KYC Policy

1. Introduction and Purpose

WATTENNE INTERNATIONAL LLC ("Company," "we," "us," or "our") is a limited liability company organized under Wyoming law. This Policy describes identity verification in connection with our Services and our efforts to address identity theft, financial fraud, money laundering, sanctions evasion, and other misuse.

We may request verification based on relevant account, payment, or abuse information. We do not require identity documents from every customer as a general condition of registration or purchase. Where applicable law requires verification or prohibits a transaction, that requirement applies regardless of a customer's verification status or payment method.

2. Tiered Verification Levels

An account may be unverified or have completed a requested review. Verification does not establish that every future payment or use is authorized, and it does not remove the eligibility restrictions in Section 5.

2.1. Standard Users (Unverified)

Customers may ordinarily register and purchase Services without submitting identity documents unless a review is required under this Policy.

• Payment Methods: This can include card and cryptocurrency purchases, subject to payment-provider requirements and applicable law.

• Requirements: Accurate registration and billing information and successful payment authorization, together with the requirements of the Terms of Use.

• Limitations: Applicable order, payment-method, and plan limits still apply. Remaining within a limit does not guarantee that verification will not be requested.

2.2. Verified Users

We may require completion of verification as a condition of a particular account review, request for higher limits, or individually agreed enterprise or reseller arrangement. This Policy does not establish an automatic spending threshold or a universal verification requirement for a payment method or product.

• Review Factors: Purchase volume, requested limits, use case, relevant payment-provider information, and credible indications of misuse may inform a verification request.

3. The "Right to Demand" (Mandatory Triggers)

We may require any customer, including one paying with cryptocurrency, to provide information reasonably necessary to assess eligibility, comply with applicable law, or investigate fraud or abuse. When a review is required, we will identify the information requested and the response period, subject to any legal restriction on what we may disclose.

Relevant information may include:

• Reported Misuse: Credible reports of unauthorized access, fraud, or another violation of the Acceptable Use Policy.

• Account or Usage Concerns: Information indicating compromised credentials or use inconsistent with account permissions or the purchased plan.

• Geographic or Identity Concerns: Information suggesting an eligibility restriction, false identity details, or evasion of applicable sanctions.

• Payment Irregularities: Relevant provider alerts, repeated failed payment attempts, or inconsistent billing information made available to us.

A report or official inquiry alone does not prove misconduct. We may restrict affected Services during a review where reasonably necessary to address a substantiated risk or comply with law. You may explain an apparent inconsistency or request review of a factual error using the contact below. Verification does not guarantee restoration where a separate restriction applies.

Failure to complete a required review within fourteen (14) days of our request (or any longer period stated in the request) may result in continued suspension or termination. Any treatment of a remaining balance is subject to the Terms, Refund Policy, sanctions restrictions, and applicable law.

4. Verification Procedures and Third-Party Reliance

4.1. Information Collected

Depending on the review and verification method, we may request relevant information such as:

• Full Legal Name.

• Date of Birth.

• Physical Residential Address (PO Boxes are not accepted).

• Government-issued Photo ID (Passport, Driver’s License, or National ID).

• Live "Selfie" or biometric check to verify liveness and document ownership.

4.2. Trusted Third-Party Provider (Persona Identities, Inc.)

Our identity-verification flow uses Persona Identities, Inc. Customers submit identity documents and any requested selfie through Persona's verification flow. The information and notices presented in that flow depend on the verification requested. Do not send identity documents to our general support email.

• Databay Records: Our verification records contain the outcome, inquiry and account references, identity-matching information, review dates, and verification-session IP address and user agent. They do not contain copies of raw identity-document images. We also receive verification responses containing identity details and document references to assess the result and match it to the account.

• Privacy: Databay's processing is governed by our Privacy Policy. Persona processes documents and verification information under its applicable notices and our agreement with it. Review the notices in the verification flow and Persona's Privacy Policy before submitting information; contact us if you need clarification.

5. Sanctions and OFAC Compliance

As a company organized in the United States, Databay must comply with applicable OFAC sanctions and applicable export controls. The AML Policy distinguishes legal restrictions from Databay's service-eligibility rules. Completing verification does not authorize a prohibited transaction.

5.1. Prohibited Jurisdictions

Under Databay's service-eligibility rules, customers located in, ordinarily resident in, or organized under the laws of the following locations are not eligible to use the Services or make purchases:

• Iran

• North Korea (DPRK)

• Cuba

• Syria

• Myanmar (Burma)

• Russia and Belarus

• The Crimea, Donetsk, and Luhansk regions of Ukraine

The location list above is an eligibility rule, not a description of identical or comprehensive sanctions on every listed location. Other applicable legal, company, or payment-provider restrictions may also prevent service.

5.2. Specially Designated Nationals (SDN)

Persons on OFAC's SDN List are not eligible. We also prohibit transactions barred by applicable restricted-party and ownership rules, including entities blocked under OFAC's 50 Percent Rule. A potential match requires consideration of the relevant facts and applicable rules, including any license or exception; control alone does not automatically establish blocking under that ownership rule. We may request information needed to resolve a concern, and must take any action required by applicable law. Payment-provider checks do not replace Databay's obligations.

5.3. U.S. Billing Addresses

Customers with a billing address in the United States are not eligible to purchase the Services. This is a separate service-eligibility restriction. You must provide accurate billing information and must not use a false or third-party billing address to circumvent it.

6. Integration with Terms of Use

This KYC Policy is incorporated into the Terms of Use. Updates, notice, and effective dates are governed by Section 3 of those Terms.

• Data Handling: All personal data collected during the verification process is handled in strict accordance with our Privacy Policy.

• Enforcement: Knowingly providing false, manipulated, or stolen documents is a material breach of the Terms and may result in restriction or termination. Disclosure to authorities is subject to applicable law and the Privacy Policy. A failed or incomplete review alone does not forfeit a balance or remove rights under the Refund Policy or applicable law.

7. Contact Information

If you have questions regarding this Policy or a pending verification request, please contact us:

WATTENNE INTERNATIONAL LLC
30 N Gould St Ste N, Sheridan, WY 82801, USA
Email: support@databay.com