Privacy Policy

Last update: 1 Jul 2025

Last update: 1 Jul 2025

Last update: 1 Jul 2025

1. Introduction This Privacy Policy explains how Focus Exchange (legal name: Bitledger, S.L., NIF: B67693705, "we," "our," "us") collects, uses, and protects your personal data when you use our services at FXC.es.

2. Data Controller Bitledger, S.L., registered in Spain, acts as the data controller under applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

3. Data We Collect We collect personal data you provide, such as name, ID documents, address, email, financial information, and crypto wallet details, as required for KYC, AML, and regulatory compliance (MiCA, SEPBLAC, CNMV, Banco de España).

4. Purpose of Processing We process your data to:

  • Provide our crypto exchange services (buy, sell, store, transfer crypto);

  • Perform identity verification (KYC/AML);

  • Fulfill legal obligations under Spanish and EU law;

  • Improve our services and protect against fraud.

5. Legal Basis Our processing relies on:

  • Contract performance;

  • Compliance with legal obligations (AML/CFT, SEPBLAC reporting);

  • Legitimate interests;

  • User consent where required.

6. Data Sharing We may share data with:

  • Regulatory authorities (e.g., SEPBLAC, Banco de España, CNMV);

  • Service providers (e.g., Sumsub for KYC/AML);

  • Payment partners, banking partners, auditors. We ensure all third parties adhere to data protection standards.

7. International Transfers If data is transferred outside the EEA, we ensure it is protected via Standard Contractual Clauses or equivalent safeguards.

8. Data Retention We retain your data for as long as required by law (e.g., AML regulations) or for as long as necessary to fulfill service purposes.

9. User Rights You have the right to access, rectify, erase, restrict, object, or request data portability. Contact us at info@FXC.es.

10. Data Security We apply technical and organizational measures to safeguard your data, including encryption, access controls, and regular security reviews.

11. Complaints You may file a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) if you believe your rights are infringed.

12. Contact Us If you have any questions, contact us at info@FXC.es.

Terms of Use

I. General Terms
These Terms of Use ("Terms") govern the conditions under which you may use the website of Bitledger, S.L., operating under the brand "Focus Exchange" ("Focus Exchange") available at https://FXC.es ("Website"). By accessing and using this Website, you agree to these Terms and any additional terms applicable to specific products or services.

II. Eligibility
You confirm you are at least 18 years old and legally able to agree to these Terms. You will not use the Website if prohibited by applicable law in your jurisdiction.

III. Use of the Website
Focus Exchange provides all services "as is." We make no warranties regarding accuracy or uninterrupted service. You agree to use the Website lawfully and avoid: unauthorized access, disrupting operations, transmitting malware, or violating others' rights.

IV. Financial Disclaimer
Information on the Website is not financial advice or a recommendation. Always seek independent advice before making financial decisions.

V. Limitation of Liability
We are not liable for any damages, losses, or interruptions related to your use of the Website or our services.

VI. Intellectual Property
All content on the Website is owned or licensed by Focus Exchange. Reproduction or use without written consent is prohibited, except for personal use.

VII. Service Interruptions
We are not liable for access interruptions due to technical issues, force majeure, legal restrictions, or any causes beyond our control.

VIII. External Links
Links to third-party sites are accessed at your own risk. We are not responsible for external content or practices.

IX. User Accounts
You are responsible for safeguarding your account credentials. Notify us immediately of unauthorized use.

X. Jurisdiction Notice
Our services are designed for the Spanish market under Spanish and EU law. Users outside Spain should seek legal advice about local suitability.

XI. Privacy and Data Protection
Your use of the Website is governed by our Privacy Policy, which aligns with GDPR and Spanish regulations. By using the Website, you consent to our data practices.

XII. Risk Disclosure
Crypto trading involves significant risk, including potential total loss. Crypto-assets are not legal tender, nor are they covered by deposit protection or investor compensation schemes.

XIII. Indemnification
You agree to indemnify and hold harmless Focus Exchange, its officers, directors, and agents from claims or losses arising from your use of the Website or breach of these Terms.

XIV. User Support
For any issues, contact us at info@FXC.es. We aim to acknowledge complaints within 5 business days and resolve them within 15 business days.

XV. Governing Law and Jurisdiction
These Terms are governed by Spanish law. Any disputes shall be resolved in the courts of Madrid, Spain.

General Service Agreement

1. Parties
This General Service Agreement ("Agreement") is entered between Bitledger, S.L., NIF: B67693705, operating under the brand Focus Exchange ("Focus Exchange" or "Provider"), and the user ("User" or "Consumer") who registers an account at FXC.es.

2. Definitions

  • Virtual Asset: A digital asset as defined under MiCA and Spanish law.

  • Virtual Asset Service: Exchange, transfer, custody, or administration of virtual assets.

  • Virtual Asset Service Provider: Bitledger, S.L. / Focus Exchange.

  • User Account: A personal account created by the User within Focus Exchange to access services.

3. Subject of the Agreement
Focus Exchange provides custodial crypto services including buying, selling, storing, sending, and receiving crypto. Users agree to comply with KYC, AML, and regulatory procedures in line with Spanish and EU law.

4. User Obligations
Users must:

  • Register and verify their identity (KYC) via Focus Exchange’s platform, supported by partners like Sumsub.

  • Provide accurate, up-to-date information.

  • Secure login credentials and promptly report suspicious activities.

  • Use the platform in compliance with applicable laws (Spanish AML law, MiCA).

5. Provider Rights
Focus Exchange reserves the right to:

  • Update terms, privacy policies, or internal rules.

  • Suspend or terminate accounts for fraud, noncompliance, or legal risk.

  • Limit transaction types, volumes, or currencies.

  • Collaborate with Spanish authorities (SEPBLAC, CNMV, Banco de España) for compliance.

6. Fees & Transactions
Users will be informed in advance of any applicable fees or charges. Transactions are typically processed within 48 hours. Users can request account statements at any time.

7. Risk Disclosure
Crypto trading involves risk, including potential loss of funds. Focus Exchange does not guarantee market performance or asset value stability.

8. Termination
Users may terminate this Agreement at any time by written notice and settlement of obligations. Focus Exchange may terminate for regulatory or legal reasons.

9. Liability
Focus Exchange is not liable for losses due to force majeure, cyberattacks, or third-party failures beyond its control. Users are responsible for their use of services.

10. Data Protection
All personal data is processed under GDPR and Spanish data protection law. See Privacy Policy at FXC.es for details.

11. Jurisdiction
This Agreement is governed by Spanish law. Any disputes will be resolved in the courts of Madrid, Spain.

12. Contact
For any questions, please contact: info@FXC.es

Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) policies and procedures

Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy – Focus Exchange (Bitledger, S.L.)

Effective Date: [Insert Date]

  1. PURPOSE AND SCOPE
    This AML/CFT Policy sets out the principles, rules, and internal controls applied by Focus Exchange (Bitledger, S.L., NIF: B67693705, "the Company") to prevent money laundering, terrorist financing, sanctions evasion, and other illicit use of its crypto services, in line with Spanish law (Ley 10/2010), EU AML Directives, MiCA Regulation, and FATF recommendations.

  2. REGULATORY FRAMEWORK
    The Company is supervised by Spanish authorities, including SEPBLAC (Spain's Financial Intelligence Unit), the Bank of Spain, and CNMV. It complies with international standards and implements requirements under EU and Spanish AML/CFT laws.

  3. ROLES AND RESPONSIBILITIES

  • Board of Directors: ultimate responsibility for AML/CFT oversight.

  • AML Compliance Officer (registered with SEPBLAC): manages the AML program, conducts risk assessments, reviews suspicious activity, reports to authorities, and ensures internal reporting lines.

  • Employees: mandatory participation in AML training and reporting of red flags.

  1. RISK-BASED APPROACH
    The Company applies a documented risk assessment to classify customers, products, services, and geographies into risk categories (low/medium/high) and tailors controls accordingly.

  2. CUSTOMER DUE DILIGENCE (CDD)

  • Identity verification (KYC) for all customers prior to providing services.

  • Enhanced Due Diligence (EDD) for high-risk customers (e.g., PEPs, cross-border, sanctioned countries).

  • Ongoing monitoring of customer activity and updating of CDD records.

  1. TRANSACTION MONITORING
    Automated tools and manual reviews detect suspicious patterns, structuring, unusual crypto transfers, and non-standard behavior. Transaction limits and thresholds are set based on risk profiles.

  2. SANCTIONS SCREENING
    Screening against EU, UN, OFAC, and Spanish national sanctions lists using automated tools.

  3. REPORTING SUSPICIOUS ACTIVITIES
    Immediate internal escalation to the AML Officer and external reporting to SEPBLAC when suspicion of money laundering, terrorist financing, or sanctions evasion arises.

  4. RECORD KEEPING
    All AML-related records, including KYC data, transaction history, risk assessments, and SAR filings, are retained securely for 10 years in line with Spanish regulations.

  5. STAFF TRAINING
    Annual AML training for all employees, tailored to their role, covering red flags, reporting obligations, and updates in regulatory requirements.

  6. INDEPENDENT REVIEW
    Regular independent AML audits or external reviews to assess program effectiveness and regulatory compliance.

  7. DATA PROTECTION
    Processing of customer data complies with GDPR and Spanish data protection law, with clear separation of AML data use.

  8. THIRD-PARTY RELATIONSHIPS
    Due diligence on third-party providers (e.g., KYC vendors like Sumsub, transaction monitoring providers like AmlBot) to ensure they meet AML compliance standards.

  9. CUSTOMER RIGHTS
    Clear communication to customers on why information is collected, how it is used, and their rights under data protection laws.

  10. REVIEW AND UPDATE
    This policy is reviewed at least annually or upon material changes in law, regulation, or business operations.

Contact: info@FXC.es | Bitledger, S.L., Spain