Acceptable Use Policy

Introduction

Effective Date: [●]

Last Updated: [●]

This Policy applies to merchants, businesses, authorised users, developers, partners and other persons using or accessing GlocalPe's platforms, APIs, payment infrastructure, foreign-exchange-related services, international collection services and related technology (“Services”).

This Policy forms part of and should be read together with the applicable GlocalPe Terms & Conditions, Merchant / Business Terms, KYC / KYB Policy, AML / CFT Policy, Prohibited / Restricted Activities Policy, Privacy Policy and other applicable policies.

1. PURPOSE

GlocalPe is committed to maintaining a secure, lawful and responsible payments environment.

The AUP is intended to prevent the Services from being used for:

• unlawful activities;
• fraud;
• financial crime;
• sanctions violations;
• prohibited businesses;
• abusive transactions;
• unauthorised access;
• misuse of payment infrastructure;
• activities that expose GlocalPe, its partners or users to unacceptable legal, regulatory or financial risk.

2. ACCEPTABLE USE

You may use the Services only for legitimate business or personal activities that:

• comply with applicable laws and regulations;
• comply with the applicable GlocalPe agreement;
• accurately represent the goods or services being provided;
• are consistent with your approved business profile;
• do not involve prohibited or restricted activities;
• do not expose GlocalPe or its partners to unlawful or unacceptable risk.

3. ACCURATE BUSINESS INFORMATION

Merchants and businesses must provide accurate and complete information concerning:

• legal entity;
• ownership;
• beneficial owners;
• directors;
• authorised representatives;
• business activities;
• websites and applications;
• products and services;
• expected transaction volumes;
• transaction countries;
• settlement information;
• other information requested during onboarding or monitoring.

You must promptly notify GlocalPe if material information changes.

4. APPROVED BUSINESS ACTIVITIES

You may use GlocalPe only for the business activities approved during onboarding or subsequently approved by GlocalPe.

You must not:

• materially change your business without appropriate disclosure;
• use a merchant account for an unrelated business;
• process transactions on behalf of an undisclosed third party;
• disguise the true nature of your business;
• use a different website or business identity from the one approved by GlocalPe.

GlocalPe may require additional due diligence where your business activities change.

5. PROHIBITED ACTIVITIES

You must not use GlocalPe Services for activities that are unlawful or prohibited by GlocalPe or its financial and regulatory partners.

Prohibited activities may include:

Financial Crime

• money laundering;
• terrorist financing;
• sanctions evasion;
• fraud;
• theft;
• financial scams;
• unlawful solicitation of funds;
• other financial crimes.

Deceptive Activities

• impersonation;
• false representations;
• misleading commercial practices;
• fraudulent investment opportunities;
• fake businesses;
• deceptive websites;
• phishing;
• identity theft.

Illegal Goods and Services

• unlawful drugs;
• trafficking;
• illegal weapons;
• stolen goods;
• counterfeit goods;
• unlawful gambling;
• other goods or services prohibited under applicable law.

Other Prohibited Activities

• activities involving unlawful exploitation;
• activities violating applicable export or trade restrictions;
• activities that materially threaten the security or integrity of GlocalPe systems;
• other activities identified as prohibited under applicable law, regulation, partner requirements or GlocalPe policies.

6. RESTRICTED ACTIVITIES

Certain activities may present heightened regulatory, financial, reputational or operational risk.

GlocalPe may permit such activities only following additional review, approval, licensing verification, enhanced due diligence or other controls.

Examples may include:

• financial services;
• foreign-exchange businesses;
• payment services;
• money transmission;
• virtual digital asset or cryptocurrency-related activities;
• investment-related businesses;
• lending;
• insurance;
• high-value goods;
• regulated healthcare;
• pharmaceuticals;
• gaming;
• marketplaces;
• charities or fundraising;
• adult-oriented businesses;
• travel-related businesses;
• businesses involving high-risk jurisdictions.

GlocalPe may maintain or update a detailed Prohibited / Restricted Activities Policy.

7. REGULATED FINANCIAL ACTIVITIES

You must not use GlocalPe to provide financial, payment, lending, investment, insurance or foreign-exchange services without the licences, registrations, approvals or authorisations required by applicable law.

You must not represent GlocalPe as providing regulatory authorisation, licensing or approval for your own business.

8. CROSS-BORDER TRANSACTIONS

Cross-border transactions must have a legitimate and lawful underlying purpose.

You must not use GlocalPe to:

• disguise the origin or destination of funds;
• circumvent foreign-exchange controls;
• evade applicable taxes;
• circumvent sanctions;
• structure transactions to avoid regulatory controls;
• misrepresent the underlying transaction;
• facilitate unlawful capital movement.

Transactions may be subject to applicable foreign-exchange, payment, tax, customs, sanctions and other requirements.

9. FOREIGN EXCHANGE

Where GlocalPe facilitates or supports foreign-exchange-related services, you must provide accurate information concerning the underlying transaction.

You must not use the Services to:

• conduct unauthorised foreign-exchange activity;
• circumvent applicable exchange-control requirements;
• misrepresent the purpose of a transaction;
• manipulate transaction information;
• facilitate unlawful currency transfers.

Additional documentation may be requested where required.

10. SOURCE AND PURPOSE OF FUNDS

You must not use GlocalPe Services for funds derived from illegal or undisclosed activities.

GlocalPe may request information concerning:

• source of funds;
• source of wealth;
• purpose of transaction;
• beneficiary;
• payer;
• underlying commercial relationship;
• supporting invoices or documents.

You must provide accurate information and supporting documentation where reasonably requested.

11. FRAUD AND DECEPTION

You must not use GlocalPe to:

• submit fraudulent transactions;
• use stolen payment information;
• impersonate another person or business;
• manipulate transaction information;
• submit false documents;
• create fake transactions;
• engage in social-engineering schemes;
• facilitate phishing;
• conduct unauthorised charge or payment activity.

12. TRANSACTION MANIPULATION

You must not attempt to manipulate transaction processing, settlement or reconciliation.

Prohibited conduct includes:

• duplicate transactions;
• fabricated transactions;
• artificial transaction activity;
• transaction splitting intended to evade controls;
• misrepresenting transaction values;
• manipulating refunds;
• manipulating settlement information;
• other attempts to circumvent transaction controls.

13. REFUNDS AND REVERSALS

Refunds must relate to genuine underlying transactions.

You must not use refunds or reversals to:

• transfer funds to unrelated persons;
• circumvent transaction restrictions;
• facilitate money laundering;
• disguise the movement of funds;
• provide unauthorised financial services.

GlocalPe may investigate unusual refund activity.

14. USE OF THIRD-PARTY ACCOUNTS

You must not use a GlocalPe account, settlement account or merchant account for transactions belonging to another undisclosed business or person.

Where third-party processing is legitimately required, it must be expressly permitted by the applicable agreement and approved by GlocalPe.

15. CUSTOMER INFORMATION

You must handle customer information responsibly and in accordance with applicable privacy and data-protection laws.

You must not:

• sell customer information unlawfully;
• misuse personal information;
• collect unnecessary information;
• disclose customer information without appropriate authority;
• use GlocalPe transaction information for unauthorised purposes.

16. CREDENTIALS AND ACCOUNT SECURITY

You are responsible for protecting:

• usernames;
• passwords;
• API keys;
• access tokens;
• authentication credentials;
• dashboard access;
• other security credentials.

You must not:

• share credentials with unauthorised persons;
• sell or transfer account access;
• attempt to obtain another user's credentials;
• bypass authentication;
• permit unauthorised API access.

17. API ACCEPTABLE USE

Where GlocalPe provides APIs, you must use them only in accordance with:

• applicable API documentation;
• technical limits;
• authentication requirements;
• contractual restrictions;
• security requirements.

You must not:

• reverse engineer APIs except where legally permitted;
• circumvent rate limits;
• conduct denial-of-service activity;
• scan or probe systems without authorisation;
• exploit vulnerabilities;
• attempt unauthorised access;
• interfere with API availability;
• use APIs to facilitate prohibited activities.

18. SECURITY TESTING

Security testing, penetration testing, vulnerability scanning or other testing of GlocalPe systems is prohibited unless expressly authorised.

Unauthorised testing may result in suspension or termination of access.

Security vulnerabilities should be reported through the applicable GlocalPe Security & Responsible Disclosure Policy.

19. MALWARE AND HARMFUL CODE

You must not introduce or distribute through GlocalPe systems:

• malware;
• viruses;
• ransomware;
• spyware;
• malicious scripts;
• destructive code;
• other harmful software.

You must not intentionally interfere with the operation or security of GlocalPe systems.

20. INTELLECTUAL PROPERTY

You must respect the intellectual-property rights of GlocalPe and third parties.

You must not use the Services to:

• distribute infringing material;
• impersonate brands;
• unlawfully reproduce protected content;
• misuse trademarks;
• facilitate counterfeit activity.

21. MISLEADING USE OF GLOCALPE

You must not:

• falsely claim to be GlocalPe;
• falsely represent a partnership or affiliation;
• use GlocalPe branding without authorisation;
• claim that GlocalPe guarantees a transaction;
• make unauthorised regulatory claims about GlocalPe;
• misrepresent the role of GlocalPe or its financial partners.

22. SANCTIONS AND RESTRICTED JURISDICTIONS

You must not use GlocalPe Services to circumvent applicable sanctions, trade restrictions or country restrictions.

Transactions may be restricted based on:

• jurisdiction;
• country;
• person;
• entity;
• beneficiary;
• payer;
• transaction purpose;
• applicable sanctions requirements;
• financial-partner requirements.

GlocalPe may block, reject, hold or review transactions where required.

23. AML / CFT REQUIREMENTS

Users must comply with GlocalPe's applicable AML / CFT requirements.

GlocalPe may:

• conduct customer due diligence;
• perform enhanced due diligence;
• monitor transactions;
• request supporting documents;
• screen customers and transactions;
• delay or reject transactions;
• restrict or suspend accounts;
• report suspicious activity where required by law.

24. KYC / KYB REQUIREMENTS

You must provide accurate information and documentation required for KYC/KYB.

You must not:

• provide forged documents;
• provide another person's identity;
• conceal beneficial ownership;
• misrepresent your business;
• circumvent verification procedures.

Failure to complete verification may result in restricted access or termination.

25. TAX AND COMMERCIAL COMPLIANCE

You are responsible for complying with tax and commercial laws applicable to your business and transactions.

You must not use GlocalPe Services to:

• evade taxes;
• conceal taxable income;
• falsify invoices;
• misrepresent transaction values;
• disguise the true commercial purpose of transactions.

26. PROHIBITED USE OF PAYMENT FLOWS

You must not use GlocalPe payment or collection flows for:

• cash-equivalent transfers unrelated to genuine commerce;
• personal remittances where not permitted;
• undisclosed third-party collections;
• unauthorised escrow arrangements;
• informal banking arrangements;
• transactions designed primarily to move funds without an underlying legitimate purpose.

27. MERCHANT WEBSITE AND CUSTOMER DISCLOSURES

Merchants must maintain accurate information on websites, applications and customer-facing interfaces used in connection with GlocalPe Services.

Where applicable, merchants should clearly disclose:

• identity of the merchant;
• goods or services;
• pricing;
• applicable taxes;
• refund and cancellation terms;
• contact information;
• privacy information;
• applicable payment terms.

28. CUSTOMER COMPLAINTS

Merchants must not prevent or discourage legitimate customer complaints or disputes.

Merchants must cooperate with GlocalPe and relevant payment or financial partners in resolving:

• transaction disputes;
• refunds;
• payment issues;
• fraud reports;
• compliance investigations.

29. BUSINESS CONTINUITY

Where applicable, merchants should maintain appropriate operational arrangements to ensure that customer obligations can be met during disruptions.

GlocalPe may impose additional requirements for merchants whose activities present material operational or customer risk.

30. MONITORING AND ENFORCEMENT

GlocalPe may monitor use of its Services for:

• fraud;
• financial crime;
• sanctions;
• security;
• compliance;
• transaction risk;
• abuse;
• violations of this AUP.

Monitoring may involve automated systems, manual review and third-party risk or compliance services.

31. TRANSACTION HOLDS AND REVIEWS

GlocalPe may delay, hold, reject, reverse or restrict transactions where reasonably necessary to:

• comply with applicable law;
• satisfy regulatory requirements;
• conduct KYC/KYB;
• investigate suspected fraud;
• conduct AML/CFT checks;
• perform sanctions screening;
• investigate suspicious activity;
• protect users or partners;
• address security concerns.

Where permitted, GlocalPe may request additional information before completing a transaction.

32. ACCOUNT SUSPENSION

GlocalPe may suspend or restrict access where it reasonably believes that:

• this AUP has been violated;
• applicable law may have been violated;
• fraudulent activity is suspected;
• KYC/KYB requirements are not satisfied;
• AML/CFT concerns exist;
• sanctions concerns exist;
• account credentials have been compromised;
• continued access presents material risk.

Suspension may occur while an investigation is ongoing.

33. ACCOUNT TERMINATION

GlocalPe may terminate access in accordance with the applicable agreement where:

• prohibited activity is identified;
• material policy violations occur;
• required verification cannot be completed;
• continued use presents unacceptable legal, regulatory or security risk;
• required by a financial partner or regulator;
• otherwise permitted under the applicable agreement.

34. REPORTING VIOLATIONS

If you become aware of activity that may violate this AUP, applicable law or GlocalPe's security requirements, you should report it promptly.

Compliance Contact: [●]

Security Contact: [●]

Fraud Contact: [●]

Email: [●]

35. COOPERATION WITH INVESTIGATIONS

You must reasonably cooperate with GlocalPe investigations relating to:

• fraud;
• financial crime;
• sanctions;
• security incidents;
• transaction disputes;
• regulatory matters;
• suspected violations of this AUP.

This may include providing documents, transaction information or other relevant information where lawfully requested.

36. CHANGES TO APPROVED BUSINESS ACTIVITIES

You must notify GlocalPe before materially changing the nature of your business where such change may affect:

• KYC/KYB;
• regulatory status;
• transaction risk;
• prohibited or restricted activity classification;
• expected transaction profile.

GlocalPe may conduct additional review before permitting the changed activity.

37. RESPONSIBILITY FOR EMPLOYEES AND CONTRACTORS

Businesses are responsible for ensuring that their employees, agents, contractors and authorised users comply with this AUP when using GlocalPe Services on their behalf.

A violation by an authorised user may be treated as a violation by the relevant business.

38. RESPONSIBILITY FOR INTEGRATED SYSTEMS

Where a merchant integrates GlocalPe through APIs or third-party technology, the merchant remains responsible for ensuring that its integration:

• operates securely;
• protects credentials;
• accurately represents transactions;
• does not circumvent GlocalPe controls;
• complies with applicable technical requirements.

39. THIRD-PARTY SERVICES

Use of GlocalPe alongside third-party platforms, applications or service providers does not permit activities prohibited under this AUP.

You remain responsible for ensuring that your use of integrated third-party services complies with applicable laws and contractual requirements.

40. POLICY UPDATES

GlocalPe may update this AUP from time to time to reflect:

• regulatory requirements;
• changes in financial-partner requirements;
• emerging fraud patterns;
• security threats;
• changes in products or services;
• changes in prohibited or restricted activities;
• applicable law.

The latest version will be published through the appropriate GlocalPe channel.

41. GOVERNING LAW

This AUP is governed by the laws of India, subject to applicable mandatory requirements.

Nothing in this Policy limits any statutory or regulatory obligation applicable to GlocalPe or its users.

42. CONTACT

GlocalPe [FULL LEGAL ENTITY NAME]

Compliance Contact: [●]

Security Contact: [●]

Fraud Contact: [●]

Legal Contact: [●]

Email: [●]

Registered Office: [●]

Website: [●]

Policy Version: [●]

Effective Date: [●]

Last Updated: [●]