Legal

Terms of use of Infra-investments d.o.o. services

I. General

These Terms of Use of Infra-Investments d.o.o., Latinski trg 6, 1000 Ljubljana (hereinafter referred to as “Infra-Investments“) set out the terms and conditions of use of Infra-Investments services, their scope and the mutual rights and obligations of the customers and Infra-Investments. Infra-Investments services include the use of exchange services via crypto ATMs (hereinafter referred to as: ATM) and the use of exchange services on the basis of the concluded Exchange Contract, by executing a bank payment transaction, the so-called “Over the counter” exchange of cryptocurrencies (hereinafter referred to as “OTC”). 

Infra-Investments is registered in the Court Register of the Republic of Slovenia and entered in the Register of Virtual Currency Service Providers, which is maintained and managed by the Office for Money Laundering Prevention of the Republic of Slovenia.  

Before using any Infra-Investments Service, you should read the full Terms of Use carefully. If you do not agree to the Terms of Use, do not use the Infra-Investments Services.

2. Services

Infra-Investments provides a natural person or legal entity acting as a customer (hereinafter referred to as “you/customer“) with exchange services between virtual and fiat currencies (i.e. coins and banknotes designated as legal tender and electronic money of a country accepted as a medium of exchange in the issuing country) and exchange services between one or more types of virtual currencies (e.g. BTC, ETH, USDT, XMR). 

3. Risks

Trading virtual currencies involves certain risks (for more information click here  ). As a customer, you should carefully assess whether your financial situation and risk tolerance are suitable for the use of exchange services between virtual and fiat currencies and exchange services between one or more types of virtual currencies. As a customer, you bear the entire and irrevocable risks of ownership of virtual currencies.

As a customer, you acknowledge that you are aware and understand that investments in virtual currencies are risky. The risks arise from the legal and tax unregulated nature of virtual currencies, from their economic and market characteristics, the most frequently mentioned of which is the extremely high fluctuation in value (volatility) of each virtual currency, or from technical problems arising from the use of the Blockchain. 

There may be additional risks that Infra-Investments has not foreseen or identified in the Terms of Use.

4. Customer information

By using Infra-Investments, you represent and warrant that you are at least 18 years of age. If you are a representative of a legal entity, by using the Infra-Investments Services you represent and warrant: (a) that the legal entity is incorporated and is acting under the applicable laws of the country under which it is incorporated; and (b) that you are authorised by that legal entity to enter into legal transactions and to act as its agent.

Infra-Investments obtains from its customers the information required by Infra-Investments for the provision of its services for the purpose of customer due diligence in accordance with the provisions of the applicable Act on Prevention of Money Laundering and Financing of Terrorism (Official Gazette of the Republic of Slovenia, No. 48/22) (hereinafter referred to as “ZPPDFT-2“). The information requested includes personal data. By providing the requested information, you agree to notify infra-investments of any changes to your personal and other information, information about representatives, and other information relating to the customer and set out in the application for establishment of a business relationship, no later than 5 days from the date on which the change occurs. 

In accordance with Article 66 of the ZPPDFT-2, Infra-Investments specifically addresses politically exposed persons (PEPs).

Infra-Investments may refuse to conclude a Contract or to provide individual services with virtual currencies if the customer refuses to provide the information referred to in paragraph 2 of this Article.

Infra-Investments does not enter into Contracts or provide individual virtual currency services with UK clients. The decision follows the UK Financial Conduct Authority’s (FCA) issuance of PS23/6, entitled “Financial promotion rules for cryptoassets”. The policy outlines new rules and guidelines relating to marketing and communication practices for cryptocurrency firms.

As a customer, you guarantee the accuracy, completeness and truthfulness of all information provided and are liable for any damage caused to Infra-Investments as a result of providing incorrect, incomplete or untrue or misleading information. You undertake to notify Infra-Investments within 90 days of any change in circumstances affecting the change in tax residency status and to deliver a new self-certification and declaration within 90 days in accordance with the change in circumstances. You acknowledge that Infra-Investments will from time to time review Customer’s information to determine whether any circumstances (U.S. Indicia) may have arisen that could cause Customer to be treated as a U.S. taxpayer (U.S. Person). Notwithstanding the foregoing, you agree to promptly notify Infra-Investments in writing of any change in the circumstances of your U.S. status (U.S. Indicia), such as acquiring U.S. citizenship, acquiring a U.S. residential address, acquiring a U.S. telephone number, etc. You undertake to notify and provide appropriate documentation evidencing any change in circumstances. 

5. Costs

Infra-Investments charges fees for its services. Fees vary depending on the type of exchange service. Fees for the use of ATM exchange services are 5% of the value. Fees for the use of OTC exchange services are value-dependent and range between 1% and 4% and are specified in the individual Exchange contract. Infra-Investments reserves the right to change its fees at any time and at its sole discretion. You will be notified of any changes in advance by e-mail. Following such notification, it is your responsibility to review the changes in the fee. Your continued use of the Infra-Investments Services after receipt of notice of changes to the Terms of Use shall constitute your understanding, acceptance and agreement to the changes. 

Infra-Investments will not charge any fees other than fees.

6. Documentation for the customer

The Terms of Use, the Privacy Policy and any other rules applicable to particular services or types of services are available for the Customer’s review on the Infra-Investments website.

7. Relationship between Infra-Investments and the customer

Infra-Investments acts as a service provider for the exchange of fiat currency into virtual currency or vice versa and as a service provider for the exchange between one or more types of virtual currencies (e.g. BTC, ETH, USDT, XMR). Infra-Investments provides services in accordance with the customer’s instructions. 

Infra-Investments does not directly store virtual assets (it does not provide private cryptographic key protection services on behalf of its customers for the storage, custody and transfer of virtual currencies), but rather sells or buys virtual assets and transfers them between digital wallets and/or transaction accounts in accordance with the customer’s instructions. 

Infra-Investments does not have or acquire any rights, ownership or interest in the Virtual Asset by virtue of its relationship with the customer. Infra-Investments does not have or acquire any control over the Virtual Assets by virtue of its relationship with the customer, except in accordance with your instructions (subject to the provisions set out in the applicable law from time to time). 

8. Services

8.1. Exchange services on the basis of a concluded Exchange Contract, with the execution of a bank payment transaction; i.e. OTC

The OTC Exchange Services are intended for the execution of transactions exceeding the daily limits (above the value of EUR 5,000.00) on the basis of a concluded Exchange Contract. Prior to conclusion, the customers due diligence and the purpose of the establishment of a business relationship under the ZPPDFT-2 are verified. Infra-Investments and the customer may, if and to the extent permitted by the laws in force, otherwise regulate their mutual rights and obligations under the Exchange Contract than as set out in these Terms of Use. In the event of any inconsistency between the provisions in the Terms of Use and the specific agreements in the Exchange Contract, the specific agreements in the Exchange Contract shall prevail.

After the establishment of the business relationship, the Customer may conclude the Exchange Contract at Infra-Investments’ registered office and/or via e-mail.

The conditions for the execution of the Exchange Contract are fulfilled upon receipt of the amount agreed in the Exchange Contract by the Customer into the Infra-Investments TRR Account (in case of an exchange of EUR for virtual currency) or are fulfilled when the amount of virtual currencies (in case of an exchange of virtual currencies in EUR) agreed in the Exchange Contract is visible on the network in the Infra-Investments Digital Wallet and has received at least three confirmations.

The customer may conclude with Infra-Investments the Exchange Contracts set out in these Terms of Use, namely an Exchange Contract for the exchange of EUR into Virtual Currencies, an Exchange Contract for the exchange of Virtual Currencies into EUR or an Exchange Contract for the exchange of several types of Virtual Currencies, with a market price, where the execution time is immediate or depends on the duration of the bank transfers and transfers of Virtual Currencies (which require a minimum of 3 confirmations and may take up to 2 days). 

8.1.1. Validity of the Exchange Contract

The Exchange Contract is concluded for the period until the bank transfer to the Customer’s TRR or the transfer of the Virtual Currency to the Customer’s Digital Wallet, as the case may be, is executed, subject to the terms and conditions set out in the Exchange Contract. Infra-Investents shall send to the customer a so-called Exchange Confirmation after the execution of the Exchange Contract. 

The exchange contract is concluded for a period until execution, but no longer than 7 days from its conclusion. In the event that the bank transfer to the Customer’s TRR or the transfer of the Virtual Currency to the Customer’s Digital Wallet, for whatever reason, is not executed within 7 days of its conclusion, the Exchange Contract shall terminate. 

Infra-Investments and the Customer may agree that the Exchange Contract shall remain in force notwithstanding that it has not been executed within 7 days of its conclusion, provided that Infra-Investments and the Customer so agree. In such case, the validity of the Exchange Contract shall be extended until its execution. 

In the event that the Exchange Contract is terminated after the expiry of 7 days from its conclusion and Infra-Investments has received the Customer’s amount on Infra-Investments TRR account, Infra-Investments shall refund the Customer the amount in full (or less the costs of bank charges and exchange rate differences, if any). 

8.1.2. Execution of the Exchange Contract

Infra-Investments shall execute the Exchange Contract when it has received all the information from the Customer and when the conditions set out in Articles 16 and 17 of these Terms of Use and other conditions necessary for the execution of the Exchange Contract have been fulfilled.

8.1.3. Withdrawal of Infra-Investments from the Exchange Contract

Infra-Investments may unilaterally withdraw from the Exchange Contract in the following cases:

  • if the Customer fails to comply with the conditions set out in Article 16 of these Terms of Use in the event of an exchange of EUR into a virtual currency,
  • if the Customer fails to comply with the condition set out in Article 17 of these Terms of Use in the event of an exchange of Virtual Currency into EUR,
  • in the event of a conflict of interest, or, 
  • when, in Infra-Investments’ sole discretion, the Exchange Contract or its execution could be contrary to Infra-Investments’ business policy, 
  • in other cases provided for by law, regulation or the Terms of Use.

Infra-Investments shall immediately notify the Customer by e-mail of the withdrawal from the Exchange Contract after having verified the existence of the cases referred to in the preceding paragraph within a reasonable time and in a reliable manner, stating in the withdrawal the reason for withdrawal from the Exchange Contract.

Notwithstanding the first and second paragraphs of this Article, Infra-Investments may also withdraw from the Exchange Contract if Infra-Investments, in the exercise of its professional diligence, determines that such withdrawal is in the best interests of the customer or Infra-Investments.

In the event that Infra-Investments withdraws from the Exchange Contract after it has already received the funds, it is obliged to return the funds to the customer to the TRR account specified in the Application for Establishment of a Business Relationship.

In the event that Infra-Investments has received an amount of Virtual Currencies in Infra-Investments’ Digital Wallet, Infra-Investments will return the received amount of Virtual Currencies to the customer’s Virtual Wallet on the date of termination of the Exchange Contract. If the return of the Virtual Currencies to the customer would not be possible for any reason, Infra-Investments shall be entitled to sell the Virtual Currencies and transfer the purchase price amount, less any exchange differences, transfer and payment costs, to the customer’s TRR account specified in the Application for Establishment of a Business Relationship, unless a different method of settlement of the obligations is provided for in the Exchange Contract.

8.1.4. Withdrawal of the Customer from the Exchange Contract

The Customer may unilaterally withdraw from the Exchange Contract without giving any reason, at the latest until the execution of the Exchange Contract. 

In the event that the customer withdraws from the Exchange Contract after Infra-Investments has already received the funds, Infra-Investments is obliged to return the funds to the customer’s TRR account specified in the Application for the conclusion of the Business Relationship.

In the event that Infra-Investments has received an amount of Virtual Currencies in Infra-Investments’ Digital Wallet, Infra-Investments will return the received amount of Virtual Currencies to the customer’s Virtual Wallet on the date of termination of the Exchange Contract. If the return of the Virtual Currencies to the customer would not be possible for any reason, Infra-Investments shall be entitled to sell the Virtual Currencies and transfer the purchase price amount, less any exchange differences, transfer and payment costs, to the customer’s TRR account specified in the Application for Establishment of a Business Relationship, unless a different method of settlement of the obligations is provided for in the Exchange Contract.

8.1.5. Modification of the components of the Exchange Contract

If, after signing the Exchange Contract, the Customer wants to change the price, quantity, special condition or any other component of the Exchange Contract by sending a message to the following e-mail address: info@bitnik.eu, the Customer shall be deemed to have withdrawn from the originally concluded Exchange Contract and to have expressed an interest in concluding a new Exchange Contract. A customer may only amend the components in the Exchange Contract if the Exchange Contract has not yet been executed or if execution can be prevented by reasonable measures. An amendment to the Exchange Contract shall be effective if the amendment is confirmed by an Infra-Investments employee by e-mail. In the event of withdrawal from the originally concluded Exchange Contract due to a change in the components of the Exchange Contract at the Customer’s request, which has not yet been executed, Infra-Investments shall be obliged to return the Customer’s funds in accordance with Article 8.1.4 of these Terms of Use. Infra-Investments shall be entitled to reimbursement of handling costs.

8.1.6. Conclusion of the Exchange contract

The Contract shall be deemed validly concluded and enforceable upon Infra-Investments:

  • received a notification from SignRequest to email address: info@bitnik.eu that the Exchange Contract has been signed by the Customer; and
  • received a scan or photograph of the signed copy of the Exchange Contract at e-mail address: info@bitnik.eu or the signed Exchange Contract was received by an Infra-Investments employee, 
  • received the contractual amount of funds (EUR or virtual currencies).

8.1.7. Conditions for the exchange of EUR into virtual currency

When exchanging EUR into virtual currency, the Customer shall, in accordance with the Exchange Contract, transfer EUR funds to the Infra-Investments TRR. The Infra-Investments TRR number is specified in the Exchange Contract.

Infra-Investments shall execute the Exchange Contract in accordance with the terms agreed in the Exchange Contract. Infra-Investments shall not be liable for any time delay in the execution of the Exchange Contract if such delay is due to force majeure or limited operation of the transfer of payments between the payment service providers (banks).

Prior to the conclusion of the Exchange Contract for the exchange of EUR into Virtual Currencies, the customer is obliged to inform Infra-Investments by e-mail of the number (address) of the digital wallet to be indicated in the Exchange Contract where the Customer wishes to receive the Virtual Currencies.

8.1.8. Conditions for the exchange of virtual currencies in EUR

When exchanging virtual currency into EUR, the Customer shall ensure the transfer of virtual currencies from the Exchange Contract to the Infra-Investments Digital Wallet. The number (address) of the Infra-Investments Digital Wallet is specified in the Exchange Contract.

Infra-Investments shall execute the Exchange Contract in accordance with the timeframe agreed in the Exchange Contract. Infra-Investments shall not be liable for any time delay in the execution of the Exchange Contract if it occurs due to force majeure or limited operation of the network.

Prior to the conclusion of the Exchange Contract for the exchange of the Virtual Currency into EUR, the Customer is obliged to inform Infra-Investments by e-mail of the TRR number to be indicated in the Exchange Contract to which the customer wishes to receive the EUR.

8.1.9. Delivery of Virtual Currencies under the Exchange Contract to the customer

Infra-Investments shall, in accordance with these Terms of Use, ensure that the Virtual Currencies are dispatched to the Customer’s Digital Wallet within the timeframe specified in the Exchange Contract, but no later than 7 days.

For virtual currency transactions, Infra-Investments provides settlement in accordance with the network’s capabilities.

8.1.10. Delivery of the EUR funds under the Exchange Contract to the Customer

Infra-Investments shall, in accordance with these Terms of Use, ensure that the EUR funds are credited to the Customer’s TRR within the period specified in the Exchange Contract, but no later than within 7 days.

Before transferring the EUR funds to the customer’s TRR, Infra-Investments will reconcile any outstanding balance due by transferring a correspondingly reduced amount of EUR funds to the customer.

8.1.11. Currency exchange certificate

Infra-Investments shall send an Exchange Confirmation to the Customer no later than on the third Business Day following the execution of the Exchange Contract.

If the Customer does not object in writing no later than until 4:00 PM on the next Business Day following receipt of the Exchange Confirmation, the information provided in the Exchange Confirmation shall be deemed to be accurate. The Customer shall be deemed to have received the Exchange Confirmation sent by e-mail when the confirmation has been sent by Infra-Investments to the Customer’s e-mail address, unless the Customer proves otherwise, in which case the Customer shall notify Infra-Investments in advance of any change of e-mail address.

8.2. Currency exchange services via crypto-ATMs; i.e. ATMs

ATM exchange services are intended for the execution of cash transactions up to the daily limit. 

Before the first use of ATM, Infra-Investments will conduct a customer due dilogence and verify the purpose of establishing a business relationship under the ZPPDFT-2. 

Once the business relationship is established, the customer can start using the ATM exchange services.

Infra-Investments ATMs are available at various locations in Slovenia, which are published on the website https://bitnik.eu/atm/. ATM locations are subject to change. 

The use of the ATM exchange services is limited to EUR 5,000.00 per customer per day for the purchase of virtual currencies (cash-in) and EUR 5,000.00 per customer per day for the sale of virtual currencies (cash-out). 

By using the ATM Exchange Service, you agree that the exchange will be made at the rate offered by Infra-Investments ATM. Infra-Investments exchange rate is available on the website: https://bitnik.eu, subject to change at Infra-Investments’ sole discretion.

8.2.1. The process of converting EUR into the virtual currency of your choice

On the Infra-Investments ATM, first select the purchase option (“buy bitcoin”). The ATM requires the mobile phone number you entered when you signed up, to which you will receive an SMS security code to confirm your phone number. After entering the security code, the QR code of your digital wallet address is scanned. Infra-Investments accepts no responsibility for scanning the correct QR code of your digital wallet address. If you scan a QR code of a Digital Wallet address that is not your own, you are taking responsibility for sending the amount of Virtual Currency to another person’s Digital Wallet address. By pressing the “send” button, the transaction is complete. By proceeding with the purchase process, you agree and accept the exchange rate displayed at the time the transaction is initiated. If technical problems occur before the insertion of the EUR notes, the purchase process will start again. If technical problems occur after the insertion of at least one EUR note, the Infra-Investments ATM will complete the transaction and the selected amount of virtual currencies will be sent to the scanned digital wallet. Infra-Investments ATM only accepts EUR banknotes and does not accept coins. 

The Infra-Investments ATM always completes the EUR to the selected virtual currency transaction, regardless of any interruptions in the process. In extremely rare cases, an interruption may occur after the insertion of EUR notes where the transaction (sending virtual currencies) would not be completed. In such a case, Infra-Investments shall, at its discretion, either return the exact EUR amount to the customer or return the amount of virtual currency obtained by the exchange.

8.2.2. Virtual currency to EUR exchange process

On the Infra-Investments ATM, first select the sell option (“sell bitcoin”). The ATM requires the mobile phone number you entered when you signed up, to which you will receive an SMS security code to confirm your phone number. Specify the amount of virtual currency you want to sell by selecting which and how many EUR notes you want to receive. After you confirm your order, the Infra-Investments ATM will display a QR code of the Infra-Investments digital wallet address and the amount of virtual currency. Once you have scanned the QR code of the Infra-Investments Digital Wallet address into your Digital Wallet and sent the exact amount of virtual currency to the address displayed on the Infra-Investments ATM, the Infra-Investments ATM will automatically detect and process the receipt of the virtual currency and pay you the EUR notes for it. Infra-Investments accepts no responsibility for scanning the correct QR code of the Infra-Investments Digital Wallet address. If you scan the QR code of the Infra-Investments Digital Wallet address and manually modify the scanned address (e.g. delete or add letters or numbers from the Digital Wallet address), you are taking responsibility for sending the amount to another person’s Digital Wallet address. Infra-Investments ATM requires your telephone number as a means of identification. For the purposes of completing the transaction, you will be notified by SMS when your notes are ready for collection. Mobile services are not in our domain and we accept no responsibility for the delivery of the SMS message. In case the transaction has received at least one confirmation and you have not received the SMS, please try to collect the banknotes anyway (by clicking on the “cash out” text on the ATM).

The Infra-Investments ATM can dispense 20 banknotes at a time. In case of a larger transaction, the banknotes will be paid out in several consecutive withdrawals. You can collect the banknotes within 24 hours after receiving the transaction confirmation. After 24 hours, you will no longer be able to collect the banknotes from the Infra-Investments ATM. In this case, please contact us at help@bitnik.eu.

The transaction is complete when Infra-Investments receives the exact amount of virtual currency at the Infra-Investments digital wallet address and you receive all the EUR notes. A Transaction shall not be deemed to be completed or terminated if Infra-Investments does not receive the correct amount of Virtual Currency at Infra-Investments’ Digital Wallet address or if the Virtual Currencies have not been sent to the correct Infra-Investments’ Digital Wallet address. In the event that Infra-Investments has not received the Virtual Currency at its Digital Wallet address, the Transaction shall be deemed to be non-existent, and Infra-Investments excludes all of its liability for such Transaction. 

8.2.3. Errors

In the event of technical errors (e.g. Infra-Investments ATM does not pay out banknotes in the event of a sale of virtual currency, etc.) in the transaction execution process, we reserve the right to rectify the errors and execute the correct transaction (including the use of the correct price that was or should have been in effect at the time the transaction was initiated) and/or to cancel the transaction in its entirety and refund the funds received. In the event of errors, you may terminate the transaction process and request a refund. In the event that any errors have occurred in the process of your transaction, please notify us immediately or at the latest within 7 days of the error to the following email address: help@bitnik.eu. After the expiration of seven days from the date of the error, the reporting of the error is no longer possible and Infra-Investments shall not be liable for any refund and excludes all its liability for refund. Subject to timely notification of the error, we will refund any EUR funds or amount of Virtual Currency to you within thirty (30) days of receipt of the notification at the latest. 

8.2.4. Payment methods

The exchange of EUR into the Virtual currency via the Infra-Investments ATM can only be made with EUR banknotes (the Infra-Investments ATM does not accept coins). 

8.2.5. Refunds and taxes

All purchases and sales of virtual currencies through the use of our exchange services are final. We do not accept or offer any refunds for your purchase or sale except as or to the extent expressly provided in these Terms of Use. 

In accordance with Article 44 (d) of the Value Added Tax Act (VAT Act-1), our services are exempt from value added tax. As a user, you are obliged to pay all taxes related to the transaction and, if applicable, to report the transactions in question to the relevant institutions.

9. Warranties and limitation of liability

9.1. Compliance

Infra-Investments undertakes to comply with the applicable laws and regulations, in particular the regulations governing the virtual currency business, the protection of personal data, the prevention of money laundering and terrorist financing and other relevant regulations, these Terms of Use, the concluded Exchange Contracts with the customer and the customer’s requirements and instructions, in the performance of the Virtual Currency Services under these Terms of Use and the Exchange Contracts, to the extent that the law or the aforementioned acts do not provide otherwise.

9.2. Infra-Investments’ Liability 

Infra-Investments shall not be liable for any failure to execute, incorrect execution or late execution of a transaction, except in the case of willful misconduct or gross negligence of Infra-Investments. 

Infra-investments shall not be liable for any damages (including but not limited to direct damages, consequential damages, loss of profits, revenue or data):

  • if the execution of the transactions is the result of exceptional and unforeseeable circumstances beyond Infra-Investments’ control or, despite its best efforts, Infra-Investments’ control, 
  • if the execution of the transaction is the result of fraud by the Customer or if the Customer has intentionally or grossly negligently failed to fulfil its obligations in relation to the use of Infra-Investments’ exchange services, 
  • if the customer has provided Infra-Investments with an incorrect digital wallet or TRR address,
  • if the transaction is the result of fraud or abuse, 
  • if there has been unauthorised access to your trr or digital wallet, 
  • if the Customer fails to notify Infra-Investments of the defect immediately and without delay or within 7 days of the defect at the e-mail address: help@bitnik.eu,
  • if there is an error, interruption, deletion of data or e-mails or delays in the performance of the exchange services which are beyond the control of Infra-Investments,
  • arising from technology, including but not limited to damage caused by security intrusions, viruses, deletions, interruptions of electronic connections, network failures or any other technical failures.

9.2. Conflicts of interest

Infra-Investments offers and provides the exchange of EUR into several different virtual currencies or virtual currencies to a number of different customers and therefore conflicts of interest may arise between Infra-Investments’ own customers. Infra-Investments has established and implements appropriate measures to identify and prevent conflicts of interest, the occurrence of which could be detrimental to the interests of its customers. 

9.3. Protection of personal data

The protection of personal and confidential data is defined in the Privacy Policy. 

10. Final provisions

10.1. Default and outstanding obligations of the Customer

In the event of default in the payment of any due and unpaid obligation hereunder or in connection with these Terms of Use and the Exchange Contracts, the Customer shall also be liable to Infra-Investments for statutory interest on late payment. In connection with the payment and accrual of default interest, the customer irrevocably authorises Infra-Investments to set off upon receipt of EUR funds or Virtual Currencies intended for the execution of the Transaction, up to the amount of the outstanding obligations together with the handling costs that would be incurred in doing so.

10.2. Customer consents

By signing the Application for Establishment of a Business Relationship, the Customer expressly agrees to these Terms of Use. If the Customer has provided Infra-Investments with his/her e-mail address, the Customer agrees to be informed of changes to Infra-Investments’ Virtual Currency Business Documents and other relevant documents by e-mail.

The Customer is obliged to check the accuracy and completeness of Infra-Investments’ notifications, in particular notifications received in connection with the Exchange Service, e.g. notifications of receipt of the Exchange Contract, invoices of executed exchanges, etc., on an ongoing basis. If the Customer does not appeal in relation to a particular notice within the time limits set out in these Terms and Conditions, the Customer shall be deemed to have accepted the notice or to have agreed to Infra-Investments’ actions and conduct resulting from the notice. If the Customer fails to receive any notice under these Terms of Use or under the Exchange Contract in the usual manner and within the usual time limits, it shall promptly notify Infra-Investments.

10.3. Modification of the Terms of Use

Infra-Investments reserves the right to modify these Terms of Use at any time and at its sole discretion. You will be notified of any changes in advance by e-mail. Upon such notice, you are required to review the amended Terms of Use. Your continued use of the Infra-Investments Services following your receipt of notice of changes to the Terms of Use constitutes your understanding, acceptance and agreement to the changes.

10.4 Complaints procedure and judicial settlement of disputes

Any disagreement, dispute or claim arising out of the relationship between Infra-Investments and the Customer arising out of the provision of ATM and OTC exchange services, which Infra-Investments and the Customer are unable to resolve amicably or by negotiation, shall be settled at the District Court in Ljubljana.

10.5 Communication with customers

Infra-Investments communicates with its customers in Slovenian. In case of communication with foreign countries, English is used. The methods of communication used between Infra-Investments and the customer are: in person at the offices, in writing by e-mail, orally by telephone and through the publicity media (including Infra-Investments’ website and daily newspapers published in the territory of the Republic of Slovenia). Infra-Investments sends reports, invoices and contracts to the customer by e-mail.

10.6. Law and validity

These Terms of Use and contractual relationships relating to them are governed by Slovenian law.

These Terms and Conditions of Use shall come into force on 1 July 2022. The Terms and Conditions of Use for Cryptocurrency Business dated 1 January 2022 shall expire on that date. Amendments to the Terms and Conditions of Use shall be accepted by the Director of Infra-Investments.

 

Ljubljana, 1.7.2022

Infra-Investments d.o.o  

 

 

 

Privacy Policy 

(General information on Personal Data Protection)

 

1. Introduction

When you use our services, you trust us with your personal data. At Infra-Investments d.o.o. (hereinafter as "Infra-Investments" or "we" or "us"), we are aware of the importance of personal data protection, and we treat personal data of individuals with care and in accordance with the applicable regulations governing the protection of personal data. In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter as "GDPR"), Infra-Investments, as the controller of personal data, is required to provide individuals whose personal data it processes with all relevant information about the processing it carries out. 

In order to implement the principle of fair and transparent processing, Infra-Investments, as the controller of the personal data of individuals, has prepared this General Information on Personal Data Protection (hereinafter referred to as "General Information"), which enables the individual to obtain, in one place, all the relevant information relating to the processing of personal data carried out by Infra-Investments. With this information, we want to inform you what personal data we collect about you, why we collect it, how we use it, which processing operations we carry out, and what your rights are and how you can exercise them. 

Infra-Investments will store and protect personal data in such a way that there will be no unjustified disclosure of data to unauthorised persons. Infra-Investments undertakes not to disclose, lend or sell personal data to any third party without first obtaining the consent of the data subject or without a basis in law. Infra-Investments employees process personal data solely in the context of their work. 

Infra-Investments processes personal data for various purposes, which we define in more detail below in this General Information. 

 

2. Operator and contact details

The data controller is Infra-Investments d.o.o., Latinski trg 6, 1000 Ljubljana, Slovenia. For any questions, please contact us via e-mail: info@bitnik.eu. 

 

3. Collection and use of your data

3.1 How do we collect your data and what types of personal data do we collect and process?

At Infra-Investments, we obtain your personal data from a variety of sources: 

  • directly from you when you choose a particular service; 
  • from official records, where and insofar as we have a proper legal basis for doing so; 
  • from public sources (public books and registers, databases, social networks, the internet or other public sources of information); 
  • we also generate data ourselves by processing the data we obtain when you use the Services (e.g. for reporting, analysis purposes). 

 

All data and information collected is processed by employees only in the context and for the purpose of carrying out their work. We process the following types of personal data: 

  • basic identification and other personal details and contact details: name, date of birth, place of (permanent and temporary) residence, tax number, telephone number and email address. This information is necessary for the conclusion and performance of the business relationship or for the communication of the offer; 
  • socio-demographic data: this is standard statistical information such as your age, residential address, gender, level of education, income, etc. This information is usually disclosed when you start using our services or is inferred from other available information; 
  • transaction data: our systems record every transaction you make using our exchange services (including every cash withdrawal and deposit at a crypto ATM). Each transaction also contains additional information such as the amount of the transaction, the account (or digital wallet) number of the transaction and the date and time of the transaction. From such information, we can make inferences about your transaction-related behaviour (e.g. how often you withdraw cash; whether transactions are consistent with your income; whether your income comes from multiple sources, etc.); 
  • details of other businesses: when you enter into a business relationship, you must also indicate the source of your income. If you are an employee, you will be asked to provide the pay slips, and if you run a business, the bank statements; 
  • information about the channels through which you contact Infra-Investments: you can contact Infra-Investments through different communication channels and at the company's headquarters (telephone, e-mail, website, etc.). When you log in and perform other activities, your computer automatically sends your IP address to the Infra-Investments server that you accessed. This allows us to detect the network and subnet number where your computer is located. If you have enabled web cookies in the browser you are using, they will enable the website to function smoothly with all its functionalities and provide you with a better user experience. We can also specify the duration of the login, what data you have entered in the forms, all of which is done for security reasons. Information about your operating system and its version, as well as technical data about the devices you use, help us to ensure that our websites and services are displayed correctly on your devices, as this is the only way we can continuously improve our services and adapt them to your technical needs; 
  • social networks: we use social networks such as Facebook, Twitter, LinkedIn. We do not store the information posted on your profile, but we do use it (if you consent when you use these social networks) to improve your user experience and to share content across different social networks; 
  • data and information that we process in order to comply with our legal obligations: this is data that we need to collect, evaluate and store for a certain period of time in order to comply with our legal obligations (e.g. Such data may, for example, include: the source and origin of your income, your capital interconnections, your nationality, your citizenship, your residential address, your field of activity, your political exposure, etc. We may also use this information for other purposes in accordance with your consent or where there is another legal basis. 

 

3.2. When do we obtain your personal data?

Infra-Investments may only process personal data if it has a lawful basis to do so. Depending on the nature of our business, the following lawful bases generally apply: 

  • a contract or negotiations to conclude such a contract (e.g. use of exchange services on the basis of a concluded Exchange Contract, through the execution of a bank payment transaction); 
  • the law; 
  • the personal consent of the data subject; 
  • a legitimate interest of Infra-Investments or of a third party which is not overridden by the interests or rights of an individual. 

Each processing of personal data has a specific purpose, which the Infra-Investments discloses to the individual when collecting his/her personal data. Personal data collected for a specific purpose shall only be processed by the Infra-Investments for an additional purpose if that purpose is compatible with the original purpose. 

 

3.2.1. processing of personal data for the purposes of concluding and executing contracts (use of exchange services via crypto ATMs and use of exchange services on the basis of a concluded Exchange Contract, through the execution of a bank payment transaction. 

Infra-Investments processes your collected personal data lawfully when the processing is necessary: 

  • for the purpose of concluding a contract (e.g. when a customer is only interested in a specific service and makes an enquiry to Infra-Investments); 
  • in the context of the provision of already agreed exchange services. 

 

You must provide Infra-Investments with a certain amount of information or we cannot conclude a contract with you. We collect and process the following data when we establish a business relationship:

  • identification data (personal name, nationality, date and place of birth, address of permanent and temporary residence, tax number, number, type, name of issuer and date of validity of the official identity document),
  • information on the purpose and nature of the business relationship (purpose of the business relationship, employment status and employer),
  • information on the origin of the assets,
  • information about your political exposure,
  • transaction details (your bank account number, your e-wallet address, the amount of the transaction, the date and time of the transaction), 
  • contact details (in particular telephone number and email address).

If you conclude the Exchange Agreement on behalf of a legal entity, we collect and process the above personal data on the legal representative of that legal entity, as well as data on the beneficial owners of the legal entity (personal name, nationality, permanent and temporary residence address, tax number, data on the relationship within the legal entity) in accordance with the provisions of the applicable law. 

If you do not provide us with this information in full, Infra-Investments may, at its sole discretion, refuse to enter into a business relationship with you.  

 

3.2.2. Processing of personal data on the basis of law 

The processing of personal data by Infra-Investments is also based on legal and other regulations, in particular tax legislation and relevant European regulations, in particular with regard to reporting obligations, identification and verification of the identity of the client, reporting of statutory and required information for the prevention of money laundering and terrorist financing to the Office for Money Laundering Prevention, which allow or even command Infra-Investments to collect personal data and, in certain cases, to further transmit them to state authorities. If you are unwilling or unable to provide the requested information, Infra-Investments must take the measures provided for by the relevant law in such cases. In practice, this usually means that you are not allowed to enter into a particular contractual relationship or that you have to terminate it. For identification purposes, Infra-Investments may, on the basis of the laws on identity cards and travel documents in conjunction with the legislation governing the prevention of money laundering and terrorist financing and tax legislation, copy your identity document and store a copy in accordance with the legislation. 

 

3.2.3. Processing of personal data based on legitimate interest 

Infra-Investments may also process your personal data where it demonstrates a compelling reason to do so, relying on a legitimate interest of Infra-Investments or a third party, but only if your interests or fundamental rights and freedoms do not override the interests of Infra-Investments. Before processing personal data on this basis, Infra-Investments shall carry out a prior risk assessment of the protection of personal data of individuals and shall weigh the justification for the use of this legal basis for the use of personal data. Infra-Investments processes personal data on the basis of legitimate interest in the following cases, among others: 

  • preventing, detecting and investigating fraud, deception and abuse, or pursuing or opposing legal claims.

 

3.2.4. Processing of personal data based on your consent 

The processing of personal data may be based on your consent, for the purposes specified in the consent:

  • to carry out marketing activities, such as sending out newsletters, informing about general offers, news, benefits, events, prize draws and other news relevant to each segment of exchange users. 

The conclusion of the contract or the provision of the exchange services is not conditional on your consent. You give your consent voluntarily and if you decide that you do not wish to give your consent or later withdraw your consent, this will in no way reduce your rights arising from your business relationship with Infra-Investments or to use the Services which do not require such consent or will not impose additional costs or other aggravating circumstances on you. In the event that you do not give your consent to the purposes of the processing of personal data listed above, give your consent partially or withdraw your consent (partially), Infra-Investments will only inform you in the cases and to the extent of the consent given or in the ways permitted by applicable law (e.g. general information, compliance with Infra-Investments' obligation to inform the service you are using). You may withdraw or modify the consent given at any time: 

  • by sending an email to info@bitnik.eu; 
  • by post to Infra-Investments' registered office; 
  • Infra-Investments will record your request to withdraw your consent in its system and will start to exercise it immediately. Infra-Investments will continue to process, even after withdrawal of your consent, only such data relating to you as it is required to process in order to comply with its legal obligations, to perform its contract with you and to pursue its legitimate interests. 

 

3.3. Who we share your data with

3.3.1. With our contractual processors 

We engage contract processors to carry out parts of the processing of personal data on our behalf, and we enter into an appropriate statutory personal data processing contract with such contract processors, committing them to the same standard of protection of personal data as if we were carrying out those parts of the processing of personal data ourselves. At the same time, these contractual processors shall process the data only for the purpose of providing the contractually defined services and for no other purpose, nor shall they use the data for their own purposes or for the purposes of third parties. 

Contract processors include, but are not limited to, e.g. computer service providers, telecommunications operators, advertising agencies, etc.).

 

3.3.2. With third parties

Infra-Investments transfers your personal data to the following third parties: 

  • to the users defined in point 3.3.1 of this General Information; 
  • to the competent national authorities. In certain cases prescribed by the applicable law, we are obliged to disclose or report your personal data to the competent state authorities and to the authorities responsible for financial, tax or anti-money laundering and anti-terrorist financing supervision (e.g. the Office for the Prevention of Money Laundering, the Financial Administration of the Republic of Slovenia, the courts, etc.). We are also obliged to disclose them to third parties if such disclosure or transmission is required by law;
  • to natural and legal persons who demonstrate an adequate legal basis for receiving personal data, upon their reasoned written request; 
  • natural and legal persons who provide proof of the data subject's authorisation; 
  • natural and legal persons for whom the data subject has given his/her explicit consent to Infra-Investments to provide personal data to them; 
  • natural and legal persons, where this is necessary for the performance of a contract or pre-contractual activity. 

In all cases, we will ensure that appropriate safeguards are in place and that we process personal data only within the scope of the lawful legal basis and the purposes chosen. 



 

3.4. Transfer of data to third countries

Infra-Investments does not, in principle, transfer or transmit the personal data collected to third countries or international organisations, except: 

  • if we receive a lawful request to transmit data to administrative authorities for the purpose of implementing measures to prevent money laundering and terrorist financing. Whenever possible, your data will be processed in the European Economic Area (EEA). However, as some of our service providers or their processors are located in countries outside the EEA, your personal data may be processed in those countries. Some of these countries may have different personal data regulations to those in the European Union. In such a case, Infra-Investments may transfer personal data to the user or to a third party in a third country;
  • if the European Commission has issued a decision on the adequacy of the level of data protection for the third country, its territory or sector; 
  • if Infra-Investments provides appropriate safeguards: 
    • by a legally binding and enforceable instrument adopted by public authorities or bodies; 
    • with binding corporate rules; 
    • with standard data protection clauses (Standard Contractual Clauses) approved by the European Commission; 
    • an approved code of conduct, together with binding and enforceable commitments by the controller or processor in the third country to apply appropriate safeguards, including with regard to the rights of data subjects; 
    • an approved certification mechanism, together with binding and enforceable commitments by the controller or processor in the third country to apply appropriate safeguards, including with regard to the rights of data subjects. 

 

4. Retention of your data

The period of retention of personal data depends on the legal basis for the processing and the purpose of the processing of each category of personal data. Personal data shall be kept only for as long as is necessary to achieve the purpose for which they were collected and processed. In determining this period, we take into account in particular the following: 

  • the duration of your contract with Infra-Investments; 
  • the time it takes to process your request or complaint; 
  • your interest in our products and services; 
  • the need to keep a record of your interactions with us in order to manage our business relationship effectively; 
  • our legal or regulatory obligations. 

For personal data processed in the context of the provision of individual services or other activities, Infra-Investments complies with the retention periods established by applicable law. As a general rule, personal data is retained for ten years after the termination of the business relationship or the completion of the transaction. Data processed on the basis of your consent will be retained until your revocation or request for deletion of the data, but no longer than 10 years after the termination of the business relationship or until the purpose for which it was obtained has been fulfilled. Personal data will be erased, destroyed, blocked or anonymised after the fulfilment of the specific purpose of the processing. 

5. Your rights in relation to the processing of personal data

Under the applicable law, you are guaranteed a number of rights, including, but not limited to:

  • Right to information: you have the right to clear, transparent and understandable information about how we use your personal data and about your rights. 
  • Right of access to your personal data: you have the right to obtain information regarding the processing of your personal data (including which data is used, for what purposes, etc.) and a copy of it. 
  • The right to data portability, i.e. the right, under certain conditions, to receive the personal data you have provided to us in a structured, commonly used computerised format and to transmit it to a third party, if technically possible. 
  • Right to rectification: you have the right to correct your information if it is inaccurate or incomplete, despite our efforts to keep it up to date, so that we can fulfil our obligation to keep information about you up to date. 
  • Right to erasure (or right to be forgotten): you have the right to have your data erased or deleted. This right may be limited in relation to our contractual or legal obligations (ongoing contracts) (in particular the prevention of legal proceedings). 
  • Right to object to the processing of your personal data, if you do not agree to the processing of your personal data which is carried out on the basis of our legitimate interests or if you do not want your personal data to be used for direct marketing purposes, you may request that such processing cease. 
  • The right to withdraw your consent at any time for the purposes for which your consent was obtained, without prejudice to the lawfulness of the processing carried out on the basis of the consent until its withdrawal. 
  • Finally, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) regarding the processing of your personal data. We encourage you to, 

You may exercise the above rights by sending a written request to Infra-Investments d.o.o., Latinski trg 6, 1000 Ljubljana, Slovenia, or by email to info@bitnik.eu, where you can also obtain further information regarding your rights. We will comply with your request as soon as possible and in any event within one month. In exceptional cases, especially for more complex claims, we have the right to extend this time limit by two additional months. Under certain conditions, we may refuse your request, or charge you a reasonable fee, or require you to provide additional information necessary to confirm your identity beforehand. The exercise of the above rights may affect, restrict or prevent the (further) use of our services. 

If there is a breach of your personal data protection that is expected to pose a significant risk to your rights and freedoms, we will notify you immediately and preferably within 72 hours. 

 

5.1. Right to lodge a complaint concerning the processing of personal data 

Any complaint regarding the processing of personal data can be sent to the following email address: info@bitnik.eu.

We cooperate with the relevant regulatory authorities to resolve complaints about the processing of personal data that we cannot resolve directly with you. You have the right to a remedy. You can contact the Information Commissioner of the Republic of Slovenia (Zaloška 59, 1000 Ljubljana, e-mail: gp.ip@ip-rs.si). Please contact us before making any complaint so that we can resolve your problem together. 

 

6. What rights do you have in relation to automated profiling?

Infra-Investments does not use decision-making based solely on automated processing, including the profiling of individuals, which produces legal effects concerning them or similarly significantly affects them. Should we use it in individual cases, we will specifically inform you of this and provide you with the right to have the controller intervene personally; the right to express your point of view; the right to obtain an explanation of the decision taken in this way; and the right to contest such decision. 

 

7. Additional information where the data have not been obtained from the individual 

Personal data not directly collected from the data subject shall be made available to the data controller at the request of the data subject. 

 

8. Final provisions

Infra-Investments reserves the right to amend or supplement this General Information in order to ensure compliance with data protection regulations. The General Information is available at Infra-Investments' head office and on the website https://bitnik.eu/. Anything not specifically provided for in this General Information or in the contract you have entered into with Infra-Investments shall be subject to the provisions of applicable law. This General Information on the protection of personal data is valid and applicable as of 1 June 2022. 

 

Infra-Investments d.o.o. 

 

 

General rules for using the video identification service 

Infra-Investments d.o.o.

 

1. Definitions

 

  1. “VideoID” is the process of identifying and verifying the identity of a customer when carrying out a customer screening by means of a video electronic identification device, carried out by Infra-Investments d.o.o..
  2. “Customer” means a natural person (customer, legal representative or proxy) who identifies himself/herself through the VideoID process. 
  3. “VideoID Service Provider or Infra-Investments” means Infra-Investments, trgovina in storitve, d.o.o., Latinski trg 6, 1000 Ljubljana. 
  4. For the purposes of video-electronic identification, an “official identity document’ is an official identity document bearing a bio metric photograph and containing optical and other security features at least equivalent to holographic elements or elements which respond to the movement of the document and thus affect their perception from different angles and can be clearly visually identified and verified, including in the form of a screenshot. 
  5.  “ZPPDFT-2” means the Law on Prevention of Money Laundering and Terrorist Financing (Official Gazette of the Republic of Slovenia, No 48/22).  

 

  1. General provisions

 

  1. The general rules of use of VideoID set out the rules for obtaining data about the customer, identifying the customer and verifying the obtained data by comparing the data from the customer’s official identity document, capturing image and sound recordings and storing the data, the scope of these services and the mutual rights and obligations of the customer and Infra-Investments d.o.o..
  2. VideoID shall be implemented for the purposes of identifying and verifying the identity of customers by means of video electronic identification in accordance with Article 34 of the ZPPDFT-2 without their personal presence, subject to the following conditions:
  • no increased risk of money laundering or terrorist financing has been identified;
  • the identity of the customer is established and verified solely on the basis of an official identity document bearing a photograph and giving details of the customer’s name and date of birth; 
  • the customer is domiciled or established in a Member State or a third country which has an effective system in place for the prevention and detection of money laundering and terrorist financing; and
  • the client is not domiciled or established in countries included in lists of high-risk third countries with strategic vulnerabilities, which do not have adequate measures in place to prevent and detect money laundering or terrorist financing, or which are more likely to be affected by money laundering or terrorist financing.

2.3.VideoID includes the technology and process to identify a person over an internet video and audio connection in both directions in a way that provides real-time video and audio transmission without interruption. 


3. Types of data to be captured

 

VideoID captures the following personal data:

  • first and last name,
  • address of permanent and temporary residence, if any,
  • date and place of birth,
  • tax number,
  • nationality,
  • the number, type and name of the issuer of the official identity document,
  • date of issue of the official identity document
  • the date of validity of the official identity document,
  • purpose of VideoID,
  • the date and time of the VideoID, screenshots of the user’s image and his/her official ID,
  • an audio recording of the entire procedure.

 

4. Description of the VideoID procedure

 

  1. When a customer confirms that he/she wishes to identify him/herself using a VideoID, this shall be recorded by the VideoID service provider. The customer will then receive a confirmation email with a link to book an appointment to perform the VideoID. The customer selects the VideoID appointment, which must be confirmed by the VideoID service provider. Once the appointment is confirmed, the customer receives an email link with an invitation to VideoID (at the pre-arranged appointment). Clicking on the received link starts the VideoID process.
  2. The customer must also produce an identity document with a biometric photograph (ID card or passport). He then initiates a video call to a call centre where his call is answered by a specially trained operator (hereafter: operator). At the beginning of the identity verification process, the customer is asked to give his/her explicit consent to the entire VideoID process and to the production and storage of screenshots of the customer’s image and images of his/her identity document, as well as an audio recording. The client will be sent a unique ID number by email or SMS, which he/she must communicate to the provider via a link as a condition for successful completion. During the video identification process, the contractor asks the client to tilt his/her head in different directions and verbally communicate the serial number of the ID document. During the video identification, the conversation between the operator and the user is recorded and several screenshots are taken showing the customer’s face and the front and back of the ID document. In addition, customer data is captured and stored for later validation of the VideoID process. After the completion of the VideoID, the data is stored on the Infra-Investments Ltd. server.

 

The VideoID processor shall terminate the process when:

  • poor lighting or sound conditions at the customer’s premises or poor quality of the image or sound transmission do not allow the customer to be identified and verified;
  • it is not possible to produce a screenshot suitable for visual verification of the customer or his/her official identity document or the data contained therein;
  • any discrepancy or inconsistency is found in the authentication of an official identity document;
  • there is uncertainty about the identity of the customer;
  • when there is a likelihood of possible influence by third parties on the expressed will of the customer and, consequently, on the validity of the consent.

 

In this case, the reason for the interruption shall be recorded by the contractor in the data collected in the procedure and the user shall be referred to undergo the VideoID again or to undergo the personal identification in person.

 

During the video link, the contractor shall check:

  • the authenticity of the official ID document;
  • compares the image of the customer on the document with the customer’s face;
  • the front of the official identity document;
  • knowledge of the information on the front of the official identity document that the customer is required to provide;
  • the presence of optical security features on the official identity document (e.g. a hologram);
  • the existence of formal marks on the official identity document;
  • the integrity of the document and that the image is not glued and the lamination is not damaged;
  • the last page of the official identity document;
  • validity of the data on the official identity document with the MRZ code (automatic);
  • the data of the official identity document with the customer’s previously obtained data;
  • a comparison of the customer’s image, the data of the official identity document and the image of the customer’s official identity document;
  • matching the logical consistency of the data: image, issue of official identity document, date of birth.

 

5. Compliance with regulations and standards

 

The VideoID service complies with the ZPPDFT-2 and the Rules on technical requirements for video-based electronic identification devices. 

 

6. Processing of personal data

 

  1. The VideoID Service Provider undertakes to fully comply with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “GDPR”) and the applicable provisions of the Personal Data Protection Act when implementing the VideoID.
  2. Infra-Investments d.o.o., as the personal data controller, will process personal data in accordance with its Privacy Policy, these General Rules and any customer consents, which also contain information on the handling of personal data and the rights of customers in relation to the processing of personal data.
  3. The captured data and the result of the identification are used solely for the purpose of verifying and identifying the user when entering into a business relationship with Infra-Investments and to comply with the requirements under the ZPPDFT- 2.
  4. The captured data and the identification result are stored in the Infra-Investments d.o.o. system for 10 years after the end of the Exchange Contract or the transaction.
  5. Infra-Investments will implement appropriate procedures and measures for the protection of personal data, including those set out in the Privacy Policy, taking into account the latest technological developments, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the risks to the rights and freedoms of individuals, which vary in likelihood and severity.

 

7. Final provisions

 

  1. The general rules on VideoID are published on the Infra-Investments website (https://bitnik.eu/en/legal/). 
  2. Infra-Investments notifies users of changes to this policy and its components via the website.
  3. The general rules for using the video identification service Infra-Investments d.o.o. enter into force on 1 August 2022.

 

 

Proof of source of wealth and funds 


According to the Prevention of Money Laundering and Terrorist Financing Act (Official Gazette of the Republic of Slovenia, No. 48/22), virtual currency asset providers are required to verify the origin of the wealth and funds that will be the subject of the transaction. If the source of the funds is not proven, it is not possible to conclude a business relationship with Infra-Investments d.o.o..

There are different sources of wealth and funds, which are subject to specific requirements. Below we explain what evidence is required for the most commonly used sources.

All documents must be attached in Slovenian, English, Slovak or Czech original. If the original is in any other language, the documents must be attached in a certified translation into Slovene or English. 

 

1. Savings from regular income

  • Provide your employer's latest pay slip (and/or tax return) or a document in your possession AND bank statement showing that the savings are higher than or equal to the amount of planned transactions. The period of the statement should cover at least three months. The attached document must show your name, the date and the amounts.

    2. Inheritance
     
  • Provide a copy of the succession order. The attached document must show your name, the date and the amounts.

    3. Sale of property (real estate, vehicle, etc.)
     
  • Provide a copy of the contract of sale AND a bank statement showing the transaction from the sale. The attached documents must show your name, the date and the amounts.

    4. Income from pension savings
     
  • Provide details of the pension fund (together with a fund statement, if available) AND a bank statement showing the transaction from the pension savings. The attached documents must show your name, the date and the amounts.

    5. Gift or donation
     
  • Provide a gift agreement or a donor's/gift-giver's declaration/letter explaining the nature of the funds AND a bank statement showing the transaction. The attached documents must show your name, the date and the amounts.

    6. Loan
     
  • Provide a loan agreement AND a bank statement showing the loan payment. The attached documents must show your name, the date and the amounts.

    7. Lottery or gambling winnings
     
  • Provide a copy of the winning certificate and a bank statement showing the transaction of the winnings. The attached documents must show your name, the date and the amounts.

    8. Dividends
     
  • Provide a certified copy of the dividend certificate, a copy of the company accounts AND a bank statement showing the transaction. The attached documents must show your name, the date and the amounts.

    9. Mining cryptocurrencies
     
  • Provide a transaction certificate showing the identifying address, which consists of a set of letters and numbers, and the name of the company that operates the online exchange platform for virtual currencies or transacts funds for them. The attached documents must show the date and the amounts.

 

 

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