Published: January 1st,  2019

Bullex (including affiliated entities as defined below) and its team take your safety and security very seriously. Please be aware that all cryptocurrency related investments come with significant risks. These risks may, for instance, comprise of complete or partial loss of Cryptocurrency (as defined below), loss of value, technology flaws, insufficient or incorrect information and regulatory changes. You are explicitly warned to ensure that you fully understand these risks before engaging in Cryptocurrency trading and/or brokering, especially in using the Bullex Site (as defined below). You should carefully consider whether trading or holding Cryptocurrencies is suitable for you in light of your financial condition. 

Should you have any questions regarding these risks, please let us know by contacting us via e-mail. If you do not fully understand these risks, you are kindly requested to seek advice on the matter and if that is not possible, you are kindly requested not to use the Bullex Services (as defined below) and/or the Bullex Site. 

By registering, accessing or using any Services made available through the Bullex website (https://bullex.eu), subsidiary websites, API’s, or Bullex apps (Android & IOS), (collectively referred to as the "Bullex Site" or the “Site”), you agree that you have read, understood and accepted all of the terms and conditions contained in this Agreement, as well as our Privacy Policy, which is incorporated by reference here and available on any page on the Bullex Site. As this is a legally binding contract, please carefully read through this Agreement and related notices before using the Bullex Site and any of our Services. 

"Bullex", "we", "our" or "us", including each of:

  • Bullex NL B.V., a Dutch limited liability company registered in the Trade Registers of the Dutch Chambers of Commerce under number 70248370;
  • Bullex, a Dutch foundation registered in the Trade Registers of the Dutch Chambers of Commerce under number 73013935,

and you or the entity which you legally represent (the “User” or “you” where applicable), 

enter into this agreement (the “Agreement”), which is governed by the terms and conditions outlined therein. Through the Site, Bullex provides you with services for trading, holding, buying and selling digital cryptocurrency and/or tokens (the “Services” and “Cryptocurrency”, respectively).


1. Eligibility and representations

1.1. There are certain jurisdictions from which you are not allowed - by law or otherwise – to use some or all of the Services and/or the Bullex Site. We do not represent or warrant that the Bullex Site, and/or any part thereof, is appropriate or available for use in any particular jurisdiction. Upon accessing or using the Bullex Site, you do so on your own initiative and at your own risk, and you are responsible for complying with all local laws, rules and regulations. We may limit the availability of the Bullex Site, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion. Accessing the Bullex Site is prohibited from territories where the content of the Bullex Site and/or the Bullex Services is deemed illegal.

1.2. By accessing and using the Bullex Site and any of the Services, you represent, declare and warrant to us that you:

1.2.1. are not on any national or international sanctions lists, such as EU, USA and UN sanctions lists;
1.2.2. are the owner of the bank account(s) used by you in connection with the Services;
1.2.3. will only sell Cryptocurrency using the Services that have been legitimately acquired; 
1.2.4. do not reside in a country nor fall under a jurisdiction of a country under which applicable laws you are not allowed to enter into this Agreement or use the Services; 
1.2.5. do not reside in a country that falls under sanctions issued by the UN, the EU, USA or any other relevant governmental organization;
1.2.6. any registration information (as well as any additional information we may require) that you submit to us is true, accurate and complete and you agree to keep it that way at all times.

1.3. You are not permitted to use any of the Services through the Bullex Site if you are in, under the control of, or a national or resident of any country subject listed on international sanction lists. Note that we may screen and monitor your profile and transactions, including submitted personal data, against sanction lists through third parties and/or subcontractors. You agree that we may provide such third parties with your personal data, insofar as is required by applicable law. We always make sure that such third parties are certified and maintain a level of security and scrutiny that is at least market standard and conforming to applicable law. Prohibited users are not to use or access the Bullex Site and any of the Services.

1.4. You indemnify Bullex against all losses and damages that may be the result of any of the representations mentioned in this article being violated.


2. Agreement Applicability

2.1 This Agreement shall be binding in full from the moment you start using and/or accessing the Services and/or the Bullex Site and it continues to be binding, even if you completely or partially stop using and/or accessing the Services, and/or the Bullex Site. You are allowed to terminate the Agreement by withdrawing any balance you may hold at Bullex and subsequently cancelling your Bullex account on the Site.

2.2 Bullex reserves the right, at its sole discretion, to change, revise, modify, add, or remove portions of this Agreement at any time. Such changes shall be published on the Bullex Site and sent to you via e-mail, giving a certain period for acceptance or rejection. Continued use of the Bullex Services and/or the Bullex Site after this period has passed, demonstrates your acceptance of such changes. If at any point you do not agree to any part of the then-current version of the Agreement, you are required to stop using the Bullex Services and the Bullex Site.

2.3 In the legal relationship between the Parties, the administrative records of Bullex shall be leading in establishing that legal relationship, unless you prove otherwise.

2.4 This Agreement and our Privacy Policy comprise the entire agreement between you and Bullex. We may not always strictly enforce our rights under this Agreement. If we do this, it will be just a temporary measure and we may enforce our rights strictly again at any time.

2.5 This Agreement is personal to you and you cannot transfer or assign your rights, licenses, interests and/or obligations to anyone else. We may transfer or assign our rights licenses, interests and/or our obligations at any time, including as part of a merger, acquisition or other corporate reorganization involving Bullex, provided that this transfer or assignment does not negatively impact the quality of the Bullex Services you receive.


3. No advisory relationship

3.1 Please note that Bullex is not your intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in connection with any trades or other decisions or activities effected by you using the Services. Also, please note that the Services currently are not regulated by the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten), the Dutch Central Bank (De Nederlandsche Bank) or any other Dutch regulatory authority. You should therefore carefully consider whether trading or holding cryptocurrencies is suitable for you. In that regard, no communication or information provided to you by us is intended as investment advice, financial advice, trading advice, or any other sort of advice. All trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. You should consult your legal or tax professional regarding your specific situation. Before making any decision to buy, sell or hold any Cryptocurrency, you should conduct your own due diligence and consult your financial advisors before making any decision. Bullex will not and cannot be held responsible for the decisions you make to buy, sell, or hold Cryptocurrency based on information provided by Bullex.


4. Bullex Account

4.1 In order to use the Bullex Services, you are required to register for a Bullex Account by providing us with personal information as required. You will also have to accept the terms of this Agreement and our Privacy Policy. We may, in our sole discretion, refuse to open a Bullex Account for you.

4.2 We will conduct certain verification procedures before you are permitted to use the Bullex Services. We request the information for registering a Bullex Account for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime. You permit us to use the information for this purpose and permit us to keep a record of such information as required by law and regulations. You authorize us to make the inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. We may require you to wait some amount of time while we make these enquiries, before permitting you to use further Bullex Services and/or before permitting you to engage in transactions beyond certain limits.

4.3 Users are responsible for keeping the electronic devices through which the Bullex Account and Bullex Services are accessed safe and maintaining adequate security and control of any and all security details that are used to access the Bullex Account. This includes taking all reasonable steps to avoid the loss, theft or misuse of such electronic devices and ensuring that these electronic devices are protected by password and/or other means like biometric authentication. Any loss or compromise of personal electronic devices or security details may result in unauthorized access of the user's Bullex Account by third-parties and the loss or theft of any balances held in your Bullex Account. Users must keep security details safe at all times.

4.4 Bullex Accounts can only be used by the person(s) whose name they are registered under. Bullex reserves the right to suspend, freeze or cancel accounts that are used by persons other than the persons whose names they are registered under. Accordingly, Bullex will not take legal responsibility for these accounts.

4.5 Bullex prioritizes maintaining the safety of your information and Cryptocurrency entrusted to us and we have implemented market standard protections for the Bullex Site and Services. However, there are account-level risks that are created by individual actions by Users. We request that you understand the need to independently take safety precautions to protect your own Bullex Account and your personal information. You hereby agree that:

4.5.1 You shall be solely responsible for the safekeeping of your Bullex Account, log-in email address and password. 
4.5.2 You will notify Bullex immediately if you are aware of any unauthorized use of your Bullex Account by any person or any other violations to the security rules and/or this Agreement.
4.5.3 You will strictly observe the security, authentication, dealing, charging, withdrawal mechanism or procedures of the Services. 
4.5.4 You will log out from the Bullex Site by taking proper steps at the end of every visit.

4.6 Bullex will not be responsible for any loss or consequences caused by your failure to comply with the provisions mentioned in Article 4.5.

4.7 If you suspect that your Bullex Account or any of your security details have been compromised or if you become aware of any fraud or attempted fraud or any other security incident (including a cyber-security attack) affecting you and/or Bullex, you must notify Bullex Support as soon as possible by email at support@bullex.eu. You are required to provide accurate and up to date information throughout the duration of the Security Breach and must take any steps that we may reasonably require to reduce, manage or report any security breach. Failure to provide prompt notification of any security breach may be taken into account in our determination of the appropriate resolution of the matter.


5. Site content properties

5.1 Bullex strives to maintain a high level of accuracy of information posted on the Bullex Site. However, Bullex cannot guarantee accuracy, suitability, reliability, completeness of the content throughout the Bullex Site, and will not accept liability for any loss or damage that may arise directly or indirectly from the Site and/or the Services. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the Bullex Site are your sole responsibility and we shall have no liability for such decisions.

5.2 Links to third-party materials (including without limitation websites) may be provided as a convenience but are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any third-party materials or on any third party sites accessible or linked to from the Bullex Site.

5.3 All rights to information on the Bullex Site and other Bullex Communications are owned by or licensed to Bullex. Any use of this website or its contents, including copying, modifying, or storing it in whole or part, other than for your own personal, non-commercial use is prohibited unless you obtain specific written permission from Bullex.


6. Broker Services

6.1 Once you have a verified Bullex Account, you will be able to deposit fiat currency (“Fiat”) using one of the payment methods available on the Bullex Site. The availability of a method of payment depends on a number of factors including, but not limited to, your country of residence, and limitations imposed by our duly registered payment processors.

6.2 When we confirmed the arrival of your deposit, we will update your Bullex Fiat Balance in your Bullex Account and inform you accordingly by e-mail. You will now be enabled to use your Bullex Fiat Balance to buy or sell Cryptocurrency at the Bullex Site.

6.3 Bullex is only able to hold your deposit in Fiat to enable you to perform a Transaction as defined below and only for a maximum of five (5) days, after which any Fiat Balance will be returned to you.

6.4 In your Bullex Account you will be able to see your Bullex Fiat Balance. You may hold Bullex Fiat denominated in the different currencies that we support, and we will show your Bullex Fiat Balance for each currency that you hold. You will not earn any interest on fiat at Bullex, nor on your Bullex Fiat Balance.

6.5 If your payment is not successful or if your payment method has insufficient funds, you authorise us, in our sole discretion, to cancel the deposit.

6.6 You may withdraw all or part of any Bullex Fiat held in your Bullex Fiat Balance at any time by selecting the relevant option at the Bullex Site and following the instructions. You should verify all transaction information prior to submitting any such request to us. You are responsible for providing us with the correct banking details.

6.7 If this Agreement is terminated, we will redeem any Bullex Fiat remaining in your Bullex Fiat Balance and transfer funds to the bank account you provide. If there is an amount due to Bullex, for instance for fees or costs, we are allowed to set off against any amount payable to you.

6.8 For any deposit, trade and/or withdrawal of Bullex Fiat and/or fiat on the bank account of Bullex we may conduct checks for the purposes of preventing fraud, money laundering, terrorist financing and other financial crimes. This may mean you are prevented or delayed from performing any such transaction.


7. Cryptocurrency Deposit Services

7.1 After logging into your Verified Bullex Account you will be able to deposit and/or withdraw Cryptocurrency to and from third party wallets by entering deposit or withdrawal requests in the Bullex Site. You will also be able to send and receive Cryptocurrency to and from the balances of other users of the Bullex Site by putting in send or receive requests (combined: “Cryptocurrency Transactions”).

7.2 In your Bullex Account you will be able to see your Cryptocurrency Balance. You may hold any of the Cryptocurrency we support. We will show your balance for each Cryptocurrency you hold.

7.3 We will process Cryptocurrency Transactions for you in accordance with the requests we receive from you. You should verify all transaction information prior to submitting any such request to us. We do not guarantee the identity of any party in the transaction. Cryptocurrency Transactions cannot be reversed once they have been broadcast to the relevant Cryptocurrency network.

7.4 Once submitted, a Cryptocurrency Transaction will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the Cryptocurrency network. Any Cryptocurrency Transaction is not complete while it is in a pending state. Cryptocurrency associated with a pending Cryptocurrency Transaction, will be designated accordingly, and will not be included in your Cryptocurrency Balance or be available to conduct Cryptocurrency and/or Exchange Transactions.

7.5 We may charge you network fees (or other relevant fees) to process a Cryptocurrency Transaction on your behalf. We will calculate the network fee in its discretion, although we will always notify you of the network fee at or before the time you authorize the Cryptocurrency Transaction.

7.6 We may refuse to process, suspend or cancel any pending Cryptocurrency Transaction as required by law or any court or other authority to which Bullex is subject in any jurisdiction. This may also be the case if such a Transaction is suspicious or is reported to us by a third party as potentially harmful or suspicious.

7.7 For any deposit, trade and/or withdrawal of Cryptocurrency we may conduct checks for the purposes of preventing fraud, money laundering, terrorist financing and other financial crimes. This may mean you are prevented or delayed from performing any such Transaction.

7.8 Bullex Services are only available in connection with the selected Cryptocurrencies that Bullex supports. These may change from time to time. Under no circumstances should you attempt to use your Cryptocurrency Balance to deposit, store, trade, or withdraw Cryptocurrencies that we do not support, although we will use reasonable efforts to help you move or sell Cryptocurrency that we no longer support. We assume no responsibility or liability in connection with any attempt to use your Cryptocurrency Balance for Cryptocurrencies that we do not support.

7.9 We securely store Cryptocurrency in our control in a combination of online and offline storage. As a result, it may be necessary for us to retrieve certain Cryptocurrency from offline storage in order to facilitate a Cryptocurrency Transaction in accordance with your requests. You acknowledge that this may delay the initiation or realization of such Cryptocurrency Transactions.

7.10 If this Agreement is terminated, we will redeem any Cryptocurrency remaining in your Cryptocurrency Balance and transfer these funds to an third party wallet, as provided by you. We do not own or control the underlying software protocols which govern the operation of Cryptocurrencies supported on the Bullex Site. Generally, the underlying protocols are open source and anyone can use, copy, modify, and distribute them. We assume no responsibility for the operation of the underlying protocols and we are not able to guarantee their functionality, security, or availability. You acknowledge and accept the risk that underlying software protocols relating to any Cryptocurrency you store in your Cryptocurrency Wallet may change.


8. Exchange Services

8.1 If you have a Verified Bullex Account you will be enabled to buy and sell Cryptocurrency and/or Bullex Fiat at the Bullex Site, with the Cryptocurrency Balance you hold in your Bullex Account (“Exchange Transactions”).

8.2 To enter an order to deposit, trade or withdraw Cryptocurrency, you must follow the relevant instructions on the Bullex Site. When such an order is initiated from your Bullex Account using your login credentials, we will assume that you authorized such transaction, unless you notify us otherwise.

8.3 By clicking the "Buy" or "Sell" button on the Bullex Site, you authorize Bullex to initiate the Exchange Transaction at the quoted buy or sell price, debit and/ or credit the Cryptocurrency Balance you hold in your Bullex Account and you agree to any applicable fees. You should verify all details carefully prior to submitting any order.

8.4 You cannot cancel, reverse, or change any transaction marked as complete or pending. When you enter an order on the Bullex Site, you can only withdraw your consent if the transaction only occurs until a specified event in the future happens. This may happen for example if you set up a limited order that will only be executed when the market price hits a certain, predefined level (a "Delayed Transaction"). In case of such Delayed Transaction, you may withdraw your order as long as the order has not been executed. You can do so by following the instructions on the Bullex Site.

8.5 We will make best efforts to fulfil all orders on the Bullex Site, but in some circumstances we may not be able to do so. This may be the case for example with a limited order if the market price doesn’t hit the predefined target price or if there is no counterparty for the Transaction.

8.6 Each completed Cryptocurrency Transaction (buy or sell) at the Bullex Site is subject to a Transaction Fee. The applicable Transaction Fee will be displayed to you prior to each transaction. We may adjust our Transaction Fees at any time.

8.7 For each Exchange Transaction the price of a given supported Cryptocurrency is quoted on the Bullex Site. This price is stated either as a buy price or as a sell price, which is the price at which you may buy or sell. You acknowledge that there may be a difference between the price you pay/ receive and the price that the counterparty of this Exchange Transaction pays/ receives, and that we may include a small margin in the quoted price. You agree to accept such a margin when you authorize an order.

8.8 We do not guarantee the availability of prices listed on the Bullex Site. We do not guarantee that you will be able to enter any orders at the Bullex Site and/or execute any Exchange Transactions at any particular price or time.

8.9 We may refuse to complete an order you have entered, where there is insufficient Cryptocurrency Balance to cover the Transaction and applicable fees at the time we receive the order.

8.10 If you believe you did not authorize a particular Transaction or that a Transaction was carried out incorrectly, you are required to contact us as soon as possible and in any case no later than 6 months after the relevant transaction occurred, by email free to support@bullex.eu. It is important that you regularly check your balances and your Transaction history regularly to ensure any unauthorized or incorrect transactions are identified and notified to us at the earliest possible opportunity. We are not responsible for any claim for unauthorized or incorrect Transactions unless you have notified us in accordance with this section.


9. Termination and Cancellation

9.1 Please note that we reserve the right to: 

9.1.1 refuse to complete or block, cancel or reverse a Transaction you have authorized;
9.1.2 suspend, restrict, or terminate your access to any or all of the Bullex Services, and/or 
9.1.3 deactivate or cancel your Bullex Account with immediate effect for any reason, including but not limited to where:
9.1.4 We are, in our reasonable opinion, required to do so by applicable law or any court or other authority to which we are subject in any jurisdiction.
9.1.5 We reasonably suspect you of acting in breach of this Agreement.
9.1.6 We have concerns that a Transaction is erroneous or about the security of your Bullex Account or we suspect the Bullex Services are being used in a fraudulent or unauthorized manner.
9.1.7 We suspect money laundering, terrorist financing, fraud, or any other financial crime.
9.1.8 Use of your Bullex Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Account activity; and/or
9.1.9 You take any action that may circumvent our controls such as opening multiple Bullex Accounts or abusing promotions which we may offer from time to time.
9.1.10 If we refuse to complete a Transaction and/or suspend or close your Bullex Account, or terminate or limit your use of Bullex Services in this way, we will (unless it would be unlawful for us to do so) provide you with notice of our actions and the reasons for refusal, suspension or closure and where appropriate, with the procedure for correcting any factual errors that led to the refusal, suspension or closure. In the event that we refuse to complete a Transaction and / or suspend your Bullex Account we will lift the suspension as soon as reasonably practicable once the reasons for refusal and / or suspension no longer exist. However, we are under no obligation to allow you to reinstate a Transaction at the same price or on the same terms as the suspended, reversed or cancelled transaction.

9.2 We may suspend, restrict, or terminate your access to any or all of the Bullex Services and/or deactivate or cancel your Bullex Account, without reason by giving you two months notice. You acknowledge that our decision to take certain actions, including limiting access to, suspending, or closing your Bullex Account, may be based on confidential criteria that are essential to our risk management and security protocols. You agree that we are under no obligation to disclose the details of its risk management and security procedures to you.

9.3 On termination of this Agreement, unless prohibited by applicable law or by any court or other order to which Bullex is subject in any jurisdiction, you may:

9.3.1 Transfer Cryptocurrency for ninety (90) days thereafter; and / or
9.3.2 Transfer Bullex Fiat at any point in the six-year period commencing with the date of the termination of the Agreement.

9.4 If we suspend or close your Bullex Account, or terminate your use of Bullex Services for any reason, we reserve the right to require you to complete verification procedures before permitting you with transfer or withdraw Cryptocurrency.

9.5 You may cancel your Bullex Account at any time by withdrawing all balances and contacting us at support@bullex.eu You will not be charged for cancelling your Bullex Account, although you will be required to pay any outstanding amounts owed to us. You authorize us to cancel or suspend any pending transactions at the time of cancellation.



10.1 You will indemnify, defend and hold harmless Bullex and its affiliates (and their respective officers, directors, employees, directors, agents and representatives) from and against any and all costs arising out of any claim, action, audit, investigation, inquiry or other proceeding instituted by a person or entity that arises out of or relates to:

10.1.1 any actual or alleged breach of your representations, warranties, or obligations set forth in this Agreement; and
10.1.2 your wrongful or improper use of the Bullex Services.

10.2 Within the limits of applicable law, Bullex shall only be liable to you for direct loss or damage resulting from attributable failure to comply with this Agreement. We will not be liable for any direct or indirect damages or losses arising in connection with this Agreement, the (use of) the Services or any materials relating thereto.

10.3 For the avoidance of doubt and notwithstanding the generality of the foregoing, no liability shall exist in any manner whatsoever for:

10.3.1 differences in prices resulting from delayed processing of buy- or sell orders;
10.3.2 cancellation of orders by reason of clearly misquoted prices;
10.3.3 any damage incurred relating to the Bullex wallet features;
10.3.4 any losses resulting from hacks, system failures and/or regulatory actions; and
10.3.4 any indirect loss (including consequential loss, loss of income and profit, loss of data and non-material loss).
10.3.5 Except in case of intentional misconduct or willful recklessness by Bullex management or managerial staff, the liability of Bullex shall in all cases be limited to the amount paid by you for the Services during the month prior to the moment the cause of the damage or loss occurred.


11. Customer feedback, Complaints and Dispute Resolution

11.1 If you have any feedback, questions, or complaints, contact us by sending an email to support@bullex.eu. When you contact us please provide us with your name, address, and any other information we may need to identify you, your Bullex Account, and the transaction on which you have feedback, questions, or complaints.

11.2 In the event of a complaint, please set out the cause of your complaint, how you would like us to resolve the complaint and any other information you believe to be relevant. We will consider your complaint without prejudice based on the information you have provided and any information available at Bullex. We will respond by email addressing all points raised in your complaint. In case we are unable to respond to your complaint within 15 business days we will send you a holding reply indicating the reasons for a delay in answering your complaint and specifying the deadline by which we will respond to your complaint.

11.3 Any offer of resolution made to you will only become binding on us if you confirm by email that you accept the resolution. An offer of resolution will not constitute any admission by us of any wrongdoing or liability regarding the subject matter of the complaint.

11.4 Any disputes that may arise between Parties which cannot be settled amicably, can only be brought before the competent court in Amsterdam, The Netherlands.

11.5 The Parties agree to keep confidential all matters relating to any complaint, including related court proceedings, to the greatest extent practicable. For purposes of this provision, references to the parties also include respective subsidiaries, affiliates, agents, employees, predecessors, successors and assigns as well as users of the Bullex Services. Nothing in this Section shall be construed as preventing either party from seeking conservatory or similar interim relief in any court of competent jurisdiction.


12. Data protection

12.1 You acknowledge and agree that we are required to process personal data in relation to you (if you are an individual), and personal data that you have provided or in the future provide to us in relation to your employees and other associated or other individuals, in connection with this Agreement, or the Bullex Services. Accordingly, you represent and warrant that:

12.1.1 your disclosure to us of any personal data relating to individuals other than yourself was or will be made in accordance with all applicable data protection and data privacy laws, and those data are accurate, up to date and relevant when disclosed;
12.1.2 before providing any such personal data to us, you have read and understood our Privacy Policy, attached to this Agreement and a copy of which is also available at every page of the Site under Privacy Policy, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided a copy of that Privacy Policy (as amended from time to time), to that individual; and
12.1.3 if from time to time we provide you with a replacement version of the Privacy Policy, you will promptly read that notice and provide a copy to any individual whose personal data you have provided to us.


13. Miscellaneous

13.1 This Agreement shall be governed by and construed and enforced in accordance with the laws of The Netherlands. This Agreement and any information or notifications that you or we are to provide should be in English. Any translation of this Agreement and the Privacy Policy is provided for your convenience only. In the event of any inconsistency, the English language version of this Agreement or other documents shall prevail.

13.2 This Agreement supersedes all prior or contemporaneous representations, understandings, agreements, or communications between User and Bullex or any of its Affiliates, whether written or verbal, regarding the subject matter of this Agreement.

13.3 Should any provision of this Agreement, or any provision incorporated into this Agreement in the future, be or become illegal, invalid or unenforceable under the laws of any jurisdiction, the legality, validity or enforceability in that jurisdiction of the other provisions of this Agreement shall not be affected, while such a provision shall be interpreted as closely as possible like it should be legal, valid or enforceable.

13.4 It is your responsibility to determine whether, and to what extent, any taxes apply to any transactions you conduct through the Bullex Site, and to withhold, collect, report and remit the correct amounts of taxes to the appropriate tax authorities. Your transaction history is available through your Bullex Account.

13.5 If we hold Cryptocurrency for you, and we are unable to contact you and have no record of your use of the Bullex Services for several years, applicable law may require us to report the Cryptocurrency as unclaimed property to the authorities in certain jurisdictions. We will try to contact you at the address shown in our records, but if we are unable to, we may be required to deliver any such funds to the authorities in certain jurisdictions as unclaimed property. We reserve the right to deduct a dormancy fee or other administrative charges from such unclaimed funds, as permitted by applicable law.

13.6 All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, the sections relating to suspension or termination, Bullex Account cancellation, debts owed to Bullex, general use of the Bullex Site, disputes with Bullex, and general provisions, will continue to be binding and operate after the termination or expiration of this Agreement.



Published: January 1st,  2019

The Bullex website as hosted on Bullex.eu and its subdomains (the “Site”) is operated by Bullex NL B.V., a Dutch limited liability company.

Please note that Bullex aims to provide information on the Site which is as complete, accurate and timely as possible. However, Bullex cannot guarantee accuracy, suitability, reliability, completeness of the content throughout the Site and other communication, and will not accept liability for any loss or damage that may arise directly or indirectly from such content, the use of the content and/or the use of the Site.

Information on the Bullex Site is provided for the primary purpose of facilitating Users to arrive at independent decisions. Bullex does not provide any investment advice and any information presented on the Site – in any whatsoever – cannot be interpreted as advice or counsel. Bullex does not accept liability for the use or interpretation of information as presented on the Site or other affiliated communication mediums. Please be aware that there may be no regulatory oversight on the Site in your jurisdiction.


You think your privacy is important? So do we!

Published: January 1st,  2019

Bullex (“Bullex”, “we”, “our” or “us”) takes your privacy very seriously. We therefore only collect information that we need to provide you with our Bullex Services, to understand how you use them and to learn how we can continuously improve them. We will never make your data available to third parties for commercial purposes.

This Privacy Policy applies to the use of the Bullex website (https://bullex.eu), subsidiary websites, API’s, or Bullex apps (Android & IOS), (collectively referred to as the "Bullex Site") and all services provided by Bullex (“Bullex Services”). If you do not agree with our practices, please do not use the Bullex Site and any of the Bullex Services it offers.

We may occasionally modify our Privacy Policy. All changes will be effective upon posting on the Site. With the publication of a new version the validity of all previous versions is cancelled. You can determine when the Privacy Policy was last revised at the top of this page. You agree to be bound by any changes if you continue to use the Bullex Site after these changes have been posted.

If you have any questions or concerns regarding this Privacy Policy or if you have a suspicion of a data breach, please contact our Privacy Officer at info@bullex.eu. You can also contact us at this email address in case you want to receive a complete overview of all data we have collected about you.


What information does Bullex collect and why?

We collect two categories of information:

  • We collect personal information you provide to us when you want to be informed about the progress of Bullex and/or when you create a Bullex Account and use our Bullex Services (“Personal Information”). Bullex will collect personal information, including formal identification documents, in order to comply with global industry regulatory standards including Know-Your-Customer (KYC), Anti-Money Laundering (AML), and Counter Terrorist Financing (CTF) before providing you a Verified Bullex Account and give you access to Bullex Services. Personal Information also includes information we collect as you use our Bullex services.
  • Aggregate and Anonymous Data: Aggregate and anonymous data is information that does not identify you specifically, including data collected automatically when you enter the Bullex Site (“Additional Data”). This may be collected using cookies, pixel tags, web beacons, browser analysis tools and web server logs. The data collected includes numbers of times you visit, how you navigate the Bullex Site, information from the devices you use to access the Bullex Site or mobile platform, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Our server logs may also record the IP addresses of the devices you use to interact with the Bullex Site. We may also collect information about a website you were visiting before you came to the Bullex Site and any website you visit after you leave the Bullex Site, if this information is supplied to us by your browser. Additional Data also includes some data collected by location services.

Below you find in full detail what Personal data we collect and why.


Personal Information Why we collect it
Name, date of birth, address, copy of ID card, Proof or residence  We collect this data as part of our profile verification process. We have to make sure who you are in order to comply with ‘Know-Your-Customer” regulation. This means we compare the information on the copy of your ID card and a Proof of residence to the other information you have provided when registering at the Bullex Site.
Email Address  Address If you choose to receive our email newsletter we will send it to the email address you provide. 

We also collect your email address as part of the account creation process. Your email address is required every time you log in. When you create an account we will use your email address for functional messages including email confirmation, customer service and messages required for the Bullex Services we provide you.
Bank Account information, Public keys Wallets, requests and orders you enter at the Bullex Site, transaction details, balances you hold at Bullex 

We collect this information dependent of your use of the Bullex Services. This information is necessary to provide you with the Bullex Services. 

When you log into your Bullex Account you will be able to see an overview of your orders, requests and transactions, plus an overview of the balances you hold at Bullex.

How does Bullex use my information?

We use Personal Information and Additional Data to:

  • Build, operate and continuously improve the Bullex Site and Bullex Services;
  • Perform user analytics;
  • Provide customer support; Communicate with you and provide additional information that may be of interest to you;
  • Send you reminders, technical notices, updates, security alerts and support, and administrative messages;
    Manage our everyday business needs such as Bullex Site and Bullex Services administration, analytics, fraud prevention, or to comply with the law.


What is Bullex’s legal basis for processing my data?

Bullex may process your personal data for the purposes mentioned in this policy on the basis of:

  • Entering into and performing of an agreement;
    Being able to comply with regulatory or policy requirements or requirements;
  • Pursuing a legitimate interest;
  • With your consent.


Does Bullex share my information with 3rd parties?

Bullex will never sell your Personal Information or Additional Data to third parties or otherwise share your data for commercial purposes. We will not display on the Bullex Site, or otherwise disclose your Personal Information to any third party unless it is necessary to provide the Bullex Services, when required by law, or if we have good faith belief that such action is reasonably necessary to:

  • Comply with current judicial proceedings, a court order or legal process served on us;
  • protect and defend our rights, property and interests, including by enforcing our agreements, policies and Terms of Use;
  • respond to claims that any submitted content violates the rights of third parties;
  • respond to your requests for customer service;
    protect the rights, property or personal safety of Bullex, its members and the public;
  • in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or;
  • with your consent to share the information.


How does Bullex store & protect my information?
We understand how important your privacy is, which is why Bullex maintains (and requires its IT service providers to maintain) appropriate safeguards to protect the security and confidentiality of the Personal Information you entrust us.

The Bullex Site and your customer information are primarily hosted within the EU and fall under the General Data Protection Regulation of the EU. To provide Bullex Services to you Bullex cooperates with a number of IT Service providers that may be based outside of the EU. If you are located in the EU, your Personal Data may be transferred to such service providers in non-EU countries that are recognized by the European Commission as providing an adequate level of data protection according to EU standards (the full list of these countries is available here). For transfers from the EU to countries not considered adequate by the European Commission, we have put in place adequate measures. Our IT service provider located in the USA are certified members pursuant to the EU/US Privacy Shield, to protect your Personal data.

We employ generally accepted industry standards to protect your Personal Information and we continuously strive to protect your information and privacy as much as we can. Unfortunately, no data transmission over Wi-Fi or the Internet can be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online.

Please recognize that you play a vital role in protecting your own Personal Information. When creating a Bullex Account, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

If you have reason to believe that your data is no longer secure, please contact us as soon as possible at info@bullex.eu.


How long does Bullex keep my information?
We store your Personal Information securely as long as you decide to use our Bullex Services. We will only retain your Personal Information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes.


How can I access/ change/ remove my Personal Information?
You can opt-out of receiving our emails by following the unsubscribe instructions included in each email or by contacting us at info@bullex.eu.

You can modify or delete the Personal Information you have provided to us by logging into you Bullex Account and updating your profile. Please note that we may have to restart our verification processes after you changed your Personal Information.

In case you want us to completely remove your information, please contact us at info@bullex.eu.