GOODS DIGITAL PASSPORT “KNOW YOUR CLIENT” POLICY
Goods Digital Passport “Know Your Client” Policy
Last Updated: May 21, 2018
PLEASE READ THIS KYC POLICY CAREFULLY BEFORE PARTICIPATING IN THE TOKEN SALE. BY REGISTERING WITH Goods Digital Passport YOU CONFIRM THAT YOU HAVE READ AND AGREE TO THIS KYC POLICY.
Goods Digital Passport is committed to prevent the use of GDP tokens and Goods Digital Passport products and services for illegal purposes. This Goods Digital Passport “Know Your Client” Policy is a key component in the program to prevent and detect money laundering, terrorist financing, fraud and identity theft.
Know Your Client” (‘KYC’ ) is an ongoing, risk?based process of identifying the participant of Goods Digital Passport token sale (the ‘ Participants ’, ‘ you ’, ‘your’ or ‘yours’ as appropriate) and verifying the Participant’s identity on the basis of documents, data or information in order to detect suspicious activities according to AML/CTF regulation, meet other legal and regulatory obligations, determine the Participant’s residence and/or location, and prevent fraud.
Goods Digital Passport may introduce and maintain verification levels (e.g. basic account, advanced account, etc.) based on the information and documents you have provided. Such ranking may affect how much GDP tokens you can purchase or your rights to withdraw GDP tokens.
You shall provide the following information to Goods Digital Passport upon registration your:
- full name (for legal entities, partnerships, foundations or trusts (‘legal entity ’) – full name of the Participant’s representative and the legal entity name);
- email address;
- country of residence.
- your name (and your business name – for legal entities) and country of residence are correct and you do not use false identity, impersonate another person or otherwise are involved in the prohibited practices (as defined in the Terms);
- you have full power and authority to enter into the agreement with Goods Digital Passport
- the Participant, who is an individual, is the owner of his/her payment account and the ultimate beneficial owner of the purchased GDP tokens;
- you or the legal entity you represent do not reside in any of the restricted territories (as defined in the Terms).
After you become a registered participant and purchase GDP tokens you will be able to complete the KYC process in the ‘Verification’ section of your dashboard by uploading the KYC documents and filling in or updating certain data about yourself, such as:
- your postal address,
- your date of birth,
- your phone number, and
- other information requested by Goods Digital Passport in order to complete the review).
At any time and at its sole discretion Goods Digital Passport may request via email and/or your account dashboard:
- the Participant’s proof of identity;
- the Participant’s proof of address;
- the Participant to perform online video verification.
The proof of identity document must be one of the following valid government issued photo ID:
- international passport (data pages with photo);
- national ID card (both sides, with photo only);
- permanent driver’s license (both sides, with photo only).
The proof of address document must be one of the following document no more than 3 months old and specifying your full name and address:
- utility bill, including electricity, water, gas, landline phone), Internet provider service or cable TV bill;
- bank statement;
- tax return accepted by the tax authority;
- property tax bill;
- election/Voters ID;
- official government letters.
You have to ensure that the scans of the documents are of high quality and that the edges of the documents are clearly visible.
In the event the Participant is a legal entity it may be additionally requested to provide:
- its formation documents;
- information sufficient for Goods Digital Passport to determine the legal entity’s good standing, the authority of the Participant’s representative to act on its behalf, as well as the representative’s identity;
- information and documents sufficient for Goods Digital Passport to identify and verify the beneficial owner, including, the ownership and control structure of that legal entity and the KYC information and documents in regard to the beneficial owner.
In certain cases (including, but not limited to when the Participant’s transactions has reached a certain threshold determined by Goods Digital Passport; in case of suspicious activity or doubts of veracity or adequacy of provided information and documents; or when Goods Digital Passport has suspicion or information that the Participant has been involved or might be involved in illegal or prohibited activities) Goods Digital Passport, at its sole discretion, may request you to provide:
- your source of funds information and information on the level of legitimate income, including but not limited to copy of a recent credit / debit / bank account statement (should be no more that 3 months old);
- certain documents to be certified by a notary public, and/or
- two forms of identification, both of which must be government issued and contain a picture and signature.
The source of fund documents shall provide evidence that identifies the actual source(s) of funds that you used to purchase GDP tokens and that it matches up with and can substantiate your buying activity. The source of funds information may be in the form of:
- proof of earnings (e.g. payslip/director remuneration/dividends/pension);
- a bank statement/savings account that clearly shows consistent incoming values from an identifiable source;
- a trust deed clearly showing a consistent entitlement to funds;
- dated proof of an award/payment made to you; or
- other clear evidence that would support ‘affordability’ in relation to your purchasing activities with Goods Digital Passport.
Goods Digital Passport will refuse to enter into or continue relationships or conduct transactions with a Participant who does not provide requested information and documents or provides false, inconsistent or conflicting information where the inconsistency or conflict cannot be resolved after reasonable inquiry.
Goods Digital Passport may suspend your account, the GDP tokens will not be distributed to you or you will not be able to withdraw your GDP tokens until Goods Digital Passport is able to obtain the requested information and/or documentation and the KYC process is completed satisfactorily. If you do not complete the KYC identification or verification your funds will be returned to you subject to the provisions of the Terms, this KYC Policy and applicable laws.
If as the result of the KYC measures it appears that you:
- have not supplied requested information and/or documentation to Goods Digital Passport and/or if Goods Digital Passport is unable to satisfactorily identify you and/or verify your source of funds (when requested) within a reasonable time-period, determined by Goods Digital Passport;
- are a resident of restricted territory (as defined in the Terms);
- are underage or is not eligible to enter the agreement with Goods Digital Passport;
- have used representatives, relatives, associates, affiliates, related parties, connected persons and/or other third parties to purchase GDP token on your behalf; and/or
- Have been directly or indirectly participating in any form of prohibited practices or other activities that Goods Digital Passport considers to constitute a misuse of its offer or breach of its terms;
Goods Digital Passport, may, as the case may be:
- return you your funds, unless it has to be withheld or forfeited due to the Terms or applicable laws;
- suspend or close your account with Goods Digital Passport;
- terminate the agreement (the Terms) with you; and/or
- report any criminal or suspicious activities to the appropriate authorities.
Goods Digital Passport may use subcontractors to perform certain KYC functions.