SIMAKKS LTD.
KYC (Know Your Client) ONBOARDING PROCESS
BUSINESS TYPOLOGY
The Business in which Simakks LTD. operates is totally online and does not require any contact between the company and the users or the performers.
Given the delicate nature of its type of business (adult contents), SIMAKKS LTD. has implemented a restrictive and rigid protocol in order to protect the Company, its members, the technicians who work on the site https://rigardyou.com and the personnel authorized to manage the site itself. The KYC guidelines protects also SIMACKKS Clients and Performers from unauthorized registrations or accesses.
This KYC in informs you of the guidelines maintained by the site and describes technically and in detail all the authorization process required by the registration of its members.
PREAMBLE
The site https://rigardyou.com is an adult site, and therefore equipped with all the newest technologies that guarantee its legality.
In particular, the site can only be viewed by adults in accordance with the declaration of adulthood (over 18 years) with which a pop-up opens on any page of the site.
Only in the event that the user declares to be of age and clicks on the specific button of the popup covering the site, assuming responsibility for the truthfulness of the information, will he be able to access the visualization of the site itself.
We remind you that if a minor makes a false declaration, the person directly responsible, according to European laws, is whoever takes his place and is required to monitor his behavior on the web.
Therefore SIMAKKS L.T.D cannot be held liable for any minors who click on the button to confirm their majority, thus issuing a false statement and committing a crime of impersonation, envisaged by all European and international legislations.
Once the user has clicked on the button which confirms that he is over 18 but it doesn’t do any logging, the site will only be partially visible: the user will only be able to access certain sections of it, such as the homepage. In particular, he may not in any case buy credits, nor spend them to view the multimedia material, the live shows of the performers, subscribe to the viewing of the uploaded media, or access the pages of the site that offer our services.
Only the homepage and other informative pages such as the Terms of Use, the Privacy Policy, the Cookie Policy and the guidelines of our site can be viewed.
This kind of guests can also send us an email by filling out a form to request information from the administrators.
Therefore, those who view our site only as guests and without completing the registration process, will not be able to access the same areas reserved for Clients and Performers in any way.
INFRINGEMENTS OF THE TERMS AND CONDITIONS
As already mentioned in Terms and corditions, any report of breach of the Terms and Conditions can be reported to the administrators, who will, within 7 days (but also much sooner) verify the report and the breach.
Failure to comply with the rules imposed by the listed Terms and Conditions will lead to the closure of the account and therefore also the cancellation of the purchased tokens.
As already specified in the Terms and Conditions, every review decision and action to prevent infringements will be exclusively evaluated by our administrators and, for serious crimes and infringements we will take care of notifying them the public authority in order to inform the institutions responsible for monitoring the web..
REGISTRATIONS
This site allows two types of registrations (excepted the administrative registration with role of Admin management of the site and reserved to our site engeneers).
– The registration as Client.
– The registration as Performer.
KYC REQUIREMENTS FOR CUSTOMER ONBOARDING
The two types of subscriptions are separated from each other, and the site, being dynamic, will detect which type of registration the user belongs to, displaying or hiding in an “intelligent” way and automatically the parts that must be displayed or hidden only at one or to the other type of user.
Also the registrations between these two categories of users, therefore, vary according to whether the user is a Client or a Performer.
REGISTRATION AND DUE DILIGENCE FOR USERS
As mentioned above, there are two levels of registration: the lowest level is that of the Client, the highest level, and which therefore requires greater anti-fraud and anti-money laundering attention, is that of the Performer.
Consequently, there are two different levels of attention and due diligence for users of the site’s services, depending on whether they are Clients or Performers.
DUE DILIGENCE FOR CLIENTS
Clients have a low level of interactivity: they can only:
* Buy credits (tk€)
* Use their tk€ to see live shows, subject to approval by the performer.
* Use their tk€ to send small gifts in tk€ to the performer (a certain amount of time must pass between one gift and another).
* Use their tk€ to ask performers for services through an official request (a request that performers can decline, because on our site nobody is forced to do anything they don’t want to do).
* Use their tk€ to subscribe to subscriptions whose value and time duration varies between a minimum and a maximum default set by the admins, and which the performer will configure personally.
* Use a third-party feature called Lovense, which sends performers vibrations of toys used for shows. Each mailing has a cost in tk€. Warning, this function will be implemented at a later time, and we will bring you to the knowledge of all aspects before integrating it.
Being that the Client can only buy credits and spend them in the aforementioned ways, watching the show one-way (performer to Client but NOT vice versa), he will never appear to the performer in order to preserve his privacy.
All these modalities are foreseen in the contract given by the Terms and Conditions and in Privacy Policy of the site.
In particular, by going to the client’s registration page, https://rigardyou.com/register-client/ you can see that the client will be asked to fulfill:
- Username field
- Password
- Password verification (it will be compared with password)
- Other information that will be used for internal search engines.
- User’s Terms and condition acceptance (valid as contract, registation impossible if not selected).
The Client will recieve an email, which must be confirmed by clicking on a link.
Once this process is completed, the Client will be able to start operating, but will still be monitored by the administrators who will be able to see at any time if it spends abnormally.
We have set ourselves a limit of €8,000/month for each client, in addition to which transactions for the purchase of tk€ will be blocked until the following month to avoid money laundering, which in any case will also be screened upon receipt, i.e. of performers’ earnings.
The sale procedure of the tk€ is exactly like that of any other site that uses woocommerce: when purchasing the tk€, the Client will also be asked for an address, city, zip code, nationality, telephone and VAT number.
Since a client cannot spend any tk€ without a Performer to receive it, the real due diligence check is carried out precisely on the Performers and not on the Clients.
APPROVING PROCEDURE FOR CLIENTS
This is the time procedure for the Client to be subscribed (in blue the admin’s tasks, in green the Client’s tasks).
- The Client sends the membership form filled in and with the acceptance of the Terms of Use activated. The membership form CANNOT technically be sent without activating the acceptance of the Terms of Use.
- The Client receives an email with a link, which he must click to confirm the accuracy of his email address. Without accomplishing this operation the Performer will be refused by internal system of the site.
- The Site Admin receives an email which will notify the site admins the Client registration.
- The Client will receive an email informing the outcome of the registration.
DUE DILIGENCE FOR PERFORMERS
Since the Performers are the only end users of our service and the only users who receive money (except of course our company, which collects a commission for each transaction between Client and Performer) SIMAKKS LTD. has decided to perform a thorough due diligence on them. Performers have an higher level of interactivity they are allowed to use the same functions as Clients, but, being Performers, they can also receive credits tk€ from:
* Theyr private live shows.
* Small gifts in tk€ to the performer (a certain amount of time must pass between one gift and another, for avoiding compulsive sending).
* Official request of shows (a request that performers can decline).
* Set up tiers to earn from viewing their media (videos and images). Set up up to 3 tiers to earn from viewing their media (videos and images) The cost of the tiers will be chosen freely by the Performer, but always within a range pre-established for all Performers by the admins, in order to avoid the transfer of large sums between Clients and Performers.
* Use a third-party feature called Lovense, which sends performers vibrations of toys used for shows. Each mailing has a cost in tk€. Warning: this function will be implemented at a later time, and we will bring you to the knowledge of all aspects before integrating it.
All these modalities are foreseen in the contract given by the Terms of Use.
Notice: that we don’t use automatic age and documents verification system. This, due to the inaccuracy of such type of systems for a percentage that varies between 1% and 3% of subscribers. Therefore, each application for membership as a Performer will be carefully and meticulously screened manually by our staff before approving access to Performer candidates. Obviously, no compiled information except the Username will be displayed on the site, but the information and images of the documents necessary for registration will be kept in an administrative record that can be consulted by our staff and available, if necessary, to the authorities of Public Security and competent judiciary.
In particular, by going to the client’s registration page, https://rigardyou.com/register-performer/ you can see that the client will be asked to fulfill:
SITE ID RECORDS
- Username Field
- Password
- Password verification
ADMINISTRATIVE RECORDS
- Full Name and Surname
- Date of Birth
- Prove of Age ID Scan: can be identity document, driver license showing name and birth date. Supported formats: pdf, jpeg, jpg, png).
- ID Type and Number: The type and number for document providing proof of age.
- Proof of Identity Selfie: Upload a selfie holding the identity document uploaded previously. Your face and front of document must be clearly visible. Supported formats: pdf, jpeg, jpg, png.
- Address: a document scan or photo proving address. Can be utility bill or bank statement showing name and address. Supported formats: pdf, jpeg, jpg, png.
- Proof Of Address Document: the Performer will be asked to upload a Proof of Address Document. Can be utility bill or bank statement showing name and address. Supported formats: pdf, jpeg, jpg, png.
- Phone Number: where the Performer can be reached if further details or required verifications. Can be used to verify identity for account recovery.
- Tax ID Number (VAT or TIN). In some countries same as the Personal Identification Code from the ID.
- Payout Method: here there will be the Payout method for us to send the earnings to performer from our accounts, it will be internal to our website: when a performer will exceed the €350 threshold in earnings, it will be paid through our company account and its tokens, resetted.
- Payout Details: details where payment should be sent (email or wallet addresses).
SITE SEARCHING RECORDS (I am, I looking for…)
- Informations for the internal search engine included in our site.
ACCEPTANCE:
- Terms od Use Acceptance: necessary for sending us the the form.
APPROVING PROCEDURE FOR PERFORMERS
SIMAKKS LTD. evaluate all the requests coming from the performers with the following time procedure (in blue the admin’s tasks, in green the aspiring Performer’s tasks):
- The aspiring Performer sends the membership form filled in and with the acceptance of the Terms of Use activated. The membership form CANNOT technically be sent without activating the acceptance of the Terms of Use.
- The aspiring Performer receives an email with a link, which he must click to confirm the accuracy of his email address. Without accomplishing this operation the Performer will be refused by internal system of the site.
- The Site Admin receives an email which will notify the site admins of the candidate performer’s request.
- The Site Admin will check all documentation. In the meantime, the aspiring performer will be kept in a “pending” condition, which means that he will not be able to interact in any way with the site for the moment.
- The Site administrator will grant or deny membership on the site.
- The Performer will receive an email informing of the outcome of the pre-registration.