Legal agreement


Please read these terms of use carefully before using this site.
These terms of use (together with the documents referred to in them) tell you the terms on which you may make use of our websites at, or any of our other domains (jointly, our "Services"). Please read these terms of use carefully before you start to use the site, as they will apply to your use of our site. We recommend that you print a copy for future reference. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.
Please note that in addition to these general terms governing your use of our site, we also refer you to our AML-policy, Return/Refund/Cancellation policy, Privacy policy and Deposit/Withdrawal policy.
  1. 1. PREAMBLE
    1. 1.1. This document (hereinafter — the Terms and Conditions) contains the principal provisions pertaining to the operation of Services and working in this System.
    2. 1.2. The Terms and Conditions define the principles and conditions on which the Administrator — a Slovakia company Interspin s.r.o. — provides for remuneration access to the System’s Services to a Customer (any person accepting the Terms and Conditions) charging Fees as per the agreed Rates in accordance with the established procedure; in turn, a Customer shall use the System and its Services in accordance with the Administrator’s instructions and guidelines as set forth in these Terms and Conditions.
    3. 1.3. This document is the Administrator’s official public offer intended for eligible parties (including individuals that are 18 years of age or older) regarding the opportunity to use the System and its Services.
    4. 1.4. Pertaining to any and all matters not provided for in the Terms and Conditions, the Administrator may regulate such matters on the basis of its internal procedures and documents (IPD) providing to a specific Customer access to information regarding such internal procedures and documents on this Customer’s written substantiated request.
    1. 2.1. Authorization Details shall mean a combination of the Login and Password and/or OAuth details by Facebook, Google and VK.
    2. 2.2. Authorization shall mean the process of authenticating a person by their Login and Password ot OAuth details.
    3. 2.3. Prohibited Activities shall mean activities characterized by one or more of the following qualities: constitute criminal offense in a Customer’s country of jurisdiction; are connected with sales of Crypto assets prohibited for sale in a Customer’s country of jurisdiction; contradict the accepted universal standards of ethics and morality.
    4. 2.4. Identification shall mean a special procedure of a Customer’s providing to the Administrator such Customer’s personal data as required by law or under these Terms and Conditions.
    5. 2.5. Customer shall mean a person pertaining to whom there arises a right or an obligation related to transfer, acceptance, and acquisition of Crypto asset or Funds under these Terms and Conditions.
    6. 2.6. Crypto asset shall mean one of wide spread cryptocurrencies accepted and/or transferred by Services within Customer’s transactions.
    7. 2.7. Funds shall mean fiat electronic money accepted and/or withdrawn by Services within Customer’s transactions.
    8. 2.8. Unidentified Customer shall mean a registered Customer whose identity was not verified: an Unidentified Customer may use the Services with restrictions as set forth in these Terms and Conditions.
    9. 2.9. Transaction shall mean Customer's purchase or sell operation via Services towards Crypto asset.
    10. 2.10. Registration shall mean the result of entering a person’s data into Services, after which a Customer is identified by the System.
    11. 2.11. Contact Details shall mean the following addresses and phone numbers: for the Administrator: for communication by mail: Severovcov 7, 85110, Bratislava, Slovakia, for communication by phone: +421233006738, for communication via Skype: Coin2card, for communication via email: /, for communication via Telegram:; for a Customer – the contact information provided by a Customer in the electronic form during the Registration procedure.
    12. 2.12. System shall mean a set of hardware and software developed, created and operating for the purpose of the Administrator’s providing the System’s Services to a Customer.
    13. 2.13. Parties shall mean the Administrator and a Customer referred to jointly.
    14. 2.14. Chargeback shall mean the procedure of cancelling a bank card payment initiated by the cardholder through their bank.
    1. 3.1. A Customer accepts these Terms and Conditions (accepts the public offer) by completing the following procedures in the required order: 1) filling out the registration forms of Services, including the creation of the Authorization Details; 2) reading these Terms and Conditions; 3) confirming accepting them by ticking the relevant field in the Service's form.
    2. 3.2. Acceptance of these Terms and Conditions means a Customer’s full and unconditional acceptance of all the provisions and conditions set forth in these Terms and Conditions without any exclusions and/or restrictions, which is equivalent to entering into a bilateral agreement.
    3. 3.3. These Terms and Conditions are accepted for an indefinite period of time.
    4. 3.4. A Customer can only obtains access to the System’s Services after a Customer has accepted these Terms and Conditions.
    1. 4.1. The purposes of the Services are to provide instant transactions of Crypto assets purchase and sell to Customers with Funds in available currencies.
    2. 4.2. Certain limits may apply to Transactions with respect to level of Customer’s Identification, Transaction’s currencies and/or Crypto assets and restrictions/limitations from banks, which emitted Customer’s card.
    3. 4.3. Customer gains an access to the Services after completion of Registration.
    4. 4.4. Access to Customer’s profile and any Transactions through the Services are possible only after Customer’s Authorization.
    5. 4.5. Customer is able to complete Identification procedure according to AML and KYC policies set by Administrator at the moment of Customer’s request.
    6. 4.6. A Login is a Customer’s email address or OAuth data specified by a Customer during the Registration.
    7. 4.7. Passwords are created by Customers and may be changed at any moment.
    8. 4.8. A Customer is responsible for keeping his Authorization Details confidential. Any actions related to the Services performed with the use of correct Authorization Details shall be considered to be actions performed by the Customer.
    9. 4.9. To use the System’s Services, a Customer has to complete the Registration onto the System’s Website confirming accepting these Terms and Conditions and their legal capacity. Customer must be older than 18 years to be able to use the System’s Services.
    10. 4.10. The information on a Customer’s Transactions is recorded and kept by the Administrator for the duration of the effective term of these Terms and Conditions and for three years after.
    11. 4.11. A Customer may register within the Services and perform Transactions if that is legally permissible and lawful in this Customer’s country of jurisdiction.
    12. 4.12. In case of a Customer has lost its Authorization Details, the Administrator shall provide him the opportunity to recover access to the Services.
    13. 4.13. The Administrator may perform Customer’s profile lockdown (suspend Transactions from a Customer’s profile) in certain cases in accordance with the Terms and Conditions and under applicable laws.
    14. 4.14. A Customer may close their profile at any time by contacting the Customer Service.
    1. 5.1. A Customer may purchase Crypto assets by placing an order to Service and payment with his bankcard.
    2. 5.2. In case of purchase of Crypto assets a Customer specifies blockchain address he wants to receive Crypto funds to.
    3. 5.3. The Service of transfers Crypto assets to specified address as soon as it receives Customer’s Funds.
    4. 5.4. A Customer may sell his Crypto assets by placing an order to Service and transferring the Crypto assets to blockchain address specified by the Service on order placement.
    5. 5.5. In case of sell of Crypto assets a Customer specifies details of his bankcard he wants to receive Funds to.
    6. 5.6. The Service of transfers Funds to specified bankcard as soon as it receives Customer’s Crypto assets.
    7. 5.7. Particular deposit/withdrawal conditions and time frames are defined by Deposit/withdrawal policies.
    8. 5.8. For security reasons, there are limits established for Customer’s Transactions.
    9. 5.9. The Administrator may restrict the range of Funds deposit/withdrawal methods for certain categories of Customers or countries according to the list of prohibited counties defined by Deposit/withdrawal policies.
    10. 5.10. When receiving an Order from a Customer, the Administrator verifies Customer’s right to perform Transactions on the basis of Customer’s Authentication via the Authorization Details.
    11. 5.11. When using bankcards, Return/Refund/Cancellation policy is applied. If the user successfully completes the verification procedure and Funds are credited to the Transaction, the card transaction is non-refundable. If the user does not complete the verification procedure, the card transaction is refunded automatically. It may take the funds up to 14 business days to appear on the card.
    1. 6.1. A Customer can access the list of his orders within his profile at any time.
    2. 6.2. A Customer shall verify that the information pertaining to its profile is accurate and current.
    1. 7.1. The Administrator shall charge fees in remuneration for the Services provided to a Customer (hereinafter – the Fees); the amount and procedures for charging the Fees are specified in the Rates.
    2. 7.2. The Rates are published on Services’ websites by the Administrator.
    3. 7.3. The Administrator may unilaterally change the Rates. These changes and amendments shall come into effect from the moment of publishing on Services websites.
    4. 7.4. All commission fees are calculated in Transaction currencies.
    5. 7.5. The Administrator debits all applicable Fees to Customer’s Funds of current Transaction.
    6. 7.6. Administrator is fixing the Rate of Transaction for 20 minutes. In case Funds or Crypto assets are not received by the Service Transaction closes at the current Rate.
    7. 7.7. If the Funds of Transaction are not sufficient to charge the applicable Fees, the Administrator may decline a Transaction or send to a Customer a request to pay the Fees.
    1. 8.1. The Administrator may collect, store, and process the personal data provided by Customers during their transactions, as well as other data automatically transmitted to the Administrator in the process of their use of the System, as well as transfer such data to third parties for the purpose of fulfilling the Terms and Conditions or additional agreements with these third parties, as well as all other Transactions with Customers’ personal data permissible under applicable laws.
    2. 8.2. The Administrator may collect, store, and process information on any purchases made, services or works paid for the purpose of targeted advertisement, as well as transfer statistical data to third parties without disclosing Customers’ personal data.
    3. 8.3. Payment details as bankcard number or other related data is not stored by the Administrator within Services databases and is transferred to third parties (banks, payment systems) via secure encrypted connections.
    1. 9.1. A Customer may:
      1. 9.1.1. obtain access to all the System’s Services in accordance with a Customer’s Status and any other restrictions;
      2. 9.1.2. request statistics on Transactions;
      3. 9.1.3. get technical and informational support;
  2. 9.2. The Administrator may:
    1. 9.2.1. change range of Services;
    2. 9.2.2. modify the Software, interfaces, operating procedures, and the Services;
    3. 9.2.3. in the event of detecting any defects or failures, for maintenance purposes and the purpose of preventing unauthorized access to the System, suspend its operation;
    4. 9.2.4. request a Customer to provide identification documents and other information in the cases provided for by the Terms and Conditions and IPD;
    5. 9.2.5. In the cases provided for by the Terms and Conditions and the IPD, refuse to carry out a Transaction (including, but not limited to, a Customer’s attempt to carry out Prohibited Activities);
    6. 9.2.6. In the cases provided for by the Terms and Conditions and the IPD, refuse to carry out a Transaction (including, but not limited to, a Customer’s attempt to carry out Prohibited Activities);
    7. 9.2.7. resort of retaliation measures against a Customer in the event of this Customer’s violation of the Terms and Conditions;
    8. 9.2.8. charge the Fees for the Services in accordance with the established Rates;
  3. 9.3. A Customer shall
    1. 9.3.1. comply with the provisions of the Terms and Conditions with the Administrator.
    2. 9.3.2. provide reliable and valid information during the Registration in the System and the procedure of Identification.
    3. 9.3.3. not allow any third parties to use its profiles, and not disclose its Authorization Details.
    4. 9.3.4. immediately notify the Administrator when discovering a Transaction carried out without his permission, unauthorized access to his personal information, or loss of the Authorization Details; all Transactions carried out with the use of the Password of this Customer prior to notification of a kind shall be considered as Transactions carried out by this Customer;
    5. 9.3.5. guarantee that there is no Malicious Software on their computer (or any other data carrier; work with the System on a computer that has the following installed: antivirus software with the updated database (not later than the date a Customer logs into the System), a firewall, the updated version of a browser, all the necessary updates for the operating system and the software; use only licensed software;
    6. 9.3.6. not refuse to provide assistance in any investigation or provide identity verification details or any other information upon request;
    7. 9.3.7. not use the System to carry out Transactions aimed at obtaining illegal profit or tax evasion;
    8. 9.3.8. not use the System for any purposes that violate any laws, including attempts to carry out Prohibited Activities;
    9. 9.3.9. keep accounting records of all revenue received as a result of Transactions made through the Services and pay all applicable taxes in accordance with the laws of a Customer’s jurisdiction;
    10. 9.3.10. A Customer acknowledges and confirms that all the provisions of the Terms and Conditions are clear, and a Customer accepts them unconditionally and in their entirety.
    11. 9.3.11. A Customer shall bear full responsibility for any cancelled, invalid, and disputed Transactions, and for any Chargebacks.
    12. 9.3.12. A Customer’s failure to comply with any provision of this paragraph 9.3. shall result in this Customer’s responsibility for all the expenses incurred.
  4. 9.4. The Administrator shall:
  5. 9.5. establish the Terms and Conditions, organize and carry out control over Customers’ compliance with the Terms and Conditions;
  6. 9.6. provide Customers with the services of access to the System;
  7. 9.7. send notifications of any Transactions carried out from a Customer’s profile to the email address provided by this Customer;
  8. 9.8. ensure the operation of the Customer Service;
    1. 10.1. A Customer must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful.
    2. 10.2. A Customer must not attempt to gain unauthorised access to the Services websites, the server on which our site is stored or any server, computer or database connected to our site.
    3. 10.3. A Customer must not attack the Services websites via a denial-of-service attack or a distributed denial-of service attack.
    4. 10.4. By breaching this provision, A Customer would commit a criminal offence under the Computer Misuse Act 1990.
    5. 10.5. Administrator will report any such breach to the relevant law enforcement authorities and Administrator will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, Customer’s right to use the Services websites will cease immediately.
  1. 11. LIABILITY
    1. 11.1. In the event of failure to comply and/or improper fulfillment of the obligations under these Terms and Conditions, the Parties shall be responsible in the accordance with the provisions of these Terms and Conditions, AML-policy, Return/Refund/Cancellation policy, Privacy policy, Deposit/Withdrawal policy, the IPD and the applicable laws of Slovakia.
    2. 11.2. If a Customer delays the fulfillment of any obligation in the monetary form as set forth in these Terms and Conditions, a Customer shall pay to the Administrator a penalty fine in the amount of 0.1% (one tenth of a percentage point) of the amount of such delayed funds to be transferred to the Administrator or any third parties for every day of such delay. A Customer shall pay to the Administrator the penalty fine as specified in this paragraph of the Terms and Conditions within 3 (three) business days after the date a Customer receives a relevant request from the Administrator in writing or electronically. The Administrator has the right but is under no obligation to send a penalty fine payment request.
    3. 11.3. A Customer shall repay to the Administrator the damages incurred as a result of various payments charged to the Administrator due to a Customer’s violations of the applicable laws when using the System on condition that the Administrator can provide the relevant documents that confirm the damages incurred by the Administrator.
    4. 11.4. A Customer shall bear responsibility for all Transactions accounted for in his profile, including any Transactions with the use of bank payment cards. These Transactions shall include any transactions entered into by a Customer’s authorized persons, agents, and affiliates, or other parties that have access to this Customer’s profile.
    5. 11.5. A Customer shall bear responsibility for complying with the requirements and provisions of all applicable laws.
    6. 11.6. A Customer acknowledges and confirms that a Customer agrees with the Policy for Complying with Anti-Money Laundering and Terrorism Financing Requirements published on the Services websites of and guarantees that a Customer shall comply with its provisions and requirements.
    7. 11.7. A Customer warrants that its activities on the Internet and in the System do not contradict the generally recognized moral principles and norms.
    8. 11.8. When the Funds within Customer’s Transactions are insufficient due to changes of Rates, the Administrator may request that a Customer immediately add Funds by the necessary amount, or may proceed with the relevant debt collection procedures against such Customer.
    9. 11.9. A Customer shall not undertake any activity that misleads other parties about services offered by the Administrator, which can directly or indirectly damage the Administrator’s reputation, including but not limited to impersonating themselves as representatives of the Administrator in any way or context, providing false data related to the Services including but not limited to falsifying transaction IDs, blockchain addresses etc as text, screenshots, or any other media, creating clones of the Administrator’s websites, and other similar activities. In case of violation the Administrator reserves the right to block profiles, freeze Crypto assets or Funds for the period of investigation, and limit the usage of the System in other ways. The Administrator also reserves the right to pursue legal action in courts of applicable jurisdiction, including cases when the this rule is violated by other parties that are not Customers of the Administrator.
    1. 12.1. The Administrator shall have no responsibility to a Customer in the event of:
      1. 12.1.1. a Customer’s transfer of their data to any third parties, deliberate provision of access to their profile in the Services, or any other violation of the confidentiality of a Customer’s information;
      2. 12.1.2. presence of any viruses or any other Malicious Software in the hardware and software used by a Customer to access the System;
      3. 12.1.3. illegal activities of any third parties, including those related to the use of a Customer’s Registration and a Customer’s email;
      4. 12.1.4. complaints pertaining to a Customer from tax, regulation, and law enforcement authorities regarding any reporting documentation or taxation in relation to a Customer’s transactions involving the System.
    2. 12.2. The Administrator shall not be responsible for temporary showdowns of the Systems, failures and errors in the operation of any hardware or software (including but not limited to any power outages or damage to any telecommunications networks, software failures, interruptions in the operation of electronic mail systems, Internet providers, payment systems, other lines, channels, and/or networks that are provided, offered, or serviced by third parties, etc.) that occur through no fault of the Administrator; in such cases, the Administrator shall not be responsible for any of a Customer’s possible damages or costs.
    3. 12.3. The Administrator shall not be responsible for:
      1. 12.3.1. a Customer’s lack of access to the software or hardware that ensure the Services’ operation or for any related damages and/or costs incurred by a Customer in such cases;
      2. 12.3.2. any consequences of inability to contact a Customer using the Contact details provided by such Customer, as well as for a Customer’s providing incorrect information in the System or a Customer’s failure to update such information;
      3. 12.3.3. a Customer’s damages and losses resulting from the impossibility of a Customer’s Identification;
      4. 12.3.4. any payment services provided to a Customer by any third parties;
      5. 12.3.5. a Customer’s losses resulting from a Customer’s failure to read the current version of the Terms and Conditions or the IPD.
      6. 12.3.6. In the event of the loss of the Authorization Details, the Services locking a profile, a Customer’s loss of the Password, Profile Lockdown, or other events that cannot be remedied without a Customer’s Identification, the Administrator shall have no responsibility to an Unidentified Customer for any possible damages and the impossibility of the use of a profile in the future. An Unidentified Customer can prove that they are the rightful holder of a profile by providing the code sent to email related to Customer’s profile.
    4. 12.4. The Administrator shall not be responsible for any damages and losses incurred by a Customer or any third parties as a result of:
      1. 12.4.1. Profile Lockdown;
      2. 12.4.2. impossibility of Transactions through the Services, regardless of the reasons for such impossibility;
      3. 12.4.3. incorrect execution of Orders to carry out Transactions;
      4. 12.4.4. issuing erroneous Orders;
      5. 12.4.5. a Customer’s violation of the established procedure for making Payments;
      6. 12.4.6. either Party’s compliance with the legislative or regulative requirements;
      7. 12.4.7. a Customer’s violation of these Terms and Conditions and/or the terms of any agreements entered into by a Customer pertaining to the use of the System, as well as the Administrator’s instructions and guidelines and/or generally accepted moral and ethical principles.
    5. 12.5. In any event, the Administrator’s responsibility to a Customer shall always be limited to the amount that does not exceed the amount of the Fees charged to this Customer for a period of previous 3 months.
    6. 12.6. The Administrator shall not be responsible for any indirect or consequential damages incurred by a Customer or any third parties, including any loss of profit, loss (forfeit, non-receipt, unsubstantiated spending) of revenue, contracts, customers, time, data, enterprise, or reputation.
    7. 12.7. A Customer shall protect the Administrator’s interests, repay any losses and pay compensation to the Administrator, and hold the Administrator and its affiliated parties harmless against any complaints, claims, expenses or costs (including any legal costs, fines and penalties) resulting from or pertaining to a Customer’s failure to comply with these Terms and Conditions, any applicable laws or regulations and/or use of the Services. This provision shall remain valid after the termination of the relations between the Parties.
    8. 12.8. If a completed Payment becomes, through a Customer’s fault, grounds for a payer’s submitting a complaint against the Administrator pertaining to protection against infringement of rights, the Administrator shall have the right to demand that a payee compensate the Administrator for any losses suffered as a result of the Administrator’s funds or other assets levied in favor of such payer.
    9. 12.9. The Administrator shall provide to Customers the Services on the ‘as is’ basis, in their current and existing form without any warranties.
    1. 13.1. During the Registration in the System, a Customer must provide to the Administrator accurate and valid information (hereinafter – the Contact Details) to be used for the purpose of communicating with and sending notifications to a Customer.
    2. 13.2. The appropriate method for informing a Customer of a Transaction made using a Customer’s profile is sending a notification to the email address provided by a Customer.
    3. 13.3. A Customer may contact the Administrator at any time by sending a message or by calling the Customer Service (during its business hours).
    4. 13.4. The Administrator may inform the Customer on important changes in the way that System operates by sending out email notifications as well as by posting news updates in the client area of the Services websites.
    1. 14.1. A Customer shall bear full responsibility for all the risks related to the use of the Internet during a Customer’s interaction with the Administrator (other Customers and/or third parties).
    2. 14.2. A Customer shall assume full responsibility for the security of its Authorization Details and for all the risks related to their loss (theft and/or compromise).
    3. 14.3. To ensure the security of a Customer’s profile and/or prevent its use for unauthorized or fraudulent purposes, the Administrator shall have the right to take the relevant measures in accordance with applicable laws, the Terms and Conditions, the IPD, including resorting to a Profile Lockdown
    4. 14.4. For other security provisions the Parties shall be responsible in the accordance with Privacy policy and statements of Terms and Conditions.
    1. 15.1. If necessary, the Administrator may unilaterally make amendments to these Terms and Conditions (including the Rates).
    2. 15.2. The updated version of the Terms and Conditions shall be published in the section of the Services website.
    3. 15.3. A Customer’s use of the System after any amendments come into force shall be considered as such Customer’s unconditional acceptance of such amendments.
    4. 15.4. The Administrator may unilaterally refuse to fulfill the provisions and requirements set forth in the Terms and Conditions pertaining to a specific Customer on condition that the Administrator notifies such Customer no later than three days in advance.
    1. 16.1. All Services shall be provided in accordance with the effective laws of Slovakia. If a Customer’s use of the System and Services contradicts the laws of this Customer’s jurisdiction, the Administrator recommends this Customer not to use the Services. A Customer shall bear the sole responsibility for its compliance with the laws of its jurisdiction and for any possible expenses and losses resulting from violating this requirement.
    1. 17.1. All disputes and disagreement arising in the process of the use of the Services based on the provisions of these Terms and Conditions shall be settled through negotiations.
    2. 17.2. The basis for negotiations shall be either Party’s submitting a written complaint to the other Party. All Complaints and claims shall be reviewed within thirty days of their receipt. If a dispute can not be resolved in accordance with the complaint procedure within the specified period of time, either Party may apply to a court in the Administrator’s country.
    1. 18.1. The Parties shall not be responsible for any delays in the performance or non-performance of the obligations, any expenses, including losses, and costs related to complaints by any third parties that may result from any force majeure circumstances. The Party experiencing the impact of any force majeure circumstances shall notify the other Party within 10 days after the commencement of such force majeure circumstances.
    2. 18.2. The provisions of paragraph 18.1. shall not limit or terminate a Customer’s obligations pertaining to making an returning Payments, as well as payment of any fines, penalties, Fees, commissions, returning any goods, or (not) performing any works or services.


AML policy means preventing criminals to use services of Interspin s.r.o. (Company identification number 48 038 105, Severovcov 7, 85110, Bratislava, Slovakia) with the aim of money laundering, terrorist financing or other criminal activities.

Money laundering is the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds.

The process of money laundering can be divided into three sequential stages:

  • Placement. At this stage funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the Company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing.
  • Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.
  • Integration. Funds get back into circulation as legitimate to purchase goods and services.

To prevent money laundering, Interspin s.r.o. neither accepts nor pays cash under any circumstances. The Company reserves the right to suspend any client's operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.

The Company reserves the right to suspend any customer's operation, that can be referred to as illegal or, may be related to money laundering in the opinion of the Company staff.

Company's procedures

Interspin s.r.o. will make sure that it is dealing with a real person or legal entity. Interspin s.r.o. also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities. The AML policy is being fulfilled within Interspin s.r.o. by means of the following:

  • know your customer policy and due diligence
  • monitoring of client activity
  • record keeping
  • payment limitations

Know Your Customer and Customer Due Diligence

Effective Customer Due Diligence measures are essential to the management of money laundering and terrorist financing risk. Customer Due Diligence means identifying the customer and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with customer and on an ongoing basis. The customer identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.

During registration process at Company’s site all individual customers provide following identification information:

  • Customers’ full name
  • Customers’ email
  • Also system fixes IP-addresses of current sessions

Therefore we adopt all the necessary measures to establish and verify the identity of our customers and beneficial owners in cases when Company buys cryptocurrencies from customers and we understand risks of these commodities could be collected in criminal ways.

In cases when Company sells cryprocurrencies to avoid fraud traffic and chargebacks Company requests next details in addition:

  • High resolution scanned copy or photo of pages of a passport or any other national ID, indicating family name and name(s), date and place of birth, passport number, issue and expiry dates, country of issue and Client’s signature.;
  • Photo of customer handling document from list above;

Monitoring of client activity

In addition to gathering information from the clients, Company continues monitoring of activities of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client's legitimate business or the usual client's transaction history known from client activity monitoring.

Company has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the Company's services by criminals.

Company constantly checks that its customers and their relevant persons have not been included in international blacklists. Company regularly monitors the lists – supplied by an external provider – containing the names of parties convicted of crimes relevant for AML/CFT purpose.

Relations with specific customers

Company applies enhanced measures in cases of increased ML/FT risk, persons who are or have been entrusted with prominent public functions (politically exposed persons or PEPs) and their close associates or parties in respect of which requests for information have been received in connection with enquiries by the authorities about offences relevant for AML/CFT purposes.

We refuse to execute transactions, which involve in any way parties included in national or international applicable blacklists (e.g. EU regulations or UN resolutions).

Record keeping

Company will keep all suspicious activity reports and any supporting documentation confidential. It will not inform anyone besides UCML or other regulatory authorities approved by UCML about suspicious activity report.

Payment limitations and retaintion procedures

To avoid suspicious activities there are limitations of amounts and number of transactions set by Company for payments to/from single account via single payment method:

Operation Per transaction Per day Per month
Payout (buy) $10 000 5 transactions $20 000 total, 20 transactions
Acquire (sell) $10 000 5 transactions $20 000 total, 20 transactions

Accounts/relations with shell banks and anonymous companies

Company considers any relations with shell banks to be prohibited. “Shell banks” mean banks that have no meaningful mind and management located within the country in which they are incorporated and licensed, and which are unaffiliated with a regulated financial group that is subject to effective consolidated supervision.

It means that Company doesn’t establish customer relations or carry out transactions with shell banks. Furthermore Company doesn’t entertain relations to trust agencies and companies, trusts, anonymous companies or companies controlled through bearer shares, headquartered in high-risk third countries.


All Company’s employees, managers and directors must be aware of this policy. Employees, managers and directors who are engaged in AML related duties must be suitably vetted. This includes a criminal check done at the time of employment and monitoring during employment. Any violation of this policy or an AML program must be reported in confidence to the Chief Executive Officer.

Employees who work in areas that are susceptible to money laundering or financing terrorism schemes must be trained in how to comply with this policy or the AML program. This includes knowing how to be alert to money laundering and terrorism financing risks and what to do once the risks are identified. Company regularly ensures that employees are trained to identify and report of transactions, which should be reported to government authorities.


Deposit Introduction

It is not necessary to deposit any funds into Customer’s account, in order to register with the Services.
For the start a Customer gets standard limits for unidentified users.
It’s important to note that full verification of identification is required to increase limits, in order for both deposits and withdrawals to be processed in full mode.

How to Make a Deposit

Transferring money is a simple four-step process, as follows:
  • Step 1 – Get to, enter amount of cryptocurrencies to be purchased and click on the ‘Get BTC’ or ‘Get ETH’ button at the top of the screen.
  • Step 2 – Use your username and password to sign into your trading account.
  • Step 3 – Input blockchain address to get Crypto assets.
  • Step 4 – Enter bankcard details and follow the on-screen instructions.

Deposit Amounts and Payment Methods

A Customer can credit using any of the following:
– Credit and Debit Cards – the Services accept MasterCard, Visa, Visa Electron and Maestro.
The Services are working to add more payment methods to those the Services accept all the time – please check back regularly or get in touch if preferred payment method is not yet listed.

Terms of Crypto assets delivery

The Services transfer Crypto assets immediately after Funds are received. Usually it gets up to 2 hours to get Crypto assets to Customer’s blockchain addresses.


Required verification procedure for withdrawal

In order to comply with applicable law, the Administrator is required to request additional documentation to verify the identity of our customers
The Administrator asks that all customers kindly read our terms & conditions, privacy policy and compliance obligations before using the Services.
Verification by received documents takes up to 3 business days.
The Administrator appreciates Customer’s cooperation in this important effort to fight fraudulent activity and identity theft.

How Long Do Withdrawals Take?

Upon receipt of a Crypto assets the Services send Funds immediately. It may take up to 3 business days for the payment to be processed and accounted by Customer’s bank. It depends on card eminent.

How To Request a Withdrawal?

Withdrawing funds with the Services is a simple four-step process, which is as follows:
  • Step 1 – Get to, enter amount of cryptocurrencies to be sold and bankcard details
  • Step 2 – click on the ‘Get Money’ button at the top of the screen.
  • Step 3 – Use your username and password to sign into your trading account.
  • Step 4 – Transfer Crypro assets to provided address.

Which Withdrawal Methods Are Accepted?

A Customer can withdraw using any of the following:
– Credit and Debit Cards – the Services accept MasterCard, Visa, Visa Electron and Maestro.

Fees and rates

The Services charge fees per transaction in a currency of Transaction in amounts of:
  • 100 RUB
  • 4 GBP
  • 4 EUR
  • $4
Rates displays in the main screen and are fixed for 20 minutes on order creation. If order is not funded within 20 minutes the Services transfer Crypto assets or Funds at current market rate.


Here are some situations when the Administrator — a Slovakia company Interspin s.r.o. — may need to refund, accept returns or cancel orders:
  • A Customer has not received Crypto assets he purchased
  • A Customer has not received Funds for Crypto assets he transferred
  • A Customer files a bankcard chargeback
  • A Customer requests to cancel ongoing order

A Customer has not received Crypto assets he purchased

Counterparties will work to reach mutually agreeable solution in regard to this transaction.
If Customer does not get Crypto assets for 72 (seventy two) hours since the Administrator received Funds, the Administrator takes an obligation to refund a Customer within 2 (two) business days after Customer’s request.

A Customer has not received Funds for Crypto assets he transferred

Counterparties will work to reach mutually agreeable solution in regard to this transaction.
If Customer does not get Funds for 72 (seventy two) hours since the Administrator received Crypto assets, the Administrator takes an obligation to transfer Crypto assets to a Customer in amount of received within 2 (two) business days after Customer’s request.

A Customer files a bankcard chargeback

For instance, a Customer is working directly with his bankcard companies when he files a chargeback.
A Customer can file chargebacks with their bankcard companies at any time, from one day after the transaction has taken place to months later. The Administrator is responsible for service chargebacks.
The final outcome of a chargeback request will be determined by the Customer’s financial institution.

A Customer requests to cancel ongoing order

There are several use cases:
  • Order created but not funded yet
Cancellation is instant on request and free of charge.
  • Crypto assets received but not paid yet
The Administrator charges cancellation fee in amount of 3% of received Crypto assets and blockchain network fee needed to perform back transfer.
In this case the Administrator cancels an Order instantly and transfers Crypto assets back to a Customer within 2 (two) business days after he got Customer’s request.
  • Funds received but Crypto assets not sent yet
The Administrator charges cancellation fee in amount of 3% of received Funds.
In this case the Administrator cancels an Order instantly and sends Funds back to a Customer within 2 (two) business days after he got Customer’s request.
  • Order is paid
There are no options of cancellation for paid orders.


Valuing Customers’ trust and understanding the importance of ensuring the confidentiality of Customers’ Personal Data, as well as that of the Informational Materials posted by Customers on the Services websites in the course of fulfilling the provisions of the Terms and Conditions, the Administrator puts into effect this Policy to define the order for performing operations involving the Parties’ Confidential Information when using the System’s Services.
Every Customer should be familiar with the terms of this Policy before starting to use the System's Services.
    1. 1.1. Cookie is a piece of Data that does not contain any Personal Data, which is created by the Website and stored on the Customer’s computer as one file or multiple files. If the Customer chooses to block a Cookie file, the Customer may experience difficulty or find it impossible to use the Services.
    2. 1.2. Informational Materials (Data) are any text, graphic, audio, video, and mixed-type materials of informational nature.
    3. 1.3. Confidential Information is any information that is not Public Data, which is considered confidential under the Parties’ agreement or in accordance with the applicable laws.
    4. 1.4. Confidentiality is accessibility of information solely to its owner, as well as any parties to which such information can and/or must be provided under law and/or under agreement with this party.
    5. 1.5. Public Data is any data (including Personal Data) to which the owner of such data provides access to an unlimited number of parties (including by means of publishing data on any website without restricting access to such data) or to which, in accordance with this Appendix and/or the effective laws, confidentiality requirements do not apply.
    6. 1.6. Personal Data is any information related, directly or indirectly, to a specific or identifiable individual person (the subject of personal data).
    7. 1.7. Receiving Party is the Party receiving Confidential Information.
    8. 1.8. Compromise of Confidential Information is one of the Parties’ actions or inaction resulting in the Confidential Information becoming known or available to third parties without the permission of the owner of such confidential information. The format of the information compromise (orally, in writing, via any technical devices, etc.) is immaterial.
    9. 1.9. Disclosing Party is a Member, in relation to the Confidential Information disclosed by the Administrator; and, it is the Administrator, in relation to the Confidential Information disclosed by a Member.
    10. 1.10. Disclosure of Confidential Information is transfer to any third party of any Confidential Information in compliance with the requirements of this Appendix, including leaking, stealing, losing, distorting, corrupting, destroying, modifying, copying, or blocking Confidential Information resulting from failure to comply or improper compliance with the terms of this Appendix by the Receiving Party.
    11. 1.11. The terms that are not defined in this section shall be used further in the text in the meanings as specified (in the order of priority) in bilateral agreements signed by the Parties and in the current version of the Terms and Conditions approved by the Administrator and all Appendixes thereto.
    1. 2.1. By using any part of the Services, the Customer gives the Administrator the right to receive, store, process, and use the Customer’s Personal Data and other Informational Materials in compliance with the terms of this Appendix.
    2. 2.2. This Appendix does not apply to, nor is the Administrator responsible for, any methods of receiving, storing, processing, using, and disclosing the Customer’s Personal Data and other Informational Materials by external companies and organizations that are not owned or managed by the Administrator and by individuals that are not the Administrator’s employees, even though the Customer may obtain access to such parties’ and persons’ websites, software and/or GWS via the Services websites.
    3. 2.3. The main purpose of receiving, storing, processing, and using the Customer’s Personal Data, Public Data, and other data is to protect the Customer’s interests, as well as to improve the quality of the personalized and general services provided by the Administrator to the Customer.
    4. 2.4. This Policy is not an independent document and serves only as an addition to the Terms and Conditions; it does not supersede or nullify any of the provisions included in the main text of the Terms and Conditions.
    5. 2.5. The provisions contained in this document and the term ‘Confidential Information’ shall not apply to the information that:
      1. 2.5.1. was, is or is made available to the Receiving Party on the non-confidential basis from a party that, to the Receiving Party’s knowledge, is not bound by any confidentiality agreement with the other Party or by any other restriction related to disclosing confidential information to the Receiving Party, or
      2. 2.5.2. was in lawful possession of the Receiving Party prior to the other Party’s disclosing it as Confidential Information, or
      3. 2.5.3. is developed by or for the Receiving Party;
      4. 2.5.4. is not in any way protected by the Disclosing Party to ensure confidentiality;
      5. 2.5.5. is made available due to the requirements of the effective laws and regulations;
      6. 2.5.6. is publicly available and known due to the Disclosing Party’s actions and decisions;
      7. 2.5.7. was available to the Receiving Party on the non-confidential basis prior to the other Party’s disclosing such information, or
      8. 2.5.8. has to be disclosed in accordance with the effective laws or under orders issued by the governmental agencies or any other competent authorities.
    1. 3.1. The Administrator can gather and process the following information about the Customer:
      • Customer’s full first name and last name, occupation, address, email address, phone number, date of birth, as well as the documents confirming the Customer’s identity and residence address, to be provided on our request;
      • information related to the Transactions performed by the Customer through the System with the use of the Services and to the execution of the Customer’s Orders;
    2. 3.2. For the purpose of fulfilling mandatory legal obligations related to anti-fraud and anti-money laundering requirements, the Administrator will receive information related to the Customer from third parties, including information about the Customer’s financial history, any decisions of local district courts, bankruptcy, information provided by credit bureaus and anti-fraud agencies, when the Customer creates profile or at any other time when the Administrator may deem it necessary to prevent fraud and minimize financial risks.
    3. 3.3. During the Customer’s Registration in the System and when the Customer is creating profile, the Customer has to provide their Authorization Data, as well as other details (mandatory or optional). After the Customer has created his profile, the Administrator is able to identify the Customer every time this Customer uses the System and visits the Services websites.
    4. 3.4. The Administrator may install cookies to Customers’ computers (unless the Customer purposely restricts this option in their browser), as well as receive, store, process, and use the information created through cookies.
    5. 3.5. When the Customer visits the Services websites, the Administrator automatically stores, processes, and uses the Customer’s data that is not their Personal Data, for example: Customer’s IP address, Customer’s location identifiable with their IP address, Customer’s computer’s technical parameters, presence or absence of specific software on the Customer’s computer, such software’s settings, cookies, as well as statistics on the Customer’s activities.
    6. 3.6. Besides visiting the Services websites, the Customer also provides information to the Administrator when using the System (if possible) via applications for mobile devices, social media applications, payment terminals, etc., contacting and submitting requests by phone, mail, email, or via other means of communication; the Administrator also receives information about the Customer from other sources when verifying the information previously provided by the Customer.
    7. 3.7. By all means the Administrator does not store Customer’s bankcard details anywhere within the Services.


The Administrator shall use the available information related to Customers for the following purposes:
  • rendering services related to Customers’ profiles and providing services requested by Customers;
  • executing Customers’ Orders related to Money Transfers and receiving Payments, as well as making Transactions using the Services;
  • notifying Customers of changes in the Services, the System, the Terms and Conditions, the Software, etc.;
  • fulfilling the requirements of the applicable laws and regulations, in particular, those related to anti-money laundering laws and KYC (Know Your Customer) procedures;
  • verifying the Customer’s financial status, identity, and sol;
  • carrying out verification procedures to prevent fraud and money laundering;
  • providing services to Customers, including responding to Customers’ questions, requests, comments, and Complaints;
  • increasing the security of the Services;
  • providing the Services websites content (including its interactive features) in a way that is most efficient for Customers and their computers;
  • providing to Customers products and services requested, or products and services that the Administrator believes may interest Customers;
  • providing assistance in the development, provision, and improvement of the System’s Services, as well as providing the Services websites content and informing Customers;
  • carrying out the Administrator’s internal procedures and processes, such as audits, analytical data processing, quality assessment as to the Services provided, etc.
    1. 5.1. The Administrator shall not provide any Personal Data to any third parties for commercial purposes without the permission of the Customer to whom this information is related.
    2. 5.2. Personal Data can be disclosed to such third parties in the following circumstances:
      • disclosing information upon receiving the permission of the Customer to whom this information is related;
      • disclosing information on substantiated requests from the government agencies with the authority to obtain such information;
      • disclosing information to agents and third parties acting under an agreement with the Administrator to fulfill obligations to the Customer (including, but not limited to, acquirers, payment card issuing banks, international card systems, telecommunication service providers, billing companies and delivery companies, the Administrator’s affiliated parties, etc.) and on the following conditions: 1) they are aware of the confidential nature of such information; 2) they take adequate measures to protect confidential information from unauthorized access and use;
      • disclosing information to the Administrator’s potential creditors, investors, acquirers, Partners, shareholders, and auditors;
      • disclosing information to companies that may offer their products and services to Customers;
      • disclosing information in the course of information exchange with other companies and organizations for the purposes of anti-fraud protection and financial risk minimization;
      • disclosing information when the Administrator believes that the Customer violates the terms of this Appendix and/or other agreements and contracts between the Administrator and the Customer, and/or the Administrator’s internal regulations and rules; or, when the Administrator deems such information disclosure necessary to investigate, prevent, or take measures against unlawful activities, suspected fraudulent activities, potential threats to any person’s physical security, violations of the Terms and Conditions or any bilateral agreements, or if it is required by law;
      • disclosing information in other circumstances in accordance with the provisions of these Terms and Conditions and the applicable laws.
    3. 5.3. Unless otherwise agreed upon in writing with a specific Customer, the Administrator can publicly disclose the fact of the existence of the Administrator’s business relationship with this Customer.
    4. 5.4. The Administrator reserves the right to disclose confidential information when it is required by the business conduct practices.
    5. 5.5. No provision contained in this Appendix shall restrict either Party’s right to disclose any Confidential Information in accordance with any court order or decision, any other legitimate obligation or requirement under the effective laws and regulations if such information disclosure is mandatory and on the condition that, if possible, the other Party is notified of such information disclosure in advance.
    6. 5.6. All Confidential Information shall remain the property of the Party disclosing such information; no rights or licenses are granted with regard to such Confidential Information, unless otherwise specifically stipulated in this Appendix.
    7. 5.7. Either Party shall return to the other Party and/or securely destroy all Confidential Information (including any part of it that may be undergoing processing, analysis, or translation, including also all copies, written notes, drawings, charts, computer programs in any and all formats, on any type of a data storage device) on the other Party’s written request, unless such documents have to be stored under the effective laws and regulations, and, if required, shall confirm in writing, with the authorized person’s signature, that such Confidential Information was duly returned or securely destroyed.
    8. 5.8. The Customer has the right to request that the Administrator restrict third parties’ access to the Customer’s Personal Data for marketing purposes, provided that it does not contradict the applicable laws and the Terms and Conditions, by sending a relevant written request to the Administrator using the Administrator’s Contact Details.
    1. 6.1. By providing their Personal Data during the Registration in the System, the Customer agrees to data processing, with or without the use of automation technology and/or devices, in particular, information gathering, storage, transfer to third parties, and use by the Administrator for the purpose of providing the Services to the Customer and for other purposes specified in the Terms and Conditions.
    2. 6.2. If the Customer does not wish for their Personal Data to be processed, the Customer should contact the Administrator using the Administrator’s Contact Details or the feedback form on the Services websites. In this case, all the information received from the Customer will be deleted from the Administrator’s client database, and the Customer will not be able to use the Services.
    1. 7.1. For the purpose of exercising Customers’ rights and the Administrator’s proper fulfillment of its obligations under the Terms and Conditions and the agreements signed by the Parties, the Administrator may review Customers’ Informational Materials (for the purpose of timely resolution of technical problems and prevention of unlawful activities that violate the rights of either Party, other Customers, etc.).
    2. 7.2. The Administrator provides limited access to Customers’ information only to the employees that, in the Administrator’s opinion, need to use such information to provide services to the Customers or perform their professional duties.
    3. 7.3. The Customer has the right to request, edit, or delete their Personal Data stored by the Administrator and/or on the Services websites. The Customer may independently edit, change, or delete their Personal Data using the relevant features of the Services websites and their profiles.
    4. 7.4. The applicable laws on personal data protection give the Customer the right of access to any information related to the Customer. Any request for access to information may result in charges to cover any and all expenses involved in providing the Customer with detailed information stored by the Administrator and/or third parties.
    1. 8.1. A publicly accessible page is any page of the Services websites to which unlimited access is open to any party and which can be indexed by search engine systems.
    2. 8.2. The Administrator allows the Customers to send messages and exchange Data on publicly accessible pages.
    3. 8.3. The Customer should exercise caution and common sense when disclosing their information that allows
    4. identifying the Customer on publicly accessible pages. It is important to remember that this information may remain on publicly accessible pages of the Services websites for an indefinite period of time. Besides, depending on a specific Service, other Customers may also view such information.
    5. 8.4. The Customer is solely responsible for any information that the Customer discloses and distributes on publicly accessible pages.
    6. 8.5. If the Customer has any concerns regarding information that allows identifying the Customer which the Customer provided on any publicly accessible page, the Customer cannot delete or edit such information; in such cases, the Customer should contact the Customer Support Service.
    1. 9.1. The Parties acknowledge and confirm that they shall ensure confidentiality of any and all information received in the course of fulfilling obligations under the Terms and Conditions, with the exception of the cases explicitly provided for in the Terms and Conditions and the Parties’ other agreements.
    2. 9.2. The Customer violating the obligations pertaining to information confidentiality shall cover all expenses and losses (including loss of profits) incurred by any third parties and/or the Administrator as a result of such actions of the part of this Customer.
    3. 9.3. The confidentiality terms are included in these Terms and Conditions and accepted by the Customer when the Customer confirms accepting the Terms and Conditions.
    4. 9.4. The Parties shall NOT disclose information pertaining to the System’s operating conditions, as well as other information received by the Parties in the course of fulfilling the obligations under the Terms and Conditions, with the exception of the cases when either Party is obligated to disclose such information in accordance with the applicable laws.
    5. 9.5. The Parties shall notify each other within 1 (one) business day of the occurrence or knowledge that they may have about any disclosure or threat of disclosure, unlawful obtainment or unlawful use of the Confidential Information by any third parties.
    6. 9.6. The Parties shall not unilaterally suspend or terminate measures aimed at protecting confidential information as specified in these Terms and Conditions, including in cases of their reorganization (merger, acquisition, division, separation, transformation, or any other type of the legal status change) or (when stipulated by the law) liquidation.
    7. 9.7. Disclosing Confidential Information on legally valid requests from law enforcement agencies or other competent government authorities and/or officials in accordance with procedures specified by the applicable laws shall not constitute a violation of the Parties’ confidentiality obligations.
    8. 9.8. In the event of disclosing Confidential Information to the authorities and/or parties stated above, the Party disclosing Confidential Information shall notify the owner of such Confidential Information in writing of the fact of information disclosure, as well as of the content of such information and the name of the agency or authority to which such Confidential Information was disclosed within 1 (one) business day after disclosing Confidential Information.
    9. 9.9. As stipulated in other sections of these Terms and Conditions, Customers are responsible for ensuring confidentiality of their Authentication Data. The Administrator is not responsible for transactions made as a result of improper storage or loss of information on the part of the Customer.
    10. 9.10. The Services will use SSL-secured channels to transmit data to Customers.
    1. 10.1. The Administrator has the right to store the Customer’s Personal Data and other data for as long as it is necessary to achieve the objective specified in this Appendix, or for a period of time required by the applicable laws, or until the Customer chooses to delete such data.
    2. 10.2. The Customer is responsible for providing accurate and true information, as well as for updating their information provided previously in the event of any changes in the information.
    3. 10.3. The Customer allows the Administrator to give permission to other parties with which the Administrator signs relevant agreements to receive, store, and process information about the Customer (except the Customer’s Personal Data and Informational Materials), such as the Customer’s IP address, cookies, and statistics on the Customer’s activities, for the purpose of improving the quality of the services provided by such parties and providing promotional information.
    4. 10.4. The Customer agrees that the confidentiality of any information transferred via the Internet is not guaranteed; if any third party gains access to such information outside the technical communication means area managed by the Administrator, the latter shall bear no responsibility for any possible damages caused by such access to information.
    5. 10.5. If, in the course of using the Services, any information becomes available to the Customer regarding the Administrator and/or any third parties, which, in accordance with the applicable laws, constitutes confidential information and/or trade secrets, the Customer shall not store, use, or distribute such information.
    6. 10.6. When a Customer clicks links on the Services websites, he may be redirected to third party sites. The Administrator does not assume any responsibility for content of third party Sites and for the information third party Sites collect from you, including the ways these third party Sites process, store, and manage such information. Third party service providers may have their own Privacy Policies. The Administrator strongly recommends to familiarise with these Policies to understand how personal information is handled. Once a Customer leaves the Services website, the terms of this Privacy Policy no longer define how his personal