HS means the service provider Honos OÜ, registry code 1709770, operating address is Tornimäe 7-163, 10145 Tallinn, Estonia and the online platform honos.pro used for the provision of the Service.
Honos.pro means the online platform at the address www.honos.pro, through which HS provides the service
Client means any natural or legal person, who uses, has used or has expressed their will to use the HS Services.
Corporate Client means a Client, who is a legal person (company).
Party means a Client or HS.
Parties is a common denominator of a Client and HS.
Third party means any natural or legal person, who is not a Party in the meaning of the User Conditions.
Contract means a contract for the Service, concluded between the Parties with the opening of an Account for the Client on the HS platform honos.pro.
Service means the service of virtual wallet or virtual currency exchange for money, rendered by HS to the Client under the Contract on the honos.pro platform.
User Account means an online account assigned to the Client after signing up, marked with a unique Honos ID username.
First level account is an unverified Account (identity not verified) through which the Client can browse the honos.pro platform, but cannot conduct any transactions (deposit, purchase, sell or exchange virtual currencies, etc.).
Second level account is a verified Account (Client’s identity is verified) to and from which the Client can transfer (deposit) and disburse both money (FIAT) and virtual currencies (cryptocurrencies) and conduct purchase and sale or exchange transactions with virtual currencies.
Wallet means a virtual environment based on virtual currencies and created for the Client for depositing virtual currencies in the Account.
Account means a payment account belonging to the Client or Honos OÜ in a credit institution (Bank) or a paying agency.
Transaction relationships are legal relationships arising between the Parties, when the Client is using, has used or has expressed their will to use the Service provided by HS.
Price List means the price list of Services provided by HS.
HONOS OÜ (equivalent to the name “honos.pro” in this document, and hereinafter in the text referred to as "HS") is an Estonian company providing the service of virtual wallet and exchange of virtual currency for money, where the platform of the web portal is at the address www.honos.pro
By setting up the HS Client Account, the Client enters into a legally binding contractual relationship with Honos OÜ.
HS USER CONDITIONS establish the services provided by HS with related pricing, terms and conditions for entering into a contractual relationship with a Client and for termination of the contract, the rights and obligations of the Parties in using the HS platform during their contractual relationship, and possible sanctions in case of violation of established rules. The purpose of the User Conditions is to establish clear and reliable relationships between HS and the Client in order to ensure legal security and simplify the procedure of transactions.
HONOS OÜ DATA PROTECTION CONDITIONS AND PRINCIPLES OF PERSONAL DATA PROCESSING (hereinafter in the text as “Data Protection Conditions”) and KNOW YOUR CLIENT REQUIREMENTS (KYC) (hereinafter in the text as “KYC Requirements”) are integral parts of HS USER CONDITIONS. All the documents listed are publicly available on the honos.pro platform. The User Conditions and the other named documents are established by HS, who can change these unilaterally, notifying Clients thereof and publishing the amended document on the honos.pro platform. The documents published on the honos.pro platform include the date of preparation or the date of the last updates. In case of contradictions between or ambiguity in the document texts in Estonian and in other languages, the text in Estonian shall prevail.
Prior to the creation of a HS Client Account and use of the offered services or products, the Client must read the complete supporting documents of the HS Contract: User Conditions, Data Protection Conditions and KYC Requirements. Upon creation of the HS Account, the Client must confirm that they have become familiar with the listed documents. The processing of personal data by HS (data collection, storage, use, delivery, etc.) is performed due to a legal obligation and in order to offer contractual services to the Client. Using HS services without approving the HS Conditions can entail unfavourable consequences and sanctions for the Client. HS has the right to make inquiries to third parties, if necessary, in order to verify the data provided by the Client.
The services offered by HS are virtual currency wallet services for depositing virtual currencies and a service of exchanging virtual currencies for money, including purchase of virtual currency for money, exchange of money into a virtual currency, mutual exchange of various virtual currencies, sale of a virtual currency for money and exchange of a virtual currency into money.
HS enables transactions in monetary currencies in euros (EUR), US dollars (USD) and Russian roubles (RUB), for which a money Account is created for the Client. HS does not provide currency exchange services.
Depositing of and transactions with virtual currencies are possible only with a limited list of virtual currencies, which changes from time to time. The list of virtual currencies accepted for transactions is available on the honos.pro platform. Clients are welcome to suggest new virtual currencies for the list of virtual currencies accepted on the HS platform, by sending their propositions to the address firstname.lastname@example.org. In case of a strong interest expressed by Clients and in the absence of circumstances or restrictions, which would preclude using the virtual currency, the currency is added to the list at the first opportunity.
The Client can view continuously the balance of their accounts (money account and virtual currency wallets), the history of completed or ongoing transactions.
- For the purposes of using the Service, the Client must create a User Account (Honos ID) on the honos.pro platform and complete the verification procedure, after which HS decides either to activate the User Account or refuse to do so;
- Persons under the age of 18 years are not allowed to create an active User Account, i.e. an account used for transactions, on the honos.pro platform;
- HS does not provide services in all regions and countries, or provides services under special conditions, regarding which the resident Client of such country is displayed a relevant notice;
- A User Account created for a Client is personal; allowing any third party to use it or have access to it is forbidden. Should HS detect a violation in relation to the use of a User Account by a third party, then, depending on the circumstances of the violation, the account will be blocked and the Client will either be given a warning to stop repeating the violation in the future or the Contract with the Client will be terminated and the User Account will be closed;
- Each Client may only have one User Account on the honos.pro platform. Should it become evident that a Client has created several Client Accounts with different identities or uses several Client Accounts with an agreement with the owners of the accounts or by concealing this from the owners, or several User Accounts have been created erroneously, then all the User Accounts will be blocked and, depending on the circumstances, the Client will be allowed to keep only one User Account of their own choice and the others will be closed, or HS will terminate the Contract with the Client and all the User Accounts used by them will be closed;
- In the transactions conducted on the honos.pro platform, the Client may only use their personal money and virtual currencies owned by them. Due to the obligation of due diligence arising from law for combating money laundering and terrorist financing (AML), HS may request the Client at any time to provide further explanations about the ownership or origin of money or virtual currencies and the purpose of transactions. HS can block the Client Account and put on hold any initiated transactions until receiving the explanations requested from the Client. Should it become evident that the Client has violated the rules, HS may, depending on the nature of the violation (objective, recurrence, other circumstances), cancel any initiated transactions and give a warning to the Client to stop repeating the violation in the future, or terminate the Contract with the Client and close the User Account;
- Clients with whom an earlier Contract has been terminated on HS’s initiative due to violations are generally not allowed to conclude a new Contract in the future.
Persons under the age of 18 years are not allowed to use the HS Service.
The accounts of HS platform honos.pro are managed on two levels. The account of the first level is activated immediately after delivering the initial registration application. Activation of the first level account includes no identity check (verification). The first level account gives the possibility to become familiar with the honos.pro platform environment, but does not allow any transactions (deposit, exchange of virtual currencies, etc.). In order to conduct transactions, one must hold a second level account.
With the initial registration the Client activates the option SIGN UP (Loo konto; Регистрация.) on the honos.pro platform, selects between a natural client or a corporate client (legal person) and completes a form (name; e-mail address), which will be their contact address in using the Client Account.
When signing up, it is compulsory to select the country of residence from the drop-down menu (the country of residence of the Client). HS offers its services pursuant to the laws and regulations of the Republic of Estonia. As HS cannot offer its services to the residents of all countries or does so under special conditions, the Client, who is a resident of such country is displayed a respective information.
With the sign-up, the Client enters a password for future logins to the HS Client Account (the password is entered into two fields, i.e. repeated in order to avoid errors).
In order to create a Client Account, the Client must confirm that they have read the supporting documents of the HS Contract: HS User Conditions, Data Protection Conditions and KYC Requirements.
During the creation of the Client Account the Client is asked, if they wish to receive the HS newsletter, direct mail, special offers or advertisements, invitations to participate in competitions or client games or surveys organised for improvement of product development and customer service. The Client can cancel such subscriptions at any time.
After entering the above-named details, the Client should click on the choice screen “REGISTER”, after which the HS platform generates automatically a unique username (ID) for the Client and sends a confirmation of the registration to the e-mail address provided by the Client at registration, and the Client should confirm the receipt. When the Client has confirmed the registration message, the first level account has been activated.
Activation of the second level account requires the Client to complete a process, where their identity is established, i.e. verification. On the honos.pro platform, the Client is verified pursuant to “Requirements and procedure for identification of persons and verification of persons’ identity with information technology means” established in the Republic of Estonia. For Client verification, HS uses the services of an external contractual partner Veriff OÜ (www.veriff.me).
In order to complete the verification process, the Client must enter into the honos.pro environment, select the icon (client) on the right in the upper menu, and activate “Verification” in the drop-down menu, which opens the window “Start Verification”. Activating the window “Start Verification” opens a form, which must be filled in with further required details. After filling in the form, activate the choice screen “START VERIFICATION”, which redirects to a verification example environment (verification procedure guide and hardware requirements). After reading the verification instructions, the choice screen “Start verification” should be activated, redirecting to the platform of the cooperation partner Veriff OÜ, who provides the verification service, where from a drop-down menu the document used for verification should be selected, then the consent given to processing of personal data under the conditions of Veriff OÜ, and the choice screen “CONFIRM” activated, after which the Client is directed to the verification procedures. The verification procedure is recorded. The second level account is activated after successful completion of the verification procedure. If the verification fails – due to a mistake, misunderstanding or a technical problem, the Client is informed about the failure of verification and the need to repeat the verification process. If the Client does not have the documents required for the online verification or the details presented by the Client require further inspection, HS can apply exceptional further procedures for personal verification, in the course of which the Client is asked to present further details and documents, based on which it will be decided, whether the person is identifiable pursuant to the due diligence obligation of HS. Should it become evident in the course of the verification process that the Client has attempted to deceive HS or the verification service provider (has used a document, which belongs to another person or is forged, or has deliberately submitted false information, etc.), the Client Account will be closed and the Contract will be terminated unilaterally by HS. The procedure for termination of the Contract is stated in the User Conditions under subsection “Termination of the Contract”.
On the HS account of a Corporate Client (company, a Client as a legal person), transactions may only be conducted by one (1) representative (natural person) authorised or appointed by the Client, whose person is verified in a process similar to the verification of a Client as a natural person. After the verification of the representative of a Corporate Client, HS sends a form to the Client for filling in with further details about persons related to the company and about the business profile. After receiving the further details, the business account manager and the management of HS make a collegiate decision about conclusion of a contract with the Client.
In case of changes in the contact details, the Client is obliged to update immediately (at the first opportunity) their details in the HS Account profile. The Client can view their details after logging in to honos.pro, under the selection of the upper menu bar, second icon on the right (client), by activating the choice “Profile”. In order to update the details, activate the window “Update the user”. If the name or the document used for verification has changed, the Client is redirected to the repeated verification (see the subsection on the activation of the second level account). In case of changes in other details of the Client, the details are updated without repeated verification.
In order to observe the due diligence obligation arising from the laws of the Republic of Estonia, HS updates Client details periodically, but not less that once in every two (2) years. The Client receives an automatically generated message about the need to update the details. After receiving such message, the Client cannot conduct any transactions on their Account, i.e. the Account is blocked until the request for updating the details has been fulfilled. Blocking is regarded as the final activity on the Account, from which starts a countdown to automatic deletion of the Account. An Account, which is blocked and not in use, is deleted automatically after … years. A more detailed description of the procedure for deleting an Account and termination of the Contract is provided in a respective subsection.
Service fees apply to transactions conducted on the honos.pro platform, displayed at the footing of the platform as well as in the transaction field upon initiation of a transaction. Service fees vary, depending on the currencies (money and various virtual currencies) and transactions (deposit, exchange, disbursement). In case of transactions involving money, the service fee is calculated in euros, in exchange transactions with various virtual currencies it is calculated in the virtual currency in which the Client initiated the transaction (currency of the first field in the transaction pair).
Payments (deposits) of money or virtual currency to Client’s HS Account have no limit restrictions.
Disbursements of money from the HS Account are limited to 100 000 euros (one hundred thousand euros) per day and 250 000 euros (two hundred and fifty thousand euros) per month. The Client can apply for an increase of the disbursement amount for a one-off transaction, which is decided by HS management.
Disbursements of virtual currencies (total amount of various virtual currencies) from the HS Account are limited to the calculated amount of 100 000 euros (one hundred thousand euros) per day and 250 000 euros (two hundred and fifty thousand euros) per month. The Client can apply for an increase of the disbursement amount for a one-off transaction, which is decided by HS management.
Monetary deposits and disbursements (FIAT) from the HS Account are accepted in euros (EUR), US dollars (USD) and roubles (RUB). HS Account does not offer currency exchange possibilities.
Deposits and disbursements of virtual currencies are possible only according to the list of virtual currencies published at and approved by honos.pro and is updated from time to time.
The Client can make money deposits (monetary deposits) to their HS Account only from accounts owned by the Client in banks or paying agencies, opened in the name of the person or client participating in the transaction in a credit institution or a paying agency registered or with a place of business in a country, which is a contracting party to the European Economic Area or in a country, where requirements equivalent to the requirements of the European Parliament and the Council (EU) directive 2015/849 are effective). Third parties cannot make payments to the Client Account.
Money (FIAT) can be disbursed from the Client Account only to an account owned by the Client in a bank or a paying agency, opened in the name of the person or client participating in the transaction in a credit institution or a paying agency registered or with a place of business in a country, which is a contracting party to the European Economic Area or in a country, where requirements equivalent to the requirements of the European Parliament and the Council (EU) directive 2015/849 are effective) and which have been previously verified (a deposit payment i.e. verification payment has been previously made to the HS Account through such account). Disbursements are subject to the two level authentication requirement. Disbursements to third parties are not possible.
The channels accepted for depositing can vary, depending on the country of residence of the Client.
Virtual currency received (paid or transferred) on the HS account of the Client, if originating from a remitter (wallet) outside honos.pro, should be provided with an explanation of its origin (who is the owner of the wallet, where the transfer is made from). When depositing virtual currency, the transfer should be provided with an explanation.
When transferring virtual currency from the HS Account, if the beneficiary (wallet) is outside the honos.pro platform, the recipient should be noted (who is the owner of the wallet, to whom the currency is transferred). When transferring virtual currency, the transfer should be provided with an explanation.
HS as an obligated entity in the meaning of the Money Laundering and Terrorist Financing Prevention Act (AML/CTF) of the Republic of Estonia is required to observe due diligence regarding Clients and transactions conducted by them. For observance of the due diligence obligation, HS may request from the Client further details about transactions (origin of the money or virtual currency; objective of the transaction; details of the other party of the transaction, etc.). In general, further information is requested in case of Transactions, where the one-off price or total amount of transactions within the current month is over 15 000 euros (fifteen thousand euros).
HS Account is only for personal use of the Client without the right to authorise any other persons (Third Parties) to use it, incl. family members, friends, business partners, lawyers or other legal representatives, etc. The Client is not permitted to allow Third Parties to use Client’s HS Account or to use the HS Account jointly with Third Parties - in case of any evidence thereof the Client Account shall be blocked by HS.
On the Client Account, the Client can monitor the status of transactions started with their activity instruction. The status displayed for transactions can be “Completed” or “Rejected”. A transaction, which has been started, but is on hold (process not complete) is visible in the list of transactions, but without any status entry. In case of transactions on hold, the Client can cancel the activity instruction. When instructed to cancel a transaction in process, HS will make every effort to cancel the transaction, but cannot guarantee that the cancellation will be successful.
- In the opinion of the Financial Supervision Authority of the Republic of Estonia, the field of virtual currencies is unregulated and financial supervision authorities do not oversee virtual currency schemes. The European Banking Authority has also published the warning. The warnings and risks are available for reading in the online environment of the Financial Supervision Authority of the Republic of Estonia and in the online environment of the European Banking Authority (EBA): EBA Warning on Virtual Currencies, EBA Op-2014-08 Opinion on Virtual Currencies
- The virtual currency service is not regulated with laws, it is controlled only by the service provider itself and all the risks are born by the user of the virtual currency. Virtual currency is a novel alternative to traditional payment systems. It is a digital money issued and normally also controlled by an IT developer. This means of payment is used and accepted by a certain virtual community and the virtual currency has no commercial coverage.
- The Client assumes sole risk for possible damages entailed with transactions, which have not occurred through deliberate activities or culpable negligence of HS (possible material damages through changes in virtual currency exchange rate, loss of virtual currency, etc.).
- The Client is responsible for the legality of transactions conducted by them on the honos.pro platform;
- The Client must verify, if the service provided by HS is permitted in their country of location, and shall have sole liability in their country of location for the legal consequences arising from transactions with virtual currencies and from using the honos.pro Service.
- Violation of laws or the rules established by HS can result in sanctions arising from the laws of the Republic of Estonia;
- HS is liable only for damages caused to the Client as a result of direct intent or culpable negligence;
- HS is not liable for damages arising from transactions of the Client (possible material damages due to changes in the exchange rate of the virtual currency, difference in virtual currency values in different trading or transaction environments, loss of virtual value, bad deal, fraud committed by the other party (third party) of a transaction, etc.);
- HS is not liable for possible damages caused to the Client with problems with the internet connection (absence of internet connection, slow connection, etc.) during the beginning or process of transaction;
- HS is not liable for damages caused by negligence of the Client (user credentials of honos.pro Client Account coming into possession of third parties; errors or mistakes in entered transaction details, etc.).
- HS is not liable for damages incurred as a result of Force Majeure events;
- HS is not liable for damages incurred through a supervision procedure of law enforcement agencies and national supervisory authorities (regulators) (enforced operational restrictions, requests for presentation of Client’s or transaction details, etc.).
- HS is not liable for legal consequences or damages to the Client arising from restrictions to transactions with virtual currencies and use of honos.pro Service in the country of location of the Client.
- The Client is obliged to notify HS immediately about transactions occurring on the User Account without their knowledge or under conditions deviating from Client's intent or about other transactions suspicious in any other way, and block their User Account in order to prevent or reduce possible damages by activating a choice (screen) “BLOCK”, which can be found at the footing of the field “ACCOUNT SETTINGS”.
- The Client is obliged to notify HS immediately, when their access password for the User Account has come into the possession of third parties or in case of such hazard (suspicion), and immediately change the access password or block their User Account by activating a choice (screen) “BLOCK”, which can be found at the footing of the field “ACCOUNT SETTINGS”.
- In case of a suspected transaction conducted by third parties on Client’s User Account or illegal access to Client’s User Account (hackers, use of unknown access passwords, technical faults, etc.) or any such potential threats detected by HS, the User Account of Client(s) and the whole access to the honos.pro platform will be blocked by HS temporarily until the circumstances have been established and the threat has been eliminated.
- The Client can terminate the Contract on their own initiative at any time by sending such notice in a format which can be reproduced,
- HS can terminate the Contract, if the Client has violated requirements arising from law or established by HS, or if the Contract cannot be continued on account of international sanctions arising from the residency of the Client, or the precepts of supervision authorities.
- If there is money or virtual currencies deposited on the HS Account of the Client at the time of terminating the Contract on the initiative of the Parties, and no activity restrictions have been established by RAP or HS regarding the Account, HS will transfer the deposited amounts as instructed by the Client to bank or paying agency accounts opened in the name of the Client in credit or paying agencies registered or with a place of business in a country, which is a contracting party to the European Economic Area or in a country, where requirements equivalent to the requirements of the European Parliament and the Council (EU) directive 2015/849 are effective) or to a virtual wallet belonging to the Client.
- Upon the termination of the Contract, the remaining balance on the Client Account cannot be transferred to third parties. If an activity restriction is imposed on the Client Account, transfer of the money or virtual currencies deposited on the account is permitted according to activity instruction of the Client after the grounds for the activity restriction cease to exist.
- If the Client has not used (entered, logged into) the honos.pro account in a period of 2 years or if the Client has failed to update duly their Client Account details and it is not possible to contact the Client for activity instructions through the contact details provided by them to HS, the Client Account is blocked and HS can transfer the deposited funds from there to HS deposit, from where the Client or their successor, on the grounds of the Law of Succession Act, can request the payment of the deposited funds at a later point of time.
- The details collected by HS from the Client (personal details and transaction data) will be deleted in 5 years after termination of the contract or closing of the Client Account or end of possible legal disputes, pursuant to the requirements of the law for combating money laundering and terrorist financing (AML).
- HS has the right for unilateral amendment of honos.pro supporting documents: User Conditions, Data Protection Conditions and KYC requirements. Clients are notified about amendment of the documents and the amended document is published on the honos.pro platform. The documents published on the honos.pro platform include the date of preparation or the date of the last updates. In case of contradictions between or ambiguity in the document texts in Estonian and in other languages, the text in Estonian shall prevail.
- Updates of honos.pro supporting documents enter into force from the moment of publication on the honos.pro platform.
- In case of disagreement with the updates of honos.pro rules (established rules, requirements or documents and related updates), the Client by continuing to use the Service assumes the legal liability for consequences resulting from violation of the rules or requirements established by HS.
- Any issues concerning the HS service (applications, complaints, inquiries) can be addressed by the Client to HS Customer Service at the address: email@example.com
- Disputes in which the Parties are unable to reach a compromise, shall be settled in Harju County Court (mail address: Lubja 4,10115 Tallinn) pursuant to the laws of the Republic of Estonia.
- Answers to frequently asked questions (FAQ) are available on honos.pro platform