KYC Policies

Registration To register an account at any of Final Enterprises N.V. websites, the player is required to enter the following details:

• Gender
• Full Name
• Date of Birth
• Email
• Country
• City
• Address
• Mobile Phone
• Password
• Currency

Age

FE does not allow any player under the age of 18 to register or take part in FEs services. It is not possible to register an account with the date of birth set to lower than 18 years of age, and if there is under any circumstances suspicion of a minor registering a fake date of birth, we will close the account till the customer is able to send a valid ID, and in some cases a face ID (picture where the customer is holding the ID next to his face).

First deposit

Upon the first deposit, all customers will receive an email explaining in detail about FEs KYC process, which mainly involves verifying their account information and chosen payment methods by sending documents. The customer will not be able to get a withdrawal approved until the relevant documents are approved by FEs payments team.

Verification

FE requires a valid government issued ID and proof of address in order to verify the customer’s name, date of birth/age, address and registered country. The proof of address needs to be recent, from the last three months, to prove they are currently living there. Customers also have to send documents proving their payment option. This is part of the first stage DD checks known as “Simplified Due Diligence” check and shall be carried out on all customers who reach EUR2000 in cumulative deposits or the equivalent in any other currency or upon first withdrawal request, whatever applies first.

At this stage, PEP and sanction checks are also carried out by relevant staff. Sanction lists consulted include Interpol, Europol, Consolidated EU Sanction List, UN Consolidated List of Targets, EEAS, Consolidated List. For PEP checks, customers are screened against CIA World Leaders Database; everypolitician.org; EU Members of Parliament. Should a customer appear on a sanction list, this shall be immediately escalated to the MLRO and the customer account shall be closed and reported to relevant authorities in Curacao or any other relevant jurisdiction. If a customer or close family member is discovered to be a PEP, this shall also be immediately flagged to the MLRO. The MLRO shall then decide whether to close the account and terminate the customer relationship, or whether to retain the customer relationship and keep the account open. If this decision is to keep the account open, the customer account shall be treated as high risk and subject to increased monitoring and fulfilment of the enhanced due diligence process.

The second stage of due diligence, known as the “Customer Due Diligence” stage, is carried out when the customer hits EUR10,000 in cumulative deposits or the equivalent in any other currency. At this stage, adverse media checks are carried out on the customer by using public sources. Therefore, depending on the country of residence and nationality, public sources are used to make adverse media checks on customers as necessary by using search engines such as Google, Bing, DuckDuckGo and referencing any media articles or other sources of public information.

The third stage of due diligence, known as the “Enhanced Due Diligence” process (“EDD”) shall be carried out for any customers, or any customers who have reached EUR50,000 in cumulative deposits or the equivalent in any other currency. At this stage, therefore, the customer shall be requested to provide a document proving the source of wealth.

Additionally, in all cases for Visa, MasterCard and bank transfers, FE would require copies of the used credit card, where you can clearly see a name and the first six and four last digits of the credit card number. If a bank account is used, FE would also need to verify that the bank account belongs to the same person as the customer, by verifying their bank statement showing customers name, bank account number and the bank logo.

All suspicious transactions shall be immediately escalated to the MLRO. The MLRO will then decide whether the filing of a suspicious transaction report with the relevant authorities in Curacao and/or the relevant country of residence of the customer as appropriate is required. If a report is not made, the MLRO shall document the reason as to why this decision was made and retain all necessary information on the case.

Privacy & Management of Persoal Data

Data subjects have the right of access to information held by Cosmoswin, subject to the provisions of the Data Protection Act 1998 and the Freedom of Information Act 2000. Any data subject wishing to access their personal data should put their request in writing to the DPC at support@cosmoswin.com. Cosmoswin will endeavor to respond to any such written requests as soon as is reasonably practicable and in any event, within 40 days for access to records and 21 days to provide a reply to an access to information request. The information will be imparted to the data subject as soon as is reasonably possible after it has come to Cosmoswins attention and in compliance with the relevant Acts.

1. Exemptions

Certain data is exempted from the provisions of the Data Protection Act which includes the following:

• Prevention or detection of crime
• Where the processing is necessary to exercise a right or obligation conferred or imposed by law or the regulating entities upon Cosmoswin, including prevention of terrorism funding and Money Laundering.

The above are examples only of some of the exemptions under the Act. Any further information on exemptions should be sought from the DPC.

2. Accuracy

Cosmoswin will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the data processor of any changes to information held about them. Data subjects have the right in some circumstances to request that inaccurate information about them is erased. This does not apply in all cases, for example, where records of mistakes or corrections are kept, or records which must be kept in the interests of all parties to which they apply.

3. Enforcement

If an individual believes that Cosmoswin has not complied with this Policy or acted otherwise than in accordance with the Data Protection Act, Cosmoswins DPC shall be notified immediately.

4. Data Security

Cosmoswin will take appropriate technical and organizational steps to ensure the security of personal data. All employees will be made aware of this policy and their duties under the Act. Cosmoswin and therefore all employees are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorized processing of personal data. An appropriate level of data security must be deployed for the type of data and the data processing being performed. In most cases, personal data must be stored in appropriate systems and be encrypted when transferred. Other personal data may be for publication or limited publication on our website, therefore having a lower requirement for data security.

5. External Processors

Cosmoswin is entitled to transfer the customers settlement data to a third party entrusted with collection or processing of payments. Otherwise the transfer of data is only carried out strictly within the framework of the legal foundation.

6. Secure Deletion

When data held in accordance with this policy is erased, it must be deleted securely in accordance with best practice at the time of deletion.

7. Retention of Data

Author: Head of customer operations
Date: March 2018
Review: March 2021