Identity verification policy

This Identity verification policy (the "Policy") sets out how Peeks confirms who you are, how old you are, where you live and, when needed, where the money and items you use on the Service come from. It is also our know your customer, or KYC, policy.

This Policy forms part of the Terms of service (the "Terms") and uses the definitions in them, including Peeks, we, us, you, Access Code Account, Account, Applicable Law, Balance, Business Day, Cashier, Connected Person, Daily stake limit, Deposit limit, Digital Currency, Launch Date, Levels, Loss limit, Masking Tool, Network Check, Play break, Prohibited Conduct, Recorded Debt, Self-exclusion, Service, Site, Skins, Steam, Step-up Check, Support, Tip, Trade URL, Vault and Verification Level. Linked Steam Account has the meaning given in the Skins trading policy. Section 2 defines the further terms this Policy uses. This Policy adds detail to section 7 of the Terms.

This Policy applies to every Account from the moment it is opened. It continues to apply after an Account is closed to any Verification that concerns activity before the closure.

This Policy works together with:

• the Anti-money laundering policy, which sets out the program that this Policy carries out Account by Account;
• the Privacy policy, which governs all personal data we process, including the data described here;
• the Restricted countries and VPN policy;
• the Payments policy and the Skins trading policy;
• the Responsible gambling policy and the Self-exclusion policy; and
• the Complaints policy.

By opening an Account you agree to the checks this Policy describes, and you authorize us, and the Identity Partner acting for us, to collect, check and keep the information and documents it lists. Before any step that needs your express consent under Applicable Law, such as the comparison of your face with the photo on your Identity Document, we ask for that consent at the step itself.

This Policy is written in English. Where we also publish it in another language, the English version decides any difference in meaning.

In this Policy:

• "Compliance Officer" means the person appointed under section 5 of the Anti-money laundering policy to own our anti-money laundering measures.
• "Enhanced Verification" means the further checks described in clause 5.8 and section 9.
• "Identity Document" means a document listed in clause 7.1.
• "Identity Partner" has the meaning given in the Terms: the independent identity verification service that carries out Verification Levels 2 to 4 for us, as section 5 describes.
• "Liveness Check" means a live capture of your face, taken through the Identity Partner, which shows that a real person is present and is the person pictured on the Identity Document.
• "Personal Details" means the details you give at Verification Level 1, listed in clause 5.2.
• "Politically Exposed Person" or "PEP" has the meaning given in section 10 of the Anti-money laundering policy. Every check this Policy applies to a PEP also applies to the PEP's family members and close associates.
• "Proof of Address" means a document listed in clause 8.1.
• "Request" means a request from us under this Policy for information or documents, made on the Site, including through live support, or by email to the address registered on your Account.
• "Response Period" means the time allowed to answer a Request under clause 13.3.
• "Restriction" means a limit placed on an Account under section 13.
• "Sanctions Lists" means the lists of persons and entities subject to financial sanctions that bind Peeks under clause 3.4.
• "Source of Funds" and "Source of Wealth" have the meanings given in the Anti-money laundering policy: where the money or items used on your Account came from, and the activities through which you came to hold your wealth as a whole.
• "Supporting Document" means any document we ask for other than an Identity Document or a Proof of Address.
• "Verification" means any check under this Policy at any Verification Level, including a repeated check and an Enhanced Verification.

Peeks is operated by 3-102-136856 Limitada, trading as Peeks Entertainment Limitada, a company organized under Costa Rican law with corporate identity number (cédula jurídica) 3-102-136856, whose registered address is Provincia 06 Puntarenas, Canton 11 Garabito, Jaco, Costado Este De La Municipalidad Garabito, Bufete Sanchez Chavarria, 61101, Costa Rica. The company's details are set out on the Company and license page.

We hold a Costa Rican data processing license.

We carry out Verification to meet our duties under Applicable Law, including:

• Law 7786 on narcotics, psychotropic substances, drugs of unauthorized use, related activities, money laundering and terrorist financing, as amended by Laws 8204 and 9449, together with its regulations, the supervision of the General Superintendency of Financial Entities (SUGEF), and reporting to the Financial Intelligence Unit of the Costa Rican Institute on Drugs (ICD);
• Law 8968 on the protection of persons with regard to the processing of their personal data, its regulation, and the oversight of the Agency for the Protection of the Data of Inhabitants (PRODHAB); and
• the standards of the Financial Action Task Force (FATF) on customer due diligence, Politically Exposed Persons and casinos, set out in its Recommendations 10, 12 and 22, which we apply as our own policy.

We may check you against the Consolidated List of the United Nations Security Council and against any other Sanctions List that binds us.

We use Verification to:

• establish that you have reached 18, or any higher age that the law applying to you sets;
• establish that you are a real, identified person who holds one Account only;
• establish that you neither live in, nor use the Service from, a country where it is not offered;
• prevent fraud, Account takeover, money laundering and the financing of terrorism;
• identify PEPs and persons named on Sanctions Lists;
• confirm that the Linked Steam Account and the items you deposit are yours;
• find the persons described in clause 3.7;
• notice when the spending on an Account may be more than its holder can afford; and
• answer lawful requests from competent authorities.

The Identity Partner and our other providers report results to us. Every decision about your Account under this Policy is made by Peeks. Where an outcome is reached by automated means, you may ask for it to be reviewed by a member of our staff under clause 20.3.

An Account may not be held anonymously or under a false name. Other players see your username, and the identity you give us under this Policy stays behind it. The Terms and section 7 of the Anti-money laundering policy set out in full who may not open or use an Account, and Verification is how we find them, including:

• persons under the age in clause 14.1;
• residents of, and persons located in, a country where the Service is not offered;
• persons named on a Sanctions List;
• persons on a Play break or in Self-exclusion who try to open another Account;
• our staff, the staff of our providers and their Connected Persons, as clause 4.8 of the Terms provides;
• persons acting for someone else or for a company; and
• persons whose earlier Account we closed because of gambling harm, or for Prohibited Conduct such as fraud, a false identity or a forged document, unless we have agreed in writing to their return, as clause 4.9 of the Terms provides.

Our Compliance Officer is responsible for this Policy, approves the Accounts of PEPs, and decides on closures and reports made under section 13. Staff who review Verifications are trained before they start that work and at least once a year after that, under section 27 of the Anti-money laundering policy.

The depth of a Verification depends on the risk an Account presents, judged from the amounts involved, the pattern of activity, the countries connected with the Account and the results of earlier checks. Two players at the same stage may be asked for different things.

Verification links each Account to one identified adult. Accounts are for individuals only, and you may hold one Account only, as the Terms provide. We may refuse an Identity Document already used to verify another Account, and a Steam account linked to one Account cannot be linked to another unless our staff release it under the Skins trading policy.

Verification is not complete once and for all. We may repeat any Verification Level, or ask for more than a Verification Level requires, at any time while the Account is open, including after a Verification Level is complete.

We record every Request, submission, result, decision and Restriction on the Account, with the reason for it and the time it was made.

The information and documents you give must be true, complete, current and your own. You must not withhold information that would change the outcome of a Verification.

Each Account is given a risk rating of low, medium or high under section 6 of the Anti-money laundering policy, and the rating is reviewed whenever the activity or circumstances of the Account change. At a low rating, the Verification Levels apply as clause 5.10 sets out. A higher rating can bring a Verification Level forward, add an Enhanced Verification or a Source of Funds check, and shorten the time between reviews. A link with a country that the FATF lists as under increased monitoring, or that we rate as high risk, can raise the rating by itself. A rating measures risk and is not a finding against you.

Two adults who live together may each hold an Account, and either of them may tell Support that they share a home, a device or a network, as clause 6.15 of the Terms provides. Accounts that share an address, a device or a network may be reviewed together, and each holder may be asked to complete a Verification Level. If you lose access to your Account, ask Support to restore it under clause 6.14 of the Terms instead of opening a new one. An Account opened while you still hold another is closed under clause 6.2 of the Terms.

Verification has four Verification Levels, completed in order, and a Verification Level can be started only once the one before it is complete. Verification Levels have no connection with Levels, the player program. Verification Level 1 must be complete before every deposit. Verification Levels 2 to 4 are carried out through the Identity Partner, which is not yet connected. Until it is, a request to start any of them is refused and an action that needs one of them cannot go ahead, and once Verification Level 1 is complete, the Verification tab of the Settings page shows Verification Level 2 as not available yet. Clause 5.10 sets out which actions need which Verification Level.

Verification Level 1 consists of your Personal Details, which you give us on the Verification tab of the Settings page: your first and last names, your date of birth, and your street address, city, state or region, country and postal code. We refuse a date of birth that is not a real date, that gives an age under 18, or that falls more than 110 years in the past. We also refuse your Personal Details where you are younger than the minimum age set for the country in them or for the country you connect from, under clause 2.5 of the Restricted countries and VPN policy, and the Site then shows "We can't continue with your account. Contact support."

Once you have given your Personal Details, Verification Level 1 is complete and the Verification tab no longer offers the form. To correct them, ask Support. Until a Verification Level 2 session starts, we may correct them at your request. From then on they are locked, and our Compliance Officer decides any request to change them under section 17.

Verification Level 2 confirms your identity with an Identity Document and a Liveness Check, through the Identity Partner.

Verification Level 3 confirms your address with a Proof of Address, through the Identity Partner.

Verification Level 4 confirms your Source of Funds and, where we ask for it, your Source of Wealth, under section 9.

Once the Identity Partner is connected, you start Verification Level 2 on the Verification tab of the Settings page after completing Verification Level 1, and Verification Levels 3 and 4 when the Site asks you to. Each attempt opens a session with the Identity Partner on a secure page, with its own reference and an expiry time, and returns you to the Site when you finish.

At any Verification Level we may also ask you for any of these:

• a second Identity Document;
• a new Liveness Check, or a photo in which you hold up your Identity Document next to a handwritten note showing a code we give you and the date;
• a voice or video call with our staff, to show us the original of a document or to go through a Request;
• a copy of a document attested by a notary public, or one bearing an apostille;
• confirmation of a document's authenticity from the authority that issued it; and
• a written explanation of a transaction or a pattern of activity, with Supporting Documents.

We and the Identity Partner may compare the information you give with records held by the authority that issued a document, with public records, and with fraud prevention and sanctions screening databases.

Each of the following is needed before the actions listed with it:

• a Linked Steam Account, and a verified email address where the Cashier lists one: every Skins deposit and withdrawal;
• Verification Level 1: every deposit;
• Verification Level 2: a deposit that brings your deposits in the last 30 days to $2,000 or more, and any deposit or withdrawal by a method that the Cashier shows as needing a verified identity;
• Verification Level 3: any action for which we ask for it, and the start of Verification Level 4; and
• Verification Level 4: a deposit that brings your deposits and the Tips you have received to $10,000 or more in the last 30 days, or to $25,000 or more in the last 365 days, and any Account under Enhanced Verification.

Clause 6.4 explains how these totals are counted. Where a deposit needs a Verification Level you have not completed, the Site shows "Verify your identity to deposit.", and where a withdrawal does, "Verify your identity to withdraw." Tips need no Verification Level, but we may ask for one before a Tip under clause 6.1.

If you, a member of your family or a close associate of yours holds, or has held, a prominent public function, you must tell Support before you make a first deposit, as clause 4.10 of the Terms requires, and tell us of any change promptly, as clause 10.4 of the Anti-money laundering policy requires. We keep a record of what you tell us and when.

We agree the time of any call under clause 5.8 with you in advance. We tell you at the start if the call is recorded, and any recording is kept with your Verification records under clause 18.7. Staff on a call never ask for anything listed in clause 11.3.

We may ask for information or documents under this Policy at any time, including before, during or after a deposit, a withdrawal, a Tip or a bet.

When you register, you check a box to state that you are at least 18 and that you accept the Terms. We record that statement together with the version of the Terms you accepted, and we may send a link to verify your email address.

Each deposit and withdrawal method shows its requirements in the Cashier. Skins deposits and withdrawals always need a Linked Steam Account, and a verified email address where the Cashier lists one, and clause 5.10 sets out the Verification Levels each action needs.

Before each deposit, we add up the deposits on your Account in the last 30 days, and the deposits together with the Tips you have received in the last 30 days and in the last 365 days. Each total counts the new deposit and any deposit still under way. Verification Level 2 must be complete before a deposit that brings the first total to $2,000 or more, and Verification Level 4 before a deposit that brings the second to $10,000 or more or the third to $25,000 or more. A Verification Level that has started but is not complete counts as the Verification Level below it. We may treat transactions that appear to be linked as one, including transactions split or timed to stay under an amount and transactions made through other Accounts acting with yours. A single Tip is limited to $10,000, and an Account may send up to $50,000 and 100 Tips a UTC day. We may ask for Verification Level 3, or for any Verification Level before these amounts are reached, at any time.

We may also start a Verification, or move an Account to a higher Verification Level, when:

• the Network Check finds a VPN, a proxy, Tor or a hosting network, or records a time zone on your device that differs from your network's;
• your network, your Personal Details and your documents point to different countries;
• there are signs that one person holds more than one Account, or that an Account is used by someone other than its holder;
• someone tries to link a Steam account already linked to another Account, or to save a Trade URL that belongs to a different Steam account;
• a withdrawal is requested after deposits with little or no play;
• Tips are large or frequent, pass back and forth between the same Accounts, or go to Accounts with which you share other links;
• deposits, withdrawals or Tips appear to be split, or timed, to stay under an amount in this Policy;
• activity on the Account becomes much larger or faster than before, or many deposits are made in a short time;
• a Skins deposit or withdrawal is reversed in Steam, or deposited items appear to be stolen or obtained by fraud;
• the email address, password, two-step login, Linked Steam Account or Trade URL changes shortly before a withdrawal;
• there are repeated failed sign-ins or two-step codes, sign-ins from several countries in a short time, or sessions that keep passing between devices;
• you ask to recover an Account, in particular without your authenticator app or recovery codes;
• you ask how to avoid a check, or what we report to the authorities;
• a check against a Sanctions List or a PEP list shows a possible match, or we find adverse public information about you;
• we have reason to doubt your age;
• your activity does not fit the information we hold about you, including your Source of Funds; or
• a competent authority asks us to, or Applicable Law requires it.

Before we act on a request to close an Account, to change locked details, to access, correct or delete personal data, or to release a Balance, we may confirm that the request comes from the Account holder.

We review completed Verifications at intervals set by the risk rating of the Account under clause 4.6, when an Identity Document expires, and when the information we hold appears to be out of date. We may also select Accounts for Verification at random.

When a Verification is needed, we tell you what it requires. Each Request lists everything we need at that stage, and we ask again only where what you send is incomplete or raises a new question, or where a further event under clause 6.5 occurs. We do not give the reason for a Request where Applicable Law forbids it.

Before a withdrawal is sent, we may check it against the deposits, play and Tips on the Account, as section 20 of the Anti-money laundering policy describes. We record the result of the checks run on each withdrawal, and we mark for review by our staff a withdrawal of $2,000 or more, or one that takes the withdrawals of the last 24 hours above $10,000. Our staff may pause withdrawals on the Account, or refuse a withdrawal, for review because of its size or pattern, or at random. When we do, we tell you, unless Applicable Law forbids it.

We accept the following documents, as long as each is valid, issued by a government authority and shows your photo:

• a passport;
• a national identity card, including a residence document issued to foreign residents; and
• a driving license, where the Identity Partner accepts the format of the issuing country.

An Identity Document must:

• be the original, valid on the day it is checked, and not reported lost or stolen;
• carry your full name, your date of birth, your photo, the document number, the issuing country and the expiry date;
• be shown in full, front and back where both sides carry information, with every edge in view;
• for a passport, show the whole photo page, including the machine-readable lines along its lower edge;
• bear your signature, where the document has a space for one; and
• be captured as a sharp color photo or scan, free of glare and shadow, with no finger or object covering any part of it.

We do not accept:

• expired, damaged or altered documents;
• photocopies, printouts, screenshots or pictures of a screen, other than an attested copy that a Request asks for under clause 5.8;
• documents without a photo, such as birth certificates, or documents not issued by a government, such as student, employee or membership cards; or
• documents that belong to another person.

Your Personal Details must agree with the name and birth date printed on your Identity Document. Our staff review small differences, such as a missing middle name, names in a different order, or a spelling that changes with accents or another alphabet. Any other difference needs Supporting Documents under section 17. Clause 7.9 explains how the details on the document reach us.

The Liveness Check uses the camera on your device and follows prompts on the screen. You must take it yourself, live, alone in the frame, in good light and with your face uncovered. A religious head covering that leaves the face in view is accepted.

We refuse a Liveness Check that uses a photo, a screen, a mask, a recording, or an image changed or generated by software. An attempt to pass one is a serious breach under clause 13.7.

The Liveness Check compares a map of your facial features with the photo on your Identity Document. The comparison serves Verification and fraud prevention only. Biometric data of this kind may be sensitive data under Law 8968, and we process it only with your express consent.

You may decline the comparison of your face, or withdraw your consent to it later, by telling Support. Withdrawing consent does not undo a check already made, and its result stays on the Account under section 18. When you withdraw consent, we ask the Identity Partner to delete the face data it holds for you, unless Applicable Law requires it to be kept. If you decline or withdraw, we offer another way to complete the Verification Level under clause 11.9 where one meets Applicable Law, and every limit that depends on that Verification Level continues to apply until it is complete.

The Identity Partner reports to us the details it reads from your Identity Document, including your name, date of birth, the issuing country, the document number and the expiry date. We use them to compare the document with your Personal Details and to know when it expires, and we may use them to find a document used on more than one Account, in any check under section 15 and in applying section 16. We may also ask for your occupation at any Verification Level.

An Identity Document issued by a country where the Service is not offered is accepted only together with a residence permit, or a national identity document, showing that you live lawfully in a country where the Service is offered, and a Proof of Address there.

We accept the following documents, each showing your full name, the residential address in your Personal Details, the name of its issuer and the date it was issued, and, except for a tenancy agreement, dated within the last three months:

• a bill for electricity, water, gas, a landline telephone or home internet;
• a statement from a bank or another regulated financial institution;
• a letter or statement from a government authority, such as a tax or social security office;
• a home insurance document; and
• any other document named in a Request.

A statement downloaded from its issuer as a PDF is accepted only as the file the issuer gave you; a PDF saved again through editing software is refused, and so is a screenshot of a web page or an app. We also refuse mobile phone bills, envelopes, documents that show only a post office box or a mail forwarding address, and documents in another person's name.

A document can serve as an Identity Document or as a Proof of Address, but not as both. A driving license that shows your address does not prove that address.

Your Proof of Address must show where you live now, in a country where the Service is offered under the Restricted countries and VPN policy.

Where no document is issued in your name at your address, tell Support before the Response Period ends, and clause 11.9 applies.

We ask about Source of Funds at Verification Level 4, in an Enhanced Verification, and when the amounts deposited, withdrawn or sent as Tips are large for the Account. We ask about Source of Wealth where Source of Funds alone does not explain the activity. We ask about both in every case that involves a PEP, or a country that the FATF lists as under increased monitoring or that we rate as high risk.

We may ask you to declare your occupation, the kind of work you do, such as employed, self-employed or retired, and your income, and for the evidence that fits your situation, usually covering the last three months:

• employed: recent payslips, a letter from your employer or a yearly statement of your pay;
• self-employed or a business owner: your latest tax return, or the accounts of the business with evidence of your share in it;
• retired: a pension statement, or bank statements showing your pension payments;
• rental income, dividends or investments: a tax return, or statements from the account that pays them;
• a sale of property, investments or digital assets: the sale documents and the bank entry that received the proceeds;
• an inheritance or a legal settlement: the will, the court order, the settlement or the estate accounts;
• a gift or support from family: a letter from the giver, with evidence of where the giver's money came from;
• winnings from another gambling operator: its statement of your wins and losses over a stated period and, if we ask, how you funded that play; and
• Skins sold on another marketplace: your sales history there.

For Skins, Source of Funds includes how the items reached your Steam inventory: bought on Steam or the Steam Community Market, received in a trade, opened from a case, or bought on another marketplace. We may ask for your Steam purchase, market or trade history, or for receipts from a marketplace. For Digital Currency, where the Cashier accepts it, Source of Funds includes how you came to hold it, and we may ask for the history of the wallet or exchange account it came from.

On a bank statement you may cover entries that are not relevant to the Request. Your name, the issuer, the last four digits of the account number, the dates and the entries we asked about must stay visible. Where you can, send statements that show both the income and the payments from it for the Skins you deposit.

We compare what you send with the activity on the Account and may ask follow-up questions. The documents must show that the money or items came from a lawful source and belong to you.

What you tell us about your income and Source of Funds also helps us protect you. Where it shows that your play may be more than you can afford, we may contact you and suggest a Deposit limit, a Loss limit, a Daily stake limit, a Time limit or a Play break under the Responsible gambling policy. We never use this information for marketing.

Skins deposits and withdrawals use only the Linked Steam Account. It must be your own account, used by you alone. An account that belongs to someone else, or that is shared, borrowed, rented or bought, may not be linked. Before each trade, the Linked Steam Account must also meet the conditions in clause 4.9 of the Skins trading policy, which include Steam Guard Mobile Authenticator for every withdrawal and every Rust deposit.

You link a Steam account by signing in through Steam, which tells us the account's Steam ID. We do not receive your Steam password. Each Account can have one Linked Steam Account, and a Steam account linked to one Account cannot be linked to another unless our staff release it under the Skins trading policy.

Linking or unlinking a Steam account, and saving a Trade URL, each need a Step-up Check. The Linked Steam Account can be changed only while no trades are open. Withdrawals currently wait 24 hours after a new link or a new Trade URL.

The Trade URL must belong to the Linked Steam Account. We refuse a Trade URL for any other Steam account, and we send withdrawals only to the Linked Steam Account.

For Skins, the Linked Steam Account is the payment method, and you must be able to show ownership of the payment method when we ask. We may ask for screenshots, taken while you are signed in to Steam, of the account's profile, inventory, purchase history or trade history, or for the other proof listed in clause 11.6 of the Payments policy.

The name on a Steam profile, and the Steam account itself, are not evidence of your identity, age or address.

Items you deposit must be yours and lawfully obtained. You must not deposit items on another person's behalf or items that belong to someone else, and you must not deposit items obtained through theft, Account takeover, phishing or a purchase that was later reversed.

Steam, and AssetPay, which processes Skins trades for us, apply their own terms. A check that either of them runs is separate from Verification under this Policy and does not replace it.

Where AssetPay needs to confirm who you are in order to process a Skins trade, we may give it the result of your Verification and the details it needs, and nothing more. Where AssetPay asks us about a trade, we may put its questions to you in a Request. Where the details AssetPay holds for a trade do not match your Personal Details, we may hold the trade until the difference is explained.

You give your Personal Details on the Verification tab of the Settings page. Once the Identity Partner is connected, documents and Liveness Checks go through its secure pages, opened from the Site. You may also be asked to send documents through the Site, or through another secure channel named in a Request.

Support messages carry text only, and we do not accept documents through them. We never ask for documents in the Peeks Discord server, in direct messages on any social network, or by email, unless a Request names email as the channel.

We never ask for your password, two-step codes, recovery codes, Steam Guard codes or Steam Web API key. Do not include any of them in what you send.

Each file must be legible and in color. A file sent through the Site must be a PDF, JPEG or PNG file of no more than 10 MB. We may ask for a translation, made by an official translator, of a Supporting Document that is not in English or Spanish.

Documents must not be edited or altered in any way. We refuse edited, combined or generated images, forged documents and another person's documents, and sending any of them is a serious breach under clause 13.7.

You may cover part of a document only where this Policy or a Request allows it. Where we ask for a copy of an Identity Document outside the Identity Partner's pages, you may cover any number we do not need, such as a tax or social security number, but your name, date of birth, nationality, photo, document number and expiry date must stay visible. We may ask for a complete copy where Applicable Law requires it.

A Supporting Document about another person, such as a letter from the giver of a gift, may be sent only with that person's permission.

We charge nothing for Verification. You bear your own costs of obtaining documents, translations and notarial copies.

If you cannot provide something a Request asks for, or cannot take a Liveness Check, for example because of a disability, because you have no device with a camera, or because a document is not issued where you live, tell Support before the Response Period ends. Where one exists that meets Applicable Law, we offer another way, such as a review of your documents by our staff, a video call, a different document or a copy attested under clause 5.8. Asking for another way does not count against you, and the Response Period pauses while we arrange it.

Each session for Verification Levels 2 to 4 has one of the following statuses:

• Pending: started, or received and under review.
• Action required: something more is needed, such as a clearer image or a missing page.
• Verified: the Verification Level is complete.
• Rejected: the check failed.
• Expired: the session was not finished in time, and a new one can be started.
• Canceled: the session was stopped before it finished.

The Verification tab of the Settings page shows where your latest Verification Level 2 check stands, whether under review, complete or in need of a fix, and what you can do next, and so does the page you return to from the Identity Partner. We may also tell you the outcome of a session through Support or by email to the address on your Account, and you may ask Support for it at any time. Each session has its own reference, which Support uses to find it when you ask about it or make a complaint.

When a check is rejected, we tell you why, unless Applicable Law prevents it, and whether and how you can try again. We may keep back the detail of why a check failed where giving it would help someone get past our fraud or security checks, but even then we tell you which Verification Level failed and what you can do next.

The usual reasons for a rejection are a document that is expired, unclear, cut off or not accepted; details that do not match your Personal Details; a Liveness Check that does not match the photo; and signs that a document or image has been altered.

To protect Accounts, we limit how many Verification attempts can be started in a short time. Repeated failed attempts may lead to an Enhanced Verification or a Restriction.

While a Request is open we may place a Restriction on the Account in proportion to the reason for the Request. A Restriction may pause withdrawals, deposits, play, Tips or payments of every kind, cap deposits over a period, or, in a serious case, freeze or suspend the Account, as clause 7.4 of the Terms allows. We tell you what the Restriction covers. Nobody can log in to a suspended Account, so we send any Request about it by email. A Restriction serves to secure the Account and to meet Applicable Law, and it is not a penalty.

A Restriction does not by itself void bets settled before it began. No interest accrues on a Balance while a Restriction applies.

You must give us what a Request asks for within the period the Request sets (the Response Period). A Request counts as received on the day we send it to you on the Site, including through live support, or to the email address on your Account. The Response Period pauses only while we review a submission that includes everything the Request asked for, or while we arrange another way under clause 11.9, and it runs again from the day we tell you the result. Sending part of what was asked, or a document refused under clause 7.3, 8.2 or 11.5, does not pause or restart it. You may ask Support for more time before it ends, and we may agree where you give a good reason.

If you do not provide what a Request asks for within the Response Period, or you refuse or fail a Verification, we may keep the Restriction, refuse further deposits, suspend or close the Account, and make any report Applicable Law requires. Declining a Verification is not, by itself, treated as a sign of wrongdoing. While the Account is open, you can return to a Verification you stopped and complete it, and we then review the Restriction.

Where we close an Account after a refused or failed Verification and find no breach of the Terms or of Applicable Law, the remaining Balance, including any amount in the Vault, is paid out under clause 16.4 of the Terms, by a method that clause 9.31 of the Terms allows, once you have passed the checks we ask for under this Policy. We first deduct any amount you owe us, such as a Recorded Debt, as clause 12.4 of the Payments policy allows. Until then, and wherever Applicable Law does not allow a payout, we hold the Balance and it stays recorded to you, as clause 21.9 of the Anti-money laundering policy provides. The Balance of a suspended Account is released only by our staff. Bets settled before a Verification is refused or failed stand, and we do not return amounts lost on them, unless clause 14.3 applies or the Terms void those bets.

Where a Verification shows a breach of the Terms, such as a second Account, a false identity, play from a restricted country or through a Masking Tool, or play by a person under the age in clause 14.1, the Terms decide what happens to the Account, its bets and its Balance, together with the Restricted countries and VPN policy for a breach that concerns location.

Giving false information, sending a forged or altered document or another person's document, or using another person's face or a generated image in a Liveness Check is a serious breach of the Terms. We may close the Account at once and report the matter to the competent authorities.

Where Applicable Law requires, we report suspicious activity to the Financial Intelligence Unit of the ICD and freeze funds as the law directs. We do not tell you about a report.

Unless the Restriction says otherwise, you can keep playing with your Balance while a Request is open. A withdrawal you have already asked for may wait, with its amount held, and the Cashier shows its state. Where the Cashier lets you cancel a waiting withdrawal, its amount returns to your Balance. If the Response Period ends without an answer, clause 13.4 applies, and section 17 of the Payments policy sets out what happens to a waiting withdrawal when an Account is suspended.

We lift a Restriction placed for a Request once the Verification is complete and nothing else calls for it, and we tell you when we do.

We are not liable for loss caused by a Restriction, a held withdrawal or the time a Verification takes, where we act in good faith under this Policy, including a change in the price or availability of an item while a withdrawal waits. This does not limit our liability where Applicable Law does not allow it to be limited.

You must be 18 or older to hold an Account, or older where the law that applies to you sets a higher age.

You confirm your age when you register. We check it at Verification Level 1, at Verification Level 2, and whenever we have reason to doubt it.

An Account that we find belongs to a person under the age in clause 14.1 is closed, and clause 4.2 of the Terms decides what happens to its bets, its winnings and the money deposited on it.

You must not let a person under the age in clause 14.1 use your Account, or a device on which you are logged in. Tell Support if you know of such a person using the Service.

We may check your name, date of birth and country against Sanctions Lists and PEP lists when you give your Personal Details, at a later Verification Level, when your details change and when a Sanctions List we use is updated.

A person named on a Sanctions List may not hold an Account. When a match is confirmed, we suspend the Account, freeze its Balance as Applicable Law requires, and make the reports it requires.

Being a PEP does not by itself bar you from the Service. The Account of a PEP needs Enhanced Verification, including Source of Wealth, and the written approval of our Compliance Officer, and it is monitored more closely. Until the Compliance Officer has approved the Account, we accept no deposit from it and send no withdrawal from it.

If you, a member of your family or a close associate of yours is a PEP, you must tell Support before your first deposit, as clause 4.10 of the Terms requires, and you must tell us of any later change promptly, as clause 5.11 explains.

While we review a possible match, we may suspend the Account, as clause 11.4 of the Anti-money laundering policy provides. Where the possible match may concern another person with a similar name, we may ask you for information that rules it out, and we restore the Account once it is ruled out.

The Service is not offered to residents of, or persons located in, the places set out in the Restricted countries and VPN policy, except as far as the Status of a country allows under clause 3.4 of that policy. Where a Verification shows that you live in one of them, that policy sets out what you may still do, and the steps it describes may include closing your Account.

The Network Check described in sections 6 and 7 of the Restricted countries and VPN policy may be switched on or off. While it is on, it runs at sign-up, at login, during visits to the Site while you are logged in and at each deposit and withdrawal. When it finds Tor, a VPN, a proxy or a hosting network, it refuses the connection or the action, or records it for review, as clauses 6.5 and 6.8 of that policy explain. A time zone on your device that differs from your network's is recorded for review and does not block anything by itself.

The Service may not be used from a country where it is not offered, even by a person who lives elsewhere.

When your network, your Personal Details and your documents point to different countries, we may ask you to explain the difference and to provide Supporting Documents, such as a residence permit or travel records.

You must tell us without delay of any change to your name, your address, your country of residence or any other Personal Details.

You ask Support to correct your Personal Details once you have given them. Until Verification Level 2 starts, we may correct them at your request. After that, our Compliance Officer decides the request, and we ask for Supporting Documents:

• for a new name, a marriage certificate, a court order or another official record of the change, and an Identity Document in the new name;
• for a new address, a Proof of Address for it; and
• for a correction to your date of birth, an Identity Document that shows the correct date.

A change may require one or more Verification Levels to be repeated. A move to a country where the Service is not offered is dealt with under clauses 5.7 and 5.8 of the Restricted countries and VPN policy.

Your username and email address are Account settings, not Personal Details. Your username can be changed once every 30 days. A new email address stays unverified until you confirm it, and we may tell your previous address about the change.

Where an Account holder has died, a person acting for the estate may ask Support for the Balance. We ask for the death certificate, evidence of that person's authority to act for the estate, and that person's Identity Document.

The Privacy policy governs how we process personal data. This section adds the points specific to Verification.

Your first and last names and your country are encrypted with AES-256-GCM before they are stored, bound to your Account, and the encryption key is held apart from the database. Your date of birth and address, your answers to questions about your Source of Funds and any document you send through the Site are sealed with a public key before they are stored, so that they can be read only with a private key that the Site itself does not hold. The Verification Level and status of each Verification, the reference of each session and, where a check needs a fix, the reason recorded for it are stored with the Account. Personal Details and documents travel only over encrypted connections.

The Identity Partner processes your documents and your Liveness Check on our behalf, under a written agreement that requires confidentiality and security. It reports to us the outcome of each session, whether you are confirmed as an adult, the country it found and the details listed in clause 7.9. We act on a result only after checking the signature that shows it came from the Identity Partner.

The Identity Partner may process data outside Costa Rica. Transfers abroad follow the Privacy policy.

Within Peeks, access to personal data in our staff tools is limited by permission to staff whose role requires it. Changes that staff make to an Account are logged with the staff member and the reason.

We use Verification data only for the purposes in clause 3.5, to handle your requests and to meet Applicable Law. We do not sell it, and we do not use it for advertising.

We keep Verification records, including results, the reasons for decisions and any copies of documents we hold, for as long as Applicable Law requires, as clause 25.2 of the Anti-money laundering policy provides. Where a complaint, dispute, investigation or legal claim concerns the records, we keep them until it ends. We then delete or anonymize them. The Privacy policy sets out how we keep and delete personal data.

Law 8968 lets you see your personal data in our records and ask us to correct it, delete it or stop processing it. Make any such request through Support or at support@peeks.gg. Deletion waits while clause 18.7 requires us to keep the records. You may also complain to PRODHAB.

We disclose Verification data to competent authorities, including the Financial Intelligence Unit of the ICD, the courts and the police, where Applicable Law requires or allows it. We may also share Verification data with AssetPay under clause 10.9.

Each Access Code Account is given $100 to play with before the Launch Date, and some are given more. None of it can be withdrawn, and it is cleared on the Launch Date. We may refuse to start a Verification on an Access Code Account before the Launch Date.

Only the login of an Access Code Account carries over to the Launch Date, as clause 6.12 of the Terms provides. Its Verification starts at Verification Level 1 after the Launch Date.

Send questions about a Verification to Support, through live support messages on the Support page or by email to support@peeks.gg.

You may complain about a Verification decision under the Complaints policy. We confirm receipt, name the person handling the complaint and answer in writing within the times that policy sets.

You may ask for any outcome reached by automated means to be reviewed by a member of our staff. The reviewer may confirm the outcome, change it, or ask for more information.

A dispute that is not resolved under the Complaints policy is governed by section 21 of the Terms. A complaint about the processing of personal data may also be taken to PRODHAB under clause 18.8.

We may amend this Policy when Applicable Law, our providers or the Service change. Each version carries the date it took effect, shown at the head of this page.

A changed Policy applies from that date. A Verification already under way continues under the version in force when it started, unless Applicable Law requires otherwise or the new version treats you more favorably.

Where a change reduces your rights or adds to what you must do in a material way, we tell you by email and by a notice on the Site before it takes effect, giving the notice that clause 1.7 of the Terms requires. A change may take effect at once where Applicable Law, an authority, or an urgent need to deal with fraud, money laundering or a security threat requires it. We keep every earlier version of this Policy and send any of them on request.

We review this Policy at least once a year, and whenever Applicable Law or the Identity Partner changes.

Support is available through live support messages on the Support page and by email at support@peeks.gg.

Matters for our Compliance Officer may be sent through Support or to support@peeks.gg, marked for the attention of the Compliance Officer.