Your Gateway to
Digital Assets.

Last updated: 1 June 2026 · Kaldex System OÜ

1. Introduction

Kaldex System OÜ ("Bitlaya", "we", "us", "our"), operator of bitlaya.com, is committed to protecting your personal data. This Privacy Policy explains what data we collect, why we collect it, how we use it, and your rights in relation to it.

2. Data Controller

Kaldex System OÜ, Registry Code 17541510, Harju maakond, Tallinn, Kesklinna linnaosa, Jõe tn 5, 10151, Estonia, is the data controller for personal data processed through bitlaya.com.

3. Information We Collect

We collect: (a) Registration data — full name, email address, and password; (b) Transaction data — cryptocurrency selected, EUR amount, wallet address, and billing postcode (card numbers processed by our payment partner; not stored by us); (c) Identity verification data — government-issued ID and proof of address where required for KYC/AML compliance; (d) Technical data — IP address, browser type, device identifiers, and session data collected via cookies and server logs.

4. Legal Basis for Processing

We process data under the following legal bases: performance of a contract (order fulfilment); legal obligation (KYC/AML requirements, FINTRAC regulations); legitimate interests (fraud prevention, security, analytics); and consent (non-essential cookies or marketing communications).

5. How We Use Your Data

Your data is used to create and manage your account; process cryptocurrency purchase orders; conduct identity verification and AML screening; send order confirmations and account communications; detect and prevent fraud and money laundering; comply with legal obligations; and improve our services through aggregated usage analytics.

6. Data Sharing

We share data with: POLARIS MONEY SERVICES INC. (principal licensed entity, for AML compliance); payment processing partners (solely for transaction processing); identity verification service providers; and regulatory authorities including FINTRAC where legally required. We do not sell your personal data.

7. International Transfers

Your data may be transferred to Canada (by POLARIS MONEY SERVICES INC.) and other countries. Such transfers are governed by appropriate safeguards including standard contractual clauses.

8. Data Retention

Account and transaction records are retained for a minimum of five years after account closure to comply with AML regulations. You may request deletion of non-essential data at privacy@bitlaya.com.

9. Your Rights

You have the right to access, correct, or request deletion of personal data we hold (subject to legal retention obligations), and to lodge a complaint with the Estonian Data Protection Inspectorate. Contact: privacy@bitlaya.com.

10. Security

We use TLS 1.3 encryption in transit, AES-256 at rest, and restrict access to personal data on a strict need-to-know basis.

11. Contact

privacy@bitlaya.com · Kaldex System OÜ, Jõe tn 5, Tallinn, 10151, Estonia.

Last updated: 1 June 2026 · Kaldex System OÜ

1. Agreement to Terms

By accessing bitlaya.com, creating an account, or completing any cryptocurrency purchase, you confirm you have read, understood, and agree to be bound by these Terms of Service. If you disagree, you must not use our services. These Terms constitute the entire agreement between you and Kaldex System OÜ ("Bitlaya", "we", "us", "our").

2. Eligibility

You must be at least 18 years old and legally permitted to enter binding contracts in your jurisdiction. You must not reside in a country subject to applicable sanctions or FATF blacklisting. By registering, you represent compliance with these requirements. We may request proof of eligibility at any time.

3. Nature of Service

Bitlaya provides a fiat-to-cryptocurrency conversion and dispatch service. We are not a cryptocurrency exchange, broker, investment adviser, or financial institution. Purchasing cryptocurrency through Bitlaya does not constitute an investment and is not covered by any deposit guarantee scheme. All purchases are dispatched to the wallet address you provide and are final.

4. Cryptocurrency Exchange Services

Our exchange services are provided through POLARIS MONEY SERVICES INC. (FINTRAC Reg. No. C10001253), regulated under Canada's PCMLTFA. By transacting, you consent to the exchange and AML screening procedures conducted by or on behalf of POLARIS MONEY SERVICES INC. in accordance with applicable Canadian financial regulations.

5. KYC and Identity Verification

We are required by law to verify the identity of users above certain transaction thresholds. By registering, you agree to provide accurate identity documentation upon request. Failure to complete verification will result in suspension of your account or cancellation of your order. All funds used for purchases must originate from legitimate sources.

6. Purchase Orders

Orders are accepted at the exchange rate displayed at submission. Rates are indicative and may vary slightly at settlement due to market movement. Confirmed orders are binding. You are solely responsible for the accuracy of the wallet address provided. Dispatch typically occurs within 30 minutes of payment confirmation.

7. Payment

We accept Visa, Mastercard, and Maestro cards. Payments are processed by our PCI-DSS compliant payment partner. We reserve the right to decline transactions for security or compliance reasons. By paying, you confirm you are the authorised cardholder.

8. Risk Warning

Cryptocurrency markets are highly volatile. The value of any digital asset you purchase may decrease substantially or to zero. Past performance is not indicative of future results. Only purchase crypto with funds you can afford to lose entirely. We do not provide investment, financial, tax, or legal advice.

9. Refunds and Cancellations

Blockchain transactions are irreversible. Once dispatched, orders cannot be recalled. Refund conditions are set out in our Refund Policy. We will not refund losses arising from market movements. Technical dispatch failures on our part are addressed under the Refund Policy.

10. Prohibited Use

Bitlaya must not be used for money laundering, terrorist financing, any illegal activity, purchases using stolen payment methods, or circumvention of KYC/AML controls. Violations will result in immediate account termination, reporting to FINTRAC and other relevant authorities, and forfeiture of any pending orders.

11. Limitation of Liability

To the maximum extent permitted by law, Kaldex System OÜ and POLARIS MONEY SERVICES INC. shall not be liable for losses from price movements, wallet address errors, service interruptions, or indirect/consequential damages. Total aggregate liability is capped at the total EUR paid by you in the 12 months preceding the relevant claim.

12. Governing Law

These Terms are governed by Estonian law. Disputes shall be referred to the Estonian courts after an attempt at amicable resolution via legal@bitlaya.com. Nothing limits your rights as a consumer under applicable Estonian or EU consumer protection law.

13. Amendments

We may update these Terms at any time. Material changes are communicated by email at least 14 days before taking effect. Continued use constitutes acceptance of updated Terms.

14. Contact

Kaldex System OÜ
Registry Code: 17541510
Jõe tn 5, Tallinn, 10151, Estonia
legal@bitlaya.com

Last updated: 1 June 2026 · POLARIS MONEY SERVICES INC. / Kaldex System OÜ

1. Overview

Bitlaya's cryptocurrency exchange services are operated through POLARIS MONEY SERVICES INC. (FINTRAC Reg. No. C10001253), incorporated in Canada and regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). POLARIS MONEY SERVICES INC. maintains a comprehensive Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) programme in compliance with Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations.

2. Supervisory Authority

Principal licensed entity: POLARIS MONEY SERVICES INC.
Registration: FINTRAC Money Services Business, Reg. No. C10001253
Valid: 17 October 2025 – 30 June 2028
Supervisory Authority: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), 24th Floor, 234 Laurier Avenue West, Ottawa, Ontario, K1P 1H7, Canada.

3. Risk-Based Approach

We apply a risk-based approach (RBA) to AML/CTF compliance. The level of scrutiny applied to each customer and transaction is proportionate to the assessed money laundering or terrorist financing risk. Risk factors include transaction size, user jurisdiction, transaction history, source of funds, and behavioural patterns. Higher-risk cases receive enhanced due diligence (EDD).

4. Customer Due Diligence (CDD)

Standard CDD is applied to all users and includes: (a) collection and verification of full name, date of birth, and residential address; (b) verification via government-issued photo ID; (c) collection of information on the purpose and nature of the customer relationship; and (d) screening against sanctions lists, PEP databases, and adverse media sources.

5. Enhanced Due Diligence (EDD)

EDD applies to high-risk customers including PEPs and their close associates, transactions above FINTRAC reporting thresholds, customers in higher-risk jurisdictions, and transactions with unusual or suspicious characteristics. EDD measures include source of funds documentation, senior management approval, additional verification, and enhanced ongoing monitoring.

6. Transaction Monitoring

All transactions are subject to automated and manual monitoring against FINTRAC's indicators of suspicious activity. Velocity, pattern, and threshold-based controls are applied. Alerts are reviewed by our compliance team and suspicious transactions are reported to FINTRAC via Suspicious Transaction Reports (STRs) as required by law.

7. Reporting Obligations

POLARIS MONEY SERVICES INC. files the following reports with FINTRAC as required: Suspicious Transaction Reports (STR); Large Virtual Currency Transaction Reports (LVCTR) for transactions of CAD 10,000 or more; Terrorist Property Reports (TPR); and Electronic Funds Transfer Reports (EFTR) where applicable.

8. Record Keeping

Comprehensive records of customer identification data, transactions, and compliance decisions are maintained for a minimum of five years in accordance with PCMLTFA requirements. All records are held securely and available to FINTRAC upon lawful request.

9. Sanctions Screening

All users and transactions are screened against Canadian OSFI sanctions lists, the UN Security Council Consolidated List, and relevant international sanctions regimes. Any confirmed match results in immediate account suspension and notification to relevant authorities.

10. No Tipping Off

Under applicable law, we are prohibited from disclosing to any customer or third party that a suspicious transaction report or other regulatory filing has been made in connection with their account or transactions.

11. Contact

AML/compliance queries: legal@bitlaya.com
POLARIS MONEY SERVICES INC. Compliance Officer: compliance@polarismoneyservices.com

Last updated: 1 June 2026 · Kaldex System OÜ

1. What Are Cookies

Cookies are small text files stored on your device when you visit bitlaya.com. They allow the website to recognise your browser, maintain your session, and improve your experience on return visits.

2. Cookies We Use

Essential cookies — strictly necessary for the website to function. These include authentication session tokens, security cookies, and your cookie consent preference. They cannot be disabled without impairing core site functionality.

Analytics cookies — collect anonymised, aggregated data on how visitors use bitlaya.com, including page views and navigation paths. Used solely to improve our service. You may opt out at any time.

Preference cookies — store your display and language settings so they persist across sessions.

3. Third-Party Cookies

We may use analytics services (such as Google Analytics) that set their own cookies operating under their own policies. We do not permit advertising or third-party tracking cookies on bitlaya.com.

4. Managing Cookies

Control cookies via the consent banner shown on first visit, or via your browser settings at any time. Disabling essential cookies will prevent account login and core functions. Consult your browser's help documentation for instructions.

5. Local Storage

We use browser local storage to persist your cookie consent preference and certain session state. This data is stored locally on your device and not transmitted to our servers.

6. Updates

This Cookie Policy may be updated periodically. A new consent banner will appear on material changes. Continued use of bitlaya.com constitutes acceptance.

7. Contact

Cookie queries: privacy@bitlaya.com

Last updated: 1 June 2026 · Kaldex System OÜ

1. Irreversibility of Crypto Transactions

Cryptocurrency transactions are irreversible by their technical nature. Once crypto assets are dispatched to the wallet address you provided, the transaction cannot be reversed, recalled, or cancelled by us. You are solely responsible for the accuracy of the wallet address you submit with every order.

2. No Refunds for Market Movements

We do not offer refunds for losses arising from cryptocurrency price fluctuations after your order is confirmed and dispatched. Price volatility is an inherent risk of digital asset markets that you accept in full when placing a purchase order. The indicative exchange rate at the time of order confirmation is the rate applied to your transaction.

3. Eligible Refund Conditions

A full refund of the EUR amount charged may be issued where:

• A technical error on our part prevented dispatch within 60 minutes of payment confirmation and you report this within 24 hours of the expected delivery time;
• Your payment cleared successfully but a verifiable system failure on our side prevented order fulfilment;
• A duplicate charge was applied to your payment method due to a technical fault;
• We cancelled your order due to a compliance or sanctions screening match (subject to applicable legal obligations regarding return of funds).

4. Refund Process

To request a refund, email support@bitlaya.com within 24 hours of the issue. Include your order reference (BTL-XXXXXX), the email address on your account, a description of the problem, and supporting evidence. Approved refunds will be returned to the original payment method within 5–10 business days. We reserve the right to request additional verification before processing any refund.

5. Chargebacks

Initiating an unauthorised chargeback for a completed and dispatched order is a breach of these Terms and may constitute fraud. We cooperate fully with card schemes and will provide delivery evidence to contest fraudulent chargebacks. Users initiating unjustified chargebacks will have their accounts permanently terminated.

6. AML / Compliance Holds

Where a transaction is placed on hold pending AML/KYC verification and verification cannot be satisfactorily completed, the EUR amount paid may be held for up to 30 days while compliance procedures are completed. If the transaction cannot be approved, funds will be returned to the original payment method minus any applicable processing fees, subject to applicable legal requirements.

7. Contact

Refund requests and billing queries: support@bitlaya.com
Kaldex System OÜ, Jõe tn 5, Tallinn, 10151, Estonia.