Kyc Policies

Introduction

Go123 maintains a comprehensive KYC policy to verify customer identity, assess risk, and monitor activity. The policy supports compliance with applicable anti‑money laundering and countering financing of terrorism laws and protects the integrity of the Go123 platform for all users.

Legal Basis, Scope and Roles

Go123 N.V. operates under licensing and regulatory oversight by the Curacao Gaming Control Board. This KYC policy applies to all current and prospective customers, and to all onboarding, deposits, withdrawals, transfers and other activities conducted on the Go123 platform.

Definitions

• Personal Data: information relating to an identified or identifiable individual that is processed by Go123 in connection with the services.
• KYC: Know Your Customer procedures designed to identify and verify customers and to assess risk.
• Due Diligence: the level of verification and monitoring applied based on risk, including Simplified, Standard, and Enhanced levels as warranted.
• Data Controller: Go123 N.V., registered in Curacao, processing personal data for the purposes described in this policy.
• Source of Funds/Wealth: the origin of funds used in transactions and the overall financial means of the customer.
• Ongoing Monitoring: continuous review of customer activity to detect and report suspicious or non‑compliant behavior.

Data Collected and Processing

Go123 collects and processes personal data necessary to verify identity, assess risk, and fulfill legal obligations. Data may include name, date of birth, nationality, residential address, contact details, government‑issued identity documents, proof of address, occupational information, and information regarding the source of funds. Device data, IP addresses, and transaction histories may also be collected to support identity verification and monitoring activities.

Data processing is conducted on the lawful bases of contract, compliance with legal obligations, and legitimate interests in preventing financial crime and protecting platform integrity. Personal data may be shared with regulators, payment processors, service providers acting on Go123’s behalf, and as otherwise required by law.

Personal data is retained in accordance with regulatory obligations, with an explicit retention period of eight (8) years from the date of the last transaction or account closure, whichever is later, unless a longer period is required by applicable law. Data subject rights, including access, correction, deletion, and objecting to processing, are described below under Rights of Data Subjects. For details on cookies and similar tools, refer to the Privacy Policy.

Identity Verification and Customer Due Diligence

1. Onboarding Verification: Before enabling full service, Go123 will verify the customer’s identity and the ownership of the payment instruments used for funding the account.
2. Documents and Data Required: accepted identity documents include government‑issued, non‑expired photo IDs; proof of address dated within the last three (3) months; and, where applicable, evidence of the source of funds and/or source of wealth.
3. Verification Methods: Go123 employs a combination of document verification, data cross‑checking against internal and external sources, and risk scoring to determine verification status. Automated checks may be supplemented by manual review where indicated by risk signals.
4. Verification Status: accounts transition through statuses such as Unverified, Verification In Progress, and Verified. Pending verification may restrict certain activities, including deposits, withdrawals, or higher‑risk transactions.
5. Ongoing Verification: customer information and documents may be re‑verified at regular intervals or when trigger events occur (e.g., changes in risk assessment, large or unusual transactions).

Risk‑Based Approach and Enhanced Due Diligence

Go123 applies a risk‑based approach to due diligence. Low‑risk customers may be subject to Simplified Due Diligence, while Standard or Enhanced Due Diligence is applied based on factors such as transaction volume, geography, funding sources, and customer profile. Enhanced Due Diligence may require:

• Additional documentation of source of funds and source of wealth;
• Proof of employment or business activity;
• Independent verification of information and ongoing monitoring with increased frequency;
• Periodic review of high‑risk accounts and activities;
• Compliance with regulatory disclosure requirements and cooperation with authorities.

Age, Eligibility and Geographic Restrictions

Go123 accepts only individuals who are at least eighteen (18) years of age and who reside in jurisdictions where the platform operates lawfully. Where restrictions apply, Go123 reserves the right to refuse service or to terminate accounts that do not meet applicable eligibility criteria.

Data Security and Confidentiality

Go123 implements appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, and destruction. Security measures include data encryption in transit and at rest, access controls, restricted data processing, regular vulnerability assessments, and audit trails. All processing is conducted in accordance with applicable data protection laws and the Privacy Policy.

Data Sharing, International Transfers and Third‑Party Processors

Go123 may share personal data with trusted third‑party processors (e.g., payment services, identity verification providers) and with regulatory authorities as required by law. When data is transferred outside the local jurisdiction, Go123 will ensure an adequate level of protection in accordance with applicable data protection rules and standards.

Regulatory Reporting and Surveillance

Go123 conducts ongoing transaction monitoring for suspicious activity and adheres to reporting requirements to relevant regulatory bodies where warranted. If activity suggests potential violations of law, appropriate disclosures may be made and accounts may be suspended or terminated.

Retention, Access and Rights of Data Subjects

Data subjects may request access to their personal data, request corrections, withdraw consent where applicable, or request deletion in accordance with applicable law. Requests should be submitted to the Go123 Compliance Office via the designated contact channel. Go123 will respond in a timely manner and in accordance with legal obligations.

Complaints, Disputes and Remedial Actions

Customers with concerns about KYC processing or data handling may contact the Go123 Compliance Office for resolution. If concerns remain unresolved, customers may pursue remedies with the relevant supervisory authority in accordance with applicable law.

Policy Changes and Customer Obligations

Go123 may update this KYC policy to reflect changes in law, regulation, or risk management practices. Material changes will be communicated to customers at least fourteen (14) days before effective date. Continued use of the platform after the change constitutes acceptance, unless the customer terminates the account prior to the effective date.

Contact Information

For questions about this policy or to exercise data subject rights, contact: Go123 Compliance Office, [email protected].