KYC Policy

This Know Your Customer Policy (the “KYC Policy”) sets out the customer identification, verification, and due diligence procedures applied by gayporno, operating under the “test cas” brand (the “Company”, “we”, “us”, or “our”), to all persons seeking to access or use the services made available through the website at https://gtspin.com and any related pages and applications operating under the “test cas” brand (collectively, the “Platform”).

This KYC Policy operates as part of the Company’s broader AML/CFT compliance framework, and should be read together with the Company’s AML/CFT Policy, Terms and Conditions, and Privacy Policy. By creating an account or otherwise using the Platform, you acknowledge and accept that you are subject to the procedures described herein.

1. Purpose and Scope

1.1 The purpose of this KYC Policy is to enable the Company to: (i) establish the identity of each user prior to the provision of services; (ii) form a reasonable understanding of the nature and purpose of each user relationship in order to develop an individual risk profile; (iii) detect and prevent the use of the Platform for money laundering, terrorist financing, sanctions evasion, fraud, or any other illicit activity; and (iv) comply with the Company’s legal, regulatory, and contractual obligations.

1.2 This KYC Policy applies to every person seeking to register, fund an account, place bets or wagers, or withdraw funds on the Platform. Distinct verification requirements may apply depending on the nature of the account, the products and services accessed, and the assessed risk profile of the user.

2. Risk-Based Verification

2.1 The Company applies a risk-based approach to customer due diligence. The level and intensity of the verification measures applied to any given user shall be commensurate with the risks associated with that user, their funding sources, their geographic profile, and their patterns of activity on the Platform.

2.2 The Company maintains different categories of customer due diligence (“CDD”) for different account types and service tiers. Where the assessed risk increases, or where specific risk indicators are triggered, the Company shall apply enhanced verification measures as set out in clause 5 below.

3. Information Collected at Registration

3.1 At the point of account creation, and prior to the issuance of any deposit address (including, for example, a QR code) to a user, the Company collects baseline information through its onboarding portal. This information enables the Company to identify the user and to commence its initial risk assessment.

3.2 The information collected at registration may include any combination of the following, calibrated to the relevant risk profile and account type:

• Cryptocurrency wallet address;
• Email address;
• Full name;
• Residential address;
• Country of residence;
• Date of birth; and
• Postal code (collectively, the “KYC Information”).

3.3 The Platform is presently available exclusively to natural persons. Accounts opened by, or on behalf of, legal entities or other non-natural persons are not accepted.

3.4 Where the Company deems it appropriate, it may rely upon the performance by a third-party institution of some or all elements of its Customer Identification Programme (“CIP”).

4. Identity, Age, and Eligibility Checks

4.1 The Company engages third-party identity verification service providers to assess the authenticity and sufficiency of the identification materials and KYC Information submitted by users, and to confirm that each user is eligible to access the Platform.

4.2 As part of this process, the Company’s verification provider:

• Confirms the user’s identity and age against the documents provided;
• Verifies that the user does not appear to be located in a comprehensively sanctioned or otherwise prohibited jurisdiction; and
• Conducts searches against global sanctions databases and watch lists, including by reference to onboarding data such as wallet addresses.

4.3 In addition to the foregoing, the Company applies IP address-based geo-blocking in order to enforce restrictions in respect of prohibited and sanctioned jurisdictions. Users are notified at the point of onboarding that the Platform is not available in restricted jurisdictions, and are required to provide contractual certifications confirming that they are not located in, or resident in, any prohibited or sanctioned jurisdiction, and that they are not subject to United States, European Union, or other applicable international sanctions regimes or watch lists.

5. Enhanced Verification

5.1 The Company conducts ongoing monitoring of user activity in order to identify behaviours or indicators that may give rise to a heightened risk of money laundering, terrorist financing, or other illicit activity. For this purpose, the Company maintains a set of internal red flag indicators.

5.2 Where one or more red flags are triggered, or where other circumstances so warrant, the Company may suspend the user’s account or restrict withdrawals, and shall communicate to the user the steps required to restore normal account access. Such steps may include verification of the user’s cryptocurrency wallet by means of a deposit of an exact prescribed amount (as further specified in the Terms and Conditions or as communicated by a Support Agent via Live Chat), or completion of Enhanced KYC procedures as described below.

5.3 In addition, every user account, irrespective of its individual circumstances, shall be suspended pending the completion of adequate Enhanced KYC procedures once that account reaches a withdrawal threshold determined by reference to the risk characterisation assigned to it over the lifetime of the account.

5.4 Enhanced KYC under this Policy shall include, without limitation, the provision of:

• Full legal name;
• Country of citizenship;
• Permanent residential or business address (for individuals, a street address; for entities, a principal place of business or other physical location);
• Identification number, comprising either a tax identification number or, where unavailable, a passport number and country of issue, an alien identification card number, or the number and country of issue of another government-issued document evidencing nationality or residence and bearing a photograph or equivalent safeguard;
• A government-issued identification document; and
• Evidence of Source of Funds and Source of Wealth.

5.5 The Company may engage third-party service providers to verify any of the foregoing information where it considers this necessary in order to establish a reasonable basis to know the true identity of the user, or where the user’s activity otherwise warrants such verification.

6. Verification Provider and Handling of Verification Data

6.1 Information submitted by users in connection with verification procedures is processed by a third-party verification provider, SumSub. All such data is transmitted in encrypted form, is not stored on the Company’s servers under any circumstances, and is deleted by the verification provider immediately upon completion of the verification process.

6.2 The Company shall store and disclose user information only as appropriate to comply with legal process, or as otherwise permitted under the Company’s Privacy Policy.

7. Verification in Connection with Withdrawals

7.1 The Company reserves the right to refuse any withdrawal request until: (i) the user’s identity has been verified and the Company has confirmed that the withdrawal is being made by the holder of the account; (ii) the withdrawal is being transferred to an account of which the user is the legal holder; and (iii) any additional information requested by the Company has been provided.

7.2 The Company may carry out additional KYC verification procedures in connection with any withdrawal, irrespective of whether prior verification has been completed. Such procedures may include further documentary requests or enhanced due diligence measures, as the Company considers appropriate in light of the relevant risk profile.

8. Sanctions and Prohibited Persons

8.1 Prior to the issuance of a deposit address to a user, and on a periodic basis thereafter, the Company screens the user’s wallet address against applicable sanctions databases. Such screening relies on third-party blockchain forensics providers, including Chainalysis.

8.2 The Company will not accept, and will block, users who fall within any of the following categories:

• Persons who fail to provide the identification information requested by the Company;
• Persons who provide false or forged identification documents;
• Persons who employ any means to misrepresent or conceal their true location;
• Persons located or resident in restricted or prohibited jurisdictions;
• Persons subject to United States, European Union, or other applicable international sanctions regimes or watch lists;
• Persons whose funds originate from, or have been exchanged in, restricted jurisdictions; and
• Persons identified as gambling-addicted or as suffering from mental health conditions that may impair their capacity to engage in gambling activity.

8.3 The Company reserves the right to block or suspend any user for any other reason, at its sole discretion.

9. Consequences of Non-Compliance

9.1 Where a user fails to complete the verification procedures requested by the Company, or where the Company is unable to satisfy itself as to the user’s identity, eligibility, or source of funds, the Company shall be entitled to: (i) refuse to process any deposit or withdrawal request; (ii) suspend or close the user’s account; and (iii) retain any funds held in the account pending the satisfactory resolution of the relevant compliance concern.

9.2 Users shall be entitled to rebut any suspension by providing additional information as part of the Company’s ongoing transaction monitoring and customer due diligence procedures. The Company shall consider any such information in good faith and shall determine the appropriate course of action on a case-by-case basis.

10. Ongoing Monitoring

10.1 The Company conducts ongoing monitoring of user accounts and activity throughout the duration of the user relationship. This monitoring may include re-screening of wallet addresses against sanctions databases, review of transaction patterns and volumes, and reassessment of the user’s risk profile in light of any new information or activity.

10.2 Where ongoing monitoring identifies any matter requiring further investigation, the Company may apply such additional verification or due diligence measures as it considers appropriate, including, without limitation, any of the measures described in clauses 5 to 8 of this KYC Policy.

11. Contact

11.1 Where you have any questions regarding this KYC Policy, or in respect of any verification procedure applied to your account, you may contact us at [email protected].