Introduction

1.1. Via using Our Service at spinvoyage.com You agree that You are hereby notified that Company may carry out verification procedures, whether itself or through third parties. You may be requested to provide Company with documents at the deposit stage and/or the withdrawal stage (or both) or at any other stage at the sole discretion of Company, such as a copy of Your passport or other identification documentation as part of the KYC procedures.

1.2. The Company may also request any documentation previously provided which would have later on expired or would no longer be valid for any reason, or to request any additional KYC documentation for any reason and at any time. Your Player Account may be blocked or closed if You do not provide requested information or documents or if such information or documents You provide is/are found false or misleading. Company reserves the right to close Your Player Account and withhold any funds held in Your Player Account until the Company verification process is complete.

1.3. Company may request additional information for performance of Your KYC such as Your age, identity, address and additional contact details, including Your place of residence, Your place from where You intend to access the Website, if other than Your place of residence, relevant payment information, all of which must be true and correct.

1.4. We shall have the right to make a phone call to the number provided by You in the course of registration of Your Player Account, which at Our own discretion may be a necessary part of the KYC procedure. Until the full verification of Your Player Account no withdrawals, payouts (cashouts) will be processed.

1.5. We reserve the right to verify You using the services and verification systems of third parties, including Sum&Substance (https://sumsub.com).

1.6. It is Your sole responsibility to ensure that the information You provide is true, complete and correct and You hereby represent and warrant to Company that the information provided is true, complete and correct.

Simplified Due Diligence (SDD)

2.1 Simplified Due Diligence (SDD) is applied to Clients who are deemed to pose a low risk of money laundering or terrorist financing. Under SDD, the level of identification and verification required is reduced but still adheres to the necessary regulatory standards.

2.2 SDD may be applied to:

Clients residing in jurisdictions with low AML/CTF risk as identified by competent authorities;
Clients who engage in low-value transactions below the established threshold;
Clients who do not perform suspicious actions or transactions on the Account.

2.3 Procedure:
Collect basic identification information (e.g., name, date of birth, nationality).
Verify identity through simplified measures such as cross-referencing with reliable databases.
Continuous monitoring to ensure that the Client's risk profile remains low.

Enhanced Due Diligence (EDD)

3.1 Enhanced Due Diligence (EDD) is required for Clients who present a higher risk of money laundering or terrorist financing. This involves more stringent verification and monitoring processes.

3.2 EDD is required for:

Politically Exposed Persons (PEPs).
Clients from high-risk jurisdictions.
Clients with complex or unusual transactions.
Clients involved in industries associated with a higher risk of money laundering or terrorist financing.

3.3 Procedure:
Obtain additional identification documentation (e.g., multiple forms of ID, proof of address).
Conduct thorough background checks and source of funds verification.
Implement ongoing monitoring of transactions to detect any suspicious activities.
Apply stricter controls on account usage and transactions.

Client Journey

Registration Verification

4.1 In order to make a deposit to the Player Account and participate in the Games offered by Company., You need to register.

At the time of Player Account registration, We collect the following information about the Client:

Email address;

4.2 This registration form is designed to be user-friendly while capturing all necessary information for initial KYC compliance.

Requirements for documents and their verification.

5.1 The Company employs Client identification procedures to verify the true identity and address of its Clients. The primary objective of "Know Your Client" (KYC) procedures, particularly for anti-money laundering purposes, is to confirm that the potential client is who they claim to be. The Company conducts thorough KYC procedures for all clients to ensure it has sufficient information to confidently identify and understand the individuals it engages with.

Verification of identity (Proof of Identity)

5.2 The Company’s identity verification process aims to confirm key details about the Clients, including their full name, date and place of birth, nationality, and the specifics of their identification document issued by their country of origin. Clients are required to submit a photo or scan of the original document certifying their identity. We accept one of the following documents as proof of identity: ID card (both sides), national passport (all relevant pages), passport (page with photo), or permanent resident card (both sides).

5.3 The document provided must contain the following information: the issuing country, serial number, date of issue, expiry date, gender, first name, last name, and date of birth. All scanned copies or photos must be made from the original documents, in color, unedited by photo editing software, and free from artifacts such as glare or blur. The document details must be clear and readable.

5.4 During the identity verification process, the Company will:

Authenticate the document by comparing its features against a knowledge base of valid documents.
Verify the document’s validity and legality through public registers or third-party services, where applicable.
Inspect the scanned or photographed document for signs of editing.
Ensure the completeness and accuracy of the information provided by the client.
Cross-check the client’s details against sanctions lists, PEP lists, terrorist lists, blacklists, and existing client databases to prevent double registration.

Verification of address

5.5 The Company's address verification process is designed to confirm the Client's permanent or temporary residence. Clients must provide a photo or scan of the original document confirming their address. We accept one of the following documents as proof of address: bank statement, utility bill, tax document, address registration document issued by local authorities, government-issued document, or court documents.

5.6 The document provided must contain the following information: the Client’s full name, postal address, date of issue (not older than 90 days), and, where applicable, a stamp and signature from the issuing organization. All scanned copies or photos must be made from the original documents, in color, unedited by photo editing software, and free from artifacts such as glare or blur. The document details must be clear and easily readable.

5.6 During the address verification process, the Company will:

Authenticate the document by verifying its validity and legality.
Check the scanned or photographed document for signs of editing.
Ensure all required details are present.
Confirm that the Client’s name on the address document matches the name on the identity verification document.
Verify that the document was issued within the last 90 days.

Verification Source of funds

5.7 The Company has a process in place to verify the source of wealth (SOW). This verification is crucial to ensure the origin and legitimacy of the funds. Examples of acceptable sources of wealth include:

A payslip dated within the last 3 months;
Tax return or income statement;
Employment contract, dated and signed by the parties, indicating the amount of salary;
Service agreement, dated and signed by the parties, indicating the terms of payment;
Invoices for the last 3 months;
A bank statement confirming the receipt of income, indicating the sender and purpose of payment;
A copy of the purchase and sale agreement;
A document confirming the sale of shares or withdrawal of funds;
Document confirming the receipt of dividends: minutes of the board meeting, dividend register;
Certificate of inheritance with a copy of the will.

5.8 During the source of wealth verification process, the Company will:
Authenticate the documents provided by verifying their validity and legality.
Inspect the scanned or photographed documents for signs of editing.
Ensure all required details, such as the client’s name and financial information, are present and accurate.
Confirm that the Client’s name on the SOW document matches the name on the identity verification document.
Assess the credibility of the source of wealth and ensure that it aligns with the Client's financial profile.

Verification with a selfie photo

5.9 Selfie photo verification is used to ensure that the verification documents genuinely belong to the Client. The Client must provide a photo of themselves holding the identification document used for verification (proof of identity) next to their face.

5.10 The selfie photo must meet these requirements:

The Client must be holding the verification document in the photo.
The Client’s face must be fully visible within the frame.
The document must be held vertically, with all its details clearly legible.

5.11 During the selfie photo verification, the Company will verify:
That the person in the photo matches the individual in the identification document.
That the document in the selfie is the same as the one used for identity verification.
That there are no signs of editing using photo editing software.
That the photo's EXIF data is present, and the creation date matches the current date.

5.12 The Company may request further details if necessary, and employees may conduct additional checks based on the situation.

Contact Us

Should You have any complaints regarding Our KYC Policy or regarding the investigations conducted on Your account or Your identity, please contact Us: [email protected].