This KYC and AML Policy governs Spinsup’s obligations to verify customer identities, monitor for money laundering and terrorist financing risks, and ensure compliant operation of the Spinsup platform. The policy applies to all customers, prospective customers, and any person accessing or using the Services.
Spinsup N.V., a regulated entity incorporated in Curaçao, acts as the data controller for personal information collected in connection with the Services. The policy designates an AML Officer responsible for oversight, governance, training, and escalation of potential compliance concerns. Spinsup adheres to applicable data protection laws, including retention of personal data for eight (8) years from the date of collection or the end of the customer relationship, whichever is later, subject to applicable statutory requirements.
Spinsup implements a risk-based monitoring program designed to identify unusual or potentially unlawful activity. The program includes automated transaction monitoring, pattern analysis, and cross-referencing of gaming activity with communication and payment histories where appropriate. Suspicious activity indicators include, but are not limited to, irregular deposit/withdrawal frequencies, atypical transaction sizes, rapid movement of funds, and discrepancies between payment method data and account activity.
Customers identified as high risk or politically exposed persons (PEPs) are subjected to enhanced due diligence. This includes increased verification steps, more frequent account reviews, and heightened scrutiny of transactions, including source of funds and destination of withdrawals. Risk assessments are reviewed and updated at regular intervals and upon material changes in customer profile or behavior.
Spinsup prohibits activation of accounts or processing of payments for customers located in or connected to jurisdictions where online gambling is restricted, prohibited, or where Spinsup is not licensed or sanctioned to operate. A non-exhaustive list of commonly restricted jurisdictions includes regions subject to international sanctions or gambling restrictions. If a customer’s residence, IP address, or payment method indicates connection to a restricted jurisdiction, account creation or continued activity may be blocked, funds refused, or an existing account closed with appropriate reasons recorded. Spinsup reserves the right to take additional steps consistent with applicable laws and sanctions regimes.
Spinsup conducts ongoing sanctions screening of customers and associated payment methods against applicable sanctions lists. If a match is identified, Spinsup may suspend or terminate access to Services and report the relevant information to the appropriate authorities as required. Spinsup may also request additional information to confirm identity, address, or source of funds and may temporarily restrict withdrawals during such inquiries.
Withdrawal permissions may be restricted during verification processes or if suspicious activity is suspected. Where verification is pending, Spinsup may place temporary holds on withdrawals or require additional documentation before funds can be released. Customers are notified of any temporary restrictions and the reasons for them.
Customers must not maintain more than one Spinsup account. Discovery of multiple accounts may result in the closure of all affected accounts and the forfeit of any winnings, at Spinsup’s discretion, to prevent circumvention of limits, verification or AML controls.
Personal data collected for AML/KYC purposes is processed lawfully, fairly, and transparently. Customers have rights to access, rectify, erase, or restrict processing of their personal data and to withdraw consent where applicable. Data may be retained for eight (8) years after the end of a customer relationship, or as required by applicable law. Spin sup may use cookies and similar tools in connection with security and authentication operations. Rights to data access and correction can be exercised by submitting a request to the designated data controller.
All Spinsup personnel receive regular AML training. The AML Officer is responsible for policy maintenance, incident response, and liaison with regulators and law enforcement where required. Policies are reviewed at least annually or upon significant regulatory change, product updates, or risk events.
All pertinent records related to customer verification, risk assessments, and transaction monitoring are maintained for the period required by law. Suspected money laundering or terrorist financing activities must be reported to the relevant financial intelligence unit (FIU) in accordance with applicable law, with information retained as part of the investigation and compliance process.
Customers may submit complaints regarding AML/KYC processing or data handling. Spinsup will acknowledge receipt, investigate in a timely manner, provide a resolution, and, if applicable, escalate to regulators in accordance with the formal complaint handling framework. Contact: [email protected]