KYC Policy

1. THE INTRODUCTION.

This Know Your Customer Policy (hereinafter "the Policy") governs the application of Know Your Customer approach by the Company (the "Company", "We", "Us", "Our").

For the purposes of this Policy:

  • a) the website Hitnspin.com hereinafter shall be referred to as the "Website";
  • b) any natural person that has an account on the Website hereinafter shall be referred to as the "user".


2. THE PURPOSES OF THIS POLICY.

The Company applies the measures, specified in this Policy, for the following purposes:

  • To prevent violation of Website`s Terms & Conditions and other applicable documents;
  • To prevent Money Laundering, Terrorist Financing and other violations of AML/CFT Legislation;
  • To prevent usage of the Website by the children;
  • To prevent cheating, collusion, and any other unlawful or illegal activity on the Website;
  • To prevent any legal, financial and reputational risks.


3. RISK ASSESSMENT.

The Company implements the risk-based approach, proposed by the Financial Actions Task Force ("FATF") in order to assess each user in the frame of this Policy.

The categories of the risk are the following

Country/Geographical risk. The Company evaluates the country of the user`s residence/domicile by the following criteria (including, but not limited to):

  • Whether country of user`s residence (jurisdiction) is defined as the "Third country with the strategic deficiencies" by the European Commission (in accordance with the Commission Delegated Regulation (EU) 2016/1675 and/or any amending regulations to this Regulation) and whether user`s jurisdiction is defined as "high-risk and other monitored jurisdiction" by the FATF;
  • Whether the country of user`s residence (jurisdiction) is defined by the credible source as lacking an appropriate Anti-Money Laundering and Counter Terrorist Financing regime, or identified by credible sources as having significant level of corruption or providing support to terrorists or terrorist activities.


Customer Risk. The Company checks the user of the Website by the following criteria (including, but not limited to):

  • Whether the user is the Politically Exposed Person;
  • Whether the user is under sanctions of the European Union or the United Nations Organization;
  • Whether the activity of the user is suspicious. Examples of the suspicious activity include, but not limited to: a) excessive depositing activity; b) usage of several devices to authorize on the Website in a short time-frame; c) usage of the user`s device by other users of the Website; d) usage of one IP address by several users; e) usage of one electronic device by several users.


Transaction risk. The Company checks the spenders of the user to ensure, that they are not high and/or disproportionate. The Company also applies additional measures if the transaction of the user is suspicious (see “transaction monitoring”).

4. VERIFICATION.

The Company applies Standard Verification (or, in legal terms, due diligence) in the following circumstances:


  • A. The total amount of the transactions, made through the Website by a user, reaches or exceeds USD/EUR 1000;
  • B. In the process of the risk assessment is determined, that a user presents a significant risk of money laundering or terrorist financing;
  • C. The behaviour of the user contains one or more factors, that gives the grounds to suspect a user in the usage of the Website in violation of the Terms and Conditions;
  • D. In other cases, when the personnel of the Company consider the Verification as a necessary measure.


When applying Standard Verification, the Company shall ask a user to submit the following documents:

  • A copy or a photo of the identification document of the user;
  • A photo of the payment card, used or intended to be used in depositing on the Website. It is important, that the name of the cardholder must be the same that the name of the user that passes the Verification. CVV code, payment card number (except for first 6 and last 4 digits) may be hidden or covered. The cardholder`s name must not be hidden or covered in any manner.
  • A photo of the user, bearing the documents that were required to pass the Verification.
  • In some situations - the user`s address confirmation. It may be utility bill, telephone bill or other documents, which, due to the local legislation, shall be deemed to be sufficient in order to confirm the address of the user.
  • In some situations - bank statement, the letter from the duty station/from the workplace.
  • In some cases - tax assessment notice.
  • Photo of the user, holding a list of paper with a necessary data, written by hand: a) the e-mail of the user, used when registering an account; and b) the date of the photo request and the confirmation code.
  • Other documents or data, that may be required by the particular situation.
  • In some cases, the Company may ask a user to connect with the Website`s Support Team via the call (including the video call).

5. ADDITIONAL VERIFICATION FOR PEPS AND USERS FROM HIGH-RISK JURISDICTIONS.

The Company applies additional Verification measures in the following circumstances:

A) The user is a Politically Exposed Persons in the meaning of the article 3(9) of the Directive 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing or the user is the member of the family of the Politically Exposed Person.
Under the article 3(9) of the abovementioned Directive, the Politically Exposed Person is a natural person who is or who has been entrusted with prominent public functions and includes the following:

  • (a) heads of State, heads of government, ministers and deputy or assistant ministers;
  • (b) members of parliament or of similar legislative bodies;
  • (c) members of the governing bodies of political parties;
  • (d) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances;
  • (e) members of courts of auditors or of the boards of central banks;
  • (f) ambassadors, chargés d'affaires and high-ranking officers in the armed forces;
  • (g) members of the administrative, management or supervisory bodies of State-owned enterprises.
  • (h) directors, deputy directors and members of the board or equivalent function of an international organisation.

The abovementioned list excludes middle-ranking or more junior officials.

The article 3(10) of the Directive 2015/849 defines "family member" as:

  • (a) the spouse, or a person considered to be equivalent to a spouse, of a politically exposed person;
  • (b) the children and their spouses, or persons considered to be equivalent to a spouse, of a politically exposed person.

B) The country of user`s residence (jurisdiction) is defined as the "Third country with the strategic deficiencies" by the European Commission (in accordance with the Commission Delegated Regulation (EU) 2016/1675 or any amending regulations) and/or the country of user`s jurisdiction is defined as "high-risk and other monitored jurisdiction" by the FATF;

C) In other cases, when the Company considers this procedure as a necessary measure.

D) The country of user`s residence (jurisdiction) is defined by the credible source as lacking an appropriate Anti-Money Laundering and Counter Terrorist Financing regime, or identified by credible sources as having a significant level of corruption or providing support to terrorists or terrorist activities.

When applying additional verification, the Company requires to submit the document(s) or data on the source of user`s wealth in accordance with his/her country’s legal and regulatory requirements. Additionally, in case of additional verification, the final approval on the verification shall be done by senior management of the Company.

The Company reserves the right to collect additional verification data of the user for the purposes of this Policy. Additionally, in cases when: a) a user refuses to pass verification; and/or b) the Company has ample grounds to suppose, that a user uses the Website for illegal purposes, and the user does not provide evidence to the contrary, the Company may inform proper regulatory/governmental/financial authorities on this case.

6. ACTIVITY MONITORING.

All operations of the users are checked on the absence of the suspicious activity. Suspicious activity includes, but not limited to:

  • Usage of several cards through different payment agents, proposed by the Company;
  • Obtaining a specific error code when making a payment;
  • Usage of payment cards, issued by different emitters, that are located in different regions;
  • Usage of different payment instruments within a short term (cards, electronic wallets, banking transactions);
  • Opposition or unwillingness of the user to verification of his/her account or payment instrument or his/her account as a whole;
  • Mismatch of the geolocation of user`s key elements (citizenship/residency, mobile carrier provider, IP address geolocation, BIN number of the card etc.);
  • Principal opposition to any phone or video call, non-provision by the user of his/her photo of him/her with the identification document in hands (upon request);
  • Matching of the user`s device ID (telephone, computer, tablet) with the device ID of another account in our system.

In case of any suspicious activity, mentioned above, this issue shall be directed to the antifraud department in order to evaluate a risk of this user and to conduct further actions. The antifraud department shall evaluate this issue and further direct it to the relevant department for further consideration.

7. TRANSACTIONS MONITORING.

All the transactions of users on withdrawal and deposits shall comply with the following requirements:

  • If the transaction is made by using a payment card, the name of the holder shall be the same as the name of the Website account owner. It means that any usage of third-party payment card is prohibited.
  • If the transaction is made by using an electronic wallet, this wallet`s electronic mail must be the same, that was used by a user when registering an account on the Website.
  • In case if a deposit is made from the payment instrument, placement of funds to which is unavailable, the withdrawal shall be made to the user`s banking account, or to another payment instrument - where it will be possible to reliably ascertain that this payment instrument really belongs to the user in question.
  • The Company does not accept payments from the anonymous payment instruments (cryptocurrencies, anonymous wallets etc.).
  • The Company does not withdraw funds, that were deposited by the user, to the payments instrument of another user.

8. RECORD-KEEPING OF USER`S DOCUMENTS AND DATA.

The documents and data, obtained during the Verification, and other financial data (including transaction data and its supportive evidence) shall be stored, kept, shared and protected in strict compliance with:

  • The Legislation of the European Union on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, namely the Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC;
  • The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("General Data Protection Regulation" or "GDPR");
  • The Limitation of Legal Proceedings act (Law 66(I)/2012) of the Republic of Cyprus;
  • The Privacy Policy of the Website.

9. AMENDMENTS AND MODIFICATIONS.

This Policy may be modified or amended at any time, at the sole discretion of the Company. It is sole responsibility of the user to review this Policy periodically for new changes and amendments. Registered users will be notified on any changes to this Policy via e-mail address, which was used when registering an account on the Website. Any continued usage of the Website after the notification has been sent shall be considered as a fact that user have read and accepted the changes to the Policy.

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