Electronic transaction and supplier disclosures

The supplier of Coinfig is Silver Sixpence (Pty) Ltd ("Sixpence", "we", "us"), a private company registered in South Africa.

Coinfig is a crypto tax calculation and reporting tool. The main characteristics, pricing, term, payment, cancellation and refund terms, service limitations, privacy terms and acceptable use requirements are set out in these Terms and the policies referenced in these Terms.

Unless expressly stated otherwise, Silver Sixpence (Pty) Ltd does not subscribe to a specific industry code of conduct or self-regulatory body for Coinfig.

Complaints and support requests may be submitted to support@coinfig.tax.

Important: limits on our responsibility

Please read these points before you agree. They limit our responsibility to you and put certain risks on you:

  • Coinfig is a calculation tool, not tax advice. Calculations and reports may contain errors, and you must review them (sections 3.2, 7, 7A and 12).
  • We are not responsible for penalties, interest or assessments imposed by SARS or any other tax authority (section 15.2).
  • Our total liability is capped (section 15.3). If you breach these Terms, you may be responsible for losses you cause us (section 16).
  • Reports are for you alone. Other people may not rely on them (section 12B).

1) Acceptance of these Terms

By creating an account, accessing, or using Coinfig ("the Service"), you agree to these Terms. If you do not agree, do not use the Service.

We may ask you to confirm your acceptance of these Terms before each payment. That confirmation forms part of your agreement with us.

If you use Coinfig on behalf of another person or entity, you confirm you have authority to bind them. If you are an organisation using Coinfig for your clients, the Enterprise Addendum also applies.

If you use Coinfig for the tax affairs of a company, trust or other entity, these Terms apply to that entity as the account holder. The Enterprise Addendum applies only where an organisation uses Coinfig to process data for its own clients.

Consumers and Business Users

You are a Business User if you open or use an account for a company, close corporation, trust, partnership or other organisation, or in the course of your trade, business or profession. Otherwise you are a Consumer. Some sections of these Terms apply differently to Consumers and Business Users, and those sections say so. If the law of your country treats you as a consumer even though you are a Business User, for example a small business under the South African Consumer Protection Act, the Consumer terms apply to you.

2) Eligibility and legal capacity

You may use Coinfig only if you have the legal capacity to enter into a binding agreement under the law that applies to you.

You must be at least 18 years old to create an account or use the Service on your own behalf. Do not create an account for a person under 18 unless you have lawful authority to act for them and Coinfig has expressly agreed to that use. If we become aware that an account does not meet this section, we may suspend or close it.

3) What Coinfig is (and is not)

3.1 What it is

Coinfig is a crypto tax calculation and reporting tool that:

  • Calculates gains and losses using the cost-basis method selected in your settings or applied by default for your tax jurisdiction (for South Africa, FIFO (first-in, first-out) unless you choose otherwise).
  • Produces supporting reports intended to assist with preparation of tax returns.
  • Provides a data completeness score based on the data you submit and/or connect.

Coinfig's default tax treatments are designed not to rely on draft or unsettled guidance. Advanced tax settings let you or your tax practitioner choose other treatments, such as paragraph 42 or the treatment of airdrops and forks. Choosing them is your decision and is not advice from Coinfig.

3.2 What it is not

Coinfig:

  • Does not validate blockchain data or guarantee that imported data is complete or accurate.
  • Does not guarantee that calculations or reports are free of errors. Calculations and reports may contain errors.
  • Is not endorsed by SARS or any other tax authority.
  • Does not provide tax advice, legal advice, financial advice, or investment advice.
  • Does not file or submit returns to SARS or any other tax authority on your behalf.
  • Does not guarantee acceptance by, or any assessment, outcome, refund, audit result or dispute outcome with, SARS or any other tax, revenue or regulatory authority in any jurisdiction (each a "Tax Authority").

You remain responsible for your tax affairs, filings, and compliance.

3.3 Jurisdictions

These Terms apply wherever you use Coinfig. Tax rules, cost-basis methods and report formats differ by country, and the level of support differs too. Each country's page and your jurisdiction setting in the app show what Coinfig supports for that country. Nothing in these Terms limits any consumer rights that apply to you under the law of your country and cannot lawfully be excluded.

4) Your account and sign-in methods

4.1 Account access

Coinfig supports:

  • Email and password login.
  • Single sign-on (SSO), currently Google, Microsoft and the other providers shown at sign-in.

We may add, remove, or change authentication methods.

4.2 Your responsibility

You are responsible for:

  • Maintaining the confidentiality of credentials.
  • Securing your email and SSO accounts.
  • All activity under your account.
  • Telling us promptly at support@coinfig.tax if you suspect that your credentials, email or SSO account have been compromised.

To the extent permitted by law, Sixpence is not liable for loss caused by unauthorised use of your credentials, email account or SSO account, except where that loss results from our negligence.

4.3 Multi-factor authentication

Coinfig supports multi-factor authentication (MFA). We recommend enabling MFA on your account. You should also use strong passwords and secure your email or SSO account, including any security features offered by your sign-in provider, such as Google or Microsoft.

5) Data sources, integrations, and API keys

5.1 Integrations

Coinfig may support exchange and wallet data via:

  • API connections using keys generated by you, read-only wherever the exchange offers that (see 5.4).
  • CSV uploads, including a general template and potentially direct exchange statement formats over time.

We may add, remove, or change integrations.

5.2 Your responsibility for inputs

You are responsible for:

  • The completeness and accuracy of all data you upload, paste, or connect.
  • Providing relevant transaction history and context needed for correct calculation, including deposits, withdrawals, and transfers.
  • Reviewing outputs before relying on them.
  • Reviewing and correcting automatically assigned transaction classifications.
  • Determining whether transactions are capital or revenue in nature.
  • Assigning or confirming base costs, acquisition values, and disposal treatment where required.
  • Ensuring that all relevant crypto activity, including off-platform wallet transfers and transactions across multiple exchanges or wallets, has been provided.
  • Selecting the correct tax year or financial year-end for the report.

5.3 Audit log of user changes

Coinfig may maintain an audit log of user changes to raw data and calculation inputs, including changes to transaction classifications, base costs, capital-versus-income assignments, tax-year settings, and other report assumptions. Audit logs are maintained to support transparency, troubleshooting, report review, data integrity, and, where available, audit-log exports.

5.4 Storage of API keys

If you choose to store API keys in Coinfig for syncing:

  • API credentials are encrypted in storage.
  • We apply reasonable access controls and safeguards.

Despite safeguards, no system is perfectly secure.

You are responsible for the permissions on any API keys or credentials you connect to Coinfig. Create them as read-only wherever the exchange offers that, and never grant trading or withdrawal permissions. Coinfig does not require and will not request permissions to trade or withdraw crypto assets. Some exchanges only offer access to certain data together with a narrower ability to move funds within your own account there. For example, AltCoinTrader's Savings permission is needed to read savings interest and also allows moving funds between your wallet and your savings account. Where Coinfig asks for a permission like that, it tells you what else the permission allows, the permission is optional, and Coinfig does not use it to move funds. If you create or provide credentials with broader permissions than Coinfig asks for, you are responsible for revoking or replacing them immediately.

To the extent permitted by law, Sixpence is not liable for any loss of crypto assets, or any action taken on an exchange or wallet account, that results from credentials you connect with permissions beyond read-only, or from a compromise of an exchange or wallet.

6) Data completeness score

The completeness score is a tool-generated indicator. It:

  • Is not an audit opinion or assurance.
  • Is not a guarantee of correctness or of acceptance by any Tax Authority.
  • Should be treated as decision support only.

7) Calculation assumptions, classifications and missing data

Coinfig may automatically classify certain transactions or apply default calculation assumptions where the available data is incomplete, ambiguous, or insufficiently reconciled.

Where deposits, withdrawals, or transfers cannot be matched or supported by sufficient acquisition or disposal data, Coinfig may apply conservative assumptions, including treating unmatched acquisitions as zero-cost acquisitions and unmatched disposals as market-value disposals, depending on the calculation context and report methodology.

Coinfig will, where reasonably possible, indicate where classifications or assumptions have been automatically applied. You remain responsible for reviewing, correcting, and approving classifications, cost-basis changes, and capital-versus-income assignments before relying on any report.

To the extent permitted by law, Sixpence is not responsible for incorrect outcomes caused by missing data, incomplete transaction histories, incorrect source statements, incorrect user classifications, manual edits, unsupported assumptions, or failure to review automatically assigned classifications.

7A) Known limitations

Coinfig's calculations will not be accurate in every case. In particular:

  • Some exchanges' APIs do not return a full transaction history. You may need to upload CSV statements to complete it.
  • Importing the same activity from both an API connection and a CSV file can create duplicates. Review flagged duplicates before relying on a report.
  • Very small balances and tokens identified as spam or scams are left out of calculations. The app and your report list what was left out.
  • Values for crypto received from accounts you have not connected are estimated at the market price on the day.
  • Transfers between your own accounts that Coinfig cannot match may be treated as a sale or a purchase until you review them. Data Completeness shows how many remain.
  • Some tokens, DeFi activity and NFTs have no reliable market price, so their values may be estimated or missing.
  • Treatments that rely on draft or unsettled SARS guidance, including paragraph 42 and the treatment of airdrops and forks, are off by default. You or your tax practitioner can turn them on in Advanced tax settings.
  • Support differs by country. In some countries only one cost-basis method is available.
  • We update calculation methods and report formats, so a report generated before an update may differ from one generated after it. We aim to show a notice in the app, where reasonably practicable, when an update may affect a report you have already generated.

8) Acceptable Use Policy

Your use of Coinfig must comply with our Acceptable Use Policy ("AUP"). The AUP is incorporated into these Terms by reference and forms part of the binding agreement between you and Sixpence.

You must not use the Service in any way that the AUP prohibits, including unlawful use, unauthorised processing of third-party data, security violations, disruption of the Service, reverse engineering, or unauthorised sharing or resale of access.

We may suspend or terminate your access, and take other enforcement actions described in the AUP and these Terms, if we reasonably believe you have breached the AUP or pose a security or legal risk.

If there is any conflict between the AUP and these Terms, the stricter rule applies, and where applicable the Enterprise Addendum will govern enterprise use.

9) Fees, term, renewals, and refunds

9.1 Individual users (annual plan)

  • Individual access is an annual plan granting 12 months of access.
  • Depending on the payment method, your plan either renews automatically each year unless cancelled, or is a once-off annual payment that does not renew. Checkout shows which applies before you pay.
  • If your plan renews automatically, you can cancel at any time and retain access until the end of the current paid period.

If your plan renews automatically, we aim to remind you before it renews, with the renewal date, the price and how to cancel. If you are a Consumer in South Africa, you may also cancel at any time on 20 business days' notice. We will then refund the unused part of your fees, less any reasonable cancellation charge the Consumer Protection Act allows.

If you cancel and the paid period expires, your access to certain functionality may be restricted. Data may continue to be retained in accordance with our Privacy Notice unless you request account deletion or data export, subject to legal, security, backup, and audit-log limitations. Reports for tax years you have already unlocked remain accessible after your access period ends, while Coinfig operates and subject to section 10.5.

Coinfig is not a records-retention service. You must download and keep your own copies of reports and supporting records for as long as the law of your country requires. If a Free account that has never had a paid plan is not used for 24 months, we may delete it. Where reasonably practicable, we will email you before we do, so that you can sign in to keep it or download your data.

Prices are displayed on our pricing pages and at checkout, in the currency shown there (for example South African rand, US dollars, euros or pounds sterling, depending on your country). Where we do not offer a price in your local currency, the price is shown in US dollars and labelled as such. Where VAT, GST or another sales tax applies, we will state at checkout and on the invoice whether it is included in the price or added to it. Payment methods, billing details, and any applicable taxes will be shown before purchase confirmation. We may change pricing from time to time, but pricing changes will not affect an access period already purchased unless otherwise agreed in writing.

We do not store full card details unless expressly stated. Card or payment information is processed by the applicable payment provider.

9.2 Enterprise subscriptions

Enterprise subscriptions are governed by the Enterprise Addendum.

9.3 No trial, refunds and statutory rights

There is no free trial of paid plans unless expressly offered in writing. The Free plan is described on the pricing page.

We do not offer refunds for a change of mind once you have used a paid plan, but you keep every right the law gives you. These include:

  • A cooling-off right where the law provides one, for example under the Electronic Communications and Transactions Act. This right may end once the paid service has started with your agreement, such as when you generate a paid report.
  • If you are a Consumer in South Africa, a refund of the unused part of your fees if you cancel an automatically renewing plan under section 9.1.
  • A remedy if the Service is not provided with reasonable care and skill.

By purchasing access to Coinfig and using the Service, you request and consent to the Service beginning immediately. Where applicable law provides a cooling-off, cancellation, or refund right, that right will apply only to the extent required by law and may be limited where the Service has already begun with your consent or where statutory exclusions apply.

If you are a Consumer in Ireland or elsewhere in the European Economic Area, you may withdraw from a purchase within 14 days of making it, without giving a reason. To withdraw, tell us clearly at support@coinfig.tax before the 14 days end. We will refund you within 14 days of hearing from you, using the payment method you used. If you asked us to start immediately and acknowledged the effect on this right, you lose it once the service has been fully provided, and if you withdraw before then you may have to pay a proportionate amount for what you have already received. This paragraph applies to you instead of anything else in this section 9.3 that says otherwise.

Nothing in these Terms limits or excludes any consumer right that cannot lawfully be limited or excluded.

9.4 Free plan

Free access is provided without charge, does not include a tax report, and may be changed, limited or withdrawn at any time.

10) Availability, maintenance and changes to the Service

10.1 No uptime commitment

Coinfig is provided on an "as available" basis. We do not provide any uptime, availability, response-time, recovery-time, or service-level commitment unless expressly agreed in a separate written agreement.

The Service may be unavailable, delayed, degraded, or interrupted from time to time, including due to maintenance, upgrades, deployments, third-party service failures, hosting interruptions, connectivity issues, security incidents, force majeure events, or other operational reasons.

10.2 Scheduled maintenance

We may perform scheduled maintenance, upgrades, fixes, deployments, or infrastructure changes from time to time. Scheduled maintenance may affect access to the Service, including login, data imports, API syncing, CSV uploads, calculations, report generation, exports, or support functionality.

Where reasonably practicable, we will notify users in advance of scheduled maintenance that is expected to materially affect access to the Service. Notice may be provided by email, in-app notification, website notice, status page, or any other reasonable communication method.

10.3 Emergency maintenance and unplanned outages

We may perform emergency maintenance or suspend access without advance notice where we reasonably consider it necessary to protect the Service, user data, system integrity, security, availability, or legal compliance.

In the case of unplanned outages or emergency maintenance, we will use reasonable efforts to notify affected users as soon as practicable, taking into account the nature, urgency, and impact of the issue.

10.4 User responsibility during downtime

You remain responsible for your own tax affairs, deadlines, filings, payments, record-keeping, and compliance obligations, even if the Service is unavailable, delayed, or degraded. You should not rely on uninterrupted access to Coinfig as your only means of meeting tax deadlines or preserving tax records.

To the maximum extent permitted by law, Sixpence is not liable for losses, penalties, interest, missed deadlines, filing delays, data-sync delays, reporting delays, or other consequences arising from downtime, maintenance, outages, or service interruptions.

10.5 Changes to the Service

We may modify, improve, suspend, discontinue, or replace any part of the Service from time to time, including integrations, report formats, calculation workflows, import methods, user-interface elements, and support features. Where a material change is expected to materially affect paid access or core functionality, we will take reasonable steps to notify users.

10.6 Preview, beta and automated features

Features we label as preview or beta, and automated features such as automatic transaction classification, are provided "as is". They may change or be withdrawn at any time, and to the extent permitted by law we have no liability for them. You must review their output before relying on it.

11) Intellectual property

Coinfig, including software, templates, interfaces, and branding, is owned by Sixpence or its licensors. You receive a limited, non-exclusive, non-transferable right to use the Service during any period in which you have access, including the Free plan, subject to these Terms.

User Data

As between you and Sixpence, you retain ownership of the data, files, records, and information that you upload, connect, classify, edit, or otherwise provide to Coinfig ("User Data").

You grant Sixpence a limited licence to host, process, transmit, analyse, display, export, and otherwise use User Data as necessary to provide, secure, maintain, and improve the Service, generate reports, provide support, comply with law, and exercise rights under these Terms. It also covers producing aggregated statistics about how Coinfig is used, which cannot identify you, to improve Coinfig.

This licence continues for as long as needed to provide the Service and for any retention period permitted under these Terms, the Privacy Notice, or applicable law.

Feedback

If you send us suggestions or feedback about Coinfig, we may use them without restriction or payment to you.

12) Reports, calculations and permitted reliance

Coinfig reports are generated from the data, classifications, tax-year settings, and assumptions available in the Service at the time the report is produced.

Reports are intended as supporting documents only. They are not tax advice, legal advice, financial advice, investment advice, audit opinions, assurance reports, submissions to any Tax Authority, or guarantees of tax treatment.

You are responsible for reviewing and validating:

  • All imported, uploaded, connected, classified, or manually edited data.
  • Transaction classifications, including whether amounts are capital or revenue in nature.
  • Base cost inputs, acquisition values, disposal values, and missing-data assumptions.
  • The applicable tax year or financial year-end used for the calculation.
  • Whether the cost-basis method you selected, or the default for your jurisdiction (such as FIFO), is appropriate for your circumstances.
  • Whether the report should be reviewed by a qualified tax practitioner before use.

Coinfig does not have knowledge of your wider financial position, non-crypto income, deductions, allowances, assessed losses, tax registrations, personal circumstances, business activities, or other facts that may affect your tax treatment.

12A) Changes in figures

Figures can change when you re-sync or add sources, when exchanges, price-feed or blockchain-data providers update or correct their data, when classifications or settings change, or when our calculation methodology is updated. Each report is a snapshot as at its generation date. We have no obligation to update reports already generated.

12B) No reliance by third parties

Reports are prepared solely for the account holder. No other person, including an accountant, bank, lender or an Enterprise Customer's End Client, may rely on them, and Sixpence owes no duty of care to any third party. There are no third-party beneficiaries of these Terms. A tax practitioner or other adviser you appoint may use your reports to help you prepare your return, but they must check the figures themselves and cannot rely on them as against Sixpence.

13) Your responsibilities and acknowledgements

You acknowledge:

  • SARS or any other Tax Authority may apply rules, interpretations, and audit requirements that differ from Coinfig outputs.
  • Penalties, interest, late payment consequences, and filing decisions are your responsibility.
  • If you are preparing documents for others, you are responsible for having a valid mandate and meeting professional standards.
  • If you do not select or confirm a tax year-end, Coinfig may assume the South African individual tax year ending on the last day of February. You are responsible for changing this where a different financial year-end applies, including for companies, trusts, or other non-individual taxpayers. If you are not a South African taxpayer, you must set the tax year-end that applies to you.

14) Privacy, POPIA, and data use

14.1 Data we process

Coinfig may process:

  • Name and surname, and, if you choose to provide them, your ID number and tax number.
  • Wallet addresses and withdrawal or deposit addresses.
  • Transaction histories and transaction identifiers.
  • User edits, transaction classifications, base cost changes, capital-versus-income assignments, tax-year settings, report assumptions, and audit-log information.

14.2 Hosting, retention, export, and deletion

Our main application and data infrastructure is hosted in South Africa. Some service providers process limited data outside South Africa, as described in section 7 of the Privacy Notice. Importing a file in a layout Coinfig does not yet recognise is part of the Service and includes an automated step in which its column headers and a small sample of its rows are processed by an AI service (Cloudflare Workers AI), which may run outside South Africa, only to work out how to read the file. This step is necessary to import such a file. Files in recognised layouts are read by our own systems. Data is retained, exported, deleted, or de-identified in accordance with our Privacy Notice, including any applicable legal, security, backup, billing, report-integrity, and audit-log limitations. You may request data export or account deletion via support@coinfig.tax, subject to reasonable identity verification.

14.3 Statistics and improvement

We may use aggregated statistics about how Coinfig is used, for example how many transactions are imported, which exchanges are connected and how often reports are generated, to maintain, secure, test and improve Coinfig. These statistics cannot reasonably identify you, your wallets or your transactions. We do not use your wallet addresses, your transaction history or your reports for any other Sixpence product, and we do not sell, publish or provide them to anyone, except to provide, secure and improve the Service or where the law requires it.

14.4 POPIA

We process personal information in line with POPIA principles, including lawfulness, minimality, purpose limitation, safeguards, and data subject rights. If you are in Ireland or elsewhere in the European Economic Area, the GDPR also applies, as described in section 16 of the Privacy Notice.

15) Liability limitations

15.1 No warranties

Nothing in these Terms excludes or limits any liability or consumer right that cannot lawfully be excluded or limited under applicable law, including any rights that may apply under South African consumer protection, electronic communications, data protection, or other mandatory laws.

The Service is provided "as is" and "as available". We do not warrant that:

  • Outputs are complete, accurate, or accepted by any Tax Authority.
  • The Service will be uninterrupted or error-free.
  • Source data from exchanges, wallets, CSV files, APIs, user uploads, pricing sources, or third-party price feeds is accurate, complete, or independently verified.
  • Automatic classifications, unmatched-transfer assumptions, zero-cost acquisition assumptions, or market-disposal assumptions are correct for your circumstances.
  • Data interpreted, parsed or classified by automated or AI-assisted tools, including uploaded CSV and PDF files, is correct.
  • The cost-basis method you selected, or the default for your jurisdiction (such as FIFO), is the correct or only permissible method for your specific tax treatment.
  • The report captures tax consequences arising from non-crypto information not provided to Coinfig.

15.2 Excluded losses

To the maximum extent permitted by law, Sixpence is not liable for:

  • Penalties, interest, additional assessments, disallowances, late payment consequences, or audit outcomes imposed by any Tax Authority.
  • Indirect, special, incidental, or consequential losses.
  • Loss of profit, opportunity, or reputation.
  • Loss or corruption of data.
  • Loss of crypto assets.
  • Unauthorised access to your account or to any exchange or wallet account you connect, except where it results from our negligence.
  • Fees of accountants or tax practitioners, and the cost of amending or re-filing a return.
  • Failures of exchanges, wallets, price feeds, blockchain-data providers, authentication, hosting or other third-party services.

15.3 Liability cap

To the maximum extent permitted by law, the total liability of Sixpence and the persons listed in section 15.4, for all claims together arising out of or in connection with these Terms, the Service, any report or this website, whether in contract, delict (including negligence), misrepresentation, under statute or otherwise, and including claims that fall outside these Terms, is limited to the fees you paid for each tax year whose report is affected by the event that gave rise to the claim, or, where no report is affected, the fees you paid in the 12 months before that event. Where no fees were paid, Sixpence has no liability to you, except liability that cannot lawfully be excluded.

Nothing in these Terms limits or excludes liability for fraud, gross negligence, wilful misconduct, death or personal injury, or any liability or right that cannot lawfully be limited or excluded, including your rights under the Consumer Protection Act.

15.4 Who is protected

The limits and exclusions in this section 15 and the indemnity in section 16 also protect Sixpence's directors, officers, employees, contractors, affiliates, licensors and service providers.

15.5 Telling us about a claim

If you are a Business User, you must notify us in writing of any claim within 12 months of becoming aware of it, and in any event within three years of the event that gave rise to it.

If you are a Consumer, please tell us about a problem as soon as you can so that we can try to fix it. This does not affect the time you have to bring a claim under the law.

15.6 Third-party reviews

Any review of our tax methodology by an independent firm, including any firm named on our website, covers the general principles of our calculation methodology only. It is not a review, audit or assurance of any individual report, creates no relationship between you and that firm, and does not change your responsibilities under these Terms.

16) Your responsibility for losses you cause

16.1 Consumers

If you are a Consumer, you are responsible for losses and reasonable legal costs that Sixpence suffers because you breached these Terms or uploaded data about another person that you had no right to share. You are not responsible for losses caused by an error in Coinfig itself.

16.2 Business Users

If you are a Business User, you indemnify Sixpence against claims, losses and costs, including reasonable legal costs on the attorney-and-client scale, arising from:

  • Your misuse of the Service.
  • Your breach of these Terms.
  • Unauthorised or unlawful processing of third-party data by you.
  • Misrepresentations made to any Tax Authority or any third party using Coinfig outputs.

16.3 Claims

We will tell you promptly about any claim covered by this section, and you may take part in its defence at your own cost.

17) Suspension and termination

We may suspend or terminate access if we reasonably believe you breached these Terms or pose a legal or security risk. We will tell you why we suspended your account unless the law prevents it. If an investigation finds that you did not breach these Terms, we will extend your paid plan by the time it was suspended, or refund that time if you prefer.

We may also suspend access while we investigate a suspected breach. Subject to the last paragraph of section 15.3, we are not liable for suspension or termination carried out in good faith under section 8, this section 17 or section 17A.

You may request account deletion at any time. Fees already paid are non-refundable except to the extent required by applicable law or expressly stated in these Terms.

17A) Sanctions and export control

You confirm that you are not named on, or owned or controlled by a person named on, a sanctions list of the United Nations, South Africa, the United States (OFAC), the European Union or the United Kingdom, and that you are not located in a country or region subject to comprehensive sanctions. You must not use Coinfig for, or on behalf of, any such person. We may suspend or terminate your access immediately if this is not true.

18) Governing law and disputes

These Terms are governed by the laws of South Africa.

Before starting formal proceedings, either party may refer a dispute to the other party in writing, and the parties will use reasonable efforts to resolve the dispute within 14 days. This does not prevent either party from seeking urgent relief or taking steps required to preserve rights.

Subject to applicable law, you consent to the jurisdiction of the courts in Gauteng for disputes arising from these Terms or the Service. Nothing in these Terms prevents you from exercising any non-excludable consumer, data protection, or regulatory complaint rights.

If you are a Consumer living outside South Africa, you keep the protections of the consumer law of your country that cannot be excluded by agreement, and you may bring a claim in the courts of your country. If you are a Consumer in Ireland or elsewhere in the European Economic Area, this includes the mandatory consumer law of your country, and we may bring a claim against you only in the courts of the country where you live. Sections 15, 16 and 18 apply to you only as far as that law allows.

19) Electronic communications and notices

You agree that we may provide notices and communications electronically, including by email, in-app notification, website notice, status page notice, or other reasonable electronic method. Electronic notices satisfy any requirement that a notice be provided in writing, to the extent permitted by law.

20) Changes to these Terms

We may update these Terms. If a change is material, we will take reasonable steps to tell you before it takes effect, for example by email or in the app. If a change is to your disadvantage and you have a paid plan, it applies to you from your next renewal, or 30 days after we tell you if that is sooner and you have not cancelled. If you cancel because of such a change, we will refund the unused part of your fees. Other changes take effect on the date shown at the top of these Terms. Continuing to use Coinfig after a change takes effect means you accept it.

21) General

21.1 Events beyond our control

We are not liable for any failure or delay caused by events beyond our reasonable control, including failures of third-party services, utilities or networks, power outages, natural disasters, or acts of government.

21.2 Assignment

We may transfer our rights and obligations under these Terms to an affiliate or to a successor in a sale or restructuring of our business, and we will tell you if we do. You may not transfer yours without our written consent.

21.3 Severability, waiver and entire agreement

If any part of these Terms is found unenforceable, the rest remains in force. In particular, if any part of section 15 is found unenforceable, the rest of section 15 continues to apply. A failure or delay in enforcing any right is not a waiver of it. These Terms, together with the documents listed in section 21.5, are the entire agreement between you and Sixpence about the Service.

21.4 Survival

Sections 11, 12B, 15, 16 and 18, and any other provision that by its nature should survive, continue after these Terms end.

21.5 Order of precedence

If these documents conflict, they apply in this order: a written agreement signed by Sixpence, then the Enterprise Addendum for enterprise use, then these Terms, then the Acceptable Use Policy, and then the Privacy Notice, Cookie Policy and Disclaimer. Where these Terms and the Acceptable Use Policy conflict on what you may do, the stricter rule applies (section 8). A partner data-processing agreement prevails for the partner-controlled personal information it covers.

Enterprise Addendum (Organisations representing individuals)

This Addendum applies when an organisation ("Enterprise Customer") uses Coinfig to process data for end clients ("End Clients").

A) Acceptance on behalf of End Clients

The Enterprise Customer accepts these Terms and this Addendum on behalf of its End Clients and warrants it has lawful authority, mandate, and permissions to:

  • Upload and process End Client data.
  • Receive, use, and share reports with End Clients and relevant stakeholders.

B) POPIA and operator obligations

The Enterprise Customer is responsible for determining the lawful basis for processing End Client data, providing required notices to End Clients, obtaining required mandates or permissions, and complying with its own POPIA and professional obligations.

To the extent that Sixpence processes End Client personal information on behalf of the Enterprise Customer, Sixpence acts as an operator or service provider for the purpose of providing Coinfig. Sixpence will process such information only as authorised by the Enterprise Customer, treat it as confidential, and apply reasonable technical and organisational safeguards.

Sixpence will notify the Enterprise Customer where it has reasonable grounds to believe that End Client personal information processed by Sixpence has been accessed or acquired by an unauthorised person, subject to reasonable investigation, containment, and legal requirements.

The Enterprise Customer is responsible for handling End Client requests, complaints, and professional obligations, unless otherwise agreed in writing.

C) Subscription, billing, and cancellation

  • Enterprise billing is monthly.
  • Unless otherwise agreed in writing, enterprise subscriptions have an initial minimum term of twelve months. After the initial term, subscriptions continue month-to-month.
  • After the initial term, you may cancel with one month written notice unless otherwise agreed in writing. Cancellation takes effect at the end of the then-current billing period.
  • Fees are non-refundable unless expressly agreed in writing.

D) Enterprise responsibilities

The Enterprise Customer must:

  • Control user access internally and ensure only authorised staff use the Service.
  • Ensure appropriate professional review of outputs before reliance.
  • Ensure data quality and document any known limitations.
  • Tell its End Clients that reports are prepared for the Enterprise Customer's use and that they may not rely on Sixpence for them (section 12B).

E) Indemnity (enterprise)

The Enterprise Customer indemnifies Sixpence against claims arising from:

  • Lack of mandate or authority to process End Client data.
  • The Enterprise Customer's professional services, advice, or representations to End Clients or any Tax Authority.
  • Misuse or unlawful processing by the Enterprise Customer or its users.
  • Any claim by an End Client against Sixpence relating to a report or the Service.

F) Liability cap (enterprise)

Sixpence's total liability to the Enterprise Customer for all claims together is capped at the fees paid in the 12 months before the event giving rise to the claim, and excludes the losses listed in section 15.2 of the main Terms. Nothing in this Addendum limits liability for gross negligence or wilful misconduct.