Terms and conditions

Acceptance of Terms of Use - Three True Trillions



By using the Three True Trillions website, registering for an Account at https://zesions.es ("Account") or using any other Three True Trillions Service, you ("you, his or yourself") agree accept and comply with the terms and conditions. Terms of Use set forth below ("Terms of Use"). You should read all of the Terms of Use carefully before using this Site or any of the Three True Trillions Services.



As used in these Terms of Use, "Three True Trillions" refers to the company, Registered in the Polish Trade and Companies Register under number RDWW461, with its registered address at 86 Hoza street unit 210 zip code 00-682 Warsaw, in Poland. with the registration number for virtual currency activities RDWW-461


References to Three True Trillions are also references to its owners, directors, investors, employees.



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



Three True Trillions allows buyers ("Buyers") and sellers ("Sellers") to use its Service capabilities to buy and sell Cryptocurrencies such as (Bitcoin BTC, Ethereum ETH, Tether USDT, Ripple XRP, Bitcoin Cash BCH, Binance Coin BNB , Cardano ADA, Litecoin LTC, Bitcoin SV BSV, USD Coin USDC, EOS EOS, Monero XMR, TRON TRX, Stellar XLM, Tezos XTZ, Neo NEO, Binance BUSD, Dash DASH, Zcash ZEC, Ethereum Classic ETC, TrueUSD TUSD, Paxos Standard PAX, HUSD HUSD, PAX Gold PAXG, Chainlink LINK, Tezos XTZ, THETA THETA, Qtum QTUM, Polkadot DOT, Filecoin FIL ).



Buy cryptocurrencies at Three True Trillions with fiat money via bank transfer.


The Buyer enters in the purchase form of the platform the amount of cryptocurrencies he wishes to acquire, his public wallet address to receive the cryptocurrencies, the platform will automatically display 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 credit mode using their personal account, with a time limit of 20 minutes to upload the payment receipt file and mark paid, if you fail to complete the payment within this time, the window closes and you will have to go through the steps above again.



In the event that the funds are not immediately credited to the Three True Trillions 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 Three True Trillions bank account, the user will receive a cryptocurrency transfer to their wallet.



Three True Trillions 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 he authorizes to operate with the cryptocurrencies purchased.



Purchases are made by bank transfer. Buyer must send receipt of payment to Three True Trillions. The conversion price will be fixed at the time of the opening order and does not change during the receipt of the payment to the Three True Trillions 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 arising from it being borne by the customer plus a fine of fifteen euros (€15).


Sell ​​crypto to Three True Trillions for fiat money via bank transfer



The Seller enters in the sales form the desired amount of cryptocurrency to sell and the platform automatically displays the amount of euros to be received or the client can enter in the form the desired amount of euros to be received, then the platform will automatically display the amount required amount of cryptocurrency All cryptocurrency transfers from the member to the Three True Trillions platform can be verified on the search engine blockchair.com.



The Seller will receive 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 features of the Site.

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



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


By registering an account, you expressly represent and warrant:

That you have accepted these Terms of Use, that you are at least 18 years of age and have the full capacity to accept these Terms of Use and to make a transaction involving cryptocurrencies.




RISKS



Trading in goods and products, real or virtual, as well as virtual currencies involves significant risk. Prices may fluctuate on any given day. Such price fluctuations may 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 worthless. 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 like 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 currency 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 foreign exchange companies and individuals. Merchants rely on a digital, decentralized, partially anonymous system that relies on peer-to-peer networks and cryptography to maintain its integrity.



Cryptocurrency trading is often susceptible to irrational, 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 alternative currencies, 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 are able to prevent transactions from settling.



There may be additional risks that we have not anticipated or identified in our Terms of Use. You should carefully assess whether your financial situation and risk tolerance are adequate to buy, sell or trade Bitcoins.


We use our banking providers to receive customer funds 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 Three True Trillions and are protected by copyright, trademark and other applicable laws. You may view, print or download one copy of the Materials from this Site on any computer for your personal, informational or non-commercial use, provided that you comply with all copyright and other proprietary notices.



The trademarks, service marks and logos of Three True Trillions 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, graphics, video and audio used on this site belong to Paynote. The Trademarks and Materials may not be copied, reproduced, modified, published, uploaded, posted, transmitted, scraped, compiled, or distributed in any form or by any means, manual or automated. The use of such Materials on any other Site or networked computer environment for any other purpose is strictly prohibited; Any such unauthorized use may violate copyright, trademark, and other applicable laws, and could result in criminal or civil penalties.



Maintenance of your account


This site is for your personal, non-commercial use only. We are vigilant in maintaining the security of our Site and Service. By registering with us, you agree to provide Three True Trillions with current, accurate and complete information about yourself, as prompted by the registration process, and to keep such information up to date. You further agree that you will not use any Account other than your own, or access any other Member's Account at any time, or assist others in gaining unauthorized access.



The creation or use of Accounts without obtaining the prior express permission of Three True Trillions will result in the immediate suspension of said Accounts, as well as 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 such Members' Accounts. Termination is not the exclusive remedy for such violation, and Three True Trillions may elect 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 actions on the Site, transactions, orders and operations initiated from your Account or using your password are (1) deemed to be made by you, and (2) irrevocable once validated using your password or made 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 terminated and the member will be liable for any losses suffered by Three True Trillions 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, financing of terrorism, malicious hacking, or any criminal or illegal activity.



The minimum trade allowed is 10 EUR.

individual client

The maximum trade allowed is 5,000 EUR per month.


Commercial Client

The maximum trade allowed is 10,000 EUR per month.



VERIFICATION OF ACCOUNTS



The creation and use of your account are subject to verifications, as required by the legal and regulatory obligations in force in Three True Trillions. You agree to provide us with the information we request for the purposes of identity verification, compliance with know-your-customer regulations, as well as detection of money laundering, financing of terrorism, 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 you agree to inform us in case of changes related to said 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 deletion of Personal Data processed in the course of verification operations.

 


Termination



You may terminate this agreement with Three True Trillions and close your Account at any time, following settlement of any pending orders.



You also agree that upon notice, in its sole discretion, you may terminate your access to the Site and your Account, including, without limitation, your right to: limit, suspend, or terminate service and Member Accounts; prohibit access to the Site and its content, services and tools; delay or remove hosted content; and take technical and legal steps to keep Members off the Site if we suspect they are creating problems or potential legal liability, infringing the intellectual property rights of others, or acting inconsistently with the letter or spirit of these Terms of Use. In addition, we may, in appropriate circumstances and at our discretion, suspend or terminate Member Accounts for any reason, including without limitation.


We expressly reserve the right to cancel and/or cancel Accounts that have not been verified by the Member despite good faith efforts by Three True Trillions 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 you with the Service as soon as possible, but there is no guarantee that access will not be interrupted or that there will be no delays, failures, errors, omissions or loss of information transmitted.



We will use reasonable efforts to ensure that you can access the Site in accordance with these Terms of Use. However, we may suspend your use of the Site for maintenance and we will use reasonable efforts to notify you. 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 carry out urgent transactions with your Account.




EXTERNAL WEBSITES



Three True Trillions is not responsible for any external or third party websites that you may access through the Site. From time to time, the Three True Trillions 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 on them. 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, failures, promotions, products, opinions, advice, statements, prices, activities and advertisements, services or actions, and/or damages, losses, failures or problems caused by, related to or arising from those sites. You shall bear 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 your use is free of such items 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 connection with the Services described in these Terms of Use. We may provide information about the price, range and volatility of cryptocurrencies that are available on our platform and events that have affected the price of such cryptocurrencies, but this should not be considered or construed as investment advice. Any decision to buy or sell Bitcoins is solely your decision and we will not be liable for any loss suffered.

 


FINANCIAL REGULATION



Three True Trillions Service and business model is to facilitate, through its Payment Services license, the buying and selling of cryptocurrencies. This specific service is currently regulated by Estonian law, by virtue of the Law of November 2017.

 


EMAIL



Unencrypted email messages sent over the Internet are not secure and Three True Trillions is not responsible for any damages caused by sending email messages in this manner. We suggest sending emails in encrypted formats; you can send us emails encrypted with PGP. 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 what 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, compelled by subpoena, court order, or other legal process.
We believe disclosure is necessary to prevent financial loss or harm.
Disclosure is necessary to report suspected illegal activity.
The disclosure is necessary to investigate violations of our Terms of Use or Privacy Policy.
For more information on how we process your Personal Data, please 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 courts of Estonia.

 


Limitation of liability

 

To the extent permitted by law, Three True Trillions will not be liable for any damages, lost profits, lost revenue, lost business, lost opportunity, lost data, indirect or consequential loss, unless the loss is sustained by negligence or intentional 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 its negligence, breach of the terms implied by law, or any other liability that may not be limited or excluded by law. . Although Three True Trillions 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 notice, and accordingly, you should verify all information with independent sources before relying on it for any decision or action. You remain fully responsible for your decisions and actions.



To the fullest extent permitted by applicable law, you agree to indemnify Three True Trillions and its partners against any action, liability, cost, claim, loss, damage, proceeding or expense suffered or incurred whether arising directly or indirectly from the use of the Three True Trillions Sites. , 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, an act of God, change of law, or change in sanctions policy, we will not be responsible for the Services provided under this agreement during the period of time coinciding with the event.




Modification of Terms



Three True Trillions reserves the right to change, add, or remove portions of these Terms of Use at any time and in its sole discretion. You will be notified in advance of any changes through your Account. Upon such notification, it is your responsibility to review the modified Terms of Use. Your continued use of the Site following 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:


Bill. The contractual agreement in which a Three True Trillions Member has agreed to our Terms of Use and Privacy Policy, and received approval to use the Three True Trillions Services, including the purchase and sale of Cryptocurrencies, and to conduct Associated Transactions.

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

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

Seller(s). Members who submit an order to sell Bitcoins through the Service.

Commission . Refers to the fee payable to Three True Trillions on each transaction, such as a purchase transaction or a sale transaction.

Members) . It refers to buyers and sellers, as well as any account holder.

Personal information . 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 Three True Trillions offer and the member agrees 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 Three Trillions bank account.

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



Transaction. Includes the following:
Purchase transaction. The agreement between the Buyer and Three True Trillions to exchange fiat currency through the Cryptocurrency Service at a proportionate rate.

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

Transaction price. The total price and additional fee paid by the Buyer or Seller for each Transaction made through the Service. The current price of the Three True Trillions service and the additional fee for each transaction reference here.





AML POLICY


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


Three True Trillions is a privately owned limited liability company incorporated under the laws of Poland with registration number: RDWW-461 and registered address: 86 Hoza street unit 210 Warsaw, Zip Code 00-682, Warsaw, Poland. may be referred to as "Three True Trillions", "We", "Our", "Company" and "Us" and includes its 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 uncompromising and reputable provision of services, 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 purpose of money laundering or terrorist financing , and amend Directives 2009/138/EC and 2013/36/EU;

The Estonian Law on Money Laundering and Terrorist Financing and other legal guidelines given by the Polish Minister of Finance; Y

Any other applicable law in force in any territory that Three True Trillions may be operating.


Three True Trillions is always set to follow the strictest rules and industry standards in any country where it may have operations in order to prevent any kind of illegal and criminal activities and any possible involvement of Three True Trillions in such.


The anti-money laundering and anti-terrorist financing policy, which is part of the Three True Trillions Terms and Conditions, requires mandatory compliance by the User. Users are required to read, review, understand, and then agree to the terms herein before using or taking advantage of any of the Three True Trillions Services.


Terms not defined in this document shall 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 currently in force within the territory of any country in which Three True Trillions may be operating.


"Ultimate 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 totally or partially owns entity subject to check.

The natural person is entitled to more than 25% (twenty-five percent) of the profits.

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)" means:

National identification cards and passports and any other identification documents issued by the government;

Documents that identify the registered address of a natural or legal person, such as, but not limited to, Bank Statement and Utility Bill; either

Any other document that may be notified by Zesion OÜ from time to time.


"Politically Exposed Person" means any natural person who is themselves or is a family member or close associate of a natural person who is:


Head of State, head of government, minister and deputy 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 further 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 high-ranking officer in the armed forces.

Member of the administrative, management or supervisory bodies of state-owned companies.

Director, deputy director or member of the board or equivalent function of an international organization.


 "Sanctions 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, EU, UN, HMT.


"Suspicious Transactions" means the following activities, whether attempted or executed:


Terrorist Financing: Transactions that, to a person acting in good faith, appear to be funds raised for use, in whole or in part, by any terrorist or related organization, or to carry out any of the activities related to terrorism or terrorist acts.

Unusually Complex: Transactions that appear to a person acting in good faith to have been structured in an unusual or unwarranted manner.

Malafide Purpose: Transactions that appear to a person acting in good faith not to have been entered into for bona fide purposes or to have no sound economic basis.

Money Laundering: Transactions that, to a person acting in good faith, appear to "clean" 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



Three True Trillions appoints and duly authorizes the Money Laundering Reporting Officer (MLRO) to oversee compliance of Three True Trillions systems and controls with the current AML/CTF Policy, relevant legislation, regulations, rules and industry orientation. 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, financing of terrorism 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). Three True Trillions implements CDD in the form of requiring any natural person, who wishes to transact with fiat money on the Three True Trillions platform, and any company/organization to verify, respectively, their identity and the identity of the ultimate beneficial owners of your company.

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

Each client, who has passed the verification procedure, can carry out transactions with fiat money on the Three True Trillions platform only under the premise that he uses bank cards and accounts of bank or electronic money services in his own name.


Identification of natural persons


Each natural person wishing to transact fiat money on the Three True Trillions platform is required to identify themselves by providing:

Full name.

Date of Birth.

Phone number.

Residence address.

Government-issued identification document, such as an international ID card and passport, bearing a photograph, date of birth, and personal identification number issued by your government.

Proof of residence of the resident, such as a utility bill or bank statement that is not more than 3 months old.

A recent photograph of themselves with their photo ID and their application.


For individuals with nationality or residence in a high-risk third country or, if deemed appropriate, Three True Trillions may also:


Require information about the source of funds and the source of wealth of the User;

Request information about the reasons for the planned or carried out transactions;

Carry out enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and by selecting patterns of transactions that need 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

Registered number in any national registry

Legal form according to the law of the place of registration

Corporate headquarters address and management address

Certificate of incorporation

Articles / Memorandum of Incorporation

Bank statement not older than 3 months indicating the address of the company.



Additional Verification Measures


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


Obtain additional information about the User, the beneficial owner(s) and any other person who may have access to the corporate account in Three True Trillions, such as data on Politically Exposed Persons.

Obtain additional information about 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 about the reasons for the planned or carried out transactions;

Obtain senior management approval to establish or continue the business relationship.

Carry out enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.



People with access to the corporate account at Three True Trillions


Three True Trillions also requires a letter signed by the board of directors, CEO, managing director, or owner of significant control stating who has 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 Three True Trillions accounts they may have.

A scanned copy of your government-issued ID card or passport.



Ultimate Beneficial Owners



While we at Three True Trillions are against blanket rejections, it is of the utmost importance to find out who has ultimate effective control over the legal entity with which we are related. As a result, we require user-provided information on all Beneficial owners about their:

Full name.

Nationality (s) maintained (s).

Identification document with photo.

Proof of address.


Taking the risk-based approach, we are especially vigilant and therefore may employ additional measures, such as the use of third-party detection providers in the event 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, Three True Trillions also requires:

Name;

Registered number in any national registry;

Legal form according to the law of the place of registration

Corporate headquarters address and management address;

The required details of UBOs as stated above, in relation to corporate "representatives".



Review of sanctions lists


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



Examination of politically exposed persons



To identify PEPs among its Users, Three True Trillions not only relies on user-provided statements, but also screens all individual account holders, all UBOs of corporate account holders, as well as any person who has access to a corporate account against several national users. and international PEP lists.


Restrictions and denial of service



Based on the information provided, Three True Trillions reserves the right to determine, in its sole discretion, the appropriate level of verification for any user, as well as the right to demote or ban users without notice. If Three True Trillions finds that any User information, obtained in accordance with the described procedure, is inadequate, 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 brought to the attention of Three True Trillions, that a particular user or account is being held under a fictitious name, Three True Trillions has the full right and authority to terminate and close such account with immediate effect and without prior notice to the Username .

Three True Trillions also reserves the right to verify user identity on an ongoing basis, particularly in cases of unusual and suspicious activity or if Three True Trillions doubts the adequacy or veracity of previously obtained customer identification data. Three True Trillions has more right to request updated documents from users, even though they have already passed identity verification in the past.

Three True Trillions may 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 Three True Trillions is not responsible for any losses.

Three True Trillions reserves the right to terminate the User Account, restrict and/or prevent access to its online platform, or report the activities of any User to the appropriate authorities if there is suspicion of illegal activity.

Once the identity of the User has been verified, Three True Trillions can withdraw from possible legal responsibility in a situation where its Services are used to carry out illegal activities.
Sensitive Personal Information



Sensitive personal information is securely collected, shared and stored in accordance with the Three True Trillions Privacy Policy.




Monitoring, analysis and reporting of user activity.



In addition to verifying user identity, Three True Trillions also reserves the right to monitor and analyze user activity as part of the AML/CTF suite of tools. Three True Trillions 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 watch lists.

Opening of cases for investigation where necessary.

Request additional information, when deemed appropriate.

Sending internal communications.

Complete legal reports, if applicable.

Case and document management.



Three True Trillions 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 the event of suspected illegal activities, as well as to suspend or terminate the transaction. provision of services to suspicious Users. The list is not exhaustive and Three True Trillions will take steps to prevent money laundering, terrorist financing or any other criminal activity.

 


Risk-based approach



Three True Trillions is dedicated to following the highest industry standards and therefore takes a risk-based approach to committing its resources in the most efficient manner; meaning that the biggest risks will get the most attention. As a result, Three True Trillions 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 business/vocational activities.

Guidance notes distributed by various governmental and intergovernmental organizations.



Business relationships with corporate account holders, who have a complex ownership structure that prevents the identification of final beneficial owners, and natural persons with nationality or residence in high-risk third countries are, for example, a priority for the Three True Trillions compliance office.


Three True Trillions keeps risk categorization confidential and may change any User's categorization at any time based on various factors. While Users have no right to request disclosure in any way, Three True Trillions may disclose User risk categorization data to the appropriate compliance authority if it finds that a particular User has executed or is likely to execute a Transaction. suspicious.

 



Modifications



This AML/CTF Policy may be reviewed and revised from time to time. The revised draft will be uploaded to https://zesions.es and will reflect the date the terms were modified. The User is required to periodically visit the website and review the terms and any changes thereto. The continued use by the User constitutes an agreement with any modification of the policy.

 


Contact



If you have any questions about these Terms of Use, your rights and obligations under these Terms of Use of the Site, our anti-money laundering, anti-terrorist financing policy, and the Service. Contact us by email: [email protected]