KYC & Sanctions Policy

Last updated: 31 July 2026

1. Purpose of This Policy

This KYC & Sanctions Policy explains the identity, payment, fraud-prevention and sanctions controls that may apply when a User accesses or uses ConSkins.

The purposes of these controls include:

• confirming that a User is eligible to use ConSkins;
• verifying the identity and age of a User where necessary;
• confirming ownership or authorised use of a Payment Method;
• preventing fraud, identity theft and Account misuse;
• identifying suspicious or unusual activity;
• preventing the use of ConSkins for money laundering, terrorist financing or sanctions evasion;
• complying with applicable laws and binding legal requirements;
• meeting reasonable requirements imposed by Payment Providers and other service providers; and
• protecting ConSkins, its Users and third parties.

This Policy forms part of the ConSkins Terms and Conditions.

2. Service Provider

The ConSkins service is operated by:

In this Policy, “ConSkins”, “we”, “us” and “our” mean CONDEO LTD.

3. Definitions

For the purposes of this Policy:

• “Account” means a registered ConSkins user account;
• “Balance” or “ConSkins Balance” means the internal account credit available for eligible purchases through ConSkins;
• “Digital Item” means a virtual in-game item available for purchase through ConSkins and capable of being transferred through Steam;
• “KYC” means identity, age, payment ownership and related verification checks that may be conducted in relation to a User;
• “Order” means a confirmed request to purchase a Digital Item using the ConSkins Balance;
• “Payment Method” means a payment card or another payment method available through the ConSkins payment interface;
• “Payment Provider” means an independent third party used to process payments, refunds, authentication and related services;
• “Restricted Jurisdiction” means a country, territory or region in which ConSkins does not provide all or part of the Service because of legal, sanctions, payment, security or operational restrictions;
• “Sanctions” means applicable financial, trade or economic restrictions imposed by the United Kingdom, United Nations or another authority whose requirements apply to ConSkins, a transaction or a service provider;
• “Sanctions List” means an applicable official list of designated or restricted individuals, entities, organisations, vessels or other persons;
• “Steam Account” means the Steam account linked to a User’s ConSkins Account;
• “Top-Up” means a payment made to add Cash-Funded Balance to an Account;
• “User”, “you” and “your” mean the individual accessing or using ConSkins.

4. Nature of This Policy

ConSkins is a digital item purchasing service and does not represent itself as a bank, deposit-taking institution, electronic money issuer or provider of general-purpose payment accounts.

This Policy does not mean that CONDEO LTD is claiming to be subject to every obligation applicable to banks, regulated payment institutions or other businesses within a formally supervised sector.

However, ConSkins may apply proportionate identity, payment, fraud-prevention and sanctions controls where reasonably necessary to:

• comply with applicable law;
• meet Payment Provider requirements;
• prevent criminal or abusive activity;
• investigate transactions;
• protect Users;
• manage legal and commercial risk; or
• enforce the Terms and Conditions.

The nature and extent of a check may vary according to the circumstances.

5. Age Requirement

ConSkins is available only to individuals who are at least 18 years old.

By creating an Account or using ConSkins, you confirm that you are at least 18.

ConSkins may request evidence of age where:

• the date of birth provided appears inconsistent;
• Account information suggests that the User may be under 18;
• a Payment Provider requires age verification;
• a transaction presents an increased risk;
• a complaint or report raises an age-related concern; or
• verification is otherwise reasonably necessary.

A User must not:

• provide a false date of birth;
• use another person’s identity to satisfy the age requirement;
• submit altered or false evidence of age;
• create an Account for a minor; or
• allow a minor to use the User’s Account.

An Account may be suspended or closed if the User is under 18 or does not complete a reasonable age-verification request.

6. Risk-Based Verification

Not every User will necessarily be required to complete the same verification process.

ConSkins may apply a risk-based approach and consider factors such as:

• the value of a Top-Up;
• the total value or frequency of transactions;
• the number of Payment Methods used;
• the age and history of the Account;
• the User’s country or region;
• inconsistencies in Account information;
• unusual device, network or location information;
• payment authentication results;
• repeated payment failures;
• previous refunds or Chargebacks;
• multiple related Accounts;
• suspected third-party payment activity;
• sanctions or legal risk;
• attempts to bypass transaction limits;
• unusual Steam Account activity; and
• information supplied by Payment Providers or fraud-prevention services.

A request for verification does not necessarily mean that ConSkins believes the User has acted unlawfully.

7. When Verification May Be Required

ConSkins or its service providers may request verification:

• during Account registration;
• before a Top-Up is accepted;
• after a Top-Up has been submitted;
• before Balance becomes available;
• before an Order is processed;
• before a Digital Item is delivered;
• before a refund is issued;
• before eligible unused Balance is returned following Account closure;
• when Account details are changed;
• when a new Payment Method is used;
• when suspicious activity is identified;
• when a Chargeback or unauthorised payment claim is made;
• when a Steam trade reversal occurs;
• when a Payment Provider requires verification;
• when required by law or a competent authority; or
• at another time where reasonably necessary to protect the Service.

A transaction may remain pending or restricted until the verification process has been completed.

8. Information That May Be Requested

Depending on the circumstances, ConSkins or a verification provider may request:

• full legal name;
• date of birth;
• residential address;
• country of residence;
• nationality;
• telephone number;
• verified email address;
• a passport;
• a national identity card;
• a driving licence;
• a residence permit;
• proof of address;
• a photograph or selfie;
• a short video or liveness check;
• confirmation of Payment Method ownership;
• a redacted payment statement;
• a bank or card transaction record;
• information concerning the source of funds;
• an explanation of transaction activity;
• confirmation of Steam Account ownership;
• the Steam ID or profile associated with the Account;
• information concerning the purpose of a payment or purchase; or
• other information reasonably required for the relevant check.

ConSkins will seek to request only information that is proportionate and relevant to the purpose of the verification.

9. Identity Documents

Any identity document provided must be:

• genuine;
• valid and unexpired, unless an expired document is expressly accepted;
• issued to the User;
• clear and legible;
• complete where a complete image is requested;
• free from unauthorised alteration;
• consistent with the Account information; and
• submitted through the method specified by ConSkins or the verification provider.

A User must not submit:

• a forged document;
• an edited or manipulated document;
• another person’s document;
• a screenshot of a document belonging to an unknown third party;
• a document obtained through identity theft;
• false address evidence; or
• information known to be inaccurate.

ConSkins may reject a document that cannot be reasonably authenticated.

10. Identity Verification Providers

ConSkins may use independent identity or fraud-prevention providers to perform verification checks.

A verification provider may:

• capture identity document information;
• assess document authenticity;
• compare identity information;
• perform facial or liveness checks where appropriate;
• check whether information is consistent;
• return a verification result;
• screen against relevant databases; and
• retain information in accordance with its own legal obligations and privacy terms.

Where a third-party verification provider is used, the User may be asked to review and accept that provider’s privacy notice or terms.

The identity of operational providers may change and does not need to be permanently named in this Policy.

11. Payment Method Verification

A Payment Method used for a Top-Up must:

• belong to the User; or
• be used with the lawful holder’s express authorisation.

ConSkins or the Payment Provider may request evidence such as:

• the name of the Payment Method holder;
• the last digits of a payment card;
• confirmation of the issuing bank;
• a transaction reference;
• a redacted statement;
• 3D Secure authentication;
• confirmation through an online banking application; or
• another proportionate proof of ownership or authority.

A User must not send a full payment card number, card security code, PIN or online banking password by email.

12. Third-Party Payment Methods

ConSkins may refuse or restrict a Top-Up made using a Payment Method that does not appear to belong to the User.

Where a third-party Payment Method is used, ConSkins may require:

• identification of the payment holder;
• evidence of the relationship between the User and payment holder;
• confirmation of the payment holder’s consent;
• proof of Payment Method ownership;
• additional transaction verification; or
• cancellation and refund to the original Payment Method.

ConSkins may prohibit third-party payments where they create an unacceptable fraud, payment or compliance risk.

A third-party payment arrangement must never be used to conceal the origin of funds or the true beneficiary of a transaction.

13. Source of Funds

Where reasonably necessary, ConSkins may request information concerning the source of funds used for a Top-Up.

This may include a general explanation or supporting evidence showing that funds originate from a lawful source, such as:

• employment income;
• personal savings;
• business income;
• investment proceeds;
• sale of personal property;
• a lawful gift;
• or another legitimate source.

The nature of the information requested will depend on the amount, transaction pattern and identified risk.

A User must not provide false or misleading source-of-funds information.

14. Purpose of Transactions

ConSkins may request an explanation of the purpose of a transaction where activity appears inconsistent with the intended use of the Service.

The ConSkins Balance is intended only for eligible purchases through ConSkins.

A User must not use ConSkins to:

• store funds for unrelated purposes;
• transfer value between persons;
• move money on behalf of an undisclosed third party;
• convert criminal proceeds into Digital Items;
• conceal the source or destination of funds;
• facilitate sanctions evasion;
• conduct unauthorised payment services;
• settle private debts;
• finance gambling or unlawful activity; or
• otherwise misuse the Service as a financial transfer mechanism.

15. Transaction Monitoring

ConSkins and its service providers may monitor transactions and Account activity for security, fraud-prevention, sanctions and legal-compliance purposes.

Monitoring may consider:

• Top-Up amounts;
• transaction frequency;
• failed payment attempts;
• Payment Methods;
• Account access patterns;
• IP address and approximate location;
• device and browser information;
• Steam Account information;
• Order history;
• refunds and Chargebacks;
• Account closure requests;
• repeated changes to Account details;
• multiple related Accounts;
• unusual purchasing patterns;
• inconsistent identity information; and
• information received from service providers.

Monitoring may be automated, manual or a combination of both.

16. Unusual or Suspicious Activity

Activity may be treated as unusual or suspicious where it includes:

• use of stolen or unauthorised Payment Methods;
• repeated payments using different cards;
• mismatched identity and payment information;
• multiple Accounts controlled by the same person;
• payments made on behalf of unknown third parties;
• rapid Top-Ups followed by unusual purchase activity;
• attempted use of the Service to transfer value;
• repeated Chargebacks;
• false non-delivery claims;
• attempts to bypass verification;
• altered documents;
• use of anonymisation tools to conceal a prohibited location;
• transactions connected to known fraud indicators;
• activity linked to a compromised Steam Account;
• transactions inconsistent with the stated purpose of the Service;
• sanctions-related concerns; or
• another pattern reasonably associated with fraud or financial crime.

The presence of one risk factor does not automatically establish unlawful conduct.

17. Sanctions Compliance

ConSkins will not knowingly provide the Service in breach of applicable Sanctions.

ConSkins may screen Users, transactions, Payment Methods and related information against:

• the UK Sanctions List;
• relevant United Nations sanctions designations;
• sanctions lists required by a Payment Provider;
• sanctions lists applicable to a transaction or service provider; and
• other official restrictions that ConSkins is legally required to observe.

Screening may occur:

• at Account registration;
• before or after a Top-Up;
• before an Order;
• before delivery;
• before a refund;
• during Account closure;
• when a sanctions list is updated; or
• when a relevant risk is identified.

18. Designated and Restricted Persons

A User must not use ConSkins if the User:

• is a person designated under applicable Sanctions;
• is owned or controlled by a designated person where the relevant restriction applies;
• acts for or on behalf of a designated person;
• is attempting to make funds or economic resources available to a designated person;
• is using ConSkins to evade a sanctions restriction;
• is subject to a binding asset freeze or transaction prohibition; or
• is otherwise prohibited from receiving the Service.

A User must not provide false information to avoid sanctions screening.

19. Restricted Jurisdictions

ConSkins may restrict or refuse access from countries, territories or regions where:

• applicable law prohibits the Service;
• broad or targeted sanctions create unacceptable legal risk;
• a Payment Provider does not support the jurisdiction;
• Digital Item delivery is not available;
• fraud levels create an unacceptable security risk;
• local legal requirements cannot reasonably be met; or
• another service provider prohibits the relevant activity.

The list of Restricted Jurisdictions may change without prior notice in response to legal, sanctions, payment or security developments.

Access to the Website does not guarantee that Account registration, Top-Ups, purchases or delivery are available in a particular country.

20. Location Information

ConSkins may use information such as:

• IP address;
• device settings;
• billing country;
• Payment Method country;
• Account information;
• telephone country code;
• Steam Account information; and
• other relevant indicators

to assess the User’s location and eligibility.

A User must not use:

• a VPN;
• a proxy;
• false address information;
• a remote device;
• location spoofing;
• another person’s Payment Method; or
• another concealment method

to bypass a geographic or sanctions restriction.

The ordinary use of privacy or security technology is not itself prohibited unless it is used to conceal a material fact or circumvent a restriction.

21. Politically Exposed Persons

Where proportionate, required by a Payment Provider or otherwise legally relevant, ConSkins or its service providers may determine whether a User is:

• a politically exposed person;
• a family member of a politically exposed person; or
• a known close associate of a politically exposed person.

Such status does not automatically prohibit the use of ConSkins.

However, it may result in:

• additional verification;
• further information concerning source of funds;
• enhanced review;
• transaction limits;
• delayed processing; or
• refusal of a transaction where the risk cannot reasonably be managed.

22. Adverse Information

Where proportionate and lawful, ConSkins or its service providers may consider reliable information indicating possible involvement in:

• fraud;
• identity theft;
• cybercrime;
• sanctions evasion;
• money laundering;
• terrorist financing;
• payment card abuse;
• organised crime;
• account theft; or
• another serious financial or security offence.

Unverified allegations will not automatically be treated as proof of wrongdoing.

ConSkins may request clarification or supporting information before making a final decision.

23. Automated Screening

ConSkins and its service providers may use automated tools to identify possible:

• identity inconsistencies;
• document fraud;
• sanctions matches;
• Payment Method risk;
• unusual transactions;
• multiple related Accounts;
• device anomalies;
• location inconsistencies;
• fraud indicators; and
• account compromise.

An automated result may lead to:

• additional authentication;
• manual review;
• delayed processing;
• a request for documents;
• rejection of a Top-Up;
• temporary restriction of Balance;
• cancellation of an Order; or
• Account suspension.

Where required by applicable data protection law, further information about automated decision-making will be provided in the Privacy Policy.

24. Possible Sanctions Match

If information appears to match a person or entity on an applicable Sanctions List, ConSkins may:

• pause Account activity;
• restrict a Top-Up;
• prevent new Orders;
• suspend delivery;
• delay a refund;
• request additional identity information;
• conduct a manual review;
• consult a Payment Provider or professional adviser;
• reject or cancel a transaction;
• restrict or close the Account;
• preserve relevant records; or
• take another action required by law.

ConSkins may be legally prohibited from completing, refunding or otherwise dealing with certain funds or economic resources without authorisation from a competent authority.

25. False Positive Reviews

A sanctions or identity screening result may occasionally relate to another person with a similar name or details.

If you believe that a restriction resulted from an incorrect match, you may contact:

info@conskins.com

You may be asked to provide:

• full legal name;
• date of birth;
• nationality;
• country of residence;
• identity document;
• address information; or
• another detail necessary to distinguish you from the listed person.

ConSkins will review the matter within a reasonable period, subject to any legal restrictions.

26. Payment Provider Decisions

A Payment Provider may independently:

• request identity verification;
• apply transaction limits;
• decline a payment;
• delay settlement;
• request further authentication;
• reverse a transaction;
• block a Payment Method; or
• refuse to process a refund.

ConSkins does not control an independent decision made by a Payment Provider.

Where reasonably possible, ConSkins may provide general information about the transaction status, but may not have access to the Payment Provider’s complete internal reasoning.

27. Failure to Complete Verification

If a User does not complete a reasonable verification request, ConSkins may:

• reject a Top-Up;
• keep a transaction pending;
• prevent use of related Balance;
• cancel a pending Order;
• suspend delivery;
• delay an Account closure refund;
• restrict Account functionality;
• suspend the Account; or
• close the Account.

Any valid unused Cash-Funded Balance will be handled in accordance with:

• applicable law;
• the Terms and Conditions;
• the ConSkins Balance, Payments & Pricing Policy;
• the Refund, Cancellation & Failed Delivery Policy; and
• any legal or Payment Provider restrictions.

Failure to verify does not entitle ConSkins to confiscate valid funds as a penalty.

28. Pending Reviews

A payment, Balance amount, Order, delivery or refund may remain pending while ConSkins:

• verifies identity;
• confirms Payment Method ownership;
• reviews a sanctions alert;
• investigates suspected fraud;
• responds to a Chargeback;
• checks transaction information;
• reviews a Steam trade reversal;
• awaits information from a service provider; or
• complies with a lawful request.

ConSkins will seek to complete reviews without undue delay, but the time required may depend on the complexity of the issue and the response of third parties.

29. Restrictions During a Review

During a verification or compliance review, ConSkins may temporarily restrict:

• Account access;
• new Top-Ups;
• available Balance;
• new Orders;
• pending Digital Item delivery;
• refunds;
• Account closure; or
• selected Account functions.

Restrictions will be proportionate to the identified risk where reasonably possible.

Unrelated activity should not be restricted for longer than reasonably necessary unless a wider restriction is required by law or security considerations.

30. Rejection or Cancellation of Transactions

ConSkins may reject or cancel a Top-Up, Order or refund where:

• identity cannot be reasonably verified;
• a Payment Method cannot be verified;
• false information was provided;
• the transaction appears unauthorised;
• fraud is reasonably suspected;
• a sanctions restriction applies;
• the User is in a Restricted Jurisdiction;
• the transaction would breach provider requirements;
• the transaction is inconsistent with the intended use of ConSkins;
• required information is not provided; or
• completing the transaction would create an unacceptable legal or security risk.

Where an Order is cancelled before delivery, the purchase amount will ordinarily be restored to the ConSkins Balance unless the underlying Top-Up is unpaid, reversed, fraudulent or legally restricted.

31. Account Suspension or Closure

ConSkins may suspend or close an Account where:

• the User is not eligible to use the Service;
• identity information is false;
• forged or altered documents are submitted;
• a Payment Method is used without authority;
• the Account is linked to fraud;
• sanctions restrictions apply;
• the User attempts to evade verification;
• multiple Accounts are used to bypass controls;
• funds appear to originate from unlawful activity;
• the User refuses necessary verification;
• the Account creates an unacceptable security or legal risk; or
• continued use would breach applicable law or provider requirements.

Where legally permitted, ConSkins will provide a general explanation and an opportunity to contact support.

32. Treatment of Balance Following Suspension or Closure

Where an Account is suspended or closed, ConSkins may temporarily restrict the Balance while it:

• confirms the source and ownership of funds;
• resolves Chargebacks;
• investigates fraud;
• completes sanctions screening;
• calculates a negative Balance;
• determines the correct refund destination; or
• complies with legal instructions.

Eligible unused Cash-Funded Balance will ordinarily be returned to the original Payment Method after permanent Account closure, subject to verification and applicable restrictions.

ConSkins will not knowingly:

• return funds to an unrelated third party;
• return funds to a Payment Method suspected to be stolen;
• make funds available in breach of Sanctions;
• refund an unpaid or reversed Top-Up; or
• treat Promotional Balance as refundable cash unless required by law.

33. Information Sharing

ConSkins may share relevant information with:

• Payment Providers;
• banks and card issuers;
• identity verification providers;
• fraud-prevention services;
• sanctions screening providers;
• Steam-related technology or fulfilment providers;
• hosting and security providers;
• professional advisers;
• insurers;
• auditors;
• courts;
• regulators;
• law enforcement agencies; and
• other competent authorities

where reasonably necessary and supported by an appropriate legal basis.

Information will not be shared merely for unrelated purposes.

34. Reports to Authorities

ConSkins may report suspected fraud, cybercrime, sanctions breaches or other unlawful activity to an appropriate authority where:

• reporting is legally required;
• a lawful request is received;
• disclosure is necessary to protect legal rights;
• disclosure is necessary to prevent or investigate crime; or
• ConSkins reasonably determines that a report is appropriate and lawful.

ConSkins may be prohibited from informing a User about a report, investigation or related disclosure.

35. No Tipping-Off or Detailed Disclosure

ConSkins may be unable to disclose:

• whether a report has been made;
• whether an authority is investigating;
• details of a sanctions review;
• internal fraud indicators;
• risk scores;
• screening rules;
• provider security requirements;
• confidential investigation methods; or
• information concerning another person.

Where possible, ConSkins will provide a general explanation without compromising legal or security obligations.

36. Accuracy of Information

Users must ensure that information provided to ConSkins remains accurate and current.

A User should promptly update or report changes to:

• legal name;
• residential address;
• country of residence;
• email address;
• Payment Method;
• linked Steam Account;
• Steam Trade URL; or
• another material Account detail.

ConSkins may request reverification if material information changes.

37. Data Protection

Identity, payment and sanctions checks involve the processing of personal data.

Depending on the check, this may include:

• identity information;
• contact details;
• identity document data;
• photographs or verification images;
• Payment Method information;
• transaction records;
• Steam Account information;
• device and network information;
• screening results;
• risk indicators;
• communications; and
• supporting documents.

ConSkins will process this information in accordance with the Privacy Policy and applicable data protection law.

38. Data Minimisation

ConSkins will seek to collect information that is:

• adequate for the relevant purpose;
• relevant to the verification or investigation; and
• limited to what is reasonably necessary.

The information required may differ between Users because the nature and level of risk may differ.

ConSkins will not intentionally request sensitive information merely because it might be useful in the future.

39. Security of Verification Information

ConSkins and its service providers will apply appropriate technical and organisational measures to protect verification information against:

• unauthorised access;
• accidental loss;
• unlawful disclosure;
• alteration;
• misuse; and
• destruction.

No online system can be guaranteed to be completely secure.

Users should submit documents only through the method specified by ConSkins or the authorised verification provider.

40. Retention

Verification and transaction information may be retained for as long as reasonably necessary to:

• administer the Account;
• complete the relevant check;
• prevent repeated fraud;
• resolve payment disputes;
• respond to Chargebacks;
• establish, exercise or defend legal claims;
• comply with accounting or legal obligations;
• respond to authorities; and
• enforce the Terms and Conditions.

Retention periods may differ depending on the type of record and the purpose for which it is held.

Information that is no longer required will be deleted, anonymised or securely disposed of in accordance with the Privacy Policy and applicable law.

41. User Rights

Depending on applicable data protection law, a User may have rights concerning personal data used for verification, including rights to:

• receive information about processing;
• request access;
• request correction;
• request deletion in certain circumstances;
• request restriction;
• object to certain processing;
• receive certain data in a portable format; and
• complain to a competent data protection authority.

These rights are not absolute and may be limited where information must be retained for fraud prevention, legal claims, sanctions compliance or another lawful purpose.

Further information is provided in the Privacy Policy.

42. Automated Decisions and Human Review

Where a decision with a significant effect is based solely on automated processing and applicable law provides a right to human involvement, the User may request that ConSkins:

• review the decision;
• consider additional information; and
• allow the User to express their position.

Not every automated risk alert constitutes a solely automated decision with legal or similarly significant effect.

43. User Cooperation

A User must cooperate reasonably with a legitimate verification or compliance review.

This includes:

• responding within a reasonable period;
• providing authentic documents;
• answering relevant questions accurately;
• protecting confidential verification links;
• not submitting another person’s information;
• not attempting to influence or deceive a verification provider; and
• notifying ConSkins if information previously supplied becomes inaccurate.

A User should contact info@conskins.com if they cannot provide a requested document so that a reasonable alternative may be considered where available.

44. Prohibited Conduct

A User must not:

• impersonate another person;
• use a false identity;
• submit forged documents;
• conceal the true Payment Method holder;
• make payments for undisclosed third parties;
• conceal the source of funds;
• evade Sanctions;
• use a Restricted Jurisdiction through location spoofing;
• create multiple Accounts to avoid checks;
• interfere with screening systems;
• bribe or threaten personnel;
• submit false explanations;
• manipulate verification images;
• use stolen credentials;
• exploit a false positive;
• disclose another person’s identity information without authority; or
• otherwise obstruct a legitimate review.

45. Appeals and Complaints

If you believe that a verification, sanctions or Account restriction decision was incorrect, you may contact:

info@conskins.com

The request should include:

• the registered Account email;
• the relevant transaction or Order reference;
• a clear explanation of the issue;
• any supporting evidence; and
• the requested outcome.

ConSkins may require verification of Account ownership before discussing the matter.

A review does not guarantee that a restriction will be removed.

Complaints will be handled in accordance with the Complaints & Dispute Resolution Policy.

46. Relationship with Other Policies

This Policy should be read together with:

• the Terms and Conditions;
• the Digital Item Delivery & Steam Trade Policy;
• the ConSkins Balance, Payments & Pricing Policy;
• the Refund, Cancellation & Failed Delivery Policy;
• the Acceptable Use, Fraud Prevention & Account Security Policy;
• the Privacy Policy;
• the Cookie Policy; and
• the Complaints & Dispute Resolution Policy.

If there is a conflict, the Terms and Conditions will prevail unless another Policy expressly takes precedence for a particular issue or applicable law requires otherwise.

47. Changes to This Policy

ConSkins may update this Policy to reflect:

• changes in applicable law;
• changes to Sanctions;
• changes to Payment Provider requirements;
• new fraud or security risks;
• changes to identity verification methods;
• operational changes;
• changes to geographic availability; or
• corrections and clarifications.

The current version will be published on the Website with a revised “Last updated” date.

A change to a Sanctions List or binding legal restriction may be applied immediately where necessary.

48. Governing Law

This Policy is governed by the laws of England and Wales.

Users may also benefit from mandatory rights and protections available under the laws of their country of residence.

Nothing in this Policy excludes rights that cannot lawfully be excluded.

49. Contact Details

Questions, verification issues, sanctions-match reviews and complaints should be sent to: