KYC/Onboarding
1. Introduction
Acus Media OÜ ("Company"), operating www.sparkfeet.com ("Platform"), is committed to maintaining a safe and compliant environment by verifying the age and identity of all content producers. This Know Your Customer (KYC) and Onboarding Policy outlines the protocols implemented to ensure the authenticity and legality of our content producers at the time of onboarding and on an ongoing basis.
2. Onboarding Verification Process
The onboarding process for content producers involves several steps to ensure the verification of their age and identity:
Submission of Identification Documents:
- Content producers are required to submit a valid government-issued ID (e.g., passport, driver’s license).
- For manual verification, additional details are required: Username, full name, date of birth, selfie of the user including a handwritten note with the username and current date.
Age Verification:
- The submitted identification documents are checked to ensure that the content producer is at least 18 years old.
- An automated system (e.g. by a third-party-provider) verifies the authenticity of the ID documents combined with a biometric check to confirm the identity.
- The biometric data is cross-referenced with the ID to ensure a match.
- Verification is mandatory for each individual depicted in any kind of sexually related and/or monetized content.
3. Ongoing Verification Process
To ensure that the models appearing on camera are the same individuals who were vetted during the onboarding process, SparkFeet implements the following ongoing verification protocols:
Periodic Re-Verification:
- Content producers are required to re-verify their identity if demanded by the platform.
Random Spot Checks:
- Random spot checks are conducted to ensure ongoing compliance.
- Content producers may be asked to re-verify their identity and/or submit a selfie or live video at any time.
Content Audit:
- Regular audits of uploaded content are performed to ensure that the individual in the content matches the verified identity.
- Content producers flagged during audits are required to undergo additional verification.
4. Reporting and Record-Keeping
Secure Storage:
- All identification documents, biometric data, and personal information are stored securely and in compliance with data protection regulations.
- Access to sensitive information is restricted to authorized personnel only.
Record Maintenance:
- Records of all verification processes are maintained for a minimum of five years.
- Detailed logs of re-verifications and spot checks are kept to ensure traceability.
5. Compliance and Cooperation
Regulatory Compliance:
- The Company ensures compliance with all relevant local, national, and international laws and regulations regarding age and identity verification.
- Policies are regularly reviewed and updated to remain compliant with legal requirements.
Cooperation with Authorities:
- The Company cooperates fully with law enforcement and regulatory authorities in cases of suspected fraud, misrepresentation, or other illegal activities.
- Information is shared with authorities as required by law and in accordance with privacy policies.
6. User Education
Training and Awareness:
- Regular updates and reminders are sent to ensure ongoing compliance.