Legal & Privacy

In this agreement the following terms, unless the context otherwise indicates, will have the following meanings:

AML Act means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and all associated regulations and rules in respect of crypto trading for AUD, EURO, USD and AED.

AML Regulations means MAS Notice No. PSN02 Notice to Holders of Payment Service License (Digital Payment Token Service) read with section 27B of the Monetary Authority of Singapore Act (Cap. 186) in respect of crypto/crypto trading.

AML Policy means the policies and programs maintained by ZebPay to comply with the AML Act and AML Regulations.

Business Day means a day that is not a Saturday, Sunday or public holiday in Singapore and/or Melbourne, Victoria.

Client Deposits means money (fiat) deposited into the Client Asset Account either by the Client transferring funds to the Client Asset Account or by crediting the Client Asset Account by ZebPay as a result of a sale of Digital Payment Token by the Client on the ZebPay Platform.

Client Deposit Money means Client Deposits credited to the Client Asset Account (not applicable to Indian Customers).

Client Asset Account or Account entails the overall term for all wallets and accounts that the Client holds with the Company on the ZebPay Platform including both fiat and crypto-wallets.

Company means Genie Technologies Pte Ltd [Registration No: 201919382H] or Awlencan Innovations Australia Pty Ltd [ACN 629 939 948] , as the context may require.

Competent Authority means the Monetary Authority of Singapore and Australian Transaction Reports and Analysis Centre (AUSTRAC) or such other relevant government authority (as the case may be).

Dispute means a dispute, controversy or claim between any of the parties as to:

• the construction of these Terms of Use;
• the rights or obligations of a part under these Terms of Use; or
• any other matter arising out of or relating to these Terms of Use.

Force Majeure shall mean and include any cause arising from or attributable to acts, or events, beyond the reasonable control of ZebPay, including natural calamity, strikes, terrorist action or threat, civil commotion, riot, crowd disorder, invasion, war, threat of or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, structural damage, epidemic or other natural disaster, calamity, attacks including through computer viruses, hacking, denial of service attacks, ransomware or other manmade disruptions or any law, order enactment, statutory direction, legislation, regulation, rule or ruling of government or any court of law or of a Government or regulatory authority.

KYC means know your customer requirements under the AML Act or the AML Regulations as may be applicable.

Privacy Policy means the privacy policy of the [Awlencan group of companies] available at www.zebpay.com/privacy-policy

Digital Payment Token Exchange means (per Schedule I of the Payment Services Act) an exchange operating in or from within Singapore which facilitates the exchange and/or trading of digital payment tokens by making or hosting offers or invitations to buy or sell digital payment tokens in exchange for any money or any other digital payment token, but does not include an exchange where the exchange in question does not come into possession of any money or any digital payment token, whether at the time that the material offer or invitation is made or otherwise.

Digital Payment Token has the same meaning as defined in the Payment Services Act.

User or Client shall mean persons availing of the ZebPay Services (as defined below), directly or indirectly, and are referred to herein as “Users”.

ZebPay Platform shall either exclusively or collectively mean and include ZebPay Android App, ZebPay iOS App (collectively, “ZebPay App”) or Zeb Web app (“Web version”), ZebPay website “www.zebpay.com” (“ZebPay Website”) and other web assets on the ZebPay.com domain, together with the ZebPay Developer Portal, Public APIs and secure authentication for Users;

ZebPay Services means the services made available from time to time on the ZebPay Platform.

Trading in Digital Payment Token involves a high degree of risk to your capital. Digital Payment Tokens may not be an appropriate for all investors and you should seek independent advice if necessary. Trading with Digital Payment Tokens may result in total loss of your investment.

• These Terms of Use form a binding agreement between you (hereinafter known as ‘The Client or User or You’) and ZebPay as the operator of the ZebPay Platform.
• By using any services made available through the ZebPay Platform the Client agrees that the Client has read, understood and accepted all the terms and conditions contained in this Terms of Use agreement as well as ZebPay’s Privacy Policy.
• As this is a legally binding contract, the Client is cordially requested to carefully read through this agreement and related notices before using any of ZebPay’s Services.
• By registering, accessing or using ZebPay’s Platform, the Client agrees to the terms and conditions set out in this Terms of Use.
• If any Client disagrees with this Terms of Use, the Client shall not proceed to initiate account registration with ZebPay or seek to acquire any of its services.
• ZebPay reserves the right to reclaim back to itself any promotion reward given to Users pursuant to any promotion if the aforementioned reward so given to the User has remained unused for a period of 30 days from the date it has been granted.

ZebPay is committed to support the global fight against money laundering and terrorist financing. In this regard, the Company has endeavo red to carefully ensure all of its internal anti-money laundering procedures comply with AML Act and AML Regulations as may be applicable.

• ZebPay reserves the right to modify or change the terms and conditions of the agreement at any time and at its sole discretion. ZebPay may provide reasonable notice of these changes to Users and will modify or change the terms by updating the Terms of Use.
• Any and all modifications or changes to the Terms of Use will be effective on the date being provided to Users. As such, Users’ continued use of ZebPay services, including but not limited to any failure to close your account during the requisite notice period, acts as acceptance of the amended agreement and rules. For the avoidance of doubt, if the User does not agree with any such modification or change, then the User should close the Client Asset Account and cease using the ZebPay Platform.

• By registering to use a ZebPay’ Client Asset Account, the Client warrants that the Client is an individual who is at least 18 years old, a legal person or an organization with full legal capacity to enter into these Terms of Use.
• If the Client is an individual and is not at least 18 years old, the Client’s legal guardian shall be responsible for all actions and consequences resulting from the Client’s actions on the ZebPay Platform and ZebPay shall have the right to cancel or freeze the Client’s Client Asset Account in addition to filing claims against the Client and the Client’s guardian for compensation/damages.
• Each Client shall have one Client Asset Account only. Multiple accounts for the same Client will not be allowed.
• Clients who are either citizens or residents of the below countries are not permitted to use the ZebPay Services in any form ( “Prohibited Jurisdiction Use”)

Democratic People’s Republic of Korea (DPRK), Iran, Albania, The Bahamas, Barbados, Botswana, Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Myanmar, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen, Zimbabwe.

• By accessing and using the ZebPay Platform, the Client acknowledges and declares that he/she is not on any trade or economic sanctions lists, such as the United Nations Security Council Sanctions List and its equivalent. You may not use your Client Asset Account to engage in the following categories of activity (“Prohibited Uses”). The specific types of use listed below are representative, but not exhaustive:
  • (a) unlawful activity;
  • (b) fraud;
  • (c) gambling;
  • (d) intellectual property infringement; or
  • (e) defamation or abuse.
  • (f) Terrorist financing
  • (g) Money laundering
  • (h) Distributing or funding drugs and drug paraphernalia or
  • (i) Malicious hacking
• Pursuant to ZebPay’s strict policy of preventing potential conflicts of interest and/or market abuse, the Client is given notice that ZebPay does not extend its services to its employees and/or their relatives, save where ZebPay is satisfied, on a case by case basis, that the risk of conflicts of interest and/or market abuse have been ameliorated. By accessing and using the ZebPay Platform, the Client acknowledges and declares that neither he/she nor any of her relations are employees of ZebPay or any of its affiliates.
• The content of these Terms of Use shall not supercede the laws of the country to which the User belongs. ZebPay maintains its position that prohibited users can not under any circumstance use or access the ZebPay Platform.

• The OTC Trading Platform Service is a service accessed through the ZebPay Platform whereby ZebPay provides an online virtual financial asset trading platform via a sophisticated ZebPay platform for products commonly known as cryptographic tokens, digital tokens or cryptographic currency.
• When a User enters into the OTC Trading Platform Service on the ZebPay Platform, the User acknowledges and consents that he/she may be transacting with ZebPay as a counterparty, meaning that for all intents and purposes, ZebPay is dealing on its own account and the prices are decided solely by ZebPay. For the purpose of the OTC Trading Platform Service, the User is subject to the provisions of its terms. Detailed terms of the OTC Trading Platform Service are available at https://zebpay.com/otc/terms-of-use/. By availing themselves of this particular service, Users are deemed to have read and understood and agree to be bound by its terms.
• The Digital Payment Token Exchange Service is a service accessed through the ZebPay Platform whereby ZebPay provides a trading platform (crypto to crypto/fiat to crypto/crypto-fiat) for digital payment tokens, but otherwise commonly known as cryptographic tokens, digital tokens or cryptographic currency. The functionalities available under this service falls into two separate classes. In broad terms, the “Instant Buy/Sell” class of services will allow Users to trade the aforementioned tokens and cryptographic currencies with ZebPay itself as the counterparty. Conversely, the “Exchange” class of services will allow Users to trade the aforementioned tokens and cryptographic currencies amongst each other, which ZebPay facilitates by providing the matching service that will pair up their respective buy and sell orders.
• When a User enters the Digital Payment Token Exchange Service on the ZebPay Platform, the User acknowledges that he or she is transacting with other users of the ZebPay platform as a counterparty and bids are matched on a non-discretionary basis with a counterparty. In this regard, ZebPay provides the platform to match the orders, and prices are therefore set by the market-forces of supply and demand.

• The Client must register and open a Client Asset Account with ZebPay for exchanging Digital Payment Tokens (Digital Payment Tokens) prior to commencement of trading on the ZebPay platform.
• All crypto-wallets will be managed by the Company.
• Client may request the withdrawal of the Digital Payment Tokens and any fiat currency subject to the limitations available at www.zebpay.com/fees/
• ZebPay strives to maintain the accuracy of information listed on the ZebPay Platform however it cannot guarantee the accuracy, suitability, reliability, completeness, performance or fitness for the purpose of the content through the ZebPay Platform and will not accept any liability whatsoever for any loss or damage that may arise directly or indirectly from the content.
• Information on ZebPay’s Platform can be subject to change without notice and is provided for the primary purpose of facilitating Users to arrive at independent decisions.
• All Users of the ZebPay Platform must understand that there are risks involved in the usage of the ZebPay Platform. ZebPay encourages all users to exercise prudence and trade responsibly within their own means and capacity.
• While ZebPay emphasises online interface security to ensure the continuity and security of its services (announcements will be made in event of downtime/maintenance), it will be non-accountable to Users for an act of God, Force Majeure, malicious targeted hacking, terrorist attacks and other unforeseen circumstances.
• ZebPay reserves the right to cancel, rollback or block transactions of all type on its platform in event of abnormal transactions or on the basis of on its internal AML Policy.
• ZebPay will not ask for any password or PIN from its users except for Users to login into ZebPay Platform and use ZebPay services. ZebPay will also not ask Users to transfer funds that are not listed on its OTC Trading Platform Service or Digital Payment Token Exchange Service.
• By using the ZebPay Platform and ZebPay’s Services, the Client declares that all information provided by the Client to ZebPay is true, accurate and complete.
• The Client agrees and understands that the underlying protocols of different crypto networks are subject to changes (each a “Fork”) which may result in more than one version of such network (each a “Forked Network”). The Client further agrees and understands that Forks may materially affect the value, function, and/or name of the crypto held by the Client with ZebPay. In the event of a Fork, ZebPay may temporarily suspend any services in respect of the relevant crypto/s (with or without advance notice to you) and may determine, in its sole discretion, whether or not to support the Forked Networks. Details of ZebPay’s position on such Forks are available at https://help.zebpay.com/support/solutions/articles/44001895103/, which may be subject to change from time to time.

• With registration of a Client Asset Account on ZebPay, the Client agrees to share personal information requested for the purposes of identity verification. This information is used specifically to identify the Client and for the detection of money laundering, terrorist financing, fraud and other financial crimes on the ZebPay Platform and which is in compliance with the AML Act and the AML Regulations, as may be applicable. ZebPay endeavours to retain and obtain this personal information in accordance with the Personal Data Protection Act 2012 (Singapore), Privacy Act 1988 (Cth) (Australia) and its Privacy Policy.
• In addition to providing this information, to facilitate compliance with global industry and government standards for data retention, the Client agrees to permit ZebPay to keep a record of such information for the lifetime of the User’s Client Asset Account plus seven (7) years after closing that account.
• The Client also authorises ZebPay to make inquiries, either directly or through third parties, that are deemed necessary to verify the Client’s identity or to protect the Client and/or ZebPay against financial crimes such as fraud, etc.

• All relevant Client Deposits shall be kept separate from money belonging to ZebPay in a Client Asset Account, unless and until such amounts are returned to the Client, become due and payable to ZebPay
• By accepting these Terms of Use, the Client hereby grants to ZebPay the authority to open and establish a ‘Client Asset Account’ and the Client agrees to grant the Company the right to control the Client’s assets including ‘Digital Payment Tokens’ and fiat.

• ZebPay is required to adhere to KYC requirements. ZebPay may undertake remote KYC procedures and video on boarding, among others.
• The KYC procedures may be created or undertaken by any authorised representative of ZebPay (such as a third-party KYC service provider) possessing all the relevant and necessary credentials to conduct the KYC and due diligence in accordance with the AML Act, AML Regulations and the AML Policy, as may be applicable.
• The Client is bound to follow all on-screen instructions and adhere to all requirements that emanate from the on-boarding on to the ZebPay Platform.

• All Users must register for a ZebPay Client Asset Account before using the ZebPay Platform via our standard application procedure. To register for an account, the Client must provide their real name, email address and such other requested information including KYC documents.
• Depending on certain conditions and in our sole discretion, we may refuse to open an account for you. No orders can be executed until a Client Asset Account is opened and cleared funds have been deposited in accordance with these Terms of Use.
• Where ZebPay is required under applicable law and regulations to report transactions with the Client to a Competent Authority or otherwise, the Client must obtain and provide ZebPay with any information as ZebPay may require. The Client shall not be permitted to place orders unless and until it has provided the information required.
• In order to open a Client Asset Account, the Client must fully complete the registration process.
• ZebPay is obliged to carry out all the searches and enquiries that ZebPay deems to be appropriate to assess the Client’s identity and/or to carry out any anti money laundering controls which may be required under the AML Act or AML Regulations, as may be applicable, or its AML Policy. This information may be also used for the prevention of money laundering or terrorism financing as well as for the management of the Client Asset Account. The Client authorises ZebPay to use the information to perform the above checks in relation to this Agreement.
• The identity verification information which may be requested can generally include but not limited to:
  • Full Name
  • Email Address,
  • Contact Information
  • Nationality
  • Telephone Number
  • Username
  • Government Issued ID/Passport
  • Date of Birth
  • Proof of address
  • Bank account details
  • Information on the User’s trades
  • Photographs and images.
• In providing the above mentioned information, the Client confirms that the information provided is accurate and authentic. Pursuant to registration, the Client must guarantee that the information is truthful, complete and updated in a timely manner inclusive of any change. If there is any reasonable doubt that any information provided by you is wrong, untruthful, incorrect, outdated or incomplete, ZebPay shall have the right to send you a notice to demand corrections, remove relevant information directly, suspend use of the Client Asset Account and, as the case may be, terminate all or part of ZebPay Service to the Client.
• The Client shall be solely and fully responsible for any loss or expenses incurred by the Client during the use of ZebPay Service if the Client cannot be reached through the contact information provided by the Client.
• The Client hereby acknowledges and agrees that he/she has the obligation to keep all information provided to ZebPay up to date and make any changes if required.
• ZebPay may or may not accept an application to become a Client in its absolute discretion, including if the Client fails to pass the relevant appropriateness checks. If the Client application is accepted by ZebPay, the Client shall be notified of its Client Asset Account.
• The Client may only start trading and/or exchanging with ZebPay on the ZebPay Platform after the initial deposit of fiat or Digital Payment Tokens is credited to the Client Asset Account and such deposit has been cleared.
• ZebPay shall be authorised to act upon any digital instructions transmitted by the Client. In this connection, ZebPay shall be entitled to carry out any instructions or orders as per the Client’s instructions.
• The Client may request ZebPay to make payments by debiting the Client Asset Account to the extent cleared funds are available at the time of the request (electronically via the ZebPay Platform)
• The initial deposit and any additional funds deposited by the Client (together, Client Deposits) shall be credited to the Client as the case may be, subject to the following conditions: (i) The Client is required to transfer Client Deposits to ZebPay only from the Client’s bank account registered with ZebPay. ZebPay does not accept Client Deposits from any other bank account of the Client or any third party account. (ii) ZebPay does not accept Client Deposits in cash.
• Any crediting or debiting of Client Deposit Money to or from the Client Asset Account is net of any bank fees, commissions or other charges or costs (including any applicable taxes, including withholding taxes) and you hereby expressly authorise ZebPay to make any such deductions.
• ZebPay may receive interest in respect of the Client Asset Account but will not pay any portion of such amounts to the Client. The Client hereby waives any right to receive interest on any positive balance of Client Deposits on the Client Asset Account.
• The Client Asset Account shall be denominated in Singapore dollars (‘Base Currency’) by default.
• All gains, earnings, losses, costs and liabilities made or incurred by the Client under or in relation to any Digital Payment Token or any service provided by ZebPay or otherwise in connection with this agreement (including any fees charged by ZebPay) shall be credited or debited to the Client Asset Account, as applicable.
• The Client hereby expressly authorises ZebPay to deduct any such amounts from any Client Deposits held in the Client Asset Account by ZebPay on the Client’s behalf.
• The Client may, at any time, withdraw funds (‘Withdrawn Funds’) from the Client Asset Account by submitting a request to ZebPay (‘Withdrawal Request’). The amount requested must be available in Client Asset Account. ZebPay may, at its discretion, elect to withhold payment (or deduct an amount from it, as applicable) if:
  • (i) ZebPay is required by applicable law or regulations to deduct or withhold such payment; or
  • (ii) there is an unresolved dispute between ZebPay and the Client in connection with this agreement or any related contract in respect of such funds.
• ZebPay will only pay Withdrawn Funds to the Clients registered bank account unless the Client has notified a change in their payment details in writing in advance and this is in compliance with applicable law and regulations, in particular anti-money laundering controls.
• The Client shall make Client Deposits and submit withdrawal requests to ZebPay using the deposit or withdrawal function on the ZebPay Platform. The Client shall be solely responsible for the safekeeping of the Client Asset Account and password/ PIN and the Client will be responsible for all activities relating to the Client’s logins sessions and password/PIN.
• (w) The Client hereby covenants that the Client:
  • (i) will not share its login details or password/PIN details with any third party;
  • (ii) will notify ZebPay immediately if the Client is aware of any unauthorised use of the Client Asset Account or the Client login or password/ PIN by any person if there is reason to believe that the User’s security has been violated;
  • (iii) will strictly observe the security, authentication, dealing, charging, withdrawal mechanisms or procedures of the ZebPay Platform; and
  • (iv) will log out from the ZebPay Platform by taking proper steps at the end of every visit/session.
• ZebPay will not be responsible for any loss or consequences caused by the Client’s failure to comply with the above terms and conditions.

• The Client represents and warrants to ZebPay that:
  • (i) The Client’s conduct will not be in violation of the law, public interests, public ethics or other’s legitimate interests,
  • (ii) the Client will not evade the payment of taxes or fees and will not violate this agreement or relevant laws and rules ;
  • (iii) all information supplied by the Client to ZebPay is complete, true, accurate and not misleading or deceptive in any regard;
  • (iv) if the Client is an individual, the Client is at least 18 years old;
  • (v) if the Client is a body corporate, unincorporated association, trust or other legal entity, the Client is validly existing in accordance with applicable law and regulations;
  • (vi) the Client has entered into this agreement and will enter into any transaction on the ZebPay Platform as a principal and not as another person’s agent or representative;
  • (vii) the Client is not subject to any law or regulation preventing it from entering into this agreement or transactions on the ZebPay Platform. In this regard, the Client is not a resident of any other jurisdiction where it may be unlawful to access the ZebPay Platform or trade with ZebPay;
  • (viii) the Client has obtained all necessary consents, licenses and authorisations and has full power and authority (in accordance with its constitutional and organisational documents, where relevant) to enter into this agreement and all transactions on the ZebPay Platform;
  • (ix) the Client will comply with all laws and regulations to which the Client is subject in relation to this agreement and any transaction contemplated by this agreement including, without limitation, all tax laws and regulations, exchange control requirements and registration requirements;
  • (x) this agreement and any transaction entered into thereunder create valid and binding obligations which are enforceable against the Client in accordance with their terms including in the jurisdiction in which the Client is resident and do not violate the terms of any law, regulation, order, charge, agreement or instrument by which the Client is bound or to which the Client’s assets are subject;
  • (xi) the Client is fully aware of the financial and other risks involved with trading in Digital Payment Tokens under this agreement and is willing and financially able to sustain a total loss of funds resulting from the trading and transactions entered into on the ZebPay Platform;
  • (xii) the Client has consistent and uninterrupted access to the internet and the email address, mobile number provided to ZebPay during the application procedure;
  • (xiii) the Client will act in accordance with applicable law and regulations regarding market abuse, manipulation or misconduct, insider trading or dealing and similar offences, as applicable;
  • (xiv)the Client will not alter, distort or otherwise manipulate the relevant market or underlying in relation to a transaction entered into under this agreement;
  • (xv) the Client will promptly notify ZebPay of the occurrence of any event of default or potential event of default or any other breach of this agreement; and
  • (xvi) the Client will not use the ZebPay Platform for the purpose of obtaining, processing, distributing, viewing, assessing, analysing, copying or replicating any information, methods or processes related to the ZebPay Platform (including without limitation by way of data scraping, the use of collection or accumulation tools and robotic or scripted responses);
  • (xvii) the Client will not reverse engineer, disassemble or otherwise attempt to construct, copy or replicate the ZebPay’s source code, formulas or processes;
  • (xviii) the Client will not interfere with the security of the ZebPay Platform or the safe use of the ZebPay Platform by others (including without limitation by way of distributing viruses, corrupted files or other similar software or programs that may damage the operation of any computer hardware or software or which are otherwise directed at the ZebPay Platform or its users);
  • (xix) the Client will not use the ZebPay Platform for any purpose that is unlawful or prohibited or in a way which infringes the intellectual property rights or other rights of any person (including us);
  • (xx) the Client will not knowingly or recklessly use and/or take advantage of a technical or technological error, loophole or glitch on ZebPay’s Platform;
  • (xxi) the Client will not use the ZebPay Platform or the information contained in it for commercial purposes which are competitive to the ZebPay Platform or our business or which would otherwise be detrimental or prejudicial to ZebPay’s interests in any way;
  • (xxii) the Client will not use systematic, repetitive or other related methods which are designed to generate or obtain repetitive and repeated amounts of data or other information from or to the Platform or which may otherwise place an unreasonable load on the infrastructure of the Platform;
  • (xxiii) the Client will not se publish, post, distribute, disseminate or send ‘spam material’ or engage in any communication that is offensive, false, unlawful, defamatory, indecent, unfair or inappropriate in any way to others, which would reasonably be considered ‘spam’ or which is deliberately false, misleading, or deceptive (or likely to mislead or deceive);
  • (xxiv) the Client will not collect or store personal data about other users of the ZebPay Platform; or
  • (xxv) the Client will not do anything else which may interfere with or negatively affect the operation of the ZebPay Platform or others users.
• If the Client violates any of the provisions of this Agreement and thereby causes any legal consequence, the Client shall independently undertake all of the legal liabilities in the Client’s own name and indemnify ZebPay from all actions, claims, losses or costs arising from such violation;
• The Client will not use any data or information displayed on the ZebPay Platform for commercial purposes without the prior consent of ZebPay.
• The Client will use the ZebPay Platform in accordance with these Terms of Use and the Privacy Policy, without taking acts of unfair competition nor attempting to intervene with the normal operation of ZebPay. Examples of such malicious acts include, but are not limited to:
  • (i) using a device, software or subroutine to interfere with the ZebPay Platform;.
  • (ii) overloading network equipment with unreasonable data loading requests;.
  • (iii) executing malicious sales or purchases on the market.
• By accessing the ZebPay Service, the Client agrees that ZebPay shall have the right to unilaterally determine whether the Client has violated any of the above covenants and take action without receiving the Client’s consent or giving prior notice to the Client. Examples of such actions include, but are not limited to:
  • (i) block and close order requests;
  • (ii) freezing your Client Asset Account;
  • (iii) reporting the incident to authorities;
  • (iv) publishing the alleged violations and actions that have been taken;
  • (v) deleting any information you published that is in violation.
• The Client consents to the ZebPay Platform’s KYC checks and procedures and under no circumstance may ZebPay refund any money or grant access to the ZebPay Platform before all necessary procedures have been vetted and consent is formally authorised for the Client to access the ZebPay Platform.
• Without prejudice to the aforesaid, any funds which are kept in the Client Asset Account will be ‘frozen’ until the relevant procedures are completed and under no circumstance may they be ‘exchanged’ or ‘withdrawn’.
• If the Client’s alleged violation causes any losses to a third-party, the Client shall solely undertake all the legal liabilities in the Client’s own name and hold ZebPay harmless from any loss, fine or extra expenses. If, due to any alleged violation ZebPay incurs any losses, is claimed by any third party for compensation or suffers any punishment imposed by any administrative authorities, the Client will indemnify ZebPay against any losses and expenses caused thereby, including legal fees on a full indemnity basis.
• The Client acknowledges and agrees that the above representations and warranties have been a material inducement to the decision of ZebPay to enter into this agreement with the Client.
• In case of any abnormal behaviour, fluctuation or delay in transactions beyond ZebPay’s control, then for such instances ZebPay shall not be liable to the Client.

• For Users contracting with Genie – Any Dispute arising out of or in connection with these Terms of Use, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The venue and seat of arbitration shall be Singapore. The arbitration proceedings shall be conducted in English language. The arbitral award shall be substantiated in writing.
• For Users contracting with Awlencan -Except where interim or urgent interlocutory relief is sought, prior to the commencement of any legal proceedings, whether in a court or by way of arbitration, the parties agree to use reasonable endeavours to resolve a Dispute in accordance with this clause.
  If a party considers that a Dispute exists, then that party must give written notice to the other party that it considers a Dispute exists specifying the Dispute, including any event, matter or omission that the party relies on as giving rise to the Dispute.
  If the Dispute is not resolved within 10 Business Days of the above notice (Resolution Period), either party may refer a Dispute to mediation no later than 10 Business Days after the end of the Resolution Period.
  Any Dispute referred to mediation:
  • must be conducted in accordance with the Resolution Institute Mediation Rules and:
  • must be conducted by a mediator agreed on by the disputing parties; or
  • if the disputing parties are unable to agree on a mediator within five Business Days of the date of the referral to mediation, be conducted by a mediator appointed by the then current chair or acting chair of the Resolution Institute following a request from any of the disputing parties.
  • The role of any mediator is to assist in negotiating a resolution of the Dispute within 45 days of his or her appointment (Mediation Period).
  • If the Dispute is not resolved by the disputing parties during the Mediation Period, then any of the disputing parties may refer the Dispute for determination by arbitration no later than five Business Days after the end of the Mediation Period.
  • Any Dispute or difference whatsoever, not resolved by the disputing parties during the Mediation Period, arising out of or in connection with this Terms of Use or the performance or non-performance of the obligations of the parties under it shall be submitted to arbitration in accordance with, and subject to, the Resolution Institute Arbitration Rules. The parties agree that an award made by the arbitrator under this clause will, in the absence of manifest error, be binding on the parties.
  Any Dispute referred to Arbitration:
• The cost of any mediator, arbitrator or both will be shared equally between the parties.
• The disputing parties will each bear their own costs of any mediation.
• Subject to any award of costs made by the arbitrator, the disputing parties will each bear their own costs of any arbitration.
• If no party refers the Dispute to mediation or arbitration under this clause, then the parties may commence legal proceedings in respect of the Dispute.
• The existence of a Dispute does not excuse any party from performing its respective obligations under this agreement (except those in respect of which the Dispute exists).
• Failure by a party to a Dispute to comply with this clause may be pleaded in bar to the continuance of any proceeding initiated by that party until this clause has been complied with.

ZebPay grants you a non-exclusive, revocable, non-transferable licence to use the software on a server controlled by us for the sole purpose of accessing and obtaining the material on the ZebPay Platform.

• Liability ZebPay will provide access to the ZebPay Platform on an “as is” and “commercially available” condition and to the maximum extent permitted by law does not offer any form of warranty with regards to the ZebPay Platform’s reliability, stability, accuracy and completeness of the technology involved. The ZebPay Platform serves merely as a venue of transactions where Digital Payment Token information can be acquired, and Digital Payment Token transactions can be conducted.
• ZebPay cannot control the quality, security or legality of the Digital Payment Tokens in any transaction, truthfulness of the transaction information, or capacity of the parties to any transaction to perform their obligations. The Client must carefully consider the associated investment risks, legal status and validity of the transaction information and investment decisions prior to your use of the ZebPay Platform.

• Release of ZebPay Liability
  • (i) If you have a dispute with one or more users of the ZebPay Platform, you agree that neither we nor our affiliates or service providers, nor any of our respective officers, directors, agents, joint venturers, employees and representatives will be liable for any claims, demands and damages (actual and consequential) of any kind or nature arising out of or in any way connected with such disputes.
  • (ii) ZebPay will not be liable for any loss caused to the User due to discontinuation of any cryptocurrency that is being offered through the ZebPay Platform.
  • (iii) ZebPay shall not be liable for any disruption of service, whereby the User is denied access to their cryptocurrencies, including those stored on the Client Asset Account.
  • (iv) ZebPay shall not be liable for any loss caused to the User through loss of any cryptocurrency stored on the User’s Client Asset Account for any reason whatsoever, save and except due to a wilful and malicious commission or omission by ZebPay directly resulting in such loss.
  • (v) ZebPay shall not be liable for any discontinuation, alteration, suspension or termination of any part of the services offered on the ZebPay Platform caused or occasioned any Force Majeure event or any change in applicable Law with respect to cryptocurrencies.
  • (vi) ZebPay shall not be liable for any loss caused to User due to fluctuations in the price of cryptocurrencies. ZebPay does not guarantee profits from sale or purchase or transfers of cryptocurrencies. ZebPay shall not be liable for any loss caused to User for suspension, cancellation or termination of a User account, including on account of a violation by such User violations of any of the terms of this agreement, the Privacy Policy or any applicable Law. The User agrees that ZebPay will not be liable to User or to any third party for termination of the User account or for restricting access to the ZebPay Platform, which shall be at the sole discretion of ZebPay.
  • (vii) The User shall not be entitled to any damages for any reason whatsoever including for consequential or compensatory damages against ZebPay for any reasons including suspension, cancellation or termination of the User account or for cessation of any or all services on the ZebPay Platform. The User shall only be entitled to refund / recovery of the cryptocurrencies credited to the Client Asset Account, subject to deductions of amounts owed to ZebPay and other legal, regulatory or statutory dues or those stipulated under applicable law, and to the permissibility of such refund or recovery under applicable law.
  • (viii) In the event that any cryptocurrencies stored in any Client Access Account are seized, or ZebPay is unable to access or return the same to User, ZebPay shall not be held liable or responsible for the same. The User is cautioned to avail itself of the ZebPay Platform subject to the above risk. At no point in time will ZebPay, its directors, shareholders, employees, representatives, officers, affiliates or assigns be held liable for any claims whatsoever for cessation of services or termination of any part of the ZebPay Platform or any disruption with respect to access to any Client Asset Account.
  • (ix) All claims by a User shall be limited to the cryptocurrencies and fiat in the relevant Client Asset Account, subject to the above mentioned conditions.
  • (x) To the maximum extent permitted by law, THE MAXIMUM CUMULATIVE LIABILITY OF ZEBPAY IN ANY EVENT, FOR ANY CLAIM, DAMAGES, TORT SHALL BE LIMITED TO THE CRYPTOCURRENCIES ACTUALLY RECEIVED FROM THE USER, AS CONSIDERATION OR FEES FOR THE SERVICES RENDERED BY ZebPay IN RELATION TO THE APPLICABLE TRANSACTION TO WHICH THE CLAIM RELATES. IF THE CLAIM DOES NOT RELATE TO ANY TRANSACTION IN PARTICULAR, THEN ZEBPAYS MAXIMUM CUMULATIVE LIABILITY SHALL BE LIMITED TO THE CRYPTOCURRENCIES ACTUALLY RECEIVED FROM THE USER, AS CONSIDERATION OR FEES FOR THE SERVICES RENDERED BY ZEBPAY IN RELATION TO THE TWO TRANSACTIONS IMMEDIATELY PRECEDING THE DATE ON WHICH THE CLAIM IS MADE BY THE USER .
• (b) No Liability for BreachZebPay will not be liable for any breach of these Terms of Use, where the breach is due to abnormal and unforeseeable circumstances beyond ZebPay’s control, the consequences of which would have been unavoidable despite all effects to the contrary, nor is ZebPay liable where the breach is due to the application of mandatory legal requirements.
• (c) Limitation of lossIn addition to the liability cap above, in no event shall ZebPay, our affiliates or our service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any of the following types of loss or damage arising under or in connection with this agreement or otherwise:
  • (i) any loss of profits or loss of expected revenue or gains, including any loss of anticipated trading profits and / or any actual or hypothetical trading losses, even if we are advised of or knew or should have known of the possibility of the same;
  • (ii) any loss of or damage to reputation or goodwill; any loss of business or opportunity, customers or contracts; any loss or waste of overheads, management or other staff time; or any other loss of revenue or actual or anticipated savings, even if we are advised of or knew or should have known of the possibility of the same;
  • (iii) any loss of use of hardware, software or data and / or any corruption of data; including but not limited to any losses or damages arising out of or relating to any inaccuracy, defect or omission of digital currency price data; any error or delay in the transmission of such data; and / or any interruption in any such data;
  • (iv) any loss or damage whatsoever which does not occur directly from our breach of this agreement; and/or
  • (v) any loss or damage whatsoever which is in excess of that which was caused as a direct result of our breach of this agreement (whether or not you are able to prove such loss or damage).

The Client agrees to indemnify and hold harmless ZebPay, its affiliates, contractors, licensors, and their respective directors, officers, employees and agents from and against any claims and damages (including legal fees, fines or penalties imposed by any regulatory authority) arising out of the Client’s breach or our enforcement of this agreement or (including with limitation your breach of the Privacy Policy, AML Policy or any other restrictions on use of ZebPay services) or your violation of any law, rule or regulation, or the rights of any third party . This shall also apply to the Client’s violation of any applicable law, regulation, or rights of any third party during your use of the ZebPay Services.

• The Client agrees that we have the right to immediately suspend the Client Asset Account (and any accounts beneficially owned by related entities or affiliates), freeze or lock the funds in all such Client Asset Accounts, and suspend access to ZebPay if we suspect any such Client Asset Accounts to be in violation of these Terms of Use, Privacy Policy, AML Act, AML Regulations, as may be applicable. or any applicable laws and regulations.
• ZebPay shall have the right to keep and use the transaction data or other information related to such Client Asset Accounts. The above account controls may also be applied in the following cases but not limited to:
  • (i) the Client Asset Account is subject to a governmental proceeding, criminal investigation or other pending litigation;
  • (ii) we detect unusual activity in the Client Asset Account;
  • (iii) we detect unauthorized access to the Client Asset Account;
  • (iv) we are required to do so by a court order or command by a regulatory/government authority;
  • (v) we reasonably suspect you of acting in breach of this Agreement;
  • (vi) we suspect money laundering, terrorist financing, fraud, or any other financial crime;
  • (vii) Use of your Client Asset Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your account activity;
  • (viii) we take any action that may circumvent our controls such as opening multiple accounts or abusing promotions which we may offer from time to time.
• In case of any of the following events, ZebPay shall have the right to directly terminate this agreement by cancelling the Client’s Asset Account, and shall have the right to permanently freeze (cancel) the authorisations of the Client’s Asset Account and withdraw the corresponding Client account:
  • (i) after ZebPay terminates services to the Client,
  • (ii) the Client allegedly registers or registers in any other person’s name as ZebPay User again, directly or indirectly;
  • (iii) the main content of User’s information that the Client has provided is untruthful, inaccurate, outdated or incomplete;
  • (iv) when this agreement) is amended, the Client expressly states and notifies ZebPay of the Client’s unwillingness to accept the amended terms of use;
  • (v) any other circumstances where ZebPay deems it should terminate the services.
• Should the Client Asset Account be terminated, the account and transactional information required for meeting data retention standards will be securely stored for five (5) years. In addition, if a transaction is unfinished during the account termination process, ZebPay shall have the right to notify the Client’s counterparty of the situation at that time.
• Subject to clause 20(f), once the Client Asset Account is closed/withdrawn, all remaining balances (which includes charges and liabilities owed to ZebPay) on the account will be due and payable to ZebPay. Upon payment of all outstanding charges to ZebPay (if any), the User will have the reasonable time to withdraw all funds from the account.
• ZebPay maintains full custody of the funds and User data/information which may be turned over to the authorities in event of account suspension/closure arising from fraud investigations, AML investigations or violation of the law or ZebPay’s Terms of Use (e.g. trading on ZebPay from a sanctioned country).

• It is the responsibility of the User to abide by local laws in relation to the legal usage of ZebPay Services in their local jurisdiction. Users must also factor, to the extent of their local law all aspects of taxation, the withholding, collection, reporting and remittance to their appropriate tax authorities.
• All users of the ZebPay Platform and any of its services acknowledge and declare that the source of their funds come from a legitimate manner and are not derived from illegal activities. ZebPay maintain a stance of cooperation with law enforcement authorities globally and will not hesitate to seize, freeze, terminate the Client Asset Account and funds of Users which are flagged or investigated by legal mandate.

• ZebPay Services are offered only on the digital domain, which is subject to risks including offensive attacks. ZebPay shall not be liable for any loss caused to the User’s account or the monies or cryptocurrencies accrued therein if the same arises due to any Force Majeure event, including commissions or omissions by third parties, forces of nature, offensive attacks on ZebPay servers or on the personal devices of the Users, changes in applicable law, or any loss caused by conditions or events beyond the reasonable control of ZebPay.
• The above limitation on liability includes any Force Majeure event set out hereunder including acts of god; fire, act of terrorists, act of civil or military authorities, civil disturbance, war, strike or other labour dispute, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond reasonable control of ZebPay; offensive attacks including virus attack, hacking, denial of service attack or theft of the personal devices of the User resulting in loss to the account.
• To the maximum extent permitted by law ZebPay shall not be liable for any loss caused to User due to a data breach of confidential information of the User, including of the User account details or User password, including when such breach has occurred due to the User sharing such details with third parties or due to the User’s failure to follow reasonable due diligence. ZebPay shall also not be liable or responsible for any disclosure by User of any User account details, including on account of a phishing attack or other third-party disruption.

• ZebPay processes all personal information in accordance with applicable law and regulations relating to the processing, privacy, and use of personal information.
• ZebPay may collect, hold and process personal information about the Client from the way in which the Client engages with ZebPay (such as by filling in the application, placing orders, or if the Client contacts ZebPay by post, email, telephone, in person or by any other means), through the Client’s interactions with ZebPay and/or the ZebPay Platform.
• Details of the types of personal information which ZebPay collects, holds or processes are set out in ZebPay’s Privacy Policy,
• ZebPay relies on the following legal basis to process and use the Client’s personal information:
  • (i) processing is necessary for the performance of the ZebPay Services provided to the Client under this agreement;
  • (ii) processing is necessary for the purposes of ZebPay’s legitimate business interests, including administering the relationship with the Client and/or analysing, improving and developing its trade, products and services. [For a more detailed overview of the legitimate business interests of ZebPay’s please refer to the relevant section of the aforesaid Privacy policy]; and
  • (iii) processing is necessary for compliance with a legal obligation to which ZebPay is subject as better identified in ZebPay’s Privacy Policy.
• The Client’s personal information may be disclosed to service providers and other suppliers (including those outside of Singapore and Australia) provided that any such transfer or access is compliant with the Personal Data Protection Act 2012 and Privacy Act 1998 respectively and is subject to appropriate contractual provisions relating to data protection and confidentiality. Further details as to where the Client’s personal information may be transferred or accessed and the basis for such transfers are set out in the Privacy Policy.
• ZebPay has security procedures covering the storage and disclosure of the Client’s personal information to prevent unauthorised access of any Client personal information and to comply with the Personal Data Protection Act 2012 (Singapore) and Privacy Act 1998 (Australia).
• Neither party may disclose to any person any information relating to the business, investments, finances or other matters of a confidential nature of the other party of which it may come into possession in connection with this agreement and its performance by the other party, and each party shall use all reasonable endeavours to prevent such disclosure, except as may be required by any applicable law, rule or regulatory, law enforcement or tax authority.
• For the avoidance of doubt, ZebPay may be required to disclose information to third parties in order to carry out fraud-checks and for KYC procedures, and the Client expressly consents to such disclosure.

If the Client has any complaints, feedback or questions, the Company may be contacted via https://help.zebpay.com and we will in our best efforts try to resolve the issue with expediency. ZebPay shall not provide any support services to walk-in users.

• InterpretationIn this clause, words and expressions defined in the A New Tax System (Goods and Services Tax) Act 1999 (Cth) (GST Act) have the meaning given to them in the GST Act.
• Consideration does not include GSTAll amounts payable or consideration to be provided under or in connection with this agreement, do not include an amount for GST.
• Recovery of GSTIf GST is or becomes payable on any supply made under or in connection with this agreement, the party required to provide the consideration for the supply must pay, in addition to and at the same time as the consideration is provided, an amount equal to the amount of GST on the supply.
• ReimbursementsWhere a party is required under this agreement to reimburse or indemnify another party for any loss or amount, the amount to be reimbursed or paid will be reduced by any input tax credit that the other party is entitled to claim.

Any payment to be made under these Terms of Use must be made by one of the following methods:

• (a) a bank draft or a bank cheque;
• (b) by credit of cleared funds to the bank account specified by the payee at least 3 Business Days before the anticipated date of the payment; or
• (c) any other lawful form of payment that the parties agree in writing.

Any payment to be made under these Terms of Use must be made by one of the following methods:

• Unless these Terms of Use expressly state otherwise, a notice, consent, approval, waiver or other communication (notice) in connection with this agreement must be in writing. A notice may be given by hand delivery, prepaid post, or by electronic message to the recipient’s physical address or email address as advised from time to time.
• A notice given under this clause will be deemed to be received:
  • (i) if hand delivered, at the time of delivery;
  • (ii) if sent by prepaid post, three Business Days after the date of posting or seven Business Days after the date of posting if posted to or from a place outside Singapore;
  • (iii) if sent by electronic message, when the sender receives an automated message confirming delivery or eight hours after the message has been sent (as recorded on the device from which the sender sent the message) unless the sender receives an automated message that the electronic message was not delivered or the sender knows or reasonably should know that there is a network failure and accordingly knows or suspects that the electronic message was not delivered,

unless a notice is received after 5.00 pm on a Business Day in the place of receipt or at any time on a non Business Day, in which case, that notice is deemed to have been received at 9.00 am on the next Business Day.

Any payment to be made under these Terms of Use must be made by one of the following methods:

A party may not assign or otherwise deal with any of its rights or obligations under these Terms without the prior written consent of the other party, and such consent must not be unreasonably withheld . However, ZebPay may, without the consent of the User assign its rights and obligations under this agreement in the case of the sale of all or part of the ZebPay Platform; and may assign its rights and obligations under this agreement to any affiliate Zebpay company in any event.

These Terms of Use may only be amended or varied at any time by ZebPay. If user does not accept such modification he/she immediately cease to use the service.

• No failure to exercise or delay in exercising any right given by or under this agreement to a party constitutes a waiver and the party may still exercise that right in the future.
• Waiver of any provision of this agreement or a right created under it must be in writing signed by the party giving the waiver and is only effective to the extent set out in that written waiver.

By giving its approval or consent about any matter dealt with in this agreement, a party does not make or give any warranty, representation or undertaking about any circumstances relating to the subject matter of the consent or approval.

If any provision of this agreement is void, voidable by a party, unenforceable, invalid or illegal and would not be so if a word or words were omitted, then that word or those words are to be severed and if this cannot be done, the entire provision is to be severed from this agreement without affecting the validity or enforceability of the remaining provisions of this agreement.

On completion or termination of the transactions contemplated by this agreement, the rights and obligations of the parties set out in this agreement will not merge and any provision that has not been fulfilled remains in force.

Each party agrees to promptly do all things reasonably necessary or desirable to give full effect to these Terms of Use, including obtaining consents and signing documents.

Time is of the essence of these Terms of Use.

These Terms of Use contain the entire agreement between the parties about their subject matter and supersede all previous communications, representations or agreements between the parties on the subject matter.

• For Users contracting with Genie – These Terms of Use are governed by the laws of Singapore and subject to the agreement to arbitrate, as stated above, the parties submit to the non-exclusive jurisdiction of the courts of Singapore in connection with these Terms of Use.
• For users contracting with Awlencan – These Terms of Use are governed by the laws of Victoria Australia and subject to the agreement to arbitrate, as stated above, the parties submit to the non exclusive jurisdiction of the courts of Victoria and the Federal Court of Australia and any courts that may hear appeals from those courts about any proceedings in connection with these Terms of Use.

1.1 “Applicable Law” means the law in force for the time being within the territory of Australia, but also includes GDPR for those customers resident in the European Union .

1.2 ‘AML’ means ‘Anti-Money Laundering’, and in this connection, the applicable legislation shall be the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) and other regulatuions made under the aforementioned Act from time to time

1.3 “ZebPay Platform” shall mean and include ZebPay Android App, ZebPay iOS App (collectively, “ZebPay App”) or ZebPay Web app (“Web version”) and ZebPay website “www.zebpay.com” (“ZebPay Website”). Collectively along with the ZebPay Developer Portal, Public APIs and secure authentication for ZebPay Users is referred to as the “ZebPay Platform”.

1.4 “GDPR ” means REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (‘General Data Protection Regulation’).

2.1 ZebPay is committed to ensuring the safety and protection of all data and information shared with ZebPay by its Users in accordance with Applicable Laws and the terms and conditions set out hereunder and processes established by ZebPay in compliance with the applicable reasonable security practices and procedures, prescribed by Government or Regulatory authorities, as the case may be.

2.2 ZebPay shall not be liable for any breach or violation of its systems or policies due to malicious attacks, errors, commissions or omissions not willfully initiated by ZebPay, leading to breach of data or information of User.

3.1 Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you.

3.2 We can ask you to provide personal information anytime you are in contact or consuming ZebPay Platform. ZebPay group of companies may share your personal information with each other and use it consistently with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content. Except as described in this Privacy Policy, ZebPay will not sell, rent or loan any personal Information to any third party.

How to contact ZebPay for data protection inquiries:

4.1 We have endeavored to nominate an independent Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set-out below.

4.2 ZebPay may collect required personal data and information of the User to provide its services. Use of the ZebPay Platform is contingent upon acceptance of the terms and conditions contained herein. User shall be deemed to have volunteered the data and information collected, retained, used and disseminated by ZebPay, upon accepting the terms herein and those contained in the Terms of Service and User agreement of ZebPay.

4.3 ZebPay processes your personal data and information of the User in accordance with the guidelines laid by Applicable Laws. Personal data’ means any information or opinion relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, which can include (but is not limited to) data concerning that person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record that is also personal information, health information about an individual, genetic information about an individual that is not otherwise health information, biometric information that is to be used for the purpose of automated biometric identification or verification, and biometric templates.

4.4 ZebPay collects your personal information to provide our Services. ZebPay ensures that your personal data is processed lawfully, fairly and in a transparent manner and is collected for specified, explicit and legitimate purposes shared with you. Any information you provide to us that is not required, is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all our Services when you do choose not to share certain information with us. We may collect the following types of information provided / shared by the User as applicable for

1) Personal Identification Information : Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, national ID proof, home address, and/or email.

Why we collect this information

• To complete your user profile and process your registration request on ZebPay Platform allowing you to enter into a contract with us.
• To provide ZebPay products, services and support and enhance the performance of our contract with you.
• To communicate with you about your account and our services, including informing you of changes to our fees and our terms and conditions related to our services.
• to conduct market research and analysis eg. surveying our Users’ needs and opinions on issues, such as our performance;
• For Managing services including your account with us.
• For sending customized offers to you if you have consented to receive our offers.
• To deal with enquiries, complaints, and feedback from you and our service providers.
• To communicate with you regarding your account and our services.
• To maintain legal and regulatory compliance.

2) Recognized Identification Information : Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.

Why we collect this information

• To complete your user profile and Verify your registration request on ZebPay Platform allowing you to enter into a contract with us.
• To complete KYC (Know your customer) form to complete the regulatory requirements of Trading.
• To ensure that our customers are genuine and preventing Identity theft.
• To detect any Fraud, Anti national activity, Money Laundering and Criminal Activities.
• To prevent anti national and terrorist finances and protect our users and business from any threat or Damage.

3) Monetary Information : Bank account information,Credit or Debit Card Number, transaction history, trading data, and/or tax identification.

Why we collect this information

• To maintain legal and regulatory compliance.
• To provide ZebPay products, services and support and enhance the performance of our contract with you.
• To detect any fraud, anti national activity, money laundering and criminal activities.
• To prevent anti national activity and terrorist finances and protect our users and business from any threat or Damage
• To ensure that our customers are genuine and preventing Identity theft.

4) Transaction Information : Information about the transactions by using ZebPay Platform, such as the name of the recipient, digital currency address, your name, the amount, and/or timestamped.

Why we collect this information

• To provide ZebPay products, services and support and enhance the performance of our contract with you.
• To facilitate transactions of users
• To detect any fraud, anti national activity, money laundering and criminal activities.
• To prevent anti national activity and terrorist finances and protect our users and business from any threat or Damage
• To maintain legal and regulatory compliance.
• To deal with enquiries, complaints, and feedback from you and our service providers.
• To provide you customer Service.
• To communicate with you regarding your account and our services.

5) Employment or Business Information : Office location, job title, and/or description of Business, role, etc.

Why we collect this information

• To complete your user profile and Verify your registration request on ZebPay Platform allowing you to enter into a contract with us.
• To complete KYC (Know your customer) form to complete the regulatory requirements of Trading.
• To ensure that our customers are genuine and preventing Identity theft.
• To detect any Fraud, anti national activity, money laundering and criminal activities
• To maintain legal and regulatory compliance.

6) Online Identifiers : User’s device information including but not limited to IMEI or equipment identification number, IMSI or subscriber identification, UUID, MAC address, OS version, device details, network operator, contact list information, Wi-fi / Data Network connectivity. Cookies Information generated by the User’s use of the app and the website, including cookies and IP addresses. Geolocation of a User’s device or such or other automatically collated data or information of User, please visit our Cookie Policy

Why we collect this information

• To ensure that our customers are genuine and preventing Identity theft.

7) Access to User’s Photo Gallery / Media / Files / Camera for using ZebPay Platform more efficiently.

Why we collect this information

• To complete your user profile and Verify your registration request on ZebPay Platform allowing you to enter into a contract with us.
• To allow you to upload KYC Documents, profile picture on ZebPay Platform.
• To provide you customer service.

8) Access to User’s apps and services including messaging through SMS; Storage data, device details;

Why we collect this information

• To complete your user profile and Verify your registration request on ZebPay Platform allowing you to enter into a contract with us.
• To read & auto-fill the OTP SMS so that we can verify your mobile number. This is helpful in your account verification (KYC).

9) Leave a message – We may collect your name, email id, mobile number, country, etc when you leave a message on our website.

Why we collect this information

• To provide ZebPay products, services and support and enhance the performance of our services.
• To inform you about ZebPay products, services or any other activities that ZebPay may undertake.

Depending on the purpose of our processing activity, the processing of your personal data will be based on one of the following:

• It is necessary for the legitimate interests of ZebPay, without unduly affecting your interests or fundamental rights and freedoms, to provide you with communications related to our products, services, promotions, offers and events. You have a right to opt-out of receiving marketing messages by clicking on the unsubscribe link at the bottom of our marketing emails or by using the personal settings in your user area;
• It is necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract;
• Required to meet our legal or regulatory responsibilities; or
• Processed with your explicit and free consent which we obtain from you from time to time.

Cookies

6.1 ZebPay uses cookies on its App and website to collect data about user. For a detailed policy on use and collection of Cookies, please visit our Cookie Policy

7.1 ZebPay may collect, use and share aggregated data to create anonymised statistical data. ZebPay may provide this statistical data to its business partners or third parties.

7.2 Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website / app feature.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

You are entitled to inform ZebPay at any time that your personal details have changed or otherwise request erasure of your personal data by emailing customer support at help@zebpay .com

7.3 We will only retain your personal data for as long as necessary to fulfil the purpose for which we have collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.

7.4 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

7.5 By law we have to keep basic information about our customers (including contract, identity, financial and transaction data) for seven (7) years after they cease being customers for online trading purposes.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. When you use this website or other services we provide to you, you may be able to link to other third-party websites, plug-ins and applications.

7.6 This Privacy Policy does not apply to those sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policies on such sites.

7.7 ZebPay uses cookies to gather information about your access to this website and other services we provide to you. Cookies are small pieces of information which use a unique identification tag and are stored on your device as a result of you using this website or other service we provide to you.

When cookies are used by us, they collect statistical and factual information about how you use our services. Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your computer notify you each time a cookie is sent to it, and thereby give yourself the choice whether to accept it or not. If you disable or refuse cookies, please note that some parts of this website may become inadmissible or not function properly and impair the quality of the services that we provide to you in relation to your account.

For more information about the types of cookies ZebPay uses, please refer to our specific Cookie Policy .

7.8 ZebPay protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

7.9 The retention period may be extended to comply with legal obligations, resolve disputes, and enforce agreements for a period of seven(7) years after termination of the account or such period, under applicable laws. ZebPay may retain data for further periods but is not obligated to do so in all instances. ZebPay shall not be liable or responsible for non – availability or non – retention of data or information beyond the termination of the User account.

7.10 The retention period may extend beyond the end of User account, but it will be only as long as it is necessary for ZebPay to have sufficient information to respond to any issues that may arise later, including but not limited to retention for the purpose of investigations or ongoing prosecutions or in case of Suspicious transactions or if ZebPay requires the information for its records or to support legal proceedings, or if ZebPay believes in good faith that a law, regulation, rule or guideline requires it.

7.11 Please note that ZebPay cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur and you play a vital role in protecting your own personal information as users while registering with ZebPay Platform, it is important to choose a password or PIN of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account

7.12 Likewise, ZebPay cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at [email protected]. ZebPay however takes all reasonable steps to secure data and information pertaining to its Users, including those prescribed under applicable laws and Rules framed thereunder.

7.13 We will keep information about visitors to our websites (not being customers) for a reasonable length of time, that lets us understand how people use our website and any technical issues they have.

7.14 We try to respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or you have a number of requests. In this case, we will notify you and keep you updated.

7.15 You have a right to make a complaint at any time to the Office of the Australia Information Commissioner (“OAIC”), the Australian supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the OAIC so please contact us or our DPO in the first instance at the email specified above.

8.1 The User shall ensure that all data and information shared with ZebPay is accurate, correct and complete. User shall ensure that change of the User’s address or any change in circumstances impacting use of the ZebPay Platform, is promptly communicated to ZebPay.

8.2 ZebPay will not be held liable or responsible for any incorrect information provided by the User to ZebPay.

8.3 User may, upon termination of the use of the ZebPay Platform, as provided in the Terms of Service, withdraw consent granted herein to ZebPay. The same shall however not affect actions undertaken or data and information collated, or technological processes initiated prior to such withdrawal of consent. Such withdrawal of consent shall also not affect retention of data and information collected prior to such withdrawal.

9.1 Where we use certain service providers which are not located in Australia, we may use specific contracts compatible with Applicable Laws which give your personal data the same protection it has in Australia (or the EU, in the case of our EU customers).

9.2 In all other instances, the User generally agrees and consents to ZebPay sharing the following anonymized data or to otherwise gives ZebPay permission to share its Data with third-parties for the following:

• For referral, operations, additional services and technology services (such as hosting providers, identity verification, support, payment, and email service providers) or;
• If required by applicable law or legal process, or if ZebPay believes that it is in accordance with applicable law or legal process; or
• To protect the rights, property and safety of ZebPay, its users and the public, including, including but not limited to usage in court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish its rights or defend against legal claims; or
• In connection with selling, merging, acquiring, transferring, or reorganizing all or parts of ZebPay’s business.

You have the following rights, which can be exercised by contacting us [email protected] so that we may consider your request under applicable law.

Right to withdraw consent – You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of ZebPay’s data processing based on consent before your withdrawal.

Right of access to and rectification of your personal information – You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated (if applicable) with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by ZebPay that is inaccurate.

Right to erasure [right to be forgotten] – You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. The above is subject to limitations by relevant data protection laws.

Right to data portability – If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible and once our platform interface allows for the ‘exportation’ of such data. In this connection, ZebPay is committed towards creating a robust function ensuring data portability in due course.

Without prejudice to the aforesaid, data portability will be prohibited if the requested migration of said data adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which alone or jointly with others, determines the purposes and means of the processing of your personal information.

Right to restriction or objections for processing – You have the right to restrict or object to us processing your personal information where one of the following applies:

You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.

The processing is unlawful, and you oppose the erasure of your personal information and request the restriction of its use instead.

We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.

You have objected to processing, pending the verification whether the legitimate grounds of ZebPay’s processing override your rights.

Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

Notification of erasure, rectification and restriction – We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves a disproportionate effort. We will inform you about those recipients if you request this information.

Right to object to processing – Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Automated individual decision-making, including profiling – You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

Right to lodge a complaint – If you believe that we have infringed your rights, we encourage you to contact us first at [email protected] , so that we can try to resolve the issue or dispute informally.

Your rights to personal information are not absolute. Access may be denied when:

• Denial of access is required or authorized by law;
• Granting access would have a negative impact on other’s privacy;
• Granting access would have a negative impact on other’s privacy;
• To protect our rights and properties; and Where the request is frivolous or vexatious

To Invoke or exercise any of your rights, please contact our Data Protection Officer (DPO) at: [email protected]

11.1 Protection of the User’s personal information is of utmost importance to ZebPay and it takes all reasonable steps to secure data and information pertaining to its Users, including those prescribed under applicable laws and Rules framed thereunder

11.2 ZebPay takes appropriate legal, administrative, physical, and reasonable electronic measures designed to protect the information that Users share with ZebPay

11.3 ZebPay however does not extend any warranties with respect to the security or safety of data and information transmitted through digital platforms or online, both of which are susceptible to malicious attacks.

These terms may be periodically reviewed and revised when required by law, or due to business reasons . we will notify you of changes to this Privacy Policy. The revised Policy will be uploaded on the ZebPay website and will reflect the modified date of the terms. Continued use of the ZebPay Platform constitutes agreement of User to the terms contained herein and any amendments thereto. ZebPay may for any important changes in the policy would send an email to the user’s registered email id.

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Services prior to the change becoming effective. ZebPay also encourages users to periodically visit our policies from time to time.

All other provisions of the ZebPay Terms of Service and user agreement shall be read along with this policy and shall form part hereof, including Governing Laws and jurisdiction, notices, severability, assignment and such or other provisions.

If you have questions, please contact our Data Protection Officer (DPO) at: dpo@zebpay .com

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device, which is like computer memory. First and third-party cookies: whether a cookie is ‘first’ or ‘third’ party refers to the domain placing the cookie.

• First-party cookies are those set by a platform that is being visited by the user at the time (e.g. cookies placed by our platform domain).
• Third-party cookies are cookies that are set by a domain other than that of the platform being visited by the user. If a user visits a platform and another entity sets a cookie through that platform, this would be a third-party cookie.

Persistent cookies: these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the platform that created that particular cookie. Session cookies: these cookies allow platform operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Generally, the platform uses cookies to distinguish you from other users of the platform. This helps us to provide you with a good experience when you browse the platform and also allows us to improve it. The cookies we may use on the platform may be categorized as follows:

• Strictly necessary
• Performance
• Functionality
• Targeting

Some cookies may fulfill more than one of these purposes. ‘Strictly Necessary’cookies let you move around the platform and use essential features like secure areas. Without these cookies, we cannot provide the requested services. We use these Strictly Necessary cookies to:

• Identify you as being logged in to the platform and to authenticate you
• Make sure you connect to the right service on the platform when we make any changes to the way it works
• For security purposes

If you prevent these cookies, we can’t guarantee how the platform or the security on the platform will perform during your visit. ‘Performance’ cookies collect information about how you use the platform, e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you and are only used to help us improve how the platform works, understand the interests of our users and measure the effectiveness of our advertising. We use performance cookies to:

• Carry out web analytics: Provide statistics on how the platform is used
• Perform affiliate tracking: Provide feedback to affiliated entities that one of our visitors also visited their site
• Obtain data on the number of users of the platform that have viewed a product or service
• Help us improve the platform by measuring any errors that occur
• Test different designs for the platform

Some of our performance cookies are managed for us by third parties. ‘Functionality’ cookies are used to provide services or to remember settings to improve your visit. We use ‘Functionality’ cookies for such purposes as:

• Remember settings you’ve applied such as layout, text size, preferences and colors
• Remember if we’ve already asked you if you want to fill in a survey
• Remember if you have engaged with a specific component or list on the platform so that it won’t repeat
• Show you when you’re logged in to the platform
• To provide and show embedded video content

Some of these cookies are managed for us by third parties. ‘Targeting’ cookies are used to track your visit to the platform, as well as other platforms, apps and online services, including the pages you have visited and the links you have followed, which allows us to display targeted ads to you on the platform. We may use targeting cookies to:

• Display targeted ads within the platform.
• To improve how we deliver personalized ads and content, and to measure the success of ad campaigns on the platform.

All cookies require your consent. We request your consent before placing them on your device. You can give your consent by clicking on the appropriate button on the banner displayed to you. If you do not wish to give consent or wish to withdraw your consent to any cookies at any time, you will need to delete, and block or disable cookies via your browser settings; see below for more information on how to do this. Please note that disabling these cookies will affect the functionality of the platform, and may prevent you from being able to access certain features on the platform.

Most web browsers allow some control of most cookies through the browser settings. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of the platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the platform. Changing your Cookie Settings. The browser settings for changing your cookies settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your internet browser for more details:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

More information. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

For any questions feel free to contact ZebPay’s Data Protection Officer at: dpo@zebpay .com

All terms defined in the Terms of Service and the Privacy Policy will carry the same meaning, force and effect in this AML Policy.

1.1 “Applicable Law” means all laws in force for the time being within the territory of the Australia, including (but not restricted to) the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (“AML/CTF Act”), the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) and other regulatuions made under the aforementioned Act from time to time.

1.2 “Designated Director” means a managing director or whole-time director of ZebPay who has been appointed and authorised to administer ZebPay’s anti-money laundering measures;

1.3 ‘AUSTRAC’ refers to the government agency responsible for the implementation of the AML/ CTF regime in Australia, for monitoring compliance with the relevant legislative provisions, and for the collection, collation, processing, analysis and dissemination of information with a view to combating ML and Funding of Terrorism.

1.4 Money-Laundering (“ML”) refers to:

(i) the conversion or transfer of property knowing or suspecting that such property is derived directly or indirectly from, or the proceeds of criminal activity or from an act or acts of participation in criminal activity, for or purposes of concealing or disguising the origin of the property or of assisting any person or persons involved or concerned in criminal activity;

(ii) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, in or over, or ownership of property, knowing or suspecting that such property is derived directly or indirectly from criminal activity or from an act or acts of participation in criminal activity;

(iii) the acquisition, possession or use of property knowing or suspecting that the same was derived or originated directly or indirectly from criminal activity or from an act or acts of participation in criminal activity;

(iv) retention without reasonable excuse of property knowing or suspecting that the same was derived or originated directly or indirectly from criminal activity or from an act or acts of participation in criminal activity;

(v) attempting any of the matters or activities defined in the above foregoing sub-paragraphs (i), (ii), (iii) and includes acting as an accomplice in respect of any of the matters or activities defined in the above foregoing sub-paragraphs.

This definition is rather exhaustive list of acts that would be considered as ML under Australian law.

1.5 “PEP” refers to individuals who are or have been entrusted with prominent public functions, their immediate family members or persons known to be close associates of such persons but shall not include middle ranking or more junior officials. As per the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1), “PEP” means an individual:

(a) who holds a prominent public position or function in a government body or an international organisation, including:

(i) Head of State or head of a country or government; or

(ii) government minister or equivalent senior politician; or

(iii) senior government official; or

(iv) Judge of the High Court of Australia, the Federal Court of Australia or a Supreme Court of a State or Territory, or a Judge of a court of equivalent seniority in a foreign country or international organisation; or

(v) governor of a central bank or any other position that has comparable influence to the Governor of the Reserve Bank of Australia; or

(vi) senior foreign representative, ambassador, or high commissioner; or

(vii) high-ranking member of the armed forces; or

(viii) board chair, chief executive, or chief financial officer of, or any other position that has comparable influence in, any State enterprise or international organisation; and

(b) who is an immediate family member of a person referred to in paragraph 1.5 (a), including:

(i) a spouse; or

(ii) a de facto partner; or

(iii) a child and a child’s spouse or de facto partner; or

(iv) a parent; and

(c) who is a close associate of a person referred to in paragraph 1.5 (a), which means any individual who is known (having regard to information that is public or readily available) to have:

(i) joint beneficial ownership of a legal entity or legal arrangement with a person referred to in paragraph 1.5 (a); or

(ii) sole beneficial ownership of a legal entity or legal arrangement that is known to exist for the benefit of a person described in paragraph 1.5 (a).

1.6 “Principal Officer” means the officer appointed by ZebPay to administer ZebPay’s anti-money laundering measures;

1.7 “Senior Management” means such directors, officers or other personnel of ZebPay as are specifically designated to monitor and ensure know-your-customer compliance and the operation of ZebPay’s internal audit systems;

1.8 “Suspicious Transaction” means a transaction, whether or not made in cash which, to a person acting in good faith:

1) give rise to a reasonable ground of suspicion that it may involve proceeds of an offense regardless of the value involved; or

2) appears to be made in circumstances of unusual or unjustified complexity; or

3) appears to have no economic rationale or bona fide purpose; or

4) gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism;

Explanation —Transaction involving financing of the activities relating to terrorism includes transaction involving funds suspected to be linked or related to, or to be used for terrorism, terrorist acts or by a terrorist, terrorist organization or those who finance or are attempting to finance terrorism.

2.1 A local Money Laundering Reporting Officer (“MLRO”) has been appointed who directly reports to the local management and for whom the local management is directly responsible.

The local MLRO is committed to undertake the following tasks:

Receive internal reports of suspicious transactions;

Endeavour to ensure the Company has a fully integrated Chain Analysis tool for all Crypto-wallets and to monitor all incoming and outgoing transactions.

Review the Know-Your- Client (“KYC”) process from the AUSTRAC website on . //www.austrac.gov.au/part-b-amlctf-program-customer-due-diligence-procedures . In completing this report the MLRO should provide as much detail as possible together with the relevant identification and other supporting documentation. To ensure the highest level of confidentiality, Suspicious Matter Report(s) (“SMRs”) will be submitted using the AUSTRAC’s online portal providing the necessary information as required under Chapter 18 of the AML/CTF Rules.

It should be noted that SMR will only be filed with AUSTRAC and will not be copied to any supervisory authority i.e. no tipping off;

Make external reporting to the relevant local authorities wherever applicable;

Provide annual reporting to the local management (the report should cover the results of any AML control activities, notification of suspicious transactions, employee training, implemented AML prevention activities);

Examine all unusual and conspicuous transactions and behaviour either as an outcome from monitoring systems or otherwise detected;

Daily check of Users against recognized “black lists” (e.g. OFAC, UN, EU, DFAT), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable

Develop procedures and policies to detect and prevent money laundering;

Periodically review the effectiveness of policies and procedures with regards to prevention and reporting of any illegal activity;

Establish staff training;

Advise and inform all employees

2.2 The MLRO shall be responsible for overseeing all aspects of the service provider’s AML/ CFT activities. The Company shall ensure that the MLRO has sufficient resources available to him or her in order to ensure compliance with the Company’s AML/ CFT policy.

The MLRO shall be responsible for:

(a) receiving reports of knowledge or suspicion of ML/ Funding of Terrorism;

(b) considering such reports to determine whether knowledge or suspicion of ML/Funding of Terrorism subsists;

(c) reporting knowledge or suspicion of ML/ Funding of Terrorism to AUSTRAC; and

(d) responding promptly to any request for information made by AUSTRAC.

2.3 Once the MLRO is appointed, the Company shall notify AUSTRAC in the form as is available on AUSTRAC website.

2.4 Should the MLRO resign and a new individual is appointed instead, AUSTRAC shall be notified as soon as possible.

ZebPay shall maintain a record of, and has evolved an internal mechanism to detect, the following:

3.1 Details pertaining to User transactions, including but not limited to:

– the nature of the transactions;

– the amount of the transaction and the currency in which it was denominated;

– the date on which the transaction was conducted; and

– the parties to the transaction.

3.2 All details for the following categories of User transactions, separately from those recorded under 3.1 above:

(i) User transactions of value of at least AUD 10,000 (Ten Thousand Australian Dollars), or its foreign currency equivalent; and User transactions that are connected to each other and that take place within a month of each other, with a monthly aggregate of at least AUD 10,000 (Ten Thousand Australian Dollars), or its foreign currency equivalent; and

(ii) All Suspicious Transactions by way of deposits and credits, withdrawals into or from any accounts in whatsoever name they are referred to in any currency maintained by way of cheques including third party cheques, pay orders, demand drafts, or any other instrument of payment of money including electronic receipts or credits and electronic payments or debits; or transfers from one account within the same banking company, financial institution and intermediary, including to and from Nostro and Vostro accounts; or any other mode in whatsoever name it is referred to;

(iii) credits or debits into or from any non-monetary accounts such as demat account, security account in any currency maintained by ZebPay;

(iv) money transfer or remittances in favour of own Users or non-Users from Australia or abroad and to third party beneficiaries in Australia or abroad including transactions on its own account in any currency by any of the following:

– demand drafts, or

– telegraphic or wire transfers or electronic remittances or transfers, or

– internet transfers, or

– Automated Clearing House remittances, or

any other mode of money transfer by whatever name called;

4.1 ZebPay will maintain hard and soft copies of the above-mentioned records of Transactions in accordance with the procedure and manner, as may be specified under applicable laws or regulations, from time to time.

4.2 In addition to the above, ZebPay shall maintain records of transactions, as per its prevailing processes.

5.1 ZebPay may be required and / or directed to cooperate and aid the government and / or law enforcement authorities, police, investigating agencies, or Tribunals and Courts within the territory of Australia or from outside the said territory.

5.2 In such cases, subject to applicable laws with respect to data protection, ZebPay shall be entitled to disclose any information about the User that is in its possession or control, including to government or law enforcement officials, police, investigating agencies, Tribunals and Courts within and outside the territory of Australia.

5.3 In particular, ZebPay shall be entitled to initiate processes and disclosures, including but not limited to the following circumstances:

(i) information pertaining to or in pursuance of claims and legal process (such as summons / warrants);

(ii) to protect ZebPay’s property, rights, and safety and the property, rights, and safety of a third party or the public in general;

(iii) to identify and stop any activity that ZebPay considers illegal, unethical, or legally actionable.

(iv) ZebPay may, if so required under applicable law, disclose the necessary information to AUSTRAC or any Australian government departments.

(v) ZebPay also compiles records and audit and compliance notes to determine the efficacy of its internal audit systems on an ongoing basis, and such notes are submitted to ZebPay’s audit committee on a quarterly basis for this purpose.

6.1 Based on the various factors and risk parameters, the clients shall be categorised into “High”, “Medium” and “Low” risk category. Frequency of risk monitoring for High Risk Customer should be Annual, Medium Risk Customer should be Two years and Low Risk Customer should be Three Years.

6.2 Certain clients may be of a higher or lower risk category depending on the circumstances such as the client’s background, type of business relationship or transaction, etc. The illustrative factors for risk profiling is given as under (list is indicative and can be expanded as per business requirements and experience):

(1) Geographical Location and Category of client.

(2) Nature of Business activity

(3) Financial Health vs Trade Volume

(4) Income Range

6.3 Risk based Monitoring approach shall be followed. Broad categories of monitoring and reason for suspicion and examples of suspicious transactions for ZebPay are indicated as under:

(1) Identity of Client

– False identification documents

– Identification documents which could not be verified within reasonable time.

– Doubt over the real beneficiary of the account.

– Accounts opened with names very close to other established business entities

(2) Suspicious Background

Suspicious background or links with known criminals

(3) Multiple Accounts

– Large number of accounts having a common account holder or authorized signatory with no rationale.

– Unexplained transfers between multiple accounts with no rationale

(4) Activity in Accounts

– Unusual activity compared to past transactions

– Sudden activity in dormant accounts

– Activity inconsistent with what would be expected from declared business

(5) Nature of Transactions

Unusual or unjustified complexity

No economic rationale or bonafide purpose

Source of funds/Cryptocurrencies are doubtful

(6) Value of Transactions

Value just under the reporting threshold amount in an apparent attempt to avoid reporting

Inconsistent with the clients apparent financial standing

Inconsistency in the transactions pattern by Customers.

6.4 ZebPay will ensure that information sought from the customer is relevant to the perceived risk, is not intrusive, and is in conformity with the guidelines issued in this regard. Any other information from the customer will be sought separately with the client’s consent and after opening the account.

Exceptions to this Policy is subject to the approval, and at the sole discretion of ZebPay Chief Compliance Officer, or a designated person. All exceptions must be documented, with reasons for the exceptions, including expiration or review date and, wherever necessary, including an action plan and timelines for compliance with the policy.

Without prejudice to the generality of the foregoing, screening of all individuals and entities against sanction programs such as for international/local sanction lists e.g UN, OFAC, EU, DFAT shall be undertaken and is mandatory. This is to ensure that the Company does not deal with any sanctioned individuals or entities. No accounts will be opened by ZebPay for any User who appears on the international sanction lists and local country watchlist of the jurisdiction i.e. DFAT that ZebPay business operates.

8.1 In risk-sensitive instances or where the customer is not present and there is some doubt e.g. due to online applications via its platform, the Company shall apply EDD measures. EDD measures are additional measures to the CDD measures.

8.2 EDD measures are applied in order to ensure that the higher risks presented by certain Customers and transactions are better monitored and managed to avoid any involvement in ML/Funding of Terrorism.

Thus, the Company applies EDD measures when the Operations Department classifies the Customer as high risk and, in all cases, where the customer is not present.

8.3 EDD measures are applied in the following cases:

(a) where the Applicant has not been physically present for identification purposes and classified as high risk subject to the Company’s CDD measures;

(b) in relation to cross-border correspondent banking relationships; or

(c) in relation to a Business Relationship or Occasional Transaction with a PEP.

8.4 In the above-mentioned instances, the MLRO and the Designated Employee/s are to be consulted in order to confirm which of the EDD measures indicated hereunder are to be applied whenever the applicant is not present and classified as high risk customer (i.e. for non-face-to-face applicants i.e. online applications).

8.5 In addition to the three (3) specific instances mentioned above, the Company shall also conduct EDD measures in relation to a Business Relationship or a transaction connected to a jurisdiction listed under the public documents issued by the FATF as required in the guidance note on high-risk and non-cooperative jurisdictions.

(NOTE: the Company restricts these clients at this stage, so the previous provisions are in case these may change in the future).

8.6 Although only three (3) relationships are mentioned above, there may be other situations which, by their nature, can present a higher risk of ML/ Funding of Terrorism. The MLRO shall, therefore, use his/her discretion when applying EDD measures in such situations. The MLRO shall ensure that such measures are applied on a risk-sensitive basis and should be appropriate in view of the higher risk of ML/ Funding of Terrorism.

NON-FACE-TO-FACE APPLICANTS

In addition to the identification and verification of identity measures to be carried out in accordance with the Identification and Verification of the Customer Section, the Operations Department shall apply one (1) or more of the following measures:

• A) ENSURE THAT THE FIRST PAYMENT OR TRANSACTION INTO THE ACCOUNT IS CARRIED OUT THROUGH AN ACCOUNT HELD BY THE APPLICANT IN THEIR NAME WITH A CREDIT INSTITUTION AUTHORISED UNDER THE BANKING ACT (Act No. 6 of 1959 as amended) OF THE LAWS OF AUSTRALIA OR OTHERWISE AUTHORISED IN ANOTHER MEMBER STATE OF THE COMMUNITY OR IN A REPUTABLE JURISDICTION.

This measure entails a bank-to-bank transfer from an existing account through which the Customer would have already been identified by the Company. Therefore, the first payment or transaction into the account held by the Applicant may be an electronic card payment only where the electronic card used to affect the payment is linked to an account held by the payer with a credit institution. In such instance, the Customer must provide the service provider’s statement form the same Bank that prove that the credit card used is liked to Customer’s account with that Bank. Prepaid credit cards and E-money payments are not admissible for EDD purposes.

Note: This is the default check and will be incorporated into the checks by Operations.

POLITICALLY EXPOSED-PERSONS (“PEPs”)

At the initial on-boarding stage (or if the client has been flagged as a PEP from a new review): The Company shall obtain such information directly from the Applicant (as part of the on-boarding questions) or from other readily available sources such as Experian, World Check, newspapers etc (the Company will automatically check if the Applicant is flagged as a PEP in the Watchlists of Experian on an automated basis). The Board of Directors’ or Senior Management approval is required in those cases where the Customer is categorized as a PEP. The application of EDD measures to PEPs is mandatory as long as the PEP remains entrusted with a prominent public function for a subsequent twelve (12) months from when he ceases to be so entrusted.

9.1 ZebPay shall exercise ongoing due diligence with respect to the business relationship with every User and closely examine the transactions in order to ensure that they are consistent with their knowledge of the User, his/her business and risk profile and where necessary, the source of funds.

9.2 ZebPay will also review its due diligence measures and undertake measures to re-verify the identity of a User and obtain further information on a User’s activities, if ZebPay has any suspicions of money laundering or the financing of terrorism.

9.3 All due diligence undertaken by ZebPay is documented, designed to consider all relevant risk factors in determining overall risk and the appropriate mitigation measures, is kept up to date; and will always be available to the relevant authorities and self-regulating bodies.

9.4 ZebPay will verify the identity of Users while carrying out transactions worth at least AUD 10,000 (Ten Thousand Australian Dollars), whether through a single transaction or a series of connected transactions.

9.5 Once a User has participated in transactions of a total value of at least over the course of his/her engagement with the ZebPay platform, or deposits or transacts in an amount of at least AUD 10,000 (Ten Thousand Australian Dollars) or equivalent foreign currency on the ZebPay Platform, ZebPay will also conduct ‘chain analysis’ to identify the relevant public address for such User and earmark such User as either as ‘high risk’, ‘medium risk’, or ‘low risk’ based on parameters such as the use of cryptocurrencies by such Users at online gambling websites, darknet websites, etc.

This limit AUD 10,000 (Ten Thousand Australian Dollars) or equivalent foreign currency may be revised by ZebPay from time to time, based on ZebPay’s determination of appropriate thresholds in accordance with ongoing compliance measures, and if so required under applicable Law.

9.6 ZebPay will, in particular, monitor the following categories of transactions, and will conduct due diligence on an ongoing basis on them:

(1) large, complex transactions, including those with unusual patterns that are inconsistent with a User’s normal / expected level of activity, without an apparent economic rationale or legitimate purpose; and

(2) transactions that involve high account turnover, inconsistent with the size of the balance ordinarily maintained by a User.

9.7 ZebPay will require Users to specify a bank account in the User’s own name (“the User Bank Account”) to which ZebPay will credit any funds payable to the User pursuant to the User’s trading activity on the ZebPay Platform. Users may request for ZebPay, from time to time, to change their User Bank Account, provided always that ZebPay will only entertain requests that are (i) in writing, (ii) specify a new bank account that is in the name of the User, and (iii) subject to ZebPay being satisfied, at its sole discretion, that the changing of bank account does not otherwise contravene ZebPay’s AML Policy. Otherwise, Users are hereby notified that as a matter of strict policy ZebPay will not entertain any request to credit the User’s funds into a bank account other than the User Bank Account.

9.8 As Users are not face-to-face customers of ZebPay, ZebPay may be required to undertake enhanced due diligence, including certification of all documents provided by the Users, calling for additional documents whenever necessary, and requiring that the first payments made by such Users be effected through the User’s KYC-compliant account with a bank. Any such requirements, as may be imposed under Applicable Law, will be incorporated into this AML Policy, and ZebPay reserves the right to update the AML Policy for this purpose.

9.9 ZebPay’s staff are trained in ZebPay’s due diligence and anti-money laundering measures, as well as all requirements prescribed under Applicable Law for this purpose and may be contacted at [email protected] if any User has questions or concerns about any of measures contained in this AML Policy.

10.1 In the event of knowledge or suspicion of ML/ Funding of Terrorism, and any knowledge, suspicion or reasonable grounds to suspect that the funds used in a transaction are the proceeds of a crime, the Company shall proceed as follows:

(i) the Company’s employee who has knowledge or suspicion of such ML/ Funding of Terrorism, shall report this matter to the MLRO.

(ii) once the MLRO has received all information relating to the knowledge or suspicion reported by the employee, he shall, together with the assistance of the Designated Employee/s, carry out a further investigation into the matter in order to decide whether such report is to be submitted to AUSTRAC as an SMR.

(iii) if the MLRO decides not to submit the report, he shall prepare a detailed report explaining his findings and the reasons for his decision and such report shall be kept in the Company’s records and retained for a period of seven (7) years in accordance with the Record Keeping Section above.

(iv) if on the other hand, the MLRO decides to submit the report to AUSTRAC, he shall complete the report in the form prescribed by AUSTRAC. This form may be filed online through the AUSTRAC website indicated above.

10.2 Any disclosures to AUSTRAC are to be made as soon as practicable, but in no circumstance, later than 24 hours after forming the relevant suspicion if the suspicion relates to terrorism financing; or three(3) business days after forming the suspicion in all other cases.

10.3 The time period mentioned in paragraph 10.2 for reporting a suspicious matter starts when the Company forms a ‘suspicion on reasonable grounds’. This may occur at any time during the enquiry, request, proposal, or commencement stages of providing a designated service to the customer.

The User hereby agrees and undertakes to not indulge, assist, abet and encourage in any manner whatsoever, in any activity involving money laundering or financing of any illegal or unlawful activities.

Part 10 of the AML/CTF Act outlines the types of records ZebPay must retain, which includes records of or about:

– transaction records;

– electronic funds transfers;

– customer identification procedures;

– AML/CTF programs; and

– due diligence assessments of correspondent banking relationships.

In addition, digital currency exchanges providers are required to retain records about their registration on AUSTRAC’s Digital Currency Exchange Register.

The AML/CTF Act requires reporting entities to retain records for seven(7) years after ceasing to provide a designated service – this is longer than the maximum period permitted under Part IIIA of the Privacy Act 1988 for retaining these types of records (generally five years). As such ZebPay shall maintain records of the identity of Users in soft copies in a manner, as may be specified under the AML/CTF Act or such applicable laws or regulations, from time to time, and in the absence thereof, from the date of cessation of the transactions between the User and ZebPay for a period of Seven (7) years.

13.1 Any notice or other communication provided for in this Agreement shall be sent only through electronic mail. User hereby agrees to receive electronic or any other form of communication and notifications from ZebPay. Email messages sent over the Internet are not always secure and ZebPay is not responsible or liable for non-receipt of such communication by User. Once the email is dispatched by ZebPay, it shall be deemed to have been served on the User. ZebPay shall be deemed to have received communications from the User only upon actual receipt into the Inbox of the account of the person to whom such communication is addressed and acknowledged. ZebPay shall not be liable or responsible for non-receipt of communications or for any damages incurred by the result of sending email messages over the Internet.

13.2 All communications to User shall be at the electronic mail address provided by User, as part of the KYC norms. User shall ensure that any change in the electronic mail address or communication option is duly intimated to ZebPay.

14.1 This Agreement shall be governed by and construed in accordance with the laws of Australia.

14.2 The parties agree to irrevocably submit to the exclusive jurisdiction of the courts in Australia for the resolution of any disputes arising from this Agreement or in connection therewith or pursuant thereto.

This Agreement shall bind and inure to the benefit of the parties, and their respective successors and permitted assigns.

16.1 The invalidity or unenforceability of any provision of this Agreement shall not in any way affect, impair or render unenforceable this Agreement or any other provision contained herein, which shall remain in full force and effect.

16.2 This Agreement shall be considered divisible as to such provision, which is deemed to be invalid or unenforceable, the remainder of this Agreement shall be enforceable and binding on the Parties.

No provision of this Agreement may be waived or changed except by a writing signed by the party against whom such waiver is sought to be enforced. The failure or omission by either party at any time to enforce or require strict or timely compliance with any provision of this Agreement shall not affect or impair that provision or any other provision in any way or the rights of such party hereof, to avail itself of the remedies it may have in respect of any subsequent breach of that or any other provision.

The Recitals, Schedules and Annexures in this Agreement shall form part of this Agreement and the contents thereof shall be read into this Agreement. Headings are for the purpose of easy reference and shall not affect the meaning or interpretation of this Agreement.

This Agreement, and the other agreements contemplated hereby, constitute the entire agreement.

ZebPay is an entity registered with the Australian Anti-Money Laundering (“AML”) regulators, i.e. AUSTRAC.

ZebPay shall appoint a Principal Officer and a Designated Director who will be designated Senior Management as required under Applicable Law, along with setting up a compliance team, who shall be responsible for ensuring compliance, monitoring transactions, and sharing and reporting information as required under the law/regulations.

22.1 These terms may be periodically reviewed and revised. The revised terms will be uploaded on the ZebPay Website and will reflect the modified date of the terms. The User is required to periodically visit the website and review the terms and any changes thereto.

22.2 Continued use of the ZebPay Services constitutes the agreement of User to the terms contained herein and any amendments thereto.

22.3 This agreement or the responsibilities or benefits arising therefrom cannot be assigned by User save and except with the prior written consent of ZebPay.

All other provisions of the ZebPay Terms of Service shall be read into this policy and shall form part hereof, including Governing Laws and Jurisdiction, notices, severability, assignment and such or other provisions.

A user may create a User Account by first downloading and installing the ZebPay App on their Android or iPhone smartphone by using the Google Play Store or iOS App Store, as applicable, subject to the terms contained herein in this website. Alternatively, user can also create an account by visiting the ZebPay website (www.zebpay.com/)

User shall comply with the procedures prescribed for opening the User Account, including providing a valid and existing email address and mobile number for completing the registration process and shall provide requisite KYC details and documents.

ZebPay reserves the right to reject registration or validation of a User Account on any grounds as it deems suitable, at its sole discretion, with due regard to legal and regulatory frameworks governing cryptocurrencies.

In addition to the terms contained herein, Users shall be bound by the terms of ZebPay’s Anti-Money Laundering Policy (“AML Policy”), which is available at AML policy. By virtue of using any part of the ZebPay’s Services, and/or by virtue of accepting and entering into this Agreement, Users are deemed to have accepted and to have agreed to comply at all times with, the terms of the AML Policy. Only Users complying with the following Know Your Customers (“KYC”) procedures, as well as all terms and procedures contained in the AML Policy, would be allowed to avail of the ZebPay’s Services:

Users shall provide the details, along with digitised copies of supporting documents for such details, simultaneously with the application for a User Account on the ZebPay Platform, failing which the User Account shall not be activated.

User hereby consents to retention of the above details and documents by ZebPay for its own use, for as long as ZebPay is required under any prevailing laws. ZebPay shall be entitled to retain user details and documents even for those Users whose registration has been rejected by ZebPay.

ZebPay shall take reasonable care and caution in the collection and retention of all information, data and documents provided by users. ZebPay shall comply with the terms of the Privacy Policy and with all applicable laws pertaining to personal data protection in the collection and retention of User data, including personal data and information. The Privacy Policy may be periodically reviewed and revised, modified or updated.

Acceptance of the terms herein shall tantamount to acceptance of the Privacy Policy, the AML Policy and the terms contained therein. Users are required to read, understand and affirm the AML Policy and the Privacy Policy before clicking the “accept and continue” button on the ZebPay platform.

ZebPay may call upon the User to furnish additional details and/or documents, either pursuant to governmental or regulatory requirements, or due to modifications in any of the terms of this Agreement, the Privacy Policy or the AML Policy. User hereby agrees and undertakes to comply with the same within the timelines prescribed.

ZebPay reserves the right to undertake the KYC (Know-Your-Customer) Policy as stipulated at //zebpay.com/global/kyc-policy in order to verify the identity of its Users at any point, and the User hereby agrees to provide co-operation, including but not limited to the provision of relevant identification and documents, in this regard.

ZebPay shall, at its sole discretion activate the User Account upon verification of the details provided through the KYC process included in this Agreement and in the AML Policy. In the event of any factual inaccuracies or discrepancies with the details or documentation provided by a User during this process, ZebPay shall be entitled to terminate the User Account without notice to the concerned User, and such User shall not be permitted to use the User Account or ZebPay Services thereafter. ZebPay is entitled to terminate User Accounts for non–compliance in providing true and correct information.

Existing Users may be called upon to comply with additional KYC and / or verification process as intimated by ZebPay from time to time.In the event of the User failing to provide additional KYC or comply with the verification process, ZebPay reserves the right to terminate or deactivate an existing User Account. Users shall be duly intimated by ZebPay, along with reasons for such deactivation and the procedures for redress (if any). Delay in termination of such User Accounts shall not amount to a waiver of the mandatory information and documentary requirements contained in this Agreement and in the AML Policy.

ZebPay may, at its sole discretion, intimate the user of reasons for non-activation of their account. ZebPay is not under any obligation, however, to provide such intimation.

Only natural or legal persons may apply for a User Account and avail of ZebPay’s services. Legal persons must have valid documents of incorporation and other documents as ZebPay may require from time to time, as currently encapsulated in our 100 point verification check protocol Upon verification, if any of the documents, information, or representations are found to be falsified, invalid or otherwise inaccurate, ZebPay is entitled to terminate the User Account for non–compliance in providing true and correct information.

In case of corporates, the antecedents of the company (name and registered office in particular) and of all beneficial owners, promoters and directors will be verified by ZebPay or any other third party engaged by ZebPay. An assessment shall be made of the financial worthiness of the user by obtaining appropriate declarations as and when required.

No users shall be accepted where it is not possible to ascertain the identity of the client, or the information provided is suspected to be false or if there is perceived non-cooperation of the user in providing full and complete information. ZebPay shall not continue to do business with such a person and may, in the appropriate circumstances, file a suspicious activity report.

ZebPay may, if so required under applicable Law, share know-your-customer and transaction records with any law enforcement authorities

Know Your Customer Standards – The objective of the KYC guidelines is to prevent the ZebPay Platform from being used, intentionally or unintentionally, by criminal elements for money laundering activities. KYC procedures enable ZebPay to know / understand their customers and their financial dealings better which in turn help them manage their risks prudently.

ZebPay’s KYC policy incorporates the following elements:

(i) Customer Acceptance Policy (“CAP”)

No account shall be opened anonymously or with fictitious names

No ZebPay user shall be below the age of 18 / cannot be a minor as defined by the law of the resident country.

All required KYC documents are mandatory.

User Accounts can be opened through the ZebPay Platform.

Each User Account is unique and can be activated by providing KYC documents pertaining to that User. Once the account is activated, the same KYC documents cannot be used to open another User Account.

Additional documents may be sought by ZebPay based on it’s internal risk assessment.

(ii) Customer Identification Procedure (“CIP”)

Customer identification means identifying the person and verifying his/ her identity by using reliable, independent source of documents, photograph or video verification of KYC documentation, (data, information or by using third-party services. ZebPay needs to obtain sufficient information necessary to establish, to its satisfaction, the identity of each user. Additional documents may be sought by ZebPay based on it’s internal risk assessment.

Types of documents required:

1) For Individual/Proprietor: Please refer to this document for our 100 point verification check.

2) For Corporate Entity:

• Certificate of incorporation & Company’s Constitution, Memorandum & Articles of Association or any other relevant documents of incorporation
• Resolution of the Board of Directors/Partners to open an account with ZebPay & identification of those who have the authority to operate the account
• Copy of a Company telephone/utility bill or a recent company bank account statement in the company’s name and bearing the office address
• A photo ID of all the Board of Directors
  ID & Address proof of an Authorised Signatory
• ID & Address proofs of a beneficial owner with ownership or control of more than 25% of the shares or voting rights or those who hold majority shares (if none of the shareholders have at least 25% shares or voting rights)

Note: ZebPay reserves the right to call for additional documents at anytime for further verification based on Users volume and trading pattern

If you have any questions regarding this KYC Policy, please contact us at [email protected]

These terms may be periodically reviewed and revised. The revised terms will be uploaded on the ZebPay Platform and will reflect the modified date of the terms. The User is required to periodically visit the ZebPay website and review the terms and any changes thereto.

Use of ZebPay Services constitutes the agreement of User to the terms contained herein and any amendments thereto.