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KYC and AML Policy

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A wallet can buy a Policy before KYC is approved, but the Policy is active for claims only once KYC is approved. No claim can be submitted or paid before then. Authorised ENGAGEX staff review each submission. This policy sets out what you must provide, how it is checked, and how we handle sanctions and financial crime risks.

1. Purpose

1.1

This policy explains how Engagex Global LLC (ENGAGEX, we or us) verifies the identity of people who use the Service, and how we seek to prevent fraud, money laundering, terrorist financing and sanctions breaches.

1.2

We keep these controls because we make a contractual promise to pay verified losses, and we need to know who we are contracting with and who we are paying.

1.3

This policy describes our own controls. It is not a statement that ENGAGEX is licensed, registered or regulated as a financial institution. ENGAGEX is not holding itself out as a licensed insurance carrier.

1.4

This policy forms part of the Terms of Service.

2. When KYC is required

2.1

A wallet can buy a Policy before its KYC is approved, including while KYC is waiting for review. KYC approval relates to the specific wallet you connect. The Policy becomes active for claims only once your KYC is approved. The Policy Period still ends 365 days after purchase, so the sooner KYC is approved, the longer the Policy is active.

2.2

No claim can be submitted or paid before KYC approval, and an incident must occur after activation to be covered. An incident that happened before your KYC was approved is not covered. A wallet can also buy a Policy directly from the smart contract without using the website. That Policy is recorded on-chain and follows the same rules. A Policy stays recorded on-chain while KYC is outstanding, and this does not by itself cancel it.

2.3

A wallet used to receive a Benefit must also pass KYC checks, as explained in the section on payout wallets.

2.4

You must be 18 or older. We use your date of birth and your document to check this.

3. Information we collect

3.1

To complete KYC, you must provide all of the following:

  • your country and state;
  • your document type: driving license, passport or government ID;
  • a live selfie through your device camera;
  • photos of both sides of your document;
  • your official full name;
  • your mobile number;
  • your date of birth;
  • your precise device location, which is mandatory; and
  • your IP address, which is captured when you submit.
3.2

Your full name and date of birth must match your document. Details of how this data is handled are in the Privacy Policy.

4. Document standards

4.1

Your document must be:

  • a genuine, valid and unexpired driving license, passport or government ID;
  • issued to you, in your official name;
  • photographed on both sides, in full, with all corners visible; and
  • clear and readable, with no glare, blur, cropping, editing or covering of any detail.
4.2

Where a document has only one printed side with information, photograph the inside page or the back as the form asks. We may ask for a different document, or a better photo, if we cannot read or rely on the one you sent.

5. Live selfie

5.1

You must take the selfie live through your device camera at the time of KYC. You must not upload an earlier photo, or use a photo of a screen, a printed picture, a filter, a mask or a generated image.

5.2

The selfie is reviewed by authorised ENGAGEX staff, who compare it visually with your document. We do not use automated biometric matching or automated liveness detection. Your face should be fully visible and well lit.

6. Device location and IP address

6.1

Precise device location is mandatory. You must allow your device to share it during KYC. If you do not, you cannot complete KYC.

6.2

Staff may compare your device location and IP address with the country and state you gave and with your document, to help identify false information and apply restrictions on where the Service is available.

6.3

Account activity is logged at each KYC step, and authorised staff can view it for each wallet, as explained in the Privacy Policy.

6.4

Using a VPN, proxy, location spoofing tool or similar method to hide your real location is a breach of the Terms of Service, and may lead to rejection of your KYC.

7. Review and outcomes

7.1

Authorised ENGAGEX staff review each KYC submission. Your submission may have one of the following outcomes:

  • Approved: the Policy for that wallet becomes active for claims.
  • More information needed: we ask you to correct or resubmit part of your KYC.
  • Rejected: the Policy for that wallet does not become active, and no claim can be submitted or paid. A Policy already recorded on-chain stays recorded and its Policy Period is not extended.
7.2

We may reject a submission where a document cannot be verified, details do not match, the selfie does not appear to show the document holder, you are under 18, the location is restricted, or we identify any other risk. We may not be able to give the reason for a rejection, particularly where the law prevents it.

7.3

KYC approval is a decision by ENGAGEX for its own purposes. It is not a certificate of identity. A claim is paid only after it is verified, as described in the Claims Policy.

8. Keeping KYC up to date

8.1

You must tell us if your information changes, including your name, country, state or mobile number, or if your document is withdrawn.

8.2

We may ask you to repeat all or part of KYC at any time, including when your document expires, when you file a claim, when a payout is due, or where we identify a risk.

8.3

ENGAGEX may withdraw a KYC approval at any time and require KYC to be redone. A withdrawal does not by itself cancel a Policy recorded on-chain, but no claim can be submitted or paid until KYC is approved again.

9. Sanctions and restricted jurisdictions

9.1

We do not provide the Service to any person, wallet or funds that are the target of sanctions under any sanctions law that applies to us or to you, or to any person owned or controlled by such a person.

9.2

We may check names, wallet addresses and transaction history against sanctions information. If we find a possible match, we may ask for more information, refuse the Service, freeze any action on your account and take any step the law requires.

9.3

We may treat a jurisdiction as restricted where sanctions law requires it, or where offering the Service there would require a licence that we do not hold. Where this applies, it is shown in the KYC form, at checkout or in the Dashboard, and KYC or a Policy will not be available.

10. Anti-money laundering controls

10.1

You must not use the Service to hide the origin of funds or to process the proceeds of crime.

10.2

To manage these risks, we may:

  • review the on-chain history of a wallet that applies, pays a Premium, makes a claim or receives funds;
  • ask about the source of funds in a wallet, and ask for supporting documents;
  • identify links between wallets, applications and claims;
  • apply closer review to larger Assured Amounts, repeated claims or unusual patterns; and
  • decline or return a payment that we are not comfortable accepting, where the law allows it.

11. Payout wallets

11.1

Any Benefit is paid in USDT, off-chain by ENGAGEX, to a wallet that passes KYC checks. Normally that is the Insured Wallet. If the Insured Wallet is compromised, you must nominate another wallet you control.

11.2

A nominated wallet must belong to you, must not be a wallet of a third party, and must pass these checks before we can pay. We may ask you to sign a message with it, to show your control.

12. Suspicious activity

12.1

If we suspect fraud, money laundering, terrorist financing or a sanctions breach, we may suspend your access, delay or refuse a transaction, decline a claim, end a Policy under its terms, and keep related records.

12.2

We may report suspected crime to law enforcement or other competent authorities where the law requires or allows it. We may be legally unable to tell you that we have done so.

13. Storage, access and retention

13.1

KYC photos are stored in private Cloudflare R2 object storage. Records are kept in a PostgreSQL database. Only authorised ENGAGEX staff review them.

13.2

We keep KYC data for 5 years after our relationship with you ends, unless the law requires otherwise. See the Privacy Policy for details and for your rights.

14. Your responsibilities and consequences of a breach

14.1

You must only submit your own information. Using a false or altered document, or another person’s identity, is a breach of the Terms of Service and may be a crime.

14.2

If you do so, we may reject your KYC, bar you from the Service, decline any claim, end your Policy as described in the Assurance Policy Wording and report the matter to competent authorities.

15. Contact

15.1

Questions about KYC can be sent to support@engagex.life or by post to Engagex Global LLC, 1309 Coffeen Avenue, Wyoming 82801, USA. Please do not send identity documents by email unless we ask you to.