X4T Terms and Conditions

Last Updated: 24 November, 2022

Terms and conditions of use agreement

This agreement describes the general terms and conditions (“Terms and Conditions”) applicable to the use of the services offered by X4T (“the Services”) within the site www.x4t.com (the “Site”). Any person (collectively “User”, “Member” or “Customer” “You”, “Your”) who wishes to access and/or use the Site or the Services may do so subject to these Terms and Conditions, together with all other policies and principles governing X4T (collectively “…….”, “We”, “Us”, “Our”) which are incorporated herein by reference.

1. Identifying Data

X4T S.A., with R.U.C. No. 80117664-6, is an entity established in accordance with the laws of the Republic of Paraguay, with its registered office at Calle Coronel Tito Bogado 2650, City of Asunción. The commercial office is located in the “The Top Business Center” building, situated at Avda. Aviadores del Chaco corner César López Moreira, with the email address support@x4t.com.

2. Purpose and Scope of Application

a) The Terms and Conditions that constitute the rules that regulate the access, navigation and use of the Site as well as the responsibilities derived from the use of its contents (understood hereinafter as “Content”, but not limited to: data, information, documents, texts, graphics, drawings, designs, codes, software, photographs, music, videos, sounds, databases, images, expressions and information, as well as any other creation protected by national laws and international treaties on intellectual and industrial property).

b) In this sense, User, Member or Client shall be understood indistinctly as the person who accesses, navigates, uses the Services or participates in activities made available or organized by X4T SA on the Site, whether for consideration or free of charge.

General Provisions

a) The Services are only available to persons who have legal capacity to contract. The Services may not be used by persons who do not have such capacity, minors or Users who have been temporarily suspended or permanently disqualified by court order. If you are registering a User as a Company, you must have the capacity to contract on behalf of and bind such entity under the terms of this Agreement.

b) The access or the mere use of the Site by the User implies the User’s adherence to the Terms and Conditions and Annexes that X4T SA has published at each moment in which he/she accesses the Site, as well as the commitment to comply, at all times, with the laws in force. Consequently, the User declares to have read and understood carefully the Terms and Conditions and declares his adherence to them. Any person who does not accept these general terms and conditions, which are mandatory and binding, must refrain from using the Site and/or the services and/or from participating in any activity organized by X4T SA within the scope of application of the terms and conditions.

c) It shall be understood that by accepting the Terms and Conditions the User declares that he/she has all the legal capacities to contract with X4T SA, that he/she is not a competitor of Ours, that he/she does not carry out activities that may be considered competitive to the Services, and that he/she does not access or use the Site for purposes of commercial competition.

d) Likewise, the User declares and accepts that he/she will not violate any of the rights of X4T SA including, but not limited to, industrial and intellectual property rights and that all means, systems, equipment and software used to access and use the Site will be of his/her exclusive ownership and that the operational capabilities and maintenance of the same will be at his/her exclusive account and risk.

e) Likewise, the User agrees that and undertakes to:

I. The content, material and services of the Site are protected by industrial and intellectual property rights and are the exclusive property of X4T SA.
II. Not to use the Site to carry out commercial activities, of any nature whatsoever.
III. The obligations assumed by X4T SA with Customers are obligations of means and not of results.
IV. Do not access the Site using automated means such as, but not limited to: harvesting bots, bots, spiders, spiders or scrapers.
V. Not to use the Site for marketing and/or multi-level marketing purposes such as but not limited to pyramid schemes, as well as other similar marketing concepts.
vi. Not to install, use or disseminate on the Site viruses or other software or code with malicious content.
VII. Not to access the site using the account and/or profile of other Users.
viii. Not to use the Site to carry out intimidating, harassing or bullying activities against other Users or third parties.
IX. Not to publish on the Site material that incites hatred, racism or violence or use pornographic material or obscene and inappropriate content for the purposes of X4T SA.
X. Not to use the site in such a way that this use may involve the violation of any of the laws, decrees, resolutions, regulations or any other regulatory provision, in particular the provisions issued by the National Securities Commission (CNV) and the Central Bank of Paraguay (BCP).
XI. Not to carry out actions that compromise the operational security of the Site.
XIII. Not to make any use or statements that disparage, defame or make false allegations or statements regarding X4T SA and/or any of its products or services.
XIII. Not to share the use and access to your private account with other Users or third parties and, in this way, make them accessible to the public.
XIV. Not to use on the Site industrial and intellectual property rights of third parties without authorization.
xv. Not to use the Site for the purpose of sending unauthorized commercial and advertising material.
XVI. Not to engage in abusive practices that distort or conceal the true purpose of the User’s communications or are intended to increase traffic to other websites.
XVII. Not to carry out practices that incite the violation of the Terms and Conditions.
XVIII. Not to carry out acts of reverse engineering.
XIX. Not to carry out acts that may generate damages, costs or other types of expenses to X4T SA.
XX. Not to share personal information or disclose personal information of third parties.

Ownership of the License

a) The User accepts that the Terms and Conditions and its Annexes are subject to changes which may be made at any time and unilaterally, without prior notice and without justification of cause.

b) Being a User of X4T SA entails the limited and revocable use of the license to use the Site and the Services included therein and in accordance with the Terms and Conditions. The revocation of the license is automatically applied in case of violation of the Terms and Conditions or any other legal or internal provision of X4T SA. In case of revocation, the User must destroy all material provided and related to the site.

c) After revocation, the User’s personal information will remain at the disposal of X4T SA in accordance with the privacy policies. All information provided to X4T SA is at the User’s risk; its loss does not entail any liability for X4T SA.

d) All content and material related to the Site is the exclusive property of X4T SA. The User acknowledges this exclusive ownership of X4T SA. Also, the Customer acknowledges that all content, material and documentation owned by X4T SA are protected by industrial and intellectual property rights and that their violation and / or misuse entails the application of the provisions provided by law in this area.

e) The User accepts and acknowledges that the data, material, documents and information contained on the Site are the exclusive property of X4T SA and undertakes not to use them illegally and/or without authorization. X4T SA reserves the right to implement all security mechanisms in order to prevent the unlawful use and distribution of its proprietary content.

f) All information provided by the User to X4T SA as well as the content thereof is the exclusive property of X4T SA. The “Content” includes, but is not limited to: text, data, graphics, images, photographs, video, audio, information, suggestions, guidance and other materials provided, made available or otherwise found through the Site, including, but not limited to, Content provided in direct response to your questions and postings.

g) The User assigns to X4T SA free of charge and in perpetuity its image, audio and video rights, provided that they have been obtained legally and with the consent of the User.

h) X4T SA reserves the right to proactively investigate any type of violation of the Terms and Conditions and, when necessary, to seek redress for damages by any means necessary, including reporting the violation to the Official Authorities.

i) X4T SA declares that it does not control or monitor the electronic devices of Customers and Users, however, and provided that the Law allows it and by authorized means, it could carry out monitoring activities in the event that it is necessary to prevent the violation of the Terms and Conditions.

j) The User agrees and consents that X4T SA may, at its sole and exclusive discretion, delete any information, documentation and content proven by the User, as well as terminate the account at any time as a consequence of the violation of the Terms and Conditions or for any type of activity that X4T SA considers worthy of objection and/or that may put the Site at risk. k) X4T S.A. is duly registered and holds an official license as a Virtual Asset Service Provider (VASP), thus ensuring compliance with current regulations in the field of cryptocurrencies and digital assets. For more information about our license, you can consult it directly through the following link: www.seprelad.gov.py/siro/soprovisorio/impresionsolicitudso.xhtml?id=32310367621607740620060463756669

5. Method of Purchase and Returns

a) X4T SA offers and sells products and services ONLY AND EXCLUSIVELY RELATED TO EDUCATIONAL AND INFORMATIVE ACTIVITIES IN THE FINANCIAL AND STOCK MARKET SECTOR; the sale is made in accordance with the nature of the product, in the form of direct sale and on a one-time basis. The User has the option to pay in cash directly at the store located in “The Top Business Center” building located at Avda. Aviadores del Chaco esq. César López Moreira, 16th floor. Alternatively, payments by credit card and/or debit card are accepted through the POS system. In the future, X4T.S.A. will provide an option to complete transactions via bank transfer, providing specific bank account details for this purpose.

b) The User accepts and consents that all information related to the payment is stored by X4T SA.

c) In the future, the platform will have a credit/debit card payment service. For this purpose, the fees for the products and services provided by the Users will be debited from the credit card or indicated at the time of contracting the service. In the event that the credit or debit card associated with the User’s account has expired or the payment has been rejected, X4T SA will proceed to the automatic cancellation of the account. It is the sole responsibility of the User to keep updated the credit card data associated with your account as well as contact details where X4T SA can carry out their communications and notifications.

d) Payments made by Users to X4T SA for the purchase of any of its products or services and for the renewal thereof, will not be subject to refund. Likewise, X4T SA does not offer and is not obliged to provide refunds or credits of any kind and for any reason, including but not limited to, for reasons of cancellation of Users’ accounts, except in those cases where the refund was mandatory for the reasons set forth in Article 17 of Law 4868/13 “On Electronic Commerce” and other applicable legal provisions on the subject.

e) All fees paid to X4T SA for the purchase of products or services or for the subscription to the same, are free of charges and taxes which must be paid by the User.

6. Changes to the Web Site and Prices.

a) The User acknowledges and accepts the right of X4T SA to unilaterally modify the content of the Site, as well as the costs and fees associated with the products and services offered. Modifications may be made at any time and without prior notice. X4T SA also reserves the right to modify or discontinue temporarily or permanently the Site (or any part of it) without notice.

b) Without prejudice to the foregoing, X4T SA reserves the right to communicate and warn of changes that may occur on the Site; These communications may be carried out by all means that are most appropriate taking into account the nature of the modifications.

7. Cancellations

a) X4T SA may reject any registration request or cancel a previously authorized registration, without such decision having to be justified, and without this generating any right on behalf of the User.

b) In the event that the User wishes to cancel his/her account, he/she will be solely responsible for the correct cancellation of the same and following the procedure and means through which it was carried out.

c) X4T SA will keep the data and information related to the Users once they have cancelled their accounts, memberships or subscriptions.

8. Exclusion of Liability

a) X4T SA shall not be liable for the incorrect interpretation and/or understanding of the contents of the Site, for the interpretation and/or understanding of the consultations, nor for its improper use, nor for actual or contingent, direct or indirect, consequential or alleged damages, loss of profits or any other damages related to the Information displayed on the Site or in its links or connections, nor related to the actions and/or decisions that the User takes or has taken, omits or has omitted to take, when consulting the Site and/or its links or connections.

b) X4T assumes no responsibility in situations where the platform presents interruptions, technical failures or any other type of inconvenience during the process of buying or selling cryptocurrencies. It is essential that our users are informed of the technological risks associated with online cryptocurrency transactions and take appropriate precautionary measures.

9. User Responsibility

a) X4T SA is not a company engaged in providing financial and investment advice and is not subject to or controlled by the National Securities Commission or the Central Bank. Therefore, the information contained in the Site and the Services of X4T SA does not constitute an offer, invitation or solicitation for you to purchase or subscribe securities or other financial or investment instruments, or to decide or modify investments. In no way does this Site, the information contained herein or the X4T SA Services constitute the basis for any contract, commitment or decision of any kind. The instruments or investments recorded on the Site or social networks are for educational, training and informational purposes only and may not be appropriate for you, given your specific investment objectives, financial position or risk profile, as these have not been taken into account for the preparation of the Site. Under no circumstances can X4T SA be held responsible for the outcome of the investments you decide to make. If the User is interested in making investments, he/she should bear in mind and pay special attention that all securities or instruments are regulated not only legally but also by specific documents approved by competent authorities, which will not include complete and accurate information about the respective security or instrument, and that the User should analyze together with his/her professional advisors (lawyers, accountants, financial advisors, tax advisors, etc.) prior to making an investment. Under no circumstances can X4T SA be held responsible for the outcome of the investments you decide to make.

b) The content and information provided by X4T SA and the Site or social networks as well as the products and Services provided are intended to be informative data.

c) The information, content and data provided by X4T SA are not intended for, nor are they directed at, nor may they be considered as, recommendations to carry out operations for the purchase and sale of crypto-assets, financial instruments or any other operation of a stock market or financial nature or any other type of investment, whatever its nature; nor does it constitute advice on financial, tax, legal or accounting matters.

10. X4T SA’s educational, research and information purposes.

a) The data, content, materials and information contained in the Site may not be considered as financial, investment or stock market advice or in any way constitute an offer, invitation or recommendation by X4T SA for the purchase or sale of securities and/or financial instruments.

b) The use by the User of the information and/or data contained in the Site and/or of the lessons learned through the subscription and/or purchase of products and Services provided by X4T SA to support the decision making at the time of making investments and/or transactions, of whatever type, does not guarantee the obtaining of any type of results and/or returns. The User accepts and acknowledges that all investments and transactions made by him/her shall be made at his/her own risk and sole responsibility.

c) X4T SA does not and does not provide you with any legal, tax, estate planning or accounting advice, or any advice with respect to the suitability, profitability or timeliness to you of any security, investment, financial product, investment strategy or other matter. The data, content and information contained in the Site should not be construed as investment or trading advice, nor is it intended as an invitation or recommendation to buy, sell or hold positions in securities or to engage in any other transaction. Such data, content and information provided by X4T SA or contained on the Site are secondary to our business and our activities which are focused on the provision of educational and training services.

11. Data Content and Information

a) X4T SA does not guarantee the veracity or validity of the information, data, comments, recommendations, news, or other materials to which the User can access through the Site; In addition, X4T SA does not guarantee that it has not been altered, after its insertion on the Site. If, in spite of the above, the User decides to rely on them to make decisions, he/she accepts and acknowledges that he/she does so exclusively at his/her own risk.

b) The social networks enabled on the Site are made up of other Users and moderators, whether or not they are employees of X4T SA, and are solely for the purpose of sharing information and content of an informative, educational or academic research nature. The information and content shared by Users reflect, exclusively, their individual interests and preferences and do not constitute, in any way, an offer, invitation or advice by X4T SA for the User to purchase or subscribe securities or other instruments, or to decide or modify their investments. Therefore, X4T SA is not responsible for the accuracy, reliability or completeness of the information.

c) X4T SA neither approves nor controls the content shared in the forums and virtual chats that may be enabled on the Site. The User accepts and acknowledges that, if he/she participates in them, he/she does so at his/her own risk and exempts X4T SA from any liability related to his/her participation in them.

d) Any participation and/or comments made by the moderators in the forums and virtual chats that may be enabled in the Site, shall be considered their personal opinions and do not represent, in any case, an invitation or advice by X4T SA for the User to purchase securities or other instruments, or to decide or modify their investments.

e) All products and services provided by X4T SA, as well as the data, content, materials and information included in the Site are for educational, training, informational and academic research purposes only.

12. Personal activities of X4T SA

a) The shareholders, officers and employees of X4T SA are persons who normally carry out stock exchange and investment activities; however, these activities are carried out individually and independently and following their own criteria and investment plans and based on their individual experience, not being obliged to follow the strategies and teachings imparted by X4T SA.

b) The User acknowledges and accepts that the shareholders, officers and employees of X4T SA are persons who normally carry out stock exchange and investment activities but who carry them out under the conditions and in accordance with the specifications mentioned in the previous paragraph. Therefore, the User hereby voluntarily waives any and all claims for damages, losses and liabilities, as well as any other costs or expenses arising from, or related to, securities trading activities that have been carried out by reference to the activities carried out by the shareholders, officers and employees of X4T SA.

13. Investments and Results

a) Crypto-asset trading activities involve high levels of risk, therefore, they are activities that must be carried out by professionals in the sector who have a thorough knowledge of the risks involved and who are willing to assume considerable or even total losses.

b) The data, content, materials and information on the Site do not constitute any kind of guarantee or indication of positive results in the activities of purchase and sale of cryptoassets that may have been carried out by the Users.

c) The shareholders, officers and employees of X4T SA, do not guarantee, in any way, the validity, suitability, timeliness, accuracy or reliability of the data, content, materials and information coming from the Site and that have been eventually used by the user for the decision at the time of making their particular investments.

14. Testimonial Disclaimer

a) The support, adhesion, testimonials and description of other Users regarding their past experiences with X4T SA and the Site are individual and non-transferable testimonials and the results and performance are the result of individual and unrepeatable experiences of some Users and are not representative of the results and performance obtained by all Users; therefore, the User should not have expectations of achieving identical or similar results or performance.

15. Third party websites

a) Certain content, products and services available on Our Site may include material from third parties.

b) Third party links on the Site may redirect to third party websites that are not affiliated with Us. We are not responsible for examining or evaluating the content or accuracy and do not warrant and shall not have any liability or responsibility for any third party materials or websites, or for any materials, products or services of third parties.

c) X4T SA shall not be liable for any damages or injury related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with third party websites. Please carefully review the policies and third party policies and make sure you understand them before engaging in any transactional practices. Complaints, claims, concerns or questions regarding third party products should be directed to the third party.

16. Indemnification

a) The User agrees to indemnify, defend and hold harmless X4T SA and its subsidiaries, affiliates, partners, employees, directors, agents, contractors, licensors, service providers, subcontractors, suppliers, interns and employees, harmless from any claim or demand, including reasonable attorneys’ fees, made by any third-party due to or arising out of a breach by the User of these Terms and Conditions or the violation of any law or the rights of a third-party.

17. Privacy and private information

a) Protecting your privacy and keeping your information secure are among Our top priorities. This section will help you understand what information we request and why.

b) To become a User of X4T SA, You will be required to provide certain basic and personal information. Our Privacy Policy details how we use, share and maintain the information you voluntarily share with X4T SA, which may include, but is not limited to, your name, identity card number, address, contact, employment, billing and other information (collectively, “Personal Information”).

c) By submitting such information, the User authorizes X4T SA, its officers, shareholders, its employees, its agents and others working on its behalf to use and/or disclose such information in accordance with our Privacy Policy. Please review the Privacy Policy carefully, as your use of the X4T SA platform constitutes your agreement.

d) In situations where X4T SA has reason to suspect that the information provided by the user is not authentic or accurate, we reserve the right to request additional documents in order to confirm and ensure the identity of the user.

e) If X4T SA identifies suspicious or unverifiable characteristics in an account, we reserve the right to terminate the account to protect the integrity of our platform and the safety of our user community.

d) In situations where X4T SA has reason to suspect that the information provided by the user is not authentic or accurate, we reserve the right to request additional documents in order to confirm and ensure the identity of the user.

e) If X4T SA identifies suspicious or unverifiable characteristics in an account, we reserve the right to terminate the account to protect the integrity of our platform and the safety of our user community.

18. Modifications to the Terms and Conditions

a) The User may review the most current version of the Terms and Conditions at any time by accessing this page.

b) X4T SA reserves the right, at its sole discretion, to update, modify or replace any part of these Terms and Conditions by posting updates and changes on Our Site as well as by any other means We deem appropriate. It is the User’s responsibility to check Our Site periodically for changes. Your continued use of or access to the Site following the posting of any changes to the Terms and Conditions constitutes automatic acceptance of those changes.

19. Applicable Legislation

a) We expect to be able to resolve any disagreements you may have with X4T SA. However, if there is a dispute that needs to be resolved, that process will be carried out in accordance with this article. These Terms and Conditions shall be deemed entered into and shall be construed and enforced in accordance with the laws of the Republic of Paraguay.

b) You agree that all disputes between you and us (whether or not such dispute involves a third party) in connection with your relationship with us, including, without limitation, disputes relating to these terms and conditions, your use of the services and/or rights of privacy and/or publicity, shall be resolved in the courts of the Capital City, Asuncion.

20. Divisibility

a) In the event that a judge or arbitrator determines that any of the clauses of the Terms and Conditions is illegal, unenforceable or void, the same shall be modified for the purpose of making it legal and enforceable in the broadest possible manner; in the event a judge or arbitrator determines that the clause as modified continues to be illegal, unenforceable or void this decision shall not affect the other clauses of the Terms and Conditions.

21. Acceptance of Terms and Conditions

a) The User agrees that these Terms and Conditions constitute a sufficiently comprehensive and complete agreement between him/her and X4T SA with respect to the Site and its contents; the same supersedes any and all existing agreements, in whatever form, oral or written, between X4T SA and the User and relating to the subject matter of the Terms and Conditions.

b) IF YOU DO NOT ACCEPT THESE TERMS AND CONDITIONS OR ANY OF THEIR CLAUSES, PLEASE EXIT THIS WEBSITE IMMEDIATELY. IN THE EVENT THAT, DESPITE NOT AGREEING, YOU CONTINUE TO BROWSE THE SITE, THIS IMPLIES AUTOMATIC ACCEPTANCE OF THE TERMS AND CONDITIONS.

APPENDIX1

AML and KYC

AML and KYC Policy

Due to legal requirements and in consideration of the security of users, the United States, the European Union and various countries, X4T S.A. has implemented and started to use the Know Your Customer/KYC (Know Your Customer), Anti Money Laundering/ CFT (prevention of money laundering, fight against terrorism financing) Policy as other financial institutions and Banks require.

These policies are intended to combat the financing of terrorism and money laundering (AML/CTF) on the exchanges by monitoring interactions and identifying actual users. It will identify and suspend any transactions made that not only wish to sell or buy a cryptocurrency, but also any that wish to hide the origin of money that is criminal, illegal behavior and finance illegal activities. X4T reserves the right to request supporting documentation regarding the source of income or funds at any time, regardless of the transaction amount. This measure is implemented to ensure compliance with applicable regulations, maintain the integrity of our platform, and uphold industry standards.

Pursuant to Law 6534/20, I authorize X4T S.A. and Infomercio to collect and share public and private information about me. This includes my telephone numbers, family ties, and journalistic, civil, criminal, commercial and financial background. This authorization is granted in order to facilitate the verification of my data using various national and international sources of information. In this way, I seek to ensure the correct validation of my request, granting my consent for such information to be consulted and shared with interested third parties, always respecting the terms of Law 6534/20.

These policies are confidential and these specific provisions are for internal use only, in order to prevent fraudulent and dishonest users. The following are some general stipulations and rules of our policies that directly affect you and the services provided.

User identification.

First of all, we must identify ourselves, we are obliged to have the identity of the persons who will be enabled to make transactions in this Platform. For this reason we request the scanning of the ID (C.I.), and the authenticity of this will be done with special software from external suppliers.

It is requested to send a “Selfie” and a photograph of the identity document in order to avoid the use of documents of third parties. For the verification of the similarity of the identification with the photo will be done with the use of special software from external suppliers, and in case of doubt, it will be checked manually by the customer service staff.

In case of reasonable doubt, the customer service team will contact you to explain the concern and resolve the problem, if it cannot be determined that the documents belong to you and are authentic, no transaction will be allowed.

User identification – companies

Transaction tracking and monitoring.

All transactions will be analyzed for unusual and suspicious behavior using our software. These selected transactions will be evaluated and analyzed by our specialists to determine if they do not represent significant risks and should be stopped and cleared (AML/CFT).

Additional verification

AML/CTF verification obligations increase as trade volume increases, the same will happen when transactions are “flagged” as unusual or suspicious. Or you are rated as a significant AML/CTF risk person by our personal results verification system.

Cooperation with you should be terminated and your transactions should be reported to the relevant authorities if our AML specialists do not clarify your doubts.

Basic Rules

The operating rules include, among others, the following:

1- It is not possible to manage a third party’s account (someone else’s) or shared or joint accounts, third party deposits in another user’s account are not accepted.

2- All required documentation must be provided, no exceptions are allowed in any field of documentation required for users.

3- In case of suspicion of AML/ CTF, X4T S.A. may refuse to process the user’s transaction at any time.

4- In compliance with international law, X4T S.A. is not obliged (or prohibited) to inform users if their behavior is reported as suspicious to the relevant authorities.

Sanctioned Countries

Accounts may not be opened and transactions may not be processed for citizens and residents of countries where transactions are prohibited by international sanctions. Or some countries that were selected by our AML team that impose a high AML/CFT risk (countries with weak anti-money laundering and terrorist financing regimes).

Verification Levels

As the level of trading increases, so does the AML/CTF risk. As a result, appropriate security and verification procedures are introduced, based on the more capital you deposit or withdraw, the more information you must enter about yourself. This may change as they change considering new knowledge and experience and the legal requirements of each Country. As for particular transactions, they may also change due to audits and efficiency checks, but you will be kept informed if changes are implemented that impact your situation.

Privacy Policy

We make sure every day that the use of our exchange is safe and comfortable for you. For this reason, you are provided with this information on how your registration data and the use of the exchange are processed.

Considering your security and privacy as a key point, we explain the Privacy Policy, what data is collected, the rights you have, and that you can be safe with us.

Your data is collected mainly at registration of your user account and while using our website. To familiarize yourself with the rules of our exchange we have created this Privacy Policy.

General Privacy Policy Information

1- The main purpose of this Privacy Policy is to explain why all the information we request from you is necessary. We specify what data is collected, what rights you have and where it comes from.

2- This Privacy Policy is based on:

A- From the European Parliament and the Council Regulation (EU) 2016/679, national and international laws on the protection of natural persons for the use of personal data and to the free movement of data.

1- We ensure that all our employees are trained for the processing of personal data to ensure the security of your personal data, it is guaranteed that our company has the technical security measures to adequately secure your data.

2- Your personal data is processed in accordance with the law, only for legally permissible and specified purposes.

3- The security and confidentiality of your personal data collected is maintained, we put our best effort to secure the data collected. This data is processed, stored and can be transferred to any country.

Who is the administrator and the data protection officer of your personal data?

1- Who manages your personal data is X4T S.A., this company is located in Asuncion, capital of the Republic of Paraguay.

2- Regarding the processing of your personal data, if you have any request, complaint or question you can contact: 0992443344. Also, you can contact the Administrator by sending a mail to the address already specified or by e-mail to support@x4t.com.

3- These complaints, requests or questions should include: full details of the person or persons concerned, the reason for the message, the basis for the request and what is expected or how the matter is to be handled.

How and why do we collect your data?

1- It should be noted that we process the data you provide us when you perform the configuration and verification on our website (the data you enter in the forms) and the data you give on our website when you use the services offered (when you buy/sell).

2- It is necessary to collect this information in order to provide our services and to comply with the requested legal provisions on identification to combat and assess fraud risks. If these data are not provided or if the data provided are false, we will not be able to continue with the service.

3- To confirm the above data, your transaction history is also monitored.

All information provided is completely confidential and is only used for the purpose reported above.

The following data is requested for the website:

Name: A full name must be provided to identify yourself.

Date of birth: It must be verified that the user is actually of legal age.

Address and Country of residence: In order to identify that the user is not located in any country that is on the above-mentioned risk list, he/she must provide his/her address and country of permanent residence.

Nationality: It must be confirmed if you are a citizen of a country where it is not possible to provide the service.

Phone number: In future updates it will be necessary to provide a phone number, which will be used to send a confirmation code for the activation and validation of the account. Additionally, with prior consent, X4T may send commercial information to the number provided.

Information regarding the identity document (passport, identity card or driving license): to corroborate that the data provided in name and age are correct, an identity number must be provided for identity confirmation.

Photograph: In order to confirm that the person entering the data is the owner of the data and not a third party.

E-mail address: To create a user, an e-mail address is requested to which information can be sent if accepted and through this e-mail to clarify doubts or queries.

IP address: this is unique information for each device, for necessary technical information (region from where the connection is made) and to exclude if it is from an unauthorized country.

Other data such as: browser type, request URL, browser language, and others are collected during use and this information is used to create statistics and optimize the service provided.

The data provided may be used to send information, participate in contests or any additional service as long as the user authorizes it.
When you want to file a complaint or any other inquiry, we ask for your data again (full name, user ID, telephone contact number, e-mail and identity card or passport number).

On what basis do we process your data?

The legal bases on which your data is processed are:

Your consent: Newsletter subscriptions require your voluntary consent and can be cancelled at any time.

For a settlement, purchase or sale or to send answers on inquiries (an agreement between the user and this company to maintain the account on our site).

When there is a legal obligation, derived from a legal act, to comply with necessary measures on these provisions and our legally legitimate interest.

Information and marketing campaigns are carried out reminding users that their data can only be used for the above mentioned and this consent can be modified at any time. An email should be sent, bearing in mind that this does not mean a deletion of your personal data, because we may process your data if it is necessary for some legal basis or if we have a legitimate obligation to do so.

In order to formalize an agreement with you, data processing is necessary if there is an obligation to comply with (either tax or accounting), in accordance with anti-money laundering regulations.

Remember that, even if you have not given us express authorization, your data must be made available if requested by the authorities in accordance with the law.

Based on our legitimate interest, your data will be processed for the purpose of defending us against claims, for evidentiary or archiving purposes, and for analytical purposes to improve our system in the future.

What are the consequences of not providing your data?

Without the required data it is not possible to set up an account or maintain an account, much less perform any transactions with it.

What is your data and how do we share it with other entities?

Except with express consent, your data cannot be shared, except with processing companies (this would be those with which the website works to carry out its commercial activities) either to send SMS messages (if authorized), messaging service providers, entities that provide us with accounting services, companies that provide document authenticity services (which you provide to confirm your identity), entities that assess fraud risks or entities that provide services for the maintenance of the website.

Entrust your data to outsourced companies, does not mean that the confidentiality of your data is violated (these will only be used for work purposes and will not be used for other purposes not approved and used in accordance with the law).

How long do we keep your data?

1- Your data will be kept for as long as it is needed for the purpose for which it was requested.

2- Retained longer than specified above for legal or tax purposes only.

3- The basis for processing your data is:

Your consent: Your consent is retained until consent is withdrawn or if that consent expires (if the service is no longer provided).

The need to execute an agreement: the time is not only the time stipulated between the parties, it must be remembered that the authorities ask us for a longer period to submit these data to their offices.

Legal obligation: Your data will be processed as long as we are legally obliged to do so according to the law.

Pursuit of legitimate interest: Provided that the interest exists.

4- It should be taken into account that even if the binding contract is terminated, we are still obliged to keep and report according to the law of each country for a certain period of time.

5- In consideration of our services we are subject to specific regulations, such as the conservation of: copies of information and documents obtained for the verification of your identity; copies of information and documents that were necessary for the evaluation of fraud risk with your transactions; copies of evidences that confirm the transactions and the necessary registry to identify the transactions. All of these must be retained for a minimum period of 5 (five) years from the termination of our relationship with you.

6- This period of time may be modified, if the legal bodies so provide.

7- After this period of time, all personal data will be deleted and anonymized.

Your rights

You have a number of rights which we will explain more in this section, if you need more information you can send an email which is indicated on the Web Site. For the contact you must remember to: give the data of the person or person interested in the request or complaint; specify the reason for the message; the legal basis or what you are requesting and how you expect the matter to be handled.

Considering the processing of your data you have:

A- The right to be informed when your personal data is being processed and the lawful basis for that processing.

B- Right to have your data corrected and updated if they are incorrect in our system and to complete incomplete personal data.

C- The right to have your personal data deleted (externally, the data remains stored for the legally required period of time).

D- The right not to have your data used for direct marketing purposes.

E- The right to request that your data not be processed.

F- The right to request that your data not be processed for particular situations, but will be processed in the same way in case it is legally justified as necessary.

G- If your consent is necessary for a data processing, it can be withdrawn at any time you consider.

H- You may file a complaint if you believe that we process your data improperly and without legal grounds, this must be submitted to a competent legal body.

I- The right to have the data provided to you given to you in a structured way so that you can use it and send it to another administrator upon request. You may request that your data be transferred to another administrator, provided that you demonstrate consent to this transfer.

Profiling

1- Once you have uploaded all your data and after evaluating your physical factors, economic situation, preferences and personal interests, a profile will be created in our system.

2- The site treats your personal data, the activities you perform on the site and thus evaluate what services to offer you. These profiles take into account the following aspects:

A- Confirm the data provided to assess the risk of money laundering or terrorist financing and thereby fulfill our legal obligation.
B- Adapt the web site considering your preferences and needs.

3- Considering these profiles, it is evaluated which operations can be carried out and what further information is necessary to request in order to guarantee the legitimacy of the transactions in accordance with the law and to avoid risks.

4- In order to decide if it is possible to provide you with any service, the profile and approval of our technicians is required, as well as verification by external entities in the AML/CFT sector.

Cookies

1- You must give consent to store the data and information you enter to be used when you re-enter and not necessary to reload it, if you do not want this should be disabled in the Internet browser options. These cookies are used by our website considering your needs and adapt the operation to this.

2- Cookies are stored in your browser and on your hard drive, depending on the device you use, and these cookies are text files containing information captured by the server and stored on your computer.

We will use this information for the following purposes on the website:

A- Auto-save surveys, login data and form data on the website.

B- Show when logged in and identify the user who logged in to the website.

C- If modifications were made to fonts, colors, etc. Remember these modifications for each user.

D- Customize what advertising to show on the web according to your preferences.

3- Thanks to the cookies, the user’s activities on the website are recorded and it is through them that the preferences of each user are individualized.

4- By default many web browsers accept cookies by default, but these can be modified in configuration. But in some cases these cookies are necessary for the functioning of the website (example: you can not bid because you do not have your data in a sale).

5- The administrator uses the service of third parties for certain web statistics, but this data is anonymous, it does not identify which user it belongs to and it is not possible to individualize and detect who it belongs to.

How do we secure your data?

A- The protection of your data is guaranteed. Your data is stored, used and transmitted securely, protected against unlawful or unauthorized processing and damage or destruction of data.

B- The security measures implemented ensure that your data is not lost, used or changed, using: PCI scanning, encryption, data backup, pseudonymization, periodic testing and strict physical access controls to our building and archive, as well as measurement and evaluation of the effectiveness of the security measures of our systems.

C- Even considering all of the above, we cannot guarantee 100% secure data transmission, therefore we request that you take reasonable precautions to protect your data. Please contact us immediately if you suspect that your passwords or account information has been disclosed.

Procedure to change the Privacy Policy.

Over time standards, technology, legal requirements will change, this means that our Privacy Policy will also change and this will be available on the website and you will be notified of it, since its notification will apply, if significantly relevant it will be sent by email simultaneously.

Statements and basic information.

It is warned and pointed out that the possibility of “infecting” the computer system is mainly malicious software such as worms, Trojans and viruses; and it is recommended for all Internet users and even more so for our users to have an antivirus program that is constantly updated. The Service Provider informs that in spite of all the modern “defenses” described in Security Policies there is no complete and unbreakable protection against malicious software, since these can enter the user by particular actions with the use of electronic services (for example: opening an e-mail).

The Service Provider informs that the service is not supervised by the state as it is not a financial institution registered and regulated as such.

3. The Services offered by the Service Provider may depend on the country, residence, citizenship or stay of the User. The list of countries with fully excluded access to the Services is published and updated on the Website. The change of the above mentioned list shall not constitute a change of the Service Agreement.

It is the user’s obligation to specify the method of payment to the tax authority and the provider is not responsible for taxes arising from transactions made in their services provided.

5. The regulations regarding the security and use of funds deposited in the user’s account are described in this document, these Policies are purely informative, they are not part of the Service Agreement. Changes made to the policy do not imply a change to the Service Agreement.

The Service provider informs and the user acknowledges that transactions are executed on the website with other users or as the service provider as user, specifically excluding those not found in the description of services offered on the website (example: OTC transactions).

Under no circumstances does the Service provider or its affiliates make any investment recommendations, recommendation to buy or sell Fiat funds or cryptocurrencies or suggest any offer either on its social media pages or on the website. The User is responsible for stipulating whether an investment strategy is suitable for him/her and all transactions shall be made only upon the User’s order.

The Service provider does not guarantee or promise any results and the User is advised to consult a Financial Advisor, Lawyer or other investment professional for advice on their individual needs. Buying and selling cryptocurrencies involves financial risk and you are cautioned to consult with the professional of your choice.

The Service Provider disclaims all liability for analysis, advice, opinions or information that prove to be incomplete or inaccurate resulting in losses, to the extent legally protective of the Provider. The User is responsible for his use of the information on the Site or research linked to the Site.

Type and scope of services

The service provided by the Service Provider through the Website is to provide the User with an electronic platform to conclude Cryptocurrency exchange transactions and exchange information.

You must have a device with internet access, compatible with web browsers and able to access Javascript files and cookies for proper use of the Web Site.

If necessary, the Service Provider has the right to change technical and technological requirements that it deems necessary for the use of the account registration, these modifications in the requirements do not constitute a change in the regulations.

Services are provided exclusively for the benefit of:

1. Fully qualified legal entities.

2. Fully capable natural persons, specifically those over 18 years of age and who have not been totally or partially incapacitated;

These services are performed for a fee, which will be published on the website. The User must keep informed about this every time he/she wishes to perform any action that entails a commission. In case of disagreement the user must withdraw the funds to close the account, it is not possible to claim the amounts of commissions once collected.

Execution of the transaction is only possible for a User who:

You have registered and verified your account on the website and that the transaction is within the verification limits.

Your account is logged in.

3. Made the deposit of cryptocurrencies or Fiat funds in accordance with the instruction available on the website.

4.Sent an instruction to execute a Transaction without any doubt;

There is no doubt in the assessment of the AML/CFT risk and there is no contraindication to the completion of the Transaction.

The instruction to execute a Transaction will specifically have all the parameters required for a transaction, such as the price and the amount of cryptocurrencies to be sold or purchased.

When an instruction to execute a Transaction is sent, the User’s funds are blocked in an appropriate amount.

The Service Provider may limit the possibility to execute a transaction by modifying or entering the minimum maximum amount for FIAT funds transaction, these values are published on the website in the table of fees and prices.

Under no circumstances will a transaction be carried out when it exceeds the value of the funds withheld (this amount includes the fee).

The user may not request the return or exchange of Cryptocurrencies or Trust funds, which were purchased through the website, the execution of a transaction is final.

Deposits and withdrawals in cash and cryptocurrencies

1. It is the right of the User to request the withdrawal of Fiat funds or cryptocurrencies available in his/her account.

2. There may be a time between the request for withdrawal of cryptocurrency or fiat funds and the time of withdrawal from the user’s bank account or address, this depends on the type of cryptocurrency or fiat fund, not on the service provider.

3. For payments, deposits and withdrawals of Fiat funds there are minimum and maximum values, which are published on the website in the fees tab, where you can also find the user’s verification level.

4. These values may be modified by the Service Provider due to changing User verification standards or AML/FTC risk assessment. Such changes can be made specifically for each user. The User is forced to withdraw deposits exceeding the limit within the period of time indicated by the Service Provider under penalty of keeping such funds on the deposit account.

5. Cryptocurrency or trust fund may be withdrawn only after the required data is provided by the service provider if deemed necessary by AML/ CFT for that transaction.

6. Only business days for deposits and withdrawals are considered in accordance with the regulations of the legislation of the Republic of Paraguay.

7. For withdrawals of fiat funds or cryptocurrency to the account belonging to or indicated by the User must be identical to the one provided to the Service Provider as the User’s personal data.

8. X4T operates exclusively on the Binance Smart Chain (BNB). It is the User’s responsibility to ensure that funds are sent to the BNB chain correctly. If a User sends funds to a non-BNB chain by mistake and such funds are lost, X4T assumes no responsibility for the loss. In addition, if the User provides an incorrect wallet address when withdrawing funds and, as a result, the funds are lost or inaccessible, X4T will also not be liable for such losses. We urge all users to carefully verify all transactions and addresses before confirming any transactions.

9. If the service provider due to economic, technical or commercial conditions is unable to withdraw the trust funds (for example, if the service provider does not have bank accounts that allow it to hold such trust funds), the equivalent of the user’s trust funds will be paid according to the reserve fund of the USDT/USDC stablecoin.

10.The service provider may decide which cryptocurrencies or fiat funds are allowed on the website and these may be modified/deleted and this change shall not constitute a change in the service contract.

11.If technical, economic or commercial conditions make it impossible or unprofitable to maintain such Fiat Fund, it shall be excluded from the list.

12. Any exclusion of a cryptocurrency shall be handled with absolute discretion, the Service Provider is not obliged to justify its reasons for the exclusion of a cryptocurrency.

13. At least two hours prior notice of the planned delisting of any Fiat Fund or Cryptocurrency shall be published. After this period, it will no longer be feasible to create new orders involving this Cryptocurrency or Fiat Fund and all existing orders will be cancelled. Notice of changes will be sent by email directly to users and by posting information on the Website.

14.The user is obliged to withdraw the cryptocurrency or trust fund that is removed from the list, within 30 days since it is announced, if not withdrawn, those funds will be deposited in accordance herewith.

15. The term specified in point 13 and 14 may be shorter if there were extraordinary circumstances beyond the control of the Service Provider, for which it is not responsible, such as damage to the Blockchain or risk of termination of the banking relationship that provides the possibility of depositing trust funds.

16. Once the cryptocurrency has been removed the User may not be able to withdraw due to objective technical impossibilities (such as the cancellation of the block chain of the Cryptocurrency). In such a case, the User’s right to claim the equivalent of the Excluded Cryptocurrency from the service provider is excluded.

17. At its discretion the Service Provider may decide to delist a particular trading pair without excluding a cryptocurrency or a trust fund. Such delisting of a trading pair shall be communicated two weeks (14 days) in advance. After the expiration of this period no new orders involving such trading pair may be created and all existing orders will be cancelled. The removal of the trading pair shall not constitute a change to the Service Agreement.

18. The Service Provider shall not be liable for any damages or losses suffered by the User in connection with the Deletion of Cryptocurrencies or Fiat Fund (and deposits made in accordance with the above points) or the deletion of trading pairs.

19. On occasion, X4T SA may not have the full amount of FIAT funds requested for a withdrawal. In such circumstances, we undertake to deliver to the user only the amount of FIAT funds available at that time in the company. Any difference between the amount requested and the amount delivered, due to unavailability, will be automatically returned to the user’s X4T wallet. If a user wishes to access an amount that we do not have at any given time, they must wait for the period of time that the company deems necessary until these funds are available. While we strive to ensure prompt availability, the exact time may vary depending on circumstances and present liquidity.

20. When the user goes to the store to withdraw FIAT funds, it is of vital importance and responsibility of the user to count and verify that the amount of cash delivered corresponds to the amount requested. Once the user leaves the X4T premises, no claims related to discrepancies in the amount withdrawn will be accepted. We urge users to perform this verification on the spot and before leaving the premises to ensure their satisfaction and avoid future inconveniences.

The rights of the service provider related to the implementation of a transaction and related to the operation of the website.

In additional cases the Service Provider has additional rights when there is a suspicion that the transaction requested by the User or other activity of the User on the Website may be related to the financing of terrorism, money laundering, commission of a crime or violation of the provisions of the Regulations, legal provisions or good customs, has the right to:

– Disable User Account;

– Refute or stop the execution of the Transaction;

– Withdraw the executed Transaction;

– Perform additional verification of the User and may request the submission of relevant documents or information.

Is the Service Provider entitled to block the right to execute Transactions and deposit or withdraw Fiat Funds and Cryptocurrency of the User if:

– The Service Provider is required to do so by local authorities or by law;

– The User has not complied with its duty to provide additional and unambiguous documentation or information at the Service Provider’s request under the Regulations;

-A risk in the AML/CFT assessment justifies it;

-The user is or has a country of citizenship or country of residence, is on the list of countries excluded from the provision of Services according to the information published on the Website.

Considering safety and ensuring the highest quality in the services provided, the service provider is entitled to:

– The right to suspend the activity of the Website for the time of software update or for the time necessary to repair the technical failure – if this is possible in a given case, the Service Provider shall notify the Users on the Website about the planned technical repairs interruption, sufficiently in advance;

– Do not provide service or discontinue service if the user is within a specific geographic area or within all geographic areas;

– Deny the possibility to register new users.

– The right to eliminate certain types of Transactions.

Several of the rights specified in this paragraph may be exercised simultaneously by the Service Provider.

Complaints

The user has the right to file a complaint related to improper operation of the website, including improper implementation of Transactions.

The complaint should be sent by e-mail to the service provider’s address found on the website or through the website.

3. A complaint shall include:

– Data that determines the User’s identification, User ID and contact information;

– An account of the action or omission in question;

– How the User wishes the Service Provider to consider the complaint;

– Other information that the User considers relevant.

Within 1 to 3 business days (this does not include Saturday, Sunday or holiday in Paraguay), the Service Provider will confirm acceptance of the complaint for review. Complaints will be considered on the basis of the information provided by the User.

Complaints are considered immediately, and at the latest within 15 working days (not including Saturday, Sunday or holiday in Paraguay), from the date of delivery of the complaint to the Service Provider. Within this period, the Service Provider will respond via e-mail or the Website:

– Admit the claim in the form requested by the User;

– Refute the complaint together with the reasons for such decision; or,

– Alternate filing of the complaint.

If the complaint is highly complex and cannot be resolved within 15 working days after receipt of the complaint, the Service Provider shall inform the User about the causes of the delay and provide information about the estimated time needed to respond to the complaint.

– After receiving the proposal, the User has 20 working days (not including Saturday, Sunday or holiday in Paraguay) to accept or reject the alternatives given by the Service Provider. Failure to reply within the deadline will be considered a withdrawal of the claim and it will be assumed that the Service Provider has no liability to the User for the subject matter of the claim. Acceptance or rejection of the Service Provider’s proposal by the User after the deadline may be considered by the Service Provider to have been submitted on time.

– May the User reject the Service Provider’s proposal within 20 working days (not including any day that is a Saturday, Sunday or holiday in Paraguay), the User is entitled to submit a defense of the rejection; in such case the procedure described above shall apply accordingly. Failure to defend such rejection within the aforementioned period shall be deemed a waiver of the claim and it shall be understood that the Service Provider has no commitment towards the User in relation to the subject matter of the claim.

Offers of alternative complaint handling shall only be binding if the user accepts the content and follows the instructions provided by the Service Provider within the time limit. No offer shall constitute an acknowledgment by the Service Provider of any misconduct or liability related to the subject matter of the complaint. Acceptance by the User of this offer of alternative handling of a complaint constitutes acceptance that the complaint will be resolved in the manner specified, and it is the User’s obligation to waive any claim arising therefrom.

Intellectual Property

X4T is a registered trademark.

– Any animation, graphics, text or any content including the functionality, layout and location of specific elements managed on the website are copyrighted works.

– It is the User’s right to use the works within the scope of the permitted private use provided for by the legal provisions.

– Any use beyond the permitted private use requires the prior approval of the Service Provider.

Exclusion of liability of the service provider.

The Service Provider shall not be liable for:

– Any loss suffered by the User as a result of Transactions made;

– Incorrect data entry by the User when depositing or withdrawing Fiat Funds or Cryptocurrencies;

– Consequences related to the loss or making available of Login Data by the User to third parties;

– Effects of events beyond the Service Provider’s control, i.e. software errors, difficulties in accessing the Internet, power outages, hacking attacks (despite maintaining the appropriate measures described on the Website), etc.

– Deletion of data entered by Users within the Service Provider’s computer system from computer systems outside the control of the Service Provider.

Transitory

1. If there is a dispute between a user and another user, the users release the Service Provider and third party service providers from any and all claims or claims for damages (possible profit or loss) for any type of outcome resulting from or relating in any way to such disputes.

2. In case of claims the user is obliged to indemnify the Service Provider and third party service providers against any claim or request for compensation for possible damages (whether any kind of fine, fee, cost for legal assistance or sanction imposed by local authorities) resulting from or related to the user’s violation of these regulations or legal provisions or rights of third parties.

3. Neither the service provider nor its suppliers are liable to a user for amounts in excess of the amounts transacted at the time, of that which was deposited to his account or the completion of a transaction by the user.

4. The limitation of liability of the service provider and its suppliers to the user is only for the value of the transaction expressed in a given cryptocurrency or currency. Liability for lost profits is not included, and liability for any other damages (actual, direct, indirect, indirect, intangible, etc.), regardless of whether transcending contract, tort, negligence, etc., resulting from or related to the authorization or unauthorized use of the Website is limited to the value of the funds provided by the User for the completion of a final Transaction subject to the above section.

5. No warranty is made by the service provider that access to the website or the services or any material contained therein will be uninterrupted, error-free or timely. The service provider excludes to the fullest extent permitted by law any implied warranties in relation to the availability of the service.

6. No warranty or guarantee is given by the Service Provider as to the integrity of the historical cryptocurrency price data available on the website.

7. The Service Provider will endeavor to process requests for a Transaction with bank accounts or credit cards without undue delay, but the Service Provider makes no guarantees regarding the time required to complete the processing of such Transactions, which depends on a number of factors beyond the Service Provider’s control.

8. The Service Provider is not responsible for any actions or consequences of events beyond its control and through no fault of the Service Provider such as: embargoes, riots, government restrictions, insurrection, war or other acts of war, terrorist acts, civil unrest, rebellion, piracy attacks (including DD.S attacks, theft or destruction of data), floods, fires, vandalism or sabotage.

9. The Service Provider shall take the utmost care to protect the Website and the User’s funds against unwanted interruptions by third parties. The security measures adopted are described in the Security Policy, the contents of which the User reads and accepts, considering the security measures adopted by the Service Provider to be sufficient.