1. Who the operator is and what the policy covers
This policy describes how the Davinchu service ("the service", "we") controls operations with the user's internal wallet: top-ups by bank card and SBP (through the PayHot payment service) and in crypto, subscription charges, partner payouts and withdrawals to an external address.
Davinchu is not a bank, a broker, an exchange office or a payment institution, and does not provide currency exchange services to third parties. The internal wallet exists to pay for the service's own plans and to pay out partner rewards.
2. Principles
- the service is not used for money laundering or for financing prohibited activity;
- operations that raise reasonable doubt are suspended until they are clarified;
- the user always receives the reason for a restriction and a way to challenge it — silently freezing funds is not acceptable;
- only the data required for a specific check is collected.
3. What data we record for each operation
For every balance operation we record:
- the account identifier and the email it is registered with;
- the amount, currency, network, its USD equivalent at the time and the rate applied;
- the destination address for withdrawals and the date it was added to the whitelist;
- date, time, status and the reason for the decision (auto-payout, manual approval, rejection);
- technical request data: IP address, device, and whether two-factor confirmation passed.
These records are kept in an audit log and are not deleted together with ordinary profile data: they exist so that it is possible to reconstruct afterwards who moved funds, when and on what grounds.
4. Identity verification (KYC)
Identity verification (KYC) is not performed in the service at the moment. If it is introduced, the threshold and the required documents will be published on this page before it applies.
5. Controls that are already in force
Everything below is implemented in the payment service and applies regardless of the amount.
- Two-factor confirmation. A withdrawal request without confirmed 2FA is rejected. This confirms that the withdrawal was started by the account owner and not by someone who obtained the session.
- Withdrawal address whitelist. Funds only go to an address the user saved in their profile in advance. Sending to an arbitrary address in one click is impossible.
- New address cooldown. A newly added address cannot be used immediately: it must age for a fixed period (the exact value is not published yet). That is the window in which the owner can see the notification about a new address and react if they did not add it.
- Limits in a rolling 24-hour window. Both the total withdrawn volume and the number of requests are capped. The exact values are not published yet. The second limit exists separately from the first because splitting a large withdrawal into a series of small ones is the usual way to get around an amount threshold.
- Payout moderation. The operator picks one of three models: automatic payout below the (not published yet) threshold, manual approval above it, or manual approval of any amount. A request awaiting approval is shown to the user as «in progress».
- Asset and network must match. The withdrawal currency and network must match the wallet currency and a supported pair; a mismatch is a rejection, not a «let's try to send it».
- Rejection when the rate is unknown. If the asset-to-USD rate is unavailable at the moment of the request, the withdrawal is not auto-approved: thresholds and limits cannot be computed, and letting the operation past the controls is worse.
- Audit log. Every request, approval and rejection is recorded with the amount, the rate, the reason for the decision and the operation identifier.
6. When an operation can be suspended or rejected
- the request exceeds the daily limit on amount or on the number of operations;
- the destination address is not whitelisted or has not finished its cooldown;
- two-factor confirmation has not passed;
- the amount is above the auto-payout threshold and is awaiting manual approval;
- there are signs the account is compromised: a password or withdrawal-address change shortly before the request, unusual geography, a series of failed logins;
- the user has breached the Terms of Service or uses the service for prohibited activity;
Suspension means the funds stay on the user's balance in a held state and return to the available balance if the request is rejected. Nothing is charged «in favour of the service» during a suspension.
7. Sanctions screening and the Travel Rule
The service does not currently screen addresses or users against sanctions lists and does not transmit originator and beneficiary information (the Travel Rule). If such checks are introduced, the procedure will be described on this page.
8. Record keeping and disclosure
Operation records and verification materials are kept for the period required by the law of the operator’s jurisdiction (not published yet) from the operation or from the closure of the account, whichever is later. Data is disclosed to third parties only on a lawful request from the competent authority of the operator's jurisdiction or by a court order.
9. How to challenge a decision
If an operation is suspended or rejected, the user has the right to an explanation and to challenge the decision. The procedure:
- write to [email protected] from the email the account is registered with;
- state the operation identifier, the date, the amount and which decision you challenge;
- attach an explanation and, where applicable, documents evidencing the source of funds;
- we answer on the merits within a reasonable time (the exact deadline is not published yet);
A rejected operation does not automatically close the account and does not deprive the user of access to the remaining balance unless there is a separate lawful ground to hold it.
10. Changes to the policy
The current version of the policy is always published on this page with the date of the update. Material changes affecting withdrawal conditions are communicated to users by any available means.