Anti-Money Laundering (AML) Policy

1. Introduction and Policy Statement

This Anti-Money Laundering Policy ("Policy") governs the use of the proxy services, data packages, and platform (collectively, the "Services") provided by WATTENNE INTERNATIONAL LLC, a Wyoming Limited Liability Company ("Databay," "we," "us," or "our"), accessible via databay.com and app.databay.com.

Databay is committed to the highest standards of compliance with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws. Although Databay is a provider of technical infrastructure and not a financial institution, we voluntarily adhere to strict standards aligned with the US Bank Secrecy Act (BSA) and international standards to prevent our Services from being used to facilitate financial crimes.

By creating an account, purchasing data (GB/TB), or using our Services, you ("Customer" or "you") agree to comply with this Policy.

2. Objective and Scope

The objective of this Policy is to prohibit and actively prevent the use of Databay’s Services for:

• Money Laundering: The process of making illegally-gained proceeds appear legal.

• Terrorist Financing: Providing funds or financial support to non-state actors.

• Sanctions Evasion: Attempting to bypass international sanctions regimes (e.g., OFAC).

• Fraudulent Purchasing: Using stolen credit cards, compromised accounts, or illicitly obtained cryptocurrency.

3. Risk-Based Approach

Databay operates a global proxy network carrying an inherent risk of misuse for concealing identity. To mitigate this, Databay adopts a Risk-Based Approach (RBA).

We apply stronger due diligence measures to higher-risk accounts (e.g., high-volume purchasing, cryptocurrency payments, or connections from high-risk jurisdictions) and reserve the right to request additional verification ("Enhanced Due Diligence") from any Customer at any time.

4. Sanctions Compliance (OFAC)

As a Wyoming, USA entity, Databay strictly complies with the regulations enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) as well as international restrictions required by our payment partners.

We strictly prohibit the use of our Services by, and do not process payments from:

• Sanctioned Jurisdictions: Individuals or entities located in Russia, Belarus, Myanmar (Burma), Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.

• Specially Designated Nationals (SDNs): Individuals or entities listed on OFAC’s Blocked Persons List.

We may utilize automated systems to screen user details and IP addresses against international sanctions lists.

5. Source of Funds and Payments

5.1. Legitimate Funds: You represent that all funds used to purchase data packages are derived from legitimate sources and are not the proceeds of illegal activities, including fraud, drug trafficking, or theft.

5.2. Payment Methods: Databay accepts payments via fiat currencies and cryptocurrencies.

5.3. Cryptocurrency Risks: If you pay via cryptocurrency, you acknowledge that Databay conducts blockchain analysis. We reserve the right to reject transactions from "mixer" services, darknet markets, or sanctioned wallets. We may delay crediting data to your account until the transaction has achieved the required confirmations.

6. Prohibited AML-Related Activities

In addition to our Acceptable Use Policy, the following financial activities are strictly prohibited:

• Structuring (Smurfing): Breaking down large transactions into smaller amounts to avoid triggers.

• Money Muling: Allowing a third party to access your account to process payments on their behalf.

• Stolen Credentials: Using payment methods that do not belong to you without authorization.

• Refunding Fraud: Purchasing services with the intent to dispute the transaction (chargeback) after utilizing the Services.

7. Monitoring and Detection

Databay employs monitoring mechanisms to detect suspicious activity. We monitor transactional patterns, such as velocity (frequency of top-ups), inconsistency (IP vs. billing address conflicts), and unusual volume purchases disproportionate to historical behavior.

8. Consequences of Policy Violation

If Databay suspects a violation of this Policy, we reserve the right to take the following actions immediately and without prior notice:

• Account Suspension: Temporary or permanent freezing of the account.

• Forfeiture of Data: All data balances (limited or no-expiration plans) may be immediately voided. No refunds will be issued.

• Enhanced KYC Demand: Requirement to submit government-issued ID before restoring access.

• Reporting: Reporting suspicious activities to US Federal authorities (e.g., FinCEN) or payment processors.

9. Liability and Indemnification

Databay shall not be liable for any damages, losses, or interruptions of service resulting from our good-faith application of this AML Policy. You agree to indemnify WATTENNE INTERNATIONAL LLC from any claims or legal costs arising out of your violation of this Policy or your use of the Services for financial crimes.

10. Policy Updates

Databay reserves the right to modify this AML Policy at any time. We will update the "Last Updated" date at the top of this page. Continued use of the Service after such changes constitutes acceptance of the new Policy.

11. Contact Information

If you have questions regarding this AML Policy, please contact our compliance team:

WATTENNE INTERNATIONAL LLC
30 N Gould St Ste N, Sheridan, WY 82801, USA
Email: [email protected]