Legal & Privacy
User Agreement
Effective Date: April 16, 2026
Please view current effective terms under: https://www.coins.ph/en-ph/user-agreement-previous
This User Agreement (“Agreement”) governs your access and use of the services provided by Betur, Inc. and DCpay Philippines, Inc., doing business as “coins.ph” (collectively, “us”, “our”, “we”, “coins.ph”).
By using our Services, you acknowledge that you are entering into a binding contract with us and shall be deemed to have read, understood, and accepted this Agreement.
1. Our Services
1.1 Our services include those offered through the website located at https://www.coins.ph; our mobile application coins.ph; any other websites, pages, features, or content we own or operate or when you use (collectively, the “Platform”); any application program interface (“API”) made available by coins.ph to you; and any other services that coins.ph may make available, directly or indirectly, from time-to-time (collectively, the “Services”).
1.2 We may change, substitute, or discontinue any of our Services or any feature or functionality of the Platform or our APIs, in whole or in part, or impose restrictions, transaction limits, additional service fees, policies or procedures, without prior notice to you, except as may be required under Applicable Law. By continuing to avail of the Services or access our Platform, you are deemed to have accepted such changes. In case you want to discontinue, you may submit the relevant request by contacting us.
2. Your Account
2.1 To use our Services, you must create an Account with us by completing our Account creation procedure, which includes providing us your identity and contact information and accepting the terms of this Agreement. We reserve the right to decline any application to create an Account with us to the fullest extent permitted by Applicable Law.
2.2 Your Account with us is an electronic wallet. You may use your Account to purchase, sell or trade Virtual Assets, send or receive Funds, make payments, or purchase goods and services featured on the Platform. Your Account is not a deposit account and will not earn any interest. It is not covered by insurance from the Philippine Deposit Insurance Corporation (“PDIC”).
2.3 From time to time, you may be required to undergo additional verification procedures. We may also require additional verification （a） if we reasonably suspect that you are, or may be, in violation of this Agreement, Applicable Law or our policies, （b） if the Transaction requires enhanced due diligence under Applicable Law or our policies, or （c） generally to enable compliance with Applicable Law or our policies. Until completion of our verification procedures, we may refuse to give you access, or suspend your access, to certain Services, without prejudice to our right to take any other steps as may be authorized under Agreement, Applicable Law or our policies.
2.4 Inactive Accounts
（a） If you do not use or initiate any Transaction in your Account for twelve (12) consecutive months, we will consider your Account as inactive. To protect your Funds, we may apply temporary restrictions on your Account or hold Transactions for review until your Account is reactivated.
（b） We may charge inactivity fees against the Funds in your inactive Account which could reduce the Account balance to zero. We further reserve the right to collect such inactivity fees from any subsequent available balance in your Account, in case of any replenishment.
（c） You may reactivate an inactive Account by contacting our Support Center and completing our reactivation procedure, which includes updating your Account information and completing our Account verification process. We may also request you to fund your Account and/or do any other steps that may be required by Applicable Law or our policies.
3. Account Safety
3.1 In order to access your Account and use certain Services, you must provide your email address and/or mobile number and designate a strong password or a personal identification number (collectively, log-in credentials”).
3.2 We use a range of security tools and protocols to protect our Platform and your Account from fraudulent activity and unauthorized access. To further enhance the security of your account, we will require you to authenticate each Transaction with a one-time code or through your designated authentication tools, such as biometrics authentication through your device or third party authentication or password managers supported by our Platform. You acknowledge that these are intended to help you keep your account secure. You must not disclose to any other person your log-in credentials or one-time codes or allow any other person to control or gain access to your device or authentication tools.
3.3 You understand that when your Account is accessed through your log-in credentials, or when Transactions are authenticated by your one-time code or designated authentication tools, we will grant such access or process such Transaction.
3.4 You undertake to keep secure the device(s), e-mail address, and mobile number you use to access your Account. You shall take reasonable precautions to prevent your device(s), e-mail address, and mobile number from falling into the possession or control of other persons without your consent and from being exposed to any computer viruses, spyware, and malware which you acknowledge may allow malicious actors (such as hackers) to gain access to your Account.
3.5 You acknowledge short messaging, direct messaging, and instant messaging facilities and email services are inherently vulnerable to spoofing, phishing, and similar attacks. You must carefully review all messages received from such channels, including those sent by (or seemingly sent by) us.
3.6 If you lose access to your e-mail address or mobile number, or need to change them for any reason, you must promptly update this information either through the Platform or by contacting us. If you suspect that your Account or device(s) have been compromised, you must immediately contact us.
4. User Acknowledgements and Covenants
4.1 You undertake not to conceal your true name, use a fictitious name, or assume another person’s identity. In this regard, you shall provide us with authentic proof of your identity and any other documents that we may require for purposes of verifying your identity, Account activity, and Transactions.
4.2 When using our Services, you will comply with this Agreement, Applicable Law, our Prohibited Use Policy, Privacy and Data Protection Policy, AML Policy and any other policies (“Policies”) that we may publish on the Platform from time to time.
4.3 You confirm that you are the sole ultimate beneficial owner of your Account and not acting on behalf of or representing any other natural person, legal person or legal entity.
4.4 You confirm that you are not located in, under the control of, or a national or resident of, and will not use any of our Services for any Transactions to or from:
（a） any internationally-sanctioned countries; or
（b） any country to which the Republic of the Philippines has embargoed goods or services;
（c） any country in the sanctions list of the Philippine Anti-Money Laundering Council, the Philippine Anti-Terrorism Council, the U.N. Security Council, the Office of Foreign Assets Control of the U.S. Department of the Treasury, and similar Government Authorities; and
（d） any state or jurisdiction where we do not provide Services.
4.5 You agree that we may impose certain eligibility requirements, minimum Transaction amounts, velocity limits, or processing cut-off times for any of our Services. We will notify you of these requirements as required by Applicable Law.
4.6 You acknowledge that this Agreement, Applicable Law and/or and our Policies may require us to restrict your Account, put your Funds on hold or deliver any portion of your Funds to a third person or Government Authority. In such events, we will notify you if authorized or not otherwise prohibited by our Agreement, Applicable Law and/or our Prohibited Use Policy.
4.7 You acknowledge that to ensure your compliance with your undertakings under this Clause, we may monitor all of your Transactions, activities, and correspondence on our Platform. To the extent that our Platform allows you to provide any content to us or other users (such as posts, comments, or public feedback), we may censor, delete, or correct such content where necessary to enforce your compliance with this Clause, prevent any Prohibited Use, or enable compliance with our Agreement, Applicable Law and/or our Prohibited Use Policy.
4.8 You acknowledge that our Support Center regularly provides you with guidance, references, and resources on our products and services, Account safety and security, fraud prevention, and the usual questions and requests we receive from our users. You undertake to read and understand these resources and participate in any user education programs that we may launch from time to time.
4.9 When you open and maintain an Account with us or use our Services, you authorize us to collect, use, and process your Data, as well as share such Data with third parties in accordance with our Privacy and Data Protection Policy.
4.10 You shall be responsible for the security of your Data, that any instruction or Transaction sent, performed or consummated through the use of your Data shall be presumed to have been executed or performed by you. You shall be responsible for the consequences arising from or in connection with your use of the Platform and your use of our Services, whether or not processed with your knowledge or authority, or any erroneous Transaction(s) arising out of or relation to wrong or incomplete information supplied by you. We shall have no obligation to notify you in case of any delay, failure or error in the execution of any Transaction or instruction using your Data.
4.11 You agree that our records (whether in electronic or documentary) on your Account, Data, Transactions, your instructions or your use of our Platform or Services shall be considered accurate and reliable proof of such matters. You may, however, contest the accuracy of our records or request a correction by contacting us or in accordance with Applicable Law.
5. Fees and Taxes
5.1 Your use of our Services are subject to applicable Fees as stated on our Fees schedule or advised to you before you complete a Transaction. Unless otherwise stated, all Fees are inclusive of all applicable Taxes. We may change our Fees from time to time. We will notify you of any Fee changes as required by Applicable Law.
5.2 Where a Transaction involves converting or trading Funds of different currencies (such as purchasing Virtual Assets with Fiat, selling Virtual Assets for Fiat, or trading one Virtual Asset or Fiat currency for another), we will advise you of the applicable conversion or trading rates and/or the amount of Funds that you will receive or be charged with (as the case may be) before processing the Transaction. By proceeding with the Transaction, you confirm your irrevocable acceptance of such rates.
5.3 All Fees will generally be debited from your Account before you complete a Transaction or within the timeframes specified on our Platform. You agree to pay all Fees when they are charged and any other amounts (collectively, “amounts due”) which you may owe us under this User Agreement. Should you fail to timely and fully pay amounts due, you agree that we may at any time （a） set off any amount we owe you against the amounts due; or （b） debit, transfer, or otherwise charge such amounts due against any Funds in your Account. You further agree to settle any deficiencies upon our demand.
6. Third Party Sites
6.1 The Platform may contain references to or content from third party websites, applications, services, or other materials (collectively “Third Party Sites”) or allow you to link your Account to any wallets or services offered such Third Party Sites. You accept that Third Party Sites are provided by persons and entities not owned, controlled, or affiliated with us.
6.2 Any links or references to Third Party Sites on the Platform do not constitute our confirmation, recommendation, or concurrence of any content from or in such Third Party Sites; our endorsement, authorization, referral, or sponsorship of any products or services in such Third Party Sites; or proof of any affiliation, partnership, or relationship with the owners or operators if such Third Party Sites, unless otherwise stated.
7. User Responsibilities for Transactions
7.1 We will execute Transactions according to the instructions you relay to us on the Platform. However, we may be required by the relevant network or Applicable Law to comply with specific protocols when processing certain Transactions and that such protocols may require us to rely on specific identifiers (such as a wallet address, mobile number, quick response code, or merchant code), even if the sender or recipient name (as applicable) does not match. For this reason, you must ensure the accuracy of all your Transaction information before completing a Transaction on the Platform. We make no assurances that we are able to reverse or correct any erroneous Transactions. You agree that in the case of Virtual Asset Transactions and certain Fiat Transactions, your error (even if unintended by you) may result in the irreversible loss of your Funds.
7.2 Should you receive （a） Funds in error, whether from us, another user of the Platform, or any other third party, or （b） Funds being recovered by the sender or the originating institution in instances authorized by Applicable Law, we may be required to comply with certain obligations under Applicable Law. In this regard, you agree that we may （a） put such Funds on hold for such periods authorized by Applicable Law, （b） disclose relevant Transaction information to the sender or originating institution, if necessary for verification purposes, and/or （c） withdraw the Funds, reverse the Transaction, or otherwise apply all corrective steps authorized by Applicable Law. If you use or withdraw Funds before we are able to execute a withdrawal, reversal, or correction (as applicable), you agree that we may charge the Transaction amount against your other Funds with us, which could reduce your Account balance to zero. You undertake to promptly pay any remainder upon our demand.
7.3 You will refrain from making any unsolicited deposit of Funds to your Account, including but not limited to, making a deposit of Funds to your Account without a corresponding order; check, wire, or other non-Fiat deposits to your Fiat wallet; depositing Funds that substantially exceed your order amount; placing an order after a deposit has been made; or any type of deposit resulting in circumvention of Account limits. We may reject or otherwise reverse unsolicited deposits, subject to notice to you and our verification of the Transaction, where necessary. Such verification may require you to provide supporting proof of the deposit, identification documents, and/or proof of ownership of the originating account, which you agree to and will promptly provide.
7.4 We may charge additional Fees for correcting any erroneous Transaction and for unsolicited deposits, which you agree to pay and authorize us to debit from any available Funds in your Account.
8. Restrictions, Suspensions, or Closure
8.1 You may opt to close your Account at any time by completing the relevant request on the Platform.
8.2 We may close your Account upon notice if you fail to deposit or maintain any Funds in it.
8.3 Upon the occurrence of any Authorized Cause, we may:
（a） Refuse, cancel, reverse, suspend action on, or undo (as applicable) the specific Transaction from which the Authorized Cause arose;
（b） Restrict your Account or any of your Wallets or otherwise suspend your access to any of Services; and/or
（c） Close your Account.
8.4 “Authorized Causes” include:
（a） If you fail to complete any of our verification procedures or supply all information we request for a Transaction or to facilitate your access to any Service;
（b） in our reasonable belief, you are in breach of this Agreement, of Applicable Law or our Prohibited Use Policy; or
（c） the Transaction or your use of our Services constitutes Prohibited Use, or will result in our breach of this Agreement, of Applicable Law, or our Prohibited Use Policy;
（d） The existence of Applicable Law or we receive orders from a Government Authority requiring us to do any of steps in Clause 8.3;
（e） Your death or incapacity;
（f） Any other causes analogous or similar to any of the foregoing.
8.5 Upon Account closure under this Clause 8, except Clause 8.4（e）, you must comply with our instructions to facilitate the withdrawal of any available Funds in your Account.
8.6 We will notify you when we restrict, suspend, or close your Account. The notice shall be provided in the manner authorized by Applicable Law.
8.7 If we receive information leading us to believe you have died or have become incapacitated, we may restrict your Account. During this time, we reserve the right to reject all Transactions on your Account until:
（a） We are obliged under Applicable Law to deliver your Funds to your heirs, the executor or administrator of your estate, your guardian, or any other third person (as the case may be), such as upon our receipt of final and executory order to do so from a Government Authority or where we receive verified legal documentation confirming the right of your heirs, the executor or administrator of your estate, your guardian, or any other third person to receive the Funds in your Account, or
（b） We receive proof in a form satisfactory to us that you have not died or have become incapacitated.
9. Liability
9.1 Our total aggregate liability to you for any individual claim or series of connected claims for losses, costs, liabilities or expenses which you may suffer arising out of this Agreement shall be limited to the value of the Funds in your Account as of the date the relevant claim arose or the actual amount of loss or damage you suffered, whichever is lower.
9.2 In no event shall we, our affiliates or service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any lost profits or any special, incidental or consequential with your use of our Platform or Services or for any loss or damage arising from:
（a） Transactions authenticated by your Security Information or otherwise authorized by you;
（b） your breach of this Agreement, our Prohibited Use Policy; or Applicable Law;
（c） our compliance with Applicable Law;
（d） Actions of third parties, such as a third party platform, financial institution, or merchant’s refusal, reversal, or termination of your Transactions; a third party’s negligent, illegal, or fraudulent activity; or any other actions not otherwise attributable to us;
（e） any other instances analogous to the foregoing.
10. Disclaimers
10.1 OUR SERVICES ARE PROVIDED “AS IS” AND WITHOUT ANY REPRESENTATION OF WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, WE SPECIFICALLY DISCLAIM ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. We do not make any promises that access to the Platform or any of the materials contained therein, your Account, any of our Services, will be continuous, uninterrupted, timely, or error-free.
10.2 Nothing in our Platform is intended to provide any legal, tax or financial advice. We are not your financial advisor and you must not regard us as acting in that capacity. You should consult your own independent professional advisors before entering into any Transaction and only enter into a Transaction if you have fully understood its nature, the contractual relationship into which you are entering, all relevant terms and conditions and the nature and extent of your exposure to loss.
11. Intellectual Property
All text; logos, branding, product names, service marks (including the name “coins.ph”); graphics, button icons, and images; audio clips; and software included in or made available on the Platform or through any of our Services (“our IP”) is the intellectual property of coins.ph or our licensors. All right, title, and interest in our IP is exclusively the property of coins.ph or our licensors. You may use our IP solely for purposes permitted under this Agreement or as may permitted by us from time to time. You agree not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of our IP.
12. User Feedback, Complaints, and Dispute Resolution
12.1 Your needs and feedback are important to us. If you need any help with our Services, or wish to give us feedback, you may visit our Support Center or contact us.
12.2 If you notice any errors or discrepancies in your Account or any of your Transactions, you shall contact us immediately. We will investigate and do our best to address your complaint within seven (7) to forty-five (45) days, depending on the complexity of your concern. If we need more time to resolve it, we will notify you.
12.3 During our investigation, we may ask you to submit documents, complete certain instructions, or participate in a verification call. We may also put your Account or Funds (as applicable) on hold for your protection if necessary to facilitate our investigation. You agree to cooperate in good faith in this process.
12.4 If we confirm that the error or discrepancy you reported is valid and was caused solely by our fault or negligence, we will take the necessary actions to correct it (“corrective action”). Depending on the nature of the issue, our corrective action may include, without limitation, reprocessing, reversing, or cancelling the relevant Transaction; updating your Account or Transaction records; and/or assisting you in recovering the Transaction amount. However, if we determine that the reported error or discrepancy was caused by your own mistake or negligence, we are under no obligation to take any corrective action. The following instances shall be deemed to arise from your mistake or negligence, without limitation:
（a） clicking on phishing or suspicious links sent by third parties (including those impersonating us or our employees);
（b） entering any incorrect or incomplete Account or Transaction details;
（c） providing your Account, Transaction, or personal information to third parties; or
（d） engaging in any similar or comparable acts.
12.5 If your complaint is not resolved via the procedure set out in this Clause 12, you will refer such complaint to final and binding arbitration to be administered by the Philippine Dispute Resolution Center, Inc. (“PDRCI”) in accordance with its arbitration rules (“PDRCI Rules”) then in force. The seat of the arbitration shall be Taguig City, Philippines. The tribunal shall consist of one arbitrator to be mutually appointed by the Parties, or if the Parties are unable to agree, an arbitrator appointed in accordance with PDRCI Rules. The decision of the arbitrator will be final, binding and incontestable, and it may be used as a basis for judgment in any country or region. Notwithstanding anything else in this Agreement, you or coins.ph may at any time commence court proceedings if necessary for urgent interlocutory relief. To the fullest extent permitted by Applicable Law, you agree to initiate arbitration on any such disputes within one year from the date on which the dispute arose.
12.6 coins.ph is regulated by the Bangko Sentral ng Pilipinas (www.bsp.gov.ph).
13. Notices
13.1 All notices required to be provided to you under this Agreement shall be provided within the periods and in the manner permitted by Applicable Law.
13.2 We may provide you communications about your Account and our Services by short message services (SMS), emails, in-Platform messages or prompts, or any other means of communication authorized by this Agreement or Applicable Law.
14. Miscellaneous
14.1 Force Majeure. We shall not be liable for delays or failure in, or interruption of, the performance of any service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to, any delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe, pandemic, national emergency, or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.
14.2 Entire Agreement. This Agreement, including all documents incorporated by reference or which incorporate this Agreement by reference, such as our Policies and any of the Additional User Terms, comprise the entire understanding and agreement between you and coins.ph as to the subject matter of this Agreement. This Agreement supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement) between you and coins.ph.
14.3 Changes. We may amend or modify this Agreement from time to time. We will inform you of any changes to this Agreement in the manner required by Applicable Law. You are advised to read carefully and check this Agreement from time to time so that you remain informed of the latest version.
14.4 Interpretation. Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.
14.5 Transfer and Assignment. You cannot transfer or assign your rights, licenses, interests and/or obligations to any other person. Subject to any notice requirement under Applicable Law, We reserve the right to assign our rights under this Agreement and any information we have collected from you under Agreement to any of our subsidiaries and affiliates or any third party. or to any successor in interest. You may opt to close your Account and terminate the agreement with immediate effect in the event of such assignment.
14.6 Separability. If any provision of these terms and conditions set forth in this Agreement shall be determined to be illegal, invalid, or unenforceable under any applicable law, such provision shall be deemed void and the remainder of these terms and conditions shall continue in full force and effect.
14.7 Governing Law. This Agreement and the relationship between us shall be governed by the laws of the Republic of the Philippines.
Additional Terms for Virtual Asset Services
Our Virtual Asset Services are subject to the following additional terms:
1. Our Virtual Asset Services
1.1 Our Platform enables you to execute Transactions with Supported Virtual Assets, such as selling or purchasing of a Supported Virtual Asset for Fiat (and vice versa), trading Supported Virtual Assets, holding Supported Virtual Assets in your Account, and sending or receiving of Supported Virtual Assets (as payment or otherwise) to or from other persons.
1.2 All Supported Virtual Assets held in your Account are held by us for your benefit on a custodial basis. Title to such assets shall at all times remain with you and shall not transfer to us.
2. Eligibility
To use our Virtual Asset Services, you must be of legal age.
3. Risk Disclosures
3.1 We take extensive security measures to protect your Account. However, you understand that the use of our Virtual Asset Services are subject to certain inherent risks, including:
（a） Virtual Asset Transactions may be irreversible once recorded on the blockchain, even if such transactions are unintended or unauthorized by you.
（b） The price or value of Virtual Assets may change rapidly, decrease, and potentially even become illiquid or fall to zero, which may cause large losses to you. We do not control, have the ability to influence, or guarantee the value of any Virtual Asset. We make no assurances that any Virtual Asset will maintain its value over time or that there will be meaningful levels of trading activities.
（c） We securely store all of your Supported Virtual Assets and private keys in a combination of online and offline storage in secure facilities. As a result, your Transactions may be delayed for up to seventy-two (72) hours if it is necessary for us to retrieve information from offline storage in order to process such Transaction.
（d） Supported Virtual Assets of like kind are fungible. Your title to Supported Virtual Assets in your Account gives you ownership rights in the corresponding amount of such Supported Virtual Asset but not necessarily in a specifically-identifiable token or other representation of such asset.
（e） We do not own or control the underlying software protocols which govern the operation of any Virtual Asset. Such protocols may change from time to time without our prior knowledge and the changes may result in two or more versions of the same Virtual Asset (“forks”). Forks may materially affect the Virtual Asset’s value, function, name, and any other characteristics and could cause such Virtual Asset to have minimal or no value, which could cause losses to you.
（f） Depending on your country of jurisdiction, Virtual Assets may not be legal tender and Applicable Law may impose certain legal obligations upon you, such as the payment of taxes. You must ensure your own compliance with your obligations under the Applicable Law of the country of your jurisdiction.
（g） Virtual Assets are subject to an evolving regulatory landscape. Changes in Applicable Law may impact our ability to offer Virtual Asset Services and/or your continued access to the Platform in your country of jurisdiction.
（h） A significant disruption in our systems (including a system failure, outage, or interruption), or in any of the blockchain networks that we support, could affect your user experience and/or ability to access the Funds in your Account. Transactions may post late, be queued, or fail.
（i） We rely on third-party service providers for certain aspects of our operations, including cloud computing, software infrastructure, or data center services; payment processors, banks, and payment gateways; as well as third parties that provide certain outsourced services and functions. Any interruptions in services provided by these third parties may impair our ability to perform our Services.
3.2 By using any of our Virtual Asset Services, you confirm your understanding and acceptance of the various risks involved in using, holding, and Transacting Virtual Assets, including the risks described in this Clause.
4. Supported and De-listed Virtual Assets
4.1 Our Virtual Asset Services are available only for Supported Virtual Assets. We reserve the right to determine the specific Virtual Assets to support.
4.2 You agree not to receive, request, store, or otherwise Transact using any unsupported Virtual Assets. If, notwithstanding your commitments under this Clause, you still Transact (erroneously or otherwise) with Unsupported Virtual Assets, you agree that such Unsupported Virtual Currencies may be lost and we may be unable to assist you in retrieving them.
4.3 From time to time, we may de-list any Supported Virtual Asset from our Platform (“De-listed Virtual Assets”), in which event the Supported Virtual Asset will be removed from our Platform. Before de-listing any Supported Virtual Asset, we will notify you as required by Applicable Law and provide a reasonable opportunity for you to transfer, withdraw, or otherwise remove such Virtual Asset from our Platform. You agree to cooperate in good faith with any instructions that we may give you in this regard.
5. Virtual Asset Transactions
5.1 We will fulfil all Virtual Asset Transactions generally within the timeframes indicated on the Platform or within reasonable time.
5.2 We may reject, return, cancel or be unable to facilitate a Transaction:
（a） upon the occurrence of an Authorized Cause for Account suspension, restriction, without prejudice to our rights to pursue any of other steps authorized in this Agreement;
（b） if, in our reasonable opinion, the Transaction is high-risk or otherwise could not be executed by our Platform, such as those involving reversible payment methods or unsupported Virtual Asset(s).
5.3 You acknowledge that a Transaction, once submitted to the relevant network, will be pending and unconfirmed for a period of time. Funds associated with Transactions that are in a pending state will be designated accordingly. You agree that such Funds will neither be included in your Account balance nor be available for any Transactions.
5.4 We will not cancel or reverse Virtual Currency Transactions that have been accepted and confirmed on the relevant blockchain.
5.5 You must refrain from directly sending Virtual Assets to your Fiat wallet. If, notwithstanding your commitment under this Clause, you still proceed with such a Transaction (whether or not inadvertently), you acknowledge that your Virtual Asset may be irretrievably lost. We reserve the right to not process any such Transactions. To the extent feasible on our Platform, we may opt to credit the Transaction to your Virtual Asset wallet, at our sole discretion.
5.6 In the event of a fork, we may temporarily suspend our Services and that we may subsequently, in our sole discretion
（a） configure or reconfigure our Platform,
（b） support only one branch of a forked Virtual Asset, which in our reasonable opinion best reflects the consensus approach or
（c） decide not to support (or cease supporting) the forked protocol entirely. We will exert reasonable efforts to provide you an opportunity to withdraw any forked Virtual Assets from the Platform.
Additional Terms for Fiat Services
Our Fiat Services are subject to the following additional terms:
1. Fiat Services
1.1 Our Platform enables you to execute Transactions with Fiat, including trading supported Fiat currencies, holding Fiat in your Account, and sending and receiving Fiat (as payment or otherwise) to or from other persons.
1.2 You acknowledge that our Fiat Services may be subject to certain requirements under Applicable Law or the policies of third party clearing switch operators, networks, and financial institutions, over which we have no control or influence.
2. Eligibility
To use our Fiat Services, you must be of legal age.
3. Risk Disclosures
3.1 We take extensive security measures to protect your Account. However, you understand that the use of our Fiat Services are subject to certain inherent risks, including:
（a） Certain Fiat Transactions operate under frameworks or systems governed by Applicable Law or administered by a Government Authority, such as but not limited to PesoNet, InstaPay and other retail payment schemes operating under the National Retail Payment System. Such Transactions are subject to the technical and operational policies of the relevant automated clearing house and participating institution, which are beyond our control.
（b） Fiat Transactions are generally irreversible once completed, even if such Transactions are unintended or unauthorized by you. While we may assist you in recovering Funds from any unintended or unauthorized Fiat Transaction, such recovery is dependent on the recipient’s consent and/or the policies of the recipient institution.
（c） Fiat Funds are fungible. Your title to any Fiat Funds in your Account gives you ownership rights in the corresponding amount of such Fiat Funds but not necessarily in a specifically-identifiable moneys or other representation of such Funds.
（d） Depending on your country of jurisdiction, certain Fiat Funds may not be legal tender and Applicable Law may impose certain legal obligations upon you for certain Transactions, such as the payment of taxes. You must ensure your own compliance with your obligations under the Applicable Law of the country of your jurisdiction.
（e） Fiat Transactions are subject to an evolving regulatory landscape. Changes in Applicable Law may impact our ability to deliver certain Fiat Services to you or your access to your Account or Funds.
（f） A significant disruption in our systems (including a system failure, outage, or interruption), or in the systems of the relevant automated clearing house or participating institution could affect your user experience and/or ability to access the Funds in your Account. Transactions may post late, be queued, or fail.
（g） We rely on third-party service providers for certain aspects of our operations, including cloud computing, software infrastructure, or data center services; payment processors, banks, and payment gateways; as well as third parties that provide certain outsourced services and functions. Any interruptions in services provided by these third parties may impair our ability to perform our Services.
3.2 By using any of our Fiat Services, you confirm your understanding and acceptance of the various risks involved in using, holding, and Transacting in Fiat, including the risks described in this Clause.
4. Merchant Transactions
4.1 The Platform enables you to use your Fiat Funds to purchase goods and services from third parties (“Merchants”). You also agree with a Merchant to enroll your Account as the source account for future payments (either on a one-time or recurring basis) to such Merchant. When making such payments, you authorize us to deduct the total amount payable to the Merchant from your Account and share Transaction details with the Merchant, as necessary, to complete your payment.
4.2 You understand that all of your dealings with a Merchant shall be governed by your agreed terms and conditions, which shall be binding exclusively between you. You agree that in such dealings, we serve only as a payment channel and you must not take our Services as a confirmation that we are representing, endorsing, recommending, referring, or sponsoring the Merchant or making any guarantees on quality of Merchant’s goods or services. You agree that we are not responsible for any of Merchant’s promises or representations to you as regards such goods or services. In this regard, you undertake to exercise due diligence and care when transacting with Merchants.
5. Cash-in Partners
5.1 We may partner with third parties (“Cash-in Partners”) to enable you to cash-in Fiat into your Account. We reserve the right to determine our Cash-in Partners. We may change, suspend, or terminate our partnership with any Cash-in Partner, in which case we will notify you where required by Applicable Law.
5.2 When you cash-in with any of our Cash-in Partners, you acknowledge that you will be required to comply with their policies, turnaround times, and processing requirements. You agree that without such compliance, Cash-in Partner may refuse to process or reverse your cash-in, in which event you will be unable to receive your intended Fiat deposit in your Account with us.
5.3 Any references in the Platform of a Cash-in Partner being “verified” or “connected” (or similar language) only indicate that the Cash-in Partner has completed our verification process and should not be taken as our endorsement, certification or guarantee of the quality of Cash-in Partner’s services. In this regard, you must exercise due diligence and care when deciding Transact with a Cash-in Partner.
Additional Terms for Trade Desk Services
Our Trade Desk Services is subject to the following additional terms:
1. Trade Desk Services
We may provide you access to a trade desk providing over-the-counter Transaction assistance (“Trade Desk”).
2. Eligibility
2.1 To be eligible for our Trade Desk Services, you must submit an application form on the Platform, maintain our prescribed verification level, and complete any additional verification procedures that we may require.
2.2 Your application is subject to our approval. We reserve the right to decline providing Trade Desk Services to you, in which case we will notify you where required by Applicable Law.
3. Trading Rules
3.1 When using our Trade Desk Services, you agree to comply with our trading rules, as follows:
（a） Each Transaction must be at least Php1,000,000.00 or its equivalent (“Minimum Trade Size”). We will decline Transactions that do not meet the Minimum Trade Size. The Minimum Trade Size may change from time to time upon notice as may be required by Applicable Law.
（b） You must Transact within the trading hours provided in this Appendix, exclusively with the persons we have authorized (“Authorized Dealer”), and only through channels designated by us (“Trading Channel”) Transacting with our Trade Desk. We will inform you of your Authorized Dealer(s) and Trading Channels upon our approval of your application for Trade Desk Services. We will not be obliged to honor or facilitate any Transactions conducted with persons other than our Authorized Dealer or on channels other than our Trading Channels.
（c） To initiate a Transaction, you must send a request to an Authorized Dealer through the Trading Channel indicating all pertinent Transaction details, such as the quantity or trade size and the specific Virtual Asset or Fiat currency to be traded.
（d） You must ensure that your Account contains sufficient available Funds for your intended Transaction. “Available Funds” means Funds which are withdrawable from your Account and are not on hold or otherwise restricted from being Transacted.
（e） Any quotation we provide for your requested Transactions are valid only for one (1) minute, during which you must either accept or reject the quotation. If you fail to respond within that period, you shall be deemed to have rejected the quotation. For avoidance of doubt, your use of any word which signifies acceptance of the quote (e.g. “done”, “deal”, “ok”, “confirmed”, or any other words of similar import and meaning) shall be considered as your acceptance of the quotation.
3.2 Quotations are final and binding upon acceptance.
3.3 Your acceptance of a quotation shall be deemed as our authority to deduct the Transaction amount from your registered Account (“Registered Account”) and to execute the Transaction.
3.4 The Additional Terms for Virtual Asset Services and for Fiat Services apply to your Virtual Asset and Fiat Transactions on our Trade Desk.
3.5 We will cancel or refuse to process any Transaction that fails to comply with our Trading Rules.
4. Trading Hours and Settlement
4.1 Our trading hours are:
| Standard business hours: | Monday to Friday (excluding non-banking days) 9:00 AM to 4:00 PM Philippine Standard Time (UTC +8:00) |
| Off-market hours: | Monday to Friday (excluding non-banking days) 4:00 PM – 9:00 PM Philippine Standard Time (UTC+8:00) |
4.2 We may change our trading hours from time to time upon notice.
4.3 Any Trade Requests made outside of our trading hours shall not be accepted.
4.4 The proceeds of your Trade Desk Transactions shall be settled to your Registered Account within the periods stated below. We will not execute any requests to settle a Trade Desk Transaction to any other account.
| Transaction Time | Settlement Time |
| Within standard business hours | Within 1 banking day |
| Within off-market hours | Within 2 banking days |
Additional Terms for Rewards Hub
Our Rewards Hub is subject to following additional terms:
1. The Rewards Hub
The Platform includes a feature which allows you to earn rewards by completing certain tasks (each, a “Task”) on the Platform.
2. Eligibility
Unless otherwise stated on the Platform:
2.1 The Rewards Hub is available only to all users who meet the eligibility requirements that we may publish from time to time on the Platform.
2.2 The following are disqualified from participating in the Rewards Hub:
（a） Corporate and institutional users (i.e., users who have been onboarded through our KYB verification process); and
（b） Users whose accounts have been tagged as high-risk, blacklisted, suspended, restricted, or closed under the User Agreement.
2.3 Your eligibility to participate in the Rewards Hub and to receive rewards is subject to your continuing compliance with the User Agreement and your completion of each Task’s rules. We reserve the right to withhold, cancel, or clawback any reward, even if already earned by you, upon your breach (or attempt to breach) the User Agreement or the relevant Task’s rules.
2.4 We may change the eligibility criteria at any time.
3. Earning Rewards
3.1 You may earn rewards by completing the Task according to the Task’s rules.
3.2 Each Task’s rules and corresponding reward shall be indicated in the Rewards Hub.
3.3 We may change Tasks and its rules, or discontinue any Task, from time to time. Your right to receive all rewards earned prior to such change or discontinuation shall be unaffected.
3.4 All earned rewards will be credited to your Account, subject to any applicable withholding taxes, which we will deduct from the reward amount. All other taxes, costs and expenses associated with your acceptance or use of any reward under Applicable Law in your country of jurisdiction (if any) shall be your responsibility.
3.5 All rewards are non-transferable.
Additional Terms For Launchpool
The Launchpool is subject to following additional terms:
1. The Launchpool
We may admit you to the Launchpool on our Platform. The Launchpool features projects (“Project”) under which participating users may receive newly-listed Supported Virtual Assets (“Project Tokens”) in exchange for locking certain Supported Virtual Assets in their account (“Launchpool Assets”) for a specified period (“Lock-up Period”).
Each Project is subject to certain rules (“Project Rules”) published on the Launchpool. The Project Rules shall determine acceptable the Launchpool Assets, the Lock-up Period, the amount of available Project Tokens, and the manner by which Project Tokens shall be earned and distributed.
2. Eligibility
2.1 The Launchpool is generally available only to active users who are natural persons and who meet the verification requirements prescribed by the Project Rules.
2.2 The following are disqualified from participating in the Launchpool:
（a） Sub-accounts;
（b） Institutional accounts;
（c） Market maker accounts;
（d） Users whose accounts have been tagged as high-risk, blacklisted, suspended, restricted, or closed under the User Agreement.
2.3 Your eligibility to participate in the Launchpool is at all times subject to your continuing compliance with the User Agreement and the relevant Project Rules. We reserve the right to withhold, cancel, or clawback any Project Tokens, even if already earned by you, upon your breach (or attempt to breach) the User Agreement or the Project Rules.
2.4 Certain Project Rules may have additional eligibility and disqualification requirements, which may change from time to time.
3. Launchpool Participation
3.1 You may participate in a Project by locking up Launchpool Assets. Your participation in a Project shall mean your acceptance of the applicable Project Rules. The Project Rules shall be supplemental to the User Agreement.
3.2 The amount of Project Tokens you may earn from a Project will generally be determined based on the amount of your locked Launchpool Assets in reference to the total locked Launchpool Assets for the Project, subject to any limits prescribed in the Project Rules. Certain Project Rules may allow referrals, in which case you may earn Project Tokens by inviting other users to participate in the Project.
3.3 You acknowledge that by locking Launchpool Assets:
（a） There is no transfer of ownership to us or any third person;
（b） The locked Launchpool Assets are neither commingled nor pooled with the Launchpool Assets of other users joining the same Project; and
（c） Your locked Launchpool Assets shall be restricted from any Transaction during the Lock-up Period, unless you unlock them.
3.4 You may opt to unlock some or all of your locked Launchpool Assets at any time during the Lock-up Period. When you unlock Launchpool Assets, you understand that:
（a） the restrictions on Launchpool Assets shall be removed;
（b） you will be deemed to have ended your participation in the Project, and consequently, you will cease to earn any Project Tokens (other than those already allocated to you prior to unlocking).
3.5 At the end of the Lock-up Period, all Launchpool Assets shall be automatically unlocked.
4. Distribution of Project Tokens
4.1 Project Tokens shall be distributed in the manner stated in the Project Rules but generally by way of airdrops.
4.2 You agree that Project Tokens, even if already earned by you, cannot be Transacted during the Lock-up Period and for two (2) business days thereafter, unless otherwise permitted by us.
4.3 Where Project Rules prescribe distribution limits, you understand that no further Project Tokens shall be allocated once the limits are reached.
Definitions
The following terms used in the User Agreement shall have the meanings set out below:
Account means an account opened and maintained with us, comprised of electronic wallet(s) for Fiat and Virtual Assets.
Applicable Law includes all applicable laws (federal, state, and local), rules, orders, guidelines, and regulations of any Government Authority applicable to you, coins.ph, our Services or this User Agreement as the context may require.
Data includes your personal information as defined under Applicable Law and any information you provide for purposes of opening and maintaining your Account or completing a Transaction.
Fees shall mean the fees we charge in relation to the creation and maintenance of your Account or use of a Service.
Fiat includes any other government-issued currency designated as legal tender in its country of issuance through government decree, regulation, or law.
Fork means a change in the underlying protocol of a Virtual Asset network that results in more than one version of a Virtual Asset.
Funds means any Fiat and Virtual Assets held in your Account.
Government Authority means any government, regulatory or administrative authority, agency, commission, board, bureau, court or instrumentality of any kind (including but not limited to any central bank, monetary authority, or securities exchange) having jurisdiction over you or coins.ph, our Service and/or this User Agreement.
Platform includes our website at https://www.coins.ph, mobile application, and any other payment gateway(s) or electronic facilities used by us or made available to you for our Services.
Service or Services means any of the Services we provide through the Platform, including our Virtual Asset Services, Fiat Services, Trade Desk Services, and Launchpool Services.
Supported Virtual Asset means a Virtual Asset listed on our Platform.
Taxes means all taxes, levies, imposts, duties, deductions, charges, or withholdings imposed, levied, withheld or assessed by a Government Authority under Applicable Law, together with any interest, additions to tax, or penalties imposed with respect thereto.
Transact, Transacting, or Transacted includes any step or action intended to initiate, carry out, or otherwise complete a Transaction.
Transaction includes all transactions facilitated through our Services, including （a） sending or receiving of Funds, whether as payment or otherwise and （b） trading of Funds.
User Agreement or Agreement includes the terms of the User Agreement, the Additional Terms for Virtual Asset Services the Additional Terms Terms for Fiat Services, the Additional Terms for Trade Desk Services, the Additional Terms for the Launchpool, the Privacy and Data Protection Policy, the AML Policy, and all other additional terms and policies supplemental to or incorporating the User Agreement.
Virtual Asset means any digital unit of exchange that is capable of being digitally traded, transferred, and used for payment or investment purposes, may either be centralized or decentralized; and are generally created or obtained by computing or manufacturing effort.
Privacy and Data Protection Policy
This Policy explains our Data collection, use, and protection practices. Unless expressly declared, this Policy does not apply to other online or offline sites, products or services other than the Platform.
By using our Services, you consent to the collection, use, and processing of your Data and to our Data protection practices as described in Policy. You confirm that all Data you provide to us are true, accurate, complete, exclusively within your control, unique to yourself and up-to-date.
Without prejudice to the foregoing, if you provide Data of any other individual to us, you warrant and agree that such individual has fully read and understood this Policy and has consented to your disclosing their Data to us for collection, use, processing and sharing as described in this Policy.
1. What Data do we collect?
When you sign up for an account with us or use our Services, we will request you to provide personal information or we will collect personal information. These may include:
• Your name and personal particulars such as contact information, address, gender, birthdate, nationality, marital status, and education;
• Your identification documents;
• Your financial information (such as salary information, deposits, investments or other proof of income, bank account details, or bank transaction details);
• Your employment or business information (such as employer name and address, business contact number, job industry, job position, job employment date, or monthly income);
• Other Data about you, such as:
- your transactions, account history, and behavior on our Platform;
- your IP address;
- your conversations with us through our official channels;
- device information including, but not limited to, unique identifier, name and type, operating system, location, mobile network information, phone settings, phone device information, contact list, device accounts, social media information, calendar information, storage information and call log information;
- standard web log information such as your browser type, traffic to and from our site, and the specific pages or tabs you accessed on our Platform;
• Data shared to us by third parties, such as information from partners for identity and transaction verification when you use any website or social media platforms operated by partners or third parties (such as Facebook, Tiktok, Instagram, Twitters, etc.) and, in the event that we make enable third party profile links to our Platform, your profile information on such third party websites or social media platforms;
• Photographs, videos, audio recordings collected online (through websites, emails, apps, etc.) or offline platforms (events, surveys, phone calls, etc.) containing your likeness or voice;
• any information requested by us and/or provided by you in relation to our Services through our Platform or as may be required by Applicable Law.
As much as we can, we aggregate and anonymize your personal information such that the resulting data does not specifically identify you as an individual. We do not consider this anonymized data as personal information.
2. Why do we collect your Data?
We collect your Data to provide you with a secure, efficient, and customized experience on our Platform and to:
• consider and/or process your application to be our customer and/or to open your Account with us;
• facilitate, process, deal with and/or administer your Account and Transactions with us;
• provide our Services and customer support timely and efficiently at your request;
• process Transactions and send notices about your Transactions;
• help you with any of your requests, resolve your complaints and troubleshoot any problems;
• prevent potentially fraudulent, prohibited, or illegal activities, including conduct matching procedures against databases of known fraudulent, prohibited or illegal transactions;
• settle disputes, enforce rights and obligations, address legal matters, etc.;
• deliver direct marketing, service update notices, and promotional offers based on your communication preferences;
• compare information for accuracy and verify it with third parties;
• conduct identification and verification in connection with any of our Services that may be provided to you by us or that you may request from us;
• facilitate and deal with the availment of products and services provided by us or our affiliates and/or third parties on our behalf;
• carry out your instructions, respond to any enquiry or deal with any feedback given by (or purported to be given by) you or on your behalf, including contacting you via phone/voice call, text message and/or other means, email and/or postal mail regarding your instructions, enquiries or feedback;
• customize, measure, and improve our Services, the content and layout of our Platform, or any any of our marketing programmes or campaigns and for this purposes, conduct the necessary research, audits, analyses, or development activities (including but not limited to data analytics, surveys, focus groups and/or profiling);
• contact you or communicate with you via various modes of communication such as but not limited to phone/voice call, text message, email and/or postal mail;
• carry out due diligence or other screening activities (including security and background checks) in accordance with regulatory and legal obligations or our risk management policies;
• comply with Applicable Law, or the requests, directives or orders of a Government Authority, such as but not limited to the BSP, SEC, AMLC, BIR, NPC, U.S. IRS, etc.;
• produce statistics and research for internal and/or statutory reporting, recording-keeping requirements and/or policy/process reviews;
• store, host, back-up (whether for disaster recovery or otherwise) your Data whether within or outside the Philippines; and
• monitor the quality and security of the Platform and discipline or train our staff.
3. When do we collect your Data?
We collect Data from you when you sign-up for an account with us, use our Platform, request access to certain Service types or features on the Platform, talk to us in our office or official contact channels.
We may also collect certain Data from third parties when you permit them to share Data with us, such as government agencies, other financial institutions, or social media sites (such as but not limited to Facebook and Twitter). We will only use that Data for the purposes stated above.
4. What are cookies?
When you access our Platform or use our Services, we or the companies we work with may place small data files called cookies or pixel tags on your computer or other device. We may use both session and persistent cookies when you access our Platform. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire. Certain content on the Platform using Adobe Flash may also store data on your computer called Local Shared Objects, commonly referred to as “Flash cookies”.
5. How do we use cookies?
We use these technologies to:
• Recognize you as a customer and remember your preferences;
• Customize our Services, content, and advertising;
• Measure promotional effectiveness; and
• Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We encrypt our cookies so that only we can interpret the information stored in them.
6. Can you refuse to let us use cookies?
You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your experience of our Platform. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.
7. Are our cookies found on any other websites?
You may encounter our cookies or pixel tags on websites that we do not control. For example, if you view a web page created by a third party or use an application developed by a third-party, there may be a cookie or pixel tag placed by the web page or application. Likewise, third parties may place cookies or pixel tags that are not subject to our control and this Policy will not cover their use.
8. Do we share your Data with other parties?
We may share or transfer your Data to third parties, including subsidiaries, affiliates, service providers, and business partners, within or outside the Philippines, when required for the purposes described in this Policy. Any such transfer is carried out under contractual and technical safeguards that ensure that the recipient processes your Data in a manner consistent with Applicable Law. Where data is transferred abroad, we require the recipient to implement protections that meet or exceed the standards of the Data Privacy Act of 2012 (Republic Act No. 10173) and we restrict any further use or disclosure unless authorized by us.
Other than the third parties described above, we may also share your personal information with:
• The persons or companies that you Transact with using our Services, such as the merchants that you pay using Funds in your account;
• Companies that we plan to merge with or be acquired by;
• Law enforcement, Government Authority, credit reporting bodies, other financial institutions or virtual asset service platforms, and similar institutions when:
◦ Required by Applicable Law;
◦ There is any actual or suspended breach of Applicable Law by or against you, such as but not limited to fraud or money laundering crimes;
◦ Required in ongoing or future legal proceedings involving your Account or Transactions or where we are otherwise compelled to disclose your Data by a subpoena, court order, or similar legal process; or
◦ We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss to you;
◦ We report or receive reports of suspected illegal activity or investigate violations of our User Agreement.
• Other third parties with your consent or direction to do so.
We do not sell or rent any of your Data to third parties for their marketing purposes and only share your Data with third parties as described in this Policy. You acknowledge, agree and consent that we may disclose your Data to third parties for any of the purposes stated hereunder and for said third parties to subsequently collect, use, disclose or process your Data for any of the above purposes.
9. How long do we keep your Data?
We keep your Data throughout your use of our Services and only for as long as necessary to fulfill the purposes for which it was collected or as may be required or allowed by Applicable Law. We retain your account and transaction Data for a minimum period of five (5) years after you close your account with us, in compliance with Applicable Law.
10. What happens to my Data after I close my account?
We will stop any further collection and use of your Data, except as required or permitted by Applicable Law or in accordance with this Policy. However, we will keep your account and transaction Data in our database as per the statutory retention periods time above mentioned. Thereafter, your Data will be destroyed in irretrievable and unusable form.
11. How do we protect your Data?
The integrity, confidentiality, and security of your information are particularly important to us. We strictly enforce data protection policies in our company and we have implemented technological, organizational, and physical security measures that are designed to protect your information from unauthorized access, use, alteration, and disclosure.
Specifically:
• We store and process your personal information only in our own secure facilities or with third party service providers who are contractually bound to protect your information in the manner described in this Policy.
• We keep your Data using a secured server behind a firewall, encryption, and security controls.
• Our security protocols and Platform infrastructure undergo regular audits and rigorous testing by internal and independent third parties
• Our Platform is ISO27001:2013 certified and fortified as per industry standards.
• We run a bug bounty programme in which we regularly invite white hats to stress test our Platform, ensuring that all blind spots are covered.
• Access to our internal systems are ring fenced, restricted only to authorised team members and protected by multifactor authentication
• We also deploy a 24/7 security monitoring and response team to monitor and mitigate any cyber threats to our Platform.
If there is an actionable breach of your Data, we will notify you within the reglementary period provided by Applicable Law.
12. What are your rights as a data subject?
You are entitled to the following rights:
• To be informed when your personal date is or will be collected and processed;
• To disallow certain processing of your personal information, such as for direct marketing purposes;
• To dispute any inaccuracy or error in your personal information and require us to correct or update it;
• To obtain a copy of your personal data in an electronic or structured format for your further use;
• To suspend, withdraw, or order the blocking, removal, or destruction of your personal information from our systems, provided such action is not critical nor required by applicable laws and regulations to maintain the products and services that you availed with us;
• To file a complaint with our Data Protection Officer or National Privacy Commission if you feel that your personal information has been misused, disclosed without your consent, or that any of your rights as a data subject has been violated.
You may refer to the National Privacy Commission’s website at www.privacy.gov.ph for a complete reference of your rights under the Data Privacy Act of 2012.
13. How do I access my personal information?
You may always review and edit your personal information at any time by logging into your account and clicking the “Profile” or “My Account” tab.
In all other cases where you wish to have access to your personal information in our records or you believe that your personal information with us is incomplete, outdated, or otherwise inaccurate, you may get in touch with our Data Protection Officer through the contact details provided below.
We may charge you a reasonable fee for the handling and processing of your requests to access your personal data, in which event, we will provide you with a written estimate of the fee we will be charging. Please note that in most jurisdictions, Applicable Law permits us to decline to respond to access requests unless the requestor agrees to pay the fee.
14. How can you reach us for data privacy concerns?
You may contact our Data Protection Officer through:
Email: privacy@coins.ph, dpo.betur@coins.ph, or dpo.dcpay@coins.ph
Phone: (02)882-26467 (882-COINS), 8am - 7pm, Mondays to Fridays
Mail: 15th Floor Asian Century Center, 27th Street corner 3rd and 4th Avenue, Fort Bonifacio, Taguig City
Please include your name, contact information, and the nature of your concern/request so that we can appropriately respond to your communication.
This Policy supplements and forms an integral portion of the User Agreement. Any capitalised terms not defined in this Policy shall have the meanings stated in the User Agreement. This Policy may change from time to time. We will publish the latest version of this Policy on our website or the Platform. You are advised to read carefully and check this Policy from time to time so that you remain informed of the latest version.
Prohibited Use Policy
In using our Services, you will not:
1. Engage in, assist in, facilitate, or fund any trade or activity in violation of Applicable Law or the rights of others (including ours and those of other users of our Platform), such as but not limited to:
1.1 theft of property (including Funds) owned by others;
1.2 narcotics, controlled substances, prescription and pharmaceutical services, drug paraphernalia, or any substances designed to mimic illegal drugs;
1.3 illegal gambling; prostitution or illegal escort services;
1.4 unlicensed sale of firearms and certain weapons;
1.5 deceptive marketing practices, extortion, blackmail, or efforts to induce unearned payments;
1.6 encouraging, promoting, facilitating violence or instructing others to commit violence;
1.7 dealing in proceeds of any unlawful activity;
1.8 defrauding or attempt to defraud other persons (including us or other users of our Platform); or
1.9 infringing upon the copyright, trademark, or any other intellectual property right of another person (including us or other users of our Platform).
2. Operate any unlicensed money, payment, e-money, or any other financial services, including but not limited to exchanges of virtual currencies, sales of money orders or traveler’s checks, and escrow services;
3. Engage in sports forecasting or odds making;
4. Do transactions involving illegal or unlicensed online gambling;
5. Do any act that imposes an unreasonable or disproportionately large load on our infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information;
6. Interfere with another user’s or any third person’s access to or use of any our Services;
7. Publish, distribute or disseminate any unlawful material or information;
8. Transmit, upload, or otherwise cause any viruses, Trojan horses, worms, or any other harmful or deleterious programs on our Platform;
9. Harvest or otherwise collect information about other users of our Platform or any third persons, including without limitation email addresses, without their consent;
10. Act as a payment intermediary or aggregator or otherwise resell any of our Services without our express written permission;
11. Use or access any account on the Platform other than your own, except in specific instances permitted by us;
12. Attempt to gain unauthorized access to our Platform, our computer systems or networks, whether through password mining or any other means;
13. Violate or circumvent your obligations under the User Agreement and any of our policies and procedures, including, but not limited to, opening multiple Accounts or abusing our promotions or rewards system;
14. Do any other act analogous to any of the foregoing.
This Policy supplements and forms an integral portion of our User Agreement. Any capitalised terms not defined in this Policy shall have the meanings stated in the User Agreement.
Anti-Money Laundering (AML) Policy
Money laundering is defined as the process intended to mask benefits derived from serious criminal offenses or criminal conduct, as described under Anti-Money Laundering Act of 2001, to make it appear that such benefits originated from a legitimate source.
1.1 The Three Stages of Money Laundering
Generally, money laundering is composed of three (3) stages involving several transactions which could alert an intermediary such as the Company to the money laundering activity:
1. Placement – the physical act of disposing of the cash proceeds drawn from illegal activities
2. Layering – the act of separating illicit proceeds from their source by creating complex tiers of financial transactions in order to disguise the audit trail and to provide anonymity
3. Integration – the act of providing an appearance of legitimacy to criminally- derived wealth. If the layering process is successful, the integration step places the laundered proceeds back into the economy in a manner that their re-entry into the
financial system has the appearance of being normal business funds
1.2 Basic Principles to Combat Money Laundering
Coins.ph endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and terrorist financing:
・Established and duly appointed Compliance Office
・Know-Your-Customer (CDD and EDD)
・Know-Your-Customer (CDD and EDD)
・Reporting to AMLC
・Ongoing Employee Training
・Ongoing monitoring and Compliance Testing
・Record Keeping and Data retention in accordance with AML laws and regulations
・Internal Audit Function
1.2.2 Compliance with Laws
Coins.ph ensures that its business is conducted in conformity with the height of ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.
1.2.3 Cooperation with Law Enforcement Agencies
Within the legal constraints relative to client confidentiality, Coins.ph cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the Executive Director of the Anti-Money Laundering Council of the Bangko Sentral ng Pilipinas.