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AML and KYC Policy

In terms of law, money laundering refers to legalising the proceeds of crime, i.e. actions that conceal the source of funds in order to make their nature appear lawful.

Anti-money laundering (AML) Policy incorporates a complex of measures aimed at prevention of use of the financial system of the country or any specific financial institution for money laundering or terrorist financing. Such measures and instruments are worked out and implemented by international and national institutions, banking and business community.

Financial institutions employ different approaches to anti-money laundering that help preventing cases of laundering of the proceeds of crime and terrorist financing. Under its AML Policy, BitSugar in its operations implements the specific measures listed below.

Our approach

Our Company's organisational structure includes the Head of Risk and Compliance, who is in charge of overseeing compliance of the Company's activities with its internal policies and procedures and relevant AML regulatory enactments.

We trust highly competent personnel of our Company, who works in close contact with our Clients. As part of Internal Regulatory documents, the Company has a Know Your Customer (KYC) Policy in place aimed at full understanding and knowledge of our Clients and Business partners.

The AML Policy of the Company consists, but is not limited to, the following pillars of KYC:

    Ongoing compliance with the requirements introduced by the national and international laws, regulations and sanctions,

    Implementation of the risk-based "KYC" and "Client Monitoring" principles,

    Determination and reporting of suspicious transactions,

    Preservation of reputation and brand value of Immofreund towards national and international authorities.


We improve our AML policy and procedures continuously and they comply with the requirements of Austria law. We make considerable investments in this process and ensure continuous training of our personnel in this area. We understand that anti-money laundering and combating terrorist financing is a continuous process that requires constant attention and ability to monitor unlawful financial schemes.

We comply with the legal requirements of the Republic of Austria for the prevention of money laundering and terrorist financing. 

 We have a strict set of rules in place in order to comply with the AML regulations of the republic of Austria and the International and EU standards:


    All existing Clients are subject to the AML Client monitoring process,

    Identity and proof of address documents and transaction records are maintained for at least five years after the Business relationship has been terminated and will be submitted to regulators accordingly, as required, without prior notification to registered users,

    immofreund may at any time suspend the operation of the Client's account, without liability and without disclosing a reason. The Client is always notified in this case after the Business relationship has been terminated,

    Prospective Clients will be required to verify their identity in line with the Company's KYC policy. This includes submission of both government ID and proof of address. Valid ID includes a passport, national card, or driving license. Valid proof of address includes utility and rates bills not older than 3-6 months, depending on the Client's Risk profile. Other forms of ID will not be accepted.


Accordingly, immofreund performs necessary controls and takes additional measures with respect to:


    Identification and verification of the valid identity and address details of (potential) customers, acceptable to the legal authorities, before establishing a Business relationship and during the course of a continuous Business relation,

    Consistency of the income levels of Clients and the financial services they perform/request with their business, the general course of action and sources of income of the Client type, in which they are included,

    Possibility of the Clients being included on national/international sanctions lists.


immofreund will not be accept the following Persons as Clients under any circumstances:


    Those who cannot provide all the required Client Identification Documents in due course and proper form,

    Those listed under Office of Foreign Assets Control's Special Designated Nationals List (OFAC SDN) watch list and/or United Nation's "Consolidated List",

    Anonymous Clients or those who use fictitious names,

    Those who hold businesses that, due to the nature of the business make it impossible to verify its legitimacy, or hold funds inconsistent with their financial status,

    Those who are suspects, based on reliable information, of being involved in any sort of criminal activities, mainly related to money laundering, drug trafficking, terrorism and organized crime;

    Bearer share companies,

    Shell companies,

    Those who raise any legitimate suspicions by the Company's staff and/or the Head of Compliance. 


Governmental (OFAC) restrictions, international sanctions and our Internal Policies prohibit us from opening accounts for individuals from the following countries: Afghanistan, Algeria, Angola, Burundi, Central African Republic, Congo Republic, Democratic Republic of Congo, Ecuador, Eritrea, Ethiopia, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Kenya, Lebanon, Liberia, Libya, Myanmar, Nigeria, North Korea, Serbia, Somalia, South Sudan, Sudan, Syria, Trinidad and Tobago, Tunisia, USA, Vanuatu, Venezuela, Western Sahara, Yemen, and Zimbabwe, as well as other individuals specifically sanctioned. 


Privacy Policy

"Immofreund" Immobilienverwertungsges.m.b.H. has created this privacy statement in order to demonstrate our commitment to privacy to our customers and users of this website and the services offered by "Immofreund". This Privacy Policy governs the manner in which "Immofreund". ("Immofreund") uses, maintains and discloses information collected from its customers and users of its website. This website is not directed at children under 13 years of age.

Information We Collect

"Immofreund" may request or collect personal information from online users in a variety of ways, including through online forms for requesting information or ordering products and services, and other instances where users are invited to volunteer such information. Some of the data we collect is information that identifies you personally, and may include your name, e-mail address, postal address, telephone and telefax numbers, payment account information, and other information necessary to provide the services requested. "Immofreund" also maintains a record of contacts for customer or technical support.


"Immofreund" may also collect information about how users access the website through log files and the use of cookies, and through third party services such as Mouseflow and Google Analytics. Such information may include standard information from your web browser (such as browser type and language), your Internet Protocol (“IP”) address, and the actions you take on Immofreund's Web sites (such as the web pages viewed and the links clicked). To opt out of Mouseflow please visit www.mouseflow.com/opt-out/.


What are Cookies?

A cookie is a piece of data stored on the user's computer tied to information about the user. We may use both session ID cookies and persistent cookies. For session ID cookies, once you close your browser or log out, the cookie terminates and is erased. A persistent cookie is a small text file stored on your computer's hard drive for an extended period of time. Your browser's help file contains information and instructions for removing persistent cookies. Session ID cookies may be used by "Immofreund" to track user preferences while the user is visiting the website. They also help to minimize load times and save on server processing. Persistent cookies may be used by "Immofreund" to store whether, for example, you want your password remembered or not, and other information. Cookies used on the "Immofreund" website do not contain personally identifiable information.


Log Files

Like most standard websites, we use log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. However, none of the information stored in our log files, including but not limited to IP addresses, is linked to personally identifiable information.


How we Use and Share this information

"Immofreund" may use and share your personal information in order to provide the services requested. For example, your information may be provided to the domain registrar in order to process domain registrations, or with the relevant certificate authority to order an SSL certificate on your behalf. We will also share your information to the extent necessary to comply with ICANN's rules, regulations, and policies, and if your domains are not set to private registration, the publicly available WHOIS registry will contain personal information, including but not limited to your title, first name, surname, domain name, e-mail address, country, and phone number.

"Immofreund" is required to supply some of your personal data in order to request an SSL certificate from the certificate authority. By submitting a request for an SSL certificate order or renewal through "Immofreund", you consent to "Immofreund" releasing all required personal information to the certificate authority in order to fulfill the request and you acknowledge and understand that "Immofreund" acts only as an intermediary between the customer and the certificate authority, in order to facilitate the order or renewal of the certificate. "Immofreund" has no influence on the outcome of an SSL certificate request and cannot guarantee that any request for an SSL certificate order or renewal will be granted.

"Immofreund" may also use the personally identifiable information collected by "Immofreund" to contact customers regarding products and services offered by "Immofreund" and, to the extent the user has agreed to it, by its trusted affiliates, independent contractors and business partners. We may also use this information and share it with trusted third parties for research purposes regarding the effectiveness of our website services, marketing, advertising and sales efforts, including, without limitation, for purposes of customer reviews (such as for the utilization of programs like Google Seller Ratings). "Immofreund" will not sell or otherwise share this information with a third party for a third party\x92s marketing purposes, unless you specifically authorize such information sharing.

"Immofreund" may also disclose aggregate, anonymous data based on information collected from users to investors and potential partners. In such cases, only statistical information will be disclosed and personally identifiable data will be kept strictly confidential. In case "Immofreund" is sold, the information collected from users may be transferred to the new owners.

"Immofreund" may from time to time engage third parties, including its own subsidiaries and affiliated companies, to preserve, analyze or otherwise store or manipulate data received by "Immofreund" from its customers. In all such cases, third party service providers will be required to treat all such data with the same degree of care as "Immofreund" and they will be prohibited from disclosing such data to any other person or party, except as otherwise provided for in this Privacy Policy.

"Immofreund" uses payment account information solely to check the financial qualifications of prospective Customers and to collect payment for the services provided by "Immofreund".


Google Analytics

We use “Google Analytics” to collect information about use of this Site, such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site.  Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information.

Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site.  This cookie cannot be used by anyone but Google, Inc.  The information generated by the cookie will be transmitted to and stored by Google on servers in the United States.

We use the information received from Google Analytics only to improve services on this Site.  We do not combine the information collected through the use of Google Analytics with personally identifiable information.

Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Privacy Policy.  You can prevent Google Analytics from recognizing you on return visits to this Site by disabling the Google Analytics cookie on your browser (https://tools.google.com/dlpage/gaoptout/.)


Special Offers and Updates

Our customers and users will occasionally receive newsletters or e-mails with information on products, services, or special offers. Out of respect for the privacy of our users, "Immofreund" gives them the opportunity to opt-out from receiving these types of communications.


Service Announcements

On rare occasions, it is necessary to send out a strictly service-related announcement, if, for instance, our service is temporarily suspended for maintenance. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.


Legally-Required Disclosures

Though we make every effort to preserve your privacy, we may need to disclose personal information when required by law, or if "Immofreund" believes that disclosure is necessary to protect "Immofreund"'s rights and/or to comply with a judicial proceeding, court order, subpoena or other legal process. "Immofreund" may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary. Please see our Subpoena Policy for more information.


Third Party Websites

The "Immofreund" website contains links to other sites. Please be aware that "Immofreund" is not responsible for the privacy practices of such other sites or of its customers. We encourage you to read the privacy statements of each and every website that collects personally identifiable information. The "Immofreund" Privacy Policy as described herein applies solely to information collected by "Immofreund".


Maintenance of Information

The information provided to "Immofreund" is saved indefinitely and may be stored on one or more databases directly or indirectly maintained by "Immofreund". "Immofreund" employs industry-standard security measures to protect the confidentiality of the information. While we cannot guarantee that loss, misuse or alteration of data will not occur, we make every effort to prevent such occurrences. Any other particularly sensitive information, such as credit card numbers collected for commercial transactions, is encrypted prior to transmission by you to "Immofreund". Your use of the "Immofreund" services may result in the transfer of information internationally, including into or outside of the United States. By visiting accessing this site or using the "Immofreund" services you consent to such transfers.

While "Immofreund" uses industry-standard measures to protect your information, no security measures are foolproof, and it is impossible to guarantee complete security of data sent or maintained via the internet.


Your Responsibility

You are responsible for the security of your Customer ID and passwords. Make sure you keep them in a safe place and do not share them with others. Always remember to log out after your session ends to ensure that others cannot access your private personal information. You should take this precaution even if you are not using a public computer, such as at a library or internet café, but even when using your private computer in your home. You are also responsible for keeping your contact and payment information up to date. You may update or change your registration information by logging into the "Immofreund" Control Panel. Certain information must be retained by "Immofreund", even after termination of your account, in order for "Immofreund" to be able to provide the services requested, comply with its legal obligations, or to allow "Immofreund" to resolve disputes or enforce its agreements.


Changes to this Privacy Statement

"Immofreund" reserves the right to change this Privacy Policy at any time, and such changes will be posted to the "Immofreund" website.



Any questions concerning this Privacy Policy may be directed by e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it. .

To report abuse, please send an e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it. .



Revised: Juli 20, 2019

© 2019"Immofreund" Immobilienverwertungsges.m.b.H. All rights reserved.

"Immofreund" Immobilienverwertungsges.m.b.H.
Vienna , Austria
SingrienerGasse 5/3A
1120 Wien

+43 699 10686700

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