KYC (Know Your Customer): Procedures carried out to verify the identity of the Customer.

Ongoing Monitoring: Periodic review of business relationships according to their risk rating.

2. Proceeds of Crime and Terrorist Financing Act (PCMLTFA)

Under the PCMLTFA, the Company must fulfill record-keeping, customer identification, and reporting obligations. To that end, we:

Establish internal policies, procedures, and controls to prevent misuse of our products or services for illicit purposes.
Apply KYC procedures to all Customers.
Regularly assess our money-laundering and terrorist-financing risks.
Comply with the document-retention requirements prescribed by the PCMLTFA.
Monitor transactions for suspicious activity and file Suspicious Transaction Reports (STRs) or Attempted Suspicious Transaction Reports (ASTRs) as needed.
Provide ongoing compliance training to our employees.
Review the effectiveness of our compliance regime every two years.

3. Ongoing Monitoring of Business Relationships

A business relationship is established once a Customer conducts two or more commercial transactions (excluding closed-loop gift card purchases) within a 12-month period. In that context, we:

Verify the Customer’s identity.
Assign and update a risk rating (high/low) to each relationship.
Monitor the relationship periodically according to its risk rating.
Record the measures taken and information obtained during monitoring.
Request additional documentation or information to verify the source of funds if necessary.

4. Know Your Customer (KYC) Processes

Before a Customer may transact, we verify identity using one or more of the following:

Email address
Mobile phone number
Full legal name
IP address and device information
Copy of identity card or passport
Any additional information or documents requested by our compliance team

5. Reporting Suspicious Activity

If we detect unexplained or unusual patterns during our monitoring, we gather further information. The Compliance Officer logs and reviews all internally reported concerns to determine whether an STR should be filed with FINTRAC. If we cannot satisfactorily verify a Customer’s identity or source of funds, the account may be closed, the business relationship terminated, and the Customer blacklisted to prevent re-registration.

6. Contact

For questions or concerns regarding this Policy or its implementation, please contact legal@p2s.gg.

Paybyte Technology OÜ reserves the right to update this Policy at any time. Changes take effect upon publication on our website.

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Privacy and Cookies Policy

Paybyte Technology OÜ ("Company", "we", "us", or "our") has established the following Privacy and Cookies Policy to protect the privacy and personal data of users ("Customer") of the services provided through its online platform (https://p2s.gg), where digital products (ePINs, CD keys, game keys, etc.) are sold. This policy explains the processes for collecting, processing, using, storing, and sharing personal data, as well as Customer rights and how to exercise them.

1. Definitions

Personal Data: Any information relating to an identified or identifiable natural person.
Service: The online platform, including the Company’s website and mobile application.
Site: The website at https://p2s.gg.
Device: Any device used to access the Service, such as a computer, tablet, smartphone, etc.
Cookie: Small text files placed on your Device by the

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