1.  Company Policy

It is the policy of the ZenbarCoin, ("Company") to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements of prevailing anti-money laundering statutes and implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

 

2.  AML Compliance Person Designation and Duties

The Company has designated Ian Brodie as its Anti-Money Laundering Policy Compliance Party (AML Compliance Party), with full responsibility for the Company's AML policy. The management of Ian Brodie has a working knowledge of anti-money laundering statutes and its implementing regulations and is qualified by experience, knowledge, and training. The duties of the AML Compliance Party will include monitoring the Company's compliance with AML obligations, overseeing communication and training for employees. The AML Compliance Party will also ensure that the Company keeps and maintains all of the required AML records, if any, The AML Compliance Party is vested with full responsibility and authority to enforce the Company's AML policy.

 

3.  Giving AML Information to Law Enforcement Agencies and Other Financial Institutions

We will respond to all law enforcement requests concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity or organization named in the request. Our policy is to respond to such inquiries within 14 days, unless otherwise specified. If the AML Compliance Party searches our records and does not find a matching account or transaction, then the AML Compliance Party will not reply to the request. We will maintain documentation that we have performed the required search.

We will respond to the request of law enforcement when we find a matching account or transaction. We will disclose to the party or parties of the subject account or transaction that law enforcement has requested or obtained information from us, except to the extent necessary to comply with the information request. The AML Compliance Party will review, maintain, and implement procedures to protect the security and confidentiality of requests regarding the protection of customers' nonpublic information. We will direct any responses we receive to the requesting law enforcement agency as designated in the request. Unless otherwise stated in the law enforcement request, we will not be required eat the information request as continuing in nature, and we will not be required to treat the periodic required as a government provided list of suspected terrorists for purposes of the customer identification and verification requirements.

We understand that the receipt of a grand jury subpoena concerning a customer does not in itself require that we file a response. When we receive a grand jury subpoena, we will conduct a risk assessment of the customer subject to the subpoena as well as review the customer's account activity. If we uncover suspicious activity during our risk assessment and review, we will elevate that customer's risk assessment and may response to the subpoena. We understand that none of our officers, employees or agents may directly or indirectly disclose to the person who is the subject of the subpoena its existence, its contents, or the information we used to respond to it. To maintain the confidentiality of any grand jury subpoena we receive, we will process and maintain the subpoena by the AML Compliance Party.

We will share information with other financial institutions regarding individuals, entities, organizations, and countries for purposes of identifying and, where appropriate, reporting activities that we suspect may involve possible terrorist activity or money laundering. We understand that this requirement applies even to financial institutions with which we are affiliated, and that we will obtain the requisite notices from affiliates and follow all required procedures.

We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, for example, by segregating it from the Company's other books and records.

We also will employ procedures to ensure that any information received from another financial institution shall not be used for any purpose other than:

 

• identifying and, where appropriate, reporting on money laundering or terrorist activities;
• determining whether to establish or maintain an account, or to engage in a transaction; or
• assisting the financial institution in complying with performing such activities.

 

4.  Checking the U.S. Office of Foreign Assets Control Listings

Before opening an account, and on an ongoing basis, the AML Compliance Party will check to ensure that a customer does not appear on the Specially Designated Nationals and Blocked Persons List ("SDN") or is not engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC. Because the SDN list and listings of economic sanctions and embargoes are updated frequently, we will consult them on a regular basis and subscribe to receive any available updates when they occur. With respect to the SDN list, we may also access that list through various software policys to ensure speed and accuracy. See alsoFINRA's OFAC Search Tool that screens names against the SDN list. AML Compliance Party will also review existing accounts against the SDN list and listings of current sanctions and embargoes when they are updated and he will document the review.

If we determine that a customer is on the SDN list or is engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC, we will reject the transaction and/or block the customer's assets and file some blocked assets and/or rejected transaction form with OFAC within 10 days. We will also call the OFAC Hotline at (800) 540-6322 immediately.

 

5.  Customer Identification Policy

We do not open or maintain "customer accounts” within the meaning of 31 CFR 103.122(a)(1)(i), in that we do not establish formal relationships with "customers” for the purpose of effecting transactions in securities. If in the future the Company elects to open customer accounts or to establish formal relationships with customers for the purpose of

effecting transactions in securities, we will first establish, document, and ensure the implementation of appropriate CIP procedures.

We will collect information to determine whether any entity opening an account would be excluded as a "customer," pursuant to the exceptions outlined in U.S. 31 CFR 103.122(a)(4)(ii) (e.g., documentation of a company's listing information, licensing, or registration of a financial institution in the U.S, and status or verification of the authenticity of a government agency or department). 

a.  Required Customer Information

Prior to opening an account, should it become applicable, AML Compliance Party will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account:

(1) the name;

(2) date of birth (for an individual);

(3) an address, which will be a residential or business street address (for an

individual), an Army Post Office (APO) or Fleet Post Office (FPO) box number, or residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address), or a principal place of business, local office, or other physical location (for a person other than an individual); and

(4) an identification number, which will be a taxpayer identification number (for U.S.

persons), or one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard (for non-U.S. persons).

When opening an account for a foreign business or enterprise that does not have an identification number, we will request alternative government-issued documentation certifying the existence of the business or enterprise.

b.  Customers Who Refuse to Provide Information

If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our Company will not open a new account and, after considering the risks involved, consider closing any existing account.

c.  Verifying Information

Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers. AML Compliance Party will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).

We will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the customer's name, street address, zip code, telephone number (if provided), date of birth and tax identification number, allow us to determine that we have a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).

Appropriate documents for verifying the identity of customers include the following:

• For an individual, an unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver's license or passport; and
• For a person other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument.

We understand that we are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer's identity. If, however, we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer's true identity.

We will use the following non-documentary methods of verifying identity:

• Independently verifying the customer's identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database, or other source;
• Checking references with other financial institutions; or
• Obtaining a financial statement.

We will use non-documentary methods of verification when:

(1) the customer is unable to present an unexpired government-issued identification document with a photograph or other similar safeguard;

(2) the Company is unfamiliar with the documents the customer presents for identification verification;

(3) the customer and Company do not have face-to-face contact; and

(4) there are other circumstances that increase the risk that the Company will be unable to verify the true identity of the customer through documentary means.

We will verify the information within a reasonable time before or after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions or dollar amount of transactions. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we may, after internal consultation with the Company's AML Compliance Party, elect to not open such account.

We recognize that the risk that we may not know the customer's true identity may be heightened for certain types of accounts, such as an account opened in the corporation, partnership or trust that is created or conducts substantial business in a jurisdiction that has been designated by the United States as a primary money laundering jurisdiction, a terrorist concern, or has been designated as a non-cooperative country or territory. We will identify customers that pose a heightened risk of not being properly identified. We will also take the following additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient.

d.  Lack of Verification

When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) not open an account; (2) impose terms under which a customer may conduct transactions while we attempt to verify the customer's identity; or (3) close an account after attempts to verify customer's identity fail

e.  Recordkeeping

We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer's identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer's identity for five years after the record is made.

f.   Comparison with Government-Provided Lists of Terrorists

At such time as we receive notice that a federal government agency has issued a list of known or suspected terrorists and identified the list as a list for CIP purposes, we will, within a reasonable period of time after an account is opened (or earlier, if required by another federal law or regulation or federal directive issued in connection with an applicable list), determine whether a customer appears on any such list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by Treasury in consultation with the federal functional regulators. We will follow all federal directives issued in connection with such lists.

We will continue to comply separately with OFAC rules prohibiting transactions with

 certain foreign countries or their nationals.

g.  Notice to Customers

We will provide notice to customers that the Company is requesting information from them to verify their identities, where required by law

Important Information About Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

 

6.  General Customer Due Diligence

It is important to our AML policy that we obtain sufficient information about each customer to allow us to evaluate the risk presented by that customer and to detect and report suspicious activity. When we open an account for a customer, the due diligence we perform may be in addition to customer information obtained for purposes of our CIP.

We will take steps to obtain sufficient customer information to comply with our suspicious activity reporting requirements. Such information should include

 

• the customer's business;
• the customer's anticipated account activity (both volume and type);
• the source of the customer's funds.

For accounts that we have deemed to be higher risk, we will obtain the following information:

 

• the purpose of the account;
• the source of funds and wealth;
• the beneficial owners of the accounts;
• the customer's (or beneficial owner's) occupation or type of business; financial statements;
• banking references;
• domicile (where the customer's business is organized);
• description of customer's primary trade area and whether international transactions are expected to be routine;
• description of the business operations and anticipated volume of trading; explanations for any changes in account activity.

 

7.   Due Diligence and Enhanced Due Diligence Requirements for Private Banking Accounts/Senior Foreign Political Figures

We will review our accounts to determine whether we offer any private banking accounts and we will conduct due diligence on such accounts. This due diligence will include, at least, (1) ascertaining the identity of all nominal holders and holders of any beneficial ownership interest in the account (including information on those holders' lines of business and sources of wealth); (2) ascertaining the source of funds deposited into the account; (3) ascertaining whether any such holder may be a senior foreign political figure; and (4) detecting and reporting, in accordance with applicable laws and regulations, any known or suspected money laundering, or use of the proceeds of foreign corruption.

We will review public information, including information available in Internet databases, to determine whether any private banking account holders are senior foreign political figures. If we discover information indicating that a particular private banking account holder may be a senior foreign political figure, and upon taking additional reasonable steps to confirm this information, we determine that the individual is, in fact, a senior foreign political figure, we will conduct additional enhanced due diligence to detect report transactions that may involve money laundering or the proceeds of foreign corruption.

In so doing, we will consider the risks that the funds in the account may be the proceeds of foreign corruption by determining the purpose and use of the private banking account, location of the account holder(s), source of funds in the account, type of transactions conducted through the account and jurisdictions involved in such transactions. The degree of scrutiny we will apply will depend on various risk factors, including, but not limited to, whether the jurisdiction the senior foreign political figure is from is one in which current or former political figures have been implicated in corruption and the length of time that a former political figure was in office. Our enhanced due diligence might include, depending on the risk factors, probing the account holder's employment history, scrutinizing the account holder's source(s) of funds, and monitoring transactions to the extent necessary to detect and report proceeds of foreign corruption, and reviewing monies coming from government, government controlled or government enterprise accounts (beyond salary amounts).

If we do not find information indicating that a private banking account holder is a senior foreign political figure, and the account holder states that he or she is not a senior foreign political figure, then we may make an assessment if a higher risk for money laundering, nevertheless, exists independent of the classification. If a higher risk is apparent, we will consider additional due diligence measures.

In either case, if due diligence (or the required enhanced due diligence, if the account holder is a senior foreign political figure) cannot be performed adequately, we will, after consultation with the Company's AML Compliance Party and as appropriate, not open the account, suspend the transaction activity, or close the account.

 

8.  Monitoring Accounts for Suspicious Activity

We will monitor account activity for unusual size, volume, pattern, or type of transactions, taking into account risk factors and red flags that are appropriate to our business Monitoring will be conducted through the automated monitoring. The AML Compliance Party or his or her designee will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities.

a.  Emergency Notification to Law Enforcement by Telephone

In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority.

b.  Red Flags

Red flags that signal possible money laundering or terrorist financing include, but are not limited to:

Customers - Insufficient or Suspicious Information

• Provides unusual or suspicious identification documents that cannot be readily verified
• Reluctant to provide complete information about nature and purpose of business, prior banking relationships, anticipated account activity, officers and directors or business location.
• Refuses to identify a legitimate source for funds or information is false, misleading, or substantially incorrect.
• Background is questionable or differs from expectations based on business activities.
• Customer with no discernable reason for using the Company's service.

Efforts to Avoid Reporting and Recordkeeping

• Reluctant to provide information needed to file reports or fails to proceed with transaction.
• Tries to persuade an employee not to file required reports or not to maintain required records.
• “Structures" deposits, withdrawals, or purchase of monetary instruments below a certain amount to avoid reporting or recordkeeping requirements.
• Unusual concern with the Company's compliance with government reporting requirements and Company's AML policies.

Certain Funds Transfer Activities

• Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent business reason.
• Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately withdrawn or wired out in manner inconsistent with customer's business or history. May indicate a Ponzi scheme.
• Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose.

Certain Securities Transactions

• Customer engages in prearranged or other non-competitive trading, including wash or cross trades of illiquid securities.
• Two or more accounts trade an illiquid stock suddenly and simultaneously.
• Customer journals securities between unrelated accounts for no apparent business reason.
• Customer has opened multiple accounts with the same beneficial owners or controlling parties for no apparent business reason.
• Customer transactions include a pattern of receiving stock in physical form or the incoming transfer of shares, selling the position and wiring out proceeds.
• Customer's trading patterns suggest that he or she may have inside information.

Activity Inconsistent With Business

• Transactions patterns show a sudden change inconsistent with normal activities.
• Unusual transfers of funds or journal entries among accounts without any apparent business purpose.
• Maintains multiple accounts or maintains accounts in the names of family members or corporate entities with no apparent business or other purpose.
• Appears to be acting as an agent for an undisclosed principal but is reluctant to provide information.

Other Suspicious Customer Activity

• Unexplained high level of account activity with very low levels of securities transactions.
• Funds deposits for purchase of a long-term investment followed shortly by a request to liquidate the position and transfer the proceeds out of the account.
• Law enforcement subpoenas.
• Large numbers of securities transactions across a number of jurisdictions.
• Buying and selling securities with no purpose or in unusual circumstances (e.g., churning at customer's request).
• Payment by third-party check or money transfer without an apparent connection to the customer.
• Payments to third-party without apparent connection to customer.
• No concern regarding the cost of transactions or fees (i.e., surrender fees, higher than necessary commissions, etc.).

 

c.  Responding to Red Flags and Suspicious Activity

When an employee of the Company detects any red flag, or other activity that may be suspicious, he or she will notify the AML Compliance Party. Under the direction of the AML Compliance Party, the Company will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or closing the account.

 

9.  AML Recordkeeping

Our AML Compliance Party and its designee will be responsible for ensuring that AML records are maintained properly. In addition, as part of our AML policy, our Company will create and maintain relevant documentation on customer identity and verification and funds transmittals. We will maintain such documentation for at least five years. We will hold such documentation confidential. We will not inform any third party about the existence of such documentation.

We shall retain either the original or a microfilm or other copy or reproduction of each of the following:

 

• A record of each extension of credit in an amount in excess of $10,000, except an extension of credit secured by an interest in real property. The record shall contain the name and address of the person to whom the extension of credit is made, the amount thereof, the nature or purpose thereof and the date thereof;
• A record of each advice, request or instruction received or given regarding any transaction resulting (or intended to result and later canceled if such a record is normally made) in the transfer of currency or other monetary instruments, funds, checks, investment securities or credit, of more than $10,000 to or from any person, account, or place outside the U.S.;
• A record of each advice, request or instruction given to another financial institution (which includes broker-dealers) or other person located within or without the U.S., regarding a transaction intended to result in the transfer of funds, or of currency, other monetary instruments, checks, investment securities or credit, of more than $10,000 to a person, account, or place outside the U.S.;
• Each document granting signature or trading authority over each customer's account;
• Each record described in U.S. Exchange Act Rule 17a-3(a): (1) (blotters), (2) ledgers for assets and liabilities, income, and expense and capital accounts), (3) (ledgers for cash and margin accounts), (4) (securities log), (5) (ledgers for securities in transfer, dividends and interest received, and securities borrowed and loaned), 6 (order tickets), (7) (purchase and sale tickets), (8) (confirms), and (9) (identity of owners of cash and margin accounts);
• A record of each remittance or transfer of funds, or of currency, checks, other monetary instruments, investment securities or credit, of more than $10,000 to a person, account, or place, outside the U.S.; and

 

• A record of each receipt of currency, other monetary instruments, checks or investment securities and of each transfer of funds or credit, of more than $10,000 received on any one occasion directly and not through a domestic financial institution, from any person, account, or place outside the U.S.

 

10.  Clearing/Introducing Company Relationships

We will work closely with our third-party partners to detect money laundering. We will exchange information, records, data, and exception reports as necessary to comply with AML laws.

 

11.  Training Policys

We will develop ongoing employee training under the leadership of the AML Compliance Party and senior management. Our training will occur on at least an annual basis. It will be based on our Company's size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.

Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees' duties; (2) what to do once the risk is identified; (3) what employees' roles are in the Company's compliance efforts and how to perform them; and (4) the Company's record retention policy.

We will review our operations to see if certain employees, such as those in compliance, margin, and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.

 

12.  Monitoring Employee Conduct and Accounts

We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of the AML Compliance Party. We will also review the AML performance of supervisors, as part of their annual performance review. The AML Compliance Party's accounts will be reviewed by the AML Compliance Person,

 

13.  Confidential Reporting of AML Non-Compliance

Employees will promptly report any potential violations of the Company's AML compliance policy to the AML Compliance Party, unless the violations implicate the AML Compliance Party, in which case the employee shall report to the AML Compliance Party. Such reports will be confidential, and the employee will suffer no retaliation for making them.

 

14.  Additional Risk Areas

The Company has reviewed all areas of its business to identify potential money laundering risks that may not be covered in the procedures described above.

 

15.  Senior Manager Approval

Senior management has approved this AML compliance policy in writing as reasonably designed to achieve and monitor our Company's ongoing compliance with the requirements of prevailing law.

Dated: September 5, 2018

Data Security

Organizational Controls

ZENBARCOIN personnel are expected to be competent, thorough, helpful, and courteous stewards of customer information that is stored on ZENBARCOIN products and in Zenbarcoin data centers. ZENBARCOIN has established a number of measures to ensure that customers and their data are treated properly.

Privacy and Control Mechanisms

ZENBARCOIN only uses the information provided by our customers to deliver the products and services purchased. All customer data is managed in compliance with our Privacy Policy. In addition, some products and all US Data Centers are audited to provide an independent validation of our policies and procedures around securing customer data.

ZENBARCOIN complies with any portion of HIPAA or the HITECH Act that are directly applicable to ZENBARCOIN. In particular, the ZENBARCOIN Platform safeguards replicated data in such a way as to satisfy HIPAA’s Security Rule. Customers wishing to establish a Business Associate relationship with ZENBARCOIN per 45 CFR 164.502(e) and 164.504(e) should request a Business Associate Agreement from ZENBARCOIN, The Business Associate Agreement defines commitments that ZENBARCOIN will make to maintain HIPAA and HITECH compliance as required

 

ZENBARCOIN

Employees

All employees are required to accept and acknowledge in writing ZENBARCOIN policies for nondisclosure and protection of ZENBARCOIN and third-party confidential information, including acceptable use of confidential information. In the course of assisting customers with their technology solutions, ZENBARCOIN support technicians understand that they may come into contact with customer communications and/or customer data and they must keep this information confidential.

 

Training

Technicians who support ZENBARCOIN products are prepared in a variety of ways. New tier 1 technicians receive class time training with tier 2 technicians and the support management team. deployments, and virtual machines may be stored on the same physical hardware as that of other customers. When data from many customers is stored at a shared physical location, ZENBARCOIN logically segregates storage and processing for different customers through specialized technology engineered specifically for that purpose.

ZENBARCOIN takes strong measures to protect customer data from inappropriate use or loss and to prevent customers from gaining access to one another's data.

We provide simple, transparent data-use policies and get independent audits

ZENBARCOIN provides you with details of our data protection policies and practices in clear, straightforward language in the Privacy Policy.

Our subcontractors are contractually obligated to meet our privacy requirements

ZENBARCOIN may hire other companies to provide limited services, such as data colocation services. We provide customer data as required to deliver the services we have retained them to provide. Subcontractors are prohibited from using customer data for any other purpose, and they are required to maintain the confidentiality of our customers' information.

• Subcontractors who handle customer data in ZENBARCOIN Platform services must enter into additional agreements with ZENBARCOIN that subject them to data protection terms.
• Subcontractors who handle ZENBARCOIN Platform customer data in their own facilities are required to set up and follow privacy standards equivalent to our own.

 

Control of your Data

You control access to your customer data

Access by ZENBARCOIN personnel.

ZENBARCOIN personnel are granted access only when necessary under management oversight. ZENBARCOIN personnel will use customer data only for purposes compatible with providing you the services, which can include customer support and troubleshooting services.

Access by subcontractors.

ZENBARCOIN will store your customer data in a limited-function account for 30 days (the retention period) to give you time to export the data or renew your subscription. During this period, ZENBARCOIN provides multiple notices, so you will be amply forewarned of the upcoming deletion of data.

• After this 30-day retention period, ZENBARCOIN will disable the account and may delete all customer data at its discretion, including any cached or backup copies.

In the multitenant environments of ZENBARCOIN Platform services, we take careful measures to logically separate customer data to help prevent one customer's data from leaking into the data of another customer, as well as to help block any customer from accessing another customer's deleted data.

Data deletion on physical storage devices

• When a disk drive used for storage in the ZENBARCOIN Platform suffers a hardware failure, it is securely erased or destroyed before ZENBARCOIN returns it to the manufacturer for replacement or repair. All of the data on the drive is completely overwritten to ensure that the data cannot be recovered by any means.

 

You have options to control the security of your customer data

The ZENBARCOIN Platform uses encryption to safeguard your data and help you maintain control over it.

When customer data moves over a network, the ZENBARCOIN Platform uses industry standard secure transport protocols between user devices and ZENBARCOIN data centers, as well as within the data centers themselves.

The ZENBARCOIN Platform uses industry-standard encryption for data at rest in transit.

How we respond to government requests

When governments or law enforcement make a lawful request for customer data from ZENBARCOIN, we are committed to transparency and limit what we disclose. Because  ZENBARCOIN believes that customers should control their own data, we will not disclose data hosted in the ZENBARCOIN Platform to a government or law enforcement agency except as you direct or where required by law.

the following things:

• Copy or upload files or information unless you have a legal right to the files or information;
• Probe, scan, or test the vulnerability of any system, or attempt to circumvent any security or authentication measures;
• Access, tamper with, or use non-public areas of the ZENBARCOIN Platform, or attempt to access or search the ZENBARCOIN Platform through non-public interfaces;
• Attempt to disrupt any user or network by sending a virus, malware, overloading, flooding, spamming, or mail-bombing, or otherwise interfere with the use of other users;
• Send unsolicited communications, promotions, advertisements, or spam;
• Attempt to access another user's account;
• Send altered, deceptive, or false source-identifying information, including “spoofing" or "phishing";
• Publish anything that is fraudulent, misleading, or infringes on another's rights;
• Misrepresent yourself or affiliation with an entity; or
• Publish or share materials that are offensive, defamatory, or unlawful.

Export Restrictions

The ZENBARCOIN Platform services may be controlled for export purposes. You must comply with all United States export laws and regulations. You assume sole responsibility for any required export approval and/or licenses and all related costs and for the violation of any United States export law or regulation. If you are located in a country subject to embargo by the United States government, you are not entitled to use the ZENBARCOIN Platform services.

Dated:  September 5, 2018

1. Your Data

Data stored in the ZENBARCOIN Platform is our customers' data and we protect their right to make decisions about that data and we are transparent about what happens to that data. With the ZENBARCOIN Platform, you are the owner of your customer data.

Customer data is defined as all data, including text, sound, video, or image files and software, that you provide to ZENBARCOIN, or is provided on your behalf.

ZENBARCOIN will use your customer data only to provide the services we have agreed upon, and for purposes that are compatible with providing those services.

You can access your customer data at any time and for any reason without assistance from ZENBARCOIN. We restrict access to it to ZENBARCOIN personnel and subcontractors. We provide

simple, transparent data-use policies.

We do not use customer data for advertising

Except as set forth below, ZENBARCOIN does not share customer data with our advertiser supported services, nor do we mine it for marketing or advertising.

In addition to providing the service and day-to-day operations, ZENBARCOIN may use your data for the following:

• Troubleshooting aimed at preventing, detecting, and repairing problems affecting the operation of services
• Ongoing improvement of features, such as those that improve the reliability of our services, or involve the detection of, and protection against, threats to the services or customer data (such as malware or spam)
• Providing personalized customer experiences
• Contacting you about new products and services

Furthermore, the ZENBARCOIN Platform uses systems that are kept logically separate from internal systems run by ZENBARCOIN.

We use logical isolation to segregate each customer's data from that of others

ZENBARCOIN Platform services are multi-tenant services, meaning that your data, ZENBARCOIN may hire other companies to provide limited services. Subcontractors can access customer data only to deliver the services we have hired them to provide. Subcontractors are prohibited from using customer data for any other purpose and are required to maintain the confidentiality of our customers' information.

 

Limits to access.

The operational processes and controls that govern access to and use of customer data in the ZENBARCOIN Platform are regularly verified. ZENBARCOIN regularly performs sample audits to attest that access is only for legitimate business purposes. Strong controls and authentication help limit access to customer data to authorized personnel only. When access is granted, whether to ZENBARCOIN personnel or our subcontractors, it is carefully controlled and logged, and revoked as soon as it is no longer needed.

 

Government and law enforcement requests.

ZENBARCOIN imposes carefully defined requirements around government and law enforcement requests for customer data. We will not disclose data hosted in the ZENBARCOIN Platform to a government agency except as you direct or where required by law. When we receive a government or law enforcement request for customer data, we attempt to redirect the third-party to obtain the requested data from our customer.

You control your customer data if you leave the service

 

ZENBARCOIN follows strict standards and specific processes for removing customer data from all systems under our control.

Data portability

You can retrieve a copy of your customer data at any time and for any reason without any assistance or notification required from ZENBARCOIN.

 

Data retention

• If you, the customer, terminate your subscription or it expires (except for free trials),

To that end, ZENBARCOIN maintains a network of Platform-scale data centers by geographic location around the globe and verifies that each meets defined security requirements. However, not all ZENBARCOIN products are deployed in all regions. To determine where data for a particular ZENBARCOIN product is stored, please refer to the product-specific security document.

 

Redundancy

Data in the ZENBARCOIN Platform is stored in a proprietary storage system developed and managed by ZENBARCOIN. This system maintains two copies of customer data to provide redundancy. In the United States, the two copies are stored in separate data center locations. Outside of the United States, the two copies are stored within the same location on separate storage systems.

 

Platform Security

ZENBARCOIN uses a defense-in-depth strategy and proprietary hardened software and operating systems to protect data and services. ZENBARCOIN conducts regular inspections to ensure the security of its systems.

 

Product Security

ZENBARCOIN

ZENBARCOIN is the 24/7 security center operated by ZENBARCOIN Networks to monitor and block the latest Internet threats. Data collected at ZENBARCOIN Central is analyzed and used to create definitions for automatic Energize Updates that fuel ZENBARCOIN products.

ZENBARCOIN is dedicated to providing technical insight for security professionals. By sharing data, ZENBARCOIN aims to build a strong community to collectively fight the latest Internet threats.

 

Data Privacy

DMCA Notice of Alleged Infringement ("Notice")

If you are a copyright owner, authorized to act on behalf of one, or authorized to act under any exclusive right under copyright, please report alleged copyright infringements taking place on or through the Site by completing a DMCA Notice of Alleged Infringement and delivering it to ZENBARCOIN Designated Copyright Agent. Upon receipt of Notice as described below, ZENBARCOIN will take whatever action, in its sole discretion, it deems appropriate, including removal of the challenged content from the Site. Please note that if you fail to comply with all of the requirements of this section and of 17 USC § 512(C)(3) your DMCA notice may not be valid.

• Identify the copyrighted work that you claim has been infringed, or - if multiple copyrighted works are covered by your Notice - you may provide a representative list of the copyrighted works that you claim have been infringed.
• Identify the material or link you claim is infringing (or the subject of infringing activity) and to which access is to be disabled, including at a minimum, if applicable, the URL of the link shown on the Site or the exact location where such material may be found.
• Provide your company affiliation (if applicable), mailing address, telephone number, and, if available, email address.
• Include both of the following statements in the body of the Notice:
  • "I hereby state that I have a good faith belief that the disputed use of the copyrighted material is not authorized by the copyright owner, its agent, or the law (e.g., as a fair use)."
  • "I hereby state that the information in this Notice is accurate and, under penalty of perjury, that I am the owner, or authorized to act on behalf of the owner, of the copyright or of an exclusive right under the copyright that is allegedly infringed."
• Provide your full legal name and your electronic or physical signature.
• Deliver this Notice, with all items completed, to ZENBARCOIN Designated Copy

 

DMCA Counter-Notice of Alleged Infringement

If you believe that your content that was removed (or to which access was disabled) is not infringing, or that you have authorization from the copyright holder, the holder's agent, or pursuant to law, to post and use the material in your content, you may send a Counter Notice containing the following information to ZENBARCOIN is the Copyright Agent:

 

• Your physical or electronic signature;
• Identification of the content that was removed or to which access has been disabled as a result of mistake or a misidentification of the content; and
• Your name, address, telephone number, and email address, a statement that you consent to the jurisdiction of the federal court in Alachua County, Florida, and a statement that you will accept service of process from the person who provided notification of the alleged infringement.

If a Counter-Notice is received by the Copyright Agent, ZENBARCOIN may send a copy of the Counter-Notice to the original complaining party informing that person that it may replace the removed content or cease disabling it in ten business days. Unless the copyright owner files an action seeking a court order against ZENBARCOIN or the person who has posted allegedly infringing content, the removed content may be replaced, or access to it restored, in ten business days or more after receipt of the Counter-Notice.

 

ZENBARCOIN Policy Regarding Repeat Infringers

ZENBARCOIN does not condone or tolerate copyright infringement or any violation of the intellectual property rights of ZENBARCOIN or of others. ZENBARCOIN reserves the right to terminate the access and/or use privileges of any person who has been determined to be a 'repeat infringer' of the copyrights of ZENBARCOIN or others. ZENBARCOIN reserves the right to define the criteria by which ZENBARCOIN will determine that a person is a 'repeat infringer.' In the event that repeat infringer' is defined by statute, law, or regulation as applicable to 17 USC S 512, ZENBARCOIN will adopt that definition as a minimum standard. Without limiting ZENBARCOIN right to define 'repeat infringer,' as a general rule, ZENBARCOIN will define a repeat infringer' as any person or entity about whom ZENBARCOIN has received two or more DMCA Notices of Alleged Infringement. ZENBARCOIN will take into account all relevant facts and circumstances when determining whether or not termination of access and/or use privileges of a 'repeat infringer' is appropriate.

REGARDLESS OF WHETHER ZENBARCOIN TERMINATES ACCESS AND/OR USE PRIVILEGES OF ANY PERSON OR ENTITY, 'REPEAT INFRINGER' OR OTHERWISE, ZENBARCOIN IN NO WAY WAIVES ANY RIGHT TO PURSUE ANY AVAILABLE REMEDY AT LAW OR IN EQUITY AGAINST COPYRIGHT INFRINGERS OR ANY OTHER INTELLECTUAL PROPERTY RIGHTS VIOLATORS, NOR WILL ZENBARCOIN INDEMNIFY OR PROVIDE LEGAL REPRESENTATION TO ANY ALLEGED INFRINGER IN ANY ACTION ARISING FROM THE ALLEGED INFRINGER'S USE OF ANY ZENBARCOIN WEBSITE OR SERVICE, EXCEPT AS EXPRESSLY DESCRIBED IN THIS NOTICE.

We do not offer direct access to customer data.

We believe that you should control your own data. ZENBARCOIN does not give any third-party (including law enforcement, other government entity, or civil litigant) direct or unfettered access to customer data except as you direct, or as required by law.

We redirect law enforcement and other third-party requests to the customer.

When we receive a government or law enforcement request for customer data, we always attempt to redirect the third third-party to obtain the requested data from our customer. For valid requests that we are not able to redirect to the customer, we disclose information only when we are legally compelled to do so, and we always make sure that we provide only the data specified in the legal order.

In either case, requests may require the release of the customer's basic contact information.

We do not give access to platform encryption keys.

We do not provide any government with our encryption keys or the ability to break our encryption

Acceptable Use and Conduct

All users must be registered to access the ZENBARCOIN Platform. Individual users must register using their name, and entity users must register under the legal name of their entity. You will be solely responsible and liable for any activity that occurs under your account.

You are solely responsible for the legality and appropriateness of your customer data uploaded or otherwise placed into the ZENBARCOIN Platform.

ZENBARCOIN may immediately and without prior notice to You, remove any content or data, or suspend or cancel accounts if it becomes aware of any misuse or illegal actions associated with an account or user.

When using the ZENBARCOIN Platform, you must not use the services to do any of

 

 

Terms of Use

General

Welcome to ZENBARCOIN (hereinafter the "Company") website. By using this site, you agree to comply with and be bound by these terms and conditions of use that govern the Company's relationship with you concerning this website. If you do not agree to these terms and conditions, please do not use this site.

Terms and Conditions of Use

The Parties

The terms 'Company' or 'us' or 'we' refer to ZENBARCOIN the owner of this website. The term 'you' or 'your' refers to the user or viewer of our website. All materials on the site is the property of ZENBARCOIN unless otherwise noted. Nothing herein is deemed to be an offering of securities under applicable law unless specifically stated as such. Nothing herein shall be deemed to evidence an agreement to purchase securities unless specifically stated as such.

Website Content

The content of this website is for informational purposes only. Postings are made at the Company's discretion and are subject to change without notice. Viewers should not assume that the information contained on this site, or linked to from this site, has been updated or co current information. The Company does not review past postings to determine whether such are accurate, and information contained in such postings may have been superseded by other information not on this site.

Disclaimer

All information, material, and graphics found or offered on this site are provided "as-is," and your use of such is at your own risk. You acknowledge that such information, materials, and graphics may contain inaccuracies or errors, and that we provide no express or implied warranties or guarantee as to their accuracy, and, to the fullest extent permitted by law, we expressly exclude and disclaim any and all such warranties and guarantees, including of merchantability, as to the accuracy, timeliness, performance, completeness, reliability, suitability, fitness for a particular purpose, title, and non-infringement of any such information, materials, and graphics.

Limitation of Liability

IN NO EVENT SHALL ZENBARCOIN BE LIABLE FOR ANY SPECIAL, INDIRECT, OR CONSEQUENTIAL DAMAGES, OR ANY DAMAGES WHATSOEVER RESULTING FROM LOSS OF USE, DATA, OR PROFITS, WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE, OR ANY OTHER ACTION AT LAW OR IN EQUITY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THIS WEBSITE OR THE INFORMATION, MATERIALS, AND GRAPHICS IT CONTAINS.

about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site or Apps may not function properly.

Information the Company Collects

All users must be registered with https://coinstocks.io

 

The Company collects and may store data when you log in. This data may include:

a. personal data

b. time of query,

c. time of reply,

d. name of client's station - identification made through HTTP protocol,

e. information about errors that occurred during the HTTP transaction,

f. URL address of the website previously visited by the user (referrer link),

g. information about your browser,

h. information about your IP address.

The Company uses such information only for administrative purposes and to ensure improve the quality of services it offers. The Company collects personally identifying and non-personally identifying information. This includes information you provide during registration, completing surveys, use of the site, and by other means. Registration information may include, but may not be limited to, personal data your email address, ZIP code, age, sex, household income, job industry, and job title.

Any suspicious transactions made by registered members may be suspended for 72 hours.

Suspicious transactions records and its senders' and receivers' identity data will be handed over to relevant government/regulation agents.

Registration

You must be 18 years or older to register on the website. If you register and create an account on the website, you agree to provide accurate and up to date information as required. Unless otherwise agreed in writing with the Company, you agree that your account is for your personal use only as a single user. You may not share your login credentials with anyone else. The Company may terminate your account or suspend or restrict access if you do. Fraudulent, abusive, or other illegal activity may be grounds for termination of your account, at the Company's discretion.

Fees

The Company reserves the right to charge fees for the use website and/or its wallet, and for services offered over it. It reserves the right to change those fees at any time.

Other Links

IF YOU DECIDE TO ACCESS ANY OF THE SITES LINKED FROM THIS SITE, YOU DO SO ENTIRELY AT YOUR OWN RISK. Links to other sites and their content are provided for convenience only and are not under the control of the Company. We are not responsible for the content of such sites or of the content contained in any sites that such sites are linked to.

Assumption of Liability

If you create a link to this website from another website or document, or pass such link onto others, you do so at your own risk and understand that by so doing, you accept all risk of loss or damages to you or any other website, person, or organization, and agree to fully indemnify and hold the Company harmless from any such loss or damages.

Applicable Law and Jurisdiction

Your use of this website and any dispute arising out of such use are subject to the laws of the State of Florida and any dispute shall be heard before a tribunal or court of general jurisdiction in Florida

Privacy Policy

This Privacy Policy governs the manner in which the Company collects, uses, maintains, and discloses information collected from users (each, a "User") of the proqyr.com website ("Site") or mobile apps ("Apps"). This privacy policy applies to this site and any Apps owned by the Company

Personal Identification Information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site or use an App, place an order, and in connection with other activities, services, features, or resources we make available on our Site or Apps. Users may be asked for, as appropriate, email address. Users may, however, visit our Site and Apps anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to personally supply identification information, except that it may prevent them from engaging in certain Site and App related activities.

Non-Personal Identification Information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users, means of connection to our Site or Apps, such as the operating system and the Internet service providers utilized, and other similar information.

Web Browser Cookies

Our Site or Apps may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information you will not be charged any fee unless the Company obtains your prior agreement to pay the fee. You will receive advance notice of any applicable fee or change in applicable fees.

How we Use Collected Information

The Company may collect and use Users personal information for the following purposes: 1) To improve customer service - Information you provide helps us respond to service requests and support needs more efficiently. 2) To send periodic emails - We may use the email address to respond to inquiries, questions, and/or other requests.

How we Protect Your Information

We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Site and Apps. The Company employs 256 bit SSL encryption.

Sharing your Personal Information

Except as required to complete transactions that you authorize, we do not sell, trade, share, or rent Users' personal identification information. We do not sell, trade, share, or rent Users' personal identification information to third parties.

Third Party Websites

Users may find content on our site and Apps that link to the sites and services of third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site and Apps. In addition, these sites, or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site and Apps, are subject to that website's own terms and policies.

Changes to this Privacy Policy

The Company has the discretion to update this privacy policy at any time. We encourage Users to frequently check this policy posting for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of any modifications.

Your Acceptance of these Terms

By using this Site or our Apps, you signify your acceptance of this privacy policy. If you do not agree to this policy, please do not use our Site or Apps. Your continued use of our Site or Apps following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at:

New support technicians also spend a period of time as an understudy to an established technician for each product in which they intend to become certified. Product knowledge is tested and established through formal online training and all technicians are expected to meet a pre-defined standard before supporting customers directly.

All ZENBARCOIN support technicians receive ongoing training in product-specific training sessions.

When an employee or contractor leaves ZENBARCOIN, a formal process is in place to immediately revoke physical and network access to ZENBARCOIN facilities and resources.

Architecture and Infrastructure Security

Storage Facility Standards

ZENBARCOIN leases space in a number of data centers worldwide. Each ZENBARCOIN data center is equipped with the following:

• Controlled access systems requiring key-card authentication

• Video-monitored access points

Intrusion alarms

• Locking cabinets

• Climate control systems

• Waterless fire-suppressant systems

• Redundant power (generator backup, UPS, no single point of failure)

• Redundant Internet connectivity

• ISO and/or SOC II certified

Data Location

Knowing the geographic location of their data is important for customers operating in regulated industries or in countries with data protection laws. ZENBARCOIN understands that some customers must maintain their data in a specific geographic location, such as within the European Union or within countries that are members of the Asia-Pacific Economic Cooperation (APEC) forum.