KYC/KYB & Screening Notice
Effective Date: [EFFECTIVE DATE] Last Updated: [LAST UPDATED] Version: 2.0
1. Purpose
To protect Users, prevent financial crime, and comply with regulatory and payment processor requirements, KidStarter performs Know Your Customer (KYC) and Know Your Business (KYB) verification and screening. This Notice forms part of the Agreement (see Terms of Service).
2. Regulatory Framework
KidStarter's screening program is designed to support compliance with:
- EU: Anti-Money Laundering Directives (AMLD 4/5/6), EU sanctions regulations;
- UK: Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended), UK sanctions (OFSI);
- US: Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC sanctions, FinCEN requirements;
- Canada: Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC requirements, Canadian sanctions;
- Payment Processor Requirements: Card network rules (Visa, Mastercard, Amex) and payment processor (e.g., Stripe) compliance requirements.
3. Who We Screen
KidStarter may verify and screen the following:
| Subject | Scope |
|---|---|
| Creators | Identity verification, authority confirmation, sanctions screening |
| Schools/Organizations | Institutional legitimacy, registration verification, sanctions and adverse media screening, authorized signatory verification |
| Corporate Sponsors | Company registration, authorized representative identity, sanctions screening, PEP checks, beneficial ownership |
| Donors | Transaction monitoring, risk-based screening for high-value or anomalous donations |
| Vendors | Business legitimacy, sanctions screening, before disbursement |
4. What We Screen Against
4.1. Sanctions Lists: OFAC SDN List (US), OFSI Consolidated List (UK), EU Consolidated Sanctions List, Canadian Consolidated Autonomous Sanctions List, UN Security Council Consolidated List, and other applicable national and international sanctions lists.
4.2. Politically Exposed Persons (PEP): Where required by regulation or risk assessment, we screen for PEPs and their close associates, particularly for Corporate Sponsors and high-value transactions.
4.3. Adverse Media: Publicly available information regarding fraud, financial crime, corruption, or other reputational risks.
4.4. Law Enforcement and Regulatory Lists: Where applicable and accessible.
5. Verification Methods
5.1. Identity Verification: Government-issued ID review (verified and not stored beyond the verification period unless legally required), email verification, phone verification, knowledge-based authentication.
5.2. Business Verification: Company registration documents, articles of incorporation, tax registration, authorized signatory lists, beneficial ownership declarations.
5.3. Ongoing Monitoring: Screening is not a one-time event. KidStarter may re-screen Users periodically or triggered by events (e.g., change of control, large transaction, adverse media hit, policy change).
6. Outcomes
Based on screening results, KidStarter may:
| Outcome | Action |
|---|---|
| Cleared | Proceed with account creation, Campaign publication, or disbursement |
| Enhanced Due Diligence Required | Request additional documentation, limit functionality until resolved |
| Restricted | Limit account functionality pending further review |
| Declined | Deny account creation, Campaign publication, or disbursement |
| Terminated | Close account and report to authorities/processors as required |
6.1. KidStarter is not required to disclose the specific reason for a decline or termination where such disclosure would compromise the integrity of our screening program, endanger any person, or violate applicable law (including tipping-off prohibitions under AML laws).
7. Data Handling
7.1. Screening data is processed in accordance with the Privacy Notice and applicable data protection laws.
7.2. KYC/KYB documentation is stored with restricted access, encrypted at rest, and retained only as long as required for compliance and fraud prevention purposes (see Data Retention & Deletion Policy).
7.3. Government-issued IDs submitted for verification are reviewed and — unless legally required to be retained — deleted within 30 days of verification completion.
8. Your Rights
8.1. You have the right to know what Personal Data we process about you in connection with KYC/KYB (see Privacy Notice Section 10).
8.2. Where applicable, you may request correction of inaccurate data.
8.3. Certain data may be exempt from deletion requests where retention is required by law.
9. Contact
Questions: [SUPPORT EMAIL] Privacy Inquiries: [PRIVACY EMAIL]