Terms and conditions

 

 
 

By using the Zesion OÜ website ("Site"), by registering for an Account at https://zesions.com ("Account") or by using any other Zesion OÜ Service , you ("you, his or yourself" ) agree to accept and comply with the terms and conditions. Terms of use listed below ("Terms of Use"). You should read all the Terms of Use carefully before using this Site or any of the Zesion OÜ Services .

 

As used in these Terms of Use, " Zesion OÜ " refers to the company, Registered in the Estonian Trade and Companies Register under number 14759852, with its registered address in Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158 / 2-88, 11317 in Estonia. The virtual currency exchange license number FVR001369 and digital currency wallet service provider license FRK001249 are placed under the prudential supervision of the Financial Sector Oversight Commission.

References to  Zesion OÜ are also references to its owners, directors, investors, employees.

 

Zesion OÜ is a company with an office in Estonia. Depending on the context, " Zesion OÜ " may also refer to the services, products, website, content or other materials (collectively " Zesion OÜ Services").

 

Zesion OÜ allows buyers ("Buyers") and sellers ("Sellers") to use its Service capabilities to buy and sell Cryptocurrencies such as (Bitcoins, Ethereum, Dash, Tether, Paxos, Ripple, Bitcoin cash, Litecoin, Zcash).

 

Buy cryptocurrencies at  Zesion OÜ with fiat money by bank transfer

The Buyer enters in the platform's purchase form the amount of cryptocurrencies he wishes to acquire, his public wallet address to receive the cryptocurrencies, the platform will automatically show the required amount of euros.

 

Then, the member will go to the next page with the Zesion OÜ bank  details , to which they must make a bank transfer in immediate crediting mode using their personal account, with a 20 minute time limit to upload the payment receipt file and mark paid, if you cannot complete the payment in this period of time, the window closes and you will have to perform the aforementioned steps again.

 

In the event that the funds are not immediately credited to the Zesion OÜ bank account, the order will become pending, as soon as the funds arrive, the percentage corresponding to the current price of the cryptocurrency will be applied and the funds will be sent to the data supplied by the client.

 

Once the payment process is complete, and after the money has reached the Zesion OÜ bank account  , the user will receive a cryptocurrency transfer in their wallet.

 

Zesion OÜ is not responsible if the destination address indicated by the Member in the purchase form is incorrect or if the Member cannot manage the private key that authorizes to operate with the acquired cryptocurrencies.

 

Purchases are made by bank transfer. The Buyer must send the payment receipt to  Zesion OÜ . The conversion price will be fixed at the time of the opening order and does not change during the income of the payment to the Zesion OÜ bank account  .

 

Bank transfers must match the Registered Member and the data previously provided. Otherwise, additional information may be required, including the return of the payment, the costs derived from them being borne by the client plus a fine of fifteen euros (€ 15);

● Sell cryptocurrencies to  Zesion OÜ for fiat money via bank transfer       

The Seller enters in the sale form the desired amount of cryptocurrency to sell and the platform automatically shows the amount of euros that will be received or the client can enter in the form the desired amount of euros that will be received, then the platform will automatically show the required amount amount of cryptocurrencies All the member's cryptocurrency transfers to the Zesion OÜ platform  can be verified on the search engine blockchair.com.

 

The Seller will receive the payment by bank transfer, under the terms specified below. The seller must provide the details of his bank account in which he wishes to receive fiat money in euros and verify the validation before giving the order to send euros to his bank account.

Depending on your country of residence, you may not be able to use all the functions of the Site.

 

It is your responsibility to follow the rules and regulations applicable in your country of residence and / or country from which you access this Site and Services. Provided that you accept and comply with these Terms of Use,  Zesion OÜ grants you the personal, non-exclusive, non-transferable, non-sublicensable and limited right to enter and use the Site and the Service.

 

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF USE WRITTEN IN THIS AGREEMENT, DO NOT ACCESS THIS SITE AND DO NOT USE THIS SERVICE.

 

By registering an account, you expressly express and warrant:

That you have accepted these Terms of Use; Y

That you are at least 18 years of age and have the full ability to accept these Terms of Use and carry out a transaction involving Bitcoins.

 
 

RISKS

 

Trading goods and products, real or virtual, as well as virtual currencies involves significant risk. Prices can fluctuate on any given day. Such price fluctuations can increase or decrease the value of your assets at any given time. Any currency, virtual or not, can be subject to large changes in value and can even become useless. There is an inherent risk that losses will occur as a result of buying, selling or trading anything in a market.

 

Cryptocurrency trading also has special risks that are not generally shared with official currencies, goods, or commodities in a market. Unlike most currencies backed by governments, other legal entities, or commodities such as gold or silver, cryptocurrencies are a unique type of "fiat" currency, backed by technology and trust. There is no central bank that can issue more currencies or take corrective action to protect the value of cryptocurrencies in a crisis.

 

Instead, cryptocurrencies are a still autonomous and largely unregulated global system of forex companies and individuals. Merchants rely on a digital, decentralized, and partially anonymous system that relies on peer-to-peer networks and cryptography to maintain their integrity.

 

Cryptocurrency trading is often susceptible to irrational (or rational) bubbles or loss of confidence, which could collapse demand relative to supply. For example, trust could collapse in cryptocurrencies due to unexpected changes imposed by software developers or others, a government crackdown, the creation of superior competitive altcoins, or a deflationary or inflationary spiral. Trust could also collapse due to technical issues: if the anonymity of the system is compromised, if money is lost or stolen, or if hackers or governments can prevent transactions from being settled.

 

There may be additional risks that we have not anticipated or identified in our Terms of Use. You need to carefully assess whether your financial situation and risk tolerance are suitable for buying, selling or trading Bitcoins.

We use our bank providers to receive funds from clients and make payments. Our banking providers DO NOT transfer, exchange or provide any services related to cryptocurrencies.

 
 

LIMITED RIGHT OF USE

 

Unless otherwise specified, all Materials on this Site are the property of  Zesion OÜ and are protected by copyright, trademark and other applicable laws. You may view, print and / or download a copy of the Materials at this Site on any computer for your personal, informational and / or non-commercial use, provided that you comply with all copyright and other proprietary notices.

 

The trademarks, service marks and logos of  Zesion OÜ and others used on this Site ("Trademarks") are the property of the company and their respective owners. The software, text, images, graphics, data, prices, operations, charts, graphs, video and audio used on this site belong to Paynote. Trademarks and materials must not be copied, reproduced, modified, published, uploaded, posted, transmitted, scraped, collected, or distributed in any form or by any means, whether manual or automatic. The use of such Materials on any other Site or computer network environment for any other purpose is strictly prohibited; Any such unauthorized use may violate copyrights, trademarks, and other applicable laws, and could result in criminal or civil penalties.

Maintaining your account - our rules.

 

This site is for your personal and non-commercial use only. We are vigilant to maintain the security of our Site and Service. By registering with us, you agree to provide  Zesion OÜ with current, accurate and complete information about yourself, as prompted by the registration process, and to keep such information up to date. Furthermore, you agree that you will not use any Account other than your own, nor will you access the Account of any other Member at any time, nor will you help others to gain unauthorized access.

 

The creation or use of Accounts without obtaining the express prior permission of  Zesion OÜ will result in the immediate suspension of such Accounts, as well as of all pending buy / sell orders. Any attempt to do so or to assist others (Members or otherwise), or the distribution of instructions, software or tools for that purpose, will result in the termination of the Accounts of such Members. Termination is not the exclusive remedy for such a violation, and  Zesion OÜ may choose to take further action against you.

 

You are also responsible for maintaining the confidentiality of your Account information, including your password, and for protecting your own Cryptocurrencies and all activity, including Transactions that are posted to your Account. Any action on the Site, transactions, orders and operations initiated from your Account or using your password (1) will be considered carried out by you, and (2) is irrevocable once validated using your password or carried out through your Account. If there is suspicious activity related to your Account, we may, but are not required to request additional information from you, including authentication documents, and freeze any transactions pending our review. You are required to comply with these security requests or agree to the termination of your [email protected] The account of any member who violates these rules may be canceled and the member will be liable for losses suffered by  Zesion OÜ or any user of the site.

Finally, you agree that you will not use the Service to engage in criminal activity of any kind, including but not limited to money laundering, illegal gambling operations, terrorist financing, malicious hacking, or any criminal or illegal activity.

 

The minimum trade allowed is 10 EUR.

 

The maximum trade allowed is 5,000 EUR / month for a Member.

 
 

ACCOUNT VERIFICATION

 

The creation and use of your account are subject to verification, as required by legal and regulatory obligations in force at  Zesion OÜ . You agree to provide us with the information we request for the purposes of identity verification, meeting the rules of knowing your customers, as well as the detection of money laundering, terrorist financing, fraud or any other financial crime. The information requested may include personal data (see our Privacy Policy) By providing us with the information we request, you confirm that it is true and accurate, and agree to inform us of changes related to such information. Your account will be blocked until we are satisfied with the information you have provided and determine, in our sole discretion, that it is sufficient to validate your account. In the meantime, you will not be allowed to cancel your Account or request the deletion of Personal Data processed in the course of verification operations.

 
 

Termination

 

You can terminate this agreement with  Zesion OÜ and close your Account at any time, after the settlement of any pending order.

 

You also agree that by notice, in your sole discretion, to terminate your access to the Site and your Account, including, but not limited to, your right to: limit, suspend or terminate the service and Members' Accounts; prohibit access to the Site and its content, services and tools; delay or remove hosted content; and take technical and legal measures to keep Members off the Site if we suspect they are creating problems or potential legal liability, infringing the intellectual property rights of third parties, or acting inconsistently with the letter or spirit of these Terms of Use. Additionally, we may, in appropriate circumstances and at our discretion, suspend or terminate Member Accounts for any reason, including, but not limited to:

We expressly reserve the right to cancel and / or terminate Accounts that have not been verified by the Member despite the good faith efforts made by  Zesion OÜ to contact them to obtain such verification ("Unverified Accounts").

 
 

SERVICE AVAILABILITY

 

All services are provided without warranty of any kind, either express or implied, and in particular without implied warranties of merchantability and fitness for a particular purpose. We do not guarantee that this site will be available 100% of the time to meet your needs. We will endeavor to provide the Service to you as soon as possible, but there are no guarantees that access will not be interrupted or that there will be no delays, failures, errors, omissions, or loss of transmitted information.

 

We will use reasonable efforts to ensure that you can access the Site in accordance with these Terms of Use. However, we may suspend use of the Site for maintenance and we will use reasonable efforts to notify. You acknowledge that this may not be possible in an emergency and accept the risks associated with the fact that you may not always be able to use the Site or conduct urgent transactions with your Account.

 
 

EXTERNAL WEBSITES

 

Zesion OÜ is not responsible for any external or third-party website that you may access through the Site. Occasionally, the Zesion OÜ website  may provide references or links to other websites ("External Websites"). We do not control these external websites or third party sites or any of the content contained therein. You agree that we are in no way responsible for external Websites referenced or linked from the Zesion OÜ website  , including but not limited to website content, policies, glitches, promotions, products, opinions, advice, statements, prices, activities and announcements, services or actions, and / or damages, losses, failures or problems caused, related or derived from those sites. You must assume all risks associated with the use of such content.

 

External websites have separate and independent terms of use and related policies. We ask that you review the policies, rules, terms and regulations of each site you visit. It is up to you to take precautions to ensure that whatever you select for use is free of items such as viruses, worms, Trojan horses, and other items of a destructive nature.

 
 

FINANCIAL ADVICE

 

For the avoidance of doubt, we do not provide any investment advice in relation to the Services described in these Terms of Use. We can provide information on the price, range and volatility of cryptocurrencies that are available on our platform and the events that have affected the price of such cryptocurrencies, but this should not be considered investment advice and should not be construed as such. Any decision to buy or sell Bitcoins is solely your decision and we will not be liable for any losses incurred.

 
 

FINANCIAL REGULATION

 

Zesion OÜ's business model and Service  is to facilitate, through its Payment Services license, the purchase and sale of Cryptocurrencies. This specific service is currently regulated by Estonian law, under the Law of November 2017.

 
 

EMAIL

 

Unencrypted email messages sent over the Internet are not secure and  Zesion OÜ can not be held liable for damages caused by sending emails in this way. We suggest sending emails in encrypted formats; You can send us PGP-encrypted emails. Instructions and keys to do so are available upon request.

 

If you send us unencrypted or unsecured email or other communications, we may respond using the same channels and you accept the risks associated with them.

 
 

DATA PROTECTION

 

Privacy is very important for us. Full details of our Privacy Policy can be found at [Privacy Policy]. We recommend that you read the Privacy Policy carefully, so that you know the data we collect, how we use it and with whom we share it.

 
 

Disclosures to legal authorities and authorized financial institutions

 
 

We may share your Personal Data with law enforcement, data protection authorities, government officials and other authorities when:

Required by law;

Required by subpoena, court order or other legal procedure;

We believe that disclosure is necessary to avoid financial damage or loss;

Disclosure is necessary to report suspected illegal activity; or

Disclosure is necessary to investigate violations of our Terms of Use or Privacy Policy.

For more information on how we process your Personal Data, see the Privacy Policy.

 

 

 

JURISDICTION

 

The Terms of Use shall be governed by and construed in accordance with the laws of Estonia. The parties irrevocably agree to submit to the exclusive jurisdiction of the Estonian courts.

 
 

Limitation of liability

 
 

To the extent permitted by law,  Zesion OÜ shall not be liable for any damage, loss of profit, loss of income, loss of business, loss of opportunity, loss of data, indirect or consequential loss, unless the loss was suffered through negligence or willful deception or fraud. Nothing in these Terms of Use excludes or limits the liability of either party for fraud, death or personal injury caused by their negligence, breach of terms implied by law, or any other liability that cannot be limited or excluded by law. . Although  Zesion OÜ strives to provide accurate and timely information on the Site, the Site may not always be entirely accurate, complete or current and may include errors. We may change or update the Site at any time without prior notice, and accordingly, you should verify all information with independent sources before relying on it to make decisions or actions. You remain fully responsible for your decisions and actions.

 

To the extent permitted by applicable law, you agree to indemnify  Zesion OÜ and its partners against any action, liability, cost, claim, loss, damage, procedure or expense suffered or incurred if it arises directly or indirectly from the use of the Sites. by  Zesion OÜ . , your use of the Service or your violation of these Terms of Use.

 
 

DIVERSE

 

If we are unable to perform the Services described in the Terms of Use due to factors beyond our control, including but not limited to a case of force majeure, change in law or change in sanctions policy, we will not be liable for the Services provided under this agreement during the period of time coinciding with the event.

 

 

Modification of Terms

 
 

Zesion OÜ reserves the right to change, add or delete parts of these Terms of Use at any time and at its sole discretion. You will be notified of any changes in advance through your Account. Upon such notification, it is your responsibility to review the modified Terms of Use. Your continued use of the Site after the posting of a notice of changes to the Terms of Use means that you accept and agree to the changes, and that all subsequent transactions you make will be subject to the modified Terms of Use.

 

 

Definitions
 

● Account. The contractual agreement in which a Member of  Zesion OÜ has accepted our Terms of Use and Privacy Policy, and received approval to use the Zesion OÜ Services  , including the purchase and sale of Cryptocurrencies, and to carry out associated Transactions.       

● Bitcoins The peer-to-peer internet currency described at http://bitcoin.org.       

● Buyer (s). Members who submit an order to buy Bitcoins through the Service.       

● Seller (s). Members submitting an order to sell Bitcoins through the Service.       

● Commission. Refers to the fee payable to  Zesion OÜ in each transaction, such as a purchase transaction or a sale transaction.       

● Member (s). Refers to buyers and sellers as well as any account holder.       

● Personal Data. Information that identifies an individual, such as name, address, email address, business information, and bank details. "Personal Data" does not include anonymous and / or aggregated data that does not identify a specific user.       

● Price. The "price per coin" that the Zesion OÜ offer  and the member agree to buy or sell Bitcoins, using the Service in a Bitcoin purchase Transaction. The price can only be expressed in euros paid by members to the Zesion OÜ bank account  .       

● Services). The technological platform, functional rules, and managed marketplace allow sellers and buyers to buy and sell Bitcoins.       

 

Transaction. Includes the following:

⦁ Purchase transaction. The agreement between the Buyer and  Zesion OÜ to exchange fiat currency through the Cryptocurrency Service at a proportionate rate.

⦁ Sales transaction. The agreement between the Seller and  Zesion OÜ to exchange Cryptocurrencies through the Service for fiat currency at a proportionate rate.

● Transaction price. The total price and the additional fee paid by the Buyer or the Seller for each Transaction made through the Service. The current price of the  Zesion OÜ service and the additional fee for each transaction referral here  

     

 

AML POLICY

 

This is the anti-money laundering and terrorist financing policy (referred to as the AML / CTF Policy) of Zesion  OÜ , which operates the website https: // zesions.com.

  Zesion  OÜ is a privately owned limited liability company incorporated under the laws of Estonia with registration number: 14759852 and registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158 ​​/ 2-88, 11317 , Republic of Estonia. Aardo  OÜ , hereinafter may be referred to as "Zesion OÜ", "We", "Our", "Company" and "We" and includes their owners, directors, investors, employees or other related parties. The terms "User", "You" and "Your" refer to a User of the online platform https: // zesion.com. 

In order to maintain an uncompromising and reputable service provision, Zesion OÜ must follow strict rules on money laundering and anti-terrorist financing, governed by local and international laws and regulations. Zesion OÜ thus implements the current policy in accordance with:

  • DIRECTIVE (EU) 2018/843 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of May 30, 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing , and amend Directives 2009/138 / EC and 2013/36 / EU;
  • The Estonian Money Laundering and Terrorism Financing Law and other legal guidelines given by the Estonian Minister of Finance; Y
  • Any other applicable law in force in any territory that Zesion OÜ may be operating.

Zesion OÜ is always set to follow the strictest rules and industry standards in any country in which you may have operations with the intention of preventing any kind of illegal and criminal activities and any possible involvement of Zesion OÜ in such.

The policy against money laundering and financing against terrorism, which is part of the Terms and Conditions of Zesion OÜ, requires mandatory compliance by the User. Users are required to read, review, understand and then accept the terms hereinafter before using or taking advantage of any of the Zesion OÜ Services.

Terms not defined in this document will have the same interpretation as in the Terms and Conditions and, in the absence thereof, for general use and understanding.

 
 

Definitions

"Applicable laws" means the law in force for the time being within the territory of any country in which Zesion OÜ may be operating;

"Beneficial Owner" means:

  • The natural person who owns a direct or indirect ownership of more than 25% (twenty-five percent) of the shares of a legal entity, where indirectly means that the natural person has the property of another legal entity that owns totally or partially entity subject to check.
  • The natural person is entitled to more than 25% (twenty-five percent) of the earnings.
  • The natural person has the power, directly or indirectly, to appoint or elect more than half of the members of the administrative or supervisory body and is also a shareholder.
  • The natural person owns more than 50% of the voting rights in the legal entity;
  • The natural person has the right to influence the legal entity as a result of an agreement or the statutes of the entity.

"Identification document (s)" refers to:

  • National identification cards and passports and any other identification document issued by the government;
  • Documents that identify the registered address of a natural or legal person, such as, among others, a bank statement and a utility bill; or
  • Any other document that may be notified by Zesion OÜ from time to time.

"Politically exposed person" refers to any natural person who is himself or herself or is a family member or close associate of a natural person who is:

  • Head of State, Head of Government, Minister and Vice Minister or Assistant Minister;
  • Member of parliament or similar legislative bodies;
  • Member of the governing bodies of political parties;
  • Member of the supreme courts, constitutional courts, or other high-level judicial bodies, whose decisions are not subject to a new appeal, except in exceptional circumstances;
  • Member of the courts of accounts or of the boards of directors of the central banks;
  • Ambassador, Charge d'Affaires and Senior Officer in the Armed Forces.
  • Member of the administrative, management or supervisory bodies of state companies.
  • Director, deputy director or member of the board or equivalent function of an international organization.

"Sanction lists" refer to lists of individuals, legal entities, and entire countries that are involved, or suspected of being involved, in illegal and criminal activities. Such lists are, for example, provided by OFAC, UE, ONU, HMT.

"Suspicious transactions" refers to the following activities, whether attempted or executed:

  • Terrorism Financing - Transactions that, to a person acting in good faith, appear to be funds raised to be used, in whole or in part, by any terrorist or related organization, or to carry out any of the terrorist-related activities or terrorist acts.
  • Unusually complex: transactions that appear to a person acting in good faith to have been structured in an unusual or unjustified way.
  • Purpose of Malafide: Transactions that appear to a person acting in good faith not to have been made for purposes of good faith or do not have a sound financial basis.
  • Money laundering - Transactions that appear to a person acting in good faith to "clean up" criminal proceeds to hide their illegal origins. Such profits are generally associated with the types of organized crime that generate huge cash profits, such as drug, arms and human trafficking, as well as fraud.

 

Money Laundering Reporting Officer
 

Zesion OÜ appoints and duly authorizes the Money Laundering Reporting Officer (MLRO) to oversee the compliance of Zesion OÜ's systems and controls with the current AML / CTF Policy, relevant legislation, regulations, standards and guidance from the industry. The MLRO has a sufficient level of seniority and independence.

The Officer has the right to interact with law enforcement authorities, who are involved in the prevention of money laundering, terrorist financing, and other illegal activities.

 
 

User verification
 

The industry standard for combating money laundering, terrorist financing, and any other financial criminal activity is customer due diligence (CDD). Zesion OÜ implements CDD in the form of requiring any natural person, who wishes to carry out fiat money transactions on the Zesion OÜ platform, and any company / organization to verify, respectively, their identity and the identity of the beneficial owners of their company .

Following the established Know-Your-Customer (KYC) rules, regulations and procedures, we request user-supplied information and identification documentation. For the purposes of verifying the identity of any User, Zesion OÜ may rely on appropriate and licensed third-party service providers to authenticate the Identification Documents and other incidental details provided by the User.

Each client, who has passed the verification procedure, can carry out fiat money transactions on the Zesion OÜ platform only on the premise that they use bank cards and bank or electronic money service accounts in their own name
 

Identification of natural persons
 

Each natural person wishing to transact with fiat money on the Zesion OÜ platform is required to identify himself by providing:

  • Full name.
  • Birthdate.
  • Phone number.
  • Residence address.
  • Government-issued identification document, such as identification card and international passport, bearing a photograph, date of birth, and personal identification number issued by your government.
  • Proof of residence of the resident, such as utility bill or bank statement that is not more than 3 months old.
  • A recent photograph of themselves with their photo identification document and their application.

For natural persons with nationality or residence in a high risk third country or, if deemed appropriate, Zesion OÜ could also:

  • Request information on the source of funds and the source of wealth of the User;
  • Request information on the reasons for the transactions planned or carried out;
  • Conduct improved monitoring of the business relationship by increasing the number and timing of applied controls, and selecting transaction patterns that require further examination.      

     

Identification of legal entities and final beneficial owners

General identity information

Each legal entity must pass a verification process before starting to use the services of Zesion OÜ, regardless of whether it will transact with fiat money or not. Must provide:

  • Name
  • Number registered in any national registry
  • Legal form in accordance with the law of the place of registration
  • Address of corporate headquarters and management address
  • Certificate of incorporation
  • Articles / Memorandum of Incorporation
  • Bank statement no earlier than 3 months indicating the address of the company.
     

Additional verification measures

With respect to business account holders, we also apply the following enhanced customer due diligence measures:

  • Obtain additional information about the User, the beneficiary owner (s) and any other person who may have access to the corporate account in Zesion OÜ, such as data on Politically Exposed Persons.
  • Obtain additional information on the intended nature of the business relationship;
  • Obtain information about the source of funds and the source of wealth of the client and the beneficial owner (s).
  • Obtain information on the reasons for the transactions planned or carried out;
  • Obtain approval from senior management to establish or continue the business relationship.
  • Carry out improved monitoring of the business relationship by increasing the number and timing of controls applied, and selecting transaction patterns that require further examination.
     
 

People with access to the corporate account in Zesion OÜ
 

Zesion OÜ also requires a letter signed by the board of directors, the CEO, the managing director or the owner of significant control stating who has the authority to trade on behalf of the company, including:

  • The full name of each merchant.
  • Role in the company.
  • Email.
  • Physical address.
  • Nationality.
  • Any personal Zesion OÜ account they may have.
  • A scanned copy of your government issued ID card or passport.
     

Final beneficial owners
 

While at Zesion OÜ we are against blanket rejections, it is of the utmost importance to find out who exercises ultimate effective control over the legal entity with which we are related. As a result, we require information provided by the user on all Beneficiary owners about their:

  • Full name.
  • Nationality (s) maintained.
  • Identification document with photo.
  • Proof of address.
     

Taking the risk-based approach, we are especially diligent and may therefore employ additional measures, such as the use of third-party detection providers in case of:

  • Organizational structure with multiple levels of ownership;
  • Organizational structure in various jurisdictions; Y
  • Lack of supporting documentation to prove ownership.

 

In the event that the legal entity is owned by another, Zesion OÜ also requires:

  • Name;
  • Number registered in any national registry;
  • Legal form in accordance with the law of the place of registration
  • Address of corporate headquarters and management address;
  • The required details of the UBOs as indicated above, in relation to corporate "representatives".

     

Sanctions list review
 

Zesion OÜ is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists and thus protects its users against the United Nations, the European Union, the United Kingdom Treasury and the Office of Control of United States Foreign Assets (OFAC) and other sanctions lists.

 

Examination of politically exposed persons
 

To identify politically exposed individuals among its Users, Zesion OÜ not only relies on statements provided by the user, but also examines all individual account holders, all UBOs of corporate account holders, as well as anyone that has access to a corporate account against several national users. and international lists of PEPs.

 

Restrictions and denial of service

 

Based on the information provided, Zesion OÜ reserves the right to determine, in its sole discretion, the appropriate level of verification for any user, as well as the right to downgrade or ban users without prior notice. If Zesion OÜ discovers that any User information, obtained in accordance with the procedure described, is inappropriate, insufficient or included in the Sanctions Lists, the Company may, at its discretion, reject or cancel (as the case may be) the registration of said user account or require the verification of said user identification documents again.

In the event that it is pointed out to Zesion OÜ that a particular user or account is maintained under a fictitious name, Zesion OÜ has the full right and authority to cancel and close said account with immediate effect and without prior notice to the user.

Zesion OÜ also reserves the right to continuously verify the identity of the user, especially in cases of unusual and suspicious activity or if Zesion OÜ doubts the suitability or veracity of previously obtained customer identification data. Zesion OÜ has more right to request updated documents from users, even though they have already passed identity verification in the past.

Zesion OÜ can also implement policies that restrict verification levels by nationality, country of residence, or any other factor. This may affect the user's ability to deposit / withdraw funds based on their verification level and Zesion OÜ is not responsible for possible losses.

Zesion OÜ reserves the right to cancel the User Account, restrict and / or prevent access to its online platform, or inform the competent authorities of the activities of any User if there are suspicions of illegal activity.

Once the identity of the User has been verified, Zesion OÜ may withdraw from possible legal liability in a situation where its Services are used to carry out illegal activities.

 

Confidential personal information

 

Sensitive personal information is collected, shared and stored securely in accordance with the Zesion OÜ Privacy Policy.

 
 

Monitoring, analysis and reports of user activity

 

In addition to verifying the identity of the user, Zesion OÜ also reserves the right to monitor and analyze their activity as part of the AML / CTF toolkit. Zesion OÜ performs a variety of compliance-related tasks, including data capture, filtering, record keeping, investigation management, and reporting. System functionalities include, but are not limited to:

  • Transaction monitoring both by artificial intelligence (using predictive algorithms, statistical analysis, classification and scoring, etc.) and by human intervention, which appear to be:

● Unusually and unnecessarily complex.      

● Unusually large.      

● Driven in an unusual pattern.      

● Lacking an apparent economic or legal purpose.      
 

 

  • Daily verification of users against recognized "blacklists" (eg OFAC), as described above.
  • Placing users on denial of service and surveillance lists.
  • Opening of cases for investigation where necessary.
  • Request additional information, when deemed appropriate.
  • Sending of internal communications.
  • Complete legal reports, if applicable.
  • Case and document management.

     

Zesion OÜ monitors all transactions on a daily basis and reserves the right to report any suspicious transactions to the appropriate law enforcement agencies through the MLRO, to request additional information and documentation in case of suspected illegal activities, as well as to suspend or terminate the disposition services to suspicious Users. The list is not exhaustive and Zesion OÜ will take the necessary measures to avoid cases of money laundering, terrorist financing or any other criminal activity.

 
 

Risk-based approach

 

Zesion OÜ is dedicated to following the highest industry standards and therefore takes a risk-based approach to committing your resources in the most efficient way; which means that the greatest risks will receive the most attention. As a result, Zesion OÜ also reserves the right to classify its Users into different risk profiles based on the following factors (including, but not limited to):

  • Sufficiency and adequacy of identification information.
  • Nature of the User's commercial / vocational activities.
  • Guidance notes distributed by various governmental and intergovernmental organizations.

Business relationships with corporate account holders, who have a complex ownership structure, which prevents the identification of beneficial owners, and individuals with nationality or residence in high-risk third countries are, for example, a priority for the compliance office of Zesion OÜ.

Zesion OÜ keeps the risk categorization confidential and can change the categorization of any User at any time given various factors. While Users do not have the right in any way to request disclosure, Zesion OÜ may disclose User's risk categorization data to the competent compliance authority if it finds that a particular User has executed or is likely to execute a suspicious Transaction. .

 

 

Modifications

 

This AML / CTF policy may be reviewed and revised periodically. The revised draft will be uploaded to https://zesion.com and will reflect the modification date of the terms. The User is required to periodically visit the website and review the terms and any changes to it. The continued use by the User constitutes an agreement with any modification of the policy.

 

 

Contact
 

If you have any questions regarding these Terms of Use, anti-money laundering and anti-terrorist financing policy, your rights, obligations, your use of the Site, the Service, your Account, or any other matter, please contact [email protected].

 

Zesion, oü.

Registry code: 14759852

Address: Harju maakond, Tallinn,

Kesklinna linnaosa,

Pärnu mnt 158 ​​/ 2-88,

11317

Estonia

 

Zesions.com

 

[email protected]

[email protected]