General

, ("bitMachina", "the business", "We", or "Us"), owns and operates a network of independent services under the "bitMachina" brand. The intention of bitMachina is to assist its users in using cryptocurrency in their everyday lives. Each independent service under the bitMachina brand is intended only for use where We operate.

We do not guarantee the usage of our products in any region/country outside of the specific country in which the products are purchased. All orders by customers who do not reside in the specific country are subject to their own risk; all processed orders are not eligible for exchange or refund.

Our services are for personal use only. Business use customers must fill out an application and be approved for such purposes before purchasing. All purchases suspected to be made for resale, business, or commercial use is subject to cancellation and can result in the removal of access to our network.

If you are using our Services on behalf of a legal entity, you further represent and warrant that (a) the legal entity is duly organized and validly existing under the applicable laws of its jurisdiction of organization; (b) you are authorized on behalf of such legal entity to act on its behalf and to be bound by this Agreement; and (c) are not identified as a "Specially Designated National" or "Politically Exposed Person;" (d) are not placed on the Commerce Department's Denied Persons List; and (e) will not use our Services if any applicable laws in your country prohibit you from doing so in accordance with this Agreement. In order to use our Services, you will be required to provide any requested information to verify and validate you as a legal entity and undergo any requested regulatory and/or compliance checks.

As used in this Agreement, the following capitalized terms have the following meanings:

• Digital Currency/Digital Currencies. A type of currency which exists only in electronic form and is not tangible, such as Bitcoin. Virtual Currency can be transferred between entities or users with the help of technology like computers, smartphones and the internet. This encompasses, but is not limited to, cryptocurrencies, e-money, virtual money, and alt-coins.
• Wallet Address. A unique identifier of alphanumeric characters, that represents a possible destination for a Virtual Currency payment. Addresses can be generated at no cost.
• Legal Tender. Any national currency, such as Canadian dollars, that may be used in connection with a purchase or sale of Virtual Currencies via the Services, and does not include any Virtual Currency.
• Fund. Virtual Currency and/or Legal Tender.

These Terms and Conditions constitutes the entire agreement between the parties relating to the Website and Service and all related activities. These Terms and Conditions shall not be modified except in writing signed by both parties or by a new posting of these Terms and Conditions issued by

If any part of these Terms and Conditions is held to be unlawful, void, or unenforceable, that part shall be deemed severed and shall not affect the validity and enforceability of the remaining provisions. The failure of to exercise or enforce any right or provision under these Terms and Conditions shall not constitute a waiver of such right or provision. Any waiver of any right or provision by must be in writing and shall only apply to the specific instance identified in such writing. You may not assign the Terms and Conditions, or any rights or licenses granted hereunder, whether voluntarily, by operation of law, or otherwise without our prior written consent.

These Terms and Conditions are governed by the laws of the Province of Ontario and the laws of Canada applicable therein, without regard to its conflicts of laws provisions. The parties hereby agree to attorn to the exclusive jurisdiction of the Courts of the Province of Ontario.

Acknowledgements

By using the Website, you agree and acknowledge that:

• The purchase and sale of any digital currency is inherently risky. Virtual currencies such as Bitcoin, Ethereum, Bitcoin Cash, or Litecoin are subject to constant price fluctuations and trading in digital currencies may result in partial or complete loss of funds. In using our Services you agree to assume all risk associated with the purchase, sale, trade or exchange of digital currencies and you will not hold bitMachina liable for the loss of any funds, either fiat or digital, incurred as a result of using our Services.
• We have no control over, and makes no representations regarding the value of any Digital Currency. You acknowledge and agree that the value of Digital Currencies in not within the control of us, can change rapidly, increase or decrease unexpectedly, and potentially even fall to zero.
• You acknowledge that participation in these networks involves a high risk. The Digital Currency network is operated by a decentralized network of independent third parties. You acknowledge and agree that we have no control over the Digital Currency network and therefore cannot and does not ensure that any transaction you submit using the Services whereby you purchase Digital Currency. Once you have submitted a Digital Currency transaction request to the Blockchain using the Services, the Blockchain will automatically complete or reject the request and you will not be able to cancel or otherwise modify your transaction request. You acknowledge and agree that there are risks associated with using an Internet-based Digital Currency service, including but not limited to, the risk of failure of hardware, software and Internet connections, the risk of malicious software introduction and the risk that third parties may obtain unauthorized access to information used during a transaction;
• We will not be responsible for any losses arising from communication failures, disruptions, errors, distortions or delays you may experience when using the Services, however caused. We assume no responsibility for any losses relating directly or indirectly to any action or inaction you take in connection with the Services and you agree that you assume all risks associated with using the Services.
• Bitcoin and other digital currencies are not currently considered legal currency, assets or property at law.
• bitMachina is not a bank, credit union, trust, or any other kind of financial institution. It is not a deposit taking institution and does not accept deposits from Users, we merely provide a platform through which Users can purchase digital currencies.
• bitMachina uses Bitbuy to determine price quotes. Please note that bitMachina can switch from Bitbuy to any other service to determine price quotes at any given time without prior notice. We do not set the exchange rate or purchase price for the digital currencies that can be purchased on the Website. Rates are determined by many factors, including but not limited to market demand, and users acknowledge that prices for digital currencies fluctuate on a daily basis.
• bitMachina does not provide securities, investment contracts, or any other document or financial instrument considered at law to be a "security", and the services we provide do not constitute trading, purchase, sale or exchange in securities, investment contracts or any other document or financial instrument considered to be a "security" at law.
• bitMachina is not responsible for any representation, advice, or opinion made by sales representatives. These people are independent contractors, and they are instructed to do the following tasks: (1) assist new customers when they use the machines for the first time; (2) providing customers with information regarding new services, offers, or discounts; (3) provide customers with meaningful information after their first transactions. We are not acting and cannot act as an advisor, including as to any financial, legal, investment, insurance or tax matters. Any information provided by us is for general information only. You are solely responsible for determining whether any contemplated transaction is appropriate for you.
• By using any of the Services, you agree that you have read, understood and accept and agree to be bound by and comply with all of the terms and conditions contained in this Agreement, as well as our Privacy Policy which is incorporated into this Agreement by reference. If you do not agree to the terms and conditions contained in this Agreement, you must not use our Services.

You do not require an account in order to use the Services. However, in order to make purchases, you need a mobile/digital wallet where we can send your bitcoin, and a valid cell phone number registered with a major carrier, which we require in order to authenticate the transaction.

Availability & Updates

We may alter, suspend, or discontinue this Website at any time and for any reason or no reason, without notice. The Website or Service may be unavailable from time to time due to maintenance or malfunction of computer or network equipment or other reasons. We may periodically add or update the information and materials on this Website without notice.

License

All information, data, text, software, messages or other materials, whether publicly posted or privately transmitted to the Website Users ("User Content"), is the sole responsibility of such Users. This means that the User, and not bitMachina, are entirely responsible for all such material uploaded, posted, emailed, transmitted or otherwise made available by using the Service. bitMachina does not control or actively monitor User Content and, as such, does not guarantee the accuracy, integrity or quality of such content. Under no circumstances will bitMachina be liable in any way for any materials, including, but not limited to, for any errors or omissions in any materials or any defects or errors in any printing or manufacturing, or for any loss or damage of any kind incurred as a result of the viewing or use of any materials posted, emailed, transmitted or otherwise made available via the Service.

We reserve the right at all times (but will have no obligation) to remove or refuse to distribute any User Content and to terminate users or reclaim usernames. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce these Terms and Conditions, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect the rights, property or safety of our users and the public.

License of Content

By submitting, posting or displaying User Content on or through the Service, you grant us (and our agents) a non-exclusive, royalty-free license (with the right to sublicense) to use, copy, modify, transmit, display and distribute such User Content. We will not be responsible or liable for any use of User Content in accordance with these Terms. You represent and warrant that you have all the rights, power and authority necessary to grant the rights granted herein to any User Content that you submit.

End User License

Except for User Content, this Website, and the information and materials that it contains, are the property of bitMachina and its licensors, and are protected from unauthorized copying and dissemination by copyright law, trademark law, and other intellectual property laws. Subject to the terms of this Agreement, bitMachina grants you a non-transferable, non-exclusive, license to use the Website for your personal use (the "License"). Nothing in the Terms gives you a right to use the bitMachina or bitMachina names, trademarks, logos, domain names, and other distinctive brand features without our prior written consent. Any future release, update, or other addition to functionality of the Website shall be subject to the terms of these Terms.

Intellectual Property

We retain all right, title and interest (including all copyright, trademark, patent, trade secrets, and all other intellectual property rights) in the Services, including our trademarks, designs, logos, URLs and trade names that are displayed on the Site, which we refer to in this Agreement collectively as the "Corporate Materials". We hereby grant you a limited, non-transferable, non-sublicensable and non-exclusive license to access and use the Corporate Materials and to use our Services solely for the intended purposes as determined by us from time to time. Any other use of the Services is expressly prohibited and you agree that this Agreement does not grant you any rights in or licenses to the Services, except for this express, limited license. Except as expressly authorized by us, you agree that you will not copy, transmit, distribute, sell, license, reverse engineer, create a derivative work of, modify, publish or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the content or any part of the Services, in whole or in part. The license granted hereby will automatically terminate if we suspend or terminate your access to the Services.

bitMachina Logos

The following is an illustrative, non-exhaustive list of logos owned by bitMachina. Because this list of logos and their status could change over time, including as we add new products and services, please review this section periodically. Please note that the absence of a product or service name or logo from the list below does not constitute a waiver of bitMachina's intellectual property rights in that name or logo.

If you become aware of any usage of bitMachina brands in violation of these Guidelines, please contact us.

Links & Third-Party Websites

This Website may contain links to other websites that are not owned or controlled by bitMachina. In no event shall any reference to any third party, third party product or service be construed as an approval or endorsement by bitMachina of that third party, third party product or service. We are also not responsible for the content of any linked websites. Any third-party websites or services accessed from the Website are subject to the terms and conditions of those websites and or services and You are responsible for determining those terms and conditions and complying with them. The presence on the Website of a link to any other website(s) does not imply that We endorse or accepts any responsibility for the content or use of such websites, and You hereby release bitMachina from all liability and/damages that may arise from Your use of such websites or receipt of services from any such websites.

Maps & Locator

This website uses third-party service providers to help users find different locations hosting our point of sales. We do not guarantee the accuracy of any data provided by such third-party service providers as bitMachina does not have any control over it. Please note that we may stop using such tools at any time and that we're not liable for any service interruption.

Disclaimers, Warranties & Conditions

THE WEBSITE, SERVICE AND ALL MATERIALS PROVIDED THEREIN ARE PROVIDED "AS IS." BITMACHINA SPECIFICALLY DISCLAIMS ALL REPRESENTATIONS, WARRANTIES AND CONDITIONS, EITHER EXPRESS, IMPLIED, STATUTORY, BY USAGE OF TRADE, COURSE OF DEALING OR OTHERWISE INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT, TITLE, SATISFACTOR Y QUALITY OR FITNESS FOR A PARTICULAR PURPOSE. ANY INFORMATION OR MATERIAL DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICE IS AT YOUR OWN DISCRETION AND RISK AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM, LOSS OF DATA, OR ANY OTHER LOSS THAT RESULTS FROM DOWNLOADING OR USING ANY SUCH MATERIAL.

WE MAKE NO WARRANTIES ABOUT THE PRICE OR AVAILABILITY OF ANY DIGITAL CURRENCY. WE DO NOT WARRANT, ENDORSE, GUARANTEE, PROVIDE ANY CONDITIONS OR REPRESENTATIONS, OR ASSUME ANY RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY ANY THIRD PARTY THROUGH THE WEBSITE OR IN RESPECT TO ANY WEBSITE THAT CAN BE REACHED FROM A LINK ON THE WEBSITE OR FEATURED IN ANY BANNER OR OTHER ADVERTISING ON THE WEBSITE, AND BITMACHINA SHALL NOT BE A PARTY TO ANY TRANSACTION THAT YOU MAY ENTER INTO WITH ANY SUCH THIRD PARTY. BITMACHINA WILL NOT BE LIABLE FOR ANY TYPE OF CONTENT EXCHANGED BY MEANS OF THE SERVICE.

NO DATA, INFORMATION OR ADVICE OBTAINED BY YOU IN ORAL OR WRITTEN FORM FROM US OR THROUGH OR FROM OUR SERVICE WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS. ANY INFORMATION AVAILABLE ON THE WEBSITE OR APPS OR THROUGH THESE SERVICES IS FOR INFORMATIONAL PURPOSES ONLY. NOTHING ON OUR WEBSITE, APPS OR SERVICE CONSTITUTES, OR IS MEANT TO CONSTITUTE, ANY KIND OF ADVICE, INCLUDING, BUT NOT LIMITED TO LEGAL, INVESTMENT, TAX, ACCOUNTING OR FINANCIAL ADVICE.

TRADING, STORING, DEALING, PURCHASING, SELLING AND OTHERWISE USING DIGITAL CURRENCIES COMES WITH INHERIT RISKS. IN USING OUR SERVICES YOU AGREE THAT BITMACHINA IS NOT RESPONSIBLE OR LIABLE TO YOU IN ANY WAY FOR CHANGES TO THE SERVICES OR AVAILABLILITY OF DIGITIAL CURRENCY, INCLUDING BUT NOT LIMITED TO, REGULATORY INTERVENTION BY A THIRD PARTY IN THE OPERATION OF THE WEBSITE AND SERVICE, OR THE UNDERLYING VALUE OF ANY VIRTUAL CURRENCY.

UNDER NO CIRCUMSTANCES SHALL BITMACHINA BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR OTHER DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, ANY DAMAGES THAT RESULT FROM (I) YOUR USE OF OR YOUR INABILITY TO USE THIS WEBSITE, BITMACHINA APP OR THE SERVICE, (II) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS, DATA, INFORMATION OR SERVICES, (III) ERRORS, MISTAKES, OR INACCURACIES IN THE MATERIALS ON THE WEBSITE, (IV) PERSONAL INJURY OR PROPERTY DAMAGE OF ANY KIND WHATSOEVER ARISING FROM OR RELATING TO YOUR USE OF THE SERVICE, ANY BUGS, VIRUSES, TROJAN HORSES, OR ANY OTHER FILES OR DATA THAT MAY BE HARMFUL TO COMPUTER OR COMMUNICATION EQUIPMENT OR DATA THAT MAY HAVE BEEN TRANSMITTED TO OR THROUGH THE WEBSITE, (V) ANY ERRORS OR OMISSIONS IN ANY MATERIAL ON THE WEBSITE OR ANY OTHER LOSS OR DAMAGE OF ANY KIND ARISING FROM OR RELATING TO YOUR USE OF THE WEBSITE; (VI) LOST PROFITS, LOSS OF USE, LOSS OF DATA, FINES, FEES, PENALTIES. THESE LIMITATIONS SHALL APPLY EVEN IF BITMACHINA HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, BITMACHINA'S LIABILITY TO YOU FOR ANY DAMAGES ARISING FROM OR RELATED TO THIS AGREEMENT (FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION), WILL AT ALL TIMES BE LIMITED TO THE GREATER OF (A) HUNDRED CANADIAN DOLLARS ($100) OR (B) AMOUNTS YOU'VE PAID BITMACHINA IN THE PRIOR 12 MONTHS (IF ANY) THE FOREGOING LIMITATIONS SHALL APPLY TO THE FULLEST EXTENSION PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.

YOU SHALL INDEMNIFY AND HOLD BITMACHINA AND ITS SUBSIDIARIES, AFFILIATES, OFFICERS, AGENTS, AND EMPLOYEES, HARMLESS FROM ALL CLAIMS, ACTIONS, PROCEEDINGS, DEMANDS, DAMAGES, LOSSES, COSTS, AND EXPENSES (INCLUDING REASONABLE ATTORNEYS' FEES), INCURRED IN CONNECTION WITH ANY MATERIALS SUBMITTED, POSTED, TRANSMITTED OR MADE AVAILABLE BY YOU THROUGH THE SERVICE AND/OR ANY VIOLATION BY YOU OF THESE TERMS AND CONDITIONS.

Authentication

When you purchase bitcoin or other virtual currencies through Our services, you will be required to submit your cellphone number. Before we process each transaction, we will send a text message with a pin number to your cellphone in order to authenticate the transaction. This allows us to verify that you meet the eligibility requirements set forth above, and you hereby authorize us to perform such authentications and verifications in order to process your transactions.

We will only accept purchases from individuals who have a cellphone number with a major cellphone carrier. If you feel you have been improperly denied, you may provide us with a scanned copy of your phone bill and a piece of government issued identification, and, if approved, will validate your transaction.

We reserve the right to refuse to process any transaction at any time, if in our sole discretion, if we believe you are or may use the Services for any criminal or illegal activities. In the event that a User fails the initial authentication process, We reserve the right to request proof of identification, including photo ID and/or other evidence in order to authenticate a User.

Forbidden Activities

In using the Website and/or Service, You shall not:

• Use the Website and/or Services in violation of the terms of this Agreement, including in violation of the eligibility requirements;
• Use the Website and/or Services for any illegal, criminal and/or fraudulent purpose;
• Copy any content unless expressly permitted to do so herein;
• Upload, post, email, transmit or otherwise make available any material that:
• is unlawful, harmful, threatening, abusive, harassing, tortuous, defamatory, vulgar, obscene, pornographic, libelous, invasive of another's privacy, hateful, or racially or ethnically objectionable, encourages criminal behavior, gives rise to civil liability, violates any law, or is otherwise objectionable;
• infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party (including privacy rights);
• is or contains unsolicited or unauthorized advertising, solicitations for business, promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes," or any other form of solicitation;
• contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment or data or the Website or that of any users or viewers of the Website or that compromises a user's privacy; or
• contains any falsehoods or misrepresentations or create an impression that You know or should know is incorrect, misleading, or deceptive, or any material that could damage or harm minors in any way;
• impersonate any person or entity or misrepresent their affiliation with a person or entity;
• interfere with or disrupt the Website or servers or networks connected to the Website, or disobey any requirements, procedures, policies or regulations of networks connected to the Website or probe, scan, or test the vulnerability of any system or network or breach or circumvent any security or authentication measures;
• intentionally or unintentionally violate any applicable local, state, national or international law or regulation;
• collect or store personal data about other users or viewers;
• license, sell, rent, lease, transfer, assign, distribute, host, or otherwise commercially exploit the Website;
• modify, translate, make derivative works of, disassemble, decompile, reverse compile or reverse engineer any software provided as part of the Website, except to the extent the foregoing restrictions are expressly prohibited by applicable law; or
• register for the Service on behalf of a group or corporate entity.

Please note that We could ban you without warnings if we suspect you of having performed one of the prohibited activities listed above.

Cancellation

We reserve the right to refuse or cancel your order at any time if your payment is made from a wallet which is considered Custodial. Custodial wallets are wallets in which the user is not in control of their own funds; the user does not hold the private keys.

We reserve the right to refuse or cancel your order at any time if the payment which is sent for the order is less than the amount required, as indicated on the payment page. If your order is underpaid, you may be asked to provide additional funds to fulfill any balance owing.

Termination

We may, under certain circumstances and without prior notice, immediately terminate Your ability to access the Services or portions thereof. Cause for such termination shall include, but not be limited to, (a) breaches or violations of these Terms and Conditions or any other agreement that You may have with bitMachina (including, without limitation, non-payment of any fees owed in connection with the website or otherwise owed by You to bitMachina), (b) requests by law enforcement or other government agencies, (c) a request by You, (d) discontinuance or material modification to the website (or any part thereof), (e) unexpected technical, security or legal issues or problems, and/or (f) participation by You, directly or indirectly, in fraudulent or illegal activities. Termination of Your access to the Website may also include removal of some or all of the materials uploaded by You to the Website. You acknowledge and agree that all terminations may be made by bitMachina in its sole discretion and that We shall not be liable to You or any third-party for any termination of Your access to this Website or for the removal of any of the materials uploaded by You to the Website. Any termination of these Terms and Conditions by bitMachina shall be in addition to any and all other rights and remedies that We may have.

Compliance

Anti-Money Laundering and Anti-Terrorist Financing Policy

Since June 1, 2020, Money Services Businesses (MSB) dealing in virtual currency must voluntarily register with FINTRAC and meet certain obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations as an MSB in Canada. Therefore, bitMachina is registered with the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC") as a Money Service Business ("MSB") and cooperates fully with FINTRAC and other law enforcement agency requests in their efforts to detect, prevent, and deter money laundering and terrorist financing. Our registration number is . Please note that mandatory registration does not constitute FINTRAC endorsement.

The scope of the regulations includes virtual currency exchange and virtual currency transfer services. More specifically:

• Virtual currency exchange services include exchanging:
• funds for virtual currency,
• virtual currency for funds or
• virtual currency for another virtual currency.
• Virtual currency transfer services include:
• transferring virtual currency at the request of a client or,
• receiving a transfer of virtual currency for remittance to a beneficiary.

We have developed an Anti-Money Laundering and Anti-Terrorist Financing Policy that meets legislative requirements and reflects management's principles on managing money laundering and terrorist financing risks. We have and will continue to implement components of our compliance regime to ensure we satisfy all applicable prescribed measures of the PCMLTF Act and Regulations.

We take our obligations seriously and that means we have undertaken and will continue to undertake the implementation of an appropriate level of compliance. Our compliance program includes:

• Implementing a Risk Based Approach in combating Money Laundering and Terrorist Financing. As part of this assessment, bitMachina assesses the risk in five categories as "high risk" a nd "not high risk." A score for the entire business is obtained by taking the average risk rating across each of the four categories. We must consider the following factors:
• Products, Services and Delivery Channels: the specific goods or services that we buy and sell as well as the ways in which we serve our customers;
• Geography: the areas in which we operate, including our suppliers, our physical locations and the areas in which our customers are located;
• Our Customers and Business Relationships: the individuals or organizations that engage in transactional activity with our business;
• New Developments & Technologies: changes to technology or other aspects of our business that can have a significant impact on our risk;
• Other Factors: this includes any element of our business that is not considered in the previous categories. We consider our employees, our suppliers and our agents as additional risk factors. Specifically of focus are our recordkeeping, reporting and key operational processes that impact all aspects of our business.
• Ongoing monitoring for suspicious activity based on risk-based indicators and other factors. We adhere to the following regulatory requirements: risk-rating all business relationships and amending their risk-rating if the need arises, conducting ongoing monitoring of the business relationship at a frequency commensurate to the client's allocated risk-rating; and, keeping a record of the measures that we have taken to monitor the relationship and the information we obtained as a result. If necessary, we may require our clients to provide additional documentation or information to confirm source of funds or the purpose of the transaction. Our compliance staff will review any transactions that trigger an alert and determine if the transactions are within the customer's stated activity before being released or completed. In some cases, bitMachina will require additional information from the customer such as source of income, proof of employment, nature of the customer's business, as well as review of client's transaction history.
• Implementing Know Your Customer and Customer Due Diligence processes for our customers. Prior to a customer being able to perform a transaction, bitMachina may identify that customer in accordance with applicable regulations. Our customers who present an elevated risk will have their identification information updated at least every two years, or sooner depending on our evaluation. Customers who present an elevated risk include (but is not limited to) Politically Exposed Persons ("PEPs") in all of its legal forms. This is to be done by reviewing original identity or entity documents and recording the updated identification or information details for our files as appropriate.
• Limits and control based on client verification levels. In some cases, we need to identify our customers and record specific information about the customer. These situations are not negotiable. We may increase or decrease a customer Transactional Limits after analyzing different factors, such as the customer's profile, the customer's documents and/or any relevant source of information.
• Assigning a Compliance Officer. Under the PCMLTFA, bitMachina has designated a Compliance Officer who is responsible for the implementation and oversight of our compliance regime, and has the authority and the resources to ensure the ongoing compliance of our organization as it relates to the identification and prevention of money laundering and terrorist financing. The Compliance Officer acquires approval from a senior officer for the compliance program.
• Ongoing Training for all employees, staff, and Management (including board of directors). The Compliance Officer will ensure that all staff have received sufficient training to be effective in their roles. Minimum standards for training are set out in the AML & CTF Compliance Policy. In instances where staff are performing specialized roles, or where the Compliance Officer has observed performance issues relating to compliance tasks, additional training will be provided.
• Report suspicious activity to FINTRAC. We must report any transactions or attempted transactions where there are reasonable grounds to suspect it relates to money laundering or terrorist activity. There is no monetary threshold for submitting a Suspicious Transaction Report. The Compliance Officer has the authority to file STRs with FINTRAC and is required to maintain a log of all reports filed in accordance with bitMachina's record keeping procedures. 'Reasonable grounds to suspect' captures predicate offences and that tax evasion is also considered a predicate offence for money laundering. Accordingly, if we suspect transactions are being undertaken to avoid or evade paying income taxes, bitMachina is obligated to report the transactions as suspicious to FINTRAC.
• Terrorist Property Reporting and Sanctions Requirements. There are two situations where We must send a terrorist property report to FINTRAC immediately: Knowing that a property is owned or controlled by or on behalf of a terrorist or terrorist group, and believing that a property is owned or controlled by or on behalf of a listed person. Where there are economic sanctions, bitMachina is required to prohibit or restrict activities in accordance with the legal requirements. In some cases, bitMachina may be required to freeze property, in addition to making reports to various government and law agencies.
• Reporting to FINTRAC of Large Virtual Currency transactions as prescribe by FINTRAC. As of June 1, 2021, Large Virtual Currency Transaction Reports have to be submitted to FINTRAC when a customer conducts a transaction, in virtual currency, valued at CAD 10,000 or more in the same 24-hour period. This may be in a single transaction or several separate transactions. The Compliance Officer will emphasize with all staff that third-party determinations must be conducted in the case of large virtual currency transactions. This involves asking the customer whether they are completing the transaction on their own behalf, or on behalf of another person or organization. If the transaction is being conducted on someone else's behalf, staff members will collect additional information about the person or organization on whose behalf the transaction is being conducted and their relationship to the person conducting the transaction.
• Periodically review our compliance program to test its effectiveness at least every two years. The Compliance Officer will ensure that an AML Compliance Effectiveness Review is conducted at least every two years. The resulting report will be signed-off by Senior Management within 30 days of issue. The minimum standards are defined in the AML & CTF Compliance Policy. In addition to ensuring that these standards are met, the Compliance Officer will ensure that all reviewers are sufficiently qualified by requesting a copy of the curriculum vitae (CV) for all reviewers prior to selecting a third-party reviewer.
• Record Keeping. As a registered MSB with FINTRAC, bitMachina is required to keep certain types of records depending on the client type and transaction type - this includes records of any STR's submitted to FINTRAC. When we have to send an STR to FINTRAC, we must take reasonable measures, before the transaction is reported, to ascertain the identity of the individual who conducted or attempted to conduct the transaction. We are required to maintain an effective recordkeeping system to enable FINTRAC to have access to the records in a timely fashion. Our records have to be kept for a minimum of 5 years, and in such a way that they can be provided to FINTRAC within 30 days of a request to examine them.

Daily Limits & Individual Order Limits

bitMachina has a daily limit which can differ among users. Your daily limit is based on a revolving 24-hour timer. Our services will prevent users from adding an amount above the daily limit. We reserve the right to cancel any orders which are placed that exceed the daily limits or any orders which are thought to be an attempt to circumvent the set daily limits.

Sanctions

Applicable Sanctions. You warrant that you will comply with all applicable international economic and export sanctions and any requirement therein. Without limiting th e generality of the aforementioned, you will not use the Services available if any of the following applies to you:

• You are a national or resident of any country included in the US embargo, United Nations sanctions, HM Treasury's Financial Sanctions (the "Restricted Territories") or you intend to distribute or provide the acquired Virtual Currency or the Services to the Restricted Territories; Countries currently not supported include the Central African Republic, Democratic Republic of the Congo, Eritrea, Iran, Iraq, Lebanon, Libya, Mali, Myanmar, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Tunisia, Ukraine, Venezuela, Yemen, and Zimbabwe.
• Your name appears on the US Treasury Department's Specially Designated Nationals List or the US Commerce Department's Denied Persons List, Unverified List, Entity List (the "Restricted Persons") or you intend to distribute or provide the Services to any person of the Restricted Persons; and
• You are on a prescribed sanctions list.

Scam Warning

The Canadian Government, The CRA, and/or Utility Companies (ex Hydro One) DO NOT ACCEPT BITCOIN OR ANY OTHER CRYPTOCURRENCY or any other form of cryptocurrency as payment.

Please do not send Bitcoin or cryptocurrencies to any request for payment. This is very likely a SCAM. Please keep your money and your cryptocurrency safe.

Fees and Charges

Exchange trading fees and network confirmation fees are deducted automatically per transaction from the exchange, and is included in our buy and/or sell price indicated on the screen of our machines. Other charges, however, may be applied by your virtual wallet provider.

In consideration for providing the Services, We charge a Service fee. The amount of the service fee we apply varies depending on a number of factors. Typically, we charge markup on transactions we process. Note that we change the markup according to market conditions.

We do not provide refunds for cryptos purchased through our Services. You hereby understand and agree that when you purchase any bitcoin or other digital currency through our Services, the transaction is final, and non-refundable.

Promotions

From time to time, bitMachina may offer promotions or discounts. These promotions are offered in our sole discretion, and we may initiate or terminate a promotion at any time for any reason without notice.

Refund Policy

All transactions are final and are not reversible once money is fed into the machine or given to a cashier for cryptocurrency purchases or when a withdrawal is initiated.

If you have made a mistake in your order, you must immediately contact us to try to rectify the situation. We will work with our customers to help with any and all issues, however as most systems are automated, it is likely a refund will not be available. Refunds are discretionary. We are not bound by any previous instances of refunds and evaluates requests on a case-by-case basis.

Technical Difficulties and Support

Please direct any technical difficulties or questions and concerns to info@bitmachina.ca and we will happily respond back during regular business hours. Please allow adequate time for a response.

Processing Times

bitMachina processes all orders after 1 confirmation on the appropriate blockchain. Some orders may require manual intervention and approval, in which cases we will strive to fulfill these orders within a maximum of 12-24 hours of receiving payment. Very large order volumes may take extra confirmations and processing time may be extended.

Security

Information sent or received over the Internet is generally unsecure and we cannot and do not make any representation or warranty concerning security of any communication to or from the Website or Service or any representation or warranty regarding the interception by third parties of personal or other information. You are responsible for safeguarding the information and/or devices that you use to access the Service and you are responsible for any activities or actions under your password. You agree to keep your password secure. We will not be liable for any loss or damage arising from your failure to comply with these requirements.

Feedback

If you provide bitMachina with any suggestions, comments or other feedback relating to any aspect of the Website and/or Service ("Feedback"), bitMachina may use such Feedback in the website or in any other bitMachina products or services (collectively, "bitMachina Offerings"). Accordingly, you agree that: (a) bitMachina is not subject to any confidentiality obligations in respect to the Feedback, (b) the Feedback is not confidential or proprietary information of you or any third party and You have all of the necessary rights to disclose the Feedback to bitMachina, (c) bitMachina (including all of its successors and assigns and any successors and assigns of any of the bitMachina Offerings) may freely use, reproduce, publicize, license, distribute, and otherwise commercialize Feedback in any bitMachina Offerings, and (d) You are not entitled to receive any compensation or re-imbursement of any kind from bitMachina or any of the other users of the Website in respect of the Feedback.

Privacy Policy

We are committed to protecting your privacy. We make available the bitMachina website located at www.bitmachina.ca including all subpages and successor pages (together the "Website"), and the bitMachina mobile applications, and the bitMachina current and future technologies (including but not limited to the "POS/Crypto-Debit-Kiosks"), together with all our Services.

Consent

By using our Services, you consent to the use of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Website and/or the Services.

"Personal Information" is any information about an identifiable individual, such as your name, telephone number, address, location, e-mail address, and phone number.

Collection of Personal Information

Two types of information may be collected through the Website and our Services: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) information that is publicly available, such as names, addresses, telephone numbers and electronic address when listed in a directory or made available through directory assistance; or (b) Non-Personal Information.

We aim to collect, use and disclose only Personal Information to enable to provide the Services, including processing purchase orders and delivering purchased goods, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes and for service improvement.

At the time of collection, bitMachina will identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information you may not be able to use certain features of the Website, App, Services, and even certain promotions.

We will maintain the confidentiality of any contact information you provide to us on signing up for our Services or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases. Please note that we use third party-services to link your IP address to your location. This product includes GeoLite2 data created by MaxMind, available from maxmind.com.

If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy.

Use of Personal Information

When ordering or registering on our site, ATMs, kiosks, Apps, or any other service, you may be asked to enter your name, email address, mailing address, phone number or other details to help you with your experience.

We collect information from you when you register on our site, place an order, subscribe to a newsletter, fill out a form, or enter information on our site or to provide us with feedback on our products or services.

Except as set forth in the Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies the individual. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Website and/or the Services.

Use of Information: We collect information for the following purposes:

• Services: In order to use our Services you must provide certain Personal Information to us such as your mobile phone number, bitcoin or other cryptocurrency wallet address, or any other information requested on our website, platforms, apps, or interfaces. None of your information will be shared with any other person or entity except for the third-parties disclosed.
• Identity Verification: We may use the Trulioo's GlobalGateway solution to verify your identity. In order to verify your identity, you must provide us with your name, date of birth, address, city, phone number, email, occupation, and your reason to use our services. This information is then provided to Trulioo to verify your identity. All personal information we provide to Trulioo will be treated in accordance with the terms of Trulioo's privacy policy, which you should read carefully. We do not control, and are not responsible for how Trulioo treats your personal information.
• Other Verification and Authentication: We may also request further proof of identification in order to conduct verification, including when your initial credentials are rejected or when you change the phone number or email address associated with your name. Such evidence may include a copy of government photo ID, current photograph, proof of mailing address, proof of cell phone number or email address ownership, as determined by us in the circumstances.
• Transactional Notifications: Despite your indicated email preferences, we provide notifications for certain activities relating to your use of our Services such as sending personal identification numbers to your mobile phone in order to verify purchases and confirmations when a transaction has been completed. We may also send you notices of any updates to our Terms and Conditions.
• Statistics: We also collect statistics about use of the Services purchased through the Website. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.

From time to time we may employ third parties to help us improve the Website and/or the Services. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website and/or the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff or other permitted persons or companies as are reasonably necessary to carry out the stated purposes We have communicated to you.

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Our servers are located in Canada and accordingly your Personal Information may be available to government agencies and/or law enforcement in this country under a lawful order, irrespective of the safeguards We have put in place for the protection of your Personal Information.

By using our Website, App and Services, you consent to the hosting of your Personal Information in Canada.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email or cellphone information for the Services to third parties.

Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. See: https://support.google.com/adwordspolicy/answer/1316548?hl=en

We have not enabled Google AdSense on our site but we may do so in the future.

Online Privacy Protection Act

OPPA is a law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond North America to require any person or company in the United States and Canada (and conceivably the world) that operates websites collecting Personally Identifiable Information from Canada consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared.

Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, Non-personal Information, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

Amendments to this Policy

We reserve the right to change this Privacy Policy at any time. If We decide to change this Privacy Policy in the future, We will post an appropriate notice on the Website or App. Changes will become effective 30 days from their posting on the Website or App. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that We have about you. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website and/or Services signifies your acceptance of any changes.

Access and Accuracy

You have the right to access the Personal Information We hold about you in order to verify the Personal Information We have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, We will provide you with a copy of your Personal Information although in certain limited circumstances, We may not be able to make all relevant Personal Information available to you, such as where that information also pertains to another individual or as otherwise required or permitted by law. In such circumstances We will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. The Website is provided solely for informational purposes and should not be used as a basis for any investment or other purpose.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and We will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which We are permitted to disclose your information. Having accurate Personal Information about you enables Us to give you the best possible service. You can help by keeping Us informed of any changes to your Personal Information.

Cookies

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information.

We use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies. If you turn cookies off, some of the features that make your site experience more efficient may not function properly.

Third-party Links

Occasionally, at our discretion, we may include or offer third party products or services on our Website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Recordings and Footage

Our machines are equipped with a security camera and microphones. Footages and audio records may be used in in cases of a crime has occurred including but not limited to theft or fraud.

Miscellaneous

Our online price index in our website's menu bar may or may not be accurate our machines price and is for aesthetic purposes only. We hold no liability regarding this widget as it is a third-party script. Unless otherwise stated all dollar amounts, including rates, fees and limits, are in CAD.

If at any time you would like to unsubscribe from receiving future emails, or get in touch with us for any other purposes, you can email us at info@bitmachina.ca.