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Terms of use

1. Warning about investing in cryptocurrencies

1. You are advised that the risk of loss from trading and holding cryptocurrencies can be substantial and that the value of cryptocurrencies is highly volatile: the price can go up and down in a very short time and is largely unpredictable. 

2. You are responsible for the risks and financial resources used. You acknowledge that investing in cryptocurrencies involves a significant risk of loss and that You may lose your initial investment. 

3. You should not engage in the trading and holding of cryptocurrencies if You do not fully understand the nature of the transactions made and the magnitude of the risk of losses.

2. Preamble

4. The SaaS platform called “Libertify” (“the platform”) is provided by Libertify (the “provider”), a société par actions simplifiée à associé unique, with a capital of €13,530, registered with the Trade and Companies Register (RCS) of Paris, under number 880 473 459, having its registered office at Paris 75016, 118 rue de Lauriston (email: info@cryptoseatbelt.com; telephone: 0 805 98 79 80; EU VAT identification number: FR03880473459; Siret number 880 473 459 000 27).

5. The publication director is Mr Steve Rosenblum, in his capacity as CEO.

6. The service provider in charge of hosting and providing direct and permanent storage is Amazon Web Services, having its registered office at Amazon Web Services, Inc. – P.O. Box 81226 – Seattle, WA 98108-1226 – United States – Phone: (206) 266-4064.

7. The provider has developed a cryptocurrency wallet monitoring platform for retail investors, which can be accessed on the “Libertify” app and the www.cryptoseatbelt.com website.

8. You acknowledge that the use of the platform requires that You read and agree to these terms of use. You acknowledge that the use of the platform requires that You comply with all the provisions of these terms of use.

9. You are deemed to have read these general terms and conditions of use of the platform (“terms of use”).

10. You must read any new version of these terms of use each time You use the platform.

11. These terms of use are neither terms of sale nor a service agreement.

3. Definitions

12. The following terms shall have the meanings set out below between the parties:

  • “Internet”: means a network of networks that allows the exchange of information through a protocol called TCP/IP. Data is transmitted through networks of a different nature that are able to read the messages according to this technical standard. Each element of this network belongs to private or public organizations that operate them in cooperation without necessarily involving a bilateral obligation of quality;
  • “Risk Profile”: means a score that defines the User’s risk appetite;
  • “Service”: means a functionality other than Simulation offered by the platform to Users, as defined in the section “Description of the platform and associated Services”;
  • “Simulation”: has the meaning given to it in sections 7.1 and 8.2;
  • “User” or “You”: means any person who accesses and implements the features of this platform.

4. Purpose

13. The purpose of these terms of use is to determine the terms and conditions of use of the Services made available to Users using the platform.

5. Acceptance and enforceability of the terms of use

   5.1 Acceptance

14. To use the platform and its Services, You must first agree to the terms of use.

15. By ticking the checkbox with the following text when You use the platform for the first time, You agree to the terms of use:

                                           “I have read, understood and agree to the terms of use of the platform”

16. Such a ticked box is proof that You have read the terms of use and constitutes your acceptance of the terms of use.

17. You can save and print these terms of use by using the standard features of your smartphone.

18. By agreeing to the terms of use, You represent that:

  • You are fully aware that the Services are provided remotely;
  • You have read the conditions under which the Libertify platform operates;
  • You have all the technical skills necessary to access and use the Services in the best possible conditions;
  • You have checked that You meet the technical prerequisites.

    5.2 Changes

19. The provider reserves the right to make such changes to these terms of use as it may deem necessary or appropriate.

20. The terms of use linked from the Libertify platform shall prevail over any version printed at an earlier date.

21. You can access any previous and archived terms of use on request by sending an email to: info@cryptoseatbelt.com.

22. By using the Libertify platform after the terms of use have been changed, You agree to the new terms of use.

    5.3 Enforceability

23. The terms of use are binding upon and enforceable upon acceptance when You first connect to the Libertify platform.

24. The terms of use apply to You for the entire period during which You use the Libertify platform and until such time as they are replaced by new terms of use.

25. You may at any time stop using the Libertify platform and the associated Services but You will remain responsible for any previous use.

6. Effective date – Term

   6.1 Term of the terms of use

26. These terms of use apply to You for the entire period during which You use the Libertify platform until the occurrence of any of the events described below.

   6.2 End at the User’s initiative

27. You will have access to the Services until your account is closed or your subscription is terminated.

   6.3 Suspension or termination of account

28. In case of suspicion of fraudulent use of the Services, the provider reserves the right, without notice or compensation, to suspend or terminate a User’s access to the Services;

29. in the event of a breach of the obligations under the terms of use, the provider reserves the right, without notice or compensation, to suspend access to all or part of the User’s account until the reason for such suspension has disappeared, or to terminate the account depending on the seriousness of the breach.

30. You acknowledge that the provider will not be liable to You or any third parties for the consequences of such termination or suspension of the account.

    6.4 Effects of the suspension or termination of the account

31. In the event your account is suspended, You will not be able to access the Services until access to the account is restored.

32. In the event your account is terminated, You will not be able to access the Services and the account data permanently.

33. In any case, You remain responsible for any use of the Services prior to the account’s termination or suspension.

34. The termination of the account will automatically result in the termination of these terms of use.

7. Hardware requirements / compatibility

    7.1 General requirements

35. You may use the Services offered on the Libertify platform subject to compliance with the following requirements:

  • be of legal age on the day of registration on the Libertify platform;
  • have the legal capacity to enter into these terms of use;
  • have subscribed to the corresponding Services;
  • have subscribed to the virtual Simulation features (limited to one year) associated with a portfolio created by You as detailed in section 8.2 below.

36. You are solely responsible for all costs relating to the access, whether for hardware, software or Internet access. You are solely responsible for the proper functioning of your equipment and Internet access.

37. Before using the Libertify platform, You must verify the quality of your hardware and software and check that they are compatible with the platform.

38. The communication costs remain the responsibility of the User.

39. The mobile application is available on Google Play Store and Apple App Store. To date, the application is compatible with Apple’s iOS version 14 and later versions, Android version 12 and later versions.

    7.2 Hardware requirements

40. You may use the Services offered on the Libertify platform subject to compliance with the following requirements:

  • have the appropriate computer equipment to access the Libertify platform (computer, tablet, smartphone with compatible operating software versions);
  • agree to these terms of use.

    7.3 Connection to other portfolio management platforms

41. The Libertify platform connects using application programming interface (API) either directly or through an API that is itself connected to the User’s various cryptocurrency exchange and portfolio management platforms. 

42. The cryptocurrency exchange and portfolio management platforms that are compatible with the Libertify platform are listed in section “Wallets” or any other equivalent term on the platform website: “www.cryptoseatbelt.com”. 

8. Description of the platform and associated Services

     8.1 Main Services

43. Libertify platform’s main Services use artificial intelligence to allow cryptocurrency investors to monitor and secure their portfolios and retail investments according to the Risk Profile that is assigned to them.

44. The Services are described on the “www.cryptoseatbelt.com” website in section “Services” or any other equivalent term. 

45. Access to the paid Services is reserved for Users who have taken out a subscription.

46. Once the Risk Profile has been determined, You connect your existing exchange and cryptocurrency wallets to the Libertify platform which pulls account balances in one consolidated dashboard and launches the monitoring Service.

47. The Libertify platform constantly monitors market prices and your assets in order to inform You, with notifications, of price movements that may be of interest to You and result in action by You. 

48. The Libertify platform is a self-learning platform based on algorithms. The User’s Risk Profile is fed at each interaction and each action recorded in order to improve the next algorithmic recommendations.

     8.2 Use of algorithms

49. The Libertify platform uses intelligent algorithms in the following two steps: 

  • User Risk Profile: a neural network per User is fed from any use and enhanced by a system of similarity with other Users that will generate a risk score;
  • market analysis: all the assets invested by Users are monitored by the algorithm which analyses the price action of each of the assets and generates signals to buy or sell which are influenced by the risk score (notifications are sent according to the communication channels chosen by the User).

      8.3 Notifications

50. Notifications to Users are targeted and determined according to the User Risk Profile.

51. You will receive the notifications on your smartphone according to the specified channel (text, email, push notifications).

52. You will then be able to click on one of the following three options: 

  • “ignore” the notification,
  • “accept” the notification, 
  • “find out more”, which will send You to a new page displaying the same notification with more information and the following choices will again be possible: accept, refuse or ignore.

53. The notification has a lifetime of fifty-nine (59) minutes.

54. You can choose the date and time of receiving the notification.

55. Any action by You will cause the notification to reload, such as a web page refresh.

56. You have access to the history of notifications received and actions taken in the “Notifications” menu of the platform.

57. An order repudiation mechanism is set up: You can cancel the last notification You have accepted within fifty-nine (59) minutes after acceptance. The order is then re-given the other way round as close as possible to the market value. 

58. By cancelling an order, You run the risk of suffering financial loss caused by the fluctuation and high volatility of the market price.

59. You may refuse to receive these notifications at any time by adjusting the platform settings on your smartphone.

      8.4 Simulation feature

60. A Simulation feature is available for interested Users to test the Libertify application and platform in a virtual only mode.

61. This virtual Simulation feature has a lifetime of one (1) year from the creation by the User of their virtual account.

62. The same User may have both an active real account and a virtual Simulation account. No link is made between the two accounts and therefore between a real portfolio and the virtual portfolio created by the User.

      8.5 Change to Services

63. The provider reserves the right to enhance or modify the Libertify platform and the Services available thereon at any time according to technological developments, changes required by technology, changes in applicable laws, or the choices made the provider at its discretion.

64. The Services offered are subject to change depending on how they are used by the User and according to the User Risk Profile: the prolonged use of certain functionalities of the application may give access to new levels of Services later on.

65. All characteristics of the Services, including price, may be modified by the addition or removal of Services in real time.

9. Accessing and using the platform

      9.1 How to access the platform

66. Access to the platform is restricted to Users who have subscribed to the Services of the platform and created a personal account on the Libertify platform. 

67. The registration of the User and the creation of the User account is done from the Libertify platform registration and subscription form. You guarantee the accuracy of the information given during the registration process.

68. When creating your account, the following steps should be followed: 

  • You fill in the registration form by giving your email address, last name, first name and choose a password that must meet the indicated password requirements;
  • You read the terms of use, scroll to the end and accept them by checking the box provided for this purpose (“I have read, I understand and I agree”) and by clicking on the ‘I agree’ button. If You do not accept the terms of use, the registration process will be stopped; 
  • You read the various information notes;
  • You complete your Risk Profile.

69. Once the account creation form has been validated, a registration confirmation email will be sent to You in order to verify your email address and activate the account.

70. To log in to your personal account, You must enter your username and password. You cannot access your personal account by any other procedure. 

71. When logging in via a smartphone, You may, however, use the identification features offered by iOS or Android, such as fingerprint login or facial recognition.

72. Users who do not have their own personal account are prohibited from accessing a personal account and agree not to enter or attempt to enter such a space. Such access will be considered fraudulent access under the provisions of the Penal Code.

73. Only one account may be assigned per individual User.

74. In case any of the mandatory information to be provided turns out to be false, incomplete, outdated, far-fetched or offensive, the provider reserves the right, without notice or compensation, to suspend or close the User’s account and deny them access to all or part of the Services of the Libertify platform.

      9.2 Login and password

75. You are assigned a username and password to access the platform. Usernames and passwords are strictly personal and confidential.

76. You are solely responsible for protecting and maintaining the confidentiality of your password and other associated confidential data. You must take all useful measures to ensure their complete confidentiality.

77. In case of security risk, the provider reserves the right to restrict access to the personal account to certain operations.

78. Any use of the platform Services with your password will be irrefutably presumed to have been made by You.

79. If You have forgotten your password, the provider has set up a password reset procedure allowing You or the administrator to create a new password.

80. You undertake to notify the provider without delay after becoming aware of any fraudulent use of your personal account, login or password.

       9.3 Right of use

81. The provider grants You a simple right to use the platform. This right is revocable, non-exclusive and worldwide and subject to payment of the subscription price by You. It is intended for use in accordance with these terms of use.

       9.4 Technical support 

82. The provider provides You with support that can be accessed by sending an email to: info@cryptoseatbelt.com.

83. Technical support is described in detail in the terms of sale.

10. Availability of the platform and Services

84. The provider implements the necessary means to ensure that the Services are accessible 24 hours a day and 7 days a week. The provider uses its best efforts in accordance with the rules of the art to provide a quality Service and secure the Services considering the complexity of the mobile networks and Internet. It cannot guarantee that the platform will be fully accessible or available at all times.

85. Maintenance operations that may cause the platform Services to be unavailable will be carried out as quickly as possible and the maintenance team will strive to optimize the operations so as to reduce the inconvenience.

86. In accordance with the standards and practices in the field, the provider will use commercially reasonable efforts to perform the Services as the provider’s obligation to the User is a best effort obligation within the meaning of French law.

87. The provider reserves the right to make any changes and improvements to the platform and the Services it offers that it deems necessary or useful for the proper functioning of the platform and the associated Services.

88. Users must ensure that their computer and transmission means are capable of following the technological developments of the platform.

89. The provider cannot be held responsible for any unavailability of the platform or the Services, whether voluntary or not, if such unavailability is caused by external factors, such as technical reasons, network congestion, misuse of the online Services, failure of Internet service providers and communication and telecommunication operators. The provider cannot further be held responsible for damage to the operating system and functionalities of the hardware used as a result of interruption or disruption in the Services.

90. You represent that You agree to the characteristics, limits and risks associated with the use of the Internet and mobile networks.

91. You acknowledge that You are aware of the nature of the mobile networks and Internet, and in particular of their technical performance and response times for consulting, searching or transferring data and information.

92. You must inform the provider without delay after becoming aware of any failure of the Services by sending a notification to the provider by email to info@cryptoseatbelt.com. Only the date of receipt of this email will be considered as proof between the parties.

93. You are aware that data circulating on the mobile networks and Internet are not necessarily protected, particularly against possible misuse.

94. You undertake not to interfere with the proper functioning of this system. In particular, You agree not to introduce viruses or any other software or technology harmful to the platform, the Services offered therein or the provider. You further agree to take all appropriate measures to protect your own data and/or software from contamination by any viruses and malicious software.

95. You must not saturate a page, take bounce actions or any other action that may interfere with or distort the operation of the platform.

96. You must not take any action that would impose a disproportionate burden on the infrastructure of the platform.

97. The following is prohibited and may result in criminal penalties: any unauthorised access to or remaining in the platform; any interference with or alteration of the operation of the platform; any introduction, suppression or modification of the data that are contained therein.

98. You must assume that all data found during such unauthorised access is confidential and agree not to disclose it.

99. The provider reserves the right, without notice or compensation, to suspend or close temporarily or permanently all or part of the platform or all or part of the access to the Services in order to carry out operations such as updates or any other maintenance operation, or if You:

  • compromise or attempt to compromise the quality of the Service or the security of a third party;
  • behave in such a way as to affect the integrity of the Services or the computer systems of the provider or its service providers or subcontractors.

11. User’s obligations 

100. You agree that:

  • You must not commit any infringement;
  • You must not reproduce, perform, or modify all or part of the platform;
  • You must not hamper the proper functioning of the platform;
  • You must use the platform fairly and in compliance with these terms of use, the applicable laws and regulations, including laws relating to intellectual and industrial property, information technology, privacy and personal data protection;
  • You must not upload, share or store any content that is unlawful or in violation of the Freedom of the Press Act of 29 July 1881, or that contains elements including, but not limited to, pornography, child pornography or violence, or any other inappropriate content;
  • You must not create or use accounts other than the one initially created, whether under your own identity or the identity of a third party, except with the prior and written authorisation of the provider. Otherwise, the relevant account(s) and all the associated Services may be suspended under the conditions set out in these terms of use;
  • You must not access the platform by any means other than by downloading it from legal platforms such as Google Play for Android and App Store for iOS.

101. You are responsible for your use of the platform, the associated Services and your actions on the platform. The information stored must not infringe the national and international laws and regulations in force. You are responsible for providing accurate and updated information when registering on and using the platform and the Services.

102. You must not manually or automatically collect data about the other Users or third parties without their consent in any manner and for any purpose such as sending unsolicited direct marketing messages or spam, or electronic chain letters.

12. Reporting unlawful content

103. You expressly acknowledge that the provider will be entitled to suspend or delete, without notice, compensation or refund:

  • any element, of any form or type whatsoever, which would present a risk of infringement of any of the provisions of these terms of use, the laws and the regulations in force and/or the right of a third party, of any nature whatsoever; 
  • unlawful content such as discriminatory, racist, defamatory, insulting, obscene, hateful or violent remarks;
  • content that has been notified by a third party through the procedure for reporting unlawful or abusive content;
  • content for which the provider has received a request or an authorisation from a court;
  • content that would damage the provider’s image or reputation.

104. In any of the above cases, the provider may immediately suspend access to your account. 

105. The provider will not be responsible for any damage caused as a result of the deletion of the content for any of the reasons mentioned in this section.

13. Hyperlinks

106. The provider reserves the right to provide hyperlinks on the platform that will give access to web pages other than its website pages.

107. The provider accepts no responsibility for the content of the information provided on such websites as a result of the activation of hyperlinks.

14. Personal data

108. In accordance with the Act No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties (Data Protection Act), as amended, You are informed that the provider processes your personal data and is the controller of such data processing operations.

109. Libertify undertakes, in this respect, as the data controller, to comply with the legislation applicable in France and in the European Union regarding the protection of personal data during the processing carried out in the context of the use of the Libertify platform and the associated services.

110. Libertify undertakes to respect the obligations contained in the personal data protection policy accessible at the following address (to be completed) and from the footer of each page of its website, application or platform.

15. Cookies

111. When using the Libertify website, application and platform, cookies or other tracers may be installed on the administrator’s or user’s terminal.

112. All the information concerning the cookies that may be deposited during such use is detailed in the Libertify cookie management policy, accessible on its website at the following address: (to be completed) and from the footer of each page of its website, application or platform.

16. Liability

         16.1 Provider’s liability

113. The provider cannot be held responsible for any direct or indirect damage or prejudice resulting from:

  • the quality of the Service, as the Service is offered “as is”;
  • the interruption or malfunction of the platform and the Services, in the absence of a breach by the provider of any of its obligations;
  • any computer security breaches, which may cause damage to Users’ hardware and data, in the absence of a breach by the provider of any of its obligations;
  • the infringement of User rights in general, in the absence of a breach by the provider of any of its obligations;
  • any impossibility of accessing the platform arising out of or in connection with the destruction of hardware, computer attacks or hacking, the temporary or permanent restriction, removal of or ban on access to the Internet network for any reason whatsoever, including breakdowns or unavailability inherent in the hosting servers, in the absence of a breach by the provider of any of its obligations;
  • the impossibility for the User to access their personal account, caused by the non-renewal, non-extension or termination of their subscription by the User;
  • the information and data shared by the User, the use of the content of the platform, or a use of the platform that is contrary to the law or the regulations in force;
  • a fraudulent or abusive use or a use caused by the voluntary or involuntary disclosure of the User’s username and/or password to anyone;
  • any malfunction, access unavailability, misuse, improper configuration of the User’s devices or applications, or use of by the User of a browser or operating system that is not widely used or an incompatibility of the User’s devices and applications;
  • the non-performance or improper performance of the terms of use caused by the User or a partner User of the platform; 
  • a force majeure event.

        16.2 User’s liability

114. You must use the Services of the platform, and all the information to which You may have access, exclusively for personal purposes and in a manner that is consistent with public policy, morality and third party rights.

115. You must not interfere with the use that other Users may make of the Platform, not access the accounts of third party Users and not access restricted areas of the platform.

116. You are solely responsible for the use of the platform and the decisions You make based on the recommendations issued on the platform or through notifications.

117. You agree that:

  • You must not use the Simulation feature to bypass the paid subscription Service;
  • You must not use your personal account for management on behalf of third parties;
  • You must not use the information obtained through the use of the Services for any purpose other than the management of your own portfolios, and in particular for the purpose of providing advice, recommendations or portfolio management services to any third party, whether or not for a fee. Any reproduction for purposes other than your personal use is strictly forbidden;
  • You must not reverse engineer in order to circumvent the system and/or to use the information provided to You by means of the Services with a view to determining or attempting to determine the characteristics of the algorithmic processing at the origin of this information.

17. Intellectual property

118. The content, general structure and software, texts, (still or animated) images, pictures, know-how of the platform and all other elements composing the site are the exclusive property of provider or its third party licensors and are protected in particular by intellectual property rights which are or will be recognised according to the laws in force.

119. Nothing in these terms of use is intended to transfer any intellectual property rights of any kind in the elements owned by the provider or its partners or third party licensors.

120. Any total or partial reproduction and/or representation of any of those elements without the provider’s express authorisation is forbidden and will constitute infringement punished by Articles L. 335-2 et seq. of the Intellectual Property Code.

121. You must not act or otherwise conduct in any manner that may directly or indirectly infringe the intellectual property rights of the provider.

122. You must not delete, remove or hide in any manner whatsoever the provider’s or its licensors’ proprietary notices on the product, or prominently include said proprietary notices, labels or brands on copies of the product.

123. It is forbidden to amend, copy, reproduce, download, disseminate, transmit, commercially exploit and/or distribute in any way whatsoever the Services, the website pages, or the computer codes of the elements composing the Services and the platform.

124. Distinctive signs of the provider and its partners, such as domain names, trademarks, names and logos appearing on the platform are protected by the Intellectual Property Code. Any total or partial reproduction of such distinctive signs made from the platform elements without the provider’s express authorisation is therefore prohibited, within the meaning of the Intellectual Property Code.

125. The platform may only be used in accordance with its intended purpose.

126. Any other uses without the express prior written permission of the provider are prohibited and shall constitute infringement.

18. Miscellaneous

        18.1 Waiver

127. The parties mutually agree that any tolerance of a situation by a party shall not grant the other party any rights in that respect.

128. Moreover, such a tolerance shall not be construed as a waiver of the rights in question.

       18.2 Sincerity

129. The parties represent that the commitments made herein are sincere.

130. Each party thus represents that it does not know any elements which, had it been disclosed, would have modified the consent of the other party.

       18.3 Headings

131. In the case of a difficulty of interpretation between one or more of the headings at the beginning of the clauses and the content of any of the clauses, the headings shall be declared non-existent.

       18.4 Severability

132. If one or several provisions of these terms of use were to be held invalid or so declared by a law, a regulation or a final decision having res judicata effect delivered by a court having proper jurisdiction, the other provisions shall remain in full force and effect.

       18.5 Entire agreement

133. These terms of use cancel and supersede all quasi-contracts, implicit and explicit commitments, promises having the same subject-matter as the subject-matter hereof.

134. However, this clause is not intended to prevent the use of the said documents but to evaluate legally the quality of the consents exchanged during the formation of the agreement.

       18.6 Rules of evidence

135. The electronic acceptance of the terms of use will have, for the provider and the User, the same probative value as an acceptance on a paper document.

136. The information required by law, professional rules and practices, or the state of the art for the conclusion of these terms of use may be transmitted between the parties by electronic means.

137. The same applies to letters sent under these terms of use.

138. You expressly agree to the use of this means in accordance with Article 1126 of the Civil Code.

139. The computer logs kept in the provider’s information systems in reasonable security conditions will be considered as proof of the communications, registration forms, and any other information and data sent by the User to the platform for carrying out the processing requested by the User.

140. The archiving of the registration and information forms must be made on a reliable and durable medium.

141. In case of conflict between the computer logs of the provider and any written document or electronic file, the parties expressly agreed that the provider’s computer logs will prevail over such documents and shall be the only ones admitted as evidence.

        18.7 Governing law

142. This agreement shall be governed by the laws of France.

143. French law shall apply to both form and substance, notwithstanding the place of performance of the essential or ancillary obligations.

       18.8 Dispute settlement

144. In case of dispute regarding these terms of use, You are informed by the provider of the possibility to have recourse to a consumer mediation procedure in the conditions provided for in Title I of Book VI of the Consumer Code.

145. The relevant mediator, the Paris Mediation and Arbitration Center, can be reached:

  • via the form available on the CMAP website at www.mediateur-conso.cmap.fr;
  • by e-mail at the following address: consommation@cmap.fr; or
  • by mail to CMAP – Service Médiation de la consommation, 39 avenue Franklin Roosevelt, 75008 Paris

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