Effective Date: January 6, 2025

Instant Deposit and Credit Card Processing Services - Terms of Service

Your use of Instant Deposit and Credit Card Processing Services enabled by Zūm Rails Inc. ("Zūm Rails") from within the instacoinatm.com website (the "Website") is subject to the following terms. These Instant Deposit and Credit Card Processing Terms of Service ("Terms of Service" are a legal agreement between Instacoin ATM Quebec Inc. ("Instacoin ATM", "we" or "us") and you, the user of the Instant Deposit or Credit Card Processing service ("you") and govern your use of the Bank Verification Service (the "Service") and related matters. By using the Service, you agree to be bound by these Terms of Service, as amended by Instacoin ATM from time to time, as well as to the Instacoin ATM Privacy Policy. You also agree that if you are accepting these terms on behalf of another entity, you have the full authorization to do so.

1. General

We use the Service to allow you to connect your bank account. Connecting your bank account helps us better support your requested payments, including by verifying your bank account and accelerating your payments where possible.

2. Using the Service

If you choose to enable the Service, Zūm Rails will ask you to connect your bank account. If you connect your bank account, you will provide your bank credentials (including your username and password) to Zūm Rails' ("Service Provider"), who will only use your credentials to retrieve bank account data for your requested transactions, including the following:

• contact information (such as your name, email address, phone number, and address), and
• account details (such as your account type and bank, branch, and account numbers).

What is collected from your account will vary depending in part on what your bank makes available. Zūm Rails will then store and use this information to better support your future requested payments with us, including by verifying your bank account and accelerating your payments where possible

Zūm Rails will also transfer to its banking partner the account details in order to debit your account at the time of your requested payments. By connecting your bank account, you also provide Zūm Rails with the authority to share certain account details with us (in the case of your account number, we will only receive the last 4 digits) to support your customer relationship with us, such as information for record keeping.

The API, or similar service, is an essential component of the Service and you cannot proceed with the Service unless you agree to use the API or similar service. In the event that the Zūm Rails API is unavailable, you agree that Zūm Rails will be entitled to select a replacement Service Provider for the time period in which the Zūm Rails API is unavailable. Zūm Rail will be solely liable to you for any damages, losses, or otherwise resulting from its use of a replacement Service Provider.

3. Data Privacy

By using the Service, you consent to the collection, use, disclosure, and retention of your personal data. You confirm that the information you are providing to Zūm Rails has no mistakes and is your correct information. Zūm Rails has its own privacy policy and for more information, please visit their website (https://zumrails.com/privacy-policy). Neither Instacoin ATM nor Zūm Rails will sell or rent your personal data. Zum Rails may use your data in an anonymized manner (without identifying you) for any purpose permitted under applicable law. Zūm Rails is not responsible or liable for the use, disclosure, or retention of your personal data by Instacoin ATM and Instacoin ATM is not responsible or liable for the use, disclosure, or retention of your personal data by Zūm Rails.

If you would like to exercise any of your privacy rights, please contact Instacoin ATM directly. Please contact Instacoin ATM regarding inquiries concerning canceling or stopping payments.

4. Grant of Power of Attorney

You grant Zūm Rails a limited power of attorney, and you appoint Zūm Rails as your attorney-in-fact and agent in all capacities to access your selected account(s), retrieve and store information as described above, to provide you the Service and as permitted by applicable laws and regulations. You agree that when Zūm Rails accesses and retrieves your information from your selected account(s), Zūm Rails is acting as your agent, and not the agent of any third-party banks. You agree that third-party banks shall be entitled to rely on the foregoing authorization, agency, and power of attorney granted by you. You understand and agree that the Service is not endorsed or sponsored by any third party whose account(s) are accessible through the Service. The power of attorney that you grant Zūm Rails may be revoked at any time by deleting the information you shared with Zūm Rails, as the case may be, or by otherwise discontinuing use of this Service.

5. Interac and the Service

If you are using the Service in conjunction with Interac, you are not permitted to initiate or receive any third-party transactions. We reserve the right to terminate, suspend or revoke access to the Service under Section 14 if you engage in such transactions. We also may close your account.

6. Credit Card

The Service is provided through a relationship by and between Zūm Rails' merchant and Zūm Rails for the purpose of providing credit card and visa debit processing services to end user. For purposes of ensuring smooth and secure card processing services, Zum Rails may collect, retain and store certain necessary end user details and information. Such details and information may include, but are not limited to, personal identifiable information such as:

• (a) First and Last Name of End User as it appears on the card used (Credit Card)
• (b) Elements of the PAN; and
• (c) Sensitive Authentication Data (SAD): we do not store SAD, it is only used to initiate transaction with payment service provider

Due to security, legal and privacy best practices, we are unable to disclose in our Terms of Service what specific elements of PAN or SAD are collected and/or stored.

7. Zūm Rails' Role

The Service is a way of verifying your bank account and facilitating payments for Instacoin ATM, but it does not change anything else about your relationship with Instacoin ATM or your bank or financial institution. You are ultimately responsible for complying with the agreements that govern your relationship with Instacoin ATM, your relationship with your bank or financial institution accounts, and that govern the purchases you make using the Service. Also, Instacoin ATM is the one that is responsible for making the deposited funds available in the selected Instacoin ATM account when you use the Service. Zūm Rails uses reasonable efforts to keep your financial data secure.

8. Proprietary Rights

Using the Service does not grant you any intellectual property, proprietary, or other rights to the Service. Furthermore, you agree not to reverse engineer, disassemble, decompile, derive or otherwise transform, or attempt any of the foregoing, any of the technology used to provide the Service, whether owned or licensed by Instacoin ATM, Zūm Rails, or any of its Service Providers.

9. Representations and Warranties

For Individuals:

By using the Service you represent and warrant that you:

• (a) are at least the age of majority (which in most jurisdictions in Canada, this is either 18 or 19 years old) in the jurisdiction in which you are located;
• (b) will not use the Service for any fraudulent, unlawful or abusive purpose; and
• (c) you have the lawful right to authorize Zūm Rails to access your bank account, or your company's bank account, as the case may be, and to use your financial data

For Sole Proprietorships, Partnerships and Corporations:

By using the Service you represent and warrant that you:

• (a) it is a sole proprietorship/partnership/corporation, duly organized, validly existing and in good standing;
• (b) it has the full right, power and authority to enter into these terms;
• (c) your acceptance of these terms have been duly authorized by all necessary action;
• (d) The acceptance of these terms will not violate, conflict with, require consent under, or result in any breach or default under (i) any of its organizational documents (including its partnership agreement, its certificate of incorporation and by-laws, as applicable), (ii) any applicable laws or (iii) the provisions of any contract or agreement to which it is a party or to which any of its material assets are bound.

10. Disclaimers

The laws in some jurisdictions, including Quebec, prohibit or limit the disclaimer of certain warranties and conditions or the exclusion or limitation of certain liabilities, and so the disclaimers and liability exclusions and limitations in these Terms of Service might not apply to you.

The Service, including all content, software, functions, materials, and information made available on, provided in connection with or accessible through the Service, are provided "as is" and "as available". To the fullest extent permissible by law, neither Instacoin ATM, Zūm Rails, nor their affiliates, and their agents, merchants or independent contractors and service providers (the "Disclaiming Entities"), make any representation, warranty, condition or guarantee, of any nature or kind whatsoever, whether express, implied or statutory, for the Services or the content, materials, information, and functions made accessible by the Service, including without limitation the timing of delivery of funds, whether or not the timing was in the control of Instacoin ATM or Zūm Rails, or for any breach of security associated with the transmission of sensitive information through the Service. Each Disclaiming Entity disclaims without limitation, any representation, warranty, condition, or guarantee of any nature or kind with respect to the Service, non-infringement, merchantability, or fitness for a particular purpose. The Disclaiming Entities do not warrant that the functions contained in the Service will be uninterrupted or error-free. The Disclaiming Entities shall not be responsible for any service interruptions, including, but not limited to, system failures or other interruptions that may affect the receipt, processing, acceptance, completion, or settlement of payment transactions. Notwithstanding anything to the contrary in these Terms of Service, you agree that you are using the Service at your own discretion and at your own risk, and you are solely responsible for any damage to, or loss of information from your computer or mobile device, that results from the download of any Data. No advice or information, whether oral or written, obtained by you from Instacoin ATM or Zūm Rails through or from the Service will create any representation, warranty, condition or guarantee not expressly stated in these Terms of Service.

11. Limitations of Liability; Force Majeure

To the maximum extent permitted by applicable law, in no event, and under no circumstances shall any Disclaiming Entity be responsible or liable to you or any third party under any circumstances for any indirect, consequential, special, punitive or exemplary, damages or losses, including but not limited to damages for loss of profits, goodwill, use, data, or other intangible losses, which may be incurred in connection with the Service, any Disclaiming Entity, or arising from or relating to these Terms of Service, any goods, services, or information purchased, received, sold, or paid for and facilitated by the Service, unauthorized access to or alteration of your transmissions or data, or any other matter relating to the Service. This section 10 is a comprehensive exclusion and limitation of liability and applies to liability under any theory (including contract, tort, strict liability, and statutory liability), regardless of any negligence or other fault or wrongdoing (including fundamental breach or gross negligence) by or on behalf of any Disclaiming Entity or any of its personnel, even if other remedies are not available or do not adequately compensate for the loss or damage, even if a Disclaiming Entity knows or ought to have known of the possibility of the loss or damage being incurred, and regardless of whether or not the loss or damage was foreseeable. Without limiting the foregoing, and to the maximum extent permitted by applicable law, in no event, and under no circumstances shall the Disclaiming Entities' total cumulative liability related to the Service, any Disclaiming Entity, or arising from or relating to these Terms of Service exceed $10 CAD dollars. Each party acknowledges that the other party has entered into these Terms of Service relying on the limitations of liability stated herein and that those limitations are an essential basis of the bargain between the parties. In addition to and without limiting any of the foregoing, no Disclaiming Entity shall be liable or responsible to you, nor be deemed to have defaulted under or breached these Terms of Service, for any failure or delay in fulfilling or performing any term of these Terms of Service, when and to the extent such failure or delay is caused by or results from acts beyond the Disclaiming Entity's reasonable control, including, without limitation, the following force majeure events ("Force Majeure Event(s)"): (a) acts of God; (b) flood, fire, earthquake, tsunami, epidemics, pandemics including the 2019 novel coronavirus pandemic (COVID-19), or explosion; (c) war, invasion, hostilities (whether war is declared or not), terrorist threats or acts, riot, or other civil unrest; (d) government order or law; (e) actions, embargoes, or blockades in effect on or after the date of this Agreement; (f) action by any governmental authority; (g) national or regional emergency; (h) strikes, labour stoppages or slowdowns, or other industrial disturbances; (i) shortage of adequate power or transportation facilities; and (j) other similar events beyond the reasonable control of the Impacted Party.

12. Governing Law and Disputes

These Terms of Service, the subject matter of these Terms of Service (including the Service), and all related matters will be governed by the laws of the Province of Ontario and applicable federal laws of Canada, excluding any rules regarding conflict of laws that would lead to the application of any other laws. These Terms of Service shall not be governed by the United Nations Convention on Contracts for the International Sale of Goods. Except to the extent prohibited by applicable law, all disputes arising from, connected with, or relating to these Terms of Service, the subject matter of these Terms of Service (including the Service) or any related matter will be resolved before the courts of Ontario sitting in the City of Toronto, Canada, and the parties each hereby irrevocably submit and attorn to the jurisdiction of those courts in respect of those matters.

13. Modification of Terms of Service; Notices

We have the right to change or add to these Terms of Service at any time, solely with prospective effect, and to change, delete, discontinue, or impose conditions on the use of the Service by posting such changes on our website or any other website we maintain or we own. We may provide you with notice via email, postings on our website, or through other reasonable means. If you are an existing user of the Service, the changes will come into effect as of the effective date indicated on the notice, and your use of the Service after we notify you of any such changes constitutes your acceptance of the modified Terms of Service. In the event that you do not agree with any such modification, your sole and exclusive remedy are to terminate your use of the Service. You can access a copy of the current terms of these Terms of Service on our website at any time. You can find out when these Terms of Service were last changed by checking the "Last updated" date at the top of these Terms of Service.

14. Assignment

You may not assign these Terms of Service or any rights or obligations hereunder, by operation of law or otherwise, without our prior written approval and any such attempted assignment shall be void. We reserve the right to freely assign these Terms of Service and the rights and obligations hereunder to any third party without your consent or any notice to you. Subject to the foregoing, these Terms of Service shall be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, personal representatives, successors, and permitted assigns.

15. Termination, Suspension, or Revocation of Access

At any time, Instacoin ATM may terminate these Terms of Service and suspend or revoke your access to the Service with or without notice and for any or no reason, including in the event of a suspected, attempted, or confirmed breach of your obligations pursuant to these Terms of Service.

16. Survival

Upon termination of your use of the Service or termination of these Terms of Service for any reason, in addition to this section, the following sections shall survive termination: Sections 6 through 15.

17. Miscellaneous

Instacoin ATM's failure to exercise or enforce any right or provision of these Terms of Service will not be considered a waiver of that right or provision. If any provision of these Terms of Service is held by any court of competent jurisdiction to be unenforceable or invalid for any reason, then that provision will be deemed severed from these Terms of Service and the remaining provisions will continue in full force and effect and remain binding and enforceable between the parties unless as a result of the severance these Terms of Service would fail in their essential purpose. Headings are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section. These Terms of Service constitute the entire agreement between you and Instacoin ATM with respect to the use of the Service. These Terms of Service describe the entire liability as between you and Instacoin ATM, and set forth your exclusive remedies, with respect to the Service. These Terms of Service are not intended and shall not be construed to create any rights or remedies in any parties other than you, Instacoin ATM, and Zūm Rails, and no other person will have the ability to assert any rights as a third-party beneficiary under these Terms of Service. No changes may be made to these Terms of Service except in accordance with Section 12. These Terms of Service do not limit any rights that Instacoin ATM or Zūm Rails may have under trade secret,

Effective Date: May 8, 2025

Transacting with Instacoin ATM Group - Our Terms of Use

1. Who We Are

You are dealing with Instacoin ATM Canada Inc. ("Instacoin Canada") if you use or access any service provided at our kiosks anywhere in Canada except Quebec.

You are dealing with Instacoin ATM Quebec Inc. ("Instacoin Quebec") if you access or use any service provided at our kiosks in Quebec.

In these Terms of Use, we refer to Instacoin Canada and Instacoin Quebec, together, as "Instacoin ATM Group" or "Instacoin ATM", or as "we", "our" or "us".

Instacoin Canada and Instacoin Quebec is each a business corporation, incorporated under Canadian federal law, and is part of the "Instacoin Group".

Because our activities involve "dealing in virtual currencies," we are registered under, and must comply with, Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the "PCMLTFA"). Instacoin Quebec is also registered under and must comply with Quebec's Money-services Businesses Act (the "MSBA"). Businesses such as ours are sometimes referred to as "money services businesses" or "MSB's". MSB's must monitor, record and report activities and transactions in accordance with the PCMLTFA and the MSBA, laws governing sanctions, restrictions on dealings with Politically-exposed Persons, Canada's Criminal Code, and other relevant law relating to money laundering ("Anti-Money Laundering Law"). Reports and other information may be given to the Financial Transactions and Reports Analysis Centre of Canada ("Fintrac") or to Revenu Québec, or to both.

To comply with applicable laws, we may from time to time request, and you agree to provide, information confirming your identity and the purpose of the transactions that you carry out or intend to carry out through our kiosks or website. Your failure to provide the information requested ,may result in the loss of all rights, benefits and privileges that you earned pursuant to our Instapoints Program.

2. What We Do

We buy and sell selected virtual currencies at kiosks across Canada. All our transactions are carried out for our own account. We do not act as an agent or depository, or in any other capacity, for any third party including any buyer or seller of virtual currencies.

Although our kiosks are sometimes called "Bitcoin ATM's" or "Cryptocurrency ATM's" or using other terms that suggest we operate an "ATM", we do not offer "automated teller services" or any other service dependent on maintaining an account with us. When you deal with us, you do so for the purpose of buying or selling virtual currencies and you are not depositing to, or Withdrawing, or making any payment from, any account with us. Our business is very different therefore, from that of conventional financial services providers such as banks, trust companies or credit unions.

Some transactions with us may be initiated on our website or involve consulting our website. However, all transactions must be concluded at one of our kiosks and this will determine whether you are dealing with Instacoin Canada or Instacoin Quebec.

We may refer to a person who transacts any business with us at a kiosk, or who visits our website or contacts us, to buy or sell virtual currencies, as a "customer". In these Terms of Use, customers may also be referred to as "you" or "your", or using similar terms.

3. You Agree to our Terms of Use

When you transact any business with us, access our website, or contact us, for the purpose of buying or selling virtual currencies at one of our kiosks, you agree to our Terms of Use as explained in this document. These Terms of Use govern all our interactions with you. If any information on our website or otherwise made available to you conflicts with these Terms of Use, these Terms of Use prevail.

Titles in our Terms of Use are for reference only and do not form part of any agreement with you. Capitalized terms used in our terms and conditions are defined where they are first identified in quotation marks (" ").

Our Terms of Use may change from time to time. We endeavour to alert you of any material change. Regardless of whether any notice was given to you, our Terms of Use, including any changes, will govern.

An agreement with you is subject as well to the law of the jurisdiction in Canada where you reside. If you use or access any service in Quebec and have chosen to use the English-language, you agree that you wish to receive all documents and communications from us in English.

4. Do You Qualify to Buy or Sell Crypto?

We sell or buy Eligible Crypto only if a customer is qualified. To qualify to transact with us:

1. You must be an individual (physical person)
2. You must be a Canadian resident
3. You must be at least 18 years of age
4. You must be transacting for yourself and not for any other person or entity
5. You must have submitted, and we must be satisfied with, all information required as a condition of any transaction, including any information required under our AML-CTF Policy.
6. You must not be prohibited from transacting with us under Anti-Money Laundering Law or our AML-CTF Policy.

When you contact us about any transaction or conclude any transaction, you agree and warrant to us that you are a qualified for the transaction. You agree that we may make enquiries of third parties, including credit bureaus, to verify the information that you give us, and you acknowledge that we will report any information required by law to competent authorities, including Fintrac.

5. Eligible Crypto, Transaction Limits, Prices

Our website lists the virtual currencies we are willing to sell or to buy ("Eligible Crypto"). Only virtual currencies on the list of Eligible Crypto will be sold or bought. We may change our list of Eligible Crypto at any time and from time to time at our entire discretion.

We will fix the minimum and maximum amount of Eligible Crypto you may sell, and the daily limits on your transactions. These amounts will be dictated by market conditions and by the policies we have implemented to comply with Anti-Money Laundering Law (our "AML-CTF Policy). All amounts will be determined by reference to the price we are willing to pay or to accept for Eligible Crypto, denominated in Canadian currency.

If we receive an amount in Eligible Crypto that exceeds the maximum we are willing to buy or your transaction limits, we will return the excess to you after deducting transactions fees provided that we have the necessary information, and the amount is more than the transaction fees and our processing fee.

If you deliver less than the minimum amount of Eligible Crypto required to execute a transaction, we may process your transaction for the lesser amount or refuse to process your transaction and return your Eligible Crypto to you less transaction fees.

When you conduct a transaction with us, you agree that the transaction amount you have selected corresponds to the value or price of the Eligible Crypto you have bought or sold, and that no additional amount is payable despite any difference between the transaction amount and the price or prices of the Eligible Crypto on any market or from any third party.

6. You are Responsible for Your Transactions

You are responsible for your transactions with us. Do not buy or sell Eligible Crypto without informing yourself of the risks, including high volatility, limited liquidity, and legal uncertainty.

Your responsibility extends to your choice of how you receive and secure any Eligible Crypto you buy. You must choose a "wallet" and must take steps to ensure that no one else has access to the wallet. If you transfer any Eligible Crypto to a wallet that you do not own and control, or permit anyone but you to access or use the wallet, you are responsible for any loss you sustain.

Except in very limited circumstances where your transaction has not yet been processed, it is impossible to reverse a transaction. Transactions in virtual currencies are intended to be final and non-cancelable. If circumstances do permit, and you wish to reverse a purchase of Eligible Crypto, you must return the Eligible Crypto and pay any damages we have incurred as a result of changes in market prices.

7. Beware of Fraud

Regrettably, we sometimes learn that a customer has purchased Eligible Crypto to make a payment to someone the customer does not know or whose identity the customer has not verified. Payments in virtual currencies are similar to payments in cash. If you have not received the goods or services for which you are paying, or from someone you trust, or if you are asked to make a payment to any governmental authority or to settle any claim against you, do not make the payment. We do not control your transactions with others including payments you might make using virtual currencies purchased from us.

All our kiosks contain warnings about fraud. Our website also warns of fraud. You acknowledge that you have read and understood these warnings when you transact with us.

Effective Date: May 8, 2025

Instacoin ATM Group Privacy Policy

1. Who this policy applies to and what it covers

This Policy applies to individuals who register personal information or enter into any transaction with us using any kiosk, website, application (including mobile application"), software, or service of ours that hyperlinks to this Policy (we call these our "Services").

"We" and "us" and similar expressions refer to Instacoin Canada in the case of any individual accessing our services in any province or territory of Canada outside Quebec, and to Instacoin Quebec in the case of any individual accessing our services in Quebec.

Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third-party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.

Our Services are not aimed at children. We prohibit access to our services by anyone who is less than 18 years old.

2. Who we are

"Instacoin" and "Instacoin ATM" are licensed trademarks of the Instacoin Group. The Instacoin Group includes, among others, Instacoin ATM Quebec Inc. ("Instacoin Quebec") and Instacoin ATM Canada Inc. ("Instacoin Canada"). When we refer to Instacoin, we may use "we", "our", "us" and similar terms, and when we do, we mean Instacoin Canada where an operation is undertaken outside Quebec, and Instacoin Quebec where an operation is undertaken in Quebec.

Each of Instacoin Canada and Instacoin Quebec is a Canadian federal corporation. Because our activities involve "dealing in virtual currencies," we have registered under, and comply with, Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the "PCMLTFA"). Instacoin Quebec is also subject to and registered under Quebec's Money-services Businesses Act (the "MSBA"). Businesses such as ours are sometimes referred to as "money services businesses" or "MSB's". MSB's must monitor, record and report activities and transactions in accordance with the PCMLTFA, laws governing sanctions, restrictions on dealings with Politically-exposed Persons, Canada's Criminal Code, and other relevant law relating to money laundering, including the MSBA in Quebec ("Anti-Money Laundering Law").

Reports and other information are given to the Financial Transactions and Reports Analysis Centre of Canada ("Fintrac"), or to Revenu Québec, or to both.

3. What we do

We buy and sell selected virtual currencies at our kiosks across Canada. Purchases and sales are made for our own account. We do not operate an exchange or act as an agent for any customer, third-party buyer or seller of virtual currency.

For legal and historical reasons, our kiosks are sometimes referred to as "ATM's". However, our Services are different from the services offered by conventional ATM networks. A conventional ATM is an "automated teller machine". Conventional ATM's give customers access to an account they maintain with a financial institution, just as a teller would at the branch of a financial institution. We are not a financial institution and do not take deposits or provide for withdrawals or payments from any customer account.

Some of our transactions may be initiated remotely, by accessing tools on our website. These tools serve only to alert us to orders that may be processed at one of our kiosks. We do not process any transaction online.

We may refer to a customer who uses the Services or contacts us, as "you" or "your", or using similar terms.

We make use of personal information as instructed or authorized by our customers. For all enquiries or instructions relating to personal information, customers may contact us as follows:

Privacy Policy Contact:

Instacoin ATM Canada Inc.
#2, 2207 90B Street SW
Edmonton AB T6X 1V8
Canada

Attention: Privacy Officer

1-888-997-6731 (Canada, except Québec)
1-855-906-4296 (Québec)

Email

4. Sources of personal information

We may collect personal information about you from your interactions with us, including your use of the Services. We may also collect information from certain third parties and other sources (including publicly available sources where permissible).

We may obtain personal information about you:

• From your use of the Services and interactions with us (please note that, for compliance and quality assurance purposes, we may record or monitor your use of one of our kiosks, and your telephone calls to our representatives)
• From our servers, logs and other technologies that automatically collect system/device and usage information to help us administer, protect and improve our Services, analyze usage and improve users' experience
• From Instacoin Direct and our other affiliates with whom you have conducted any business
• Through cookies and similar technologies if included on our Services
• From payment networks and partners and service providers who work with us in relation to your Service
• From publicly available sources such as blockchains and the internet, public websites, open government databases or other data in the public domain, to help us verify and maintain data accuracy and provide and enhance the Services

5. Types of personal information we collect

Some transactions with us may require us to obtain and validate personal information, including information needed to verify that all transactions limits are respected and that our Services are not being used to abet criminal activity. We may also be required to obtain, validate, and report personal information about you and the Services we provide to you under Anti-Money Laundering Law.

Depending on several factors, including the amount of any transaction at one of our kiosks, and the cumulative daily volume of transactions by a customer or at a kiosk, we collect and verify personal information including the following:

• Transactions with us or transactions and accounts with Instacoin Direct
• Wallet and public blockchain addresses, transactions, or accounts
• Name and contact data, such as, first and last name, email address, postal address, phone number, and other similar contact data
• Information required by cybersecurity services
• Device information, such as information about your device including IP address, location or provider
• Payment information, such as your means of payment or our payments to you

6. Use or disclosure of personal information

We use or disclose personal information to provide and improve Services and for other purposes that are in our legitimate interests, as well as for compliance purposes, including compliance with Anti-money Laundering Law.

When we use personal information about you, we do so in order:

• To perform the Service you have requested or to comply with the terms and conditions governing the Service
• To furnish information required by third parties who provide services to us or to you in accordance with the terms and conditions governing our Services
• To take steps or refrain from taking steps that you have authorized
• To comply with the law, including Anti-Money Laundering Law and any lawful warrant or seizure, and to comply with the policies we have implemented under Anti-Money Laundering Law (our "AML-CTF Policy).

You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information.

7. No Marketing Use

We do not use, process or sell any personal information for commercial purposes unrelated to our Services. We do not carry out or make available personal information for interest-based advertising campaigns. Whenever required by law, we will give you the option to opt out of any marketing messages we might deliver.

8. Security and retention of personal information

We take the security of personal information seriously and we use appropriate technologies and procedures to protect personal information (including administrative, technical, and physical safeguards) according to the risk level and the Service provided.

We retain your information where required in accordance with our records retention schedule based on a classification scheme consisting of business functions, record classes, and record types, including legal limitation or prescription periods and outstanding legal proceedings.

9. Your privacy rights

You may have rights under data protection, privacy or other applicable law to have access to your personal information, and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. We will honor your rights under applicable law. These rights may include:

• The right to make a written request for details of your personal information and a copy of that personal information
• The right to have inaccurate information about you corrected or removed
• The right to request that your personal information is only used for restricted purposes (in which event Services may be restricted)

In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.