Coinsellor Privacy Protection Policy

Last updated: Dec 12. 2023


Coinsellor is committed to safeguarding your privacy and personal data, adhering to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as "the Regulation," along with other legal requirements of the European Union and the Republic of Poland, recommendations of the financial sector, and guidelines of good practice. This Privacy Protection Policy outlines our practices regarding the processing of your personal data, which includes any information directly or indirectly related to you, respecting your right to privacy and its protection.


  • Data subject: A natural person whose personal data is processed.
  • Controller: a natural or legal person, public institution, agency, or other body that alone or jointly with others determines the purposes and means of personal data processing; Coinsellor, with legal name Coinsellor sp. z o.o., registered under the address ul. Stefana Batorego 18/108, 02-591 Warsaw, Poland, with NIP (Tax Identification Number) 7011176752 and KRS (National Court Register) 0001071610; email address:
  • Personal data: Any information relevant to the Data Subject, such as name, surname, personal identification number, address, telephone number, email address, video surveillance, economic and other actions specific to the Data Subject.
  • Personal data: Any information relevant to the Data Subject, such as name, surname, personal identification number, address, telephone number, email address, video surveillance, economic and other actions specific to the Data Subject.
  • Terms: These Privacy Protection Policy.
  • Consent: Freely and knowingly provided consent by the Data Subject for the processing of Personal Data.
  • Profiling: The use of Personal Data to assess the Data Subject’s personal conduct, predicting conduct related to economic situation, preferences, interests, reliability, behavior, and location.
  • Data State Inspectorate: An institution supervising the application of the Regulation in the Republic of Poland.
  • Third party: A natural or legal person authorized to process Personal Data under the direct authority of the Controller or Processor.


Coinsellor processes the personal data of the Data Subject in accordance with the Regulation, following these principles:

  • Legality, integrity, and transparency: Personal data is processed lawfully, in good faith, and transparently to the Data Subject.
  • Purpose limitation: Personal data is collected for specified, explicit, and legitimate purposes and not processed further in a way incompatible with those purposes.
  • Data minimization: Personal data is adequate, relevant, and includes only the necessary information for processing purposes.
  • Accuracy: Personal data is accurate and kept up to date, with steps taken to correct inaccurate data promptly.
  • Restriction on storage: Personal data is stored for no longer than necessary for the processing purposes.
  • Integrity and Confidentiality: Personal data is processed to ensure adequate security, protection against unauthorized processing, and accidental loss.


In accordance with the purposes specified in the Terms and to the extent necessary, Coinsellor processes the following Personal Data:

  • Identification data: Name, surname, personal identification number, date of birth, information specified in the personal identification document (passport or identity card).
  • Contact information: Address, telephone number, email address.
  • Information related to tax residence: Country of birth, residence, taxpayer number, citizenship, place of tax residence.
  • Communication information: Data from letters, emails, and telephone calls.
  • Investment Portfolio and Virtual Currency Wallet information: Cryptocurrency balance, cryptographic asset flow, incoming and outgoing cryptographic transfers, commissions, and other Virtual Currency fees.
  • Financial data: Origin of funds and assets, country of registered tax residence, accounts, payment documents, financial liabilities, payment discipline, types, and value of assets.
  • Data related to knowledge in finances: Education, knowledge, and experience in the field of investment.
  • Transaction data: Data related to services received, requests, complaints, agreement performance, and similar data.
  • Data related to economic activity: Information about job, employment, economic or commercial activity, business partners, income stability, and other sources of profit.
  • Audio and video data: Visual surveillance, video and audio recordings when visiting customer service points or contacting staff.


Coinsellor processes your Personal Data on the following grounds:

  • For concluding and performing an agreement to provide relevant services.
  • To fulfill obligations specified by law.
  • Based on your Consent.
  • To pursue legitimate interests of the Controller or a third party, ensuring proportionality to your right to privacy.

We will continue to process your Personal Data as long as you receive our services. Depending on the services provided, this basis may be combined with other grounds for processing Personal Data.


Main goals include:

  • Provision of contract services.
  • Identification of risks, assessment, documentation, and provision in transactions with customers.
  • Protection of clients’ Cryptographic Assets.
  • Performance of economic and administrative activities.

Sub-purposes include:

  • Identification by processing name, surname, personal identification number, date of birth, and personal identification document data.
  • Provision of services, evaluation of applications, and fulfillment of contractual obligations.
  • Assessment of product suitability, advising on digital payment issues, and collection of Personal Data related to finance.
  • Video surveillance for safety, prevention, and detection of violations of the law.
  • Improvement of service quality, management of customer relationships, and handling inquiries and complaints.
  • Marketing activities, subject to your Consent.
  • Compliance with anti-money laundering legislation and customer research.
  • Compliance with legal obligations, reporting to public authorities, and solvency, accounting, and auditing requirements.


  • When provided directly by you through applications, emails, in-person visits, and phone calls.
  • When you use our services, including visiting our office and website.
  • When provided by third parties, such as cooperation partners, maintainers of databases, state institutions, and law enforcement institutions.


With the purpose of ensuring safety, Coinsellor employs camera surveillance at its premises. The processed Personal Data includes images and videos of clients inside and outside the office premises, along with sound recordings within the office. The legal basis for camera surveillance is the legitimate interest of ensuring the security of employees, clients, and assets.

Recordings are retained for a maximum of 60 days from the recording date. Access to Personal Data is restricted to authorized employees for security purposes.


We transfer your Personal Data to:

  • Service intermediaries and third parties involved in transaction execution.
  • Authorities such as tax authorities, supervisory authorities, and law enforcement agencies.
  • State institutions, maintainers of databases, investigative institutions, courts, bailiffs, and notaries.

Access to your Personal Data is restricted to authorized employees and partners who process it in line with the specified purposes and legal requirements.


Coinsellor may make automated individual decisions and perform Profiling when establishing or providing services to you. Profiling aims to evaluate and forecast personal wishes, interests, reliability, and behavior for marketing and service suitability assessment. You have the right to object to automated decision-making, except when necessary for the agreement or based on your Consent.


Your Personal Data is stored within the EU / EEA territory.


Storage duration is based on the purposes of processing, legal obligations, and protection of interests. The criteria include the need for service performance, legal requirements, protection of interests, and evidence of lawful processing. Your Personal Data is deleted or anonymized when one or more criteria are met.


As part of privacy laws compliance, you have the right to:

  • Revoke Consent.
  • Access your Personal Data.
  • Correct your Personal Data.
  • Delete your Personal Data.
  • Restrict processing of your Personal Data.
  • Transfer your Personal Data.
  • Object to processing based on legitimate interests.
  • Abandon automated decision-making and Profiling.


Submit your request to, signed with a secure electronic signature. We will respond within one month, with a possible two-month extension for extensive requests. The response will be provided by encrypted email. Processing of your request is free unless it is recurring, manifestly unfounded, or excessive.


Coinsellor applies organizational, physical, and technological measures to protect Personal Data according to risk. Employees processing Personal Data receive appropriate training. Processors adhering to our instructions and applicable laws implement security measures.


Terms may be unilaterally changed or supplemented in connection with regulatory amendments or operational changes. Changes not related to regulatory requirements will be notified 60 days in advance.For more information on changes, visit our website

Coinsellor Anti-Money Laundering and Know Your Customer Policy

Last updated: Dec 12. 2023


The Coinsellor Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) aim to prevent and mitigate the risks of Coinsellor being involved in illegal activities. International and local regulations require Coinsellor to establish effective internal procedures and mechanisms to deter money laundering, terrorist financing, and other illicit activities.For Law Enforcement requests, please direct your official document to our compliance team here.

AML/KYC Policy covers the following matters:

  • Verification Procedures
  • Compliance Officer
  • Monitoring Transactions
  • Risk Assessment

1. Verification Procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Coinsellor establishes its verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).

Coinsellor’s identity verification procedure requires the User to provide reliable, independent source documents, data, or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, Coinsellor reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

Coinsellor will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used, and Coinsellor reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Coinsellor reserves the right to verify User’s identity on an ongoing basis, especially when their identification information has changed, or their activity seems to be suspicious (unusual for the particular User). In addition, Coinsellor reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared, and protected strictly in accordance with Coinsellor’s Privacy Policy and related regulations.

Once the User’s identity has been verified, Coinsellor can remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

Coinsellor is prohibited from transacting with individuals, companies, and countries that are on prescribed sanctions lists. Coinsellor will therefore screen against United Nations, European Union, UK Treasury, and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by Coinsellor, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Coinsellor’s anti-money laundering and counter-terrorist financing, including but not limited to:

  • Collecting Users’ identification information;
  • Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations;
  • Monitoring transactions and investigating any significant deviations from normal activity;
  • Implementing a records management system for appropriate storage and retrieval of documents, files, forms, and logs;
  • Updating risk assessment regularly;
  • Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing, and other illegal activity.

3. Monitoring Transactions

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Coinsellor relies on data analysis as a risk-assessment and suspicion detection tool. Coinsellor performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

  • Daily check of Users against recognized “black lists” (e.g., OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications, and filling out statutory reports, if applicable;
  • Case and document management.

With regard to the AML/KYC Policy, Coinsellor will monitor all transactions and it reserves the right to:

  • Ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
  • Request the User to provide any additional information and documents in case of suspicious transactions;
  • Suspend or terminate User’s Account when Coinsellor has a reasonable suspicion that such User engaged in illegal activity.

The above list is not exhaustive, and the Compliance Officer will monitor Users’ transactions on a day-to-day basis to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

4. Risk Assessment

Coinsellor, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Coinsellor ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

Coinsellor User Agreement

Last updated: Dec 12. 2023

1. Scope of the Agreement

1.1. This User Agreement ("Agreement") is a legally binding contract between the user (referred to as “User,” “You”/”you”) and Coinsellor sp. z o.o. (referred to as "Coinsellor," “We”/”we”), governing the use of the Coinsellor crypto exchange service (the "Service"). This Agreement applies to all services provided by Coinsellor, whether accessed directly through Coinsellor's platform, Binance P2P platform, or via direct contact with Coinsellor. It constitutes an integral part of transactions between the User and Coinsellor.

1.2. Coinsellor operates a crypto exchange platform that enables Users to engage in one-off transactions to exchange Fiat currency for Virtual Assets. The Service includes the initiation of the transfer of Virtual Assets to the User's Wallet, confirmed by the User. The term "Service" encompasses all these functionalities.

1.3. Users acknowledge and agree to access and use the Coinsellor Service at their own risk. Prior to using the Service, Users must carefully consider whether purchasing or holding Virtual Assets is suitable for them, taking into account their financial situation and knowledge. Coinsellor does not provide financial advice, and Users are encouraged to consult with professional advisors if needed.

1.4. Users may submit orders to Coinsellor via the Coinsellor platform or third-party widgets. Coinsellor is not responsible for any third-party platforms or applications used to access the Service.

1.5. By submitting an order, applying for, and using the Service, You agree to the terms in force at that time. It is recommended to carefully read these terms each time You use the Service, as they may be updated, with changes effective immediately upon posting.

1.6. For information on how Coinsellor processes Your personal data, please visit our website and read our Privacy Notice.

2. Definitions

  • "User Order/Order" means a request by the User for the Service (exchange of Fiat currency for Virtual Assets) submitted to Coinsellor and accepted for processing.
  • "Fiat" refers to national currency such as USD, EUR, etc., designated as legal tender.
  • "Payment Method" means a method of enabling payments by Users, such as payment cards, wire transfers, or e-wallets.
  • "Virtual Asset(s)" means a digital representation of value that can be digitally traded or transferred, utilizing encryption techniques to regulate generation and verify asset transfer.
  • "Wallet/Wallet Address" means an on-blockchain virtual address holding Virtual Assets.
  • "Widget" means Coinsellor's widget and software through which Users can access Coinsellor Services.
  • "Coinsellor" refers to Coinsellor sp. z o.o., a company registered in Poland under the legal address ul. Stefana Batorego 18/108, 02-591 Warsaw, tax ID (NIP) of 7011176752 and registration number (KRS) 0001071610.

3. User Eligibility Requirements and Representations

3.1. To use Coinsellor Service, You must:

  • Be 18 or over with sufficient capacity for legally binding contracts.
  • Agree to these terms and use the Service accordingly.
  • Comply with all applicable laws and regulations.
  • Not engage in illegal practices violating laws and regulations, including anti-corruption, AML/CTF, and assets hiding prevention.
  • Not be sanctioned by the US, UK, or EU.
  • Not have citizenship or legal residence in any country on the FATF black list or under economic sanctions.
  • Not have been previously suspended from using Coinsellor Service.

3.2. By using Coinsellor Service, You agree and represent that:

  • You will use the Service only for Yourself, not on behalf of any third party.
  • You will provide information for identity verification as required by Coinsellor.

3.3. You authorize Coinsellor to make necessary inquiries to verify Your identity, protect against fraud, and take actions deemed necessary.

4. Terms of Coinsellor Service

4.1. Coinsellor does not open accounts or provide crypto-wallet services to Users. Users acknowledge that Coinsellor is not responsible for safeguarding Virtual Assets, private keys, or security information.

4.2. When using Coinsellor Service, You are buying Virtual Assets directly from Coinsellor, not acting as an intermediary or marketplace between other buyers and sellers.

4.3. Coinsellor has no control over transaction times for Virtual Assets, and Users accept the risk of delayed transfers, with Coinsellor not held responsible for resulting losses.

4.4. Coinsellor uses Virtual Assets exchanges and payment service providers to initiate transfers, not responsible for actions, delays, or errors made by such third-party providers.

4.5. Users are responsible for determining applicable laws and tax obligations related to transactions, with Coinsellor not providing tax advice.

4.6. Coinsellor may impose limits on the minimum or maximum volume of orders at its discretion.

5. User Fees

5.1. Users agree to pay User Fees for the usage of Services, including:

  • Network Fee, automatically generated by blockchain transactions.
  • Processing Fee, due in Fiat.
  • Any other fees applicable at the time of User Order.

5.2. User Fees are presented before processing User Orders.

6. Responsibilities of User

6.1. User orders may be submitted via the Coinsellor platform or third-party widgets under specified conditions.

6.2. By submitting an order, Users acknowledge possible changes in fees and Virtual Asset amounts due to the nature of Virtual Assets and third-party involvement.

6.3. Users must provide accurate Wallet Address information, verify its correctness, and accept responsibility for any inaccuracies.

6.4. Users indemnify Coinsellor against any claims, losses, damages, or expenses arising from User's use of the Service or breach of these terms.

7. Cancellations and Refunds

7.1. User-submitted Orders cannot be cancelled or refunded. All Orders are final.

7.2. Coinsellor reserves the right to cancel Orders without advance notice.

6.3. Users must provide accurate Wallet Address information, verify its correctness, and accept responsibility for any inaccuracies.

7.3. Coinsellor is not responsible for inaccuracies in User-provided data and will not issue refunds.

8. Termination and Suspension of Service

8.1. These terms apply until terminated by Coinsellor, given the nature of one-off transactions.

8.2. Coinsellor may suspend or terminate access to the Service immediately if:

  • User no longer meets eligibility requirements.
  • User breaches these terms.
  • User fails to pay any Fees.
  • Instructed by a competent authority.
  • For other justified reasons.
  • User fails to pay any Fees.

8.3. Provisions surviving termination include indemnity, taxes, warranty disclaimers, IP, and governing law.

9. Intellectual Property

Users acknowledge Coinsellor as the sole owner of the Widget, website, Service, and related intellectual property rights. Users may not reproduce or store any part of Coinsellor's Widget or Services without prior written permission.

10. Warranty Disclaimer

The Coinsellor website, Widget, and Services are provided "as is" and "as available." Coinsellor disclaims all warranties, representations, and conditions related to these terms or the use of its website, Widget, and Services.

11. Liability

Coinsellor is not liable for:

  • Any loss/damages, including indirect or consequential losses/damages.
  • Loss of data, funds, Virtual Assets, or investment opportunities.
  • Loss resulting from third-party actions or circumstances beyond Coinsellor's control, which includes anything any third party does or fails to do, including third party exchanges, payment providers, token issuers and/or wallet providers, delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond Our reasonable control and shall not affect the validity and enforceability of any remaining provisions.

12. Complaints Resolution

In case of an infringement, Users can send complaints to within three months of the relevant event. Coinsellor will examine complaints and respond within 14 days. If Users disagree with the resolution, they may contact the State Consumer Rights Protection Authority of the Poland.

13. Applicable Legislation and Dispute Resolution

The laws of Poland apply to these terms. Disputes between Coinsellor and Users will be resolved in the Warsaw District Court.

14. Miscellaneous

14.1. Singular/plural, headings, and severability clauses apply.

14.2. These terms constitute the entire agreement between the parties and supersede any prior agreements.

14.3. Coinsellor may assign its rights and obligations without user consent.

14.4. Failure to exercise rights under these terms does not constitute waiver.