AML / KYC Policy
(Anti-Money Laundering & Know Your Customer Policy)
1. Purpose
This policy is designed to prevent:
• money laundering;
• terrorist financing;
• fraud;
• misuse of the platform.
Although the Company does not operate a regulated activity requiring a licence from the UK Gambling Commission, DONJUAN&CO LTD voluntarily applies standards aligned with UK best practices.
2. Identity verification (KYC)
2.1 Standard verification
The Organiser may request:
• valid government-issued identification;
• proof of address (issued within the last 3 months);
• age verification;
• a copy of the passport.
2.2 Enhanced Due Diligence (EDD)
Enhanced checks may be carried out in cases including, but not limited to:
• high-value winnings;
• unusual or repeated payment activity;
• use of third-party payment methods;
• participants located in high-risk jurisdictions;
• attempted chargebacks or disputed transactions.
Additional measures may include:
• selfie verification with identity document;
• biometric verification;
• source of funds verification;
• sanctions and Politically Exposed Persons (PEP) screening.
3. Transaction monitoring
The Company actively monitors for:
• rapid or repeated purchase activity;
• attempts to bypass the 10-ticket limit;
• multiple accounts linked to the same IP address;
• declined payments or chargeback attempts.
4. Sanctions & enforcement
In the event of suspicion or breach, the Organiser reserves the right to:
• temporarily suspend an account;
• refuse to award the prize;
• cancel entries;
• report the matter to relevant authorities where required.
5. Data retention
KYC data is retained:
• for a minimum of 5 years;
• in accordance with the UK GDPR;
• using appropriate technical and organisational security measures.
RPECP Policy
(Responsible Play & Ethical Competition Policy)
1. ethical commitment
Although the competition is legally classified as a skill-based competition under the Gambling Act 2005, the Company adopts a responsible approach inspired by industry standards applicable to gaming and prize competitions.
2. participation limits
• Maximum of 10 tickets per person
• Monitoring of excessive or unusual behaviour
• Accounts may be restricted or suspended in cases of abuse
3. self-exclusion
Participants may request:
• temporary suspension of their account;
• permanent account closure;
• full exclusion from future participation.
Requests will be processed within 48 hours.
4. Underage policy
• Age verification may be carried out at any time
• Any account identified as belonging to a minor will be immediately suspended
• No refunds will be issued in cases of false age declaration
5. responsible communication
The Company undertakes:
• not to present participation as an investment opportunity;
• not to suggest it constitutes a source of income;
• not to target vulnerable individuals.
Anti-Fraud & Chargeback Policy
1. Purpose
This policy aims to prevent:
• payment card fraud;
• abusive chargebacks;
• fraudulent multiple account registrations;
• manipulation of the draw process.
2. Technical measures
The platform may implement the following measures:
• IP address analysis
• proxy and VPN detection
• device fingerprinting
• mandatory 3D Secure authentication
• CVV and AVS verification
These measures are implemented to ensure the integrity, security, and fairness of the platform.
3. Chargebacks
In the event of a chargeback:
• immediate account suspension;
• blocking of any winnings;
• case escalation to the payment service provider (PSP);
• systematic dispute of the chargeback.
If a prize has already been awarded prior to the chargeback:
• legal action may be initiated to recover the value of the prize;
• administrative and recovery costs may be charged to the participant.
4. Multiple accounts and misuse
The following are strictly prohibited:
• creation of multiple accounts;
• use of third-party payment methods;
• participation under a false or fraudulent identity.
Sanctions may include:
• cancellation of all entries;
• permanent account ban;
• exclusion from future competitions.
5. Evidence retention
The Company retains the following records:
• activity logs;
• payment records;
• draw records via RandomDraws;
• timestamped entry data.
Minimum retention period: 12 months.