Transaction Policy

The Transaction and User Verification Policy ("T&U policy") given here is a testament to the organization's commitment to maintaining a clean system and preventing the use of Cushy Pay services for illegal activities. It explains the company's policies and procedures instituted to ensure that the users are not using the services offered by the company to facilitate the commission of any criminal offenses, including but not restricted to those under any valid money laundering laws together with the rules issued thereunder and the rules and regulations as prescribed by the regulators. Cushy Pay has prepared this T&U policy to ensure trading transparency and prevent money laundering and/or other illegal actions.

The terms "we," "us," "company," and "our" refer to Cushy Pay, and the terms "your," "you," and "user" and refer to a user of our online platforms.

The T&U policy applies uniformly to any user wanting to avail the services or otherwise using or benefitting from the online platforms and may be read as a part of the user terms and conditions. You must read this policy before using online platforms or submitting any personal information. By using the online platforms, you expressly consent to be obliged by the user Terms & Conditions and, subsequently, this T&U policy.

Cushy Pay may modify and bring up-to-date this T&U policy regularly. These changes may be done without prior notice, but any changes will only apply to activities and information on a future and not backdated basis. As a user, you can examine this T&U policy when you access the online platforms.

1. User responsibilities

a. You agree to take the responsibility to comply with the terms and conditions defined in this policy and accede your consent to not use the services and the online platforms in any manner that would result in committing/attempting to commit any criminal offense. You also concur and consent to any alterations made to this policy in due course and/or without notice.
b. As a user, you must ensure that any personal information and/or identification documents submitted by you belong to you.
c. Suppose you are acting on behalf of a juridical person. In that case, you must identify the beneficial owner and assist in verifying the identity of such a beneficial owner and any individual who purports to act on behalf of such a juridical person.

2. Purpose of the policy

To alleviate its risks relating to money laundering and/ or other illegal activities, the organization puts in place this policy containing the following elements:

1. customer acceptance terms;

2. transaction monitoring terms

3. customer verification procedure;

3. Customer acceptance terms

a. Cushy Pay may either at the time of opening of the user account, or during any transactions, or through periodic updates, or due to any other reason, confirm your compliance with the following terms:

i. You may require to undergo an authentication process during the activation of your user account by providing your identification documents and such other details, as mandated under this T&U policy.

ii. You may be required to furnish such other details as the company may deem necessary to verify your identity.

iii. You may be required to submit such extra information and/or data as/may a competent enforcement authority directs.

iv. You may be required to ascertain that your linked bank account is with a scheduled commercial bank compliant with all know-your-customer (KYC) procedures as mandated under the applicable laws.

b. Cushy Pay in its sole discretion, may refuse to open any new accounts, dismiss existing user accounts after giving due notice, or decline to process any transactions on the online platforms if it is incapable of ensuring compliance with any of the above-mentioned conditions, either due to non- cooperation by the user or due to the particulars provided by the user being untrustworthy or unverifiable to the satisfaction of the company.

4. Customer verification procedure

a. Cushy Pay, during any transactions or, during the activation of user accounts or, for any other reason may require for verification of any user's identity – one copy of any identification document containing their identity and address details; one recent photograph; any other documents pertaining to business/financial status of such individual as may be prescribed by the company from time to time.

b. To verify any user's identity, the company may rely on appropriate and licensed third-party service providers (such as Cushy Payit bureaus) for authenticating the identification papers and other incidental details as provided by the user.

c. In case the company finds any user information obtained following the procedure defined under this clause to be inadequate or insufficient, Cushy Pay may, in its discretion, refuse or terminate the registration of the user account or ask for the user's identification documents (as the case may be).

5. Transaction monitoring terms

a. All transactions performed and/or attempted to be managed through the Cushy Pay app are monitored regularly by the company to promptly identify and highlight certain kinds of transactions deemed suspicious by the company.

b. From time to time, the company may undertake a necessary inquiry to identify and examine transactions conflicting with any user's risk profile, sophistication, and expected pattern of usage

c. The degree of monitoring shall depend on several factors, including each user's risk report.

d. If the company requires, it can take any of the following steps to regulate the use of the Cushy Pay app by any user:

i. Negative name checks: name-checks ensure that the user doesn't transfer the funds to his account.

ii. Pan check: for each transaction, the company may require the user to input the pan card of the end person to whom the payment is being made.

iii. Block payments to cc account to avoid balance transfer(s) for a user between different Cushy Payit cards.

iv. Cushy Pay may also put transaction limits meaning each account may limit the size and/or the total number of transactions. These limits may be finalized on a per transaction basis as well as a monthly basis.

v. Additionally, the company may also limit the number of receivers per user.

6. Maintenance of records

Cushy Pay will maintain and safeguard the information and/or data as given below:

a. The records of all suspicious transactions executed through the Cushy Pay app for at least 5 (five) years before/ from the date of each transaction.

b. Records of all suspicious transactions identified under clause 5 (transaction monitoring terms) above for at least 5 (five) years, counting but not limited to the data about the value, nature, and participants to such transactions and the remittance date.

c. Records of identification for the users during the subsistence of and for at least 7 (seven) years from the date of closing of such user account.