Bitoy's AML/CFT Policy

Dear Global Bitoy Users:

Bitoy is committed to creating a secure environment for cryptocurrency trading. To this end, Bitoy adheres to international standards and practices by implementing robust internal controls and establishing a comprehensive Anti-Money Laundering/Counter-Terrorism Financing/Sanctions (AML/CTF/Sanctions) program. For the safety of your assets and the stability of transactions, please read Bitoy's AML (Anti-Money Laundering) and KYC (Know Your Customer) policies carefully.

 

This AML/CTF/CPF Policy (the “Policy”) is designed to prevent and mitigate the potential risks of Bitoy facilitating any illegal activities related to money laundering (“ML”), terrorism financing (“TF”), and proliferation financing (“PF”) during the provision of its platform services. This Policy is for informational purposes only and does not impose any legal obligations on Bitoy or any other persons (natural or otherwise).

 

Bitoy primarily bases its program on the recommendations and international guidelines of the Financial Action Task Force (“FATF”) and considers the relevant laws, regulations, amendments, and guidelines related to AML/CTF/CPF. The program aims to establish a secure, stable, and reliable virtual asset trading service for its customers, including but not limited to:

- AML and CTF Ordinance (“AML/CTF Ordinance”);

- AML and CTF (National Risk Assessment) Ordinance 2022;

- AML and CTF (Counter-Measures) Ordinance 2022;

- AML and CTF (Cross-Border Declaration) Ordinance 2022;

- Beneficial Ownership Act 2020;

- Beneficial Ownership Regulations 2020;

- Terrorism Prevention Act 2004;

- Prevention of Proliferation Financing Ordinance 2021.

 

Principles and Methods of Bitoy's AML/KYC Operations

 

Bitoy is dedicated to supporting AML/KYC operations. Principally, we will:

 

1. Conduct due diligence when dealing with our customers and individuals appointed to act on behalf of our customers.

2. Develop business to the highest ethical standards and strive to prevent any business relationships related to or potentially aiding money laundering or terrorist financing.

3. Assist and cooperate with relevant legal authorities to prevent the threats of money laundering and terrorist financing.

 

I. Bitoy's Risk Assessment and Risk Mitigation Methods

 

Risk Assessment:

 

We anticipate that the majority of our customers will be retail customers, and as of the date of this Policy, we will primarily operate in the British Virgin Islands.

 

When Bitoy engages with new customers, we will collect the following information and make judgments:

 

Customer Registration:

 

Bitoy is committed to making decisions that enable its business and customers to act in compliance and ethically. During registration, Bitoy must identify each customer and the beneficial owner of each account before opening any account and must not open or maintain any anonymous or fictitious accounts. Therefore, Bitoy registers only customers who meet established standards from a risk, compliance, and regulatory perspective.

 

A. Recording and/or Collecting Documents Pertaining to:**

 

1) Individual Customers:

To join Bitoy, customers must provide satisfactory proof of identity. Positive identification of the customer must be obtained from documents issued by a reliable source, and copies of these documents along with other recorded details must be kept.

The customer’s risk assessment will determine what information Bitoy should obtain and whether this information should be independently verified.

 

Bitoy will verify the collected identity information by referring to documents, data, or information provided by reliable and independent sources. Examples of such documents, data, or information include but are not limited to:

- Government-issued ID with a photograph or other national ID.

- Valid travel document (e.g., an unexpired passport).

- Other relevant documents, data, or information provided by reliable and independent sources (e.g., documents issued by government agencies).

 

Bitoy will retain copies of personal identification documents for records and use third-party identity verification systems to authenticate the customer’s ID and selfies.

Bitoy will screen each applicant and any relevant entities and individuals against sanctions, PEP, and adverse media lists to identify potential sanctioned targets and PEP.

 

2) Institutional Customers:

 

The primary requirement is to identify the persons who ultimately control the business and institutional assets, paying particular attention to any shareholders or others who may have a significant influence on the company’s affairs. Before establishing a business relationship, steps should be taken through company searches and/or other commercial investigations to ensure that the applicant company has not been or is not in the process of being dissolved, struck off, wound up, or terminated.

 

The customer’s risk assessment will determine what information we should obtain and whether this information should be independently verified.

 

At a minimum, the following information should be obtained from institutional customers (where applicable):

- Full name of the institutional customer, including any aliases and trade names.

- Company registration number.

- Date of incorporation.

- Country of incorporation.

- For trusts, the jurisdiction of administration.

- Type of legal entity, such as a corporation, partnership, trust, non-profit organization, unincorporated association, limited liability company, public company, or other types.

- Registered address.

- Principal place of business address.

- Description of the business and activities of the institutional customer.

- Any licenses obtained by the institutional customer to conduct business.

- Ownership and control structure showing ultimate beneficial ownership.

- Locations of the partnership headquarters, operating facilities, branches, and subsidiaries.

- Full name of directors/partners/managers/trustees (as applicable), including any aliases, and unique identification numbers (e.g., ID or valid passport number) and residential addresses.

- Full name of account authorized signatories and any other natural persons acting on behalf of the institutional customer, including any aliases, and unique identification numbers (e.g., ID or valid passport number) and residential addresses.

- Contact details of the authorized signatories and other persons acting on behalf of the customer.

- Board resolutions or other authorizing documents that authorize the opening of the account and confirm the authority of each authorized signatory and/or other natural persons acting on behalf of the institutional customer to act on the account.

- Description of the source of funds, etc.

- Full name of the account’s beneficial owners (including any aliases) and unique identification numbers (e.g., ID or valid passport number) and residential addresses.

 

B. Ensuring that our customers, associated persons of customers, individuals appointed to act on behalf of customers, and the beneficial owners of customers are evaluated and screened against designated individual and entity lists, which include (but are not limited to) the following jurisdictions:

- Turkey;

- Vietnam;

- UAE;

- Barbados;

- Burkina Faso;

- Bulgaria;

- Democratic Republic of the Congo;

- Cameroon;

- Gibraltar;

- Haiti;

- Croatia;

- Iran;

- Jamaica;

- Jordan;

- Kenya;

- North Korea;

- Cayman Islands;

- Mali;

- Myanmar;

- Mozambique;

- Namibia;

- Nigeria;

- Panama;

- Philippines;

- Sudan;

- Senegal;

- Syria;

- Tanzania;

- Uganda;

- Yemen;

- South Africa;

 

C. Types of Unacceptable Customers:**

Bitoy will not accept the following types of customers and establish business relationships with them:

1. Shell banks;

2. Entities or individuals appearing on relevant sanctions lists and blacklists, including OFAC and SDN lists;

3. Customers who fail or refuse to provide all necessary KYC information and data to verify their identity and establish their economic status without adequate justification;

4. Entities issuing bearer shares;

5. Unapproved PEP and senior management;

6. Residents of countries/regions where Bitoy does not provide regulated or compliance-purpose services and/or products;

7. Customers involved in criminal activities, including but not limited to money laundering, terrorist financing, proliferation financing, tax evasion, and corruption;

8. Customers from high-risk non-cooperative jurisdictions;

9. Customers involved in purchasing and/or selling products/services in darknet markets.

 

Please note that the above list is not exhaustive, and Bitoy will consider specific circumstances when determining whether to establish business relationships.

 

Bitoy adopts a Risk-Based Approach (“RBA”) to determine the extent, frequency, or scope of customer due diligence measures and ongoing monitoring based on the assessed ML/TF/PF risks associated with the customer or business relationship. There is currently no universally accepted approach to prescribe the nature and scope of an RBA. However, an effective RBA involves identifying and categorizing ML/TF/PF risks at the customer level and devising reasonable measures based on the identified risks. An effective RBA allows the company to make reasonable business judgments about its customers. The RBA should not aim to prohibit the company from transacting with customers or establishing business relationships with potential customers but should assist the company in effectively managing potential ML/TF/PF risks.

 

Broadly, the model for assessing customer risk profiles is based on the following factors:

 

1) Country Risk

   - The geographical location of the customer or the origin of their business activities poses relevant risks. For individual users, Bitoy considers the customer's nationality and country of residence when assessing country risk. For institutional users, Bitoy considers the country of registration, the primary place of business, and the geographical distribution of the customer's operations. The country risk factor assesses the potential ML, TF, and PF risks based on the ML, TF, and PF control environment of each country, including regulatory scrutiny and supervision, corruption, sanctions, etc. To determine such jurisdictions, country reports issued by international organizations can be considered, including but not limited to:

     - FATF High-Risk and Non-Cooperative Jurisdictions List;

     - FATF Mutual Evaluation Reports;

     - Transparency International Corruption Perceptions Index;

     - OECD’s Country Risk Classification;

     - OFAC Sanctions List, including the Specially Designated Nationals and Blocked Persons List (SDN);

     - Basel AML Index.

   - Based on country risk, countries are categorized into low, medium, high, and prohibited. This categorization method derives from a range of reliable public information sources, including information published by FATF, OFAC, the UK, EU, and UN sanctions lists, etc.

 

2) Customer Risk

   - Different customers pose varying degrees of ML/TF/PF risks. Bitoy considers various factors to determine the ML/TF/PF risk levels of customers, including but not limited to:

     - Whether the customer is a publicly listed company or a private company;

     - Whether the customer is regulated or unregulated;

     - Whether the customer involves any complex structures that make it more challenging to determine the ultimate beneficial owner;

     - Whether the customer uses nominee shareholders;

     - Whether the customer issues bearer shares;

     - Whether there is a risk associated with Politically Exposed Persons (PEP);

     - Whether the customer is engaged in any high-risk business activities;

     - Whether the customer is associated with restricted countries and/or subject to sanctions measures, adverse news, and law enforcement actions.

 

3) Product/Service Risk

   - Different products or services pose varying degrees of ML/TF/PF risks, as customers may utilize products or services for ML/TF/PF. Therefore, Bitoy considers the characteristics of the services it offers and the extent to which they are susceptible to ML/TF/PF abuse and takes appropriate measures described in this Policy to mitigate and manage the identified risks.

 

4) Delivery/Distribution Channel Risk

   - Bitoy should also consider its delivery/distribution channels and the extent to which these channels are susceptible to ML/TF/PF abuse. Customers solicited or engaged through networks, emails, telephone, or social media channels without face-to-face contact generally pose higher ML/TF/PF risks compared to those engaged face-to-face.

 

II. Our New Products, Practices, and Technological Approaches

 

We should provide appropriate advice on identifying and assessing the risks of money laundering and terrorist financing that may arise in the following areas:

- Development of new products and new business practices, including new delivery mechanisms;

- Use of new technologies or developing technologies for new and existing products.

We will pay particular attention to any new products and new business practices, including new delivery mechanisms, and new or developing technologies that favor anonymity, such as digital tokens that facilitate anonymity (whether securities, payment, and/or utility tokens).

 

III. Bitoy's Customer Due Diligence ("DD")

 

Bitoy does not open, maintain, or accept anonymous or fictitious accounts. Accordingly, Bitoy employs a robust customer due diligence process to verify user identity. Bitoy will initiate the KYC process at the inception of each customer relationship, and users will not be permitted to transact until they have completed Bitoy's mandatory KYC registration process. Bitoy will not accept entities with unclear beneficial ownership structures or from prohibited/sanctioned regions.

 

Based on the customer’s anti-money laundering risk rating and other risk characteristics, DD is divided into three levels:

1) Customer Due Diligence (“CDD”)

2) Simplified Due Diligence (“SDD”)

3) Enhanced Due Diligence (“EDD”)

 

Customer Due Diligence (“CDD”)

CDD is a process of:

1. Identifying the customer using reliable, independent source documents, data, or information.

2. Determining the ultimate beneficial owner and taking reasonable measures to verify the identity of the beneficial owner so that Bitoy is satisfied it knows who the beneficial owner is. For legal persons and arrangements, this should include taking reasonable measures to understand the ownership and control structure of the customer.

3. Identifying and verifying any person purporting to act on behalf of the customer and verifying that they are so authorized.

4. Obtaining information on the purpose and intended nature of the business relationship.

5. Where applicable, obtaining, recording, and confirming additional KYC information on the customer profile, including but not limited to the source of funds, source of wealth, purpose of the account, expected activity, and investment objectives.

6. Conducting ongoing due diligence on the business relationship and scrutinizing transactions throughout the relationship to ensure that the transactions being conducted are consistent with Bitoy's knowledge of the customer, their business, and risk profile, including, where necessary, the source of funds.

7. DD should be conducted on all customers with standard due diligence requirements (i.e., CDD) unless they qualify for Bitoy’s SDD measures.

 

Simplified Due Diligence (“SDD”)

SDD should only apply to the following customers:

1. Low anti-money laundering risk;

2. Regulated financial institutions, investment vehicles, or publicly listed companies in FATF member countries, government, or public bodies;

3. Have been screened against sanctions lists;

4. No suspicious indicators or red flags are present.

 

Customers eligible for SDD are not required to identify and verify the UBO. However, other aspects of CDD must be conducted, and ongoing monitoring of the business relationship is still required. SDD measures should not be applied in any case where it is known, believed, or suspected that there is ML, TF, or PF, regardless of the size and nature of the transaction or customer. Additionally, SDD should not be applied where there are any higher risk situations or factors present.

 

When applying SDD, Bitoy may still:

1. Identify the customer and verify the customer’s identity;

2. Obtain information on the purpose and intended nature of the business relationship with Bitoy;

3. Identify any person purporting to act on behalf of the customer (if any) and take reasonable measures to verify the authority of such person to act on behalf of the customer.

 

Enhanced Due Diligence (“EDD”)

Bitoy must apply EDD measures:

1. For PEPs, family members of PEPs, and close associates of PEPs, whether they are customers or beneficial owners;

2. When the customer risk assessment indicates a higher risk of ML/TF/PF;

3. When higher ML/TF/PF risks are identified through regulatory guidance;

4. When media sources confirm adverse information about the customer;

5. When the customer is from a high-risk jurisdiction based on residence, nationality, or economic activities;

6. When any unusual or suspicious activities occur.

 

The above list is not exhaustive regarding when EDD should be applied. For business relationships or transactions involving higher risk, Bitoy must apply the following EDD measures:

1. Obtain additional information about the customer and the beneficial owner(s);

2. Obtain additional information about the intended nature of the business relationship;

3. Obtain information on the source of funds and source of wealth of the customer and beneficial owner(s);

4. Obtain information on the reasons for intended or executed transactions;

5. Increase the number and timing of controls applied and select patterns of transactions that need further examination to enhance the monitoring of the business relationship.

 

IV. Ongoing Monitoring

 

Bitoy will continuously monitor its business relationships with customers. The ongoing monitoring will be proportionate to the risk rating assigned to the customer by Bitoy and will include the following actions:

1. Monitoring customer transactions and activities to detect suspicious transactions, including ensuring that Bitoy has processes to detect, assess, and, where applicable, submit suspicious transaction reports.

2. Timely updating of information about the customer, their beneficial ownership, name screening results, and the purpose and intended nature of the business relationship.

3. Reassessing the level of risk associated with the customer's transactions and activities.

4. Determining whether the customer’s transactions or activities are consistent with the information previously obtained about the customer, including the customer's risk assessment.

 

Periodic Reviews

 

Bitoy requires periodic reviews of customer information to ensure that the information kept in the customer KYC profile is up-to-date and accurate. Bitoy will achieve this by reviewing customer documents, data, and information at different frequencies, properly examining transactions conducted on behalf of the customer, and reviewing the customer’s business risk profile and source of funds. This will enable Bitoy to determine whether ongoing transactions are consistent with Bitoy’s knowledge of the customer, their business, and their risk profile.

 

Bitoy will pay particular attention to any activity that:

- Is complex.

- Involves unusually large transactions.

- Is conducted in an unusual manner.

- Lacks an apparent economic or lawful purpose.

 

The frequency of periodic reviews depends on the customer’s risk assessment, as follows:

 

If any changes occur in the customer’s information, the updated information should be reflected in the customer's KYC profile. For significant changes (i.e., changes in industry, country of incorporation), the customer risk assessment will be updated. Additionally, after any changes, re-screening must be conducted.

 

If the customer’s risk rating increases and the customer is classified as high risk, enhanced due diligence (EDD) should be conducted in accordance with the risk rating.

 

Trigger Reviews

 

Bitoy must ensure that documents, data, and information obtained for DD purposes remain up-to-date. Events that trigger the update of DD information must include (but are not limited to):

- Changes in the customer’s location.

- Changes in the customer’s beneficial ownership.

- Information that is inconsistent with Bitoy’s knowledge of the customer.

 

Event-driven reviews may also be triggered by (but are not limited to):

- Significant transactions (relative to the relationship).

- Transactions inconsistent with previous activity.

- Major changes in key positions.

- Involvement of PEPs.

- Significant changes in the customer’s business activities (this includes starting new business in new countries).

- Reasons for knowledge, suspicion, or concern (e.g., suspicion of the authenticity of provided information). If an STR has already been filed, care must be taken to avoid any disclosures that might constitute tipping off.

- Multiple users using the same IP address and/or device.

 

Bitoy will also require every customer it has a business relationship with to update their KYC information, including but not limited to proof of identity and beneficial ownership. For low-risk customers, these updates will be conducted every three (3) years, for medium-risk customers every two (2) years, and for high-risk customers annually. When updating this information, Bitoy will also consider whether the customer’s transactions and activities are consistent with Bitoy’s understanding of the customer’s business and activities and will update records accordingly, listing the purpose and intended nature of Bitoy’s business relationship with the customer.

 

Based on the updated information, Bitoy will reassess and assign the customer’s risk level to detect changes in the customer's circumstances that might make the business relationship undesirable or expose Bitoy to a higher ML/TF/PF risk. If, after reassessment, Bitoy determines that more information or documents must be obtained from the customer, the customer will be required to provide such additional information or documents.

 

Bitoy will continue ongoing monitoring until the business relationship with the customer ends. The business relationship ends seven (7) years after the customer closes their last account with Bitoy.

 

Enhanced Measures for High-Risk Customers

 

In addition to the ongoing monitoring measures outlined above and the enhanced customer identification measures described in this policy, Bitoy will require every high-risk customer it has a business relationship with to update their information, such as identity and beneficial ownership, annually after onboarding.

 

Risk Reduction for High-Risk Customers

 

As part of the annual update process, Bitoy will decide whether to maintain the relationship with the customer. Additionally, Bitoy will coordinate the analysis of customer and transaction data to understand trends and other indicators of suspicious activity to improve control over businesses marked with high-risk activities. Bitoy will limit or reject customer accounts that exceed its risk tolerance.

 

If Bitoy decides to reduce the customer’s risk, this will result in the customer’s account being closed, and the customer being restricted from using Bitoy’s services. Ongoing monitoring requirements, including monitoring of de-risked customers due to adverse media, and determining whether an STR should be filed with the financial intelligence unit or equivalent, will continue to apply to closed accounts and be effective for seven (7) years from the account closure date.

 

Dormant Accounts

 

If a customer’s account shows no activity (including login activity) for 24 months, it will become a dormant account and will be frozen. Dormant accounts will only be reactivated after Bitoy’s AML team reassesses all KYC information and documents related to the customer.

 

V. Record Keeping at Bitoy

 

Bitoy is committed to an environment where all types of records are stored electronically and can be promptly retrieved.

 

Bitoy will maintain the following documents and records:

1. Copies or references of evidence obtained for customer due diligence measures, including account documents, business correspondence, and all documents proving the identity of customers and beneficial owners.

2. Audit trails of customer risk assessments at onboarding and ongoing.

3. Details of customer transactions.

4. Details of actions taken on internal and external suspicion reports within seven years of their creation.

5. Information considered by the AML reporting office regarding internal reports of potential suspicion within seven years of their creation, in cases where a suspicious transaction report (STR) was not filed.

6. Records of AML/CTF/CPF-related training.

7. AML/CTF/CPF-related reports.

 

Records must be retained for at least seven (7) years from the following dates:

1. The date on which the evidence of a person’s identity was obtained;

2. The date of any transaction or communication related to the customer;

3. The date the business relationship ended.

 

The purpose of record-keeping is to maintain an audit trail to assist Bitoy and authorities in investigating any ML/TF/PF allegations, support any financial investigation, and ensure that criminal funds do not enter the financial system, otherwise, the authorities might detect and seize such funds. Records kept for the above purposes should be sufficient to allow financial intelligence units and other relevant authorities to reconstruct transactions easily at any time. The manner and format of record-keeping should enable Bitoy to comply immediately with information requests from law enforcement or financial intelligence units.

 

If any records need to be retained, a copy should be kept with appropriate backup and recovery procedures: 

1. If a paper copy can be readily generated, it should be kept in a machine-readable format;

2. If a paper copy can be readily generated, it should be kept in electronic format, and the retention method should allow for proper authentication.

 

If information about a customer is retained, it must be kept as up-to-date as possible. It must ensure that customer information (e.g., personal and financial status, address or job changes) is kept current.

 

VI. Suspicious Transaction Reporting (STR)

 

Bitoy is committed to preventing and detecting suspicious activities that may jeopardize the safety and well-being of Bitoy personnel and its service community. Bitoy recognizes that vigilance, early detection, and timely reporting are critical to combating potential threats.

 

Bitoy aims to establish a systematic and consistent approach to identifying, documenting, and reporting suspicious activities, enabling appropriate investigations and necessary actions to effectively mitigate risks and cooperate with financial intelligence units and relevant authorities.

 

To this end, Bitoy will notify the relevant authorities and submit suspicious transaction reports (STRs) as required by law. Bitoy will also maintain all records and transactions related to all such transactions and STRs.

 

VII. Employee Screening and Training

 

A. Employee Screening

 

The employee recruitment process must consider reputational analysis of candidates to ensure that employees and officials meet Bitoy's ethical and reputational standards and are committed to preventing and combating terrorist financing, proliferation financing, money laundering, and the concealment of assets, rights, and property crimes. Bitoy conducts background checks on all employees to ensure that each hired employee has a clear background. Employees must be monitored to prevent fraudulent activities and ensure the effectiveness of AML/CTF/CPF policies and procedures.

 

B. Training

 

Training is a critical component of Bitoy’s AML program. Bitoy will develop and document a plan for ongoing compliance training and its delivery, ensuring that Bitoy personnel authorized to act on behalf of Bitoy receive adequate training to understand the requirements of all applicable AML/CTF/CPF laws and regulations. Employees who interact with customers, participate in customer transaction activities in any way, or are responsible for overseeing the AML program (e.g., senior management, IT staff) must complete AML training.

 

The training aims to encourage a culture of compliance within Bitoy. All affected personnel will receive training at least annually. New employees joining Bitoy or taking relevant positions must complete training as part of the new employee onboarding process before engaging with customers.

 

The training program will be tailored to the roles and responsibilities of appropriate employees and will cover the following topics:

1. What is money laundering, terrorist financing, and proliferation financing;

2. Overview of the importance of AML/CTF/CPF;

3. Requirements of this policy and related procedures and controls;

4. Recent developments and changes in relevant laws and regulations;

5. Penalties and consequences of non-compliance with this policy and legal requirements, and the risks faced by Bitoy;

6. Emphasis on senior management and board commitment to ongoing education, training, and compliance;

7. Recognition of common indicators of suspicious transactions related to money laundering, terrorist financing, and proliferation financing, and examples of different types of suspicious transactions and reporting methods.

 

Annual refresher training (or more frequently if necessary) is essential for all employees to:

(i) Understand their (and Bitoy’s) ongoing obligations under applicable laws and regulations;

(ii) Understand the requirements outlined in this policy;

(iii) Stay informed of trends in money laundering, terrorist financing, and proliferation financing within the industry, as well as any new or changing legislative requirements.

 

Any AML officers working with Bitoy will receive additional training to provide ongoing education to ensure they understand their role and responsibilities in maintaining an effective AML program to mitigate AML/CTF/CPF risks, including trends in money laundering, terrorist financing, and proliferation financing related to cryptocurrencies and cryptocurrency exchanges/platforms/counters.

 

AML/CTF/CPF training materials will be reviewed by the Money Laundering Reporting Officer (MLRO) before delivery. The MLRO is responsible for determining the method and form of training. Training can be delivered through face-to-face presentations, staff meetings, testing modules, conference calls, videos, or online training. The effectiveness of the training program will be tested by requiring trainees to complete a quiz with a range of questions that, if answered correctly, ensure that employees or agents have a basic understanding of the regulations and their responsibility to comply with them.

 

Training and testing materials, training session dates, and attendance records will be kept in written form. The MLRO is responsible for ensuring the training program remains current and accurately reflects new legislative and regulatory developments, and for maintaining records of all compliance training, including training logs updated each time training is delivered to or completed by employees or anyone acting on behalf of Bitoy, and following up with anyone who misses training.

 

VIII. Policy Review

 

This policy will be reviewed at least annually to test its effectiveness and assess whether Bitoy’s practices comply with legislative and regulatory requirements.

 

Bitoy will also review this policy if:

- There are significant changes in the law or practice;

- Bitoy discovers or is alerted to deficiencies in this policy;

- Changes in Bitoy’s business, customers, or other factors impact this policy.

 

BITOY Team

June 27, 2024

 

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