KYC Policy (Know Your Customer, Identity Verification)

Last updated: August 19th, 2022

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This Know Your Customer Policy (“KYC Policy”) is an integral part of the legal procedure of Kado Software, Inc. (“Kado”, “we”, “us”) and it is an integral part of Kado’s Terms and Conditions. In order to be able to use the services of Kado, every user of Kado’s platform and services (“User”) needs to have declared to have read and agreed with these conditions. 

This KYC Policy describes the KYC process we use to identify our User and is designed to prevent money laundering, terrorist financing, fraud, or any other financial crime. By accepting our Terms and Conditions, you accept this KYC Policy as well.

In accordance with applicable law and AML policy the applied due diligence measures regarding a User are:

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• Identification and verification of the User;
• Identification of the beneficial owner;
• Understanding of business relationship or conducting a financial transaction;
• Gathering information on whether a person is a politically exposed person or family member or a close associate of a politically exposed person; and
• business relationship monitoring.

For this KYC Policy we may require you to provide us with the following information: first name, last name, date of birth, taxpayer identification number, telephone number, residential address, e-mail address, government issued photo ID (as a proof of identity), utility bill or bank statement (as s proof of address/residence), bank and tax documents or other documents that we consider necessary for your identification.

A proof of identity can be done through any or all of the following:

• A government issued photo ID such as passport, national ID card, driving license or other forms of government issued photo ID’s.
• The entire document must be presented in a color copy with full name, ID number, photo, signature and the date of expiration with at least six (6) months validation period.

A proof of address can be done through any or all of the following:

• Utility bill (Water/Electricity/Gas/Internet/Land Line Telephone) or Bank statement.
  

• The entire document must be presented in a copy with full name, physical address, issuance date and Utility company/Bank name and must be issued within the last three (3) months of submission.

We may request you to provide us with some financial information, describing your financial situation such as credit/debit cards or bank details, bank statements, sources of funds/wealth, and ask you to fill in our questionnaire to clarify the purposes for opening an account with us. We will also ask you about who is the final beneficial owner of the account and whether you are a politically exposed person, a family member, or a close associate of a politically exposed person.

In addition to documentation we may also choose to verify your identity through (i) selfie (in different types such as liveness check, selfie with a document, web camera photo, short video fragment) and/or (ii) video identification call via live video and/or audio chat and/or call conference. This can be done during the on-boarding process, before or after a transaction.

The submitted documents should have a valid date of expiring and should list your name/photo/your address. You agree to keep us updated if any of the information or documents you provide changes. We also reserve the right to require certified or notarized copies at your expense.

You acknowledge and agree that in order to conduct such verification process and/or background checks, in accordance with our AML policy, we may perform inquiries, directly or indirectly through third party service providers that we consider necessary to verify your identity or to prevent fraud, suspicious activity, misidentification, money laundering or any other prohibited activity. We reserve the right to take any action we deem necessary with respect to the outcome of such inquiries. You hereby acknowledge that we shall have the right to investigate you in case we determine you to be risky or suspicious.

When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full.

We shall have the right to verify your identity on an on-going basis, including cases when your identification information has been changed or your activity seemed to be suspicious (unusual for you). We reserve the right to request up-to-date documents from you, even though you have passed identity verification in the past.

We may monitor and analyze your transactions. We may perform compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. We may place you on watch and service denial lists, open cases for investigation where needed, send internal communications and fill out statutory reports, if applicable.

We shall have the right to:

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• report your transactions of suspicious nature to the proper law enforcement,
• request you to provide any additional information and documents in case of suspicious transactions,
• suspend or terminate your account when we have a suspicion that you are engaged in illegal activity.

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