The website www.miki.com Casino", "Website", “Company”, "We", "Us", "Our") is owned and operated by Novi B.V., a company registered in accordance with Curaçao Law, registration No. 155510, address: Dr. M. J. Hugenholtzweg 25, Willemstad, Curacao. www.miki.com is licensed and regulated by the Curacao Gaming Authority and operates under the License No. 365/JAZ issued to Gaming Services Provider, Authorized and Regulated by the Government of Curaçao.
2. INFORMATION COLLECTED
We consider information that may be used to identify an individual, including, but not limited to, first and last name, date of birth, home or other physical address, email address, phone number or other relevant information to be Personal Information (‘Personal Information’). You may be asked to provide Personal Information when you use our website, register for an account or use our services. The Personal Information that we collect may include information such as: contact information (including telephone number), shipping information, billing information, transaction history, website usage preferences, and feedback regarding the Services. This information is held by us on servers based in Germany and elsewhere from time to time. When you interact with the services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. This information is essential for the provision and quality of our services. We do not collect Personal Information about you without your knowledge.
3. MEANS OF COLLECTING AND PROCESSING DATA
4. INFORMATION USE
We use the Personal Information we collect from you to deliver our Services, to provide customer support, to undertake necessary security and identify verification checks, to process any of your online transactions, to assist your participation in third-party promotions, meet certain business requirements and for any other purpose related to the operation of the Services. As such, we may share your Personal Information with our carefully selected partners (including any other parties that have data sharing arrangements with the latter).
Your Personal Information may also be used by us to provide you with: (1) promotional offers and information regarding our products and services; and (2) promotional offers and information regarding the products and services of our partners, in order to enlarge the range of provided products and improve our customer service. From time-to-time, we may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age). By accepting any contest prize or winnings from us, you consent to use of your name for advertising and promotional purposes without additional compensation, except where prohibited by law. Unless you have elected not to receive promotional information, we may also use your Personal Information (including your email address and phone number) to provide you with information regarding our products, services and promotions, including other gaming products (including online poker, casino, betting, backgammon) and products and services from third parties carefully selected by us.
5. CERTAIN EXCLUDED DISCLOSURES
We may disclose your Personal Information if required to do so by law, or if we believe in good faith that such action is necessary to: (1) comply with any legal process served on us, any of our sites or the services or in circumstances where we are under a substantially similar legal obligation; (2) protect and defend our rights or property; or (3) act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us, the company , or any other user of the services in any way including but not limited to game manipulation or payment fraud, or if we suspect you of fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), we reserve the right to share this information (together with your identity) with other online gaming sites, banks, credit card companies, appropriate agencies and relevant authorities. (4) For the purpose of research on the prevention of addiction, data can be made anonymous and passed on to the respective institutions.
You may ‘opt out’ of receiving any promotional communications either by choosing to opt out via your account settings available on our sites or the services or in an email you receive from us, or at any time by sending an email, or by writing to us at Customer Service.
Information placed on your device
When accessing our services, we may store information on your device. This information is referred to as cookies, which are small text files that are stored on your device when you visit online pages that record your preferences. We also use Local Shared Objects or ‘flash cookies’. ‘Flash cookies’ are similar to browser cookies. They allow us to remember things about your visits across our sites. Neither cookies nor flash cookies can be used to access or use other information on your computer. We only use these methods to track your use of our services. Cookies help us monitor traffic to the site, improve our services and make it easier and/or more relevant for your use. We use flash cookies and third party cookies to help us show you more relevant and desirable advertisements.
Strictly necessary cookies
Strictly necessary cookies are essential to allow a user move around a website and use its features, such as accessing secure areas of the website or making financial transactions. Without these cookies, we would not be able to make our websites work efficiently.
During the registration process
These cookies will hold information collected during your registration and will allow us to recognize you as a customer and provide you with the services you require. We may also use this data to better understand your interests while online and to enhance your visits to our platforms.
On our website
A ‘session-based’ cookie: This type of cookie is only allocated to your computer for the duration of your visit to our website. A session-based cookie helps you move around our website faster and, if you’re a registered customer, it allows us to give you information that is more relevant to you. This cookie automatically expires when you close your browser.
A ‘persistent’ cookie: This type of cookie will remain on your computer for a period of time set for each cookie. Flash cookies are also persistent.
‘Analytical’ cookies: This type of cookie allows us to recognize and count the number of visitors to our site and see how visitors use our services. These helps us improve the way our sites work, for example, by ensuring you can find what you are looking for easily.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether.
You can modify your Flash Player settings to prevent the use of flash cookies. The Settings Manager of your Flash Player allows you manage your preferences. To disallow flash cookies from all third party content go to the ‘Global Storage Settings’ panel of the Settings Manager and de-select the check box labelled ‘Allow third party flash content to store information on your computer’ and close the Settings Manager. Alternatively you can also adjust your settings for specific websites you visit through the ‘Website Storage Settings’ panel which is also found in the Settings Manager.
If you are using an old version of Flash Player or older web browser, the Settings Manager may not be available to you. We recommend that you ensure that you refresh your Flash Player and browser to the latest available versions.
If you choose to decline cookies, you may not be able to experience all of the interactive features on our sites.
8. CONSENT TO USE OF ELECTRONIC SERVICE PROVIDERS
9. CONSENT TO SECURITY REVIEW
We reserve the right to conduct a security review at any time to validate the registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms and Conditions and of applicable law. By using our services and thereby agreeing to our Terms and Conditions you authorize us to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide during your use of our services, including, where necessary, the transfer of information outside of your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third-party databases. In addition, to facilitate these security reviews, you agree to provide such information or documentation as we may request.
We understand the importance of security and the techniques needed to secure information. We store all of the Personal Information we receive directly from you in an encrypted and password-protected database residing within our secure network behind active state-of-the-art firewall software. (Our Services support SSL Version 3 with 128-bit encryption). We also take measures to ensure our subsidiaries, agents, affiliates and suppliers employ adequate security measures.
11. PROTECTION OF MINORS
Our Services are not intended for or directed at persons under the age of eighteen (18) (or the lawful age in their respective jurisdiction). Any person who provides their information to us through any part of the services signifies to us that they are eighteen (18) years of age (or the lawful age in their respective jurisdiction) or older. It is our policy to uncover attempts by minors to access our services which may involve having to initiate a security review. If we become aware that a minor has attempted to or has submitted personal information via our services, we will not accept their information and will take steps to purge the information from our records.
12. INTERNATIONAL TRANSFERS
Personal Information collected on the services may be stored and processed in any country in which we or our affiliates, suppliers or agents maintain facilities. By using our services, you expressly consent to any transfer of information outside of your country (including to countries that may not be assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.
13. THIRD-PARTY PRACTICES
14. LEGAL DISCLAIMER
The Services operate ‘AS-IS’ and ‘AS-AVAILABLE’ without liability of any kind. We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technology and business, we cannot guarantee nor do we claim that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said Personal Information.
In addition, as per Article 77 of the GDPR, you have the right lodge a complaint related to your data processing to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement.
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Last updated: 19.05.2022
(AMLI Anti-Money-Laundering policy of www.miki.com.
Introduction: www.miki.com is operated by Novi B.V. having its office at Dr. M. J. Hugenholtzweg 25, Willemstad, Curacao. Company Registration number 155510
Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on www.miki.com for that a three step account verification is done in order to insure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.
www.miki.com also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.
www.miki.com is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
The AML program of www.miki.com is designed to be compliant with :
EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
EU : “Regulation 2015/847 on information accompanying transfers of funds”
EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash
• Money Laundering is understood as:
• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.
Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
In accordance with the AML legislation, www.miki.com has appointed the “highest level” for the prevention of ML: The full management of Novi B.V. are in charge.
Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.
The AMLCO is placed under the direct responsibility of the general Management:
Each major change of www.miki.com AML policy is subject to be approval by the general management of Novi B.V. and the Anti money laundering compliance officer.
Step one verification must be done by every user and customer to withdraw. Regarding of the choice of payment, the amount of payment, the amount of withdraw, the choice of withdraw and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. Following information’s must be filled in: first name, second name, date of birth, country of usual residence, gender and full address.
Step two verification must be done by every user which deposit over 2000$ (two thousand Dollar) or withdraws over 2000$ (two thousand Dollar) or sends another user over 1000$ (one thousand Dollar) Until step two verification is done the withdraw, tip or deposit will be hold. Step to verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different. There will also be an electronic check if the filled in Data from the step one verification is correct. The electronic check will check via two different databanks to insure the given information’s matches with the filled document and the name from the ID: If the electronic test fails or is not possible the user/customer is required to send in a conformation of his current resident. A certificate of registration by the government or a similar document is required.
Step three verification must be done by every user which deposit over 5000$ (five thousand Dollar) or withdraws over 5000$ (five thousand Dollar) or sends another user over 3000$ (three thousand Dollar) Until step three verification is done the withdraw, tip or deposit will be hold. For step 3 a user/customer will be asked for a source of wealth.
The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.
This identification relies on the following fundamental principles:
A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information, besides date of birth, nationality, gender, first name, second name and the picture. To secure their privacy.
Please note that all four corners of the ID have to be visible in the same image and all details has to be clearly readable besides the named above. We might ask for all details if necessary.
An employee may do additional checks if necessary, based on the situation.
Proof of address will be done via to different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manually proof.
A recent utility bill sent to your registered address, issued within the last 3 months or an official document made by the government that proofs your state of residence.
To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document is visible, and all text is readable.
For example: An electricity bill, water bill, bank statement or any governmental post addressed to you.
An employee may do additional checks if necessary, based on the situation.
If a player deposits over a five thousand euro there is a process of understandings the source of wealth (SOW)
Examples of SOW are:
· Ownership of business
It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible an employee may ask for an additional document or prove.
The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and an information on the website itself.
www.miki.com also asks for a bank wire/credit card to further insure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
The basic document will be accessible via the setting page on www.miki.com Every user has to fill out the following information’s:
· First name
· Second name
· Date of Birth
The document will be saved and created by an AI, an employee may do additional checks if necessary based on the situation.
In order to deal with the different risks and different states of wealth in different regions on the earth www.miki.com will categorize every nation in three different regions of risk.
For every nation from the region one the three-step verification is done as described earlier.
For every nation from the region two the three-step verification will be done at lower deposit, withdraw and tip amounts. Step one will be done as usually. Step two will be done after depositing 1000$ (one thousand Dollars), withdrawing 1000$ (one thousand Dollars) or tipping another user/customer 500$ (five hundred Dollars.) Step three will be done after depositing 2500$ (two thousand five hundred Dollars), withdrawing 2500$ (two thousand five hundred Dollars) or tipping another user/customer 1000$ (one thousand Dollars). Also, users from a low risk region that change crypto currency in any other currency will be treated like user/customers from a medium risk region.
Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.
In addition, an AI which is overseen by the AML compliance officer will look for any unusual behaviour and report it right away to a employee of www.miki.com
According to a risk based few and general experience the human employees will recheck all checks which are done bevor by the AI or other employees and may redo or do additional checks according to the situation.
In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behaviour like: Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account to for Deposit and Withdraw, nationality changes, currency changes, behaviour and activity changes as well as checks, if an account is used by it´s original owner.
Also a User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.
As part of its risk-based approach, www.miki.com has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to www.miki.com and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.
The identification of AML risk categories is based on www.miki.com understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.
The EWRA is yearly reassessed.
ensures that an “ongoing transaction monitoring” is conducted to detect
transactions which are unusual or suspicious compared to the customer profile.
This transaction monitoring is conducted on two levels:
1) The first Line of Control:
www.miki.com works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto www.miki.com from taking place without proper execution of KYC procedures onto the potential customer.
2) The second Line of Control:
www.miki.com makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:
• Requests for the execution of financial transactions on the account;
• Requests in relation to means of payment or services on the account;
Also, the three-step verification with adjusted risk management should provide all necessary information’s about all costumers of www.miki.com at all time.
Also, all transaction must be overseen by employees over watched by the AML compliance officer who is over watched by the general management.
The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.
Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.
These checks will be done by an automated System, while an Employee crosschecks them for additional security.
The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).
Any www.miki.com staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.
3) The third Line of Control:
As a last line of defence against AML www.miki.com will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.
If fraud or Money Laundering is found the authorities will be informed.
In its internal procedures, www.miki.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.
Depending on the result of this examination and on the basis of the information gathered, the AML team:
• will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
• will decide whether or not it is necessary to terminate the business relations with the customer.
The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of www.miki.com
Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.
Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.
These data will be safely, encrypted stored offline and online.
www.miki.com human employees will make manual controls on a risk based approve for which they get special training.
The training and awareness program is reflected by its usage:
- A mandatory AML training program in accordance with the latest regulatory evolutions, for all in touch with finances
- Academic AML learning sessions for all new employees
The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML-specialist working in Novi B.V. AML team.
Internal audit regularly establishes missions and reports about AML activities.
All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
www.miki.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)
If you have any questions about our AML and KYC Policy, please contact us:
· By email: [email protected]
If you have any complains about our AML and KYC Policy or about the checks done on your Account and your Person, please contact us:
· By email: [email protected]