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 provides network services. Wallet Balance is prepaid credit for Databay's own Services, subject to the restrictions and refund rights in the Terms of Use. Our approach relies on payment-provider transaction monitoring and permits review of account risks and information made available to us. Our legal obligations depend on applicable law and our actual activities; this Policy does not determine our regulatory status or claim certification of a regulated AML program.

This Policy forms part of the Terms of Use, subject to their Sections 1 and 3 on agreement, notice and prospective changes. Customers must comply with the version applicable to their relationship with the Company.

2. Objective and Scope

This Policy prohibits use of Databay's Services for:

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

• Terrorist Financing: Providing funds or financial support for terrorism or to persons or organizations where that support is prohibited by applicable law.

• Sanctions Evasion: Evading or facilitating a violation of applicable economic sanctions or export restrictions.

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

3. Risk-Based Approach

We may request verification or additional information reasonably needed to assess fraud, payment, sanctions, or abuse risks, including in relation to high-volume purchases, cryptocurrency payments, or geographic restrictions. Required reviews are governed by the KYC Policy and depend on the relevant circumstances. Any verification or restriction required by applicable law remains mandatory.

4. Sanctions Compliance (OFAC)

Databay must comply with applicable U.S. economic sanctions, including those administered by the Office of Foreign Assets Control (OFAC), and applicable export controls, including restrictions administered by the Bureau of Industry and Security (BIS). Restrictions may concern persons, ownership, destinations, end users, or end uses. Applicable licenses, exceptions, and prohibitions depend on the particular transaction and may change.

The Services must not be used for a transaction prohibited by those laws. In addition, the following service-eligibility restrictions apply:

• Excluded Locations: Customers located in, ordinarily resident in, or organized under the laws of Russia, Belarus, Myanmar (Burma), Cuba, Iran, North Korea, Syria, or the Crimea, Donetsk, and Luhansk regions of Ukraine are not eligible to use the Services or make purchases. This is Databay's eligibility rule; it does not mean each location is subject to the same sanctions or a comprehensive U.S. embargo.

• Restricted Persons: Persons on OFAC's Specially Designated Nationals and Blocked Persons List are not eligible. Transactions prohibited under other applicable restricted-party or ownership rules are also prohibited, including dealings with entities blocked under OFAC's 50 Percent Rule.

You must not use another person's identity, payment method, account, or location information to evade these restrictions or make the Services available for a prohibited use. You must provide accurate information reasonably requested to assess eligibility. Databay and its payment providers may apply eligibility restrictions stricter than the legal minimum; a legal authorization does not itself require us to offer service. A potential sanctions match may require clarification before a determination can be made.

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 credit card payments through Stripe and cryptocurrency payments through Confirmo.

5.3. Cryptocurrency Risks: Cryptocurrency payments are subject to payment-provider transaction monitoring as described in Section 7. 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 activities are prohibited:

• Evasion of Review: Splitting payments or using multiple accounts to evade an applicable legal requirement or a verification or payment restriction communicated by Databay or its payment provider.

• 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.

• Payment or Refund Fraud: Making a knowingly false refund or payment-dispute claim. This does not restrict a good-faith dispute, chargeback, or remedy available under applicable law or the Refund Policy.

7. Monitoring and Detection

Transaction monitoring for credit card payments is performed by Stripe and for cryptocurrency payments by Confirmo, under the relevant provider's services and policies. The checks performed and the information made available to Databay depend on the provider and payment method.

Databay may review provider alerts and information made available to us, together with account information and abuse reports, and may request further verification or take action under Section 8 when appropriate. Using payment providers does not remove Databay's own obligations under applicable law.

8. Consequences of Policy Violation

Where available information gives us reasonable grounds to suspect a violation, we may take proportionate protective action while reviewing it. We may act without advance notice where reasonably necessary to address the risk or comply with law. Depending on the circumstances, action may include:

• Service Restrictions: Restricting an affected payment or account, or suspending or terminating access under the Terms.

• Balances: Applying a hold or other restriction only as authorized by the Terms or required by law. A concern or inquiry alone does not forfeit a balance. Refunds, release of balances, and any legally required blocking or rejection remain subject to applicable law, the Terms, and the Refund Policy.

• Verification: Requiring relevant identity or account information under the KYC Policy before deciding whether access can be restored.

• Reporting: Making disclosures to payment providers or competent authorities only where required or permitted by applicable law and consistent with the Privacy Policy.

A complaint, official inquiry, or possible sanctions match is not by itself a finding of misconduct. You may ask us to review a factual error using the contact below. Applicable legal restrictions may limit the information we can share or whether access or funds can be released.

9. Liability and Indemnification

Liability and indemnification in connection with actions taken under this Policy are governed by Sections 14 and 15 of the Terms of Use.

10. Policy Updates

Updates to this AML Policy, including notice, effective dates, and acceptance, are governed by Section 3 of the Terms of Use.

11. Contact Information

If you have questions regarding this AML Policy, please contact us:

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