Privacy Policy

We, Upside Ventures Pte. Ltd, are registered at 7500A Beach Road #05-319 Singapore 199591 (referred to as "Company"/"us"/"we"/"our"). We value your trust and respect your privacy. This privacy policy ("Policy") provides the practices and policies adopted by us for collecting, storing, retrieving, sharing or using your personal information.


This Policy is a part of the terms and conditions (Terms of Use) regarding use of the services ("Services") availed by you through our website ("Website") and/or our mobile application Qoinup ("Application") whether existing now or in the future (the Website and Application will be collectively referred to as the "Platforms"). The Terms of Use are available at for your reference. This Policy is applicable to all personal information that is disclosed by you and/or collected by the Company at the time of registration on the Platforms, while accessing the Platforms and during the course of availing the Services through the Platforms. You are encouraged to review this Policy and the Terms of Use, before using our Platforms or providing us any information, to make sure that you understand how your personal information will be used. By using our Platforms, it shall be deemed that you are expressly consenting to be bound by the terms and conditions described in this Policy.


We reserve the right to modify or review the provisions in this Policy without prior notice. You are requested to review this Policy periodically and remain informed of any changes. Your continued use of our Platforms or Services following any change to the Policy will be deemed to be acceptance of the revised terms of the Policy.




You may be required to provide us or we may collect your personal information including sensitive personal information during the course of or in connection with provision of Services through the Platforms, for reporting and resolving a grievance or for troubleshooting, while your are accessing the Platform, for participating in optional surveys, promotions or offers related to our the Platform and for advertisements.


Personal information means and includes all information that can be linked to a specific individual or to identify any individual, such as name, address, mailing address, telephone number, email address, information regarding your transactions and trading, and financial information such as bank account or credit/debit card details, fund transfer requests or other payment instruction details, digital assets wallets held on third party exchanges/websites, information or documents relating to customer verification, information about your mobile phone, permanent account number, Aadhaar details, account log-in information, information requested by us to detect and protect us against frauds, suspicious or illegal transactions, money laundering and other similar activity, information pertaining to your IP address and the device or computer used by you for the purpose and any details that may have been voluntarily provided by the user while accessing the Platforms or in connection with the Services.


The Company may collect, disclose, process, transfer, use your personal information for: (a) in relation to or in connection with provision of the Services, (b) for processing payments in relation to the Services, (c) for sending periodic emails, updates, or communication in relation to the Services, (d) for data analysis, testing, internal operations, research, statistical and survey purposes in relation to the Platforms and the Services, (e) for providing advertisements, recommendations, promotions, advertisements and offers, (f) for customizing your experience on the Platforms, (g) for updating and maintaining a back up of our records, (h) for complying with laws of applicable jurisdictions and directions of governmental authorities, regulatory authorities and law enforcement, (i) for keeping the Platform secure and mitigating risks related to suspicious or illegal transactions, money laundering and other similar activity, (j) for preventing potentially prohibited or illegal activities, (k) for undertaking a verification of your identity with third party electronic identification providers, and (l) for allowing you to participate in interactive features of our Services and Platforms. We may also require additional information, from time to time, about you for performing on-going due diligence (as may be required under laws of applicable jurisdiction) based on your risk assessment, transaction value, etc.


If a User provides incomplete or incorrect personal information, the User will be permitted to remedy such information and the Company will not be held responsible for such incorrectness or incompleteness of the personal information provided by the User or the consequences arising due to provision of incomplete or incorrect personal information. The User will be permitted to change any personal information disclosed earlier. Further, the Company and its affiliates will be indemnified by the User against any losses, actions, costs or consequences arising due to furnishing of incorrect or incomplete personal information or corrections made by such User.


If you do not agree to the Terms and Conditions or this Policy, then please do not provide us any information. If a User does not wish to provide any information, then such User may not be entitled to avail the Services through the Platforms.




We do not sell, trade, or rent Users’ personal information to others. We do not share any personal information related to a User with any third party for uses like marketing and promotional purpose. Your stored personal information is available only to you (for editing purposes), our authorized employees, customer service personnel, verification department and to administrators and consultants, and selected third party entities including but not limited to service providers who authenticate know your customer (KYC) and details as furnished/provided by the Users to the Company, commercial banks which provide banking facilities to the Company, payment processing companies and other digital asset exchanges or websites as the Company may require for providing the Services etc. You acknowledge that your personal information may be processed, stored and processed outside India.


You also agree that the Company shall be free to transfer/disclose any information shared by you with Company, to a related party or to an affiliate or to any entity controlled by the promoters of the Company. We may also transfer your information during sale of assets or business to another company, de-merger into another company, while getting acquired by another company or getting merged with another company.


In addition to the above, the Company may also be required to share your information with governmental authorities, regulatory authorities and law enforcement under laws of applicable jurisdictions or pursuant to an order of a court, regulatory authority or governmental authority or similar proceedings.




When you access our platform we may also collect non-personal information ("General Information") such as browser name, the type of computer and technical information about the User's means of connection to our Platforms, such as the operating system and the internet service providers utilized, anonymous site statistical data and other similar information.


We reserve the right to use General Information collected by us for any purpose whatsoever including statistical analysis, marketing and promotion. Consequently, we may share such General Information or any analysis with any person, at our sole discretion.




Our Platforms may contain links to other websites that may collect personally identifiable information about you. We are not responsible for the privacy practices or content of any website for which links may be provided on the Platforms. You are encouraged to exercise caution and review the privacy policies applicable to such websites.




When a User visits our Platforms, one or more cookies shall be sent to computer or the device being used by the User. Limited personal information may be collected through cookies and tracking technology. Further, if any personal information has been provided previously, cookies may be tied to such information. The cookies are used for improving the quality of the Platforms provided by the Company, for providing promotions, advertisements and offers, for storing User preferences, providing the Services, improving search results and tracking User trends. The User has the option of disabling cookies via their browser preferences. However, Users are advised and made aware that if they disable cookies on their browser, some parts of Platforms may not function as effectively.




The Company may use action tags (also called pixel tags, clear GIF, or beacons) to identify websites/pages visited and interacted with by the User. Action tags may collect and transmit this data in a manner that identifies the User if User has registered with the Platforms, or is logged into the Platforms. The Company also uses action tags in emails, to determine whether an email has been opened or whether it has been forwarded to a third party.




This Policy is not applicable to any information voluntarily disclosed by you to other Users of our Platforms or third parties, except as provided in this Policy. You are advised not to provide your personal information to other Users on the Platforms. The Company does not ask for the User’s passwords through unsolicited emails or telephone calls.




The Company has taken all reasonable measures and precautions to keep the personal information safe and secure and to prevent any unauthorized access to or misuse of the same.


The Company is not liable to any User for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused to any User due to unauthorized access or misuse of personal information by any third party (beyond the control of the Company). The Company has a comprehensive and documented information security programme that contains managerial, technical, operational and physical security control measures.




The Company may, at its sole discretion, retain any information and/or data provided by you for as long as your account is active, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, in accordance with our Terms of Use and KYC and AML Policy and/or as necessitated under applicable law. The retention period may be extended in accordance with the applicable law.


You agree that the Company does not make any warranties and shall not be liable for non-availability or non-retention of any information and/or data provided by you beyond the deletion of your account.




If you wish to report a violation of this Policy or you have any questions or need assistance, please contact our grievance officer:


Name: Siddhesh Kadam



Cancellation/Refund Policy


Qoinup, under no circumstance, entertains the refund or cancellation of a successfully fulfilled order. Once a buyer order is fully or partially matched, the amount transferred to the seller(s) and these transactions cannot be reversed.


Qoinup shall be entitled to retain/deduct the amounts due to it from the user and transfer or refund the balance lying in the User Account, except when it is unable to do so in compliance with applicable laws. Transfers shall be to any other cryptocurrency wallet specified by User and refund shall be in INR.



KYC and AML Policy


This know your customer and anti money laundering policy is a part of the Terms of Use. All terms of the Terms of Use are included in this policy by reference.




  1. The User will provide the following information/documents for verification of the User Account. Information/documents for verification may include:


  1. Name as in the permanent account number ("PAN") card or bank account;
  2. Self attested copy of PAN card;
  3. Self attested copy of Aadhaar card/valid driver’s license/passport;
  4. Duly certified copy of incorporation documents and constitutional documents;
  5. Duly certified resolutions authorizing the entity to transact on the Platforms and identification documents containing identification and address details of the individual authorised to transact;
  6. Valid phone number;
  7. Valid email address;
  8. Details of bank account linked to the Fiat Wallet including the account number; and
  9. Any additional information/documents as may be required by the Company for User verification or re-verification from time to time or as may be required by law enforcement, governmental or judicial authorities.


  1. The Company may, at its sole discretion activate the User Account upon verification of the information provided by the User. For the purposes of verification of any User’s identity, the Company may rely on appropriate and licensed third party service providers to authenticate the documents and other incidental information provided by the User.


  1. In case of any change in contact details, the User will update the details on the Platforms and submit documentary evidence for re-verification within 7 days of such change.


  1. The User permits the Company to retain the above documents and information as long as the Company deems necessary. The Company will be entitled to retain the above details and documents even for of those Users whose registration has been rejected by the Company.




  1. The Company may regularly monitor and keep records of all transactions executed and/or attempted to be executed on the Platforms both manually and through use of software based algorithms in order to promptly identify and highlight certain kinds of transactions. The Company may, from time to time, undertake necessary investigation in order to identify and examine transactions inconsistent with any User’s risk profile, as may be determined by the Company, sophistication, and expected usage patterns. The Company may share, from time to time, this monitoring information regarding identified transactions, identification information of such Users, or any other information mandated under the applicable law with the appropriate law enforcement, governmental or judicial authorities.


  1. In order to improve the integrity and transparency of transactions on the Platforms, the User is encouraged to report any information that the User is privy to regarding any Suspicious Transactions or transactions which the User believes are dubious in nature, to our compliance officers by writing to them at "Suspicious Transactions" refers to the following activities, whether attempted or executed: (a) terrorist financing: transactions which to a person acting in good faith appear to be any funds collected to be used, in full or in part, by any terrorist or related organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts; (b) unusually complex: transactions which to a person acting in good faith appear to have been structured in a manner of unusual or unjustified complexity; (c) malafide purpose: transactions which to a person acting in good faith appear to have not been transacted for bonafide purpose or have a sound economic rationale; or (d) money laundering: transactions which to a person acting in good faith appear to involve proceeds of any offence listed in the schedule to the Prevention of Money Laundering Act, 2002.


  1. Notwithstanding anything contained in this policy or the Terms of Use, amounts lying in any User Account suspected of being associated with any activity that contravenes any applicable law will not be released in favour of any User until an appropriate order is received from a governmental, regulatory, judicial or quasi-judicial body that is competent to pass such an order.


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Copyright 2017, All Rights Reserved


Copyright 2017, All Rights Reserved