1. PRIVACY
www.miki.com is committed to
protecting your personal information. This Privacy Policy lets you know what
information we collect when you use our services, why we collect this
information and how we use the collected information.
Please note that this Privacy Policy
will be agreed between you and YOUR
WEBSITE. (‘We’, ‘Us’ or ‘Our’, as appropriate). This Privacy Policy is an
integrated part of YOUR WEBSITE’s
Terms and Conditions.
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.
We may periodically make changes to
this Privacy Policy and will notify you of these changes by posting the
modified terms on our platforms. We recommend that you revisit this Privacy
Policy regularly.
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
We may automatically collect certain
data as discussed above and receive Personal Information about you where you
provide such information through the services or other communications and
interactions on the YOUR WEBSITE site. We may also receive Personal Information
from online vendors and service providers, and from customer lists lawfully
acquired from third-party vendors. In addition, we may engage the services of
third-party service providers to provide technical support process your online
transactions and maintain your account. We will have access to any information
you provide to such vendors, service providers and third-party e-commerce
services, and we will use the Personal Information as set out in this Privacy
Policy below. This information will only be disclosed to third parties outside
the company in accordance with this Privacy Policy. We take steps to ensure
that our arrangements with third-party service providers and online vendors
protect your privacy.
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.
6. ACCESS
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.
In addition, You may contact us if
you: 1) want to confirm the accuracy of the Personal Information we have
collected about you; 2) would like to update your Personal Information; and/or
3) have any complaint regarding our use of your Personal Information. If
requested, we will (1) update any information you have provided to us, in case
you prove the necessity for such changes or (2) mark any information to
prohibit future use for marketing purposes. For the avoidance of doubt, nothing
in this Privacy Policy shall prevent us from retaining your Personal
Information where we are required to do so by law.
7. COOKIES
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
For visitors to our website, we use
cookies to collect information. Our servers use three different types of
cookies:
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.
Flash cookies
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
In order to play real money games on
our services, you will be required to send money to and receive money from us.
We may use third-party electronic payment systems to process such financial
transactions. By accepting this Privacy Policy, you expressly consent to
Personal Information necessary for the processing of transactions including,
where necessary, the transfer of information outside of your country. We take
steps to ensure that our arrangements with payments systems protect your
privacy.
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.
10.
SECURITY
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
We cannot ensure the protection of
any information that you provide to a third-party online site that links to or
from the services or any information collected by any third party administering
our affiliate program (if applicable) or any other program, since these
third-party online sites are owned and operated independently from us. Any
information collected by these third parties is governed by the privacy policy,
if any, of such third party.
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.
15. CONSENT
TO PRIVACY POLICY
Your use of our services constitutes
an agreement to our Privacy Policy.
This is our entire and exclusive
Privacy Policy and it supersedes any earlier version. This Privacy Policy
should be read in conjunction with our Terms and Conditions and any additional
applicable terms posted on our platforms. We may periodically make changes to
this Privacy Policy and will notify you of these changes by posting the
modified terms on our Platforms. Your continued use of our services following
any changes to this Privacy Policy constitutes your acceptance of the changes.
We recommend that you revisit this Privacy Policy regularly.
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.
16. Other
web sites
Our web site may contain links to
other web sites, which are outside our control and are not covered by this
Privacy Policy. If you access other sites using the links provided, the
operators of these sites may collect information from you, which will be used
by them in accordance with their privacy policy, which may differ from ours. We
are not responsible. Solely the operators of these websites shall be
responsible for their functionality or possible errors on the linked sites.
17. When you play casino slots developed by INCLLUDE ANY SOFTWARE COMPANIES FOR WHICH YOU HAVE AN AGREEMENT
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
·
Employment
·
Inheritance
·
Investment
·
Family
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
·
Nationality
·
Gender
·
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.
AML-Compliance
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]