SAVEDROID NL B.V.
1016 EJ AMSTERDAM
Netherlands Commercial Court (NCC) & Netherlands Commercial Court
of Appeal (NCCA)
Dr. Yassin Hankir, Joachim V. Brockmann
Information regarding the Online Dispute Resolution
If you live in a country in the European Economic Area (which includes the European Union), and any other included country or territory (collectively referred to as the "European Region"), you can use the new online dispute resolution (ODR) for alternative resolution between consumers and digital traders. Go to: http://ec.europa.eu/consumers/odr.
As used herein, "savedroid" refers to the company savedroid NL B.V., including without limitation thereby, its owners/shareholders, directors, investors, employees, affiliated companies, or other related parties. savedroid NL B.V. is a company with limited liability, incorporated under the laws of the Netherlands.
Noteworthy and depending upon context, "My Solid Wealth" shall have a meaning of the website, the services, products, content or other materials (collectively, "Materials" such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, software etc.) provided by the company savedroid as mentioned above.
A My Solid Wealth Account ("Account" or "Accounts") is an Account held by an "Account Holder" with the specific objective of exchanging digital currency (like Bitcoin) and fiat currency through the My Solid Wealth platform.
By Creating an Account to use the My Solid Wealth Services, Account Holders represent and warrant:
- they acknowledge and agree that there are risks associated with purchasing, owing and using the digital and fiat currency.
You can buy digital currencies and sell digital currencies in a few minutes after creating an Account. My Solid Wealth works with accounts to provide you with additional security. It also gives you a 'one-click' ordering method, which speeds up the process and helps avoiding errors (such as making a mistake when typing the digital currency address of your private wallet). Your Account is only used for these purposes.
A new Account can be created by any natural person or legal entity by providing:
- First name;
- Last name;
- Email address;
It is the sole responsibility of the Account Holder to provide correct account details and to make sure to have access to his Account as well as to make it secure. By providing false account details, a fee of 50 EUR is due.
It should be borne in mind that "savedroid" takes no responsibility for any losses.
CONDITIONS AND LIMITS
- My Solid Wealth may, at its sole discretion, decide who we will or will not enter into a transaction with.
- My Solid Wealth reserves the right to change the buy and/or sell limits on your Account as we deem necessary.
- Account Holders are responsible for maintaining the confidentiality of their Account information and for all activity including Transactions that occur under their Account.
- Account Holders agree to provide My Solid Wealth with accurate, current and complete information as prompted by the Create Account process
- Financial transactions i.e. “pay-in” and “withdrawal” can be conducted through different payment providers (SOFORT, SEPA, PayPal)
- My Solid Wealth cannot be held responsible for the loss of digital currencies resulting from an Account Holder not being able to access their personal wallet and/or digital currency address(es) which they provided to My Solid Wealth to be used by My Solid Wealth for sending (or returning) digital currency to the Account Holder.
- My Solid Wealth will provide one specific digital currency address per Account where the Account Holder can send the digital currency that is to be sold by My Solid Wealth ("digital currency Sell address").
- Customers are not allowed to have a multiple Accounts nor to share payment methods (i. e. either debit/credit/wireless) with other Account Holders.
- When buying or selling digital currencies through the My Solid Wealth Exchange Service, Account Holders are buying from, or selling to, My Solid Wealth directly. My Solid Wealth does not act as an intermediary or marketplace between other buyers and sellers of digital currencies.
- The Exchange Service is subject to the My Solid Wealth "Reference Price". "Reference Price" means the liquidity adjusted price of a given digital currency amount in terms of local currency as quoted on the My Solid Wealth Site. The "Reference Price" is stated either as a "Buy Price," the price in terms of local currency at which you purchase digital currency from My Solid Wealth, or as a "Sell Price," the price in terms of local currency at which you sell digital currency to My Solid Wealth.
- For the purpose of any transaction that incorporates the "Reference Price", you agree, as a condition of using the My Solid Wealth Exchange Services, to accept the "Reference Price" as t he sole conversion metric.
- Account Holders acknowledge and agree that the digital currencies price is based on the My Solid Wealth Reference Price. Volatile market conditions and API delays can affect the Reference Price, both positive and negative, for which My Solid Wealth cannot be hold responsible.
- Account Holders also acknowledge and agree that the payment in relation to the transaction may be delayed due to availability of banking systems.
- Account Holders may only cancel an order initiated via our Services if such cancellation occurs before My Solid Wealth executed the transaction. Once your order has been executed, you may not change, withdraw or cancel your authorization for My Solid Wealth to complete such transaction. All trades are irreversible once initiated. While we may, at our sole discretion, reverse a trade under certain extraordinary conditions, an Account Holder does not have any right to a reversal of a trade.
Our Services consist of facilitating the buying and selling of digital currencies such as Bitcoin and their use to purchase goods in an international open payment system. My Solid Wealth does not keep or manage any digital currency wallets. The Services we provide are currently unregulated in the Netherlands. However, it is our policy to comply with applicable laws and regulations regarding AML and identity verification (Know Your Customer, called KYC procedures), and to detect and prevent the use of our Services for money laundering or to facilitate criminal or terrorist activities.
Any decision to purchase or sell digital currency is your decision and we will not be liable for any loss suffered.
My Solid Wealth is a stand-alone digital currency exchange business, where you deal directly with My Solid Wealth (as opposed to an exchange market where you deal directly with other buyers and sellers).
There is no fee for a transaction. However, there is a 10% spread as well as 10 EUR payout fee. These fees are clearly specified on the Buy and Sell pages and are presented well in advance of initiating your order. Digital currencies such as Bitcoin are a digital non-returnable and non-refundable product for which you lose your right of withdrawal.
BUY DIGITAL CURRENCIES
When buying digital currency, you acknowledge and agree to accept:
- That you will be provided with the details of the My Solid Wealth bank account after clicking the review order button on the Buy page.
- SEPA bank transfers are processed daily after receiving a notification from our bank of the User's transfer. Expect a waiting time of one to three working days between a bank transfer and receiving the digital currency to personal Account.
- Initiate SEPA transfer from the bank account connected to personal My Solid Wealth Account
- Put personal My Solid Wealth Account information in the 'comment' (sometimes called 'label' or 'reference') field of the bank transaction.
- Transfer the amounts within the limits of the Customer's My Solid Wealth Account.
- During the first week after creating a New My Solid Wealth Account, the maximum Buy transaction size per day is limited.
- Once our bank confirms the User's transfer, My Solid Wealth will initiate a buy transaction and the digital currency will be sent to the User's Account.
- The ticket size ranges from EUR 100 to EUR 500, depending on which country the Account holder is based.
- The estimated amount of digital currency on the Buy page is based on the actual price at that moment. Thereafter, the final value will depend on the market situation and exchange availability at the time the User's buy transaction is processed.
- When the User's digital currency is sent to his Account, he will receive a confirmation email with the financial transaction details.
- Bank transfers not in line with these terms will be returned (after deduction of bank costs).
SELL DIGITAL CURRENCY
- If the User initiate a Sell transaction through the form on the Sell page, the digital currency price for his transaction will be locked in for a short period, so he knows exactly what his payout will be. If the User's transaction takes more than the lock in period to finalise, his digital currency price will be updated with the My Solid Wealth reference sell price at the time of receiving his digital currency. Alternatively, if The User does not use the Sell form to lock the digital currency price, his digital currency will automatically be traded when My Solid Wealth receives them. The User's payout is then based on My Solid Wealth market reference price of that moment.
- The payout fee is EUR 10.
- It is in the Account Holder's responsibility to activate accurately a Sell form to lock his digital currency price in order to commence with a trade. This secure action will prevent automatic t rade by My Solid Wealth.
- The processing of Electronic Funds Transfer varies from country to country and from one bank to another. Generally, funds are verified within 24 hours of the transaction being initiated.
Unless otherwise specified, all Materials on this Site are the property of My Solid Wealth and are protected by copyright, trademark and/or other applicable laws. You may view, print and/or download a copy of the Materials from this Site solely for your personal, informational, non-commercial use, provided you keep intact all copyright and other proprietary notices.
The Trademarks, service marks and logos of My Solid Wealth and others used in this Site are the property of My Solid Wealth and their respective owners. The software, text, images, graphics, data, prices, trades, charts, graphs, video and audio used on this Site belong to My Solid Wealth. The Trademarks and Materials should not be copied, reproduced, modified, republished, uploaded, posted, transmitted, scraped, collected or distributed in any form or by any means. Any unauthorized use is prohibited and may violate copyright, trademark and/or other applicable laws and could result in criminal or civil penalties.
Account Holders represent and warrant that they are the legitimate owners and are allowed to use all digital currencies of the Transactions being carried out and do not infringe the rights of any third party or applicable laws.
My Solid Wealth cannot be held liable for any malfunction, breakdown, delay or interruption to the Internet connection, or if for any reason our Services are unavailable at any time or for any period.
Where our Site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them.
My Solid Wealth shall be liable towards you within the scope of the use of the Site for culpably inflicted personal injuries to an unlimited extent. For financial losses culpably inflicted upon you My Solid Wealth will be liable with the exceptions and restrictions stipulated below.
In case of simple negligence My Solid Wealth is, in any case, only liable for the breach of essential contractual obligations and the liability is limited to the amount of the foreseeable damages, the occurrence of which typically has to be expected with contracts of this type. Such essential contractual obligations in the aforementioned meaning are obligations which are essential for the achievement of the contractual purpose or the fulfilment of which enables the proper execution of the contract at all and on the compliance with which you may regularly rely. The foreseeable damage, typical for the contract, is the damage, which is under usual circumstances related to the cause of the damage and the type of the contract.
You are responsible for the accuracy and completeness of your details, in particular with regard to details concerning name, address and bank details.
My Solid Wealth is not liable, if – owing to incorrect or incomplete declaration of details by you – a contract is not concluded, you do not actually receive declarations from My Solid Wealth or Services cannot be provided by My Solid Wealth or are provided incorrectly.
The prices or exchange rates of virtual currencies are subject to continuous and substantial fluctuations, e.g. owing to announced legislative proposals, governmental restrictions, news in connection with cyber-crime or other factors, which possibly cause excessive enthusiasm on the markets or a disproportionately high loss of trust. Prices of virtual currencies can moreover be manipulated. The value of your saved virtual currencies can therefore suddenly increase sharply or also fall to a large extent, up to a value of nil.
Virtual currencies as well as crypto stock exchanges, on which virtual currencies are traded, are not subject to any state supervision and are not regulated. In particular, in the event of interruption of operations of such crypto stock exchanges or the Blockchain, on which a virtual currency is based, there is the risk that an exchange into or exchange back of virtual currencies into Fiat money will not be carried out or only carried out with a substantial time delay and during which the exchange rates can fluctuate substantially.
My Solid Wealth is not liable for the damages suffered by you in connection with rate fluctuations of virtual currencies, unless these damages are a result of gross negligence, willful intent or of the non-compliance with applicable laws.
The conclusion of certain transactions in connection with virtual currencies on Blockchain networks can be postponed for a certain period of time, until a sufficient number of confirmations have been received. A transaction of virtual currencies, will therefore under certain circumstances not be displayed in your My Solid Wealth account, until a sufficient number of confirmations has been received and was confirmed by My Solid Wealth. There is, moreover, the possibility that transactions in Blockchain networks are aborted or that Blocks remain unconfirmed. In addition, transactions of virtual currencies are possibly not capable of being reversed.
My Solid Wealth is not liable for the damages suffered by you, which result from non-concluded transactions or transactions, which were not concluded in time or were concluded inaccurately via a Blockchain network.
- attempts to gain unauthorized access to the Site or another Account Holder’s Account or providing assistance to others attempting to do so,
- overcoming software security features limiting use of or protecting any content,
- usage of the Services to perform illegal activities such as money laundering, illegal gambling operations, financing terrorism, or other criminal activities,
- failure to pay or fraudulent payment for transactions,
- unexpected operational difficulties, or
- upon the request of law enforcement or other government agencies, if deemed to be legitimate and compelling by My Solid Wealth, acting in its sole discretion.
We also reserve the right to cancel unconfirmed Accounts or Accounts that have been inactive for a period of 6 months or more, and/or to modify or discontinue our Site or Services. Account Holders agree that My Solid Wealth will not be liable to them or to any third party for termination of their Account or access to the Site.
This Anti-Money Laundering ('AML') Policy and Identity Verification Policy (collectively the ‘AML Policy’) is designed to stipulate the commitment of savedroid NL B.V. (the 'Company') controlling and responsible for the website My Solid Wealth to detect, prevent and report attempts to use its financial services platform (the ‘Services’) to illegally launder money, to finance illegal activities such as terrorism and drug trafficking, or to commit fraud.
Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals are known to specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.
savedroid NL B.V. is a company with limited liability, incorporated under the laws of the Netherlands.
The Company offers the Services through its platform My Solid Wealth with the URL MySolidWealth.com that allows people to buy and sell math-based currencies such as Bitcoin. The Company does not keep or manage math-based currency (such as Bitcoin) wallets and/or fiat money deposits. The Company recognizes that decentralized and distributed digital currency and payment systems in which payments are processed and secured by advanced cryptography and distributed computing power instead of a centralised (government) institution pose a risk of illegal use (as do all financial systems). The Company believes, however, that the legitimate use of math-based currency networks can potentially provide immense benefits and efficiencies within the global economy.
Although the Services provided by the Company are currently unregulated in the Netherlands, it is the Company's policy to comply with applicable laws and regulations regarding AML and identity verification (Know Your Customer / KYC procedures), and to detect and prevent the use of its Services for money laundering or to facilitate criminal or terrorist activities. Accordingly, the Company has implemented this AML Policy and accompanying systems and procedures to assess the specific risks posed by the Company’s Services and established controls to address those risks as required by law. While the Company is committed to protecting its users' privacy, it will not allow people to use its Services to launder money, commit fraud or other financial crimes, finance terrorist activities, or facilitate other illegal conduct.
The Company's AML Policy is based on the guidance of De Nederlandse Bank (DNB) on the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act (Wet ter voorkoming van witwassen en financieren van terrorisme / Wwft). This guidance was drawn up by the DNB on the recommendation of the Financial Action Task Force on money laundering (FATF), and provides tools enabling to comply with statutory obligations arising from integrity regulations.
If you have any questions relating to this AML Policy, the use of your Account, the Services, or any other matter, please contact us:
Last updated: 19.03.2020Hide AML and Identity Verification Policy
As used herein, "savedroid" refers to the company savedroid NL B.V., including without limitation thereby, its owners, directors, investors, employees or other related parties. savedroid NL B.V. is a company with limited liability, incorporated under the laws of the Netherlands.
Depending upon context, "My Solid Wealth" may refer to the services, products, website, content or other materials (collectively, "Materials") provided by savedroid.
"Savedroid" and its affiliates (hereinafter, "savedroid", "we", "us" or "our") are committed to protecting and respecting your privacy.
- The kinds of Personal Information which we may collect about you and how it may be used;
- Any disclosure of Personal Information to third parties;
- Your ability to correct, update and delete your Personal Information;
- The security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control; and
- Retention of Personal Information.
- the agreement between the Buyer and the Seller to exchange digital or fiat currency through the Service for currencies at a commonly agreed rate ("Currency Purchase Transaction"),
- the conversion of currencies into digital or fiat currency deposited by Account Holders on their account ("Conversion Transaction"),
- the transfer of digital or fiat currency among Account Holders ("Currency Transfer Transaction"),
- the purchase of ancillary products ("Purchase Transactions").
My Solid Wealth may not offer all of these types of transactions at this time or in all places.
GATHERING AND USE OF PERSONAL INFORMATION
We may collect your Personal Information if you use the website, open an Account to use the Platform or perform any Transactions on the Platform. The types of Personal Information that we collect may include:
- Your name;
- Your photographic identification, including a high-quality image of your government issued ID; passport, national ID card, and EU driving licence;
- Your address;
- Your email address;
- Your banking details including account numbers;
- Your date of birth;
- Your trades; and
- Your utility bill or bank statement confirming your residential address.
We may use your Personal Information for the following purposes:
- To personalize your experience (your information helps us to better respond to your individual needs);
- To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);
- To analyse use of our website;
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
- To undertake a verification of your identity in accordance with our Anti-Money Laundering ("AML") and Identity Verification Policy;
- To process transactions. Your information, whether public or private, will not be sold, exchanged, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested by the customer;
- To send periodic emails. The email address you provide for order processing, may be used to send you information and updates pertaining to your order or request, in addition to receiving occasional company news, updates, promotions, related product or service information, etc.;
- To administer a contest, promotion, survey or other website feature.
- We will process your Personal Information only for the purpose(s) for which it has been provided to us.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our website, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our website are most visited and difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties.
We use third party service providers to assist us in better understanding the use of our website. Our service providers may place cookies on the hard drive of your computer and receive information that we select that will educate us on such things as how visitors navigate around our website, what products are browsed and general Transaction information. Our service providers analyse this information and provide us with aggregate reports. The information and analysis provided by our service providers can be used to assist us in better understanding our visitors' interests in our website and how to better serve those interests. The information collected by our service providers may be linked to and combined with information that we collect about you while you are using the Platform. Our service providers are contractually restricted from using information they receive from our website other than to assist us.
DISCLOSURE OF PERSONAL INFORMATION
You acknowledge that by using our Services and your acceptance of the My Solid Wealth Terms and Conditions, you will be providing us with Personal Information. You consent to us disclosing that information where we are required by law to third parties for electronic identification purposes as outlined above.
Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
THIRD PARTY LINKS
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party websites have separate and independent privacy policies. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
We do not control those third party websites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party websites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those websites.
CORRECTION / UPDATING / DELETION OF PERSONAL INFORMATION
You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at:
My Solid Wealth will action your request only where this is not inconsistent with its Terms and Conditions, legal and regulatory obligations. Upon your written request, we will provide you with the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. Such request will be accepted once per calendar quarter per Account Holder.
We have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction.
We implement a variety of security measures to maintain the safety of your Personal Information when you submit a request, place an order or access your Personal Information. These security measures include: password protected directories and databases to safeguard your information, SSL (Secure Sockets Layered) technology to ensure that your information is fully encrypted and sent across the Internet securely and other measures to protect our servers from hackers and other vulnerabilities.
Only authorized personnel of My Solid Wealth have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.
RETENTION OF PERSONAL INFORMATION