1. PURPOSE AND SCOPE

   This Privacy Policy ("Policy") regulates and applies to all personal information held by PayToPlay OU (herein after the Company) as the controller of Customer's personal data and goes into detail on how the data are processed, including the measures taken to ensure that Customers' data is safe and secure. The terms of this Policy will apply to all personal information provided to the Company, and will continue to apply for as long as the Company hold Customers' personal data in terms of the applicable law. The Company is compliant with the applicable Estonian and International laws for the Prevention of Money Laundering and Terrorist Financing, GDPR as well as other data protection legislation applicable in Estonia. For the purposes of this Policy, personal data shall mean any information relating to Customer, which identifies or may identify a Customer and includes the following categories:

   • Personal identification information: name, e-mail, phone number, mailing address, ID or other documents and other details;
   • Payment information: bank information, card information, transaction history;
   • Other data collected by Cookies.

   The Customer understands that the Company will not be able to provide the Services to Customer if he/she refuses to provide the Company information according to the Company’s KYC/AML requirements for verification of identity and ongoing monitoring of activity. In some cases, the Company may require additional details and documents for KYC and AML/CTF purposes.

2. PURPOSE OF COLLECTING AND PROCESSING OF PERSONAL DATA

   The Company shall use and process the Customer’s personal data for the following purposes:

   • to provided Services under the Agreement;
   • to identify and verify the information about the Customer;
   • to comply with the Company’s legal obligations (e.g. KYC/AML requirements);
   • to prevent any fraud and scam activity;
   • to provide the Customer information on the Company’s products, news and updates;
   • other purposes as may be required by the Company’s policy or applicable law.

3. CONTROLLING AND PROCESSING CUSTOMER’S PERSONAL DATA

   Except for the Company that collects, stores and processes Customers’ personal data, the following third parties acting on Company’s behalf (“Service Provider”), may collect, process and store personal data provided by the Customer:

   • Company's affiliates, agents and representatives;
   • Company's contractors providing software for identity verification and anti-fraud purposes;
   • Company's contractors providing information from publicly accessible sources (for instance on sanctions);
   • Company's financial service providers through which it facilitates transactions;
   • law enforcement or regulatory agencies if required or permitted by law.

   According to the GDPR any Service Provider that processes the Customers’ personal data is obliged to:

   • act on the written instructions of the Company (unless required by law to act without such instructions);
   • take appropriate measures to ensure the security of processing;
   • delete or return of all personal data as requested by the Company;
   • perform other obligations as required by the GDPR and applicable law.

   The Company has a regulatory obligation to supervise and effectively oversee the outsourced functions and to act appropriately when it determines that the Service Provider is not performing the said functions effectively and in accordance with the applicable legislation.

   The Company may use or disclose personal information without Customer’s consent only in certain circumstances:

   • if required by law or by order of a court, administrative agency, or other government authority;
   • if the disclosure is necessary to protect the rights, privacy, property, or safety of Customers;
   • if the Company believes the information is related to a breach of the Agreement or violation of the law, that has been, is being, or is about to be committed;
   • if it is necessary for fraud protection, risk reduction, or the establishment or collection of funds owed to the Company;
   • for other reasons allowed or required by law;

   When the Company is required or permitted to disclose information without consent, Company will not disclose more information than necessary to fulfil the disclosure purpose.

4. CUSTOMER’S RIGHTS

   Customer has the following rights:

   • to request copies of the it’s personal data;
   • to request the Company to rectify information the Customer deems to be inaccurate or incomplete;
   • to request the Company to erase the Customer’s personal information;
   • to request the Company to restrict the processing of the Customer’s information;
   • to object to the processing of the Customer’s personal data;
   • other rights foreseen by the GDPR and applicable law.

   The Company must provide a copy of the information free of charge. However, the Company can charge a “reasonable fee” when a request is unfounded or excessive, particularly if it is repetitive.

   As a general rule, the Customer data is processed within the European Union/European Economic Area (EU/EEA), but in some cases it is transferred to and processed in countries outside the EU/EEA.

   If the processing and the storage of personal data provided by the Customer shall be provided in any jurisdiction within the European Union or outside of the European Union, the Company confirms this shall be done in accordance with applicable laws.

5. DATA SECURITY

   The Company has implemented necessary security measures to comply with acknowledged international security standards.

   As soon as the Company receives the Customer's information, the Company implements strict security measures and procedures to avoid unauthorized access from any third party.

   The Company undertakes appropriate technical, organizational and administrative security measures to protect any information it holds in its records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. However, the Company cannot guarantee complete security of Customer’s data. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Customer information at any time.

   Customers must prevent unauthorized access to Customer’s profile and personal information by selecting and protecting Customer’s password appropriately and limiting access to Customer’s computer or device and browser by signing off after the Customer finished accessing Customer’s account.

   Transmission of information via regular email exchange is not always completely secure. The Company however exercises all possible actions to protect Customers’ personal data, yet it cannot guarantee the security of Customer data that is transmitted via email; any transmission is at the Customers’ own risk. Once the Company has received the Customer information it will use procedures and security features in an attempt to prevent unauthorized access.

   When Customers contact the Company, a person may be requested to provide some additional personal data, like their name or email address. Such data will be used to respond to their query and verify their identity. Emails are stored on Company’s standard internal contact systems which are secure and cannot be accessed by unauthorized external parties.

6. CHANGES TO THIS PRIVACY STATEMENT

   The Company reserves the right to modify or amend this Privacy Statement unilaterally at any time in accordance with this provision.

   If any changes are made to this privacy statement, the Company shall notify the Customer accordingly. The revision date shown on at the end of this page will also be amended. The Company does however encourage the Customer to review this privacy statement occasionally so as to always be informed about how the Company is processing and protecting Customer’s personal information.

7. COOKIES

   Company’s website uses small files known as cookies to enhance its functionality and improve Customer’s experience.

   A cookie is a small text file that is stored on a Customer's computer for record-keeping purposes. Company uses cookies on the Platform(s). The Company links the information it stores in cookies to any personally identifiable information Customer submits while on the Platform. The Company uses both session ID cookies and persistent cookies. A session ID cookie does not expire when Customer closes his browser. A persistent cookie remains on Customer’s hard drive for an extended period of time. Customer can remove persistent cookies by following directions provided in Customer’s Internet browser's “help" file.

   Company sets persistent cookies for statistical purposes. Persistent cookies also enable the Company to track and target the location and interests of our Customers and to enhance the experience of Company’s services on the Platform.

   If Customer rejects cookies, Customer may still use the Platform.

8. MONITORING AND REVIEW

   The Company will monitor on a regular basis the effectiveness of this Policy and, in particular, the execution quality of the procedures explained in the Policy and, where appropriate, it reserves the right to correct any deficiencies.

   In addition, the Company will review the Policy at least annually. A review will also be carried out whenever a material change occurs that affects the ability of the Company to continue to the best possible result for the execution of its Customer Orders on a consistent basis using the venues included in this Policy.

   The Company will inform its Customers of any material change to this Policy by posting an updated version of this Policy on its Website(s).

9. CONTACT

   If the Customer has a concern about the way the Company handles its personal information, the Customer has a right to lodge a complaint. For further information, please contact our Data Protection Officer at: [email protected].

DEFINITIONS

Company - PayToPlay OÜ, registered in Estonia with registration number: 14740025.

Website Platform - a website that is operated by the Company and available at https://paytoplay.ee.

Privacy Policy -This document

Customer - a legal entity that has read and agreed to the Terms of use of PayToPlay OU and uses services of the Company provided through the Website Platforms.

GDPR - the General Data Protection Regulation (EU) 2016/679.

KYC or Due Diligence - documents that are requested by PayToPlay OU from the Customers in order to identify the Customer and comply with applicable laws.

Last update: June 01, 2023

1. INTRODUCTION

   1. These Terms of Use is a legal agreement between Paytoplay OÜ and its Customers (“Agreement”).
   2. Paytoplay OÜ is a company organized and existing under the laws of Estonia under number 14740025 and having its legal place of business at Pärnu mnt 139C, office 210, Tallinn, Estonia, 11317 (“Company” or “PayToPlay”). PayToPlay conducts its business activity (“Service(s)”).
   3. The Client/Customer of the Company is a legal entity to whom the Company provides its Services in line with this Agreement.
   4. The Company and the Customer together referred to as the Parties.
   5. Customer acknowledges that it has carefully read and understood this Agreement in its entirety and that he/she agrees to all of the provisions contained herein prior to using the Services.

   SCOPE OF THE AGREEMENT

   1. This Agreement sets out the terms and conditions for provision of the Services on the Platform.
   2. Upon entering into business relations with the Company, the Client asserts that it has read this Agreement, other Company's policies, the Company’s Fees set by the Company and agrees thereto.
   3. The Agreement shall constitute an integral part of all transactions between the Parties. In case of any discrepancy between the Agreement and the norms stipulated in any agreement between the Parties, the latter shall prevail.

   GENERAL CONDITIONS

   1. Customer may only conclude an agreement with the Company on provision Services and only if it is permitted to do so in Customer’s country of residence.
   2. By concluding the agreement, the Customer hereby represents and warrants to the Company that:
      1. The Customer has full legal capacity and ability to act in order to execute and perform right and obligations under the agreement;
      2. The concluding the agreement does not violate any laws or regulations applicable to the Customer;
      3. The agreement and all its consequences are binding upon the Customer and do not cause infringements of the laws of Estonia or the laws of the place of performance of the services;
      4. All information supplied by the Customer to the Company, including information on its activities, financial condition, and location, is true and is not misleading. All documents and notices supplied by Customer to Company are true and valid. Customer is aware of criminal responsibility for supplying Company with false information;
      5. Customer shall notify the Company promptly, but not later than within two weeks, of any changes to the information provided;
      6. The Customer has not offered, promised or given something or any preference to any Company’s employee, directly or indirectly, for the latter to act or abstain from any action in infringement of his duties;
      7. The Customer is not engaged in money laundering, that is, concealing or disguising the criminal origin of funds or other estate obtained as a result of criminal offence, or in terrorism financing, and the Customer’s funds on deposit at the Company have not been obtained through unlawful means;
   3. The Company shall be entitled to verify the representation and certification and other information supplied by the Customer at any time.
   4. In the course of the Company’s AML/CFT obligations and internal procedures, the Company may ask Customer at any time to confirm the accuracy of Customer’s information or to provide documents or other evidence.
   5. All transactions between the Customer and the Company shall be performed by wire transfer or other electronic means, in which the identities of both parties can be verified by the Company and which the Company, at its sole discretion, shall deem appropriate.
   6. The Client/Customer acknowledges and agrees that the Services on the Platform are not a marketplace, and any contract of sale made through the Services is directly between the Client and it’s customer. The Client is the seller of record for all items it sells through the Services. The Client is responsible for the creation and operation of the goods and services that it may sell through the Services, and all aspects of the transactions between the Client and it’s customer(s). This includes, but is not limited to, authorizing the charge to the Client’s customer in respect of the customer’s purchase, refunds, returns, fulfilling any sales or customer service, fraudulent transactions, required legal disclosures, regulatory compliance, alleged or actual violation of applicable laws (including but not limited to consumer protection laws in any jurisdiction where the Client offers products or services for sale), or Client’s breach of these Terms of Use. The Client represents and warrants that the goods and services it sells through the Services will be true, accurate, and complete, and will not violate any applicable laws, regulations or rights of third parties. For the avoidance of doubt, Paytoplay will not be the seller or merchant or record and will have no responsibility for items sold to customers through the Services.
   7. The Client is solely responsible for the goods or services that it may sell through the Services (including description, price, fees, tax that the Client calculates, defects, required legal disclosures, regulatory compliance, offers or promotional content), including compliance with any applicable laws or regulations.
   8. The Client may not use the Services for any illegal or unauthorized purpose nor may the Client, in the use of the Service, violate any laws in its jurisdiction (including but not limited to copyright laws), the laws applicable to the Client in its customer’s jurisdiction, or the laws of the Republic of Estonia. The Client will comply with all applicable laws, rules and regulations (including but not limited to obtaining and complying with the requirements of any license or permit that may be necessary to the Client) in Client’s use of the Service and performance of obligations under the Terms of Use.

   NO FINANCIAL ADVICE

   1. The Company does not facilitate or provide trading or investment or brokerage accounts or facilities, nor does the Company provide investment or any other financial advice.

   LIMITATION OF LIABILITY AND INDEMNIFICATION

   1. The Company (or The Company’s licensors, agents, suppliers, service providers, or any other subscribers or suppliers) in no event shall be liable to Customer, or any other third party for any direct, special, indirect, incidental, consequential, exemplary, or punitive damages, including, without limitation, damages for loss of profits, loss of business, loss of opportunity, loss of reputation, loss of information, business interruption, revenue, or goodwill, which may arise from Customer’s use of the Company’s Services and the Platform or any materials contained on the Platform.
   2. Without prejudice to any other terms of this Agreement relating to the limitation of liability and provision of indemnities, the following shall apply in particular to provision of Services under this Agreement:
      1. any kinds of the System errors: malfunction or failure of transmission, communication or computer facilities, or any transmission errors, technical faults, malfunctions, illegal intervention in network equipment, network overloads, malicious suspension of access by third parties, Internet malfunctions, interruptions, etc.
      2. any delays, inaccuracies, errors or omissions in any data provided to the Customer in connection with the Platform or use of related Services.
      3. any viruses, worms, software bombs or similar malicious code items introduced into the Customer`s information system and/or Service provided by the Company, provided that the Company has taken reasonable steps to prevent any such incident.
      4. any loss, liability or cost whatsoever arising from any unauthorized use of the Platform or related Services.
      5. any software and/or service of any third-party is used by the Company in the enforcement of any of the provisions of this Agreement.
      6. any disruption or impairment of the Platform or the Service or for disruptions or impairments of intermediary services on which The Company rely for the performance of The Company’s obligations hereunder.
      7. any claims, losses, damages, costs or expenses, lost opportunity to transact resulting from any Force Majeure circumstances which under the control of the Company.
   3. To the maximum extent permitted by applicable laws, Customer also agree to defend and indemnify the Company should any third party be harmed by Customer’s illegal actions.
   4. The Company’s liability will be limited to the fullest possible extent permitted by applicable law.

   DISCLAIMER OF WARRANTIES

   1. The Company’s Services and Platform are provided on an "as is" and "as available" basis. The Company expressly disclaims and Customer waives all warranties of any kind, whether expressed or implied or statutory, including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title and non-infringement as to The Company’s Services, Platform and the information, content and materials contained therein.
   2. The Company makes no representations or warranties that the Platform or Services, or any materials contained therein, will be uninterrupted, timely, secure or error-free; nor do The Company makes any representations or warranties as to the quality, suitability, truth, usefulness, accuracy, or completeness of the Platform or Services or any of the materials contained therein.
   3. Customer acknowledges that the information Customer stores or transfers through the Company’s Platform or Services may become irretrievably lost or corrupted or temporarily unavailable due to a variety of causes, including software failures, protocol changes by third party providers, Internet outages, force majeure or other disasters, scheduled or unscheduled maintenance, or other causes either within or outside The Company’s control. Customer is solely responsible for backing up and maintaining duplicate copies of any information Customer stores or transfers through The Company’s Services.

   SERVICE PROVIDERS

   1. The Customer does hereby agree and acknowledge that the Platform, and related software and Services may be provided by an external third-party licensor. The Company does not bear any responsibility as to the Platform and related software and Services provided by external third-party licensors. The Company make no representations or warranties that the technological facility (the Platform), and related software and Services will be uninterrupted, timely, secure, or error-free.
   2. The Customer hereby agrees and acknowledges that the functionality of the Platform, its configuration and content may be modified by an external third-party licensor.

   COMMUNICATIONS, STATEMENTS AND CONFIRMATION

   1. The Company may communicate with the Customer by sending information to Customer’s email or posting information on the Website, in which case the information will be treated as received by the Customer when it is posted by the Company.
   2. The Company may also contact Customer via email address of the Customer. Notices sent by email will be deemed to have been received at the time of transmission as shown by the sender’s records (or if sent outside business hours, at 9 am on the first business day following dispatch).

   COMPLAINTS

   1. If any conflict situation arises when the Customer reasonably believes the Company to be in breach of one or more terms of this Agreement as a result of any action or failure to act, the Customer has the right to file a complaint with the Company within one day after the grievance has arisen. The customer may send his complaint to: [email protected].

   PRIVACY

   1. Privacy and data protection are governed by The Company’s Privacy policy, which is available on the Platform.

   GOVERNING LAW AND JURISDICTION

   1. This Agreement, and the rights and obligations of the parties hereto, shall be governed by and enforced in all respects by the laws of Estonia.
   2. The Customer agrees that any civil action, arbitration or other legal proceeding between the Company or its employees or agents, and the Customer arising out of or relating to this Agreement shall be brought, heard and resolved only by a court located in Company’s jurisdiction.
   3. The Company may offer to settle any claim in an arbitration court in the jurisdiction of the Company.

   ANTI-MONEY LAUNDERING POLICY

   1. The Company is committed to providing its Customers safe and compliant Services. For this purpose the Company has developed an Anti-Money Laundering Policy, a summary of which is available on the Platform.

   AMENDMENTS

   1. The Customer understands, acknowledges and agrees that the Company may amend or change this Agreement at any time at its sole discretion. The Company will post the amendment or an updated version of the Agreement on the Platform with an indication of the last update date. The Customer agrees to be bound by the terms of such amendment or change on the earlier of:
   1. 1 (one) business day after the Company has posted such amendment as specified above; or
   2. on such occasion when the Customer executes any transaction on the Platform;
   2. All such amendments and changes shall apply equally to all Customers, including those who accepted this Agreement before the effective date of the amendments or changes.
   3. If the Customer objects to a part or all of the Agreement, then the Customer must stop using the Services of the Company immediately. By continuing to use The Company’s Services and the Platform, Customer acknowledge that Customer agree to be bound by provisions of this Agreement (with all changes and amendments hereto).

   TERMINATION

   1. This Agreement shall be in force until its termination, and may be terminated by the Customer at any time, provided that the Customer has no liabilities held by or owed to the Company.
   2. The Company may at any time suspend or terminate this Agreement without notice in the following cases:
   1. Customer breaches any condition of this Agreement or other legally binding obligations between the Company and Customer;
   2. Customer violate or the Company have reason to believe that Customer are in violation of any law or regulation that is applicable to Customer’s use of The Company’s Services; or
   3. The Company have reason to believe that Customer are in any way involved in any fraudulent activity, money laundering, terrorism financing or other criminal activity.

   FORCE MAJEURE

   1. The Company is not responsible for any damages caused by delay or failure to perform its obligations under the Agreement in the event that said delay or failure is due to fires; strikes; floods; power outages or failures; acts of God or the state’s enemies; lawful acts of public authorities; any and all acts that are regarded as Force Majeure in legal practice.

   COPYRIGHTS AND OTHER INTELLECTUAL PROPERTY RIGHTS

   1. Unless otherwise indicated, all copyright and other intellectual property rights of all content and other materials contained on The Company’s Website or provided in connection with the Services are the proprietary property of the Company.
   2. The Company grant the Customer a limited, nonexclusive and non-sub-licensable permission to access and use the data made available by the Company for personal or internal business use of the Customer. Such permission does not include any unauthorized distribution or use, modification or public display of any data made available by the Company. The permission granted under this provision will be automatically terminated if the Company suspends or terminates Customer’s access to the Services.

   RESTRICTED JURISDICTIONS

   1. The Company does not provide Services to persons who reside in the countries identified by the FATF as high risk or non-cooperative jurisdictions.

   SUPPORT

   1. If the Customer has any questions or concerns related to the Agreement, their rights and/or obligations, they can contact the Company according to the following contact information:

PayToPlay OU

Pärnu mnt 139C, office 210, Tallinn, Estonia, 11317

[email protected]

Last update: June 01, 2023

INTRODUCTION

This Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate risks of Paytoplay OU related to money laundering and associated risks. This is a short extract of key principles of the internal Policy and should not be seen as a complete document. You can request the full document by contacting customer support of the Company.

Domestic and international regulations require Paytoplay OU to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Customers.

AML/KYC Policy covers the following matters:

1. appointing of an Anti-Money Laundering Compliance Officer (AMLCO) and making sure that employees know how to report any suspicious activity to him;
2. identifying the responsibilities of senior managers and providing them with regular information on money laundering risks;
3. training relevant employees on their anti-money laundering responsibilities;
4. documenting and updating anti-money laundering policies, controls and procedures;
5. introducing measures to make sure that the risk of money laundering is taken into account in the day-to-day running of your business;
6. Forwarding/reporting all sustained suspicions to the relevant authority;
7. Promptly responding to all communication from the relevant authority.

GENERAL PRINCIPLES

Before the company can execute any transaction for any new Customer, a number of procedures need to be in place and carried out:

1. AML procedures, namely identification, record-keeping, discovering and monitoring unusual or suspicious transactions and as appropriate internal reporting and control;
2. Employees know their responsibilities and the company’s procedures;
3. Relevant training is being undertaken;
4. All relevant requests from outside sources are forwarded directly to the AMLCO.

IDENTITY VERIFICATION

Whenever the company receives supporting documents related to a new Customer’s identity, it needs to be completely satisfied that they demonstrate the existence of the new Customer as a real natural or legal person and that they are indeed whom they say they are. Although the company will at times rely on third party sources as part of its fact checking procedure when on boarding Customers, the company bears ultimate legal responsibility for the correct and full performance of the necessary checks under the present policy and applicable Law.

Customer’s identification information will be collected, stored, shared and protected strictly in accordance with the company’s Privacy Policy and related regulations that correspond to the GDPR requirements and its internal rules.

Upon implementing DD measures the following person shall be identified:

1. Client – a legal person;
2. Representative of the Client – an individual who is authorised to act on behalf of the Client;
3. Beneficial Owner of the Client;
4. PEP – if the Client or a person connected with the Client is a PEP

The Client shall be identified for the first time, i.e. before establishing a Business Relationship, electronically on the Website.

Electronic identification shall take place on the Website using the following sources

1. The source is the following data entered by the Client:
1. Legal entity name;
2. Email
3. Information regarding the purpose of using the Service;

ANTI-MONEY LAUNDERING COMPLIANCE OFFICER

AMLCO is ultimately responsible for implementing the regulations concerning AML. For the sake of ease of navigation in this document ‘compliance officer’ and ‘AMLCO’ refer to the same person; however, the specific tasks of each role are different.

As noted above, the AMLCO is a person of authority with access to any and all relevant information for the completion of his duties.

You can contact our AMLCO department by emailing us at: [email protected].

INTERNAL AUDIT AND AMENDMENTS OF THE POLICY

Compliance with the AML legislation shall be inspected at least once a year by the AMLRO.

If the inspection reveals any deficiencies in the Policy or their implementation, the report shall set out measures to be applied to remedy the deficiencies, as well as the respective time schedule and the time of a follow-up inspection.

If a follow-up inspection is carried out, the results of the follow-up inspection shall be added to the inspection report, which shall state the list of measures to remedy any deficiencies discovered in the course of the follow-up inspection, and the time actually spent on remedying the same.

The inspection report shall be presented to the Management Board, who shall decide on taking measures to remedy any deficiencies discovered.

REGISTRATION AND STORAGE OF DATA

The Company shall ensure that Client and Transaction data are registered in the Company’s Client database within the required scope.

Registration of data of a Client that is a legal person

The following information concerning a Client that is a legal person shall be recorded:

1. Name, legal form, registry code, address, date of registration and places of business;
2. Information concerning means of communication and contact person(s);
3. Field(s) of activity;
4. Country of tax residency of the legal person (VAT number);
5. Other relevant information having significance in the matter.

SANCTION POLICY

The Company is required to implement the applicable International Sanctions.

The Company is prohibited from transacting with individuals, companies and countries that are under international sanctions.

The Company shall draw special attention to all its Clients (present and new), to the activities of the Clients and to the facts which refer to the possibility that the Client is a subject of International Sanctions. Control and verification of possibly imposed International Sanctions shall be conducted by the Representatives as part of DD measures applied to the Clients in accordance with this Policy.

In case of doubt, the Company shall ask the Client to provide additional information that may help to identify whether the Client is the subject of International Sanctions.

The Company shall:

1. regularly monitor the website of the Financial Intelligence Unit (FIU) and immediately take measures provided for in the act on the imposition or implementation of International Sanctions;
2. upon entry into force of an act on the imposition or implementation of International Sanctions, the amendment, repeal or expiry thereof, immediately check whether any of the Clients are subject to International Sanctions with regard to whom the financial sanction is imposed, amended or terminated;
3. keep an updated record of subjects of International Sanctions and submit this information to the Representatives in the form that allows to use this information in the course of their activity;
4. provide training to the Representatives that allows them to establish independently the subjects of International Sanctions;
5. assist the Representatives if they have suspicion or knowledge that a Client is a subject of International Sanctions;
6. supervise the application of the Policy regarding the implementation of International Sanctions by the Representatives;
7. review and keep updated the Policy regarding the implementation of International Sanctions;
8. notify the FIU of Clients that are subjects of International Sanctions or regarding which the Company has suspicions;
9. keep a record of the performed checks, notifications submitted to the FIU and the applied measures regarding the detected subjects of International Sanctions.

If in the course of the check, it is detected that a Client or an organization that used to be a Client is the subject of International Sanctions, the Company shall notify the FIU.

PROHIBITED COUNTRIES

The Company does not provide services to persons residing in countries that:

1. Were black-listed by international organizations due to money laundering risks;
2. Consider services of the Company to be illegal and banned.

Full list of such countries is available in the full version of the Anti-Money Laundering Policy and can be accessed by requesting the same from Paytoplay OU. Company reserves the right to update this list by the decision of the AMLCO having effect prior to updating of this document.




Last update: June 01, 2023