Ninjapay(Ninja Labs- FZCO) a company established in Dubai freezone, UAE, bearing registration number DSO FZCO 17720 with registered seat at Dubai Silicon Oasis, DDP, Building A1, Dubai, UAE is a legal organization which endeavors to ensure all of its policies and procedures are fully compliant with the Privacy and Data Protection Act 2014 (Victoria) and the GDPR (General Data Protection Regulation 2016/679) requirements. We also endeavor to treat your privacy concerns very seriously.

<aside> 💡 18Aug 22: Having regard for the safety of the users and due to the legal requirements, The European Union, The United States of America and other countries, Ninja Labs- FZCO has implemented and started to use KYC policy (customer’s identification), AML / CTF (combating money-laundering and terrorist financing) as it is required from banks and other financial institutions.

The purpose of those policies is an effective combating of money-laundering and terrorist financing (AML / CTF) on our platform by proper identification of actual users of our accounts and supervision of their transactions. We shall identify and cease transactions made not only to purchase/sell a cryptocurrency but made mainly to hide the criminal origin of money, finance illegal activity or other unlawful behaviors.

Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce to you some of the general rules and stipulations of our policies which directly concern you and affect the services we render.

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User’s identification

<aside> đź’ˇ 18Aug 22: In the first place, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to do transactions on our platform. This is the reason why we collect ID scans, which authenticity is verified with special software of professional external providers.

We require sending “selfie” or a recording of yours with ID document in order to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is made with the use of special software of professional external providers or, in case of doubts, done manually by our customer support services.

In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues that arose.

If we cannot determine, beyond a reasonable doubt, that the documents you provided belong to you and are the authentic we won’t be able to let you execute any transactions.

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What personal information does Ninjapay collect and process?

email address
name
gender
date of birth
home address
phone number
nationality
device ID
a video recording of you and a photographic image
transactional information

User’s identification – Companies

<aside> 💡 18Aug 22: In case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company.

Since standards regarding governmental documentation of legal entities are different in each country, every time the verification of such users is done “manually” and is considerably more time-consuming.

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Transactions’ monitoring and supervision

<aside> đź’ˇ 18Aug 22: Using our proprietary software we also analyze all transactions that take place on our platform looking for suspicious and unusual behaviors. And with the help of third parties we raise a red flag wherever a suspicious transactions or activity is detected. Monitoring is facilitated basis transaction monitoring rules prescribed by Financial Intelligence Units (FIU). Along with transactional data, information of customer current/historical profile is presented for informed decision making. The solution helps in detecting suspicious activity from the following perspective:

  1. Anti money laundering (AML)
  2. Terrorist financing (CFT)
  3. Surveillance
  4. Insider trading

Such selected transactions are analyzed by our AML specialists and evaluated if they do not provide significant AML / CTF risks or if they needed to be ceased and clarified with the User.

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Additional verification

<aside> 💡 18Aug 22: When your trade volume rises, our AML / CTF verification duties increase as well. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your personal results in qualifying you as a person imposing significant AML / CTF risk.

In such cases, we can require additional documentation proving your real, exact place of residence, education, occupation, as well as the source of money you are using on the platform.

Our third party partners assists screening Institutions like us to be compliant with client due diligence process of name screening also known as sanctions screening or AML check as per Prevention of Money Laundering Act (PMLA). The solution comes with a combination of sophisticated matching engines that can help in detection of terrorists, probable financial crime profiles/ fraudulent customers with provided 50+ watchlist feeds that covers:

  1. International & domestic sanctions (UAPA, UNSC, OFAC,…)
  2. Regulatory feeds
  3. Watchlist provided by statutory bodies
  4. Watchlist provided by stock exchanges
  5. Politically Exposed Person (PEP)

Unfortunately, If our AML specialists decide information received from you don’t clarify our doubts, we will be obliged to end our cooperation with you or even report your transactions to relevant authorities.

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Basic AM / CTF Rules

<aside> đź’ˇ 18Aug 22: Our operating rules include inter alia as follows:

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