UAB “AB Exchange”

TRANSPARENCY AND ACCOUNTABILITY POLICY

Date: 26.07.2022

 

If you have any questions about this Transparency and Accountability Policy, please feel free to contact us by email at [email protected]

 

We respect the privacy of visitors to our Website and Users of our Services, as well as we respect the right of competent authorities to collect the necessary information.

This Transparency and Accountability Policy (“Policy”) applies to the processing of competent authorities’ requests and providing requested information if it complies with the applicable law. 

Definitions in this Policy are used within the meaning of the Privacy Policy and Guidelines for Anti-Money Laundering, Combating Terrorist Financing and Sanctions. 

By continuing to use our Services, you acknowledge that you have read, understood and accepted the information described in this Policy. 

Please note that our Services, Websites and Chatbot are not intended for minors below the age of 18 years and we do not knowingly collect data relating to minors.

If provided a translation of the English language version of this Policy, the English language version of the Policy will control if there is any conflict.

 

IF YOU DO NOT AGREE WITH THIS POLICY IN GENERAL OR ANY PART OF IT, PLEASE DO NOT ACCESS TO OUR WEBSITE OR USE OUR SERVICES!

 

1. GENERAL PROVISIONS

1.1. Competent authority is any person or organization that has, under Lithuanian law or EU regulation, the legally delegated or invested authority, capacity, or power to perform designated functions, among which:

  • to file requests for obtaining information;
  • to monitor compliance with money laundering regulations;
  • to investigate and prosecute money laundering and associated predicate offences and terrorist financing; and
  • to seize or freeze and confiscate criminal assets.

1.2. Any request for information must be official, in clear English or Lithuanian, include a valid email address to which we can respond and legally defined attributes by which we can establish a person or an organization that contacts us. A valid email is one that is clearly associated with the competent authority in question.  For any relevant requests please contact us at – [email protected]. 

2. REQUESTS

2.1. We cooperate with competent authorities in preventing money laundering and terrorist financing, thereby communicating information available to us and replying to queries within a reasonable time, following the duties, obligations and restrictions arising from legislation. 

2.2. Please include the following information in your request, so that we can give you as much detailed response as possible:

  • complete information about the competent authority issuing the request for information;
  • full name and identification information of the person in charge;
  • contact information of competent authority (including official email, postal address and phone number);
  • the description of the types of information which competent authority wants to receive; 
  • date of request, a signature of the person in charge and official seal (if applicable); and
  • сlause of law, under which competent authority requests the information.

2.3. Please note that seizure and forfeiture of the assets on Users’ accounts are possible only under the court order submitted to us via e-mail address for correspondence. The court order shall be made in (or translated to) English or Lithuanian language. For the execution of the forfeit of someone’s digital property, providing a virtual wallet for us to transfer virtual assets to is required.

2.4. We will answer your request as soon as possible, but we would like to examine it thoroughly, so allow at least 15 business days for us to do that unless prescribed otherwise by relevant legislation. 

2.5. Please note that in case you represent the competent authority outside of the European Union, a procedure under the Mutual Legal Assistance Treaty may apply. 

2.6. Legal entities and individuals have the right to request information from us through Customer Support – [email protected]. To legal entities and individuals, we can disclose only information and data concerning the activity of the petitioner as our User, unless otherwise prescribed by relevant legislation. The period for us to reply to a User’s legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Please note that we may request that you provide some details necessary to verify your identity when you make a request to us.

3. RELIEF FROM LIABILITY

3.1. We and our employees, representatives, and/or persons who act in our name shall not, upon the performance of the obligations arising from the relevant legislation, be liable for the caused damage in connection with the notification of the competent authority of the suspicion of money laundering or terrorist financing.

3.2. The performance in good faith of the notification obligation arising from the relevant legislation and communication of relevant data by us shall not be deemed an infringement of the confidentiality requirement provided by law or contract and no liability provided by legislation or contract is imputed with regard to the person who performed the notification obligation for disclosure of the information.

3.3. The information provided in response to requests is collected and provided to the fullest and most accurate extent possible. However, nothing in such information can be guaranteed to be free of errors, mistakes, misrepresentations, or failures. Therefore, neither we nor where applicable any of our respective directors, officers, employees, agents, or outsourced advisors makes any representation, warranty, or guarantee whatsoever with respect to the information and, in particular, as to the accuracy or completeness of the information.

3.4. Nothing in this Policy shall be deemed or construed as non-willingness to provide the requested information.