AML Policy

EestIBIK OÜ | CODEXNOVA

ANTI-MONEY LAUNDERING,
COUNTER-TERRORIST FINANCING & SANCTIONS POLICY

Public Policy | Last updated: November 2026

1. Purpose of this Policy

EestIBIK OÜ (the “Company”, “we”, “us” or “our”) operates Codexnova, an online platform through which digital photographs, videos and other licensed digital products are offered. We are committed to preventing the Website, customer accounts, payment flows, creator relationships and digital-content activity from being misused for money laundering, terrorist financing, sanctions evasion, fraud or other unlawful activity.

We maintain verification, payment-security, content-review and compliance safeguards appropriate to our business, applicable law and the requirements of our payment partners. The Company acts as an online merchant and does not provide bank accounts, money-remittance services, customer custody, peer-to-peer payments or a general facility for transferring money between users. Customer payments, refunds and creator payouts are handled through approved third-party payment service providers.

2. Activities Covered

This Policy applies to activity connected with Codexnova, including customer purchases, registered accounts, content supplied by Creators, refunds, disputes and payments due to Creators or other approved suppliers.

Codexnova is the seller to the end customer. External Creators may supply or license digital content to the Company under the Platform rules, but Buyers do not make direct payments to Creators. Financial transactions must relate to genuine purchases, refunds or amounts properly due for accepted digital content. The Website must not be used to move unrelated funds, receive money for third parties or disguise the true purpose of a transaction.

3. Identity and Account Verification

Customers and Creators must provide truthful, complete and current information. Ordinary low-risk retail purchases may be completed using the information reasonably required for the transaction, fraud prevention and legal record-keeping. Additional identity or supporting information may be requested where required by law, a payment provider or a reasonable compliance or fraud concern.

Before a Creator receives a payout, we or an authorised verification provider may request information needed to verify identity, age, residence, tax or contact details, ownership of the payout destination, and the Creator’s right to supply or license the relevant content. For legal-entity suppliers, we may also request company-registration, representative or ownership information where appropriate.

A transaction, listing, refund or payout may be delayed, restricted or declined if required checks cannot be completed, information is inconsistent, or the activity presents an unresolved legal, sanctions, fraud, payment or intellectual-property concern.

4. Permitted Use and Prohibited Activity

Codexnova may be used only for lawful purchases and the supply of legitimate digital products in accordance with our Terms & Conditions and related policies. Users and Creators must not:

use stolen, unauthorised or third-party payment methods or payout destinations;

provide false identity, account, tax or payment information, or impersonate another person;

use the Platform to transfer money between unrelated persons, conceal the source or destination of funds, or bypass sanctions or payment restrictions;

manipulate purchases, refunds, chargebacks, account activity or Creator earnings;

upload or monetise content without the necessary ownership, licence or other rights; or

use malware, phishing, automated abuse or other fraudulent methods to obtain products, payments or account access.

Digital products are subject to the Platform’s review and moderation process. We may reject or remove content that is misleading, unlawful, infringing, technically defective or otherwise inconsistent with Platform requirements.

5. Payments, Refunds and Creator Payouts

Customer payments are accepted only through Company-approved payment channels. Payment-card credentials are processed by authorised payment service providers and the Company does not store full card numbers or authentication secrets.

Refunds are handled by the Company as the seller and, as a general rule, are returned through the original payment method or original payment provider. We do not use refunds as a mechanism for transferring funds to unrelated third parties. Repeated, inconsistent or unusual refund activity may be reviewed before a discretionary refund is completed, without affecting mandatory consumer rights.

Creator earnings must arise from genuine digital content accepted under the Platform’s commercial terms. Payouts are made only to verified Creators through an approved payment provider and to a verified payout destination. Where automatic payout functionality is used, a payout may be initiated once the Creator’s cleared balance meets the applicable threshold and other eligibility conditions stated in the Platform terms or payment policy. Payouts to unrelated third parties are not permitted.

We may postpone, restrict, reject or place a payout on hold where reasonably necessary to address incomplete verification, disputed content ownership, fraud indicators, chargebacks, sanctions concerns, account-security issues, legal restrictions or payment-provider requirements. Legitimate payment entitlements remain subject to the applicable contract terms and mandatory law.

6. Sanctions and Geographic Restrictions

We take reasonable steps to comply with sanctions and restrictive measures applicable to EestIBIK OÜ, including relevant European Union and Estonian requirements. We also follow additional geographic or payment restrictions imposed by our authorised payment partners where applicable.

We may restrict account functions, refuse a transaction, prevent or delay a payout, or request additional information where a sanctions concern, prohibited jurisdiction or other legal restriction is identified. Where required or permitted by law, we may cooperate with payment partners and competent public authorities and make appropriate disclosures. We may withhold information about confidential checks or investigations where disclosure is prohibited or could undermine lawful safeguards.

7. Digital Content and Account Integrity

Because Codexnova distributes digital products, we take reasonable measures to confirm that content offered through the Platform is legitimate and suitable for sale. This may include review of product information, technical quality, originality, copyright or licensing rights and compliance with Platform standards.

We may review account or transaction activity where there are reasonable signs of payment abuse, account takeover, repeated disputes, unusual purchasing behaviour, inconsistent identities, suspicious payout instructions or other activity that may indicate fraud or financial crime. Depending on the circumstances, we may request clarification, suspend the affected transaction or account, remove content, withhold a payout or take other proportionate action.

8. Personal Data and Privacy Compliance

Personal information used for account administration, identity verification, fraud prevention, payment processing, sanctions compliance, dispute handling and legal obligations is processed in accordance with applicable data-protection law, including the General Data Protection Regulation (GDPR). Information may be shared with payment processors, verification providers, professional advisers and competent authorities where permitted or required.

We seek to collect only information reasonably necessary for the relevant purpose and to protect it using appropriate organisational and technical measures. Our Privacy Policy provides further information about the categories of data we process, the purposes of processing, retention and users’ privacy rights.

9. Other Policies, Updates and Contact

This Policy should be read together with Codexnova’s Terms & Conditions, Payment & Refund Policy, Sales and Dispute Resolution Policy, Product Review and Moderation rules and Privacy Policy. Mandatory consumer and data-protection rights remain unaffected.

We may update this Policy to reflect changes in the Platform, payment methods, legal requirements or service-provider requirements. The current version will be published on the Website. Questions may be sent to info@codexnova.com. EestIBIK OÜ, registration number 14275503, Pärnu mnt 139c, Kesklinna linnaosa, Tallinn 11317, Estonia.