1. Purpose

HILLMARK CONSULTING LTD may perform know-your-customer, sanctions, fraud, source-of-funds, and account ownership checks to protect Brightskins, users, payment providers, and legal compliance.

Checks are risk-based and may be required before or after an order, sale, refund, withdrawal, complaint, chargeback, or account review.

2. When checks may be requested

• High-value, unusual, repeated, or suspicious transactions.
• Payment, Steam, device, location, identity, or Trade Offer data that does not match or appears inconsistent.
• Chargebacks, refund abuse, stolen account indicators, sanctions indicators, PEP indicators, or fraud alerts.
• Requests from payment providers, banks, card networks, regulators, law enforcement, or professional advisers.
• Legal, compliance, consumer-law, AML, sanctions, or dispute-handling requirements.

3. Documents and information

• Government-issued photo ID, proof of address, proof of payment ownership, and Steam account ownership evidence.
• Selfie or liveness check, where required by a verification provider.
• Source-of-funds or source-of-wealth information, such as bank statements, payslips, sale records, or other reasonable evidence.
• Company documents, beneficial ownership details, or authority-to-act evidence where an account or payment is linked to a business.

4. Sanctions and PEP screening

We may screen users, counterparties, payments, locations, and related information against sanctions, watchlists, PEP lists, adverse media, and fraud-prevention databases. We may block, cancel, refund, restrict, or report activity where screening identifies unacceptable risk.

5. Data handling and retention

KYC and sanctions data is handled under the Privacy Policy. We keep it only as long as necessary for legal compliance, fraud prevention, risk management, dispute handling, and law enforcement cooperation.

Access is limited to authorised staff, providers, advisers, and authorities where necessary.

6. Refusal or failure to complete checks

If you refuse or fail to complete requested checks, or provide false or misleading information, we may refuse service, hold delivery, cancel or refund an order, restrict the account, or report the matter where lawful.