1.1. This Policy is developed in order to determine Adbooro Platform users' data within the framework of counteraction to the legalization (money-laundering) of illegally obtained income, and is subject to mandatory compliance in accordance with the following Public offer agreement paragraphs: Art.2, Art. 3.1.4., Art. 3.2., 4.3., 4.7., 4.9.

Adbooro Platform is a set of web pages hosted on the Internet, united by a single address space www.Adbooro.com, designed for Services orders and payments via the Internet, under the terms of this agreement and the Order. The legal representative of the platform is 205505663, Palbooro Ltd, "Knyaz Boris I" No 148, et. 1, 1000 Sofia, Bulgaria. The platform owns all relevant exclusive rights to the Site, including the right to the Site domain name. The platform takes user Orders and takes actions for their execution, which are described below, under the terms of this agreement.

Identification — the implementation of methods set in the actions, which should ensure that users or customers provide information related to a real person identity in order to assign him or her an ID on the Adbooro platform. It provides a user with a login and password, performs data collecting of the identification object.

Verification — a set of actions to verify the documents and information provided in order to confirm the Adbooro platform user identity.

Approbation — the execution of measures in order to provide individual users with the special rights to take orders and grant service recompense, and which aims to check the availability of the required criteria used for the possible users group, after which a user is admitted to the group and define as a possible "User Contractor".

Authentication — a set of measures to confirm the identity and possible information on payments when Ordering, consisting of the user's actions to enter the login and password, as well as Adbooro Platform verification one's biometric data, Order information, payment information.

Confirmation — Adbooro Platform set of actions and response measures in order to confirm the Order terms fulfillment and the services Payment validity, in accordance with the Public offer of the paid services agreement.

3.1. This Policy is binding upon Adbooro Platform's contractors and employees and is developed for the following purposes:

3.1.1.Providing international requirements and standards governing the organization and implementation of activities for the Users and Customer Payments identification in order to counteract the possible money laundering received from unidentified or illegal activities, as well as terrorism financing, interference in another state political affairs (including violations of electoral legislation, violations of the law on information, violations of the law on state secrets), or violations of another state legal system (plea for crimes, disclosure of the investigation secrecy, illegal collection and dissemination of private information).


3.1.2. Good standing protection of the Adbooro Platform, Youtube Platform, and their contractors and partners.


3.1.3. Informing respective individuals about changes in regulatory requirements for the Adbooro Platform, including requirements from the Youtube Platform, contractors and partners.


3.1.4. Providing crucial assistance in resolving the issues related to the confirmation of the services delivery, as well as payment for services performed.


3.1.5. Exclusion of the Adbooro Platform participation in the conscious or unconscious actions for the legalization of illegally obtained income and terrorism financing.



3.2. This Policy is fulfilled in the following work stages with the participants and in the implementation of compliance control in order to counter the legalization of illegal income and the terrorism financing.

3.2.1. The stage of the User identification, verification.


3.2.2. The stage of the User approbation.


3.2.3. The stage of the Order and payment data Authentication .


3.2.4. The stage of the confirmation of the data on order execution, payment, recipient and payer identity re-verification, if necessary.


3.2.5. The stage of recording request data about a user and one's operations from users' financial constitutions or Adbooro Platform.

4.1. Adbooro Platform user must be YouTube platform user and comply with the rules of both platforms.



4.2. The user identity must be established on the basis of the individual or legal entity and personality documents.



4.3. Awareness of the content, the user's viewing indicators to provide him with orders and assess the risks of their implementation.



4.4. The exclusivity of the User positive Reputation. If the Adbooro Platform suspects the user of possible money laundering, information about it should be sent to the authorized bodies and constitutions of financial partners to protect its reputation, as well as YouTube platform in all cases of violation of the conditions found during the user's work and control by the Adbooro Platform.

5.1. The lack of documents necessary to confirm the legal status.



5.2. Difference in the video nature and kind of activity, the sphere of understanding, sphere of the user experience with the services the user joins the Adbooro Platform, or the order is not related to the activities and experience of one of the parties, is not performed in full, is executed with violations and has a clear sign of an fabricated churning, but at the same time a large price structure of remuneration from the customer.



5.3. The lack of the order obvious economic rationale or compensation for the work performed between the Adbooro Platform participants.



5.4. Participant's inadequate behavior in communication with the Adbooro Platform at each stage of identification, verification, approbation, authentication, confirmation.

6.1. In order to identify the user, the data assigned by the Youtube platform containing full information about the user is used:

• User name
  
  
• confirmed status
  
  
• the number of channel followers

• the number of channel views
  
  
• channel registration date
  
  
• channel interests
  
  
• country of channel location
  
  
• channel e-mail

• channel violation status
  

6.2. The purpose of this stage is to find out information about the user, his / her legal reliability and the possibility to become the platform's user, since the user obligatory condition is the channel registered on the Youtube platform, with a confirmed status, and an impeccable reputation without violations on the part of Youtube.

7.1. With respect to individuals, the following is confirmed:

• Name;
  
  
• Surname;

• Middle name (when applicable to a national custom);
  
  
• Citizenship;
  
  
• Date of birth, personal identification number;
  
  
• Document data;
  
  
• Residence; -

• Taxpayer identification number (if applicable);
  
  
• Occupation;
  
  
• Contact information - phone number, e-mail.
  
  

7.2. During an individual verification, the documents are checked for the credibility of the information provided, and the following is confirmed:

• Whether the identity document is valid;
  

• Whether the photo is true;
  
  
• Whether there is a personal identification code according to gender and age;
  
  
• Country of issue and nationality;
  
  
• Valid place of residence.
  
  

7.3. In case of any doubt about the document, the state authorities that issued the document can be contacted to obtain the necessary confirmation.



7.4. In cases of a minor's channel, the documents of the channel operator, the user's legal guardian or trustee, must be checked.



7.5. The party providing the data must be straightforward and unambiguous to agree to the rules of providing data for the Adbooro Platform verification. After verification, all data is encrypted, and the original documents are destroyed with the user notification, leaving after the verification only data on the user identification and his Name, age, country of residence.



7.6. To verify the legal entity the following is used:

• Name of legal entity;
  
  
• Registration number;
  
  
• Legal address and principal activity address;
  
  
• Corporate form;
  
  
• Full information regarding legal representatives;
  
  

• Beneficiaries;
  
  
• Directors or managers of the legal entity.
  
  

7.7. Verification of information is carried out using public registers and databases or by sending requests to public authorities. A certificate from the registry can be replaced by authorized access to the registry.



7.8. The party providing the data must be straightforward and unambiguous to agree to the rules of providing data for Adbooro Platform verification as a trade secret. After the verification, all data is encrypted, and the verified information is stored on the platform data internal resource hidden from other users.



7.9. The purpose of verification is to determine the high-risk participants who live in the offshore gray zone, as well as identify:

• a public organization or other organization performing public functions that operates in the EU;
  
  
• institution of the EU;
  
  

• a credit institution operating in the EU where the provisions of directive 2015/849 are applied;
  
  
• an individual who is multiple citizenship, where, in accordance with the report of the Task group on financial arrangements significant legislation to counteract money laundering works;
  
  
• an individual is a PEP;
  
  
• an individual is a close relative of a person to whom the special set of sanctions is applied
  
  

7.10. During the Verification and risk assessment, the user is assigned a risk status from lowest to highest by assessing other risk factors (in summing up each element as 1 point):

• User, corporate structure, and field of activity not related to the information;
  
  
• User is or is associated with a government official;
  
  
• The beneficiary of the user is an individual by the declaration or acting by minor proxy notice;
  
  
• User is associated with low tax jurisdictions;
  
  
• User is subject to international sanctions;

• User is a novice on the YouTube platform and has no positive experience of cooperation in the field of information;
  
  
• User is a VIP or celebrity, or channel with a large number of views and acts for charitable purposes in relation to a third party (charities, crafting platform, NGO fundraising).
  
  
• The nature of the planned Order;
  
  
• Order Amount;
  
  
• Problems during the identification procedure;
  
  

The following sum of points is recognized: High risk 7-9, middle risk – 6-4, low risk 3-0. The following channels are not allowed to participate:

• Channels from the "sanctioned party list" (OFAC, EU, etc.);
  
  
• Channels from high-risk countries (FATF list).
  
  
• Channels dealing with high-risk spheres (financial transactions, data collection, gaming portals);
  
  
• Minor owners without a legal representative and without legal representative's open account;
  
  

• Minor owners without legal representative and without minor's open account;
  
  
• Channels that are found to violate YouTube platform terms;
  
  
• PEP or persons exposed to individual sanctions.

8.1. User should have a regular number of views, allowing followers to make a minimum number of The Customer channel views. Adbooro checks the each user data by the Company employee personal work (not by automatic performance of viewing units algorithmic search results).



8.2. User should have an impeccable reputation, no warnings, suspensions or other valid decisions from YouTube. Adbooro employee checks each user's data on his channel.



8.3. Meet the content scope of one or more Adbooro audience categories. Adbooro independently sets the criteria for classifying content into the category of audience groups depending on the interests, users physical and cognitive data, the scope of their interest and searches in the region and such categories are published in the status of Executive Users, as well as a standardized Order in the Personal Account. The criteria for determining Categories for Adbooro are indicators, characteristics, requirements of the target group, the target audience of the content.



8.4. Adbooro employee personally checks the channel content (at least 25% of the video amount), using a specially designed YouTube program that is open and free of charge placed on the YouTube portal in order to check the content, with the help of which copyright owners can search for such materials and provide YouTube with the information necessary to delete them. The aim is to perform the content duplication check and not to violate a number of the video and audio third-party Intellectual Property rights.


8.5. Adbooro employee checks the channel content (not less than 25% of the video amount) using:

• method of video stop-frames visual monitoring in fast rewind;

• method of description and subtitles keywords visual comparison on stop frames in fast rewind;
  
  
• method of the keywords content search results by popularity, name, description, tags in the channel videos;
  
  
• method of the contextual advertising topic assessing in the channel;
  
  
• method of the author's, visual, content and competitive comparison indicators of primary analyses indicators delivery.
  

8.6. Channels that are suspected of using the following methods are not allowed to approved users: clickbait, content nonconformities, excessive tagging, contentless placement of the video previews stop-frame, 80% of videos are collaborations with other channels with exceeding number of followers and views.

9.1. The Adbooro employee performs channels Content Authentication before accepting the Order, and transferring the Order to the Executive Channels for compliance with the audience characteristics, not violating the channel terms, compliance with the Content terms by methods similar to the methods of identification and approbation.



9.2. If the video has not been moderated on the YouTube platform, such video is not accepted for Order fulfillment and the customer is obliged to undergo the verification procedure again. In accordance with the Order risk class, the platform applies measures to inform third parties about violations.

10.1. Adbooro accepts order contractors Applications about the incomplete fulfillment of the order conditions and considers these faults by examining the order terms:

• issue views
  
  
• temporary order compliance
  
  
• non-use of prohibited methods
  
  

10.2. Adbooro sends the revision guidance to the Executive Users or, in the case of the impossibility to correct the disadvantages and to improve the Order, decides to refund by the ratio of the each incorrect or missing view value, as a result of this application Confirmation by order.



10.3. Adbooro verifies all orders of high risk execution and payment with re-verification before the both participants payment.



10.4. If the Customer does not send any objections regarding the Services performed by the User in 3 (three) days after the end of the services delivered by the User, the Services are considered to be performed properly by the User and accepted by the Customer without comments, and Adbooro assumes obligations to verify the order execution and payment for the Executive Use services of middle risk and low risk Order. Any disagreements between the parties on the Order implementation are impossible after payment for the Executive User services.

11.1. When paying by credit card, the payment is processed on the Bank or Service Provider authorization page, where you should enter your credit card details:

• bank card type;
  
  
• bank card number;
  
  
• bank card validity period (indicated on the card front side);

• Name of the card holder (in Latin letters, exactly as indicated on the card);
  
  
• CVC2/CVV2 code;
  
  

11.2. Adbooro does not have access to this information, does not store information on such incoming fees, does not process such data and cannot be the subject of such data disclosure.

Adbooro takes measures to comply with the policy, monitor compliance with this policy and respond to violations and identifies violations in this policy application by: training employees, retraining, selective managers control, and additional incentives in the case of 100% compliance by the employee.