KNOW YOUR CUSTOMER (KYC) POLICY

The Company follows a detailed Know Your Customer (KYC) policy as part of its overall compliance responsibilities. This policy is designed to ensure the legal use of our platform, prevent fraud, identity theft, money laundering, and terrorism financing, in line with relevant legal and regulatory requirements.

1. Purpose of KYC Measures

The KYC procedures are implemented to:

  • Verify the identity of every Customer;
  • Ensure that all funds used on the platform come from legal sources;
  • Prevent the platform from being used for criminal or fraudulent activities;
  • Comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and regulatory requirements.

2. Initial Identity Verification

The Company performs identity verification during the registration process and before allowing specific account activities. As a minimum, each Customer must provide:

  • Full legal name;
  • Date of birth;
  • Permanent residential address.

Depending on the type, frequency, or amount of transactions, the Company may request additional information and supporting documents at its sole discretion.

In addition, certain transactions may undergo more thorough due diligence procedures to ensure compliance with applicable regulations.

All documents submitted must be clear, valid, unaltered, and verifiable. If there is any uncertainty, the Company may ask for notarized documents or carry out additional checks, including biometric verification or database screening.

3. Triggers for Additional Verification

Enhanced verification measures may be implemented in the following situations:

  • Cumulative deposits, withdrawals, or transactions that meet or exceed the applicable threshold;
  • Detection of unusual or inconsistent activity in the account;
  • Residence in, or transactions involving, high-risk jurisdictions;
  • Indications of identity theft, impersonation, or the use of third-party payment methods;
  • Classification as a Politically Exposed Person (PEP) or connection to a sanctioned entity.

In these cases, the Company may request documentation to confirm the source of funds or wealth, additional identity documents, transaction history, or banking information. All data may undergo real-time screening and risk profiling.

4. Ongoing Due Diligence and Monitoring

KYC is an ongoing process. The Company continually monitors Customer activity, including:

  • Regular updates of Customer information;
  • Analysis of transactional behavior;
  • Re-verification in case of significant changes (e.g., change of address, payment method, or jurisdiction);
  • Enhanced due diligence for high-risk accounts or behaviors.

When necessary, the Company reserves the right to suspend or limit account functions until additional due diligence procedures are completed.

5. Refusal to Comply

If the Customer fails or refuses to provide the requested information or documents, the Company may take the following actions:

  • Suspend or restrict account access;
  • Freeze deposits, withdrawals, or gameplay;
  • Terminate the account relationship;
  • Report the issue to the relevant regulatory or investigative authorities.

The Company will not be held responsible for any losses or delays caused by such actions when they are necessary for regulatory compliance or to protect the platform.

6. Fraud and Internal Review

If fraudulent activity, misrepresentation, or the use of counterfeit documents is suspected, the Company may:

  • Block or permanently close the Customer’s account;
  • Cancel any pending payments and transactions;
  • Initiate an internal investigation and involve relevant external authorities;
  • Retain or forfeit funds when permitted by applicable law or regulation.

Any such actions will be fair, documented, and based on objective evidence. The Company will take all reasonable measures to ensure confidentiality and legal compliance throughout the process.

7. Document Validity and Security

All documents provided to the Company are handled in accordance with relevant data protection laws. The Company applies appropriate security measures to store and process KYC data, and retains such records for the legally required period after account closure or final transaction.