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AML Policy

Zimba Infotech LLP, is a Limited Liability Partnership incorporated in India Under Law of Limited Liability Partnership Act, 2008 having registered office at Ahmedabad (herein after called as LLP). LLP term include its owners, designated partners or other related parties and Users term referred to person availing of the LLP Services, both directly or indirectly.

This Anti-Money Laundering Policy (herein after referred to as the “AML Policy”) refers to the LLP’s commitments against financing of terrorism, money laundering, and other related illegal activities. It describes the LLP's procedures and policies established to make sure that the Services offered by the LLP are not used by you to facilitate commission of any criminal offences, that include but are not limited to those under the Unlawful Activities Prevention Act, 1967 and Prevention of Money Laundering Act, 2002. Even though under the said laws, the LLP does not qualify as an entity obligated to follow the processes prescribed herein, the LLP has prepared this AML Policy to ensure transparency in trading and to assure the prevention of money laundering and other illegitimate and illegal activities.

Definitions

  • “Applicable Law” means all laws in force for the time being within the territory of India, including (but not restricted to) the Prevention of Money Laundering Act 2002 (“PMLA”), the Prevention of Money Laundering (Maintenance of Records) Rules 2005 (“PML Rules”), and the Reserve Bank of India’s (“RBI”) Master Direction on Know Your Customer Rules (“KYC Rules”), updated as of 25 February 2016;
  • “Designated Partner” means all the  partners  are bodies corporate or one or more partners are individuals and bodies corporate, at least two individuals who are  partners of such LLP or nominees of such bodies corporate shall act in according with Limited Liability Partnership Act,2012.
  • “Identification Document(s)” refer to Passport, Permanent Account Number (PAN) card, Aadhaar Number, Government issued identify cards or other document as may be notified by the US from time to time.
  • “Principal Officer” means the officer appointed by us to administer ours anti-money laundering measures, in accordance with the PMLA;
  • “Suspicious Transactions” refers to the following acts, whether executed or attempted:
    • (i) Terrorist financing: transactions that to a person acting in good faith seem to be any funds collected to be utilized, in part or in full, by any terrorists or related organization, or in order to conduct any of the activities relating to terrorist acts or terrorism;
    • (ii) Unusually Complex: transactions that to a person acting in good faith seem to have been structured in a manner of unjustified or unusual complexity;
    • (iii) Malafide Purpose: transactions which to a person acting in good faith appear to have not been transacted for bonafide purpose or have a sound economic rationale.
    • (iv) Money Laundering: transactions that to a person acting in good faith seem to involve proceeds of any offence listed in the Schedule to the Prevention of Money Laundering Act, 2002.

Purpose - Anti-Money Laundering Policy

The LLP purpose to put in place this policy which includes transaction monitoring terms, risk management procedure, customer acceptance terms, customer verification procedure In order to its risks relating to money laundering and other illegal activities.

Your Obligation

A. You must ensure that any personal information and/or Identification Documents submitted by you belong to you.

B. You admit that it is your duty to ascertain compliance with the terms and conditions described in this AML Policy and conform your consent to not using the Online Platforms and the Services in any manner that results in attempting to commit/committing any criminal offences.

C. You also agree and accept to any changes made to this Privacy Policy in due course and without notice.

D. You must file a fresh address proof within 6 months of making any changes to the address mentioned as per the ‘proof of address’ submitted by you.

E. In case you are acting on behalf of a juridical person, you must identify the Beneficial Owner and also assist in verification of the identity of such Beneficial Owner and any individual who purports to act on behalf of such juridical person.

Risk Management Procedure

We may categorize you into low, medium or high risk categories, after undertaking an appropriate risk assessment of you based on the following factors (including without limitation):

Nature of your business/vocational activities; or

Sufficiency and adequacy of identification information submitted under Clause - Customer Verification Procedure; or

Guidance notes circulated by various governmental and inter-governmental organizations; or

Its social and/or financial status.

Customer Acceptance Terms

The LLP may either at the time of Account opening, or while conducting any transactions, or during Periodic Updation, or for any other reason, ensure your compliance with the following:

  • Require that you undergo a verification process during the activation process of your User Account by submitting your Identification Documents and such other details, as mandated under Clause - Customer Verification Procedure of this AML Policy;
  • Require you to furnish other details as may be deemed necessary by the Company to verify your identity, if the Company has reason to believe that you are a person or entity enlisted in the Sanctions Lists.
  • Require you to submit such additional data and/or information as may be directed by a competent enforcement authority.
  • Require you to certify that your Linked Bank Account is held only with a scheduled commercial bank compliant with all Know Your Customer (KYC) procedures mandated under the applicable laws.

Transaction Monitoring Terms

All transactions executed and/or attempted to be executed on the Online Platforms are regularly monitored by us, both manually and through use of software based algorithms, in order to promptly identify and highlight certain kinds of transaction including without limitation, the following kinds of transactions:

  • High value transactions of amounts greater than INR 50,000 (Rupees Fifty Thousand);
  • Suspicious Transactions;

The LLP may, from time to time, undertake necessary investigation in order to identify and examine transactions inconsistent with any risk of your profile (determined in accordance with Clause - Risk Management Procedure, sophistication, and expected usage pattern.

The extent of monitoring shall depend on various factors including upon your risk profile.

The LLP reserves the right to terminate the your Account, restrict and/or prevent access to Online Platforms, or report to the appropriate enforcement authorities the activities of your transactions identified under this Clause - Transaction Monitoring Terms.

Policy Modification

These terms may be periodically reviewed, revised and modified. Such changes may be made without any prior notice, but any changes will only apply to activities and information on a going forward and not retroactive basis.

You are required to periodically visit the website and review terms and any changes thereto. Continued use of the our Services constitutes agreement with you to the terms contained herein and any amendments thereto.

Grievance

You may register your grievance with respect to data collection, retention or use to LLP’s Grievance Officer via Support ticket at: https://support.cryptoidol.com/portal/newticket

Assorted

All other provisions of the our Terms of Service shall be read into this policy and shall form part hereof, including Governing Laws and jurisdiction, notices, severability, assignment and such or other provisions.