Know Your Customer and Anti-Money Laundering Policy

Last updated: 02/11/2026

This policy is issued by ElVivia Group Limited, a company registered in England and Wales under company number 17550774, registered office 9 Chapel Place, 2nd Floor, London EC2A 3DQ, United Kingdom, which operates Animator Hub ("we", "us").

This policy explains how we identify the people who use and pay for Animator Hub, how we confirm that they are adults, and how we stop the service being used for fraud, money laundering, terrorist financing or to evade sanctions.

1. What we sell and why the risk is low

Animator Hub sells prepaid credits that are spent on AI generated images, videos and companion features inside the platform. The design of the product limits how it could be used to move money:

• Credits can only be spent on our own digital services. They cannot be withdrawn, cashed out, exchanged for money or cryptocurrency, or sold back to us
• Credits cannot be transferred, gifted or sent from one account to another
• We do not hold money on behalf of users, we offer no wallet, balance withdrawal or peer to peer payment, and users cannot pay each other through the platform
• Where a refund is agreed, it goes back only to the original payment method, never to a different card, account or wallet
• Card numbers never reach our servers. Payments are taken by our card payment provider and our cryptocurrency payment provider, both of which run their own customer and transaction checks

ElVivia Group Limited is not a bank, payment institution or other firm regulated for anti-money laundering purposes, and it does not hold client money. We apply the controls below because they are good practice for a business that takes payments online, and because our payment partners require them.

2. Who is responsible

The Director of ElVivia Group Limited is responsible for this policy, acts as its compliance officer and decides on every escalated case. The policy is reviewed at least once a year and whenever our products, payment methods or the law change.

3. Knowing our users

Every account is tied to a verified identity point and an adult declaration:

• An account is opened with an email address that must be verified before the account can sign in, or with a Google account
• Every signed-in user must confirm that they are at least 18 years old and accept our Terms and Content Policy before they can generate anything. We record that acceptance, and our servers refuse requests from an account without it
• We record technical information needed to prevent abuse, such as sign-in times, the country a request comes from and whether it comes from a data centre network
• One person may hold one account. Accounts that look created to collect free credits more than once are refused them and may be closed, and so may accounts opened to get around a suspension

4. Age verification

Animator Hub is for adults only. A self declaration is the minimum, not the whole of our approach.

We are introducing age assurance through a specialist age assurance provider that is certified for this work, starting with users in the United Kingdom, where the Online Safety Act requires highly effective age assurance for adult content. Once it is live, a user in the United Kingdom sees no explicit content until their account has passed a one-time check. The check can use email based age estimation, facial age estimation or an identity document with a matching selfie. We will extend it to other places where the law requires it.

We keep only the result of a check: passed or failed, the date, the method and the provider's reference. We never receive or store the selfie, the identity document or a date of birth. The provider deletes the facial data it uses for an estimate once the check is complete and keeps other check data only for the short period set out in its own privacy policy.

Separately from the account level check, every photograph uploaded as a source image is screened for the apparent age of every person in it, and an image of anyone who may be under 20 is refused. See the Content Monitoring Policy for how that works.

5. Payment checks

• Card payments are authorised by our card payment provider, which applies its own fraud screening. Cryptocurrency payments are processed by our cryptocurrency payment provider, which applies its own screening of incoming transactions
• We keep a record of every purchase: amount, currency, outcome, time and the account it belongs to
• A card is linked to the account through a non-reversible fingerprint. An unpaid balance from a failed or reversed payment follows the account and the card, and must be settled before a new purchase goes through
• Chargebacks and payment reversals are reviewed. Fraudulent chargebacks lead to suspension of the account
• Where we have reason to believe a payment is made with a card or wallet the user is not entitled to use, we stop the purchase and review the account

6. Affiliates and anyone we pay

Affiliates are the only people who receive money from us in connection with the platform, so they get the closest checks:

• Commission is only earned on genuine purchases by referred users, and it is reversed if the purchase is refunded
• Commission matures after 30 days, so refunds and chargebacks are known before any payout
• Every payout is approved by hand. There are no automatic payouts
• Before the first payout we collect the affiliate's full legal name or company name, country of residence or registration, and the payout address, and we screen the name against the United Kingdom sanctions list
• For a business affiliate we confirm its registration with the public company register. Before any payout above an equivalent of USD 1,000 in a 12 month period, or whenever something does not add up, we ask for an identity document or company documents
• Self referral, traffic bought with stolen cards and referrals of linked accounts are not paid, and the affiliate account is closed

7. Sanctions

We do not knowingly provide services to, or make payments to, any person or entity on the United Kingdom, United Nations, European Union or United States sanctions lists, or to anyone acting for them. Our payment providers screen payments against sanctions lists, and we screen every affiliate before the first payout. If we find a match we stop the service and the payment and report as the law requires.

8. Warning signs we act on

We review an account when we see any of the following:

• Many accounts linked to one person, device, card or payment address
• Purchases that do not fit normal use, such as many large purchases in a short time with little or no use of the credits
• Repeated failed payments, several cards tried on one account, or a chargeback followed by a new purchase with another card
• Requests to refund to a different payment method than the one used
• An affiliate whose referred purchases are refunded or charged back far more often than normal, or whose referrals look like the affiliate's own accounts
• Information that is false, inconsistent or refused when we ask for it

During a review we may pause purchases, pause payouts or suspend the account. We may ask for more information and close the account if it is not provided.

9. Reporting

Where we know or suspect that money laundering or terrorist financing is taking place, we report it to the National Crime Agency, and we report fraud to the relevant authorities and to our payment providers. We do not tell the person concerned that a report has been made. We cooperate with law enforcement and respond to valid legal process.

10. Records

We keep purchase, refund, chargeback and payout records, affiliate checks and the records of any review for at least six years, as required for accounting and tax purposes, and longer where a case or legal hold is open. Age check results are kept for as long as the account exists. These records are handled as described in our Privacy Policy and are used for nothing else.

11. Contact

Questions about this policy, and requests from payment partners or authorities, can be sent to support@animatorhub.ai.