Legal

EMBILY FZ LLC TERMS OF USE

By using this website (“Site”), registering for a Embily Account (“Account”), or using any of our other Embily Services, you (“you, your, or yourself”) are agreeing to accept and comply with the terms and conditions of use stated below (“Terms of Use”). You should read the entire Terms of Use carefully before you use this Site or any of the Embily Services. As used in this Terms of Use, “Embily” refers to the company Embily FZ LLC with registered address at Units 2201 & 2202, Level 22, Boulevard Plaza, Tower 2, Downtown Dubai, including, without limitation, its owners, directors, investors, employees or other related parties. Depending upon the context, “Embily” may also refer to the services, products, website, content or other materials (collectively, “Embily Services”) provided by Embily. The Service operated by Embily allows sellers (“Sellers”), to convert their digital assets and make payments and transactions with converted currencies. The Service operated by Embily also allows all registered users of the Service (“Members”) to:

Use digital assets for purchasing goods.

Depending on your country of residence, you may not be able to use all the functions of the Site. It is your responsibility to follow those rules and laws in your country of residence and/or country from which you access this Site and Services. As long as you agree to and comply with these Terms of Use, Embily grants to you a personal, non-exclusive, non-transferable, non-sublicensable and limited right to enter and use the Site and the Service. IF YOU DO NOT ACCEPT THE TERMS OF USE AND CONDITIONS OUTLINED IN THIS AGREEMENT, DO NOT ACCESS THIS SITE AND DO NOT USE THIS SERVICE. By opening an Account, you expressly represent and warrant:

  • You have accepted these Terms; and
  • You are at least 18 years of age and have the full capacity to accept these Terms and enter into a transaction involving Digital Assets.

RISKS

The trading of goods and products, real or virtual, as well as virtual currencies involves significant risk. Prices can and do fluctuate on any given day. Due to such price fluctuations, you may increase or lose value in your assets at any given moment. Any assets – virtual or not – may be subject to large swings in value and may even become worthless. There is an inherent risk that losses will occur as a result of buying, selling or trading anything on a market. Digital asset trading also has special risks not generally shared with official currencies or goods or commodities or other assets in a market. Unlike most currencies, which are backed by governments or other legal entities, or by commodities such as gold or silver, cryptocurrency, a kind of digital asset, is a unique kind of “fiat” currency, backed by technology and trust. There is no central bank that can take corrective measure to protect the value of digital assets in a crisis or issue more cryptocurrency. Instead, digital cryptocurrency assets are as-yet autonomous and largely unregulated worldwide systems of currency firms and individuals. Traders put their trust in a digital, decentralised and partially anonymous system that relies on peer-to-peer networking and cryptography to maintain its integrity. Digital asset trading is probably susceptible to irrational (or rational) bubbles or loss of confidence, which could collapse demand relative to supply. For example, confidence might collapse in digital assets because of unexpected changes imposed by the software developers or others, a government crackdown, the creation of superior competing alternative currencies, or a deflationary or inflationary spiral. Confidence might also collapse because of technical problems: if the anonymity of the system is compromised, if money is lost or stolen, or if hackers or governments are able to prevent any transactions from settling. There may be additional risks that we have not foreseen or identified in our Terms of Use. You should carefully assess whether your financial situation and tolerance for risk are suitable for buying, selling or trading digital assets.

LIMITED RIGHT OF USE

Unless otherwise specified, all Materials on this Site are the property of Embily and are protected by copyright, trademark and other applicable laws. You may view, print and/or download a copy of the Materials from this Site on any single computer solely for your personal, informational, non-commercial use, provided you keep intact all copyright and other proprietary notices. The trademarks, service marks and logos of Embily and others used in this Site (“Trademarks”) are the property of Embily and their respective owners. The software, text, images, graphics, data, prices, trades, charts, graphs, video and audio used on this Site belong to Embily. The Trademarks and Material should not be copied, reproduced, modified, republished, uploaded, posted, transmitted, scraped, collected or distributed in any form or by any means, whether manual or automated. The use of any such Materials on any other Site or networked computer environment for any other purpose is strictly prohibited; any such unauthorised use may violate copyright, trademark and other applicable laws and could result in criminal or civil penalties.

MAINTAINING YOUR ACCOUNT: OUR RULES

By registering with us, you agree to provide Embily with current, accurate, and complete information about yourself as prompted by the registration process, and to keep such information updated. You further agree that you will not use any Account other than your own, or access the Account of any other Member at any time, or assist others in obtaining unauthorised access. The creation or use of Accounts without obtaining the prior express permission from Embily will result in the immediate suspension of all said Accounts, as well as all pending purchase/sale offers. Any attempt to do so or to assist others (Members or otherwise), or the distribution of instructions, software or tools for that purpose, will result in the Accounts of such Members being terminated. Termination is not the exclusive remedy for such a violation, and Embily may elect to take further action against you. You also are responsible for maintaining the confidentiality of your Account information, including your password, safeguarding your own Digital Assets, and for all activity including Transactions that are posted to your Account. If there is suspicious activity related to your Account, we may, but are not obligated, to request additional information from you, including authenticating documents and to freeze any transactions pending our review. You are obligated to comply with these security requests or accept termination of your Account. You are required to notify Embily immediately of any unauthorised use of your Account or password, or any other breach of security by email addressed to services@embily.com. Any Account who violates these rules may be terminated, and thereafter held liable for losses incurred by Embily or any user of the Site. Finally, you agree that you will not use the Service to perform criminal activity of any sort, including but not limited to, money laundering, illegal gambling operations, terrorist financing, or malicious hacking.

TERMINATION AND ESCROW OF UNVERIFIED ACCOUNTS

You may terminate this agreement with Embily, and close your Account at any time, following the settlement of any pending transactions. You also agree that Embily may, by giving notice, in its sole discretion terminate your access to the Site and to your Account, including without limitation, our right to: limit, suspend or terminate the service and Members’ Accounts, prohibit access to the Site and its content, services and tools, delay or remove hosted content, and take technical and legal steps to keep Members off the Site if we think that they are creating problems or possible legal liabilities, infringing the intellectual property rights of third parties, or acting inconsistently with the letter or spirit of these Terms. Additionally, we may, in appropriate circumstances and at our discretion, suspend or terminate Accounts of Members for any reason, including without limitation: (1) attempts to gain unauthorised access to the Site or another Member’s account or providing assistance to others’ attempting to do so, (2) overcoming software security features limiting use of or protecting any content, (3) usage of the Service to perform illegal activities such as money laundering, illegal gambling operations, financing terrorism, or other criminal activities, (4) violations of these Terms of Use, (5) failure to pay or fraudulent payment for Transactions, (6) unexpected operational difficulties, or (7) upon the request of law enforcement or other government agencies, if deemed to be legitimate and compelling by Embily, acting in its sole discretion. We expressly reserve the right to cancel and/or terminate Accounts that have not been verified by the Client despite our good faith efforts to contact you seeking such verification (“Unverified Accounts”). The suspension of an Account shall not affect the payment of the commissions due for past Transactions. Upon termination, Members shall communicate a valid bank account to allow for the transfer of any currencies credited to their account. Said bank account shall be held by the Member. Digital Assets may be transferred to a valid bank account only after conversion into a currency. Embily shall transfer the currencies as soon as possible following the Member’s request within the timeframes specified by Embily. Embily will send to you the credit balance of your Account, however, in circumstances, a number of intermediaries may be involved in an international payment and these or the beneficiary bank may deduct charges. We will use reasonable efforts to ensure that such charges are disclosed to you prior to sending your payment, however where they cannot be avoided, you acknowledge that these charges cannot always be calculated in advance and that you agree to be responsible for such charges. Upon Account closing, any amount less than $500 in value will not be returned.

AVAILABILITY OF SERVICES

All services are provided without warranty of any kind, either express or implied. We do not represent that this Site will be available 100% of the time to meet your needs. We will strive to provide you with the Service as soon as possible but there are no guarantees that access will not be interrupted, or that there will be no delays, failures, errors, omissions or loss of transmitted information. We will use reasonable endeavours to ensure that the Site can normally be accessed by you in accordance with these Terms of Use. We may suspend use of the Site for maintenance and will make reasonable efforts to give you notice. You acknowledge that this may not be possible in an emergency.

EXTERNAL WEBSITES

Embily makes no representations whatsoever about any outside or third party website which you may access through the Site. Occasionally, the Embily website may provide references or links to other websites (“External Websites”). We do not control these External Websites third party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External Websites referenced or linked from the Embily website, including, but not limited to, website content, policies, failures, promotions, products, opinions, advice, statements, prices, activities and advertisements, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. You shall bear all risks associated with the use of such content. External Websites have separate and independent terms of use and related policies. We request that you review the policies, rules, terms, and regulations of each site that you visit. It is up to you to take precautions to ensure that whatever device used is free of items such as viruses, worms, Trojan horses and other items of a destructive nature.

FINANCIAL ADVICE

For the avoidance of doubt, we do not provide any investment advice in connection with the Services contemplated by these Terms of Use. We may provide information on the price, range, volatility of Digital Assets and events that have affected the price of Digital Assets but this is not considered investment advice and should not be construed as such. Any decision to purchase or sell Digital Assets is your decision and we will not be liable for any loss suffered.

FINANCIAL REGULATION

Our business model and our Service consists of being an intermediary between digital asset holders and digital payment providers. The services we are currently providing are regulated under a service provider commercial licence issued by the Dubai Internet City Free Zone Authority of Dubai, U.A.E.

EMAIL

Email messages sent over the Internet are not secure and Embily is not responsible for any damages incurred by the result of sending email messages over the Internet. We suggest sending email in encrypted formats.

DISCLOSURES TO LEGAL AUTHORITIES AND AUTHORIZED FINANCIAL INSTITUTIONS

We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:

Required by law;

Compelled by subpoena, court order, or other legal procedure;

We believe that the disclosure is necessary to prevent physical harm or financial loss;

Disclosure is necessary to report suspected illegal activity; or

Disclosure is necessary to investigate violations of our Terms of Use or Privacy Policy.

Access to products and services detailed on this website may be restricted to certain persons or countries. In particular, the products and services referred to herein are not available to U.S. Persons, as defined by Regulation S of the United States Securities and Exchange Commission, as amended (“U.S. Persons”). The information contained on this website is not available to U.S. Persons. Individuals who are such “U.S. Persons” should not view this website. More generally, the products and services presented on this website may only be purchased in jurisdictions in which their marketing and distribution are authorised. Embily advises all interested parties to check in advance whether they are legally entitled to purchase the products and/or services presented on the website.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We store and process your Personal Information in data centres around the world, wherever Embily facilities or service providers are located. As such, we may transfer your Personal Information outside of the European Economic Area (“EEA”). Such transfers are undertaken in accordance with our legal and regulatory obligations.

JURISDICTION

The Terms of Use shall be governed and construed in accordance with U.A.E. Law. The parties agree to irrevocably submit to the exclusive jurisdiction of the U.A.E. Courts.

LIMITATION OF LIABILITY

To the extent permitted by law, Embily will not be held liable for any damages, loss of profit, loss of revenue, loss of business, loss of opportunity, loss of data, indirect or consequential loss unless the loss suffered arising from negligence or willful deceit or fraud. Nothing in these terms excludes or limits the liability of either party for fraud, death or personal injury caused by its negligence, breach of terms implied by operation of law, or any other liability which may not by law be limited or excluded. Subject to the foregoing, Embily’s aggregate liability in respect of claims based on events arising out of or in connection with any single Member’s use of the Site and/or Service, whether in contract or tort (including negligence) or otherwise, shall in no circumstances exceed the greater of either (a) the total amount held on Account for the Member making a claim less any amount of Commission that may be due and payable in respect of such Account; or (b) 125% of the amount of the Transaction(s) that are the subject of the claim less any amount of Commission that may be due and payable in respect of such Transaction(s).

INDEMNITY

To the full extent permitted by applicable law, you hereby agree to indemnify Embily, its employees and its partners against any action, liability, cost, claim, loss, damage, proceeding or expense suffered or incurred if direct or not directly arising from your use of Embily’s Sites, your use of the Service, or from your violation of these Terms of Use.

MISCELLANEOUS

If we are unable to perform the Services outlined in the Terms of Use due to factors beyond our control including but not limited to an event of Force Majeure, change of law or change in sanctions policy we will not have any liability to you with respect to the Services provided under this agreement and for a time period coincident with the event.

MODIFICATION OF TERMS

Embily reserves the right to change, add or remove portions of these Terms, at any time, in an exercise of its sole discretion. You will be notified of any changes in advance through your Account. Upon such notification, it is your responsibility to review the amended Terms. Your continued use of the Site following the posting of a notice of changes to the Terms signifies that you accept and agree to the changes and that all subsequent transactions by you will be subject to the amended Terms.

DEFINITIONS

Account. The contractual arrangement wherein an Embily Member has accepted our Terms of Use and Privacy Policy and received approval to use the Embily Services and to perform associated Transactions.

Digital Assets is anything that exists in a binary format and comes with the right to use. Data that do not possess that right are not considered assets.

User(s). Member(s) that are using Embily offered services. Commission. Refers to the fee which is payable to Embily on each Deposit, such as a Digital Assets deposit on the Users account.

Member(s). Refers to Embily service users as well as any holder of an Account.

Personal Information. Information that identifies an individual, such as name, address, e-mail address, account information, and banking details. “Personal Information” does not include anonymised and/or aggregated data that does not identify a specific user.

Price. The “price per coin” for which Members are willing to exchange Digital Assets, using the Service in a Digital Assets Exchange Transaction. The Price may be expressed in any of the currencies deposited by Members in their Account and supported by the Service.

Transaction. Includes the following:

The conversion of Digital Assets into currencies deposited by Members on their Account (“Conversion Transaction”);

The purchase of ancillary products (“Purchase Transactions”).

Transaction Price. The total price paid by the Buyer in respect of each Transaction performed through the Service.

CONTACT US

If you have any questions relating to these Terms of Use, your rights and obligations arising from these Terms and/or your use of the Site and the Services, your Account, or any other matter, please contact office@embily.com.)

Know Your Customer (KYC) & Anti-Money Laundering (AML) Policy

The Company protects itself from involvement in money laundering or suspicious activity by the following:

  • Performing an enterprise-wide risk assessment to determine the risk profile of the Company
  • Establishing AML policies and procedures
  • Implementing internal controls throughout its operations that are designed to mitigate risks of money laundering
  • Performing know your customer (“KYC”) procedures on all users
  • Designating a Compliance Officer with full responsibility for the AML Program
  • Conducting an annual AML audit
  • Providing AML training to all employees

 

POLICIES AND PROCEDURES

The Policy will be approved by the Company’s Board. The Policy once approved will be provided to all employees. Each employee will acknowledge the Policy in writing. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.

 

INTERNAL CONTROLS

The Company has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with all AML legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the Customer Identification Program, the Suspicious Activity Reporting system, and the required reports on the Program’s effectiveness to the Board.

 

TRAINING

All of the officers and employees of the Company are required to receive AML training at least annually. New employees will receive appropriate AML training within 30 days of their hire date. Training for all employees will include not only the legal elements of AML laws and regulations but will also cover job specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations.

 

CUSTOMER IDENTIFICATION

It is the Company’s policy to ensure that it has reasonably identified each customer who uses the Company’s platform. Users may be identified using a variety of methods.

ACCOUNT OPENING PROCEDURES.

Additionally, the Company will, as part of its account-opening process: (i) cross-check the names of users against compliance databases such as the OFAC Specially Designated Nationals list and other governmental watch lists; (ii) require users to provide proof of identification; and (iii) not permit any payment above 100 US dollar to be made with incomplete account-opening information.

 

PROOF OF IDENTIFICATION:

Individual

Name

Date and place of birth

Residence address and mailing address if different (PO Box alone will not be acceptable)

Official issued identification number (e.g., passport number, social security number, employee identification number or individual taxpayer identification number)

Copy of valid photo identification of the principal(s) involved with the account (e.g., driver’s license, passport, alien identification card)

 

VERIFICATION

Documents used in opening an account relationship must be verified prior to establishing the account. Verification of identity will require multi-factor authentication, layered security and other controls to ensure a meaningful user identity confirmation process based on account size or other factors.

The following are examples of verification methods the Company may use:

Obtaining proof of address, such as a copy of a utility bill or bank statement from the account holder.

Comparing the identifying information with information available from a trusted third party source, such as a credit report from a consumer-reporting agency, Veratad, Lexus Nexus Instant ID

Analyzing whether there is logical consistency between the identifying information provided, such as the customer’s name, street address, ZIP code, telephone number, date of birth, and social security number (logical verification).

Utilizing knowledge-based challenge questions.

Utilizing complex device identification (such as “digital fingerprints” or geo-location checks).

Obtaining a notarized copy of an individual’s birth certificate for valid identification.

When the type of account increases the risk that the Company will not be able to verify the true identity of the customer through documents is confirmed the account will be closed.

 

SUSPICIOUS TRANSACTION AND ACTIVITY REPORTS

The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Internal controls will be implemented so that an ongoing monitoring system is in place to detect such activity as it occurs. When such suspicious activity is detected, the Company will determine whether a filing with any law enforcement authority is necessary.

Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction.

The Company will initially make the decision of whether a transaction is potentially suspicious. Once the Company has finished the review of the transaction details, he or she will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.

The Company will maintain a copy of the filing as well as all backup documentation. The fact that a filing has been made is confidential. No one, other than those involved in the investigation and reporting should be told of its existence. In no event should the parties involved in the suspicious activity be told of the filing. The Company may inform the Company’s Board of the filing and the underlying transaction.

 

REPORTING REQUIREMENTS

Reasonable procedures for maintaining records of the information used to verify a person’s name; address and other identifying information are required under this Policy. The following are required steps in the record keeping process:

The Company is required to maintain a record of identifying information provided by the customer.

Where the Company relies upon a document to verify identity, the Company must maintain a copy of the document that the Company relied on that clearly evidences the type of document and any identifying information it may contain.

The Company must also record the methods and result of any additional measures undertaken to verify the identity of the customer.

The Company must record the resolution of any discrepancy in the identifying information obtained.

All transaction and identification records will be maintained for a minimum period of five years.

 

AML AUDIT

The Company is responsible for directing the annual AML audit of the Company’s operations. The independent audit will be conducted by an independent third party with working knowledge of BSA requirements, or by Company personnel with working knowledge of BSA requirements. The Company will develop corrective action plans for all issues that are raised in the audit and will provide the audit report and all corrective action plans to the Company’s senior management for review. Reports of the corrective action will continue until all are resolved.

EMBILY FZ LLC PRIVACY POLICY

GENERAL

This Privacy Policy, together with our Terms of Use, governs Embily’s collection, processing and use of your Personal Information. As used in this Privacy Policy, “Embily” refers to the company Embily FZ LLC, including, without limitation, its owners, directors, investors, employees or other related parties. Depending upon the context, “Embily” may also refer to the services, products, website, content or other materials (collectively, “Embily Services”) provided by Embily.”Personal Information” refers to information that identifies an individual, such as name, address, e-mail address, trading information, and banking details. “Personal Information” does not include anonymised and/or aggregated data that does not identify a specific user.

Embily and its affiliates (hereinafter, “Embily”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

The types of Personal Information we collect and how it may be used;

Our use of cookies and similar technology;

How and why we may disclose your Personal Information to third parties;

The transfer of your Personal Information within and outside of the European Economic Area (“EEA”);

Your right to access, correct, update, and delete your Personal Information;

The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Information; and

Embily’s retention of your Personal Information.

 

COLLECTION AND USE OF PERSONAL INFORMATION
PERSONAL INFORMATION WE COLLECT
We collect the Personal Information you provide directly to us when you open a Embily Account, perform any transactions on the Embily Platform, or use other Embily Services. This may include:

Contact information, such as name, home address, and email address.

Account information, such as username and password.

Financial information, such as bank account numbers, bank statement, and transaction information.

Identity verification information, such as images of your government issued ID, passport, national ID card, or driving license.

Residence verification information, such as Utility bill details or similar information.

We also automatically collect certain computer, device, and browsing information when you access the Embily website or use Embily Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

Computer or mobile device information, including IP address, operating system, browser type.

Website usage information.
 
USE OF COOKIES AND SIMILAR TECHNOLOGY
The Embily site is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general interaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.
 
HOW WE USE YOUR PERSONAL INFORMATION
We may use your Personal Information to:

Process your Embily transactions. We will process your Personal Information only for the purpose(s) for which it has been provided to us.

Verify your identity in accordance with the Money Laundering Regulations 2007 and the Embily Anti Money Laundering policy, as well as address other law enforcement needs as more fully described in our Terms of Use.

Personalise your Embily Services experience.

Analyse Embily website usage, and improve our website and website offerings.

Help us respond to your customer service requests and support needs.

Contact you about Embily Services. The email address you provide may be used to communicate information and updates related to your use of the Embily Services. We may also occasionally communicate company news, updates, promotions, and related information relating to similar products and services provided by Embily.

Administer a contest, promotion, survey or other site features as will be more explained on the website.

We do not perform behavioral tracking of a customer’s activities on our Website or across different Websites, nor do we allow third-party data collection through our Service.

If you wish to stop receiving marketing communications from us, please contact us at office@embily.com to opt-out.
 

DISCLOSING AND TRANSFERRING PERSONAL INFORMATION

We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information outside the EEA, as described below.
DISCLOSURES TO THIRD PARTIES
In processing your transactions, we may share some of your Personal Information with third party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Embily Services or as required by law. By using our Services and accepting our Terms of Use, you consent to the disclosure of your Personal Information as described in this Privacy Policy. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. Embily’s third party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective those described in this Privacy Policy, or those we are subject to under applicable data protection laws.
 
DISCLOSURES TO LEGAL AUTHORITIES
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:

Compelled by subpoena, court order, or other legal procedure.

We believe that the disclosure is necessary to prevent physical harm or financial loss.

Disclosure is necessary to report suspected illegal activity.

Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use.
 
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We store and process your Personal Information in data centres around the world, wherever Embily facilities or service providers are located. As such, we may transfer your Personal Information outside of the EEA. Such transfers are undertaken in accordance with our legal and regulatory obligations.
 

EXTERNAL WEBSITES

Occasionally, the Embily website may provide references or links to other websites (“External Websites”). We do not control these External Websites third party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External Websites referenced or linked from the Embily website, including, but not limited to, website content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. External Websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our site and welcome any feedback about External Website information provided on the Embily website.
 

ACCESS RIGHTS TO PERSONAL INFORMATION

You have the right to access your Personal Information to correct, update, and block inaccurate and/or incorrect data. To exercise this right, contact us at office@embily.com. Embily will respond to your request only where this is not inconsistent with our Terms of Use and other legal and regulatory obligations.
 

SECURITY OF PERSONAL INFORMATION

We use a variety of security measures to ensure the confidentiality of your Personal Information, and to protect your Personal Information from loss, theft, unauthorised access, misuse, alteration or destruction. These security measures include, but are not limited to:

Password protected directories and databases.

Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.

PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised Embily personnel are permitted access to your Personal Information, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.
 

RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain Account and other Personal Information for at least five years after an Account is closed.
 

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of Embily. When we make changes to this Privacy Policy, we will notify all users on our website, and make the amended Privacy Policy available on our website.
 

DEFINITIONS

Account. The contractual arrangement wherein a Embily Member has accepted our Terms of Use and Privacy Policy, and received approval to use the Embily Services, including the exchange and conversion of Digital Assets and to perform associated Transactions.

Embily Platform. Hardware and software technologies used by Embily to provide the Service as set out in our Terms of Use.

Personal Information. Information that identifies an individual, such as name, address, e-mail address, trading information, and banking details. “Personal Information” does not include anonymised and/or aggregated data that does not identify a specific user.

Service(s). The technological platform, functional rules and market managed by Embily FZ LLC to permit Members to perform conversion transactions of Digital Assets.

Transaction. Includes the following:

The conversion of Digital Assets into currencies deposited by Members on their account (“Conversion Transaction”);

The purchase of ancillary products (“Purchase Transactions”).
 

CONTACT US

Please contact us with questions, comments, or concerns regarding our Privacy Policy and/or practices at office@embily.com

EMBILY FZ LLC REGISTRAR RECORD

We are very proud to be part of the flourishing U.A.E. economy. Embily FZ LLC is a Dubai Free Zone registered limited liability company.

You can find us in Dubai Internet City company registrar – http://www.dic.ae/business-partners-search-list/?cs=Embily