. All we are providing you is a method by which you can exchange, trade, and/or store certain virtual currencies, and we make no representations or warranties concerning the value, stability, or legality of virtual currencies.

5. Risk Acknowledgement:

5.1. You accept the following risks:

5.1.1. The risk of loss in trading virtual currencies such as Bitcoin (collectively, “Digital Assets”) may be substantial and losses may occur over a short period of time.

5.1.2. The price and liquidity of Digital Assets has been subject to large fluctuations in the past and may be subject to large fluctuations in the future.

5.1.3. Digital Assets are not legal tender, not backed by any government, and accounts and value balances are not subject to any kind of insurance, compensation or have Securities Investor Protection.

5.1.4. Legislative and regulatory changes or actions at the state, federal or international level may adversely affect the use, transfer, exchange and value of Digital Assets.

5.1.5. Transactions in Digital Assets may be irreversible, and accordingly, losses due to fraudulent or accidental transactions may not be recoverable.

5.1.6. Some Digital Assets transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transactions.

5.1.7. The value of Digital Assets may be derived from the continued willingness of market participants to exchange fiat currencies for Digital Assets, which may result in the potential for permanent and total loss of value of a particular virtual currency should the market for that Virtual Currency disappear.

5.1.8. There is no assurance that a person who accepts Digital Assets as a payment today will continue to do so in the future.

5.1.9. The nature of Digital Assets may lead to an increased risk of fraud or cyberattack, and may mean that technological difficulties experienced by the Company may prevent the access or use of your Digital Assets.

5.1.10. Any bond or trust account we may hold for your benefit may not be sufficient to cover all losses incurred by you.

5.2. You acknowledge that you are solely responsible for determining the nature, potential value, suitability, and appropriateness of those risks for you, and that the Company does not give advice or recommendations regarding Digital Assets including the suitability and appropriateness of, and investment strategies for, Digital Assets. You acknowledge and agree that you shall access and use the Services at your own risk. However, this brief statement does not disclose all of the risks associated with trading in Digital Assets. You should, therefore, carefully consider whether such trading is suitable for you in light of your circumstances and financial resources. You should be aware that you may sustain a total loss of the funds in your Account, and that under certain market conditions, you may find it difficult or impossible to liquidate a position.

5.3. You understand and agree that:

5.3.1. Due to technical and other restrictions, the virtual currency values displayed on our Site may be delayed and therefore not reflect the current, live market value of such currency. Nonetheless, you agree that the values displayed on our Site control your Account and your use of the Site and Services, including the Exchange.

5.3.2. While virtual currency market values as publicly displayed on the Site may be delayed, we may offer access to live market value data via technical measures. This live market value data is valuable to us, and we take proprietary measures to keep all live market value data confidential and inaccessible to the public. To the extent that you receive access to such live data, you hereby agree that you will not redistribute, retransmit, duplicate, or otherwise make such data available in any way, either through automated, manual, or any other means. Any distribution or transmission of our live market values feed is a material breach of this Agreement as well as a violation of our trade secrets. You agree that we are not responsible for any failure or outage in the live market value data provided by us.

5.3.3. In order to use the Exchange, you must create an account with us. Your Account will be used to store various virtual currency amounts as deposited by you. In creating your Account, you may be asked to provide certain registration details or other information. In order to verify your identity, some of this information may be personal, private or detailed. In connection with completing the online registration form, you agree to provide true, accurate, current and complete information about yourself as prompted by the registration form (such information being the “Registration Data”); and you further agree to maintain and promptly update the Registration Data to keep it true, accurate, current and complete at all times while you are a Member. While we use reasonable efforts to protect the personal information of others from inadvertent release or misappropriation, we are not responsible for the intentional or criminal acts of third parties such as hackers or “phishers.” Please refer to our Privacy Policy for more information on the use of your personal information.

5.3.4. You must promptly inform us of all changes, including, but not limited to, changes in your address and changes in any virtual or fiat currency account used by you in connection with the Site and Services, if applicable. If you provide any information that is untrue, inaccurate, not current or incomplete, or if we or any of our authorized agents have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate your Account and refuse any and all current or future use of the Site and Services, as well as subject you to civil liability or refer you to the appropriate law enforcement authorities for criminal prosecution. We shall not be liable to make any compensation, monetary or otherwise, following such suspension, termination or inability to use the Site or the Services.

5.3.5. You are entirely responsible for any and all activities conducted through your Account. You agree to notify us immediately of any unauthorized use of your password or user ID as well as of any other breach of security. While we may implement certain monitoring, procedures designed to alert us to fraudulent activity, we are not responsible for any unauthorized use of your account, and you agree that you are responsible for such unauthorized use and for protecting.

5.3.6. Control or use of your Account may not be transferred, leased, assigned or sold to a third party. We disclaim any and all liability arising from fraudulent entry and use of the Site, Exchange, and other Services (including, but not limited to, liabilities arising from unauthorized trades executed through your Account). If a User fraudulently obtains access to your Account or the Exchange, we may terminate the User’s access and membership immediately and take all necessary and appropriate actions under applicable Kenyan and international laws.

5.3.7. As part of our security measures and policies, please note that we will never ask you, for any reason, whether by email, regular mail or telephone, to disclose your account password. Password inquiries will only be conducted online and only after you have signed onto the company’s site. We will never send you embedded links in an email requesting that you sign onto the site by clicking such a link. If you receive an embedded link by email, claiming to be from us, you should not open it or click on the link. The email is not from us and is likely fraudulent. Never give your account password to anyone whom you do not intend to authorize to use your account.

5.3.8. In order to provide you with the Services, including the Exchange, you may also be required to disclose certain other third-party account information to us, including, without limitation, your bank account number, your Bitcoin addresses and related information. As indicated elsewhere in this Agreement, we are not responsible for any unauthorized use of your Account with Us or any third-party accounts, which you use in connection with the Exchange.

6. Funding your Account –

After creating your Account with us, you will be able to fund your Account by transferring, for example, BTC, from your accounts with such third party virtual currency providers into accounts operated by the Exchange. No fees are charged by us for funding your Account; however, third parties, such as your bank, may charge transaction and other fees.

6.1. For example, to fund your Account with 10 BTC, you would use the third-party Bitcoin software to transfer your own pre-existing 10 BTC to the Exchange’s Bitcoin address for the omnibus client account. The Exchange would then credit your Account with 10 BTC on the Exchange’s ledger, and you would be able to trade those BTC for Kenyan Shilling on the Exchange.

7. Trading –

After your Account has been funded, you may begin to trade your virtual currency with other Members. Trading is accomplished via bids and offers to buy and sell virtual currency. Specific examples and illustrations of how trading works may be found on the Site. We are not responsible for any disputes among or between Members regarding any transaction.

7.1. Members may only sell as much virtual currency as is recorded by us in the Exchange ledger plus the applicable Transaction Fee. Any attempt by you to sell more virtual currency than our records show exists in your Account after deduction of the applicable Transaction Fee will result in an unsuccessful trade and may be grounds for termination of your Account.

7.2. Once an order has been executed and the appropriate currencies have been credited and debited from the Members’ Accounts, there is no way to reverse the transaction. 

8. Fees for Member Transactions –

In order to provide the Site, Exchange, and other Services to you, we charge a fee on each transaction initiated by Members of the Site (“Transaction Fee”). The current Transaction Fee may be found on our Site. We reserve the right to change, modify or increase Transaction Fee from time to time. Any such changes, modifications or increases will be effective upon posting such changes, modifications or increases on our Site at If you do not agree to the posted changes, modifications, or increases, you may close your Account as provided in herein. Your first use of your Account following the posting of any changes or revisions to the terms of this Agreement or modified Transaction Fee as posted on the Site will constitute your acceptance of all such changes or revisions.

8.1. Transaction Fees are paid by both the buyer Member and seller Member in any given transaction. The BTC buyer will be charged a fee in KES and the BTC seller will be charged a fee in BTC. Any fees charged by a third party, including any third party provider of virtual currency when moving such virtual currency

9. Trading Errors-

If you believe that you have been erroneously charged a Transaction Fee, please notify us immediately of such error, along with any additional information concerning the transaction. If we do not hear from you within thirty (30) days after such alleged erroneous Transaction Fee first appears on any Account statement, such fee will be deemed acceptable by you for all purposes.

10. Limitation of Liability

Save as permitted to the maximum extent by applicable laws, in no event shall we (or our licensors, agents, suppliers, resellers, service providers, or any other subscribers or suppliers) be liable to you, or any other third party for any direct, special, indirect, incidental, consequential, exemplary, or punitive damages, including without limitation, damages for loss of profits, loss of information, business interruption, revenue, or goodwill, which may arise from any person’s use, misuse, or inability to use the Site, Exchange, Services, or any of the materials contained therein, even if we have been advised of the probability of such damages. This is for any matter arising out of or relating to this Agreement and your use of the Site and the Services, whether such liability is asserted on the basis of contract, tort or otherwise, even if we have been advised of the possibility of such damages. We (nor any bank where our deposit accounts are held) will not be liable for our failure to perform any obligations under this Agreement due to events beyond our control, and the time provided for performing such obligations shall be extended by a period of time equal to the duration of such events. Events beyond our control include, but are not limited to, acts of God, war, riot, arson, embargoes, civil commotion, strikes, labour disputes, equipment failures, bank failures, virtual currency market collapse or fluctuations, credit or debit card transaction processing failures, strikes, fire, flood, earthquake, hurricanes, tropical storms or other natural disaster or casualty, shortages of labour or material, shortage of transportation, facilities, fuel, energy, government regulation or restriction, acts of civil or military authority or terrorism, fibre cuts, weather conditions, breaches or failures to perform by third parties, technical problems, including hardware and software crashes and other malfunctions, failure of the telecommunications or information services infrastructure, hacking, SPAM or failure of any computer, server or software disruptions on account of or caused by vandalism, theft, phone service outages, power outage, Internet disruptions, viruses, and mechanical, power or communications failures. If, after the date of this Agreement, any law, regulation, rule, regulation or decision of any funding method association, or ordinance, whether federal, state, or local, becomes effective which substantially alters our ability to perform Services hereunder, we shall have the right to cancel this Agreement, with notice, if reasonably possible, effective upon the earlier of (is) the date upon which we are unable to provide our Services hereunder; or (ii) thirty (30) days following notice. In no event shall our maximum total aggregate liability hereunder for direct damages exceed the total fees actually paid by you for use of the Site or Services for a period of more than three (3) months from the accrual of the applicable cause or causes of action. Because some jurisdictions prohibit the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. To the extent allowable by law, we reserve the right to set-off any damages or amounts owed to us by you for your breach of this Agreement or other obligations under this Agreement against funds in your Account.

11. Cancellation and Termination of your Membership and Account:

11.1. You may close your Account by providing written notice to us, and on such notice, a hold will be placed on your Account to allow all pending transactions to clear, if any. After notifying us of your desire to close your Account, you may use the Exchange to withdraw the remaining available currency associated with your Account.

11.2. All currencies appearing in the ledger and attributed to you must be withdrawn or otherwise sold or transferred before cancellation of your Membership and closing of your Account will be finalized.

11.3. We reserve the right at our sole discretion to block access to or to suspend, close or terminate your Account if:

(i) you violate the terms and conditions of this Agreement, including but not limited to engaging in abusive or harassing behaviour;

(ii) you add currency to your Account using any source that you do not have the legal right from which to transfer funds;

(iii) we have reasonable suspicion that you are directly or indirectly using our Site, Exchange or other Services in violation of applicable law or regulation;

(iv) we are directed by a regulatory authority, law enforcement, or a court of competent jurisdiction;

(v) we are otherwise required to do so by applicable law or regulation; or

(vi) for any other reason in our sole and absolute discretion. We are not responsible for any loss of currency or funds resulting from your violation of the terms and conditions of this Agreement or from any government forfeiture.

11.4. Without limiting other remedies, we may immediately issue a warning, temporarily suspend, indefinitely suspend, or terminate your access and use of the Site and Services, including closing your Account, at any time, with or without advance notice, if: We believe, in our sole discretion, that you have breached any material term of this Agreement or the document(s) it incorporates by reference;

11.4.1. We are unable to verify or authenticate any information you provide to us;

11.4.2. We believe, in our sole discretion, that your actions may cause legal liability for you, our users or us; or


11.4.3. We decide to cease operations or to otherwise discontinue any services or options provided by the Site, Exchange, or parts thereof.

11.5. You agree that neither the Site nor any third party acting on our behalf shall be liable to you for any termination of your access to any part of the Site or Services.

11.6. You agree that if your access is terminated by us, you will not attempt to regain access to the Site, Exchange, or Services – using the same or different username – without prior written consent from us.

11.7. Stolen Cards and Fraudulent Use of Credit Cards – We take credit card fraud very seriously. To the extent that the Site or Services allow the use of credit cards, discovery that any Member has used a stolen or fraudulent credit card will result in the notification of the appropriate law enforcement agencies and termination of such Member’s account.

11.8. Service Interruption – From time to time due to technological factors, scheduled software uploads and other factors beyond or within our control, the Site, Exchange, or other Services may be temporarily interrupted. You agree that we are not liable for any loss and damage arising from such interruption and to hold us harmless against any such interruption of or inability to access the Site or Service. 

12. Miscellaneous Provisions

12.1. Assignment. The rights and liabilities of the parties hereto will bind and inure to the benefit of their respective assignees, successors, executors, and administrators, as the case may be. You may not assign this Agreement without our prior written consent. We may assign this Agreement and our rights and obligations hereunder at any time upon thirty (30) days prior written notice to you.

12.2. Severability. If for any reason a court of competent jurisdiction or an arbitrator finds any provision of this Agreement, or any portion thereof, to be invalid, unenforceable or illegal, such invalidity, unenforceability or illegality shall not affect the remainder of this Agreement which will continue to be in full force and effect.

12.3. No Waiver. No waiver or action made by us shall be deemed a waiver of any subsequent default of the same provision of this Agreement. No failure or delay in exercising or enforcing any privilege, right, remedy, or power hereunder shall be deemed a waiver of such provision by us. If any term, clause or provision hereof is held invalid or unenforceable by a court of competent jurisdiction, such invalidity shall not affect the validity or operation of any other term, clause or provision and such invalid term, clause or provision shall be deemed to be severed from this Agreement. All waivers must be in writing.

12.4. Headings. All headings are solely for the convenience of reference and shall not affect the meaning, construction or effect of this Agreement.

12.5. Complete Agreement. This Agreement, together with our Privacy Policy constitutes the entire agreement between the parties with respect to your access and use of the Site, Exchange, Services and the Materials contained therein, and your use of the Site and Services, and supersedes and replaces all prior understandings or agreements, written or oral, regarding such subject matter.

12.6. Other Jurisdictions.

We make no representation that the Site, Exchange, Services or any of the Materials contained therein are appropriate or available for use in other locations, and access to them from territories where their content or function may be illegal or is otherwise prohibited. Those who choose to access the Site, Exchange and Services from such locations do on their own initiative and are solely responsible for determining compliance with all applicable local laws

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