MNT exchange. (hereinafter referred to as the 'Company') has the following policy to protect users' personal information and rights and interests in accordance with the Personal Information Protection Act and to smoothly handle users' conflicts related to personal information.

This Privacy Policy applies to all services of the company's website, and may differ from services provided on other websites. When the company revises the personal information processing policy, it is notified through the website notice (or individual notice).
The company's privacy policy contains the following contents.
1. Consent to collection of personal information
2. Purpose of collection and use of personal information
3. Items of personal information collected and method of collection
4. Retention and use period of collected personal information
5. Sharing and provision of collected personal information
6. Matters concerning the management of the user's own personal information (view, correction, deletion, etc.)
7. Matters concerning the operation of cookies
8. Technical-management measures related to personal information
9. Matters concerning the collection of opinions and processing of requests related to personal information
Article 1. Consent to collection of personal information
 
The company establishes that a procedure for users to click the "agree" button or "cancel" button on the contents of the company's privacy policy or terms of use, and if they click the "agree" button, they agree to the collection of personal information as they are considered

 

Article 2. Purpose of collection and use of personal information

"Personal information" means information about a living individual that can identify the individual by the name, resident registration number, etc. (including those that can be easily combined and identified).

Most of the services provided can be used at any time without separate user registration. However, the company collects personal information of users to provide services for safe transaction of digital assets and storage and management of assets.

The company does not disclose the user's personal information without the user's prior consent, and the collected information is used as follows.

 

2-1 More useful services can be developed based on the personal information provided by users. The company prioritizes the services to be developed more efficiently based on the personal information provided by existing users to the company when developing new services or contents, and the company can reasonably select and provide the contents that users need. can.

2-2. The company notifies users of the details of personal information collected by the company, how to use it, information to be provided or entrusted, and how to destroy it through the personal information processing policy.

2-3. Users have legal rights regarding their personal information, including the right to self-determination of personal information. And the Privacy Policy guides you on how to exercise your legal rights regarding your personal information.

2-4. It also guides you on how to prevent personal information infringement accidents and recover damage when an accident has already occurred.

 

Article 3 Items of Personal Information to be Collected and Method of Collection

The company receives essential information for providing services online when users sign up as members to use member services. The essential information received when signing up for membership is name, resident registration number, e-mail address, address, phone number, passport information, etc. In addition, additional personal information may be requested according to the member's transaction level.

 

Article 4. Personal information processing and retention period
Personal information is processed and retained within the personal information retention/use period agreed upon when collecting personal information from the information subject, and, in principle, is destroyed without delay when the purpose of processing personal information is achieved.

- Records on contract or subscription withdrawal: 5 years
- Records on payment and supply of goods: 5 years
- Records on consumer complaints or dispute handling: 3 years

 

Article 5. Sharing and provision of collected personal information

The company uses users' personal information within the scope notified in "B. Purpose of collection and use of personal information", and uses it beyond the scope provided without the user's prior consent or, in principle, discloses the user's personal information to the outside world. Do not. However, the following cases are exceptions.

5-1 When users have agreed to disclosure in advance

5-2 When it is necessary for the settlement of charges for service provision

5-3 In case of violating the terms of use or policies such as the service terms and conditions posted on the website or other member services

5-4 If there are sufficient grounds to believe that personal information should be disclosed in order to take legal action against others by causing mental or material harm to others using the service

5-5 If there are other parts required by law

 

Article 6 Matters concerning the management of the user's own personal information (view, correction, deletion, etc.)

6-1. Users can use the company homepage at any time to view or modify their registered personal information according to the procedure, and may request cancellation of membership.

6-2. The company immediately handles the user's request for member information management through legal procedures.

 

Article 7. Matters concerning the operation of cookies
 
In order to provide customized services tailored to users, the company uses 'cookies' that store and retrieve users' information from time to time. Cookies are a small amount of information that the server (HTTP) used to run the website sends to the user's computer browser, and is sometimes stored on the hard disk of the user's IT equipment.

Article 8. Technical-management measures related to personal information

8-1 The company has the following measures to prevent money laundering and illegal transactions through theft of personal information.
The company is doing its best to prevent leakage or damage of members' personal information due to hacking or computer viruses. In preparation for damage to personal information, data is backed up from time to time, the latest vaccine program is used to prevent leakage or damage of personal information or data of users, and personal information is safely transmitted over the network through encryption algorithms. In addition, we use an intrusion prevention system to control unauthorized access from outside, and we strive to equip all possible technical devices to ensure systemic stability.

8-2 Users' all personal information is thoroughly protected by passwords. Only the member knows the password of the member ID (ID), and confirmation and change of personal information can only be done by the person who knows the password. Therefore, users should not disclose their password to anyone.

 

Article 9. Matters concerning collection of opinions and processing of requests related to personal information

The company collects the opinions of users in relation to personal information protection and prepares all procedures and methods to handle complaints. Users can report complaints by phone or e-mail by referring to the customer center information specified below, and the company will provide prompt and sufficient answers to users' reports.

 

 

AML/CTF/KYC Policy

MNT EXCHANGE Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of MNT EXCHANGE being involved in any kind of illegal activity.

Both international and local regulations require MNT EXCHANGE to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters:

1. Verification procedures.
2. Sanctions and PEP lists screening.
3. Compliance Officer.
4. Monitoring Transactions.
5. Risk Assessment.

1. Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CIP”). According to CIP, MNT EXCHANGE establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

“KYC” Bsaed on refers to:

1. Establish customer identity
2. Understand the nature of the customer’s activities (primary goal is to satisfy that the source of the customer’s funds is legitimate)
3. Assess money laundering risks associated with that customer for purposes of monitoring the customer’s activities

1.1. Identity verification
MNT EXCHANGE’s identity verification procedure requires the User to provide MNT EXCHANGE with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes MNT EXCHANGE reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

MNT EXCHANGE will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and MNT EXCHANGE reserves the right to investigate certain Users who have been determined to be risky or suspicious.

MNT EXCHANGE reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, MNT EXCHANGE reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the MNT EXCHANGE’s Privacy Policy and related regulations.

Once the User’s identity has been verified, MNT EXCHANGE is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
1) Customer Identification Program (CIP)

The minimum requirements to open an individual financial account in MNT Exchange are clearly delimited in the CIP as following steps :

1. Name
2. Date of birth
3. Address
4. Identification number ( Phone Identification )
5. ID card ( Passport )
6. Identification E mail

1.2. Bank account verification
The Users who are intended to use account in connection with the MNT EXCHANGE’s Services have to pass account verification in accordance with instructions available on the MNT EXCHANGE’s Site.

 

2. Sanctions and PEP lists screening.
MNT EXCHANGE screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:

on the onboarding stage when the user is submitting the application;
on each anti-fraud and AML alerts manually by Compliance Officer;
monthly by running automatically with a script to re-check all DB of customers.
For the screening process performing MNT EXCHANGE uses data (provided by AML/KYC software providers) integrated into the proprietary software and supported by World-Check One online search tool for manual confirmation.

 

3. Compliance Officer
The Compliance Officer is the person, duly authorized by MNT EXCHANGE, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of MNT EXCHANGE’s anti-money laundering and counter-terrorist financing, including but not limited to:

a. Collecting Users’ identification information.
b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
c. Monitoring transactions and investigating any significant deviations from normal activity.
d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
e. Updating risk assessment regularly.
f. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

 

4. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, MNT EXCHANGE relies on data analysis as a risk-assessment and suspicion detection tool. MNT EXCHANGE performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

1) Daily check of Users against recognized “black lists”, aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;

2) Case and document management.

With regard to the AML/KYC Policy, MNT EXCHANGE will monitor all transactions and it reserves with CEZA and I-wave the right to:

ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
request the User to provide any additional information and documents in case of suspicious transactions;
suspend or terminate User’s Account when MNT EXCHANGE has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

 

5. Risk Assessment
MNT EXCHANGE, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, MNT EXCHANGE is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

 

6  Suspicious Activity Reporting
6.1. As a regulated company, there are various regulations that need to be complied with and the company has an obligation to report suspicious activity to the relevant financial intelligent.
Failure to act on or report suspicions where there are reasonable grounds to suspect criminality, can be an offence under current legislation.
6.2 Staff are reminded of their obligations through training and refresher training and by following their obligations are helping the company protect itself against the risk of money laundering and terrorist financing and helping it comply with its legal obligations.

6.3. All staff must report suspicions as soon as possible following the procedures set out in the Reporting Suspicious Activity Policy.
To be able to report, staff must have reasonable grounds to suspect that the activity or transaction may involve proceeds of crime and or relate to terrorist financing AND have followed procedures, gathered facts as much as possible and determined there are still reasonable grounds for suspicion.

 

7. Customers Terrorist Financing (CTF)
7.1, Money Laundering is the process of disguising the origin of the proceeds of crime. Terrorist financing provides funds for terrorist activity. The use of products and services by money launderers and terrorists exposes the Company to significant criminal, regulatory and reputational risk.

7.2 This policy is designed to provide direction to staff on the approach and management of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) within the Company. This policy supports management’s objective of mitigating the following risks:
• Money laundering;
• Terrorist financing;
• Sanctions;
• Politically exposed persons (PEPs);
• Legal and regulatory risk.
This policy applies to all individuals working at all levels within the Company, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term workers, casual and agency staff, all of whom are collectively referred to as ‘staff’ in this document
7.3. Terrorist Financing
There can be considerable similarities between the movement of terrorist property and the laundering of criminal property:
some terrorist groups are known to have well established links with organizing criminal activity.
However, there are two major differences between terrorist property and criminal property. More generally:
• often only small amounts are required to commit individual terrorist acts, thus increasing the difficulty of tracking the terrorist property;
• terrorists can be funded from legitimately obtained income, including charitable donations, and it is extremely difficult to identify the stage at which legitimate funds become terrorist property.
The Company will ensure its staff are well versed in AML awareness and the underlying policies and procedures allowing the Company to demonstrate compliance with applicable rules and regulations in this aspect.

 

8. Policy Training
8.1. All employees will be made aware, through the annual compulsory training program of:
• The risks of money laundering and terrorist financing, the relevant legislation, and their obligations under that legislation;
• The identity and responsibilities of the Company’s nominated officer (To CEZA and            I-wave);
• The Company’s procedures in how to know and deal with potential money laundering or terrorist financing suspicious transactions or activity.

8.2. Staff training on anti-money laundering and counter terrorist financing will be carried out at least annually for all staff, and details will be recorded.