BigWallet Prohibited Business Types


Unfortunately, not all businesses can make use of the BigWallet services due to legislation, regulation, network rules or requirements. We want to be as transparent as possible so please have a look at the below categories to be sure we can be of service to you.

Not sure if BigWallet can support your business? Please contact us at info@bigwallet.com and we can discuss together if BigWallet is the right fit for your business.

Please see the categories of absolute prohibited businesses that we do not accept as clients.

  • Academic paper-writing and test-taking services:Individuals who falsely take up tests or exams in the name of other individuals; and individuals who prepare documents (such as dissertation, theses, assignments etc.) to be presented to academic institutions for obtaining certifications, diplomas, degrees etc. Pre-written essays, thesis papers, and dissertations; offers for paper-writing or test-taking services.
  • Adoption agencies - for profit: Agencies that take payment for the placement of infants with adoptive parents.
  • Animals and regulated species: Animal parts, blood, or fluids; noxious weeds; prohibited seeds; plants or other organisms (including product derivatives) in danger of extinction or whose trade is otherwise regulated by law.
  • Any services providing peripheral support of illegal activities: Any legal services that promote, directly or indirectly, illegal activities.
  • Child pornography, bestiality and any other illegal contentAny merchant providing pornographic content or services involving the use of a minor, or one appearing to be a minor, engaging in sexually explicit conduct. Any merchant providing pornographic content or services related to sexual intercourse between a person and an animal.
  • Copyright media and software:Unauthorized copies of books, music, movies, and other licensed or protected materials including copies without proper attribution; and unauthorized copies of software, video games and other licensed or protected materials, including OEM or bundled software.
  • Counterfeit and unauthorized goods: Replicas or imitations of designer or other goods; items without a celebrity endorsement that would normally require such an association; fake autographs; currency; stamps; tickets; other potentially unauthorized goods.
  • Devices or techniques for unlocking technical protection measures: Mod chips or other devices for circumventing technical protection measures on digital devices.
  • Drug paraphernalia: Any business whose products are solely intended for aiding the consumption of illegal drugs.
  • Government IDs, documents, or uniforms:Including but not limited to government issued IDs, passports, diplomas, noble titles, and uniforms, except if sold by an authorized government agency or by a supplier accredited by an authorised government agency.
  • Gun sales over the Internet: Any sale of firearms over the Internet.
  • Hacking and cracking materials: Manuals, how-to guides, information, or equipment that violate the law by damaging or enabling unlawful access to software, servers, websites, or other protected property.
  • Human parts and remains: Organs or other body parts; body fluids; stem cells; embryos.
  • Illegal telecommunications equipment: Devices intended to obtain cable and satellite signals for free, cable descramblers and black boxes, access cards, access card programmers and unloopers, unlawful tools or products to modify cellular telephones, and other equipment deemed unlawful by the Federal Communications Commission (FCC) or other competent regulatory body in the country in which the goods are offered for sale.
  • Jamming equipment: Merchants offering “cell jammers” or similar devices designed to block communications and create a “quiet zone” in vehicles, schools, theaters, restaurants, and other places.
  • Online Pharmaceuticals: Online sale of controlled drugs.
  • Protected cultural items and artefacts:Material covered by the UNESCO 1970 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property or otherwise restricted by law from sale, export or transfer; Artefacts, cave formations (speleothems, stalactites, and stalagmites) and grave-related items that are protected under federal laws, such as The Federal Cave Resources Protection Act of 1988, and the Native American Grave Protection and Repatriation Act.
  • Investment & Credit Services:Rotational savings.
  • Money and Legal Services:Check cashing and transferring.

Businesses that are accepted on a case-by-case basis

Apart from the above categories we have multiple business types that we allow the use of our services to, but which we judge on a case-by-case basis. If your activity is one of the below, please contact us on info@bigwallet.com to ensure together if BigWallet is the right fit for your business.

Merchants whose MCC’s are considered high risk by the card schemes, namely;

  • 5122 / 5912 - Non–face-to-face pharmaceutical Merchants
  • 5962—Direct Marketing—Travel-Related Arrangement Services
  • Merchants providing e-wallet services
  • Merchants providing payment services to other merchants via prepaid/anonymous vouchers
  • Merchants with equity issued in the form of anonymous shares (bearer shares) resulting in significant restrictions in the process for the verification of the ultimate beneficial owners.
  • Merchants with a chargeback to transaction ratio that exceeds card scheme program thresholds or any other threshold as communicated by BigWallet from time to time
  • Merchants offering products or services on a subscription scheme that is either not made clear to the customer or is not congruent with the product or service being offered
  • Payment Solutions, on web, mobile or application
  • Remittance of funds
  • SaaS ecommerce solutions
  • SaaS Marketplace solutions
  • SaaS Crowdfunding solutions
  • Unregulated Crowdfunding equity platforms
  • Charitable donations, gift and/or counter gifts
  • Any solution that is White or Grey Label
  • Compliant platforms that have their client targets outside of the European Economic Area (EEA)
  • Complex Financial Workflow platforms
  • Alcohol related services

Please note that BigWallet has the full right to deny your business activity at any moment if they see fit and to adjust the above conditions based on changes in its environment.


Merchant Website Requirements


BigWallet has adopted and follows the below requirements and criteria prior approval of merchant account application.

Website Terms and Conditions

Merchants website must contain the following information and set of T&C’s:

  • General Terms and Conditions - Customers must be able to ‘click to accept’ your terms and conditions during registration and before proceeding to your website’s payment page(s).
  • Privacy policy - The policy need to be aligned with the GDPR requirements of customer data handling and customers must be able to ‘click to accept’ your terms and conditions before proceeding to your website’s payment page(s).
  • Delivery/Shipping policy (when applicable)
  • Cancellation, Returns & Refunds policies.
  • Visible pricing and currency terms - the prices of the products / services on offer must be clearly stated and including VAT.
  • Billing Descriptor - Billing descriptors should either represent the website domain or the legal name of the merchant appearing on the website.
  • AML/KYC policy (when applicable) - When your business type requires license.

Contact Information

Full contact details should be available on the merchant’s website and must include:

  • Telephone number, Email address (alternatively a contact form)
  • Legal/trading address (PO Box addresses will not be sufficient)
  • The full legal name of your business must be displayed in the footer, payment page and “contact us” section of the merchants website.

Card Schemes Logos

  • Logos of the card schemes should be displayed on the merchants website and payment page e.g. VISA, MasterCard, Verified by Visa

*If the merchant website is in its inception/development phase, the merchant will need to provide us with login details to access the development website along with your application.


Privacy Policy

Silvegate Technologies Limited Privacy Notice for clients’ representatives and beneficial owners

1. INTRODUCTION

This is Silvergate’s Privacy Notice under Art. 14 of the GDPR for Client’s representatives and beneficial owners. If you are a Client’s r epresentative or a beneficial owner, this Privacy Notice provides you with information on the processing of personal data by Silvergate (Silvergate or we).

2. SOURCE OF YOUR PERSONAL DATA

We received your personal data from the person acting on behalf your company, our contractual party (Client).

3. WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Notice is applicable to Silvergate’s processing of all personal data of its Clients’ beneficial owners, representatives and persons authorised by these representatives. When a Client enters into a contractual agreement with Silvergate, it is required, as part of concluding the contract, to provide us with some personal data of its representatives and, in some cases, of its ultimate beneficial owners.

4. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Silvergate is the controller of the processing of all personal data that fall within the scope of this Privacy Notice. This Privacy Notice indicates what personal data are processed by Silvergate and for what purpose, and to which persons or entities the data will or may be provided. Silvergate Technologies Limited resides at: Antheon 2, Monolivko 4, Kato Polemidia, 4151, Limassol - Cyprus

5. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

The personal information that we process can be divided into two categories:

(a) To comply with legally required assessments under the Cyprus Anti-money laundering law

(i) What does this purpose entail?

In some cases, Silvergate processes Clients’ representatives and beneficial owners’ personal data to comply with laws and regulations on anti-money laundering.

To comply with the relevant laws and regulations, we may need to disclose your personal data to government institutions, supervisory authorities, banks and our providers.

(ii) On what legal grounds do we process personal data for this purpose?

The basis for processing your personal data is Silvergate’s legal obligation entailed in the Cyprus Act No on the Prevention of Legalization of Proceeds of Criminal Activity and Terrorist Financing.

We are furthermore obligated to collect such personal data given the provisions of the money laundering law which require that we verify your identity before we enter into a contract or a business relationship with you or the legal entity for which you are the authorised representative / agent or beneficial owner. You must, therefore, provide us at least with your identity card/passport, your full name, place of birth (city and country), and your residential address so that we may comply with our statutory obligation as mentioned above.

Kindly note that if you do not provide us with the required data, then we will not be allowed to commence or continue our business relationship with you either as an individual or as the authorised representative/agent or beneficial owner of a legal entity.

(iii) Which personal data do we process for this purpose?

For this purpose, if you are a Client’s representative, we collect:

  • basic identification information such as name, surname, title, address of residence, date of birth, personal No., and contact information like phone No., email address, identity document (ID) and utility bills;
  • Number of Client’s bank accounts at your disposal and related information (ie information regarding the persons entitled to deal with the account);
  • Business licences, their extent and validity (if applicable); and
  • Previous political/public functions in case you, as a Client’s representative, still hold that function or were released from the function within the past year.
  • Data for FATCA/CRS reports,
  • Authentication data i.e. signature, nationality, business and/or home address etc.

If you are a Client’s ultimate beneficial owner, we also collect information regarding your identity and address (if applicable).

(iv) For what period do we retain your personal data for this purpose?

We will keep your personal data for as long as we have a business relationship with you (as an individual or in respect of our dealings with a legal entity you are authorised to represent or of which you are the beneficial owner).

Once our business relationship with you has ended, we may keep your data for up to ten (10) years in accordance with the directive of the Data Protection Commissioner (http://www.dataprotection.gov.cy).

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.

Authorized representatives/agents or beneficial owners of a legal entity prospective customer we shall keep your personal data maximum for 3 years from the date of notification of the rejection of your application for payment services and/or facilities or from the date of withdrawal of such application, as per Data Protection Commissioner directive (http://www.dataprotection.gov.cy).

(b) For the conclusion and execution of agreements with Clients

(i) What does this purpose entail?

When a Client enters into a contractual relationship with us, we process your personal data for administrative purposes such as sending invoices and making payments and contacting you concerning specific Silvergate service. Silvergate will process your personal data to further execute our agreement, including for the delivery of customer services.

(ii) On what legal ground do we process personal data for this purpose?

The basis for processing your personal data is the performance of the contract with the Client you represent.

(iii) Which personal data do we process for this purpose?

For this purpose, we process your contact details, ie address and email address and personal details, ie your name and date of birth.

(iv) For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the duration of the contractual relationship. After this term, your personal data will be deleted from our systems.

6. WHO HAS ACCESS TO YOUR PERSONAL DATA?

6.1 Access to your personal data within Trust Pay

Silvergate’s employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform Silvergate’s legal obligations.

6.2 Access to your personal data by third parties

Your personal data will not be supplied to third parties, except where required by law or to execute your payment or you have given us your consent to do so. The following third parties have access to your personal data under Silvergate’s legal obligations:

  • Banks and other financial institutions involved in transactions connected with providing payment services
  • State institutions
  • Providers of sanctions lists, identity verification and review of compliance with Anti-money laundering laws

7. HOW ARE YOUR PERSONAL DATA SECURED?

Silvergate shall maintain appropriate technical and organizational measures for protection of the security (including protection against unauthorized or unlawful processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, personal data), confidentiality and integrity of Client´s data. Silvergate regularly monitors compliance with these measures. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access and we make no warranty, express, implied or otherwise, that we will for use prevent such access.

8. WHAT ARE YOUR RIGHTS?

Subject to some limitations, you can request access to or the correction, restriction, portability or removal of the data that Silvergate processes about you at any time by sending a request to our address Silvergate Technologies Limited, Antheon 2, Monolivko 4, Kato Polemidia, 4151, Limassol, Cyprus.

Should you have any questions regarding the processing of your personal data, please contact us by written request to our address: Silvergate Technologies Limited, Antheon 2, Monolivko 4, Kato Polemidia, 4151, Limassol, Cyprus.

If you feel that we are breaching the applicable privacy rules you have the right to lodge a complaint with the Office for Personal Data Protection of Cyprus or other competent authority.

GDPR Compliance Statement (Vs1)

Introduction

The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach. The General Protection Regulation (GDPR) (EU) 2016/679 is the EU regulation on data protection and privacy for all individuals within the European Union and the European Economic Area. has been designed to meet the requirements of the digital age.

Silvergate Technologies Limitedis a company incorporated under the laws of the Republic of Cyprus under registration number HE346672 with registered office address Antheon 2, Monovoliko 4, Kato Polemidia, 4151 Limassol, Cyprus and is a licensed Payment Institution under license number 115.1.2.26/2018 and regulated by the Central Bank of Cyprus.

Our Commitment

Silvergate Technologies Limited (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR.

Silvergate Technologies Limitedis dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Silvergate Technologies Limitedrespects your privacy policy and recognizes Your right for transparency and integrity as to the way of collecting and processing of your personal data.

DEFINITIONS

Controller –the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and the means of the processing of Personal Data.

Personal Data –means any information relating to an identified or identifiable natural person (name, ID, location and any other factors specific to the physical, genetic, mental, economic, cultural or social identity of that natural person); The information for the legal entities such as business, partnerships, trusts or other organizations provided by its authorized person, signatory, partner, trustee, executor or a like shall be considered as appropriate.

Processor –a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller;

Processing –obtaining, recording, storing, holding, using or carrying out any operation or set of operations on the information or data including organization, adaptation or consultation on the information or data, as well as disclosure by transmission, dissemination or otherwise making available, or alimenting, combining, blocking, removing or destructing of the information or data;

Sub-Processor –a processor engaged by the data importer or by any other sub-processor if the data importer and who agrees to receive from the data importer or from any other sub-processor of the data importer personal data exclusively intended for the processing activities to be carried out on behalf of the data exporter after the transfer in accordance with the data exporters instructions.

WHAT INFORMATION WE COLLECT FROM YOU

  • Silvergate Technologies Limited is required to collect the following Personal Data:

    - Personal information (name, address, email, telephone number, mobile number, temporary residential address, employment address, name of employer, personal status, i.e. identity card number, passport number, marital status, occupation, country of taxation and other);
    - Financial information (income, source and size of wealth and other)
    - Recording of the call conversations between You and the Company

  • Silvergate Technologies Limited is also required to collect and keep all the documents which confirm the accuracy of provided personal and financial information (passport, ID, Utility Bills, Bank Statements, Internal passports, bank referenced, CV’s or any other documents which may be requested by the Company in order to comply with the applicable law).
  • Silvergate Technologies Limited always makes sure that all Personal Data we collect is adequate, relevant and limited to what is necessary in relation to the purposes for which they are collected and processed.
  • In cases where we receive data which was not requested or where information was unintentionally revealed, and the company does not intend to use it for purposes of processing or where data was received by mistake, Silvergate Technologies Limited shall notify You that such data was received and destroy it, unless You wish otherwise

WHY WE COLLECT YOUR INFORMATION

According to GDPR, Silvergate Technologies Limited acts as a Controller of Your Personal Data and determines solely or jointly with others, the main purpose and legal grounds for the collection and processing of Your Personal Data.

Below Silvergate Technologies Limited outlines the following purposes and legal reasons:

  • Execution of the contract.The collection and processing of Your Personal Data is necessary for entering into business relationship with You for the provision of payment services.
  • Compliance with legal frameworkwithin which Silvergate Technologies Limited operates, the Directive of the European Union on Payment Services in the internal Market of 2015, which was further implemented into national law of the Republic of Cyprus through the Provision and Use of Payment Services and Access to Payment Systems Law of 2018, and the Prevention and Suppression of Money laundering Activities Laws 2007 to 2018 of the Republic of Cyprus implementing the relevant Anti-Money Laundering Directive of the European Union, as well as Directive (EU) 2015/849 of the European Parliament and of the Council and Commission Directive 2006/70/EC, together with other relevant laws applicable for the Anti-Money Laundering prevention and the laws applicable to the operation of Silvergate Technologies Limited.

    Compliance with these regulations requires from the company to identify and verify personal information related to You and all connected persons, as well as exercise anti-money laundering controls, keeping and collecting Personal Data of the particular period of time and disclose such information to the supervisory and other regulatory authorities, etc.;

  • Legitimate Interestspursued by the company in order to protect its business environment. Provided that such interest does not infringe the rights, interests and Your fundamental freedoms.

    "Legitimate interests" is a heading that covers several different reasons why Silvergate Technologies Limited may need to collect and process Your Personal Data which may not be covered by other headings, such as: to prevent fraud or financial crime, to provide a better service, to transfer Personal Data between group entities for internal administrative purposes, or for the purposes of network or information security.

CATEGORIES OF RECEIPIENTS OF YOUR PERSONAL DATA

Your Personal Data in the curse of performing our contractual and statutory obligations may be disclosed to the following Processors, Sub-Processors and Controllers:

  • Supervisory and other regulatory and public authorities, including governmental bodies; Some examples are the Central Bank of Cyprus(CBC) and the Unit for Combating Money Laundering (MOKAS);
  • External auditors, lawyers, agents, consultants and other professional advisors subject to confidentiality agreements;
  • Banks and other financial organizations subject to the confidentiality agreements;
  • Fraud prevention agencies;
  • File storage companies, archiving and/or records management companies, cloud storage companies subject to the confidentiality agreements;
  • Employees of Silvergate Technologies Limited

Silvergate Technologies Limited may be required to transfer the information provided by You outside of the European Economic Area (for example third party providers or banks) for the purpose of executing the services provided in a manner as described under Silvergate Technologies Limited’s Internal Policies. Such transfer is subject to Article 49(1)(b) and Article 49(1)(c) of the GDPR.

The company ensures an adequate level of protection for any Personal Data processed by others on behalf of Silvergate Technologies Limited that it is transferred within or outside the European Area.

Unless expressly declared by You, the Personal Data collected and keeping by Silvergate Technologies Limited will not disclosed to any third party other that the above-mentioned recipients.

HOW WE TREAT YOUR PERSONAL DATA FOR MARKETING ACTIVITIES AND WHETHER PROFILING IS USED FOR SUCH ACTIVITIES

We may process your personal data to tell you about products, services and offers that may be of interest to you or your business.

The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services, such as information on your transactions. We study all such information to form a view on what we think you may need or what may interest you. In some cases, profiling is used, i.e. we process your data automatically with the aim of evaluating certain personal preferences in order to provide you with targeted marketing information on products.

We can only use your personal data to promote our products and services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so.

You have the right to object at any time to the processing of your personal data for marketing purposes, by contacting us at any time through email indicated below in this document or in writing.

KEEPING PERSONAL DATA

In accordance with the laws and regulations of the Republic of Cyprus, Silvergate Technologies Limited is obliged to keep and update Your Personal Data for as long as Silvergate Technologies Limited provides its services to You. Once our business relationship with you has ended, we may keep your data for up to ten (10) years in accordance with the directive of the Data Protection Commissioner (http://www.dataprotection.gov.cy). However, Silvergate Technologies Limited will be required to keep Your Personal Data for the longer period of time if it is prescribed by laws, competent authorities or other regulations (such as pending legal proceedings or investigations) or technical reasons.

SAFEGUARDING

Silvergate Technologies Limited takes all reasonable and appropriate steps to protect Your Personal Data from misuse, loss or unauthorized disclose. The Company is doing this by having a range of appropriate technical and organizational measures. In addition, Silvergate shall maintain appropriate technical and organizational measures for protection of the security (including protection against unauthorized or unlawful processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, personal data), confidentiality and integrity of Client´s data. Silvergate regularly monitors compliance with these measures. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access and we make no warranty, express, implied or otherwise, that we will for use prevent such access.

YOUR RIGHTS

You have the following rights in relation to the Personal Data provided by You to the Company:

  • The right to access to or have a copy to the Personal Data we hold about you as well as some supplementary information on that data and to check that we are lawfully processing it;
  • The right to request rectification of incorrect data concerning You; This enables you to have any incomplete or inaccurate data we hold about you corrected;
  • The right for data portability if it should become relevant; Also you have the right to have your personal data transmitted directly by us to another data controller you will name
  • The right to request, on legitimate grounds the erasure of Your Personal Data; This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
  • The right to object the processing of Personal Data based on Silvergate Technologies Limited legitimate interests and/or processing of Personal Data for direct marketing purposes; If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
  • The right to restrict processing of Your Personal Data if you disagree over the accuracy of the personal data, the reason for processing or if you wish us to retain your date for longer that the retention period, e.g. to establish, exercise or defend a legal claim;
  • The right to withdraw consent, by written notice at any time, if the process of Your data is based on consent. Please note that this will not affect the lawfulness of processing based on consent before it was withdrawn by You;

Please feel free to exercise the above rights by sending an email to gdpr@bigwallet.com

You have the right to lodge a complaint regarding the processing of Your Personal Data by BigWallet by sending you complaint via email to gdpr@bigwallet.com and the Company’s responsible officer will investigate your complaint. In the event that you are not satisfied with the response or if You feel that Your Concerns have not been adequately addressed by the Company, you have the right to file a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus. Find out on their website how to submit a complaint (http://www.dataprotection.gov.cy).

PERSONAL DATA BREACH NOTIFICATION

In case the Company becomes aware of Personal Data breach which may result in high risk to Your rights and freedoms, the company shall without undue delay notify You of such breach and provide the following information:

  • Type of Personal Data affected;
  • The nature of breach;
  • Steps to be taken by the Company in order to minimize any damage

You should inform the company immediately by sending an email to gdpr@bigwallet.com of any possible damage, loss or misuse such breach may cause You in order to assist Silvergate Technologies Limited assess all possible solutions promptly.

CHANGES IN THE GDPR STATEMENT

We may modify or amend this privacy statement from time to time.

We will notify you appropriately when we make changes to this privacy statement and we will amend the revision date at the top of this page. We do however encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.

GOVERNING LAW

This Privacy Policy shall be construed and interpreted in accordance with the laws of the Republic of Cyprus. You and the Company hereto irrevocably submit to the exclusive jurisdiction of the courts of the Republic of Cyprus in connection to any dispute arising from the terms of this policy.

AML Policy Statement

Silvergate Technologies Limited is committed to implementing the most effective anti-money laundering standards available.

Silvergate’s AML Policy is designed to prevent the use of Silvergate’s services in relation to money laundering and terrorist financing activities, fraud and other financial crimes. To this end, Silvergate established an Anti-Money Laundering Program (“AML Program”) which analysed below in this Policy and may request the following information from its customers:

a) Silvergate reserves the right to request proper documentation to verify your identity and/or your business. Additional personal or business information or bank account details may also be requested from you.

b) Silvergate reserves the right to specific identification as part of a screening process for Silvergate accounts that are under scrutinity or international watchlists.

c) Silvergate reserves the right to request the abovementioned information during your application for a Silvergate account in order to provide you with the services.

d) Silvergate reserves the right to review the abovementioned information submitted during your application to review your account. This review is conducted on a regular basis and in accordance with Silvergate’s AML policy and all applicable laws and regulations.

Silvergate Technologies Limited has established an AML Program for this purpose. The objective of the AML Program is to ensure that money laundering risks identified by Silvergate Technologies Limited are appropriately mitigated. This is achieved by establishing Board-approved, minimum governing policies, principles, and standards and implementing appropriate controls, to protect Silvergate Technologies Limited, its employees; shareholders and customers from money laundering.

The AML Program provides guidance to all Silvergate Technologies Limited employees, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.

The AML Program is based upon the Cyprus laws, regulations and regulatory guidance from the Central Bank of Cyprus and the European Union in all the jurisdictions in which Silvergate Technologies Limited conduct business.

The Program includes but is not limited to:

* The appointment of a Money Laundering Reporting Officer (“MLRO”) as required by local regulation

* A Customer Due Diligence (“CDD”) Program, which incorporates Customer Identification and Verification (“ID&V”) and Know Your Customer (“KYC”) principles, and the implementing of program designed to appropriately remediate CDD of our existing customers

* Conducting enhanced due diligence (“EDD”) on customers assessed as higher risk, such as Politically Exposed Persons (“PEPs”) in senior positions, their relatives and close associates

* Establishing processes and systems designed to monitor customer transactions for the purpose of identifying suspicious activity

* The investigation and subsequent reporting of suspicious activity to the appropriate regulatory bodies Regular independent testing and regular AML training of its employees

* Any relevant additional local requirements

Silvergate Technologies Limited with company registration number HE346672 and legal address at Antheon 2, Monolivko 4, Kato Polemidia, 4151, Limassol, Cyprus is authorized and regulated by the Central Bank of Cyprus under license number 115.1.2.26/2018

Cookies Policy

At Silvergate Technologies Limited, we want to ensure that your visit to our website is smooth, reliable and as useful to you as possible. To help us do this, we use cookies and similar technologies to make our website relevant to your interests and needs. This helps provide you with the services you have requested, good user experience, tailored content and interest-based adverts. For example, we can recognise and remember important information, such as preferred settings, that will make it more comfortable for you to browse our website.

What are cookies?

Cookies are small text files that are automatically placed on your computer or mobile device when you visit almost any Web site. They are stored by your Internet browser. Cookies contain basic information about your Internet use, but they do not normally identify you personally. Your browser sends these cookies back to the site every time you revisit it, so it can recognize your computer or mobile device and personalize and improve your site experience.

What type of cookies do we use?

The cookies we use fall into 3 categories. These categories are described below:

Essential cookies:

These cookies are necessary to help you access and move around our site and use all its features. Without these cookies, our website would not work properly and you would not be able to use certain important features. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Analytics and customisation cookies:

At Silvergate Technologies Limited, we want to make your experience on our website as helpful, smooth and as enjoyable as possible. We use cookies to help us understand how our website is being used and how we can improve your experience on it. This type of so-called “analytics” cookies can provide us with anonymous information to help us understand which parts of our website interest our visitors and if they experience any errors. We use these cookies to test different designs and features for our sites and we also use them to help us monitor how our visitors reach our sites. Finally, all of the informationcollected by these cookies is anonymous and is only used for statistical purposes.

Advertising cookies:

Advertising cookies help ensure that our advertisements are as relevant to you as possible. We work with third party advertisers to give you access to interesting and exciting content on our website. These third party cookies record information about your use of advertisements and help to improve your online experience. For example, some advertising cookies help select advertisements that are based on your interests. Others help prevent the same advertisement from continuously reappearing for you. Without these cookies, online advertisements you encounter will be less relevant to you and your interests.

Managing your cookie settings:

You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies. Most advertising networks offer you a way to opt out of advertising cookies.

Please note that, if you choose to delete Silvergate Technologies Limited cookies, your access to some functionality and areas of our website may be degraded or restricted. In addition, the removal of the advertising and marketing related cookies of the website (which are used for the personalisation of the content) will not result in the removal of all adverts during your browsing session, only those over which we have control. You may also miss information about the latest changes to the products and services that we provide or of promotional offers that you might find interesting