KYC, AML, SANCTIONS AND ELIGIBILITY POLICY

1. Purpose and Status

This Policy describes the public identity, eligibility, fraud, sanctions and integrity controls of Data Infrastructure Development Group LLC. It does not disclose confidential internal thresholds, vendor rules, investigative techniques or escalation triggers where disclosure could enable circumvention or create security risk.

This Policy forms part of the Terms of Service and Program Rules. The Company may apply stricter controls than a payment provider or statutory minimum where reasonably necessary to manage fraud, sanctions, sports-integrity, legal or reputational risk.

2. Verification Timing

• Basic country, payment and fraud screening at registration and purchase.
• Full identity, age and residential-address verification before access to the Funded Stage or before any Performance Reward, whichever occurs first.
• Enhanced review for high values, PEP exposure, adverse media, unusual activity, third-party payment indicators, country conflicts or inconsistent data.
• Re-verification after a material Account change, document expiry, security incident, provider request, law change or other material risk event.

3. Information the Company May Request

The Company may request government identification, selfie/liveness, proof of address, tax identification, payment or payout ownership, occupation, employer, source of funds, source of wealth, beneficial ownership information, sports-industry role, explanation of activity, or other documents reasonably relevant to eligibility, payment or fraud review.

4. Sanctions and Prohibited Persons

The Company may screen Participants, beneficial owners, payment counterparties and payout destinations against sanctions applicable to a Wyoming entity and its relevant European/UK operations, including U.S. OFAC, United Nations, European Union and United Kingdom sanctions where applicable. The Company may reject, block, freeze, suspend, report or terminate activity where required by law or a material provider obligation.

5. Politically Exposed Persons and Adverse Media

A politically exposed person, family member or close associate may be declined or subjected to enhanced due diligence, senior approval, source-of-wealth/source-of-funds review and enhanced monitoring. The Company may also consider credible adverse media relevant to fraud, corruption, sanctions, organized crime or other material financial-crime risk.

6. Approved Jurisdictions — Default-Deny Model

The Services are not globally available. The Company applies a default-deny model. A person may register, purchase, participate or request a Reward only if the person is both ordinarily resident and physically located in a jurisdiction that appears in the Approved Jurisdiction Schedule below and that the Company has technically activated for the relevant Service.

A country appearing in a language selector, payment dropdown, sports-data feed or other interface does not by itself mean that the Services are legally or commercially available there.

7. Approved Jurisdiction Schedule

Current approved launch scope:

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Iceland, Liechtenstein, Norway, Switzerland and the United Kingdom (England, Wales, Scotland and Northern Ireland).

Inclusion in the list means only that the jurisdiction is within the intended launch scope. The Company may withhold or pause activation pending local legal, licensing, payment, advertising, consumer-protection or risk review.

8. Restricted Jurisdictions

Every jurisdiction not expressly listed in the Approved Jurisdiction Schedule is restricted unless the Company later approves it in writing and technically activates it. This specifically includes, without limitation:

• United States of America, District of Columbia, Puerto Rico, Guam, U.S. Virgin Islands, American Samoa, Northern Mariana Islands and all other U.S. territories or possessions.
• United Arab Emirates, Qatar, Saudi Arabia, Bahrain, Kuwait and Oman.
• Canada, Australia, New Zealand, Singapore and Hong Kong.
• Russia, Belarus, Crimea, Sevastopol and comprehensively sanctioned or occupied regions to the extent prohibited by applicable sanctions.
• Every country or territory subject to a FATF call for action, comprehensive sanctions, an applicable legal prohibition, or a material restriction imposed by the Company’s bank, payment processor, identity provider, insurer or other essential provider.
• Andorra, Monaco, San Marino, Vatican City, Albania, Bosnia and Herzegovina, Kosovo, Moldova, Montenegro, North Macedonia, Serbia, Ukraine and other European countries not expressly listed above, unless separately approved and activated.

9. Residence and Physical-Location Requirement

An eligible Participant must be ordinarily resident in an activated Approved Jurisdiction and physically located in an activated Approved Jurisdiction when registering, purchasing, submitting Picks, accessing an active Challenge or Funded Stage, and requesting or receiving a Reward. Temporary travel to a Restricted Jurisdiction may result in access being paused until the Participant returns and completes any requested re-verification.

10. Connection Tests and Geolocation

The Company may determine jurisdictional connection using permanent address, ordinary residence, identification, tax residence where relevant, payment instrument, payout account, telephone number, IP address, device information, GPS or other geolocation signals, and other reliable indicators. Conflicting indicators may trigger suspension or enhanced review.

11. Circumvention and Misrepresentation

VPNs, proxies, TOR, GPS spoofing, remote desktop, false addresses, nominees, third-party devices, third-party payment methods, synthetic identities and other methods intended to conceal or misrepresent identity or location are prohibited. Deliberate circumvention may result in order cancellation, Account suspension or termination, Challenge failure and Reward ineligibility, subject to mandatory law and an evidence-based review.

12. Suspicious Activity, Fraud and No Tipping-Off

Risk indicators may include identity mismatch, synthetic identity, linked Accounts, rapid device or country changes, suspicious payments, false chargebacks, coordinated Picks, insider relationships, third-party payout requests, sanctions exposure and attempts to avoid verification. The Company may restrict activity and make reports or disclosures where required or permitted by law.

Where law, security requirements or anti-tipping-off rules restrict disclosure of an investigation, report, risk score or vendor method, the Company may be unable to provide detailed reasons for a delay, restriction or rejection.

13. Payment and Reward Ownership Checks

Payment methods and payout accounts must ordinarily be held in the Participant’s legal name. The Company may reject anonymous, third-party, unsupported, sanctioned or outside-region destinations and may require bank-account or payment-wallet ownership evidence before a Reward is paid.

14. Record Retention and Data Protection

Verification, screening, eligibility, payment and decision records are retained and protected under the Privacy and Cookie Policy and applicable law. Access is limited to authorized personnel and service providers with a legitimate need to know.

15. Changes in Jurisdiction Status

Country status may change immediately because of sanctions, legislation, regulatory action, legal advice, provider restrictions or material risk. The Company may stop new registrations, purchases or activity in an affected jurisdiction. For existing paid Programs, the Company will apply a lawful and commercially reasonable solution, which may include completion under restrictions, suspension, replacement access, credit or refund where legally required.