Política de PLD/AML

Anti-Money Laundering (AML) Policy

 

1. INTRODUCTION

Privacy is a digital platform that mediates the relationship between Content Creators and Subscribers, allowing the availability and monetization of digital content, including content classified as adult, whose access is restricted exclusively to people over 18 (eighteen) years of age.

As Privacy is an intermediary digital platform in the availability and monetization of digital content, in the exercise of such activity, financial transactions are carried out, which are processed by autonomous and independent payment institutions in favor of Privacy. For this reason, Privacy recognizes the importance of maintaining robust controls aimed at the prevention, detection and enforcement of activities potentially related to money laundering and terrorist financing.

This Policy establishes the regulatory framework, controls and procedures adopted by Privacy to mitigate money laundering and terrorist financing risks, in accordance with applicable laws and regulations.

2. PURPOSE

The purpose of this Policy is to establish clear and binding guidelines for the prevention, detection and restraint of suspicious money laundering and terrorist financing operations, ensuring the continuous monitoring of transactions and financial activities on the platform with a view to identifying atypical patterns or indicative of illicit activities.

To this end, the Policy structures Know Your Customer (KYC) procedures, comprising identity verification, transactional profile analysis and enhanced due diligence for higher-risk users, as well as defines internal obligations related to the reporting of suspicious activities to the competent authorities, in accordance with applicable legislation.

Through this instrument, Privacy seeks to mitigate legal, operational, and reputational risks arising from any links with illicit activities, while demonstrating its compliance with business partners, financial institutions, payment processors, and regulatory bodies, reaffirming its institutional commitment to the integrity of the platform and to national and international standards for the prevention of money laundering and terrorist financing.

3. SCOPE

This Policy applies to Content Creators, national and international, who earn financial values through the platform, subscribers who carry out financial transactions on the platform, as well as employees, partners, suppliers and service providers who act, directly or indirectly, in activities related to compliance, fraud prevention, payment processing and risk management, and to the internal areas responsible for compliance, fraud prevention, finance and information security.

Its provisions cover the entire life cycle of transactions and accounts held on the platform, from initial registration to eventual de-accreditation, including the monitoring, analysis and treatment procedures applicable at each stage. In this context, Privacy acts as an intermediary and, in this capacity, guides its internal compliance practices by strict compliance with the guidelines established by its payment solution providers, which are subject to the regulation and supervision of the Central Bank of Brazil and other regulatory entities under other jurisdictions, ensuring alignment with the regulatory standards applicable to the financial processing chain of which it is a part.

4. GUIDELINES

Privacy adopts a risk-based approach to the prevention of money laundering and terrorist financing, implementing controls proportional to the level of risk identified in its operations, user profiles and the jurisdictions involved.

4.1 KNOW YOUR CUSTOMER (KYC)

Privacy carries out procedures for identifying and verifying the identity of all users prior to the release of transactional functionalities, in accordance with its Accreditation Policy. The KYC process includes:

• Capture and validation of official document with photo;
• Proof of life (liveness detection) and biometric validation (face match);
• Documentscopy and data extraction by OCR;
• Confirmation of majority based on data extracted from the official document;
• Background check, including PEP (Politically Exposed Person) and national and international restrictive and sanctions lists;
• For Creators residing in Brazil: registration consultation with the Federal Revenue Service, verification of death registration.

4.2 TRANSACTION MONITORING

Privacy maintains systems for continuous monitoring of financial transactions, operating in an automated manner and complemented by specialized human analysis. The monitoring includes:

• Analysis of transactional patterns and identification of atypical behaviors, including transactions with values above the standard, unusual frequency, or incompatibility with the user's profile;
• Use of an anti-fraud tool that employs artificial intelligence, device and user behavioral analysis, verification of registration data and cross-referencing of multiple information for risk classification and mitigation;
• Statistical models developed by a data science team to detect behaviors indicative of financial fraud and money laundering, with automatic alert generation for the analysis table;
• Analysis of BINs (Bank Identification Numbers), elevated tickets and atypical behavior patterns in relation to the history of Creators and buyers.

The alerts generated are submitted to the dedicated team of fraud prevention analysts, who conduct an investigative process structured according to standard operating procedures. At the end of the investigation, each occurrence is submitted to risk classification, which may result in a ban of the user, continuous monitoring or release of the operation.

4.3 SANCTIONS SCREENING AND RESTRICTIVE LISTS

Privacy screens users against national and international sanctions lists, including:

• Sanctions lists issued by Brazilian government agencies;
• Lists of Politically Exposed Persons (PPE);
• Applicable international sanctions and restrictive lists.

The screening is carried out at the time of accreditation and updated periodically, and can be reprocessed at any time according to risk assessment. The identification of a positive match on any list triggers an in-depth review process and, as the case may be, may result in the registration being rejected, blocked or banned from the account.

4.4 RECORD KEEPING

Privacy keeps records of all financial transactions, identity verification (KYC) procedures, risk analysis and suspicious activity reports, for the period applicable by the regulation and legislation of each of the respective registries. Records include:

• Registration data and identity verification documentation;
• Transactional history of Creators and Subscribers;
• Pass, fail, and risk analysis logs;
• Logs of alerts generated and investigations performed.

4.5 SANCTIONS

Violation of this Policy may result in the application of measures that include, but are not limited to:

• Temporary retention of amounts eventually due;
• Platform ban;
• Adoption of other measures provided for in the Terms of Use and Internal Policies.

4.6 CONTROLS AND MONITORING

Privacy maintains:

• Auditable record of all verifications, analyses and decisions made under this Policy;
• Approval and disapproval logs of registrations and transactions;
• Continuous monitoring to identify later inconsistencies;
• Periodic reviews of controls, procedures and detection parameters;
• Continuous feedback of predictive models based on confirmed cases.

5. FINAL CONSIDERATIONS

Privacy reaffirms its commitment to the prevention of money laundering and terrorist financing, to maintaining a secure digital environment and to adopting robust compliance mechanisms.

The procedures described in this Policy are structured in alignment with international best practices and applicable regulatory principles, including, where applicable, the recommendations of the Financial Action Task Force (FATF).

This Policy will be reviewed periodically and whenever there are relevant changes in the regulatory, technological or operational environment.

Privacy – Anti-Money Laundering (AML) Policy