Kyc Policies

Scope and Purpose

91 Club conducts Know Your Customer (KYC) procedures to verify a customer’s identity, confirm age and residency, and to comply with applicable anti-money laundering (AML) and countering the financing of terrorism (CFT) obligations. This policy applies to all customers and to all services offered by 91 Club.

When KYC Is Triggered

KYC verification becomes mandatory when a customer reaches either of the following thresholds or events: aggregate lifetime deposits exceed 2,000 EUR (or the equivalent in the customer’s transactional currency) or a withdrawal request of any amount is submitted. 91 Club may also initiate KYC checks at its risk-based discretion in accordance with applicable law and licensing requirements.

Verification Process and Statuses

  • Submission: The customer provides the documents and information specified in this policy for verification.
  • Review and decision: Our KYC team reviews submissions. A decision is communicated within 24–72 hours of submission, provided no further information is required.
  • Outcomes: Approved (full verification completed), Temporarily Approved (limited activity pending full verification), or Rejected. If additional information is needed, a request will be issued and the status remains Temporarily Approved.
  • Temporary approval restrictions: While temporarily approved, deposits are limited to a cumulative total of 500 EUR (or the equivalent in the customer’s currency) and no withdrawals are permitted until full verification is achieved.

If verification fails or is incomplete, 91 Club will notify the customer of the reason and may suspend or close the account in accordance with this policy and applicable law.

Required Documents and Verification Steps

  • Government-issued photo identification: acceptable documents include a passport, national ID card, or driver’s license, valid and clearly readable.
  • Selfie with ID: a current photo of the customer holding the ID to confirm identity against the document provided.
  • Proof of address: a document issued within the last three months showing the customer’s name and current residential address (e.g., utility bill, bank statement).
  • Payment verification (if deposits are made by card): photos of the front and back of the card used, with the CVC/CVV obscured; the cardholder name must match the customer’s name. We may request masked or partially redacted images as appropriate.
  • Source of funds and income documentation: where requested, documents such as recent pay slips, bank statements, or tax documents to verify funds for AML/CFT purposes.
  • Video or telephone verification: at our discretion, the customer may be invited to participate in a live verification interview.

Additional AML/CFT and Compliance Measures

To comply with AML/CFT laws, 91 Club conducts ongoing risk-based screening of customer data and transactions for indicators of money laundering, fraud, or other illicit activity. This may include cross-checks against internal risk models and external screening databases. We may suspend activity or request further information if suspicious activity is detected.

Data Collection, Processing, and Retention

During KYC, 91 Club collects and processes personal data necessary to identify, verify, and assess customers for compliance. Categories include:

  • Identification and contact data (e.g., name, date of birth, address, email, phone).
  • Identity documents and verification data (IDs, selfies).
  • Financial data related to deposits, withdrawals, and payment methods.
  • Transaction and activity data (play activity, balances, devices, login information).
  • Marketing preferences and communications data (when consent is provided).

Data may be shared with regulatory authorities and licensed bodies as required by law. Records pertaining to KYC and AML/CFT checks are retained for a minimum period in accordance with licensing and data retention requirements, typically several years after account closure or last activity.

Rights of the Customer

Customers have rights under applicable data protection laws, including access to their personal data, correction of incomplete or inaccurate data, and restriction or objection to certain processing. Customers may request data portability, erasure where lawful, and withdrawal of consent for direct marketing at any time.

Consequences of Non-Disclosure or Misrepresentation

Providing false, incomplete, or misleading information or failing to provide the requested documents may result in temporary restrictions, suspension, or termination of the customer’s account, loss of eligibility for bonuses or winnings, and potential regulatory consequences.

Governing Law and Dispute Resolution

This policy is governed by the licensing jurisdiction under which 91 Club operates. Any disputes arising from KYC processing or AML/CFT compliance will be resolved under the jurisdiction's competent courts, subject to mandatory regulatory dispute-resolution procedures where applicable.

Contact and Queries

For questions about this policy or to submit data subject requests, contact the support team at 91 Club: [email protected]. For matters related to data protection, you may also contact our Data Protection Officer at [email protected].