🪪 PICK2WIN — Know Your Customer (KYC) Policy (UK)

📅 Effective Date: 1 February 2026
🏢 Operator: PICK2WIN Pvt Ltd (UK)
⚖️ Jurisdiction: England & Wales
🎰 Regulator: UK Gambling Commission (UKGC)
🌍 Website: www.pick2win.uk
📨 Support: compliance@pick2win.uk

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🎯 1. Purpose

The Know Your Customer (KYC) Policy ensures every PICK2WIN user is verified before withdrawing money to prevent identity fraud, financial crime, and underage access.
This policy follows:

• UK Gambling Commission (UKGC) Remote Technical Standards
• Money Laundering Regulations 2017 (MLR 2017)
• FCA Payment Services Regulations
• UK GDPR & Data Protection Act 2018

KYC ensures safety, fairness, and complete regulatory compliance.

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🧭 2. Objectives

PICK2WIN’s KYC process ensures:

1. Accurate verification of identity, age (18+), and UK residence
2. Only legitimate UK users can withdraw funds
3. Prevention of impersonation, underage access, and fraudulent activity
4. Compliance with AML/CFT obligations
5. Strong data protection and encryption under GDPR

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🧾 3. Verification Partner – SumSub

PICK2WIN uses SumSub (Sum & Substance Ltd), an FCA-registered, UKGC-compatible verification provider.

SumSub verifies:

• 🎂 Age check (must be 18+)
• 🪪 Identity authentication + biometric face match
• 🏠 Address verification
• 💳 Payment ownership matching

All processes are encrypted, audited, and compliant with UKGC & GDPR standards.

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👤 4. KYC Verification Requirements

4.1 Acceptable Identity Proof (ONE of the following)

• UK Passport
• UK Driving Licence
• National ID Card
• Biometric Residence Permit

4.2 Acceptable Address Proof (ONE of the following)

• Utility Bill (≤ 90 days)
• Bank/Card Statement (≤ 90 days)
• Council Tax Bill (current year)
• Government-issued letter

4.3 Payment Ownership Verification

• All deposits must come from an account/card in the same verified name
• Business, joint, third-party payments are not permitted
• Ownership mismatch results in immediate restriction

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🔍 5. Verification Timing & Process

Stage	Requirement	Required?
Account Registration	Basic details (name, DOB, postcode)	Auto-validated
Before First Deposit	❗ KYC NOT required	Optional
Before Subscription Purchase	KYC NOT required	Optional
Before Joining Paid Contests	Recommended	Not mandatory
Before First Withdrawal	FULL KYC MANDATORY	✔ Required
Ongoing Checks	AML risk-based	Triggered

⭐ CRITICAL OPERATIONAL RULE

Users may deposit, subscribe, and play WITHOUT KYC, but:

❗ NO withdrawal is allowed until full KYC is completed and approved.

Why KYC is NOT forced at registration

• Many users register but never become active → unnecessary verification cost
• Reduces friction for new users while still compliant
• Prevents verifying thousands of inactive accounts

Why withdrawal requires full KYC

Because money is leaving the platform and must go only to the verified real owner.
This prevents:

✔ Fraud
✔ Identity misuse
✔ Money laundering
✔ Third-party withdrawals

📌 User profile shows:
• KYC Pending until approved
• KYC Done after successful verification

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💷 6. Incomplete or Failed KYC

If KYC fails or remains incomplete:

• 🚫 Withdrawals blocked
• 🚫 Payment ownership restricted
• 🚫 AML flags may freeze account temporarily
• 📩 Users receive instructions to resubmit acceptable documents
• ⏳ 30+ days of no action may lead to temporary suspension

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🧩 7. Enhanced Due Diligence (EDD)

EDD applies when:

• Deposit/play behaviour exceeds affordability limits
• AML triggers emerge (patterns, frequency, device mismatch)
• Withdrawals appear inconsistent with declared income

EDD may require:

• Payslips
• Bank statements
• Source of Funds (SoF)
• Source of Wealth (SoW)

PICK2WIN rarely requests SoF/SoW because income-based monthly deposit limits already reduce AML risk.

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⚙️ 8. Re-Verification Triggers

Re-verification occurs if:

• User changes address or payment method
• New device/IP anomalies detected
• Inactivity for 6+ months
• Requested during regulatory or AML audits

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🔒 9. Data Protection & Retention

• All KYC records encrypted with AES-256
• Retained for minimum 5 years (legal obligation)
• Access allowed only to authorised AML/KYC officers
• Shared ONLY with regulatory authorities when required:

• UKGC
• FCA
• NCA
• Law enforcement

No KYC data is ever sold or used for non-compliance purposes.

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🧠 10. User Rights (GDPR)

Users can request:

• 📄 Access to their KYC data
• ✏️ Correction of inaccurate information
• 🗑 Deletion (unless we must retain it legally)
• 🚫 Processing restriction (where permitted)

Requests → privacy@pick2win.uk
Response → within 30 days

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🕵️ 11. Anti-Fraud & Misuse Prevention

PICK2WIN automatically flags:

• ❌ Multiple accounts
• ❌ Fake or edited documents
• ❌ Third-party funding
• ❌ Device/IP manipulation
• ❌ Collusion or coordinated gameplay

Serious violations →
⛔ Immediate permanent ban + report to UKGC, FCA, NCA.

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🧾 12. KYC Compliance Summary

Requirement	Verified By	Mandatory?	Notes
Age (18+)	SumSub	✔ Required	Before play
Identity Proof	SumSub	✔ Required	Before withdrawal
Address Proof	SumSub	✔ Required	Before withdrawal
Payment Ownership	SumSub + Stripe	✔ Required	Must match user name
AML / EDD	PICK2WIN Compliance	Trigger-based	Only for risk cases

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🛡️ 13. Policy Enforcement

• Non-compliance → withdrawal block or account freeze
• Fraud → permanent ban
• KYC must be kept accurate & up to date
• Withdrawals never occur until KYC Done

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💖 14. Ethical Commitment

PICK2WIN ensures:

✔ No underage access
✔ No identity misuse
✔ No fraud or money laundering
✔ User funds are protected
✔ Data is processed ethically & securely

“Verification builds trust — and trust builds a safer community.”

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📞 15. Contact Information

📧 compliance@pick2win.uk
🕘 Support Hours: 9 AM – 9 PM (GMT), Mon–Sun

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