LGST Services dba Coinhub User Agreement, Privacy & Identity Verification Policy
By using this or any other Coinhub Bitcoin Kiosk & Teller Applications, you expressly consent and agree to the terms of this agreement.
You agree and understand that Bitcoin is not legal tender, carries no protection by the FDIC, and the use of bitcoin is subject to all applicable state and federal laws and regulations. LGST Services collects required data when necessary to be compliant.
You agree that all sales are final, and you understand that bitcoin transactions, by their very nature, are irreversible.
The Company shall not transmit monetary value to another person or to another location for any person. This prohibition does not apply to sending bitcoins to wallets hosted by third-party services, as long as the customer has exclusive access to that hosted wallet. All mistakes done by a client are not the responsibility of LGST Services dba Coinhub, for example, providing a wrong wallet to which bitcoin or other cryptocurrency was sent to.
You agree and consent to receive electronically all communications, agreements, documents, notices and disclosures (collectively, “Communications”) that we provide in connection with your use of Coinhub ATMs and transactions. Communications include:
- An access code text (SMS) message associated with every transaction attempted at this kiosk.
- Notifications about special pricing, or expansion of Coinhub.
You may request to receive via email:
- Account details, history, transaction receipts, confirmations, and any other Account or transaction information;
- Legal, regulatory, and tax disclosures or statements
- Responses to claims or customer support inquiries filed in connection with your Account.
We may provide these Communications to you by posting them to the CoinhubATM website, emailing them to you at the primary email address with which you have contacted us, and communicating to you via instant chat, and/or through other electronic communication such as text message (SMS) or mobile push notification.
LGST Services dba Coinhub may request certain identifying information in order to comply with applicable, laws, policies, and regulations. This information includes, but is not limited to
- your name;
- your photographic identification;
- your address;
- your phone number;
- your e-mail address;
- your date of birth; and social security number
We may share your personal information with:
- Service providers under contract who help with parts of our business operations such as fraud prevention, bill collection, marketing and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Financial institutions with which we partner.
- Law enforcement, government officials, or other third parties when: We are compelled to do so by a subpoena, court order or similar legal procedure; or We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
- Other third parties with your consent or direction to do so. Company will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described in this policy
By doing a transaction with any CoinhubATM or employee of the firm (LSGT SERVICES LLC – D/B/A COINHUB), you hereby agree to abide by our anti-money laundering policy, designed to meet strict standards, including the existence of systems and controls to mitigate the risk to any person who accesses or uses the service. This includes, but is not limited to:
- Establishing robust internal policies, procedures and controls that strive to combat any attempted use of BOA for illegal or illicit purposes and to offer our customers’ basic protections under consumer protection laws;
- Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
- Filing Suspicious Activity Reports (“SARs”);
- Filing Currency Transaction Reports (“CTRs”);
- Maintaining comprehensive records of orders and other transfers;
- Appointing a Chief Compliance Officer who will be responsible for the implementation and oversight of our BSA/AML Program;
- Executing Know Your Customer (“KYC”) procedures on all customers;
- Performing regular, independent audits of our BSA/AML Program; and
- Following record retention requirements;
Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner, and prevent fraud. In accordance with this, identities are verified, authenticated, and checked against government watch-lists, including the Office of Foreign Assets Control (“OFAC”). Below is the following information we collect for clients that transact a greater daily amount where such an identity check is required:
- Email address;
- Mobile phone number;
- Full legal name;
- Social Security Number (“SSN”) or any comparable identification issued by government;
- Date of birth (“DOB”);
- Proof of identity (e.g., driver’s license, passport or government-issued ID);
- Home address (not a mailing address or P.O. Box); and
- Additional information or documentation at the discretion of our Compliance Team.
- Non-US Customers will be required to provide proof of address (e.g., electric, gas or water bill).
If You are an institutional customer, We will collect, verify and authenticate the following information:
- Legal name;
- Employer Identification Number (“EIN”) or any comparable identification number issued by government;
- Full legal name (of all account signatories and beneficial owners);
- Email address (of all account signatories);
- Mobile phone number (of all account signatories);
- Address (principal place of business and/or other physical location);
- Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable);
- Contract information of owners/principals/executive management (as applicable);
- Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
- Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).
- If your institution successfully meets and completes our CIP requirements and neither it, nor any of its owners, principals, executive, or managers appear on OFAC or any other governmental watchlist, we will provide you with account opening agreements electronically.
We also file required reports (i.e. Suspicious Activity Reports) if we know, suspect, or have reason to suspect any malicious activities. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities, or personal means.
Our compliance department monitors transactions to help identify unusual patterns of customer activity. In addition, we have to report all currency transactions over a determined amount to the US government (i.e. FinCEN). Our compliance department maintains records and supporting documentation of all reports that we file.
We retain all records for five (5) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.