Terms and conditions

Acceptance of Terms of Use - Zesions.com.
By using the Zesions website ("Site"), registering for an Account at https://zesions.com ("Account") or using any other Zesions Services, you ("you, your or yourself") you agree to accept and comply with the terms and conditions. Conditions of use set forth below ("Terms of Use"). You should read all Terms of Use carefully before using this Site or any of the Zesion OÜ Services.

As used in these Terms of Use, "Zesion OÜ" refers to the company, Registered in the Estonian Trade and Companies Register under number 14759852, with its registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158 /2-88, 11317 in Estonia. With main headquarters in Poland. With cryptocurrency business registration certificate number 2401-CKRDST.4225.77.2023. Reference number RDWW-647 of Poland, is placed under the prudential supervision of the Polish Financial Sector Surveillance Commission.

References to Zesions are also references to its owners, directors, investors, employees.
Zesion OÜ is a company with an office in Estonia. Depending on the context, “ Zesion OÜ” may also refer to the services, products, website, content or other materials (collectively “ Zesions”).
Zesions allows buyers and sellers to use their local currency to buy and sell Cryptocurrencies such as (Bitcoin BTC, Ethereum ETH, Tether USDT, Ripple XRP, Cardano ADA, Litecoin LTC, USD Coin USDC, EOS EOS, TRON TRX).

Buy cryptocurrencies on Zesions with fiat money via bank transfer or card.
The Buyer enters in the platform's purchase form the amount of cryptocurrencies they wish to purchase, their public wallet address to receive the cryptocurrencies, the platform will automatically display the required amount of euros.
After continuing, the member will go to the next page with the Zesion OÜ bank details, to which they must make a bank transfer in immediate accreditation mode using their personal account, with a time limit of 20 minutes to upload the proof of payment file. payment and mark paid, if you cannot complete the payment within this period of time, the window closes and you will have to perform the aforementioned steps again.
In the event that the funds are not immediately credited to the Zesion OÜ bank account, the order will become pending, as soon as the funds arrive, the user must set up a new order with the fiduciary amount that was sent to obtain the price current cryptocurrency and will be sent to the data provided on the platform by the client.
Once the payment process is complete, and after the money has arrived in the Zesion OÜ bank account, the user will receive a cryptocurrency transfer to their wallet and will receive a notification with their completed transaction.
Zesion OÜ is not responsible if the destination address indicated by the Member in the purchase form is incorrect or if the Member cannot manage the private key that authorizes trading with the purchased cryptocurrencies.
Purchases are made by bank transfer. The Buyer must send the payment receipt to Zesions through the platform. The conversion price will be set at the time of opening order and does not change during payment receipts to Zesions bank account.
Bank transfers must match the registered Member and details previously provided. Otherwise, additional information may be required, including the return of payment, the resulting costs being borne by the client plus a fine of one hundred and fifty euros (€150).

Sell cryptocurrencies to Zesions for fiat money via bank transfer
The Seller enters in the sales form the desired amount of cryptocurrency to sell and the platform automatically displays the amount of euros that will be received or the client can enter in the form the desired amount of euros that will be received, then the platform will automatically display the required amount of cryptocurrencies. All member cryptocurrency transfers to the Zesions platform can be verified on the blockchair.com search engine.
The Seller will receive payment by bank transfer, under the terms specified below. The seller must provide the details of his bank account in which he wants to receive fiat money in euros and check the validation before giving the order to send euros to his bank account.

Depending on your country of residence, you may not be able to use all features of the Site.
It is your responsibility to follow the rules and regulations applicable in your country of residence and/or country from which you access this Site and Services. Provided that you accept and comply with these Terms of Use, Zesions grants you the personal right, non-exclusive, non-transferable, non-sublicensable and limited access to and use of the Site and the Service.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF USE WRITTEN IN THIS AGREEMENT, DO NOT ACCESS THIS SITE AND DO NOT USE THIS SERVICE.
By registering an account, you expressly represent and warrant:
That you have accepted these Terms of Use, that you are at least 18 years of age and have full capacity to accept these Terms of Use and conduct a transaction involving cryptocurrency.

RISKS
Trading goods and products, real or virtual, as well as virtual currencies involves significant risk. Prices may fluctuate on any given day. Such price fluctuations may increase or decrease the value of your assets at any given time. Any currency, virtual or not, can be subject to large changes in value and may even become useless. There is an inherent risk that losses will occur as a result of buying, selling or trading anything on a market.
Cryptocurrency trading also has special risks that are not generally shared with official currencies, goods, or commodities on an exchange. Unlike most currencies backed by governments, other legal entities, or commodities like gold or silver, cryptocurrencies are a unique type of “fiat” currency, backed by technology and trust. There is no central bank that can issue more currency or take corrective action to protect the value of cryptocurrencies in a crisis.
Instead, cryptocurrencies are a still autonomous and largely unregulated global system of currency companies and individuals. Traders rely on a digital, decentralized and partially anonymous system that relies on peer-to-peer networks and cryptography to maintain its integrity.
Cryptocurrency trading is often susceptible to irrational, rational bubbles or loss of confidence, which could collapse demand relative to supply. For example, trust could collapse in cryptocurrencies due to unexpected changes imposed by software developers or others, a government crackdown, the creation of superior competitive altcoins, or a deflationary or inflationary spiral. Trust could also collapse due to technical problems: if the anonymity of the system is compromised, if money is lost or stolen, or if hackers or governments can prevent transactions from settling.
There may be additional risks that we have not anticipated or identified in our Terms of Use. You should carefully evaluate whether your financial situation and risk tolerance are suitable for buying, selling or trading Bitcoins.

We use our banking providers to receive client funds and make payments. Our banking providers DO NOT transfer, exchange or provide any cryptocurrency related services.

LIMITED RIGHT OF USE
Unless otherwise specified, all Materials on this Site are the property of Zesion OÜ and are protected by copyright, trademark and other applicable laws. You may view, print or download one copy of the Materials from this Site on any computer for your personal, informational or non-commercial use, provided you comply with all copyright and other proprietary notices.
The trademarks, service marks and logos of Zesions and others used on this Site ("Trademarks") are the property of Company and their respective owners. The software, text, images, graphics, data, prices, operations, charts, graphs, video and audio used on this site belong to Zesions. The trademarks and materials must not be copied, reproduced, modified, republished, uploaded, posted, transmitted, scraped, compiled or distributed in any form or by any means, whether manual or automated. The use of such Materials on any other Site or networked computer environment for any other purpose is strictly prohibited; Any such unauthorized use may violate copyright, trademark and other applicable laws, and could result in criminal or civil penalties.

Maintaining your account
This site is for your personal, non-commercial use only. We are vigilant in maintaining the security of our Site and Service. By registering with us, you agree to provide Zesions with current, accurate and complete information about yourself, as prompted by the registration process, and to keep such information up to date. You further agree that you will not use any Account other than your own, access any other Member's Account at any time, or assist others in gaining unauthorized access.
Creation or use of Accounts without obtaining the prior express permission of Zesions will result in immediate suspension. 

data of said Accounts, as well as of all pending purchase/sale orders. Any attempt to do so or to assist others (Members or otherwise), or the distribution of instructions, software or tools for that purpose, will result in the termination of such Members' Accounts. Termination is not the exclusive remedy for such a violation, and Zesions may elect to take further action against you.
You are also responsible for maintaining the confidentiality of your Account information, including your password, and for protecting your own Cryptocurrencies and all activities, including transactions, that are posted to your Account. Any actions on the site, transactions, orders and operations initiated from your account or using your password (1) will be deemed to have been performed by you, and (2) are irrevocable once validated using your password or performed through your account. If there is suspicious activity related to your account, we may, but are not obligated to, request additional information from you, including authentication documents, and freeze any transactions pending our review. You are required to comply with these security requests or accept the termination of your account through the settings area or by the support area. The account of any member who violates these rules may be terminated and the member will be liable for any losses incurred by Zesions or any user of the site.


Finally, you agree that you will not use the Service to conduct criminal activities of any kind, including, but not limited to, money laundering, illegal gambling operations, terrorist financing, malicious hacking, or any criminal or illegal activity.

The minimum trade allowed is 300 EUR.

Individual client
The maximum trade allowed is 5,000 EUR.

Commercial Client
The maximum trade allowed is 10,000 EUR.

You can request an increase in limits through the support area.

VERIFICATION OF ACCOUNTS
The creation and use of your account is subject to verifications, as required by legal and regulatory obligations in force at Zesions. You agree to provide us with the information we request for the purposes of identity verification, compliance with know-your-customer regulations, as well as the detection of money laundering, terrorist financing, fraud or any other financial crime. The information requested may include personal data (see our Privacy Policy) By providing us with the information we request, you confirm that it is true and accurate, and you agree to inform us of any changes to such information. Your account will be locked until we are satisfied with the information you have provided and determine, in our sole discretion, that it is sufficient to validate your account. In the meantime, you will not be permitted to cancel your Account or request deletion of Personal Data processed in the course of verification operations.
 
Termination
You may terminate this agreement with Zesions and close your account at any time, following the settlement of any pending orders.
You also agree that upon notice, in its sole discretion, terminate your access to the Site and your Account, including, without limitation, your right to: limit, suspend or terminate the service and Member Accounts; prohibit access to the Site and its content, services and tools; delay or delete hosted content; and take technical and legal measures to keep Members off the Site if we suspect that they are creating problems or potential legal liability, infringing the intellectual property rights of others, or acting inconsistently with the letter or spirit of these Terms of Use. Additionally, we may, in appropriate circumstances and at our discretion, suspend or terminate Member Accounts for any reason, including, but not limited to.

We expressly reserve the right to cancel and/or cancel Accounts that have not been verified by the Member despite good faith efforts by Zesions to contact them to obtain such verification ("Unverified Accounts").

SERVICE AVAILABILITY
All services are provided without warranty of any kind, whether express or implied, and in particular without implied warranties of merchantability and fitness for a particular purpose. We do not guarantee that this site will be available 100% of the time to meet your needs. We will endeavor to provide the Service to you as quickly as possible, but there is no guarantee that access will not be interrupted or that there will be no delays, failures, errors, omissions or loss of transmitted information.
We will use reasonable efforts to ensure that you can access the Site in accordance with these Terms of Use. However, we may suspend use of the Site for maintenance and will use reasonable efforts to provide notice. You acknowledge that this may not be possible in an emergency and accept the risks associated with the fact that you may not always be able to use the Site or conduct urgent transactions with your Account.

EXTERNAL WEBSITES
Zesion OÜ is not responsible for any external or third-party websites that you may access through the Site. From time to time, the Zesion OÜ website may provide references or links to other websites ("External Websites"). We do not control these external websites or third party sites or any of the content contained therein. You agree that we are in no way responsible for any External Websites referenced or linked from the Zesion OÜ website, including, but not limited to, website content, policies, faults, promotions, products, opinions, advice, statements, prices, activities and advertisements, services or actions, and/or damages, losses, failures or problems caused, related to or arising from those sites. You must assume all risks associated with the use of such content.
External websites have separate and independent terms of use and related policies. We ask that you review the policies, rules, terms and regulations of each site you visit. It is up to you to take precautions to ensure that whatever you select for your use is free of items such as viruses, worms, Trojan horses and other items of a destructive nature.

FINANCIAL ADVICE
For the avoidance of doubt, we do not provide any investment advice in connection with the Services described in these Terms of Use. We may provide information about the price, range and volatility of cryptocurrencies that are available on our platform and events that have affected the price of such cryptocurrencies, but this should not be considered and should not be construed as investment advice. Any decision to buy or sell Bitcoins is solely your decision and we will not be liable for any losses incurred.

FINANCIAL REGULATION
Zesions' business model and Service is to facilitate, through its cryptocurrency business services license. This specific service is currently regulated by Polish law.
 
EMAIL
Unencrypted email messages sent over the Internet are not secure and Zesions is not responsible for any damage caused by sending email messages in this manner. We suggest sending emails in encrypted formats; You can send us emails encrypted with PGP. Instructions and keys to do so are available upon request.
If you send us unencrypted or unsecured email or other communications, we may respond using the same channels and you accept the risks associated with them.

DATA PROTECTION
Privacy is very important for us. Full details of our Privacy Policy can be found at [Privacy Policy]. We recommend that you read the Privacy Policy carefully, so that you are aware of the data we collect, how we use it and with whom we share it.
 
Disclosures to legal authorities and authorized financial institutions
We may share your Personal Data with law enforcement, data protection authorities, government officials and other authorities when:
Required by law, compelled by subpoena, court order or other legal process.
We believe disclosure is necessary to prevent harm or financial loss.
Disclosure is necessary to report suspected illegal activity.
The disclosure is necessary to investigate violations of our Terms of Use or Privacy Policy.
For more information on how we process your Personal Data, please see the Privacy Policy.

JURISDICTION
The Terms of Use shall be governed by and construed in accordance with the laws of Estonia. The parties irrevocably agree to submit to the exclusive jurisdiction of the courts of Estonia.
 
Limitation of liability
 
To the extent permitted by law, Zesion OÜ does not will be liable for any damage, loss of profits, loss of income, loss of business, loss of opportunity, loss of data, indirect or consequential loss, unless the loss was suffered by negligence or intentional deception or fraud. Nothing in these Terms of Use excludes or limits the liability of either party for fraud, death or personal injury caused by its negligence, breach of terms implied by law or any other liability that cannot be limited or excluded by law. . Although Zesion OÜ strives to provide accurate and timely information on the Site, the Site may not always be entirely accurate, complete or current and may include errors. We may change or update the Site at any time without notice, and accordingly you should verify all information with independent sources before relying on it for any decisions or actions. You remain completely responsible for your decisions and actions.
To the extent permitted by applicable law, you agree to indemnify Zesion OÜ and its partners against any actions, liabilities, costs, claims, losses, damages, proceedings or expenses suffered or incurred if arising directly or indirectly from your use of the Sites. by Zesion OÜ. , your use of the Service or your violation of these Terms of Use.

DIVERSE
If we are unable to perform the Services described in the Terms of Use due to factors beyond our control, including, but not limited to, an event of force majeure, change in law or change in sanctions policy, we will not be responsible for the Services provided under this agreement during the period of time coinciding with the event.

Modification of Terms
Zesion OÜ reserves the right to change, add or remove portions of these Terms of Use at any time and at its sole discretion. You will be notified of any changes in advance through your Account. Upon such notice, it is your responsibility to review the modified Terms of Use. Your continued use of the Site following the posting of notice of changes to the Terms of Use means that you accept and agree to the changes, and that all subsequent transactions you make will be subject to the modified Terms of Use.

Definitions:
Account. The contractual agreement whereby a Zesion OÜ Member has accepted our Terms of Use and Privacy Policy, and received approval to use the Zesion OÜ Services, including the purchase and sale of Cryptocurrencies, and to conduct associated Transactions.
Bitcoins The peer-to-peer Internet currency described at http://bitcoin.org.
Buyer(s). Members who submit an order to purchase Bitcoins through the Service.
Seller(s). Members who submit an order to sell Bitcoins through the Service.
Commission . Refers to the fee payable to Zesion OÜ in each transaction, such as a purchase transaction or a sale transaction.
Members) . Refers to buyers and sellers, as well as any account holder.
Personal information . Information that identifies an individual, such as name, address, email address, business information and banking details. “Personal Data” does not include anonymous and/or aggregated data that does not identify a specific user.
Price. The "price per coin" that Zesion OÜ offer and the member agree to buy or sell Bitcoins, using the Service in a Bitcoin purchase Transaction. The price can only be expressed in euros paid by members to the Zesion OÜ bank account.
Services). The technological platform, functional rules and managed market allow sellers and buyers to buy and sell Bitcoins.



Transaction. Includes the following:



⦁ Purchase transaction. The agreement between the Buyer and Zesion OÜ to exchange fiat currency through the Cryptocurrency Service at a proportionate rate.
⦁ Sales transaction. The agreement between the Seller and Zesion OÜ to exchange Cryptocurrencies through the Service for fiat currency at a proportionate rate.
Transaction price. The total price and additional fee paid by the Buyer or Seller for each Transaction conducted through the Service. The current price of the Zesion OÜ service and the additional fee for each transaction reference here.

AML POLICY

This is the anti-money laundering and anti-terrorist financing policy (referred to as AML/CTF Policy) of Zesion OÜ, which operates the website https://zesions.com


Zesion OÜ is a privately held limited liability company incorporated under the laws of Estonia with registration number: 14759852 and registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158/2-88, 11317, Republic of Estonia. Zesion OÜ, hereinafter may be referred to as "Zesion OÜ", "We", "Our", "Company" and "N"us" and includes its owners, directors, investors, employees or other related parties. The terms "User", "You" and "Your" refer to a User of the online platform https://zesion.com.


In order to maintain uncompromising and reputable service provision, Zesion OÜ must follow strict rules on money laundering and anti-terrorist financing, governed by local and international laws and regulations. Zesion OÜ thus implements the current policy in accordance with:


DIRECTIVE (EU) 2018/843 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing , and amend Directives 2009/138/EC and 2013/36/EU;
The Polish Money Laundering and Terrorist Financing Law and other legal guidelines given by the Estonian Minister of Finance.
Any other applicable law in force in any territory that Zesion OÜ may be operating.


Zesion OÜ is always configured to follow the strictest rules and industry standards in any country in which it may have operations with the intention of preventing any type of illegal and criminal activities and any possible involvement of Zesion OÜ in such.


The anti-money laundering and anti-terrorist financing policy, which is part of the Zesion OÜ Terms and Conditions, requires mandatory compliance by the User. Users are required to read, review, understand and then accept the terms hereinafter before using or availing any of the Zesion OÜ Services.


Terms not defined herein shall have the same interpretation as in the Terms and Conditions and, in the absence thereof, for general use and understanding.



Definitions


"Applicable laws" means the law for the time being in force within the territory of any country in which Zesion OÜ may be operating.


"Beneficial owner" means:


The natural person who owns directly or indirectly more than 25% (twenty-five percent) of the shares of a legal entity, where indirectly means that the natural person has ownership of another legal entity who wholly or partially owns the entity subject to check.
The individual is entitled to more than 25% (twenty-five percent) of the profits.
The natural person has the power, directly or indirectly, to appoint or elect more than half of the members of the administrative or supervisory body and is also a shareholder.
The natural person owns more than 50% of the voting rights in the legal entity;
The natural person has the right to influence the legal entity as a result of an agreement or the entity's statutes.


"Identification document(s)" means:
National ID cards and passports and any other government-issued identification documents;
Documents that identify the registered address of a natural or legal person, such as, but not limited to, Bank Statement and Utility Bill; either
Any other documents that may be notified by Zesion OÜ from time to time.


"Politically exposed person" means any natural person who is themselves or is a family member or close associate of a natural person who is:


Head of State, head of government, minister and deputy minister or assistant minister;
Member of parliament or similar legislative bodies;
Member of the governing bodies of political parties;
Member of supreme courts, constitutional courts or other high-level judicial bodies, whose decisions are not subject to further appeal, except in exceptional circumstances;
Member of the audit courts or the boards of directors of central banks;
Ambassador, chargé d'affaires and high-ranking officer in the armed forces.
Member of the administrative, management or supervisory bodies of state companies.
Director, deputy director or board member or equivalent function of an international organization.


  "Sanctions lists" refer to lists of individuals, legal entities and entire countries that are involved, or suspected of being involved, in illegal and criminal activities. Such lists are, for example, provided by OFAC, EU, UN, HMT.


"Suspicious Transactions" refers to the following activities, whether attempted or executed:


Terrorist financing: transactions that, to a person acting in good faith, appear to be funds raised to be used, in whole or in part, by any terrorist or related organization, or to carry out any terrorist-related activities or terrorist acts.
Unusually complex: transactions that to a person acting in good faith appear to have been structured in an unusual or unjustified manner.
Purpose of Malafí De: transactions that to a person acting in good faith appear not to have been carried out for good faith purposes or do not have a sound economic basis.
Money laundering: Transactions that, to a person acting in good faith, appear to “clean up” criminal proceeds to conceal their illegal origins. Such profits are generally associated with the types of organized crime that generate huge cash profits, such as drug, weapons and human trafficking, as well as fraud.
 
Money Laundering Reporting Officer
Zesion OÜ appoints and duly authorizes the Money Laundering Reporting Officer (MLRO) to monitor the compliance of Zesion OÜ systems and controls with the current AML/CTF Policy, relevant legislation, regulations, standards and guidance of the industry. The MLRO has a sufficient level of seniority and independence.


The Officer has the right to interact with law enforcement authorities, who are involved in the prevention of money laundering, terrorist financing and other illegal activities.
 
User verification
The industry standard for combating money laundering, terrorist financing and any other financial criminal activity is customer due diligence (CDD). Zesion OÜ implements CDD in the form of requiring any natural person, who wishes to transact with fiat money on the Zesion OÜ platform, and any company/organization to verify, respectively, their identity and the identity of the beneficial owners of their company .

Following established Know-Your-Customer (KYC) rules, regulations and procedures, we request user-supplied information and identification documentation. For the purposes of verifying the identity of any User, Zesion OÜ may rely on appropriate and licensed third-party service providers to authenticate the Identification Documents and other incidental details provided by the User.

Each client, who has passed the verification procedure, can carry out transactions with fiat money on the Zesion OÜ platform only on the premise that he uses bank cards and bank or electronic money service accounts in his own name.



Identification of natural persons


Each natural person wishing to transact fiat money on the Zesion OÜ platform is required to identify themselves by providing:


Full name.
Birthdate.
Phone number.
Residence address.
Government-issued identification document, such as an identification card and international passport, that bears a photograph, date of birth, and personal identification number issued by your government.
Proof of residency for the resident, such as a utility bill or bank statement that is no older than 3 months.
A recent photo of themselves with their photo ID and application.


For natural persons with nationality or residence in a high-risk third country or, if considered appropriate, Zesion OÜ could also:


Require information about the User's source of funds and source of wealth;
Request information about the reasons for the transactions planned or carried out;
Carry out enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that require closer examination.



Identification of legal entities and final beneficial owners

General identity information

Every legal entity must pass a verification process before starting to use Zesion OÜ services, regardless of whether you will be transacting with fiat money or not. Must provide:


Name
Number registered in any national registry
Legal form in accordance with the law of the place of registration
Corporate headquarters address and management address
Certificate of incorporation
Articles / Memorandum of Incorporation
Bank statement no older than 3 months indicating the company address.


Additional verification measures
With respect to merchant account holders, we additionally apply the following enhanced customer due diligence measures:


Obtain additional information about the User, the beneficial owner(s) and any other person who may have access to the corporate account at Zesion OÜ, such as data on Politically Exposed Persons.
Obtain additional information about the intended nature of the business relationship;
Obtain information about the source of funds and source of wealth of the client and the s) beneficial owner(s).
Obtain information about the reasons for the transactions planned or carried out;
Obtain approval from senior management to establish or continue the business relationship.
Conduct enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting transaction patterns that require closer examination.

People with access to the corporate account at Zesion OÜ
Zesion OÜ also requires a letter signed by the board of directors, CEO, managing director or owner of significant control stating who has authority to trade on behalf of the company, including:


The full name of each merchant.
Role in the company.
Email.
Physical address.
Nationality.
Any personal Zesion OÜ account they may have.
A scanned copy of your government-issued ID card or passport.



Beneficial owners



While at Zesion OÜ we are against blanket rejections, it is of utmost importance to find out who exercises final effective control over the legal entity with which we are related. As a result, we require user-provided information about all Beneficial Owners about their:


Full name.
Maintained nationality(s).
Photo identification document.
Proof of address.


Taking the risk-based approach, we are especially diligent and may therefore employ additional measures, such as the use of third-party detection providers in case of:


Organizational structure with multiple levels of ownership;
Organizational structure in various jurisdictions; and
Lack of supporting documentation to prove ownership.
In the event that the legal entity is owned by another, Zesion OÜ also requires:
Name;
Number registered in any national registry;
Legal form in accordance with the law of the place of registration
Corporate headquarters address and management address;
The required details of UBOs as set out above, in relation to corporate "representatives".

Review of sanctions lists
Zesion OÜ is prohibited from transacting with persons, companies and countries that are on prescribed sanctions lists and therefore protects its users against the United Nations, the European Union, the United Kingdom Treasury and the Control Office United States Foreign Assets (OFAC) and other sanctions lists.

Examination of politically exposed persons

To identify politically exposed persons among its Users, Zesion OÜ not only relies on statements provided by the user, but also examines all individual account holders, all UBOs of corporate account holders, as well as any person who has access to a corporate account against multiple national users. and international PEP lists.

Restrictions and denial of service
Based on the information provided, Zesion OÜ reserves the right to determine, in its sole discretion, the appropriate verification level for any user, as well as the right to demote or ban users without prior notice. If Zesion OÜ discovers that any User information, obtained in accordance with the described procedure, is inadequate, insufficient or included in the Sanctions Lists, the Company may, at its discretion, refuse or cancel (as the case may be) the registration of such user account or require verification of such user identification documents again.


In the event that it is brought to the attention of Zesion OÜ that a particular user or account is being maintained under a fictitious name, Zesion OÜ has the full right and authority to cancel and close such account with immediate effect and without prior notice to the user.


Zesion OÜ also reserves the right to verify the user's identity on an ongoing basis, especially in cases of unusual and suspicious activity or if Zesion OÜ doubts the suitability or veracity of previously obtained customer identification data. Zesion OÜ has more right to request updated documents from users, even though they have already passed identity verification in the past.


Zesion OÜ may also implement policies that restrict verification levels by nationality, country of residence or any other factor. This may affect the user's ability to deposit/withdraw funds based on their verification level and Zesion OÜ is not responsible for any possible losses.


Zesion OÜ reserves the right to cancel the User Account, restrict and/or prevent access to its online platform, or inform the competent authorities of the activities of any User if there are suspicions of illegal activity.

Once the identity of l User, Zesion OÜ may withdraw from possible legal liability in a situation where its Services are used to carry out illegal activities.

Sensitive personal information
Sensitive personal information is collected, shared and stored securely in accordance with the Zesion OÜ Privacy Policy.

Monitoring, analysis and reporting of user activity.
In addition to verifying the identity of the user, Zesion OÜ also reserves the right to monitor and analyze their activity as part of the AML/CTF toolkit. Zesion OÜ performs a variety of compliance-related tasks, including data capture, filtering, record keeping, investigation management and reporting. System functionalities include, but are not limited to:


Transaction monitoring both by artificial intelligence (using predictive algorithms, statistical analysis, classification and scoring, etc.) and human intervention, which appear to be:
Unusually and unnecessarily complex.
Unusually large.
Conducted in an unusual pattern.
Lacking any apparent economic or legal purpose.


Daily verification of users against recognized "blacklists" (e.g. OFAC), as described above.
Placing users on denial of service and monitoring lists.
Opening cases for investigation where necessary.
Request additional information, when considered appropriate.
Sending internal communications.
Complete legal reports, if applicable.
Case and document management.



Zesion OÜ monitors all transactions on a daily basis and reserves the right to report any suspicious transactions to the appropriate law enforcement agencies via the MLRO, to request additional information and documentation in case of suspected illegal activities, as well as to suspend or terminate the disposition of services to suspicious Users. The list is not exhaustive and Zesion OÜ will take the necessary measures to avoid cases of money laundering, terrorist financing or any other criminal activity.
 
Risk-based approach
Zesion OÜ is dedicated to following the highest industry standards and therefore takes a risk-based approach to committing its resources in the most efficient manner; meaning the biggest risks will receive the most attention. As a result, Zesion OÜ also reserves the right to classify its Users into different risk profiles based on the following factors (including, but not limited to):

Sufficiency and adequacy of identification information.
Nature of the User's business/vocational activities.
Guidance notes distributed by various governmental and intergovernmental organizations.

Business relationships with corporate account holders, who have a complex ownership structure, which prevents the identification of the final beneficial owners, and natural persons with nationality or residence in high-risk third countries are, for example, a priority for the compliance office of Zesion OÜ.

Zesion OÜ keeps the risk categorization confidential and may change the categorization of any User at any time given various factors. While Users have no right in any way to request disclosure, Zesion OÜ may disclose User's risk categorization data to the competent enforcement authority if it finds that a particular User has executed or is likely to execute a Suspicious Transaction. .
 
Modifications
This AML/CTF policy may be reviewed and revised periodically. The revised draft will be uploaded to https://zesions.com and will reflect the date the terms were modified. The User is required to periodically visit the website and review the terms and any changes thereto. The User's continued use constitutes agreement to any modifications to the policy.
 
Contact
If you have any questions about these Terms of Use, your rights and obligations arising from these Terms of Use of the Site, our anti-money laundering, counter-terrorism financing policy, and the Service. Contact us by email: [email protected].