User Identification Protocol

1. The Company takes reasonable measures to establish the identity of any person to whom it provides Services.
2. In order to do so, the Company collects certain player identification details from each User, who registers an account with Us, in accordance with our Terms and the Privacy Policy.
3. Verification. We require Players to undergo a verification process (“Verification”).
   • KYC Partner
     As explained in our Privacy Policy, we use the services of a third-party, Jumio (“KYC Partner”) to perform Know Your Customer compliance checks (“KYC”) for our Players. Our KYC Partner’s Privacy Policy is available at https://www.jumio.com/legal-information/privacy-notices/.
   • KYC Verification
     Our KYC Partner will conduct a document verification and a liveness test for Players. All information collected, processed, or stored by the KYC Partner on behalf of WinZO for Players is referred henceforth as “Verification Information.”
     1. Document Verification : As part of the KYC Document Verification, the KYC Partner may ask you to submit/ upload a picture of your government-issued photo identification document such as a passport or driving license or residence permit or national ID card, etc. (each a “KYC Document”). Please note that the specific requirements for KYC compliance can vary depending on the regulations in the state or jurisdiction where you are residing and our KYC Partner’s discretion is operating.
     2. Liveness Test. As part of the Liveness Test, the KYC Partner will ask the Player to take a live selfie, to verify if the Player is the same natural person to whom the KYC Document as described above, relates. The KYC Partner will verify the authenticity of the KYC Document and may share the extracted ID Document details, the uploaded KYC Document, your uploaded picture, photo match results and final authenticity results with us.
   • Other Verification
     Our KYC Partner is also responsible for conducting checks on Players located outside the US to determine compliance with sanctions lists maintained by the Office of Foreign Assets Control (“OFAC”) and other global sanctions lists, and may seek additional information and data from you in this regard.
   • Disclaimer
     User understands and agrees that WinZO is not responsible or liable for lapses in the verification process. Please refer to our KYC Partner’s policies to understand what verification information is collected, how the Verification Information is processed, stored, and disclosed, for how long the Verification Information is retained, and your rights with respect to such Verification Information. It is expressly clarified and User understands that WinZO is not responsible or liable for any handling, use, processing, storing, deleting, or disclosure of such KYC Information.
   • Sanctions Compliance Procedures
     While WinZO relies primarily on our KYC Partner’s OFAC and global sanctions screening processes, WinZO also (a) maintains records of transactions and compliance efforts; (b) has an internal compliance program under which international transactions are screened against OFAC lists, and (c) regularly trains employees on OFAC regulations and compliance procedures.

User Obligations

1. Users accept that they must comply with this AML Policy. Users specifically confirm that they neither do they intend to, nor are they using the Platform and our Services to commit any criminal offenses.
2. Users must ensure that they submit accurate and up-to-date personal information that belongs to them.

Transaction Monitoring

1. We monitor activity on the Platform, through manual and automated means, on an ongoing basis. Such monitoring may be performed using rule-based systems developed in-house and by third parties, to review User history and activity patterns, to check for unusual or suspicious behavior, and implement additional controls or limits on the Platform. Users may make payments for Services only through integrated payment gateways, through electronic means. We neither accept payments from Users, nor allow withdrawals by Users in the form of cash.
2. If we detect unusual or suspicious User behavior, we may take actions we deem appropriate, including without limitation:
   • ask Users to submit more information and/or documents;
   • mandate additional KYC verification;
   • restrict, suspend, or terminate a User’s account;
   • disallow withdrawal of funds by a User; and
   • forfeit amounts sought to be withdrawn by a User.
3. We monitor Users’ relationships in accordance with the best industry practices, and in alignment with international recommendations, guidelines, and commitments. The extent of monitoring may depend on various factors including upon each User’s risk profile, volume, value of transaction, time of transaction, and frequency of transactions with similar players, table etc.
4. Any User account which may be involved in suspicious transactions potentially related to money laundering, or other offense, may be reported to the appropriate law enforcement agencies. For the purposes of this clause, suspicious transactions may mean and/or include:
   • unusually complex transactions;
   • transactions which do not appear to be undertaken in good faith;
   • transactions which do not appear to have any economic basis;
   • transactions which appear to involve proceeds of any offense.
5. We maintain records of transactions occurring on our Platform for such timelines that are required under the applicable laws.

Changes to AML Policy