Learn About WinClash Terms and Conditions

Introduction to the General Terms and Conditions

These terms and conditions, along with the documents referred to and linked below (the “Terms”), set out the basis upon which the website operated under the URL https://winclash.com (the “Website”) and its related or connected services (collectively, the “Service”) will be provided to you.

Please read these terms carefully, as they form a binding legal agreement between you—our customer (the “Customer”)—and us. By opening an account (the “Account”) and using the Service, you agree to be bound by these terms, along with any amendments that may be published from time to time.

If anything is unclear, please contact us using the contact details below.

WinClash will only communicate with customers via email to their registered email address (the “Registered Email Address”) as provided when opening your WinClash account. Communication from WinClash will be issued through the following email address:

Email: support@winclash.com

We reserve the right to amend these terms (including any documents referred to and linked below) at any time. If such an amendment is not substantial, we may not provide you with prior notice. You will be notified in advance of any material changes to the terms and may be required to reconfirm acceptance of the updated terms before the changes come into effect. If you object to any such changes, you must immediately stop using the service, and the termination provisions below will apply. Continued use of the service indicates your agreement to be bound by such changes. Any bets not settled prior to the changed terms taking effect will be subject to the pre-existing terms.

If at any time you are in doubt about how to place bets or otherwise use the service, you should refer back to these terms or contact our Customer Service Department at support@winclash.com

1. Your Obligations

You agree that at all times when using the Service:

You are over 18 years of age (or over the age of majority as stipulated in the laws of the jurisdiction applicable to you) and can enter into a binding legal agreement with us.

It is the User’s responsibility to check and enter this site only if the user is in a country where it is lawful to place bets on the service (if in doubt, you should seek local legal advice). It is your responsibility to ensure that your use of the service is legal.

When sending money to us you are authorised to do so e.g. you are the authorised user of the debit/credit card or other payment method you use.

You will not, by participating in the Services and/or placing bets be placed in a position of actual, potential or perceived conflict of interest in any manner.

You have never failed to pay, or attempted to fail to pay a liability on a bet.

You are acting solely on your own behalf as a private individual in a personal capacity and not on behalf of another party or for any commercial purposes.

By placing bets, you may lose some or all of your money lodged with us in accordance with these terms and you will be fully responsible for that loss.

You must use the service for legitimate betting purposes only and must not nor attempt to manipulate any market or element within the service in bad faith or in a manner that adversely affects the integrity of the Service or us.

When placing bets on the service you must not use any information obtained in breach of any legislation in force in the country in which you were when the bet was placed.

You must make all payments to us in good faith and not attempt to reverse a payment made or take any action which will cause such payment to be reversed by a third party in order to avoid a liability legitimately incurred.

You must otherwise generally act in good faith in relation to use of the service at all times and for all bets made through the service.

2. Registration

You agree that at all times when using the service:

In order to protect the integrity of the service and for other operational reasons, we reserve the right to refuse to accept a registration application from any applicant at our sole discretion and without any obligation to communicate a specific reason.

Before using the service, you must personally complete the registration form and read and accept these terms. In order to start betting on the service, we will require you to become a verified customer, which includes passing certain checks. You may be required to provide a valid proof of identification and any other document as it may be deemed necessary.

This includes, but is not limited to, a picture ID (copy of passport, driver’s license, or national ID card) and a recent utility bill listing your name and address as proof of residence to the minimum. We reserve the right to suspend wagering or restrict account options on any account until the required information is received. This procedure is a statutory requirement and is done in accordance with the applicable gaming regulation and the anti-money laundering legal requirements. Additionally, you will need to fund your WinClash account using the payment methods set out in the payment section of our website.

You must provide complete and accurate information about yourself, inclusive of a valid name, surname, address, and email address, and update such information in the future to keep it complete and accurate. It is your responsibility to keep your contact details up to date on your account. Failure to do so may result in you failing to receive important account-related notifications and information from us, including changes we make to these terms. We identify and communicate with our customers via their registered email address. It is the responsibility of the customer to maintain an active and unique email account, to provide us with the correct email address, and to advise WinClash of any changes in their email address. Each customer is wholly responsible for maintaining the security of his registered email address to prevent the use of his registered email address by any third party. WinClash shall not be responsible for any damages or losses deemed or alleged to have resulted from communications between WinClash and the customer using the registered email address. Any customer not having an email address reachable by WinClash will have his account suspended until such an address is provided to us. We will immediately suspend your account upon written notice to you to this effect if you intentionally provide false or inaccurate personal information. We may also take legal action against you for doing so in certain circumstances and/or contact the relevant authorities, who may also take action against you.

You are only allowed to register one account with the service. Accounts are subject to immediate closure if it is found that you have multiple accounts registered with us.

This includes the use of representatives, relatives, associates, affiliates, related parties, connected persons, and/or third parties operating on your behalf.

In order to ensure your financial worthiness and to confirm your identity, we may use any third-party information providers we consider necessary.

You must keep your password for the service confidential. Provided that the account information requested has been correctly supplied, we are entitled to assume that bets, deposits, and withdrawals have been made by you. We advise you to change your password on a regular basis and never disclose it to any third party. Passwords must contain at least one letter, one number, and one special character and must be at least eight characters long. It is your responsibility to protect your password, and any failure to do so shall be at your sole risk and expense. You must log out of the service at the end of each session. If you believe any of your account information is being misused by a third party, or your account has been hacked into, or your password has been discovered by a third party, you must notify us immediately by email using your registered email address at support@winclash.com

You must notify us if your registered email address has been hacked into; we may, however, require you to provide additional information/documentation so that we can verify your identity. We will immediately suspend your account once we are aware of such an incident. In the meantime, you are responsible for all activity on your account, including third-party access, regardless of whether or not their access was authorised by you.

You must not at any time transmit any content or other information on the service to another customer or any other party by way of a screen capture (or other similar method), nor display any such information or content in a frame or in any other manner that is different from how it would appear if such customer or third party had typed the URL for the service into the browser line.

When registering, you will be required to choose the currency in which you will operate your account. This will be the currency of your deposits, withdrawals, and bets placed and matched into the service as set out in these terms. Some payment methods do not process in all currencies. In such cases a processing currency will be displayed, along with a conversion calculator available on the page.

We are under no obligation to open an account for you, and our website sign-up page is merely an invitation to treat. It is entirely within our sole discretion whether or not to proceed with the opening of an account for you, and, should we refuse to open an account for you, we are under no obligation to provide you with a reason for the refusal.

Upon receipt of your application, we may be in touch to request further information and/or documentation from you in order for us to comply with our regulatory and legal obligations.

3. Restricted Use

• 3.1 You must not use the Service:

  If you are under the age of 18 (or below the age of majority as defined by the laws of the jurisdiction applicable to you), or if you are not legally able to enter into a binding legal agreement with us:

  🞄  Collecting nicknames, email addresses, or other information from other customers by any means (e.g., sending spam, unsolicited emails, or unauthorized framing or linking to the service);

  🞄  Disrupting or unduly affecting or influencing the activities of other customers or the operation of the service;

  🞄   Promoting unsolicited commercial advertisements, affiliate links, or other forms of solicitation that may be removed from the service without notice.

• 3.2 You cannot sell, transfer, or assign your account to third parties, nor can you acquire a player account from another individual.
• 3.3 You may not, in any manner, transfer funds between player accounts.
• 3.4 We may immediately terminate your account upon written notice if you use the service for unauthorized purposes. In certain circumstances, we may also take legal action against you.

4. Privacy

Any information provided to us will be protected and processed strictly in accordance with these Terms and our Privacy Policy. We will not disclose your identity unless lawfully required by competent authorities, such as regulators, law enforcement (for investigating fraud, money laundering, or sports integrity issues), or financial institutions (e.g., banks or payment providers). Upon registration, your information will be stored in our database, which may involve transferring your personal data outside the European Economic Area (EEA) to jurisdictions with varying data protection standards. By agreeing to these Terms, you consent to the transfer of your personal information for service provision purposes, as outlined in our Privacy Policy.

5. Your Account

We accept accounts in multiple currencies.

We do not offer credit for the use of the service.

We may close or suspend an account and refund any funds held if you are not, or if we reasonably believe you are not, complying with these terms, or to ensure the integrity or fairness of the service, or if we have other reasonable grounds to do so. We may not always be able to provide prior notice.

We reserve the right to suspend an account at any time without prior notice and return all funds. However, we will honor any contractual obligations that have already matured. We reserve the right to refuse, restrict, cancel, or limit any wager at any time for any reason, including any bet perceived to have been placed fraudulently in order to circumvent our betting limits and/or system regulations.

If we close or suspend your account due to non-compliance with these terms, we may cancel and/or void any of your bets.

If any amount is mistakenly credited to your account, it remains our property. Upon becoming aware of such an error, we will notify you, and the amount will be withdrawn from your account.

If, for any reason, your account goes overdrawn, you will owe us the amount overdrawn.

You must inform us as soon as you become aware of any errors regarding your account.

Customers have the right to self-exclude from https://winclash.com. These requests must be sent from the customer’s registered email address to support@winclash.com.

Customers may set limitations on the amount they may wager and lose. Such requests must be sent from the customer’s registered email address to support@winclash.com. Implementation and increases in limits will be processed diligently; however, any request to remove or reduce limitations will be honored only after a seven-day cooling-off period following your request.

You cannot transfer, sell, or pledge your account to another person. This prohibition includes the transfer of any assets of value, including but not limited to ownership of accounts, winnings, deposits, bets, rights, and/or claims in connection with these assets, whether legal, commercial, or otherwise. The prohibition also includes, but is not limited to, encumbrance, pledging, assigning, usufruct, trading, brokering, hypothecation, and/or gifting in cooperation with a fiduciary or any third party, company, natural or legal individual, foundation, or association, in any manner.

Should you wish to close your account with us, please send an email from your registered email address to support@winclash.com.

6. Deposit of Funds

You may deposit funds into your account using any of the methods listed on our website. All deposits should be made in the same currency as your account. Any deposits made in a different currency will be converted using the daily exchange rate obtained from www.oanda.com or at our bank’s prevailing exchange rate, after which your account will be credited accordingly.

Fees and charges may apply to customer deposits and withdrawals. Details of fees and charges can be found here: https://winclash.com/account?q=deposit. You are responsible for any bank charges that you may incur when depositing funds with us. Exceptions to this rule are outlined on our "Payment Options" pages

WinClash is not a financial institution and uses third-party electronic payment processors to handle credit and debit card deposits. These transactions are not processed directly by us. If you deposit funds using a credit or debit card, your account will only be credited if we receive an approval and authorization code from the payment issuing institution. If the card issuer does not provide such authorization, your account will not be credited with those funds.

Your funds are deposited and held in the respective client account based on the currency of your account.

We are not a financial institution, and you will not be entitled to any interest on outstanding account balances. Any interest accrued on client accounts will be paid to us.

Funds originating from illicit means must not be deposited with us.

7. Withdrawal of Funds

You may withdraw any or all of your account balance within the transaction limits as shown on the website here:https://winclash.com/account?q=withdraw.

All withdrawals must be made in the currency of your account, unless otherwise stipulated by us.

We reserve the right to request documentation for identity verification prior to processing any withdrawals from your account. We also reserve the right to request this documentation at any time during the course of your relationship with us.

All withdrawals must be made to the original debit card, credit card, bank account, or payment method used to deposit funds into your WinClash account. At our discretion, we may allow you to withdraw to a payment method that was not used for your original deposit, subject to additional security checks.

If you wish to withdraw funds but your account is inaccessible, dormant, locked, or closed, please contact our Customer Service Department at https://winclash.com

8. Payment Transactions and Processors

You are fully responsible for paying all amounts owed to us. You must make all payments to us in good faith and not attempt to reverse a payment or take any action that would cause such payment to be reversed by a third party in order to avoid a legitimately incurred liability. You will reimburse us for any chargebacks, denials, or reversals of payment you initiate, as well as any loss suffered by us as a result. We also reserve the right to impose an administration fee, or its currency equivalent, for each chargeback, denial, or reversal of payment you initiate.

We reserve the right to use third-party electronic payment processors and/or merchant banks to process payments made by you, and you agree to be bound by their terms and conditions, provided these terms are made available to you and do not conflict with our terms.

All transactions made on our site may be monitored to prevent money laundering or terrorism financing activities. Suspicious transactions will be reported to the relevant authority based on the jurisdiction governing the transaction.

9. Errors

In the event of an error or malfunction of our system or processes, all bets are rendered void. You are obligated to inform us immediately upon becoming aware of any error with the service. In the event of communication, system errors, bugs, or viruses occurring in connection with the service and/or payments made to you as a result of a defect or issue in the service, we will not be liable to you or any third party for any direct or indirect costs, expenses, losses, or claims arising from such errors. We reserve the right to void all affected games/bets and take any other action to correct such errors.

In the event of a casino system malfunction or disconnection issues, all bets are rendered void. If such an error or any system failure or game error results in an issue with odds calculation, charges, fees, rake, bonuses, payouts, or currency conversions, or any other casino system malfunction (the “Casino Error”), we reserve the right to declare null and void any wagers or bets affected by the Casino Error and to take any funds from your account relating to those bets or wagers.

We make every effort to ensure that we do not make errors in posting lines. However, if, due to human error or system issues, a bet is accepted at odds that are materially different from those available in the general market at the time the bet was placed, or if the odds are clearly incorrect based on the probability of the event, we reserve the right to cancel or void that wager, or to cancel or void any wager made after an event has started.

We have the right to recover from you any amount overpaid and to adjust your account to rectify any mistakes. Examples of such mistakes include incorrect prices or an incorrect event result entry. If there are insufficient funds in your account, we may demand that you pay us the relevant outstanding amount for any erroneous bets or wagers. Accordingly, we reserve the right to cancel, reduce, or delete any pending bets, whether placed with funds resulting from the error or not.

10. General Rules

If a sport-specific rule contradicts a general rule, the general rule will not apply.

The winner of an event will be determined on the date the event is settled. We do not recognize protested or overturned decisions for wagering purposes. The result of an event suspended after the start of the competition will be decided according to the wagering rules specified by us for that sport.

All results posted shall be final after 72 hours, and no queries will be entertained after that period. Within 72 hours after results are posted, the company will only reset or correct results due to human error, system error, or mistakes made by the results source.

Minimum and maximum wager amounts on all sporting events will be determined by us and are subject to change without prior written notice. We also reserve the right to adjust limits on individual accounts.

11. Communications and Notices

All communications and notices to be given under these terms by you to us shall be sent to support@winclash.com .

All communications and notices to be given under these terms by us to you shall, unless otherwise specified, be posted on the website and/or sent to the registered email address we hold on our system for the relevant customer. The method of such communication shall be at our sole discretion.

All communications and notices to be given under these terms by either you or us shall be in writing in the English language when the service is not operated by WinClash and must be sent to and from the registered email address in your account.

12. Matters Beyond Our Control

We cannot be held liable for any failure or delay in providing the service due to an event of force majeure that could reasonably be considered outside our control despite our execution of reasonable preventative measures. Such events include, but are not limited to, acts of God, trade or labor disputes, power outages, acts or failures by any government or authority, obstruction or failure of telecommunication services, or any other delay or failure caused by a third party. We will not be liable for any resulting loss or damage that you may suffer. In such an event, we reserve the right to cancel or suspend the service without incurring any liability.

13. Liability

To the extent permitted by applicable law, we will not compensate you for any reasonably foreseeable loss or damage (either direct or indirect) you may suffer if we fail to carry out our obligations under these terms, unless we breach any duties imposed on us by law (including causing death or personal injury through negligence). In such cases, we shall not be liable if the failure is attributed to:

• (I) Your own fault.
• (II) A third party unconnected with our performance of these terms (for example, issues with communications networks, congestion, connectivity, or the performance of your computer equipment).
• (III) Any other events that neither we nor our suppliers could have foreseen or prevented, even with reasonable care. As this service is for consumer use only, we will not be liable for any business losses.

  In the event that we are held liable for any event under these terms, our total aggregate liability to you shall not exceed:

• (A) The value of the bets and/or wagers you placed via your account in respect of the relevant bet/wager or product that caused the liability. We strongly recommend that you (i) verify the suitability and compatibility of the service with your computer equipment before use, and (ii) take reasonable precautions, such as installing anti-virus software, to protect yourself from harmful programs or devices.

14. Gambling By Those Under Age

If we suspect that you are, or receive notification that you were, under 18 years of age (or below the age of majority as stipulated in the laws of your jurisdiction) when you placed any bets, your account will be suspended to prevent further betting or withdrawals. We will investigate the matter, including whether you have been betting on behalf of a person underage. If it is found that:

• (a). You are or were under 18 years old or below the legal age for betting in your jurisdiction at the time of your bet, or
• (b). You have been betting on behalf of someone underage,
then:
• I. All winnings currently or due to be credited to your account will be retained.
• II. All winnings obtained from underage betting must be returned to us on demand. If you fail to comply, we will seek to recover all costs associated with the recovery of such funds.
• III. Any money deposited into your account, excluding winnings, will be refunded.

This condition also applies if you are over 18 but placed bets in a jurisdiction where the legal minimum age for betting is higher than 18.

In the event we suspect you are in breach of this clause or attempting to circumvent it fraudulently, we reserve the right to take any necessary action to investigate, including notifying the relevant law enforcement authorities.

15. Anti Money-Laundering and KYC Policy

It is the policy of WinClash to actively prevent the use of our services for financial crimes, money laundering, and terrorist financing.

Strict compliance with all applicable regulations protects the senior management and staff from legal and regulatory risks and helps preserve the reputation of WinClash against the damage caused by involvement in money laundering and terrorist financing.

To achieve these objectives, it is the policy of WinClash that:

• Every staff member must meet their obligations according to their role and responsibilities.

• Commercial considerations cannot take precedence over WinClash's anti-money laundering commitment.

• A Money Laundering Reporting Officer/Nominated Officer (MLRO) and a deputy will be appointed to oversee compliance. The deputy will be the CEO.

• WinClash will strictly comply with all applicable AML/CFT rules and regulations, with a focus on:

•     ◦   Creating a culture of compliance.
•     ◦   Ensuring customer identities are verified appropriately.
•     ◦   Implementing "Know Your Customer" (KYC) procedures.
•     ◦   Ensuring staff are trained on legal obligations and to report suspicious activities.
•     ◦   Conducting ongoing monitoring of customer relationships and transactions.

Our policies, procedures, and internal controls are designed to ensure compliance with all relevant regulations, and we will review and update them regularly to keep pace with changes in regulations and business operations.

• 15.1 Money Laundering and Terrorism Financing

Money laundering refers to:

• I. The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property, or of assisting any person involved in the commission of such an activity to evade the legal consequences of that person’s actions.
• II. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity.
• III. The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity.
• IV. Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the actions referred to in points (I), (II), and (III).

Money laundering shall be regarded as such even if the activities that generated the property to be laundered were carried out in the territory of another Member State or in a third country.

Terrorism financing refers to the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, to carry out any terrorist act.

• 15.2 Organization of the AML/CFT Function

Terrorism financing means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any terrorist act.

• 15.2.1 Senior Management

Senior management is responsible for the overall compliance policy of WinClash, ensuring that adequate resources are provided for the proper training of staff and the implementation of risk systems. This includes computer software to assist in oversight. Senior management will receive and consider monthly compliance reports sent by the MLRO and authorize changes based on the recommendations, if required.

Senior management consists of the Board of Directors, the Executive Management Committee, and the MLRO.

• 15.2.2 Staff

Staff are responsible for understanding the AML Compliance Policy and their respective responsibilities. They must ensure company procedures are adhered to and obtain all documentary evidence as outlined within the manual. Staff are also required to report all suspicious and unusual activity to the MLRO.

• 15.3 Compliance Policies and Procedures
• 15.3.1 The Risk-Based Approach

In the context of money laundering and terrorist financing, a risk-based approach covers the following:

• The risk assessment of customer relationships and business activities.

• The risk mitigation to implement controls to handle identified risks.

• Keeping customer identification, beneficial ownership, and business relationship information up to date.

• Ongoing monitoring of business relationships and transactions.

Existing regulatory obligations, such as customer identification, are a minimum baseline requirement. Where enhanced due diligence is appropriate, a key principle of the risk-based approach is to focus resources where they are most needed to manage risks within our tolerance level.

• 15.3.2 Risk Mitigation

Risk mitigation involves implementing controls to limit the potential risks of money laundering and terrorist financing identified in the risk assessment, ensuring that the risks remain within the tolerance level. When the risk assessment determines that the risk is high for money laundering or terrorist financing, WinClash will develop risk mitigation strategies and apply them.

In all situations, risk mitigation controls and measures include:

• Focusing on operations (products and services, customers and business relationships, geographic locations, and any other relevant factors) that are more vulnerable to abuse by money launderers and criminals.

• Informing senior management of compliance initiatives, identified compliance deficiencies, corrective actions taken, and suspicious transaction reports filed.

• Ensuring program continuity despite changes in management, employees, or structure.

• Meeting all regulatory record-keeping and reporting requirements, as well as ensuring timely updates in response to changes in requirements.

• 15.3.3 Risk Assessment

WinClash is required to and will analyze potential threats and vulnerabilities to money laundering and terrorist financing to which the business may be exposed through a risk assessment.

The risk assessment will document and consider the following:

• Products, services, and delivery channels

• Geographic locations and areas of operation

• Customers

The risk assessment may identify high-risk situations for which additional risk mitigation controls and monitoring may be required. The risk assessment is not static and will change over time.

When a customer is identified as high-risk, they are subject to more frequent ongoing monitoring and updating of customer identification information, as well as other appropriate enhanced measures.

WinClash shall perform an initial risk assessment at the beginning of a new customer relationship and on an ongoing basis for existing customers.

• 15.4 Client and Business Risk
• 15.4.1 The Risk-Based Approach

WinClash will identify products and services, or combinations of them, that may pose an elevated risk of money laundering or terrorist financing. For example, products and services that support the movement and conversion of assets into, through, and out of the financial system pose a high risk. Certain services have also been identified by financial regulators, governmental authorities, or other credible sources as being potentially high-risk for money laundering or terrorist financing.

• Wire transactions

• Transactions involving third parties

• Non-face-to-face business relationships

• 15.4.2 Geographic Locations and Areas of Operation

Certain geographic locations pose an elevated risk for money laundering and terrorist financing. These have been described by the FATF and other resources such as Transparency International.

Clients from, or identified as linked to, these countries will be regarded as high-risk:

• Any country subject to sanctions, embargoes, or similar measures

• Any country identified by credible sources as providing funding or support for terrorist activities or having designated terrorist organizations operating within their country

• Any country known to be a tax haven, source of narcotics, or engaged in other significant criminal activity

• Any country identified by the Financial Action Task Force (FATF) as non-cooperative in the fight against money laundering or terrorist financing or subject to a FATF statement

• Any country identified by credible sources as lacking appropriate money laundering or terrorist financing laws and regulations or as having significant levels of corruption

WinClash does not do business with or provide services to anyone in countries belonging to a list of select nations subject to comprehensive international sanctions.

• 15.4.3 Customer Relationships

The risk assessment requires knowing your customers (“KYC”). This is not limited to identification or record-keeping; it also involves understanding the customers, including their activities, transaction patterns, and how they operate.

Examples of the factors considered include:

• How long we have known the customer and had a business relationship.

• Customers wanting to carry out large transactions

• Customers with regulatory or enforcement issues

• Customers with multiple online complaints

• Customers whose identification is difficult to verify

• Customers who are politically exposed/p>

Each customer is risk-rated as either posing a low, medium, or high risk of money laundering and/or terrorist financing. The rating given at the beginning of the business relationship may be adjusted after reassessment and may change over time. The level of customer due diligence will vary depending on the risk rating of the customer at the start of the relationship and as it changes. For all high-risk clients, enhanced due diligence is applied immediately.

• 15.4.4 Regulatory risk

Regulatory risk refers to the failure to meet our obligations under applicable legislation. Examples of breaches of regulatory obligations include:

• Failure to properly conduct customer identification

• Inadequate staff training

• Lack of an anti-money laundering and anti-terrorist financing (AML/CFT) program

• Failure to report suspicious transactions

• Absence of an MLRO

• Failure to maintain complete customer records

• 15.4.5 Compliance Training

WinClash has a training program for all relevant employees and other individuals who act on behalf of the company. The goal of this training is to ensure that those who have contact with customers, observe customer transaction activity, or handle funds in any way understand the reporting, customer identification, and record-keeping requirements.

All new employees of WinClash are required to complete anti-money laundering and terrorist financing compliance training within their first three months of employment. For customer-facing staff, training is delivered before they engage with customers.

Training is currently conducted through a customized course, delivered electronically via a learning management system. The training program is reviewed and updated by the MLRO to reflect changes in requirements. The compliance training includes a test that all participants must pass in order to consider their training complete.

To ensure employee training remains up to date, all existing employees will receive follow-up training on new and existing AML and regulatory requirements on a regular basis (at least within one year of their last training). If the online training test results show that a staff member does not fully understand the training material, WinClash will ensure the staff member receives specialized one-on- one training to better understand the material.

An employee log of assigned and completed training materials is kept by the MLRO and the Human Resources department for administrative purposes. These records are retained for a period of five years.

Compliance training is adjusted according to the employee’s role within the company. The MLRO will review functions and arrange suitable, customized training where necessary.

At a minimum, our training will include:

15.5 Minimum standards – KYC POLICY

WinClash has established standards regarding Know-Your-Customer (“KYC”) requirements. These standards mandate due diligence on each prospective customer before entering into a business relationship. This includes the identification and verification of the customer's identity and, as applicable, their representatives and beneficial owners, based on documents, data, or information obtained from a reliable and independent source, in compliance with domestic and European AML/CFT legislation and regulations.

The interpretation of the KYC principle begins with the identification of the customer through the necessary identification documents.

That identification, along with other gathered information, enables the application of the Customer Acceptance Policy.

In addition to these objective criteria, there are subjective elements that may raise suspicions regarding a customer, to which particular attention should be paid.

Finally, since KYC involves dynamic data, not just static data, it requires ongoing follow-up and monitoring of the customer throughout the relationship.

• 15.5.1 Customer Identification and Verification (KYC)

The formal identification of customers upon entering into commercial relations is a vital element, both for regulations related to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

• Each customer (i.e., each individual person and/or each person involved in the case of a legal entity) must be identified using original supporting documents.

• These documents will be recorded in a centralized system.

• 15.5.2 Risk Profile Calculation

To assist in determining the level of AML/CFT due diligence to be exercised with regard to the customer, a “compliance” risk profile is calculated initially upon entry into the relationship (low, medium, high) and is then recalculated daily.

• 15.5.3 Customer Acceptance Policy
• 15.5.3.1 Customer Identification

Client identification is intended to confirm the existence and identity of the individual with whom WinClash has a business relationship, as well as to obtain supporting identity information. This includes measures to:

• Confirm the existence of the individual through identification documents.

• Conduct due diligence into the identity of the customer, including:

•     ◦ Cross-referencing customer names against government watch lists.
•     ◦ Determining whether the customers are politically exposed persons (PEPs).
•     ◦ Determining whether any third parties are involved.
•     ◦ Reviewing relevant publicly available information on the customer (e.g., adverse media, social media).
•     ◦ Reviewing their background and reputation.
•     ◦ Keeping records of all information and documents obtained.
• 15.5.3.2 Identifying Information for Customers

This section outlines the standard identification requirements for individuals who have entered into a business relationship with WinClash. This outline is likely sufficient for most situations. However, if the customer is assessed as presenting a higher money laundering or terrorist financing risk, in line with our identified risk matrix, WinClash requires additional identity information and increases the level of verification accordingly.

Where the result of the standard verification check raises concerns or uncertainty about the identity, the number of matches required to reasonably satisfy the individual's identity will increase. Any concerns must be reported to the MLRO.

If a customer is unable to produce a primary ID, the reasons for this should be noted, and they may not be able to maintain an account.

All documentary evidence must be recent:

• Passports and drivers’ licenses should be valid and not expired.

• Utility bills should be dated within the last 3 months.

In terms of beneficial ownership, we will ask every customer whether they are acting in their own capacity or on behalf of another person. If they are acting for another person, we will require details of such.

Sources of Evidence

Proof of Identity - Acceptable Photo Identity:

• Valid passport.

• Valid photo card driving license (full or provisional).

• National identity card.

Proof of Identity - Acceptable Non-Photo Evidence of Identity:

Documents issued by a government department, incorporating the person’s name and residential address or date of birth, such as:

• Court appointment documents (e.g., grant of probate, bankruptcy).

• Current council tax demand letter or statement.

• Recent (within the last 3 months) bank statements or credit/debit card statements issued by a regulated financial institution in the UK, EU, or an equivalent jurisdiction.

• A recent utility bill (gas, water, electricity, telephone); it must be a bill or statement of account (not correspondence). Statements printed from the internet are not acceptable on their own (a secondary check will be required, such as a reference to a telephone directory, including an online directory).

• A solicitor’s letter confirming a recent house purchase or land sale at the previous address.

When accepting evidence of identity from a customer, it is important that sufficient checks are made on the evidence provided to satisfy us of the customer’s identity, and that a record of the checks is kept. This will be done by the MLRO or under the supervision of the MLRO.

Usual Checks on Photo ID May Include:

• Likeness to the customer.

• Does the date of birth on the evidence match the apparent age of the customer?

• Is the ID valid?

• Is the spelling of names consistent with other documents provided by the customer?

Checks on Secondary Evidence of ID May Include:

• Do the addresses match the address given on the photo ID?

• Does the name on the secondary evidence match the name on the photo ID?

• 15.5.3.3 Identifying Information for Customers

Verification of the customer's identity occurs when the customer reaches the equivalent of a €2,000 threshold or if the player is considered a high-risk player upon registration. The main trigger for identity verification is a single transaction (or smaller, linked transactions) that reach or exceed the equivalent of €2,000, either at the deposit or withdrawal stage. For example, transactions will be considered linked when they are carried out by the same customer during a single session on the WinClash website or if they occur within 48 hours.

In all cases, the customer will receive a notification to upload identity verification documents as listed above. Each document provided by customers to WinClash is manually checked by dedicated staff.

Further events that may trigger the identity verification process include:

• When a customer requests a withdrawal to a different account than the one used to make a deposit (e.g., because certain payment service providers do not support incoming payments or for other reasons). In such cases, the withdrawal request will be immediately deducted from the customer’s account; however, it will not be processed until the customer’s identity has been verified to ensure the funds are going to the correct person.

• When a customer makes multiple deposits within a short timeframe (five or more deposits in one hour).

• When staff identifies suspicious deposit patterns, or when several payment cards are used (three or more different payment methods within one week).

• When the registration country and IP address do not match. In such cases, the player account may not be blocked, and the player may still make deposits and play games; however, no withdrawals will be allowed until verification has been completed.

• When a deposit exceeds the equivalent of €5,000.

Copies of all documents used for identification will be kept.

• 15.5.3.4 Additional Documents

Additional documents may be requested from customers to substantiate their activities or to better understand their patterns:

• Proof of Bank Account: This may be a screenshot or a copy of the bank statement showing the customer’s name, IBAN, and the name of the bank (for instances when a customer requests a withdrawal to a bank account).

• Proof of Payment Card: This may be a photo or copy of the front side of the card or a bank statement that includes both the card details and the customer's name (for instances when suspicious deposit patterns are identified).

• To protect the customer’s card data, WinClash informs them that they may obfuscate some of the card details; however, the customer’s name, as well as the first and last four digits of the card number, must be visible.

• Bank Statements and Payslips: These may be requested from customers exhibiting potentially problematic gambling patterns or when external information available on the customer does not validate the amounts being gambled. In such cases, WinClash would ask high-volume customers for documents to support the funds being spent on gambling.

• 15.5.3.5 Mitigation of Impersonation Risk

Various additional customer identity checks are permitted based on a risk-based approach. These checks may include:

• Requiring the first payment to be carried out through an account in the customer’s name with an EU/EEA-regulated credit institution or one from an equivalent jurisdiction.

• Verifying additional aspects of the customer’s identity or their electronic ‘footprint’.

• Contacting the customer by phone prior to opening the account, using a verified home or business number (either electronically or otherwise), or calling the customer before further transactions are permitted, to verify additional aspects of personal identity information provided during account setup.

• 15.5.3.6 Keeping Information Up-to-Date

Once the identity of a customer has been confirmed, it does not need to be confirmed again. However, if there is any doubt about the information held, that identification will be re-obtained, including the identification of the customer.

WinClash may review the customer's documentation and update it as appropriate. Any changes to identification, such as a change of name, will require new documents to be obtained.

16. Fraud

We will seek criminal and contractual sanctions against any customer involved in fraud, dishonesty, or criminal acts. We will withhold payment to any customer where such activities are suspected. The customer shall indemnify and be liable to pay us on demand for all costs, charges, or losses sustained or incurred by us (including direct, indirect, or consequential losses, loss of profit, loss of business, and loss of reputation) arising directly or indirectly from the customer’s fraud, dishonesty, or criminal acts.

17. Responsible Gaming Policy

WinClash is committed to promoting responsible wagering among its customers, as well as raising awareness of problem gambling and improving prevention, intervention, and treatment efforts.

WinClash’s Responsible Gambling Policy outlines its commitment to minimizing the negative effects of problem gambling and promoting responsible gambling practices.

WinClash supports the engagement of online gamblers, offering them a wide range of games and entertainment. We also take responsibility for our product lineup.

The aim of WinClash is to provide the world’s safest and most innovative gaming platform for adults. The offered products are clear and safe, allowing each user to play within their financial means while receiving the highest quality service. Integrity, fairness, and reliability are the guiding principles of WinClash ’s operations. It is therefore essential that WinClash strives to avoid and reduce the problems that may arise from gambling participation, particularly in cases of excessive play. At the same time, it is important to respect the rights of those who engage in games of chance as a reasonable form of entertainment.

Responsible gaming at WinClash is based on three fundamental principles: player security, game security, and protection against gambling addiction. Together with research institutes, associations, and therapy institutions, we work to create a responsible, secure, and reliable framework for online gaming.

Player Security

We take responsibility for the security of our players. Player protection is based on prohibiting minors from participating in games and ensuring privacy, which involves the responsible handling of personal data and payments. Fairness and the random nature of the products offered are closely monitored by independent organizations. Marketing communication is also aimed at player protection; we promise only what players can reasonably expect in our transparent approach.

Protection Against Gambling Addiction: Research, Prevention, and Intervention

The majority of users who engage in sports betting, casino games, and other gaming activities play in moderation for entertainment. However, certain habits and behaviours (such as shopping, playing sports, eating, or consuming alcohol) that are typically considered normal and harmless can become addictive for some people and cause problems. Similarly, sports betting and gambling can lead to issues for a small group of customers.

Customers with gambling addiction are prohibited from further participation in the gaming offerings. Subsequently, they are provided with contacts for organizations where they can receive professional advice and support.

Self-responsibility is the most sustainable form of prevention.

The basic principle promoted by WinClash is that the final decision and responsibility regarding whether to play or not, and how much money to spend on gambling, should lie with the customer.

The self-responsibility of the customer is, therefore, the most effective form of protection against addiction. WinClash sees its role in assisting customers by providing transparent products, complete information, and maintaining a clear code of conduct.

Protection of Minors

WinClash does not allow minors (persons under the age of 18) to participate in games or make bets. Therefore, confirmation of reaching the age of majority and confirmation of date of birth are mandatory during registration. WinClash takes the issue of minors participating in games and betting very seriously. To offer the best possible protection for minors, we also rely on the support of parents and caregivers. Please keep your account access details (user ID and password) in a safe place.

Furthermore, we recommend installing filtering software. This software will allow you to restrict access to internet resources that are inappropriate for children and teenagers.

Responsibility Towards Problematic Gambling

WinClash offers a variety of games and bets, which are forms of entertainment for the majority of customers. At the same time, the company takes responsibility for its customers by providing support and tools to maintain a secure and enjoyable environment while acknowledging the associated risks.

Clients who struggle to assess risks, recognize their limits, or those who suffer from gambling addiction are unable to enjoy our product lineup responsibly and perceive it as a form of entertainment. WinClash takes responsibility for such users by blocking their access to its products for their own protection.

Get Informed About the Main Issues

Most people play for enjoyment. Moderate participation within one’s financial means is entirely acceptable. However, for a small percentage of people, gambling is not just a form of entertainment; it becomes a serious issue that must be addressed.

What is Problematic Gambling Behaviour?

Problematic gambling behaviour is considered to be any behaviour that interferes with a person’s lifestyle, work, financial position, or health, or that of their family. Extended participation in gambling is harmful to such individuals and may lead to negative consequences.

In 1980, pathological gambling was officially recognized and classified as a psychological disorder in the international classification system DSM-IV and ICD-10. It is defined as a long-term, recurring, and increasingly compulsive inclination toward gambling, despite existing negative personal and social consequences, such as debt, family breakdown, and career setbacks.

When Should Gambling Behaviour Be Considered an Addiction?

It is important to note that only experts can diagnose gambling addiction. The material presented on this webpage is intended to help individuals assess their gambling behaviour.

The special risk of non-substance addictions is that it is difficult to distinguish between pleasure and addiction. However, there are some diagnostic signals that may indicate the presence of a gambling problem. If at least five of the following symptoms are present, the likelihood of severe dependence is high:

1. The player is completely consumed by gambling, with all thoughts focused on the game.

2. The bet amount increases over time.

3. Attempts to quit or control gambling are unsuccessful.

4. When trying to limit gambling, the person experiences irritation and disappointment.

5. Gambling is used as a way to escape from problems or discomfort.

6. The player tries to recover lost money.

7. The player lies about their gambling behaviour.

8. The player commits illegal acts.

9. The player damages or breaks relationships with family and colleagues.

10. The player borrows money to continue gambling.

Rules for Responsible Gaming

By following the rules below, you can enjoy gaming without anxiety:

1. Only start playing when you are calm and focused.

2. Take regular breaks.

3. Predefine the maximum amount you can spend on gaming each month.

4. Once you set a limit, do not exceed it.

5. Before playing, define the maximum amount of winnings at which you will stop playing.

6. Determine the amount you can afford to lose beforehand.

7. Do not play under the influence of alcohol or drugs.

8. Do not play when you are in a depressed state

18. Intellectual Property

We trade as WinClash , and the WinClash name and logo are registered trademarks. Any unauthorized use of our trademark and logo may result in legal action being taken against you.

The URL https://winclash.com is owned by us, and no unauthorized use of the URL is permitted on another website or digital platform without our prior written consent.

As between us and you, we are the sole owners of the rights in and to the service, our technology, software, and business systems (the "Systems"), as well as our odds.

I. You must not use your personal profile for your own commercial gain (such as selling your status update to an advertiser); and

II. When selecting a nickname for your account, we reserve the right to remove or reclaim it if we believe it is appropriate.

You may not use our URL, trademarks, trade names and/or trade dress, or logos (the "Marks") and/or our odds in connection with any product or service that is not ours, that in any manner is likely to cause confusion among customers or the public, or that disparages us.

Except as expressly provided in these Terms, we and our licensors do not grant you any express or implied rights, licenses, titles, or interests in or to the Systems or the Marks, and all such rights, licenses, titles, and interests are specifically retained by us and our licensors. You agree not to use any automatic or manual device to monitor or copy web pages or content within the Service. Any unauthorized use or reproduction may result in legal action being taken against you.

19. Your License

Subject to these terms and your compliance with them, we grant you a non-exclusive, limited, non-transferable, and non-sublicensable license to access and use the Service for your personal, non-commercial purposes only. Our license to you terminates if our agreement with you under these terms ends.

Except in respect of your own content, you may not under any circumstances modify, publish, transmit, transfer, sell, reproduce, upload, post, distribute, perform, display, create derivative works from, or in any other manner exploit the Service and/or any of the content thereon, or the software contained therein, except as we expressly permit in these terms or otherwise on the website. No information or content on the Service, or made available to you in connection with the Service, may be modified or altered, merged with other data, or published in any form, including, for example, screen or database scraping, and any other activity intended to collect, store, reorganize, or manipulate such information or content.

Any non-compliance by you with this clause may also violate our or third parties’ intellectual property and other proprietary rights, which may subject you to civil liability and/or criminal prosecution.

20. Your Conduct and Safety

We want you to enjoy the Service. However, for your protection and that of all customers, posting any content on the Service, as well as conduct in connection therewith and/or the Service, which is in any way unlawful, inappropriate, or undesirable, is strictly prohibited. If you engage in prohibited behaviour, or if we determine, in our sole discretion, that you are engaging in prohibited behaviour, your access to the Service may be terminated immediately without notice to you.

Legal action may be taken against you by another customer, third parties, enforcement authorities, and/or us, with respect to your engagement in prohibited behaviour.

Prohibited behaviour includes, but is not limited to, accessing or using the Service to:

I. Promote or share information that you know is false, misleading, or unlawful;

II. Conduct any unlawful or illegal activity, such as but not limited to, any activity that furthers or promotes criminal activity, provides instructional information about making or buying weapons, violates another customer’s or any third party’s privacy or rights, or creates or spreads computer viruses;

III. Harm minors in any way;

IV. Transmit or make available any content that is unlawful, harmful, threatening, abusive, tortious, defamatory, vulgar, obscene, lewd, violent, hateful, or racially, ethnically, or otherwise objectionable;

V. Transmit or make available any content that you do not have a right to make available under any law or contractual or fiduciary relationship, including content that infringes a third party’s copyright, trademark, or other intellectual property and proprietary rights;

VI. Transmit or make available any content or material containing software viruses or other programming codes designed to interrupt, destroy, or alter the functionality of the Service, its presentation, or any other website, computer software, or hardware;

VII. Interfere with, disrupt, or reverse-engineer the Service in any manner, including intercepting, emulating, or redirecting communication protocols, creating or using cheats, mods, or hacks, or using any software to modify the Service or collect information;

VIII. Retrieve or index any information from the Service using automated mechanisms such as robots or spiders;

IX. Engage in any activity or action that, in our sole discretion, may result in another customer being defrauded or scammed;

X. Transmit or make available any unsolicited or unauthorized advertising or mass mailing, including but not limited to, junk mail, instant messaging, spam, chain letters, pyramid schemes, or other solicitations;

XI. Create WinClash accounts by automated means or under false or fraudulent pretences;

XII. Impersonate another customer or third party;

XIII. Engage in any other act or behaviour that we reasonably consider to be contrary to our business principles.

The list above is not exhaustive and may be modified by us at any time. If you become aware of misuse of the Service, please contact us through the “Contact Us” section of the website. We reserve the right to investigate and take appropriate action, including deleting the Customer’s posts and/or terminating their account, and taking action against any Customer or third party who directly or indirectly engages in Prohibited Behaviour, with or without notice.

21. Links to Other Websites

The Service may contain links to third-party websites that are not maintained by us and over which we have no control. These links are provided solely for convenience and are not investigated, monitored, or checked for accuracy by us. Links to such websites do not imply any endorsement or affiliation with those websites or their owners. We are not responsible for the availability, accuracy, completeness, accessibility, or usefulness of these sites. We recommend taking the usual precautions when visiting new websites, including reviewing their privacy policies and terms of use.

22. Self-Exclusion

If you believe you are at risk of developing a gambling problem, please consider using self- exclusion to prevent gambling with WinClash for a specified period (6 months, 1 year, 2 years, 5 years, or permanently).

During self-exclusion, you will not be able to use your account for betting, although you can still log in and withdraw any remaining balance. WinClash will make every effort to detect and close any new accounts you open.

We also recommend removing WinClash apps, downloads, and social media links and considering software that blocks gambling websites.

You can self-exclude in the “My Gambling Controls” section of Members by selecting “Self- Exclusion.” Alternatively, contact our customer care team for assistance.

If you self-exclude from WinClash , we strongly recommend that you self-exclude from all other gambling operators.

23. Complaints

If you have any concerns or questions regarding these terms, contact our Customer Service Department at support@winclash.com

Any dispute related to the sports betting product or casino product should be emailed to support@winclash.com. The casino rules can be accessed from within the casino games.

24. Registration and Account Security

Customers must provide real names and information when registering and maintaining their accounts. You must not:

I. Provide false personal information or create an account for anyone else; II. Use your personal profile for commercial gain; III. Select a nickname that we reserve the right to remove or reclaim.

25. Assignment

You may not assign these terms or any rights or obligations without our prior written consent, which will not be unreasonably withheld. We may assign our rights and obligations without your consent.

26. Severability

If any provision of these terms is deemed unenforceable, the relevant provision will be modified to allow enforcement in line with the original intent. The validity of the remaining provisions will not be affected.

27. Breach of These Terms

We may suspend or terminate your account and refuse the Service if, in our reasonable opinion, you breach any material term of these Terms. We will promptly notify you of any action taken.

28. General Provisions

Term of Agreement: These terms remain in effect while you access or use the Service or are a customer of WinClash

Gender: Words importing the singular number include the plural and vice versa; words in the masculine gender include the feminine and neuter genders, and words importing persons include individuals, partnerships, associations, trusts, unincorporated organizations, and corporations.

Waiver: No waiver by us of any breach of these terms will be effective unless made in writing and signed by us.

Headings: Headings are for convenience only and do not affect the interpretation of these terms.

Acknowledgment: By accessing or using the Service, you acknowledge you have read, understood, and agreed to these terms.

Language: In case of discrepancy between the English version and other translations, the English version will prevail.

Entire agreement: These Terms constitute the entire agreement between you and us with respect to your access to and use of the Service, and supersedes all other prior agreements and communications, whether oral or written with respect to the subject matter hereof.

Betting Rules: Any dispute related to sports betting should be emailed to support@winclash.com

Casino Rules: Any dispute related to the casino product should be emailed to support@winclash.com. Full casino rules are available within the casino games.