Legal

Introduction

This Acceptable Use Policy ("AUP") sets out the activities that are not permitted in relation to the use of any Services provided by Tazapay (collectively, the "Tazapay Services"). This AUP has been developed with reference to applicable anti-money laundering and countering the financing of terrorism ("AML/CFT") laws, regulations, notices, and guidelines as may be applicable in each relevant jurisdiction.

The Tazapay General Account Holder Terms and Conditions (the "General Terms"), applicable Service Appendices, User Terms and Conditions (the "User Terms"), Privacy Policy, and any other policies referenced therein are incorporated into this AUP where applicable. Capitalised terms used but not defined in this AUP shall have the meanings given to them in the General Terms. For End Clients using or accessing the Tazapay Services via a Provider (as defined in the Embedded Flows Terms), the Embedded Flow Terms pursuant to your contractual arrangement with such Provider are incorporated into this AUP by reference.

You are responsible for complying with all Applicable Laws in relation to your use of the Tazapay Services, regardless of the purpose. In addition, you must adhere to this AUP, and any breach of this AUP shall also constitute a breach of the General Terms and/or the User Terms. If you are an End Client of a Provider, you must adhere to this AUP when using the Tazapay Services, and any breach of this AUP shall also constitute a breach of the Embedded Flow Terms pursuant to your contractual arrangement with such Provider.

Your use of the Tazapay Services constitutes your acceptance of this AUP as in effect at the time of your use.

Scope

This AUP applies to all Account Holders, Users, and any other persons or entities accessing or using the Tazapay Services, regardless of the jurisdiction from which such access or use occurs. It applies across all Tazapay entities and all Tazapay Services, including but not limited to the Payment Gateway, Global Collection Accounts, Payouts, Escrow, Institutional Account, and Virtual Asset Onramp and Offramp services.

AUP Violations and Prohibited Industries

Tazapay does not permit Account Holders or their Users or End Clients to conduct fraudulent, illegal, or otherwise prohibited activities through the Tazapay Services, or to misuse the Tazapay Services for any unwanted or unlawful purpose.

Tazapay uses the information obtained from Account Holders, publicly available information, government records and databases, and reliable and independent third-party data sources to determine the nature of an Account Holder's business and the appropriate industry classification. Where a Service Provider is involved in the fund flows for an Account Holder, the prohibited industries list of such Service Provider shall also be taken into consideration.

Account Holders, Users, or End Clients found to be in violation of this Section 3 may have their access to the Tazapay Services suspended or terminated immediately, without prior notice, in accordance with the General Terms, User Terms, or Embedded Flows Terms. Account Holders shall be subject to Assessments of liquidated damages in accordance with the assessment table in Schedule A of the General Terms.

1. Severity Category Framework

   Each prohibited industry listed in Sections 3.2 to 3.4 below is hereby assigned to one of three severity categories:

   Category	Severity Level	Description
   Cat 1	Moderate	AUP violations that are likely to cause moderate reputational damage to Tazapay and result in moderate pecuniary losses, typically involving industries that are regulated or distasteful but carry limited systemic risk or public opprobrium.
   Cat 2	Major	AUP violations that are likely to cause major reputational damage to Tazapay and result in significant pecuniary losses, typically involving industries with high potential for harm, exploitation, or serious regulatory and financial exposure.
   Cat 3	Severe	AUP violations that are likely to cause severe reputational damage to Tazapay and result in severe pecuniary losses, typically involving industries linked to criminality, extreme harm, public safety risks, or activities that would expose Tazapay to potential criminal or regulatory sanction.

   Additionally and without limiting the foregoing, any action taken by an Account Holder, User, or End Client that otherwise constitutes of any Prohibited Use of the Tazapay Services (as defined and described in the General (Account Holder) Terms, its Appendices, and the Embedded Flows Terms, or is in contravention of any Account Holder Obligations with respect to disclosure of Transaction information (including, but not limited to accurate disclosure of URLs on which Transactions will be processed) shall be treated at minimum as Category 2 violations.

2. Category 1: Moderate Reputational Damage

   Prohibited Industry
   1. Selling of likes or followers for social media
   2. Tattoo parlours or massage parlours
   3. Outbound telemarketing
   4. Pawn shops
   5. Affiliation with religious, political, or social campaigning
   6. Aroma, organic, or herbal products misrepresented as having medical or pharmaceutical benefits (where such representation is prohibited by Applicable Laws)
   7. Credit repair services
   8. Tobacco, cigars, electronic cigarettes, and nicotine products
   9. Unlicensed tax, accounting, and legal firms

3. Category 2: Major Reputational Damage

   Prohibited Industry
   1. Adult entertainment, websites, or content
   2. Counterfeit items or goods
   3. Espionage equipment and accessories
   4. Gambling providers or transactions, including games of chance
   5. Illegal downloads of movies, music, computer and video games
   6. Illegal or unlicensed sale of financial information
   7. Mail order bride services
   8. Money changers or unlicensed money transmission services
   9. Online pharmacies; sale of prescription drugs or devices online
   10. Poisonous and hazardous materials
   11. Pyramid or Ponzi schemes
   12. Shell banks and companies
   13. Signal jammers or blockers that interfere with cellular or communication devices
   14. Stolen goods, including digital and virtual goods
   15. Surrogacy services
   16. Illegal or unlicensed investment schemes
   17. Prohibited industries as designated by major card schemes or Payment Partners (where not otherwise classified in Category 3)

4. Category 3: Severe Reputational Damage

   Prohibited Industry
   1. Drugs or drug proprietors selling illegal substances
   2. Human remains and body parts
   3. Products or services promoting abuse, hatred, racism, religious persecution, terrorism, violence, or containing offensive content
   4. Sanction list inclusions (global)
   5. Trade of weapons, ammunition, military arms, explosive devices, and firearm parts
   6. Drug paraphernalia

   Note: The above lists are for guidance and are not exhaustive. Tazapay reserves the right to conduct enhanced due diligence based on additional factors or circumstances as it deems necessary, and to assign a severity category to any newly identified prohibited industry at its sole reasonable discretion. The assignment of a severity category or risk classification to any industry does not constitute a representation that activities in such industry would not also attract liability under applicable law or under the indemnity provisions of the General Terms.

High-Risk / Restricted Industries

Tazapay has identified certain industries as high-risk or restricted. Account Holders operating in such industries may be onboarded at Tazapay's discretion, subject to enhanced due diligence. The list of high-risk industries is set out below:

Note: The lists of high-risk/restricted industries provided above are for guidance and are not exhaustive. Tazapay reserves the right to conduct enhanced due diligence based on additional factors or circumstances as it deems necessary. The decision to conduct enhanced due diligence, or to decline or terminate services, is at Tazapay's sole discretion.

Determination and Monitoring

1. Tazapay shall continuously monitor Account Holder platforms, Accounts, and Transactions for permitted use and compliance with this AUP.

2. Account Holders shall have the obligation to provide such information as may be requested by Tazapay from time to time to establish compliance with the General Terms and this AUP.

3. Tazapay shall have the right to determine, at its sole discretion and based on the Account Holder's responses to applicable requests for information, whether the Account Holder has violated this AUP.

Consequences of Violation

If an Account Holder, their User, or End Client is found to be in violation of this AUP, Tazapay may, at its sole discretion and without prejudice to any other rights or remedies available under the General Terms or Applicable Law, take one or more of the following actions:

1. Immediately suspend or terminate the Account Holder's access to all or part of the Tazapay Services, without prior notice;

2. Levy Assessments of liquidated damages on the Account Holder in accordance with the Fees and Assessment Schedule A to the General Terms or as otherwise agreed in writing;

3. Impose restrictions on the Account Holder's use of the Tazapay Services;

4. Withhold, freeze, or delay settlement of funds;

5. Report the violation to the relevant regulatory, law enforcement, or governmental authorities;

6. Pursue all available legal recourse, whether through arbitration, litigation, or otherwise.

Account Holder Responsibilities

Each Account Holder is responsible for:

1. Ensuring that all Users or End Clients authorised to access or use the Tazapay Services on the Account Holder's behalf are aware of and comply with this AUP;

2. Using the Tazapay Services only for their intended purpose as described in the applicable Service Appendices;

3. Not using, and not permitting Users or End Clients to use, the Tazapay Services for any illegal, unlawful, or banned activities, or in violation of any domestic or international laws and regulations;

4. Not performing or allowing to be performed any actions detrimental to the security, integrity, or performance of the Tazapay Services or any API connection; and

5. Promptly notifying Tazapay of any suspected or actual violation of this AUP.

Amendments

Tazapay reserves the right to modify this AUP at any time by posting a revised version on the Tazapay website. Where the modifications constitute a material change, Tazapay will take reasonable efforts to notify affected Account Holders. Your continued use of the Tazapay Services following any modification shall constitute acceptance of the revised AUP.