AML and KYC Policy
INTRODUCTION We are believed that the creation of an appropriate “KYC” policy is an important integral part of companies. Due to the fact that services should be associated with the need to reduce risks and finance terrorism and fraudulent activities. Company management, officers and employees should be studied and have the necessary working knowledge.
REGISTRATION, INSPECTION, BANKING AND CUSTOMER MANAGEMENT
2.1 Terms governing customer accounts
Each client reads and accepts the conditions during the registration process.
2.1.3 Confidentiality All customer data is accepted in accordance with the conditions. For unregistered users, data processing is not installed.
The data of registered users is stored on the server in the premises. Only authorized employees have data access rights. Detailed information on the safety of equipment, network and software is provided in section 5 below.
Third parties are allowed internal rules and policies.
All data is stored in accordance with the General Data Protection Regulation (GDPR) of the EU 2016/679.
2.2 Customer Identification and Verification
2.2.1 Customer Identification Anyone who wishes to place bets and use the services of a bet on the web-site website is required to register their personal account. Registration of your personal account includes the following fields:
Confirmation that the client is 18 years old.
Name and surname: as indicated in the passport / customer ID
Place and date of birth
country, city, place of residence
Number and series of identification document
Telephone number If he did not fill out all the necessary fields in the registration form. The information presented in the registration form is analyzed using the approach based on the risk assessment described in the AML Policy (ML and FT risk assessment) - the nature and complexity of the risk. After the client gains access to his account, you will be able to access your account. This password can be changed at any time on the site, after the authorization procedure. 2.2.2 Client Validation The company within 30 days from the date of filing the application for registration began verification of identity. The initial check is carried out by the Company to confirm that the game account is registered on real data and that the client has reached the age of 18 years. To do this, the client can upload their civil passport, identity card and other documents in the settings of the game account. The address of residence can be confirmed in the last 6 months. Confirmation of the address must correspond to the name and address indicated in the application for registration. The document number should be clearly visible on the document. Only color photographs and copies of documents are accepted. Document pages should be fully visible. Valid document languages: Greek, English, Russian, Ukrainian. Valid file formats: jpg, jpeg, gif, no more than 5 MB. The Company may require confirmation of the identity of the Client at any time, regardless of whether the Client has passed the initial verification. The list of additional documents may include: an identity card, birth certificate, utility bill, statement of account / account, etc. The client can provide these documents by sending a letter to support. The verification of the identity of the owner of the game account is carried out within 24 hours.
iii) if the player has unusual activity that will cause suspicion (unusual changes in access, deposits or gambling), then how will the enhanced CDD be performed.
iv) The following are acceptable ways to deposit funds into your gaming account: a. Through electronic systems (electronic wallet, electronic money); b. Credit Card (VISA / MasterCard) from. Prepaid cards
The client can go to the website and after logging into his account, he can go to the web page where he can make a deposit. A list of payment systems will appear for selection, and the client will be able to choose a payment method to make his request. The client can also check the percentage of commission for each type of payment.
If the customer selects an electronic system, he is redirected to the payment system page. He / she made the payment on the web page of a private payment system. One wallet of the payment system can be used to replenish the account of only one client. In addition, the Payment system verifies the legitimacy of funds in accordance with agreements with each Payment system. When a client makes a deposit with a credit card, the client data is verified with the data presented in his / her payment system.
v) The company allows customers to have a more active deposit mechanism. The checks described above are performed for any method of paying a deposit. The risk of such customers increases in accordance with their approaches to their withdrawal. Customer must choose a deposit. Further control measures, development
vi) When a customer fills out a form on a page of a redirected Payment System (Iframe), the Payment system or processed system sends a response in the software. If the payment system or payment providers detect any suspicious fraudulent transactions, the software should be sent electronically with a notification that the particular operation was not successful.
vii) The company does not accept non-guaranteed funds.
viii) The company is not liable if the client’s account is not paid within the third time (banks, payment system, communication channels, etc.) or due to force majeure circumstances.
2.3.3 Credit provided to customers
The company does not allow bids on the basis of non-guaranteed funds. The system does not automatically give loans to customers.
2.3.4 Account Management
i) The company provides customers with two types of rates:
- bets made by the client before the event (preliminary match);
- bets made during the event (live).
- A detailed description of the types of bets offered by the Company is given in Section 9 of the Terms. The system of lists of bets on the client’s account. Bookmakers check the results, count after each match, for their correctness, since their result is related to the result. The correctness of the match result is checked by the appropriate department. After the completion of events / match. ii) Customer accounts are not any associates. iii) All transactions on a trading platform registered in the system. Records are stored on the server. iv) The customer is not contacted, except for special AML procedures. v) Bonuses are credited to the customer's account in accordance with internal rules regarding bonuses and conditions. The client must fulfill all the conditions of the bonus offer. 2.3.5. Withdraw funds from the funds of the Client i) The company provides customers with the following methods of withdrawing funds from gaming accounts:
- through electronic systems (electronic wallet, electronic money) - processing time up to 12 hours.
- credit card (VISA / MasterCard) - processing time (from 3 to 6 business days) ii) the client can withdraw the full amount from him. The withdrawal of funds can be processed as follows:
- bank transfer within 5 business days from the date of the request;
- Platform systems within 1 business day of the request. (additional information on section 4 of the Terms)
iii) the client initiates a request to withdraw funds from his personal account and fills out a special form. Each conclusion is associated with the same source from which the payment was made. iv) it is possible only after verifying that the personal information of the account holder matches and / or matches personal data. It is strictly prohibited regardless of the degree of relationship with the Client. v) all costs of transferring funds. vi) The client should be responsible for providing reliable information during registration and updating it with any changes. vii) the client must undergo a verification process by the company. The company verified the identity and address of residence. The check will be carried out by downloading high-quality color photographs of your passport and other identification documents, as well as photographs of the front side of the credit / debit card that was used to replenish the account. Please note that all data must be clearly visible. The company provided feedback on what needs to be fixed. viii) Removal fee for each client. Additional information about depositing and withdrawing funds. Inside the system, transfers from client to client are not possible. 2.3.6 Rejected Transactions A company may decline a deposit operation in the following cases:
- In case of suspicion or detection of fraud or hacking account
- In case of suspicion or discovery that the credit card does not belong to the account holder. The payment system may reject deposits for several reasons, but does not exclude In case of suspicion of fraud (multi-account, the use of any software for automatic bets, arbitrage bets, if the player’s account is not used for bets and other products offered by the Company, participation in loyalty programs, etc.), the Company reserves a check of the player’s activity before its completion. The payment system may deviate from a withdrawal transaction. In this case, the payment system will refund If the Anti-Fraud Department detects any unusual transaction (it must notify the MLRO) that action is needed. Replaces "STR can be filed." 2.3.7 Client Activity Report Detailed information on the activities of the Client can be checked on his personal page.
2.4 Closing accounts
2.4.1 Inactive accounts
According to the terms of the company, an account is considered inactive if, over the past 6 months, the Account for access to funds is considered “inactive” if for up to 24 months. This means that there were no accounts in the account.
The company and its divisions control inactive accounts. The relevant department maintains a register of all inactive accounts. After registration, you can also enter a valid phone number.
All inactive accounts that have a transaction history are deleted from the system.
2.4.2 Deactivating or Closing Accounts
All entries are made from the system.
Funds remaining in such accounts may be received in accordance with the withdrawal procedure.
2.4.3 Withdrawn Accounts
The Anti-Fraud Department constantly monitors Client transactions. If an employee of the relevant department detects unusual and / or suspicious activity, then the client's account may be blocked for a limited period of time to investigate it. In addition, the company has the right to cancel bets, win bonuses from all relevant accounts.
18.104.22.168. The company considers the following actions suspicious: i) a client opens more than one game account (for example, use of IP addresses, computers or other devices, etc.); and / or ii) The client acts as part of a syndicate (using the same or similar names, address, phone, email, the same or similar IP address, computers or other devices acting on the same or similar pattern). The support team requires information and / or documents to check for suspicious activity. Additional information may also be requested from partners who receive deposits and withdraw funds from the bet account in order to receive information about the origin of the funds. The client still has the opportunity to access his / her personal account during the investigation process, but the funds will remain frozen and no transactions will be allowed until the investigation is completed. All stages of the investigation are recorded in the system. If the investigation is successfully completed, the client can use his funds again. The account will be blocked until the requested documents are received. 2.5 Customers at risk 2.5.1 Minors In accordance with KYC policies and conditions, Companies over 18 years of age cannot register and play. Automatic verification of 100% coverage upon registration on the website The customer is personally responsible for providing false information. The company has the right to take all necessary measures, as described in the KYC Policy and Terms of the Company. If it is discovered that a minor is using a game account, then the specified account will be immediately blocked, and all transactions in processing will be canceled. Invoices will be returned to the owners. In case of detection of a deposit of a minor player. 2.5.2 Gambling Issues There are 3 ways to solve problems with gambling.
Using chat or phone, you can contact us by phone. Anti-fraud request to evaluate and take all necessary measures to temporarily limit or block an account. The request that the client will be notified by email of the changes has been made to his account.
Overview of the support team. The support service identifies problematic customers in the chat or in the chat. Typically, these clients are concerned about a support group or other customers or exhibit compulsive gambling behavior. One of the main requirements is a permanent loan request issued by the Company. (no one can give loans to customers).
Mathematical review. Customers of all anti-fraud and anti-fraud activities. One of the triggers that track a department is the trigger for gambling problems. It includes the following algorithms: if the client has losses that increase 10 times in 3 months (90 days), or if the client has losses in the last 12 months, then he will be identified as a problem gambling client. Based on the results of this analysis, the anti-fraud department contacts the support department with a request to contact the customer. The support department initiates communication with the client, where the situation is, gives links to problematic gambling sites and offers to make a request for self-restriction with the most convenient and suitable conditions for the client.
The client received the status "Problem of gambling" in the system of companies. More information about Player protection and Responsible Bets can be found in Section 6 of the Terms. 2.5.3 Self-restraint A company must always accept and accept electronic signatures on a self-limited player. The client has the right to limit his gambling expenses, set a time limit or even pause by sending a request, or indicate his user ID and the specific type, amount and term of the restriction. Customers may request the following types of restrictions (self-restriction): i) limitation of the amount of funds that the client can provide for a certain period of time (day, week, month); ii) limit the amount of cash; ii) Establishing a time limit for the Client’s betting sessions; iii) customer self-exclusion from bets - for a certain period of time or for an indefinite period. 22.214.171.124. If the client wants to change the active restriction, the following rules apply: If such a request does not require changes, then this means that 7 calendar days from the date of initial restriction; If necessary, when he received support, he should take effect. 126.96.36.199. We recommend that you contact support at support. 2.5.4 Player Protection Information
Customers gain access to their page (customers are notified of the importance of saving their identifier and password after completing registration on the website). After you have all the necessary duties and / or requirements for the client, you will be provided with an identity card.
The page includes:
Customer data on finances: withdrawal request. all operations were performed in the system (date, time, amount, type of operation and description of the source of payment)
The client puts the information: -Date, time, amount, sporting event, odd and the result of each bet.
Incomplete customer bids
- Date, time, amount, sporting event, odd of each bet.
Deposit / withdrawal page, where the client can provide all possible ways of depositing and withdrawing funds, check the commission and choose the type that is most convenient for you.
The client can update their information, add documents, change the password, etc. In addition, the client can see this program.
The client can find any changes and actions that have been performed. In addition, if the client has any doubts, he can easily enter the chat to support his page and check the IP address and date of the last login.
2.6 Accepting Bets 2.6.1 Real Play Clients passed the verification procedure and registered on the site. Bets can be settled in all circumstances, except when: -Does not have enough funds in the client's account -The user had to conduct an extended additional legal audit, but has not yet completed
- The anti-fraud department soon blocked the account based on unusual and / or suspicious actions, until the client confirmed that everything was correct 2.7 Customer complaints 2.7.1. In the event of a dispute, it is advisable that the Client submit a written complaint to the Company through the customer support service (support). The complaint must contain clear and unambiguous information about the identity of the applicant and contain all relevant data that served as the basis for the complaint, including relevant financial documents confirming payment of the placed rate (s). 2.7.2. The Customer and the Company must do everything possible to reach a settlement agreement within a reasonable time. As a general rule, the Company will make a decision on the Customer’s complaint within 10 business days. 2.7.3. Any dispute or claim arising out of or in connection with the Terms, the KYC Policy or its subject matter, whether contractual or non-contractual, shall be governed by and construed in accordance with the laws of Curacao.
The company maintains registers of important gambling information. The system has the ability to generate an automated registry on demand. All data is stored in the register of the Client, which includes, but is not limited to:
- All registration data (name, surname, address, etc.)
- All payment data (all movements and payment methods)
- History of all bets
- Status of Anti-Fraud and other responsible departments
- Comments of the payment or fraud department
- limits for customers