KYC Policy - Customer Verification Guidelines

SIRELIS AI LIMITED

1. Purpose of Policy

This KYC Policy sets out the principles applied by SIRELIS AI LIMITED when verifying users who register an account and request access to enhanced platform features. The Policy is intended to support a secure, reliable, and transparent environment for the use of the Company's AI-driven and technology-based services.

User verification is applied to confirm identity, age eligibility, and suitability for access to specific platform features. Verification measures are proportionate, limited in scope, and applied for the purposes of protecting platform integrity, preventing misuse, and supporting appropriate use of the services.

This Policy describes the Company's general approach to onboarding, verification, and access management and should be read together with the Terms of Use and the Privacy Policy, which govern access to the platform and the processing of personal data.

2. Definitions

Know Your Customer (KYC) means the process applied by the Company to identify and verify users who register an account and request access to enhanced platform features, for the purpose of confirming identity, eligibility, and appropriate use of the platform.

Know Your Business (KYB) means the process applied by the Company to identify and verify business or organisational users where access to business-level features or technical integrations is requested.

Identity Verification means the process of validating information provided by a user to confirm that the individual or entity is genuine and eligible to access the platform. This process may involve automated checks and, where necessary, manual review.

Risk Assessment means an internal evaluation of account-related factors conducted to determine whether access to the platform should be granted, restricted, or subject to further review.

3. KYC Process

SIRELIS AI LIMITED applies a structured user verification process to support the secure and reliable operation of its AI-driven technology platform. The KYC process is intended to confirm the identity of users who register an account and request access to enhanced platform features, and to support appropriate and intended use of the platform.

The Company applies proportionate Know Your Customer (KYC) and, where applicable, Know Your Business (KYB) procedures to verify user-provided information, reduce the risk of misuse, and protect platform integrity. These procedures are not financial, regulatory, or compliance measures and are implemented solely for operational, security, and trust-related purposes.

During the onboarding process, users may be required to provide accurate personal or business-related information and relevant supporting documentation. Such information is reviewed using a combination of automated verification tools and, where appropriate, manual checks. The scope and level of verification applied depend on the type of account, requested functionality, and observed usage patterns.

The KYC process enables the Company to identify incomplete or inconsistent information, as well as indicators of elevated risk, at an early stage. This supports timely and proportionate measures aimed at preventing misuse of the platform and maintaining a stable operating environment.

Where a user fails to complete verification, provides inaccurate or misleading information, or attempts to circumvent onboarding requirements, the Company may restrict, suspend, or refuse access to certain features or to the account as a whole. Such measures are applied to safeguard the platform and its users and do not constitute penalties, sanctions, or legal determinations.

Information collected as part of the KYC process is handled in accordance with the Company's Privacy Policy. Data is processed solely for verification and platform integrity purposes, retained in line with applicable data protection principles, and not used beyond the scope described in this Policy.

4. Objectives of the Onboarding Policy

The onboarding and verification framework of SIRELIS AI LIMITED is intended to ensure that access to the platform is granted only to eligible users and that the platform is used in a secure and intended manner. The framework supports platform stability, user trust, and the proper functioning of the Company's AI-driven services.

Onboarding measures are applied to establish a basic understanding of who is using the platform and how its features are intended to be used. This supports the management of access to enhanced functionality, the identification of potential misuse, and the maintenance of consistent operational standards.

The onboarding framework forms part of the Company's internal approach to safeguarding platform integrity and managing operational risk. It does not constitute regulatory compliance activity, enforcement action, or financial oversight.

5. Re-verification and Updating Documents Process

SIRELIS AI LIMITED may request users to update or re-verify previously provided information where this is necessary to maintain accurate account records and protect platform integrity. Re-verification is applied on a discretionary basis and only in connection with material changes to an account, requested functionality, or identified inconsistencies.

Users may be required to submit updated information or supporting documentation relevant to the specific request. The scope of re-verification is limited to what is reasonably necessary and may involve automated checks or manual review.

Failure to complete re-verification may result in temporary restrictions on access to certain platform features until the process is completed. All information collected during re-verification is processed in accordance with the Privacy Policy and is used solely for verification and platform integrity purposes.

6. KYC Record Keeping

SIRELIS AI LIMITED maintains records relating to user onboarding and verification in order to ensure accuracy, continuity, and the proper operation of the platform. Such records may include information and documentation submitted during registration, verification, or re-verification processes, as well as records of related account updates.

User information is retained only for as long as reasonably necessary for verification, platform integrity, and operational purposes. Detailed rules governing data retention, storage, and deletion are set out in the Privacy Policy, which applies to all personal data processed by the Company.

Appropriate technical and organizational measures are implemented to protect verification records against unauthorized access, misuse, alteration, or disclosure. Access to such records is restricted to authorized personnel and service providers acting on the Company's behalf under applicable confidentiality and data protection obligations.

Verification records are used solely for onboarding, account management, and platform security purposes and are processed in accordance with applicable data protection principles.

SIRELIS AI LIMITED may share limited onboarding and verification information with third-party service providers strictly where this is necessary to support identity verification, platform security, or related operational functions. Such providers act on the Company's behalf and are subject to contractual confidentiality, data protection, and security obligations.

Information is disclosed only to the extent required for the specific purpose and is not shared for any unrelated use. The Company does not sell, license, or otherwise disclose verification data for marketing or commercial exploitation.

User information may also be disclosed where required by applicable law or pursuant to a valid legal request. In all cases, disclosures are assessed to ensure that only the minimum amount of data necessary for the relevant purpose is shared.

All third-party processing of verification data is governed by the principles, safeguards, and controls described in the Privacy Policy.

8. Policy Review and Updates

SIRELIS AI LIMITED may review and update this KYC Policy from time to time to reflect changes in platform functionality, operational practices, or applicable legal requirements. The Policy is reviewed periodically to ensure it remains accurate, relevant, and consistent with the Company's services.

Material updates to this Policy will be communicated through the platform or by other appropriate means. Continued use of the platform after an updated version becomes effective constitutes acceptance of the revised Policy.

The most current version of this KYC Policy will be made available on the Website.