Legal
Contact

Address:

65 London Wall, London,

United Kingdom, EC2M 5TU

Phone: 07490 782 552

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© GIGA BRITS LTD​

Company Registration Number: 1075 1896

MSB: XYML00000130434

ICO: ZA503040

TERMS AND CONDITIONS OF BUSINESS

GIGABRITS LIMITED


These terms and conditions of business (“our terms”) apply to our personal foreign exchange services (“our services”).


You should read our terms carefully before using our services. If, having read our terms, you do not understand any of them, please contact us at contact@ibex-bitcoin.com. Our terms contain limitations on the scope of our obligations to you as well as limitations on and exemptions from our liability to you in the event that you suffer any loss or harm as a result of using our services.


Definitions


In Our Terms the following words have the following meanings:

“Acceptance”

our acceptance of a Request communicated to you by online order confirmation or over the phone

“Authorized Person”

a person who is authorized by you and accepted by us to provide us with instructions on your behalf;

“Business Day”

9am to 4.30pm Monday to Friday excluding Bank Holidays and Public Holidays in England.

“Contract”

the contract between us for the performance of any FX currency or Crypto Asset transaction;

“Contract Note”

A document setting out the details of the contract we have agreed to perform for you and our requirements concerning the FX or Crypto currency which will be sent to you following our Acceptance;

“Deposit”

the deposit which we may ask you to pay in advance to secure the currency or Crypto Asset, also sometimes referred to as “Margin”;

“Gigabrits”, “we”, “our” or “us”

refers to Gigabrits Limited, which is a company incorporated in England with company number 10751896 and registered office 65 London Wall, London, United Kingdom, EC2M 5TU;

“Our Services”

our Personal Foreign Exchange Services;

“Our Terms”

these terms and conditions of business;

“Our Website”

the website;

“Request”

your request for a currency transaction communicated to us by you confirming an online order if you are an on-line customer, or confirming your instructions over the phone if you are a telephone customer;

“Spot conversion”

a transaction forming part of Our Services where we apply the FX rate or Crypto Assets rate available on the day you request your transactions, and that we Accept;

“you” or “your”

refers to you, our customer;

“Your Nominated Account”

the bank account which, for the purposes of the Contract, you notify us in advance into which we are to pay any sums due to you or any third party whom you instruct us to pay;

All references in Our Terms (unless otherwise stated) (a) to a person or persons shall include any natural person, company, firm, partnership, trust, public body or other organisation; (b) to “clauses” are to clauses of Our Terms; (c) to any legislation (including statutes, statutory provisions or regulations) shall include them as amended from time to time; and (d) made in the singular shall include the plural and vice versa.

All headings used in Our Terms are for ease of reference only and shall not affect the interpretation of Our Terms.


Changes to Our Terms

We may be required to amend Our Terms from time to time, for example in order to comply with changes in the law or regulatory and other requirements or changes in market conditions. No change to Our Terms will apply to any Contract already made with you prior to the date of the change coming into effect.

In the event of any change at any time to Our Terms, we will notify you by email and/or by posting a clear readily accessible notice of change on Our Website or, if you are a telephone customer and have not provided us with an email address where we can contact you, by post to the last postal address we have for you


APPLICABLE Law

Our Terms are governed by English law and any disputes between us relating to the Contract will normally be dealt with in the courts in England or Wales. Our Terms do not affect your statutory rights as a consumer


FINANCIAL MARKETS

No advice

Although we may provide market information at your request, we are not providing any advice (whether to proceed, or not proceed or in respect of timing) concerning any foreign currency or crypto currency. You must rely on your own skill and judgement whether or not to make a Request and whether a particular currency or type of currency is suitable for you.

Closing

Banks have fixed cut off times for the receipt and dispatch of electronic payments. We are not responsible for and have no liability for any delay in or failure of any transaction which results from a late arrival of funds or from late receipt of instructions which results in any fixed cut off imposed by any bank not being met.


FORMATION OF CONTRACT

Each currency conversion which we perform for you is subject to a separate Contract. Each Contract will be formed when we communicate to you our Acceptance. Details of the Contract will be communicated in our Acceptance and confirmed in writing in our Contract Note. We may in our sole discretion refuse to proceed with any Request or any FX contract for any type of currency at any time.


Your responsibility to us

Registration

Before we can perform any of Our Services for you, you must register with us. In order to complete your registration, you must provide us with all the details we require, including relating to your identity and proof of address and any other information we may require from you to enable us to complete our anti-money laundering process. If your account is not used for 18 (eighteen) months, it may be deactivated and you may need to re-register.


Money Laundering

You will promptly supply us on request with any information and documentation which we need to obtain to enable us to comply with any legal obligations relating to Our Services, including as may be required by the Money Laundering Regulations 2017.


Speculation

You must not use any of Our Services for any speculative purpose.


Password and Security

It is your responsibility to keep safe any password which you may use to access any part of Our Services.


Information

You are responsible for the completeness and accuracy of all information you provide to us at any time, including any in your Request and Your Nominated Account details. You must provide us with instructions, and make sure any Authorized Person provides us with instructions, in the English language.

You must keep your contact information up to date at all times and be available to meet your obligations under this contract. You will notify us as soon as you become aware of any error in any details you have provided to us or in connection with any FX transaction. You will also notify us immediately if any of the circumstances listed in clause 8.1.4 (which relate to your ability to pay us for Our Services) occurs.


Personal Capacity

You will not complete the Request on behalf of any other person and, unless you are an Authorised Person, will not provide us with any instructions for or on behalf of or on account of any other person. You are over 18 (eighteen) years of age and are not suffering from any disability or impairment (mental or otherwise) which may affect your capacity to enter into the Contract.


Local Law

We are not responsible for compliance with any local law other than English Law. If you are accessing Our Website from outside the United Kingdom, you must satisfy yourself of any other local law requirements.


Authorisation

You may authorise another person to provide us with instructions on your behalf. In these circumstances, we will treat the instructions of the Authorised Person as if they came from you.


Payment

Your payment will be due to us in full in cleared funds by no later than 12.00 midday on the Business Day we tell you in our Acceptance.

You must pay all sums due to us for all FX currency in full in cleared funds by the due date for payment into Our Nominated Account or in the form we may instruct you to do so.

You must pay all sums due to us for all FX or Crypto conversion in the currency agreed in the Contract.

You may not make any discounts or deductions from any payments due to us.

We may charge interest on any sum due to us at any time which is not received by us in full in cleared funds by the due date for payment at the rate of 4% (four percent) above the base rate from time to time of the Bank of England, and this interest will accrue daily from the due date for payment until we are in receipt of the overdue amount in full in cleared funds.


Our responsibility to you

We will:

provide Our Services at all times in accordance with Our Terms;

in relation to all FX currencies and Crypto currencies:

tell you what the Value Date will be;

tell you what amount is payable by you, together with the date by which we must be in receipt of your payment in full in cleared funds;

hold all sums which you have paid to us, that has not vested in us, in our client bank account or use them in the performance of our obligations we incur in relation to our clients’ contract;

use the contact information you provide to us to contact you, including to verify any transaction, to check your identity or to notify you of any requirement for a Margin Call.

We will not:

provide any of Our Services to you unless or until you have met the requirements of Registration, Money Laundering, Speculation, Password and Security, Information and Personal Capacity of Our Terms;

make any onward payment for any Contract until we are in receipt of cleared funds from you;

accept any monies in payment of any sums due to us from any person other than you or the Authorised Person;

proceed with any Contract having a value higher than any transaction limit which we may impose from time to time.


Payments

We will pay into Your Nominated Account any sums we have agreed to pay on your behalf as soon as practicable after the Value Date. You should note that it can take more than 5 (five) Business Days after the Value Date for the funds to clear depending on local banking arrangements.

We may be required to make deductions from any sums we have agreed to pay on your behalf for taxation reasons. If this is the case, our payment will be made less an amount equivalent to our taxation liability.

We may use any sum which we receive from you (including any sum forming part of any Deposit you have paid and any sum received from you held in our client bank account) at any time to settle any liability which we may incur relating to any of your Contracts.


Crypto Currencies are a type of currency, and as such bought and sold in currency pairs, as standard currency being sold by a Bureau de Change.

When receiving Bitcoin or Cryptographic Asset as part of a transaction, the latter is finalised after it is confirmed in a number of blocks. Because of the probabilistic settlement nature of Cryptocurrencies and Cryptographic Assets, GGB will decide on a case by case basis, based on network conditions how many confirmations are necessary to advise that your transaction is concluded.


The latter is fundamentally different from any other regulated activities, such as payment services, were one settlement confirms delivery of a payment transaction; you must understand that this is not a payment service due to inherent different with the type of underlying asset/products. GGB is not a crypto exchange, we only sell Cryptographic Assets in exchange for other currencies only.

In what we determine to be normal network conditions 1 confirmation is likely to be sufficient, however the latter is subject to external factors.

The number of confirmations when GGB is sending Bitcoin or Cryptographic asset payments is to be determined by them, a node of their choice. Or a block explorer of GGB’s choice.

GGB will determine the number of confirmations a transaction has by internal consultation with a cryptocurrency node run locally on company hardware, GGB will solely reserve the right to decide what node version and implementation are to be used for this purpose. Also, alternatively to this practice a block explorer of GGB's choosing may be used as reference for transaction confirmation count.


Fees

If the client sent a Bitcoin or Cryptographic Asset transaction with an insufficient large fee in order to be confirmed within the next block, or if for whatever reason GGB decides the fee needs to be increased (“bumped”), we can do so by the procedure called CPFP (“child pays for parent”), in doing so the addition fee imparted to the transaction will be deducted from the client’s portion of the trade amount, unless specified differently by GGB.

“A Child Pays for Parent (CPFP) transaction is one where a higher fee transaction is formed and broadcast to incentivize miners to also confirm the unconfirmed transaction from which it’s inputs are drawn i.e. the: parent transaction”

Unless specified differently by GGB, the sender of the Bitcoin or Cryptographic asset will pay for the miner/network fees.


Forks/chain split

Bitcoin forks are defined variantly as changes in the protocol of the Bitcoin network or as the situations that occur "when two or more blocks have the same block height". In the case of such a network event GGB decides what chain of the protocol implementation is valid for the trade.

Chain Reorganisation

The term "blockchain reorganization" is used to refer to the situation where a client discovers a new difficulty wise-longest well-formed blockchain which excludes one or more blocks that the client previously thought were part of the difficulty wise-longest well-formed blockchain.

These excluded blocks become orphans.

In the case of such an event, GGB has sole authority of decision regarding if the transaction as executed is or has remained valid.

In the case of any protocol consensus ambiguity of the Bitcoin or Cryptographic asset network, it is up to GGB to decide what transaction and network circumstances are considered to be relevant to the trade at hand.


Price data

GGB can choose at its own discretion, on a case by case basis, what reference will be used as the trade relevant spot price for Bitcoin or other Cryptographic asset is involved in a trade.


Termination

The Contract will expire automatically on full settlement of the Contract.

We may terminate the Contract immediately without notice to you:

where you fail to make any payment due to us relating to any Contract by the due date for payment;

where we are required to do so by law, by any court of competent jurisdiction or any governmental or regulatory body which authorises us to perform Our Services;

following a material breach by you of any of Our Terms (which would include any breach by you of any of the provisions of clause 5 or in the event that we discover any fraud or fraudulent activity by you;

in the event that you become unable to pay your obligations as and when they fall due for payment, or that a petition in bankruptcy is presented against you or you are declared bankrupt, you become insolvent, you are placed into receivership, administration or go into liquidation or are subjected to any similar event.

When the Contract is formed, we take on risk and incur liability straight away on your behalf. For this reason, we do not give you the right to terminate the Contract except in writing to us in the event that we become insolvent or we are placed into receivership, administration or go into liquidation.

The provisions of this clause 7.4 and clauses 8 (Our Liability), 9 (Circumstances beyond our Control), 10 (Linking and Framing), 13.1 (Regulatory Requirements), 13.6 (Entire Agreement) and 13.7 (Third Party Rights) shall survive the termination or expiry of the Contract for any reason.

Consequences of Termination

If the Contract is terminated for any reason:

we:

will Close Out any pending Contract not yet completed; and

will notify you of any loss that we make or liability we incur as a result of Close Out or termination;

may use any sum which you have paid us (including any Deposit), to settle any of our liability or recompense us for our loss incurred in connection with the Close Out or termination, unless the Close Out or termination is as a result our being subject to one of the events detailed in clause 7.3;

you must pay us on demand the amount of any loss that we make or liability we incur as a result of any Close Out or termination, unless the Close Out or termination is as a result of our being subject to one of the events detailed in clause 7.3;


Our liability

We are not liable to you for any loss or damage which you may incur:

as a result of any breach by you of any of clauses regarding Registration, Money Laundering, Speculation, Password and Security, Information or Personal Capacity;

where we terminate the Contract in any of the circumstances set out in clause 7.2 (which sets out our rights of termination);

as a result of any fluctuation in any exchange rate;

where you do not provide us with any sum we require in payment by the due date for payment;

as a result of any act or omission by you or any Authorised Person.

We are not at fault for any loss of access a customer experiences to Cryptographic Assets under their own control either before, during, or after a trade. We are not responsible for any losses a customer may incur because of Cryptographic Asset price fluctuations. Any misdirected Cryptographic Asset payments initiated by a customer during the course of a trade are the sole liability of the customer themselves.

Our total liability to you in connection with the Contract is, subject to clause 8.4, limited to the lower of:

the total amount paid by you to us under the Contract;

or the value of the commission we would have earned for your transaction.

In no event are we liable to you or any other person for any type of loss which under English law is considered to be “indirect loss” or “consequential loss” (being loss or damage which does not follow directly from our breach of the terms of the Contract) nor are we liable for any loss of data, loss of profits, loss of revenue, loss of turnover, loss of sales, loss of production, loss of anticipated savings, loss of goodwill, loss of business opportunity or contracts or any other economic loss whatsoever arising out of or in connection with the Contract which an English court would not consider to be direct financial loss or damage to your property.

No provision of this clause 8 nor any other provision of Our Terms shall have as its object or effect the exclusion or limitation of any liability we may have for personal injury or death resulting from our negligence or for fraud.


Circumstances beyond our control

We are not liable to you if we are unable to perform any of our obligations to you or our performance of any of our obligations is delayed due to any circumstances outside of our reasonable control, including (without limitation) any industrial action, labour dispute, act of God, fire, flood or storm, war, riot, civil commotion, siege, security alert, act of terrorism or any resulting precautionary measures taken, act of vandalism, sabotage, virus, malicious damage, compliance with any statute, statutory provision, law, governmental or court order, the actions or instructions of the police or of any governmental or regulatory body which authorises us to perform Our Services, cut or failure of power, failure of equipment, systems or software or internet interconnectivity. If any of these circumstances occur then the Contract shall be suspended for the period during which they continue.


Linking and framing

We are not responsible for the content, policies or services of any other persons or sites linked to or accessible via Our Website. The existence of any link to any other website does not constitute an endorsement of or association with any such website or any person operating any such website. Any reliance on any content, policies or services of any other persons or websites are at your sole risk. Any queries, concerns or complaints concerning such websites should be directed to the persons responsible for their operation.


Confidentiality

We respect the privacy of the affairs of all our customers and will always aim to treat your instructions with the utmost confidence. We will only use any information which you communicate to us in confidence in order to perform of Our Services in accordance with the Contract and not disclose any such information to anyone, except:

- where the information becomes generally available to the public through no fault of our own;

- where the information was provided to us on a non-confidential basis or was already in our possession not subject to a duty of confidence;

- where the information is received by us from another person on a non-confidential basis who, to our knowledge, is not subject to a duty of confidence relating to the information;

- where the information was already known to us;

- where you agree that we may disclose it to any person without imposing a duty of confidence;

- where it is personal data, in which case we may handle it as provided for by the provisions of clause 12 (Personal Data)

- where we are required to do so by any governmental or regulatory authority, by a court order or otherwise by law (including in cooperating with the police or other law enforcement agencies in connection with the prevention or detection of any criminal activity).


Personal data

We will handle any “personal data” you provide to us (for example, your home telephone number or home address) in accordance with the provisions of the Data Protection Act 1998 (“the Act”) and subsequent legislation that may replace or amend it, especially the EU’s General Data Protection Regulation.

The Act provides a “data subject” with certain rights against and imposes certain duties on a “data controller” in relation to its handling of a data subject’s personal data. For the purposes of the Contract and the Act, you are the data subject and we are the data controller in relation to all your personal data which you disclose to us. Where you provide us with personal data of an Authorised Person, the Authorised Person is the data subject of that personal data. Further information concerning your rights and the rights of any Authorised Person as a “data subject” and our duties as a “data controller” can be found by visiting the website of the Information Commissioner at www.ico.gov.uk. If you do not have access to the Internet, the Information Commissioner’s Office can also be contacted by telephone on 08456 306060.

We may share personal data which you provide to us with other members of the Gigabrits Limited or with associate companies for the sole purpose of delivering our services to you; the latter may include processing your personal data outside the EU and the EEA.

We may also be required to share personal data which you provide to us with relevant government bodies or regulatory authorities (such as HM Revenue and Customs, which regulates some of our other businesses in the United Kingdom), with credit control or debt collection agencies (for example, where you owe us money), the police or other law enforcement agencies (for example, in connection with money laundering or fraud investigations), or be required to disclose it to other persons by order of a court or otherwise to meet any regulatory, statutory or legal requirement on us.

Please refer to our Privacy Policy for details of how we process personal data.

If you have any queries concerning our handling of any personal data of which you are a data subject, please contact us by email at contact@ibex-bitcoin.com.

If you have access to the Internet, further information on how we handle personal data is set out in our Privacy Policy, which can be found by clicking the “Privacy Policy” link on Our Website home page.


General


Regulatory Requirements

We may be required to disclose certain information to a governmental or regulatory body or agency, to a court or otherwise by law concerning you or the services we provide to you or any Authorised Person to help combat fraud, money laundering offences or criminal activity or to meet any statutory or other legal requirement imposed on us from time to time. We may also record any telephone discussions we have with you and use any transcripts of such discussions, for example for training purposes or in order to meet our legal obligations or in the prevention or detection of money laundering or crime. You agree that we may do any of these things without further liability to you or any Authorised Person.


Severability

If any court of competent jurisdiction finds that any part of Our Terms is invalid, unlawful or unenforceable for any reason those parts (to the extent possible) shall be deleted from Our Terms and the remaining parts (to the extent possible) shall remain in force and continue to be binding on you and us.


No waiver

No failure to enforce or delay in enforcing any right or remedy available to you or us under the Contract (including as provided for in Our Terms or otherwise available under English law) will mean that you or we cannot exercise any such right or remedy at a later date.


Assignment

You may not assign, transfer, charge or dispose of the Contract or any of your obligations, rights or privileges under the Contract to any other person at any time without our prior consent in writing. We may assign, transfer, charge or dispose of the Contract in whole or in part or any of our obligations, rights or privileges to any other person at any time, provided we take appropriate steps to ensure that doing so will not harm any of your rights under the Contract.


Notices

Where any notice is required by Our Terms to be given in writing, it must:

if you are an on-line customer: (a) in the case of any to be sent by you, be sent by you to Gigabrits Limited and (b) in the case of any to be sent by us, be sent to the email address which you have told us in writing (for example, when registering with us) to use to contact you;

if you are a telephone customer: (a) in the case of any to be sent by you and you have access to the Internet, be sent by you to contact@ibex-bitcoin.com and, if you do not have access to the Internet, be sent by you by post to 65 London Wall, London, United Kingdom, EC2M 5TU and (b) in the case of any to be sent by us, be sent to the email address which you have told us in writing (for example when registering with us) to use to contact you or, if you have not provided us with an email address, by post to the last postal address we have for you (which, unless you have notified us in writing of a change, will normally be the one you told us when you registered with us);

or, in each case, to such other email or postal address in the United Kingdom which you notify us in advance in writing (in the case of any notice to be sent to you) or we notify you in advance in writing (in the case of any notice to be sent to us) in accordance with this clause 13.5. All notices given in accordance with this clause 13.5 shall be treated as being served on the first Business Day following transmission of the email.


Entire Agreement

The details set out in your Request and our Acceptance (each as confirmed in our Contract Note) and Our Terms form the entire agreement between us concerning the Contract. No other discussions, telephone conversations, email communications, documents or materials form part of the Contract. This clause 13.6 does not exclude any liability we may have to you for fraud, or prevent you from bringing any claim against us for fraud or fraudulent misrepresentation.


Variation

Our Terms cannot be changed except as provided for in clause 2 (Changes to Our Terms) or in writing by a properly authorised representative of Gigabrits Limited.


Third Party Rights

The Contract (Rights of Third Parties) Act 1999 shall not apply to the Contract. This means that only you and we have any rights, obligations or privileges under the Contract and no-one other than you or we can enforce any of its terms or take any action under the Contract.


BACKGROUND:


Gigabrits (hereinafter “GGB”) understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://www.ibex-bitcoin.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.


Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:


“Account”

means an account required to access and/or use certain areas and features of Our Site;


“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;


“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;


“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 amended by EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and


“We/Us/Our”

means GGB, its subsidiaries in the UK registered in England.


Information About Us

Our Site is owned and operated by Gigabrits Limited.

Our Data Protection Officer is Mr. Dragos Birsan and can be contacted by email at contact@ibex-bitcoin.com by telephone on +44 7950 894 053 or by post at 65 London Wall, London, United Kingdom, EC2M 5TU

In the UK we are regulated by HMRC as a Bureau de Change.


What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.


Your Rights

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

The right to be informed about Our collection and use of personal data;

The right of access to the personal data We hold about you (see section 12);

The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

The right to restrict (i.e. prevent) the processing of your personal data;

The right to data portability (obtaining a copy of your personal data to re-use with another service or organization);

The right to object to Us using your personal data for particular purposes; and

Rights with respect to automated decision making and profiling.

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.


What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-persona data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy

For details, please refer to our Data Protection Policy and Privacy Notice.


How Do We Use Your Data?

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 as amended by GDPR at all times. For more details on security see section 7, below.

Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

Providing and managing your Account;

Providing and managing your access to Our Site;

Personalizing and tailoring your experience on Our Site;

Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);

Personalizing and tailoring Our services for you;

Replying to emails from you;

Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time;

Market research;

Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 as amended by GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Third-parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

5 years since the date we concluded our last transaction or ended our relationship with our clients;

6 months for employment applications

In an on-going basis for employment purposes, and for 4 years after individuals leave employment.


How and Where Do We Store Your Data?

We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

Your data will be stored in the UK, unless you request we provide you with offshore services, in which case your information will be shared with our Custodians outside the EEA (Please refer to our Privacy Notice for links to our Custodians Privacy Policy and information on how the process personal data). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and GDPR including:

Organizing Data Processing control arrangements with our Custodians

Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

Steps We take to secure and protect your data include:

Appointment of a Data Protection Officer

Implementation of a Data Management Framework, including policies, procedures and internal control mechanisms to ensure your data is secure and processed according to your rights.


Do We Share Your Data?

In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

We may sometimes contract with third parties -such as Custodians to provide services to you on Our behalf. These may include payment processing, order processing and fulfillment of your instructions. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

The third party data processors used by Us and listed in our Privacy Notice are located in the UK; we also may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and GDPR

In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.


What Happens If Our Business Changes Hands?

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will, however, be given the choice to have your data deleted or withheld from the new owner or controller.


How Can You Control Your Data?

In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.


Your Right to Withhold Information

You may access certain areas of Our Site without providing any data at all. However, to use all the features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see section 13.


How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at contact@ibex-bitcoin.com, or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.


Our Use of Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for marketing and performance purposes. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

The following first party Cookies may be placed on your computer or device:


Name of Cookie Purpose Strictly Necessary

<<insert file name>> <<insert description>> <<yes / no>>

<<insert file name>> <<insert description>> <<yes / no>>

<<insert file name>> <<insert description>> <<yes / no>>

<<insert file name>> <<insert description>> <<yes / no>>

<<insert file name>> <<insert description>> <<yes / no>>


and the following third party Cookies may be placed on your computer or device:


Name of Cookie Provider Purpose

<<insert file name>> <<Insert Name of Provider>> <<insert description>>

<<insert file name>> <<Insert Name of Provider>> <<insert description>>

<<insert file name>> <<Insert Name of Provider>> <<insert description>>

<<insert file name>> <<Insert Name of Provider>> <<insert description>>

<<insert file name>> <<Insert Name of Provider>> <<insert description>>


Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyze anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie First / Third Party Provider Purpose

<<insert file name>> <<first / third>> <<insert name>> <<insert description>>

<<insert file name>> <<first / third>> <<insert name>> <<insert description>>

<<insert file name>> <<first / third>> <<insert name>> <<insert description>>

<<insert file name>> <<first / third>> <<insert name>> <<insert description>>

<<insert file name>> <<first / third>> <<insert name>> <<insert description>>


If you have any questions about Our Site or this Privacy Policy, please contact Us by email at contact@ibex-bitcoin.com, by telephone on +44 (0) 7950 894 053, or by post at 65 London Wall, London, United Kingdom, EC2M 5TU. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.



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