Terms of Use
Privacy Policy
Merchant On-Boarding Policy
Grievance Redressal Policy

Last updated on July 29, 2021

Terms of Use

These terms of use (“Terms of Use”) is a contract between you and PMmax Technology Limited (“PayerMax”) and governs your access to the website of PayerMax at https://www.payermax.com (“Site”), including all sub-pages on this website, and use of any services of PayerMax (“PayerMax Service”). If you are an individual, you must be above eighteen (18) years of age and competent to contract under the applicable laws to access or use the PayerMax Service. If you are a merchant or business, your business must be validly organised and operating legally in the jurisdiction where PayerMax has operation in order to use the PayerMax Service.

By visiting the Site, logging on to or using the PayerMax Service, you shall be presumed to have read the Terms of Use (which includes the Merchant On-Boarding Policy and Grievance Redressal Policy, which are separately put up on the Site) and unconditionally and irrevocably accepted the terms and conditions set out therein.

The Terms of Use may be revised or altered by us at our sole discretion from time to time, and the latest Terms of Use will be posted on the Site. We will use commercially reasonable efforts to generally notify all users of any material changes to these Terms of Use, such as through a notice on our Site. However, you are responsible for periodically reviewing these Terms of Use and check for such changes.

1. PayerMax Service

PayerMax is a payment aggregator, processing, consolidating and reconciling payments paid to, or received from, various digital payment channels across the world into a single integrated payment solution product. Our one-stop, locally integrated payment solution allows our merchant clients to collect and make payments from and to their customers and users through a multitude of local and international digital payment methods, such as digital wallets, credit and debit cards, and bank transfers. You may subject to these Terms of Use and other related agreements integrate such relevant payment features into your website or application.

2. Use of the PayerMax Service

  • 2.1 If you are a merchant or business:
    • (a) you should refer to the Site for our integration and registration process in relation to a merchant account. You may apply for a merchant account with us, subject to provision of all required documents, signing a separate contract, and submitting a merchant application form to us. These Terms of Use are deemed to be incorporated into the contract between you and PayerMax;
    • (b) you shall apply for on-boarding which is subject to Know Your Customer (KYC) and Enhanced due diligence (EDD) requirements as specifically stated in the Merchant On-Boarding Policy or other related agreements;
    • (c) you must report any suspicious customers or transactions upon detecting a risk of the same, and cease making the service available to individuals and businesses. You shall cooperate with PayerMax including assisting us on all inspections for suspicious activities and other risk assessments and monitoring. Any failure or delay to justify the authenticity or reasonability of the transactions may result in suspension of the settlement payouts or services.
  • 2.2 If you are using the PayerMax Service on behalf of a company, partnership, association, government or other organization (“Organization”), you warrant that you are authorised to do so and that you are authorised to bind your Organization to the Terms of Use. In such circumstances, 'you' or ‘user’ will include your Organization.
  • 2.3 Without prejudice to other provisions of the Terms of Use and subject to the country specified terms as set out below, you may not use the PayerMax Service for activities that:
    • (a) violate any law, statute, ordinance or regulation;
    • (b) relate to transactions involving (i) certain controlled substances or other products that present a risk to consumer safety, (ii) drug paraphernalia, (iii) items that encourage, promote, facilitate or instruct others to engage in illegal activity, (iv) stolen goods including digital and virtual goods, (v) the promotion of hate, violence, racial or other forms of intolerance that is discriminatory or the financial exploitation of a crime, (vi) items that are considered obscene, (vii) items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction, (viii) certain sexually oriented materials or services, (ix) ammunition, firearms, or certain firearm parts or accessories, or (x) certain weapons or knives regulated under applicable law;
    • (c) relate to transactions that (i) show the personal information of third parties in violation of applicable laws, (ii) support pyramid or ponzi schemes, matrix programs, other "get rich quick" schemes or certain multi-level marketing programs, (iii) are associated with purchases of annuities or lottery contracts, lay-away systems, off-shore banking or transactions to finance or refinance debts funded by a credit card, (iv) are for the sale of certain items before the seller has control or possession of the item, (v) are by payment processors to collect payments on behalf of merchants, (vi) are associated with the sale of traveler's checks or money orders, (vii) involve currency exchanges or check cashing businesses, (viii) involve certain credit repair, debt settlement services, credit transactions or insurance activities, or (ix) involve offering or receiving payments for the purpose of bribery or corruption; or
    • (d) involve the sales of products or services identified by government agencies to have a high likelihood of being fraudulent.
  • 2.4 You undertake that you shall, during the use of the PayerMax Service, be in compliance with the mandates of Financial Action Task Force on Money Laundering (“FATF”) and local Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) supervisor institutions and acknowledges that the you have not directly or indirectly lent, contributed or otherwise made available funds to any of its affiliates, joint venture partners or any other person or entity for the purpose of financing the activities of any person currently subject to the Specially Designated List.

3. Risk Factors

  • 3.1 Technical Risk. While the PayerMax Service has been extensively tested and PayerMax maintains technology-risk management and business-continuity arrangements, the PayerMax Service may experience unforeseen outages or bugs beyond PayerMax’s reasonable control. Should this occur, PayerMax will take remedial steps to restore functionality as promptly as practicable.
  • 3.2 Risk of Reliance on Third Parties. The PayerMax Service relies, in whole or partly, on third-party software and the continued development and support of third parties. There is no assurance or guarantee that those third parties will maintain their support of their software, which might have a material adverse effect on the PayerMax Service.
  • 3.3 Regulatory Risk. While every effort has been taken to ensure that the PayerMax Service are compliant with local laws, it is difficult to predict how or whether regulatory agencies may apply existing regulation with respect to the PayerMax Service. It is likewise difficult to predict how or whether legislatures or regulatory agencies may implement changes to law and regulation affecting PayerMax Service. Regulatory actions could negatively impact PayerMax in various ways, and thus the PayerMax Service may not be available to users in certain jurisdictions.
  • 3.4 Taxation Risk. It is possible that your intended treatment of the PayerMax Service may be challenged by tax authorities. You must seek your own tax advice in connection with the PayerMax Service provided by PayerMax, which may result in adverse tax consequences to you, including, without limitation, withholding taxes, transfer taxes, value-added taxes, income taxes and similar taxes, levies, duties or other charges and tax reporting requirements.

4. Ownership and Intellectual Property Rights

  • 4.1 The PayerMax Service are protected by copyright, trademarks, patents, trade secret and/or other intellectual property laws. PayerMax, our affiliates, licensors, or our service providers own all legal right, the title, interest, copyright and other worldwide intellectual property rights in the PayerMax Services and all copies of the PayerMax Services improved, updated, upgraded, modified, or customized and any software or documents provided to you as part of or in connection with the PayerMax Service, including, without limitation, all intellectual property rights that exist therein, whether registered or not, and wherever in the world they may exist. In addition, this Terms of Use does not grant you any rights to the intellectual property rights in the PayerMax Service.
  • 4.2 Unless you have agreed otherwise in writing with PayerMax, nothing in the Terms of Use gives you a right to use any of PayerMax’s trade names, trademarks, service marks, logos, domain names, and other distinctive brand features.
  • 4.3 Unless you have been expressly authorised to do so in writing by PayerMax, you agree that in using the PayerMax Service, you will not use any trade mark, service mark, trade name, logo of any company or organization in a way that is likely or intended to cause confusion about the owner or authorised user of such marks, names or logos.

5. Data Security (with respect to a merchant or business)

  • 5.1 Password Security. In order to access the PayerMax Service, you will be required to provide your name and email address and to create a password. You are responsible for keeping the electronic device through which you access the PayerMax Service safe and maintaining adequate security and control of any and all security details that you use to access the PayerMax Service. This includes taking all reasonable steps to avoid the loss, theft or misuse of such electronic device and ensuring that such electronic device is both encrypted and password-protected. PayerMax assumes no responsibility for any loss that you may sustain due to compromise of account login credentials due to no fault of PayerMax and/or failure to follow the requirements set out in the Terms of Use, or follow or act on any notices or alerts that we may send to you.
  • 5.2 Loss and Compromise. Any loss or compromise of your electronic device or your security details may result in unauthorised access to your PayerMax account by third parties and the loss or theft of stored value held in your PayerMax account and any associated accounts, including your account(s) with any third-party payment portal(s) and linked bank account(s) and credit card(s). You must keep your security details safe at all times. For example, you should not write them down or otherwise make them visible to others.
  • 5.3 Shared Access. You should never allow remote access or share your computer screen with someone else when you are logged on to your PayerMax account. PayerMax will never under any circumstances ask you for your passwords or to screen-share or otherwise seek to access your computer or PayerMax account. You should not provide your details to any third party for the purposes of remotely accessing your PayerMax account. Always log into your PayerMax account through the Site to review any required actions if you have any uncertainty regarding the authenticity of any communication or notice.
  • 5.4 Security Breach. If you suspect that your PayerMax account or any of your security details have been compromised or if you become aware of any fraud or attempted fraud or any other security incident (including a cyber-security attack) affecting you and/or PayerMax (together a “Security Breach”), you must notify PayerMax as soon as possible (using the contact details under “General Provisions” below) and continue to provide accurate and up to date information throughout the duration of the Security Breach. You must take any steps that we reasonably require to reduce, manage or report any Security Breach. Failure to provide prompt notification of any Security Breach may be taken into account in our determination of the appropriate resolution of the matter.
  • 5.5 Safety and Security of Your Computer and Devices. PayerMax is not liable for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of a reputable and readily available virus-screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks, and you should use care in reviewing messages purporting to originate from us.

6. PayerMax’s Rights

  • 6.1 Prohibited Use. Without prejudice to other provisions under this Terms of Use and subject to clause 2 above, we reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request. We reserve the right to cancel and/or suspend your PayeMax account(s) and/or block transactions or freeze funds immediately and without notice if we determine, in our sole discretion, that your PayerMax account is associated with a prohibited use.
  • 6.2 Suspension. PayerMax may suspend and restrict your access to any or all the PayerMax Service if:
    • (a) we are so required by a court order or binding order of a government authority;
    • (b) we reasonably suspect you of using your PayerMax account in connection with a prohibited use;
    • (c) use of your PayerMax 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;
    • (d) our service partners are unable to support your use of the PayerMax Service;
    • (e) if you are a merchant or business, your KYC credentials are found to be ingenuine or fake;
    • (f) if you make incorrect or untrue disclosure of the nature of your business, resulting in a merchant category code violation;
    • (g) you take any action that PayerMax deems as circumventing its controls, including, but not limited to, opening multiple PayerMax accounts; and/or
    • (h) breach of any of the provisions under this Terms of Use.
  • 6.3 No advice. PayerMax makes no representation or warranty, express or implied, to the extent not prohibited by applicable laws, regarding the advisability of using any of the PayerMax Service. The past performance of the PayerMax Service is not a guide to future performance. PayerMax does not offer fiduciary services and is not your agent, advisor or fiduciary.
  • 6.4 Not an Offering. The content of the Site and the PayerMax Service do not constitute an offer to buy or sell or a solicitation of an offer to buy or sell investments, securities, partnership interests, commodities or any other financial instruments; the content or the Site and the Services also do not constitute, and may not be used for or in connection with, an offer or solicitation by anyone in any jurisdiction in which such an offer or solicitation is not authorised or permitted, or to any person to whom it is unlawful to make such offer or solicitation.

7. Liability and Indemnity

  • 7.1 Limitation on Liability. Subject to the overall provisions stated above, you expressly understand and agree that in no event shall PayerMax, its affiliates, and its or their licensors or service providers be liable to you for:
    • (a) any direct, indirect, incidental, special, consequential, punitive or exemplary damages, costs, losses, penalties, fines, charges or expenses which may be incurred by you, however caused and under any theory of liability. This shall include, but not be limited to, any loss of profit (whether incurred directly or indirectly), any loss of goodwill or business reputation, any loss of profits, any loss of data or other information suffered, business interruption, cost of procurement of substitute goods or Services, loss of privacy arising out of or in any way related to the use of or inability to use PayerMax Service or other intangible loss;
    • (b) any loss or damage which may be incurred by you, including but not limited to loss or damage as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, or as a result of any relationship or transaction between you and any advertiser or sponsor whose advertisement appears on the PayerMax Service;
    • (c) the deletion of, corruption of, or failure to store, any content and other communications data maintained or transmitted by or through your use of the PayerMax Service;
    • (d) your failure to provide PayerMax with accurate registration data or KYC documents;
    • (e) your failure to keep your password or account details secure and confidential, or:
      • (i) you erroneously direct us to submit payment instructions multiple times;
      • (ii) you direct us to submit the wrong amount;
      • (iii) you direct us to submit a payment instruction for a wrong person; or
      • (iv) you provide us with incorrect or incomplete information.
  • 7.2 In the event of any jurisdiction does not allow limitations on implied warranties or the exclusion or limitation of certain damages, all or part of the disclaimers as listed above in clause 7.1 may not apply.
  • 7.3 If you are a merchant or business, you shall ensure that, among others, all industry requisite approvals, licenses and registration in accordance with all applicable laws, rules, regulations, guidelines in force from time to time, have been obtained and are kept in full force and effect to enable you to offer your products for sale.
  • 7.4 Indemnity. You agree to indemnify and hold PayerMax, its affiliates, its licensors, its service providers, and its and their respective officers, directors, employees, agents, successors, assignees and licensors, in any manner whatsoever, harmless from and against all losses arising from claims, demands, actions (including, without limitation, lawyer’s and experts’ fees) or other proceedings as a result of:
    • (a) fraud, negligence and wilful misconduct by you in the use of the PayerMax Service;
    • (b) violation of applicable laws, rules or regulations in the use of the PayerMax Service and/ or in the conduct of your business or in relation to any information available as part of the PayerMax Service, including but not limited to the legal provisions mentioned thereafter;
    • (c) breach of the confidentiality obligations under these Terms of Use; your wrongful or improper use of the PayerMax Service and breach of any third party rights;
    • (d) disputes raised by your customer in relation to a transaction where such dispute is not attributable to the PayerMax Service;
    • (e) penalties, fines, charges, or any other actions as a result of breach or violation of any your representations and warranties; and
    • (f) fines, penalties and charges imposed by the acquiring bank, card payment networks or any governmental authority on account of transactions on the website or platform or the use of personal information or data that are in violation of applicable law.

8. Complaints and Dispute Resolution

  • 8.1 If you have a dispute with PayerMax, you agree to contact PayerMax through our support team in first instance to attempt to resolve any such dispute amicably. If we cannot resolve the dispute through the PayerMax support team, you agree that the dispute will be resolved in the manner described immediately below.
  • 8.2 Each party (i) waives all its respective right(s) to have any and all disputes, claims, suits, actions, causes of action, demands or proceedings (collectively, "Disputes") arising from or related to these Terms of Use resolved in a court, and (ii) waives all its respective right(s) to have any Disputes heard before a court. Instead, each party shall arbitrate Disputes through binding arbitration (which is the referral of a Dispute to one or more persons charged with reviewing the Dispute and making a final and binding determination to resolve it instead of having the Dispute decided by a judge or jury in court).
  • 8.3 Any Dispute arising out of or related to these Terms is personal to you and will be resolved solely through individual arbitration, and shall in no circumstances be brought as a class arbitration, class action or any other type of representative proceeding. There will be no class arbitration or arbitration in which an entity attempts to resolve a Dispute as a representative of another individual or group of individuals. Further, a Dispute cannot be brought as a class or other type of representative action, whether within or outside of arbitration, or on behalf of any other individual or group of individuals.
  • 8.4 Any Dispute arising out of or in connection with these Terms of Use (including without limitation the enforceability of this section or any question regarding its existence, validity or termination) shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Hong Kong. The tribunal shall consist of [1] arbitrator. The language of the arbitration shall be English.

9. Privacy and Disclosure

For information about the way in which we collect, process and share your personal information, please refer to our Privacy Policy, the full text of which is accessible on the website of PayerMax (https://www.payermax.com/terms/).

10. General Provisions

  • 10.1 Contacting PayerMax
    • To give us notice under these Terms of Use, or if you have feedback or general questions, please contact us via our user support at service@payermax.com. When you contact us you may need to provide some information we may need to identify you, your PayerMax account(s), and the matter or transaction in relation to which you are contacting us.
  • 10.2 No Warranty
    • We, our affiliates, our licensors, and our service providers do not represent or warrant, express or implied, that the PayerMax Service will operate without interruption or will be error free. Especially in the following cases:
      • (a) modification or alteration of the PayerMax Service made without the prior written approval of PayerMax;
      • (b) accident, neglect, misuse or abuse, or
      • (c) exposure to conditions outside the range of the environmental, power and operating specifications provided by PayerMax.
    • The PayerMax Service are provided on an as is and as available basis. Use of the service is at your own risk. To the maximum extent permitted by applicable law, the PayerMax Service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, or non-infringement.
  • 10.3 Availability
    • The PayerMax Service and the Site may be temporarily unavailable from time to time for maintenance or other reasons. PayerMax assumes no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, communications line failure, theft or destruction or unauthorized access to, or alteration of, user communications. PayerMax is not responsible for any problems or technical malfunction of any telephone network or lines, computer online systems, servers or providers, computer equipment, software, failure of email or players on account of technical problems or traffic congestion on the Internet or on the Site or combination thereof, including injury or damage to users or to any other person's computer related to or resulting from participating or downloading materials in connection with the internet and/or in connection with the Services. Under no circumstances will PayerMax be responsible for any loss or damage, including any loss or damage to any user of content of the PayerMax’s website, financial damages or lost profits, or loss of business, resulting from anyone's use of the PayerMax Service and the Site, any user content or third-party content posted on or through the PayerMax Service or the Site or transmitted to users, or any interactions between users of the PayerMax’s website, whether online or offline.
  • 10.4 Accuracy of content on the PayerMax’s website
    • Although we intend to provide accurate and timely information on the Site, the website (including, without limitation, its content) may not always be entirely complete or current. In an effort to continue to provide you with as complete and accurate information as possible, information may, to the extent permitted by applicable law, be changed or updated from time to time without notice, including without limitation information regarding our policies and PayerMax Service.
    • Links to third-party materials (including without limitation any websites) are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any such third-party materials accessible or linked to from the Site.
  • 10.5 Assignment
    • You may not assign any rights and/or licenses granted under these Terms of Use. We reserve the right to assign our rights without restriction, including without limitation to any PayerMax affiliates or subsidiaries, or to any successor in interest of any business associated with the PayerMax Service. Any attempted transfer or assignment in violation hereof shall be null and void. Subject to the foregoing, these Terms of Use will bind and inure to the benefit of the parties, their successors and permitted assigns. In the event that PayerMax is acquired by or merged with a third-party entity or undergoes a change of control, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control.
  • 10.6 PayerMax’s Role
    • PayerMax only acts as payment aggregator providing the PayerMax Service only. We do not (i) act as an escrow agent with respect to any funds kept in your account; (ii) act as your agent or trustee; (iii) enter into a partnership, joint venture, agency or employment relationship with you; (iv) have control of, nor liability for, the products or services that are paid for with the PayerMax Service; (v) guarantee the identity of any buyer or seller; (vi) ensure that a buyer or a seller will complete a transaction; (vii) determine if you are liable for any taxes, or unless otherwise specified, collect or pay any taxes that may arise from your use of the PayerMax Service.
  • 10.7 Force Majeure
    • We will not be liable for failure to perform under the Terms of Use as a result of any event of force majeure including, not be limited to acts of god, fire, wars, sabotage, civil unrest, labor unrest, action of statutory authorities or local or state, central governments, change in laws, rules and regulations, affecting our and/or the payment system providers performance.
  • 10.8 Confidentiality
    • You agree not to disclose or attempt to use or personally benefit from any non-public information or information that by its nature should be considered confidential (“Confidential Information”) that he may learn on the website or through the services. You shall hold such Confidential Information in confidence and shall not disclose Confidential Information to any third party without our prior written consent. You acknowledge and agree that a breach of this clause would cause irreparable harm and that we shall be entitled to seek equitable relief from such breach. This obligation shall continue until such time as the non-public information has become publicly known through no action of your own. If you are compelled by order of a court or other governmental or legal body (or have notice that such an order is being sought) to divulge any such non-public information, you agree to promptly and diligently notify PayerMax and cooperate fully with PayerMax in protecting such information to the extent possible under applicable law.
  • 10.9 No Waiver
    • The failure of PayerMax to exercise or enforce any right or provision of these Terms of Use shall not constitute a waiver of such right or provision in that or any other instance.
  • 10.10 Severability
    • If any provision of these Terms of Use is held invalid, the remainder of these Terms of Use shall continue in full force and effect. If any provision of these Terms of Use shall be deemed unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from these Terms of Use and shall not affect the validity and enforceability of any remaining provisions.
  • 10.11 Termination
    • We may terminate or suspend use of the PayerMax Service at any time in our discretion, with notification to you. Upon any termination for any reason, we shall have no liability to you and no further obligations under the Terms of Use.
    • Any termination of the Terms of Use does not relieve you of any obligations to pay any fees or costs accrued prior to the termination and any other amounts owed by you to us, and/or the payment system providers, in accordance with the terms of the separate contact between you and PayerMax in relation to your merchant account.
  • 10.12 Governing Law
    • These Terms of Use shall be governed by the laws of Hong Kong Special Administrative Region and the general international business practices and / or industry practices shall be referred to where there are no applicable laws or regulations.
  • 10.13 Survival
    • The following provisions of these Terms of Use shall survive termination of your use or access to the PayerMax Service and the Site: the sections concerning Intellectual Property, Liability and Indemnity, Complaints and Dispute Resolution and General Provisions, and any other provision that by its terms survives termination of your use or access to the PayerMax Service and the Site.

11. Country Specified Provisions

The following additional or amended terms shall apply to you if you are a user in the relevant jurisdiction specified below.

  • 11.1 India
    • Without prejudice to other provisions under the Terms of Use, in connection to clause 2 “Use of the PayerMax Service”, you shall not host, display, upload, modify, publish, transmit, store, update or share any information that:
      • (a) belongs to another person and to which you do not have any right to;
      • (b) is harmful to children;
      • (c) infringes any patent, trademark, copyright or other proprietary rights;
      • (d) violates any law for the time being in force;
      • (e) deceives or misleads the addressee about the origin of such messages or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact;
      • (f) impersonates another person;
      • (g) contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource;
      • (h) threatens the unity, integrity, defense, security or sovereignty of India, friendly relations with foreign states, or public order, or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting other nation; and
      • (i) is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person.
  • 11.2 Indonesia
    • If the PayerMax Service is used or accessed from within Republic of Indonesia, then the following supplemental terms are incorporated into the Terms of Use by reference and shall apply and override any conflicting provisions in the Terms of Use:
      • (a) Governing Language. These Terms of Use are made in English and Indonesian language versions. In the event of any discrepancy between the English and Indonesian language versions, the English language version shall prevail.
      • (b) Parental or Guardian Consent. If You are under the age of 21, You hereby represent that You had the consent of Your parent or legal guardian to access the Services or to register for an account on the Services.
      • (c) Waiver. For the purpose of termination and/or dissolution and/or rescission of the Terms of Use, we and You hereby waive the applicability of the provisions under Article 1266 of the Indonesian Civil Code, to the extent that the court order and/or decision would otherwise be required to validly terminate and/or dissolve and/or rescind the Terms of Use.

Last updated on July 19, 2021

PayerMax, operated by PMmax Technology Limited (“PayerMax”, “we”, “our” or “us”), acts as a payment aggregator facilitating payment processing (“PayerMax Service”) for our customers (the “merchants”). During this payment processing, PayerMax will need personal information to process specific transactions. This PayerMax Privacy Policy describes how we collect, use, store and disclose personal information.

PayerMax may process personal information of the following categories of individuals in the provision of PayerMax Services:

  • (a) individuals employed or associated with merchants, such as representatives, suppliers or end-users;
  • (b) vendors or business partners or individuals employed or associated with such organisations that assist us in the provision of PayerMax Service; and
  • (c) visitors that log on or use our website https://www.payermax.com/.

We collectively refer to the individuals listed above as “you” in this Privacy Policy.

We process the personal information of end-users of merchants on behalf of the merchants. We are not responsible for and have no control over the privacy or security practices of the merchants, which may differ from those explained in this Privacy Policy. If your personal information has been submitted to us by or on behalf of the merchants and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly.

Your use of PayerMax Service is governed by the PayerMax Terms of Service, which describes in more detail the PayerMax Service covered by this Privacy Policy. Capitalized terms not defined in this PayerMax Privacy Policy shall have the meaning ascribed to them in the PayerMax Terms of Service.

Information we collect and how we use it

Sources of information

We process personal information that you provide to us in a number of ways, including:

  • When you make or receive a payment from the merchants who using PayerMax Service
  • When you make an inquiry about our PayerMax Service or otherwise interact on our website
  • When you interact with us by telephone, email and other electronic communication
  • When you attend an event with us or a third party we are working with or sign up to receive publications from us
  • When we onboard you as a merchant and interact regarding our service
  • When you provide services to us or seek to provide such services

We may also process your personal information from third-party sources as necessary for the provision of PayerMax Service. We may obtain this information from your organisation, from public sources or third parties, depending on the relevant circumstances. For example, we may obtain certain personal information about you from:

  • Third-party licensed payment provider or bank, such as your transaction information, as necessary to provide PayerMax Service; or
  • third parties, such as government agencies, information service providers, or from publicly available records to carry out due diligence and other legally required compliance checks, such as those related to knowing your customer (KYC), anti-money laundering (AML) and Specially Designated Lists.

Type of personal information

When you use our website or when we interact with you to provide PayerMax Service or to receive services from you as a vendor, the personal information we receive, collect and process may include:

  • Contact information, such as your name, email, phone number, billing address.

In addition to the information listed above, we may collect information about the transaction from you depending on which payment method you choose to make or receive a payment, including:

  • Bank card information such as the name on the card, card type, card number, card verification value, and expiration date, or the information about the account you open with other licensed payment channels to process the payment;
  • Identification information, such as your ID number or tax number, Customer ID generated by merchants to verify the process the transactions or conduct anti-money laundering and/or fraud prevention checks
  • Transaction information, such as amount and time of transaction, currency and language you used;

We collect the following personal information from your device when you use PayerMax Service to carry out data analysis for advertising, and to protect you from fraud, phishing or other misconduct:

  • IP address, app version, system version and type, device model, system language, network type, carrier, android ID, Mac address, IMEI, advertising identifier number and browser system.

You may provide your personal information to us voluntarily. However, there are circumstances in which we may not be able to assist you, or an organization with which you are associated, unless you provide us with your personal information. For example, your personal information may be required for legally required compliance checks, for security and other reasons to allow you to access PayerMax Service. In these cases, without the relevant personal information, we may be unable to assist you, and we would inform you that this is the case.

We do not knowingly collect personal information from or about children under the age of 18. If you are under 18, please do not use PayerMax Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under 18, we will delete that information as soon as possible. If you believe that a child under 18 may have provided us personal information, please contact as using details provided in section 8 below.

Legal justification for our use of your personal information

We may process your personal information in connection with any of the purposes set out above on one or more of the following legal grounds:

  • To perform our obligations under a contract with you or your organization;
  • To comply with our legal obligations, as well as to keep records of our compliance processes or tax records;
  • To pursue our legitimate interests, or those of a third-party recipient of your personal information, provided that those interests are not overridden by your interests or fundamental rights and freedoms. Specifically, we have legitimate interests in promoting and marketing our services to existing and potential customers, in maintaining customer accounts for efficient operation of our business, in keeping our information, trade secrets and confidential data safe and secure, in handling complaints and claims to protect our business; or
  • Based on your consent to process your personal information in that manner.

Information we share

We will only share your personal information with third parties in the following circumstances:

  • A merchant. If we have collected your personal information in the course of providing PayerMax Service to that merchant, and where permitted by law to others for the purpose of providing PayerMax Service. For example, when you make a purchase or transaction with that merchant, we make certain personal information about you available to the merchant you purchase from or transact with;
  • Licensed payment service provider. We may exchange certain personal information about you to enable the provision of PayerMax Service, such as your transaction information with the licensed payment service provider or bank as necessary to provide PayerMax Service;
  • Third parties providing services for AML/KYC checks, credit risk reduction, and other fraud and crime prevention purposes, or similar services, including financial institutions, credit reference agencies, and regulatory bodies with whom such personal information is shared;
  • Courts, law enforcement authorities, regulators, government officials or other competent authorities where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, including in order to protect the legitimate rights and interests of you and others. Such disclosures may be necessary for us to comply with mandates from FATF and local AML/CFT requirements. We may provide your Customer ID, contact information, and any other transaction information to competent authorities;
  • Our corporate group, we also share your personal information within our corporate group, including parent, subsidiary or affiliate companies as needed to provide the PayerMax Service or for the purposes set out in this policy.
  • Service providers which we engage to process personal information for any of the purposes listed above on our behalf and in accordance with our instructions only, such as licensed payment service providers, cloud storage providers; and/or
  • Prospective sellers or buyers of any of our business or assets to which we might assign or novate any of our rights and obligations; in such case we may disclose your personal information to the prospective seller or buyer of such business or assets.

Any information you provide directly to a third-party merchant, website or application is not covered by this PayerMax Privacy Policy. We are not responsible for the privacy or security practices of merchants or other third parties with whom you choose to share your personal information directly. We encourage you to review the privacy policies of any third party to whom you choose to share your personal information directly.

The personal information we collect may be transferred to and stored outside of the country you use PayerMax Service for the purposes specified in this Privacy Policy. For example, we store all of our data, including personal information, with AWS in Singapore.

Any international transfers of your personal information will be made according to appropriate safeguards under the applicable laws and regulations. If you wish to enquire further about these safeguards used, please contact us using the details set out in section 8 of this Privacy Policy. We may transfer your personal information outside of the country where you use PayerMax Service, and where we do so we will protect personal information as required by applicable laws.

How long do we keep your personal information?

Your personal information will be retained only for as long as necessary for the purposes for which the information was collected, except where necessary to meet our legal obligations (for example, in relation to KYC/AML requirements) or to establish, exercise or defend potential legal claims or to pursue our legitimate interests.

Your rights

Your rights will depend on the laws which apply to you and us, but you may have:

  • the right to obtain access to your personal information,
  • to have your personal information we hold rectified or deleted,
  • to restrict our processing of that information,
  • to object to our processing of personal information,
  • to have your personal information transferred to you or another organisation, and
  • to lodge a complaint with a relevant data protection authority.

Where you have provided us with consent for the processing, you may be able to withdraw it. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. To withdraw your consent or to exercise any of the rights above, if they are applicable, you should use our contact details set out in section 8 below.

We must ensure that your personal information we hold is accurate and up to date, where relevant. Therefore, please advise us of any changes to your information by emailing us.

Security

We are concerned about safeguarding the confidentiality of your information. We employ administrative, physical and electronic measures designed to protect your Information from unauthorized access and use. Please be aware that no security measures that we take to protect your information are absolutely guaranteed to avoid unauthorized access or use of your information which is impenetrable.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., information related to your e-wallet password, credit or debit card password, racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) through PayerMax to us, unless such information is required by us for legal compliance checks, such as KYC/AML.

Contacting Us

If you have any questions, complaints or comments about this PayerMax Privacy Policy or our privacy practices, or to report any violations of the PayerMax Privacy Policy, please contact us at: dpo@payermax.com.

Changes to This Privacy Policy

We may revise this PayerMax Privacy Policy from time to time to reflect any changes to the way how we process your personal information or changing legal requirements. The most current version of the policy will govern our use of your information. Please check back frequently to see any updates or changes. This Privacy Policy was last updated on the date provided at the top of this page.

Supplemental Terms

The following additional or amended terms shall apply to you if you are a user in the relevant jurisdiction specified below.

Brazil

Law No. 13,709/2018 (the Brazilian General Data Protection Law, aka “LGPD”) offers additional rights and regulations for individuals located in Brazil. Further to the information set out in sections 1, 5, 7, and 10 of this Privacy Policy, the following additional information applies to you if you are located in Brazil:

Minor’s Personal Information: We do not knowingly collect personal information from or about children and adolescents under the age of 18. If you are under 18, please do not attempt to use PayerMax Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child or adolescent under 18, we will delete that information as soon as possible. If you believe that a child or adolescent under 18 may have provided us personal information, please contact us.

Data subject’s requests: Under Article 18 of the LGPD, you have the following rights as data subject:

  • confirmation of the existence of processing activities;
  • access to your personal information;
  • correction of incomplete, inaccurate, or outdated personal information;
  • anonymization, blocking or elimination of unnecessary or excessive personal information or of information processed in noncompliance with the LGPD;
  • portability of your personal information;
  • elimination of your personal information processed with your consent;
  • information of the public and private entities with which we shared your personal information;
  • information on the possibility of not providing consent and on the consequences of the denial;
  • revocation of consent; and
  • petition against us before the National Authority for Data Protection (“ANPD”).

Indonesia

If the Services are used or accessed from within Republic of Indonesia, then the following supplemental terms shall apply and override any conflicting provisions in the Privacy Policy:

Consent from third parties. If you provide any personal data or information of third party individuals and/or parties, you represent and warrant that you have obtained the necessary consent to do so.

Data sharing. We will not share your information with third parties for any purposes other than the provision of PayerMax Service specified herein, without your consent.

Governing Language. These Privacy Policy are made in English and Indonesian language versions. In the event of any discrepancy between the English and Indonesian language versions, the English language version shall prevail.

Parental or Guardian Consent. If you are under the age of 21, you hereby represent that you had the consent of your parent or legal guardian to use the PayerMax Service.

Waiver. For the purpose of termination and/or dissolution and/or rescission of the Privacy Policy, we and you hereby waive the applicability of the provisions under Article 1266 of the Indonesian Civil Code, to the extent that the court order and/or decision would otherwise be required to validly terminate and/or dissolve and/or rescind the Privacy Policy.

Philippines

If the Services are used or accessed from within Philippines, then the following supplemental terms shall apply and override any conflicting provisions in the Privacy Policy:

Clause 1 (Information we collect and how we use it), add:

If you have provided us with personal information of third party individuals, you are required to obtain the individual's prior consent and you represent and warrant that you had or have their consent or are otherwise entitled to provide their personal information to us. By providing us with personal information of third party individual(s), you also warrant that the individual(s) is informed of and consents to the terms of this Privacy Policy.

Clause 3 (Information we share), combine bullets 3 and 5 as follows:

Service providers which we engage to process personal information for any of the purposes listed above on our behalf and in accordance with our instructions only, such as local licensed payment service providers, cloud storage providers as well as companies providing services for AML/KYC checks, credit risk reduction, and other fraud and crime prevention purposes, and companies providing similar services, including financial institutions, credit reference agencies, and regulatory bodies with whom such personal data is shared; and/or

Clause 5 (Your rights) insert following clause:

Where you have provided us with consent for the processing, you may be able to withdraw it. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations or for any of the purposes set out in this Privacy Policy where the processing of your personal information is not based on consent.

South Korea

If the Services are used or accessed from within South Korea, then the following supplemental terms shall apply and override any conflicting provisions in the Privacy Policy:

After the purpose of processing of your personal information is achieved, your personal information will be transmitted to a separate database (or moved to a separate storage if your information is retained in a paper form) and retained for a certain period in accordance with PayerMax’s internal regulations and other applicable laws and regulations before it is destroyed. Your personal information relocated to a separated database will not be used for other purposes, unless it is required under the applicable laws and regulations. When destroying your personal information, we will take reasonable and technically feasible measures to make the personal information irrecoverable. For example, electronic files that contain personal information will permanently be deleted using a technical method that makes the files irrecoverable, and any other records, print-outs, documents or any other recording media will be shredded or incinerated.

Glossary of terms

AbbreviationTerm
EDDEnhanced due diligence
KYCKnow Your Customer
RBIReserve Bank of India
UNSCUnited Nations Security Council
UNSCRUnited Nations Security Council resolution

Introduction of the Policy

This Merchant On-Boarding Policy (Policy) has been formulated to provide the minimum requirements pertaining to the procedures that the Company shall implement when associating with Overseas Merchants and it shall, among others, cover aspects related to merchant due diligence, reporting and record management and endeavors to be in line with the requirements of the bank in this regard. The compliance and operations team of the Company will be responsible for effective implementation of this policy.

Objective of the Policy

The Policy is applicable to all employees of the Company and has been prepared to achieve the following objectives:

  • 1. To establish a framework for the implementation of adequate merchant on-boarding processes, procedures and controls;

  • 2. To regularly review the Policy and procedures herein to ensure its effectiveness.

  • 3. Merchant on-boarding procedure will follow in lines with the policy to define their on-boarding process

Merchant on-boarding

Due diligence

  • The Company shall, at the outset, screen the names of the merchants as well as the authorized officials / shareholders/ Beneficial owners of the merchant against the following:

    • 1. Sanctions lists circulated by RBI
    • 2. Sanction list of respective geography of the merchant
    • 3. Negative merchant lists maintained with the Company
    • 4. Any other sanctions list circulated by Citi Bank
    • The Company shall also not accept merchants that are falling under the restricted categories (list as per Annexure 1)
  • The Company will also ensure that Application name/ Brand name of the customers are screened against the available negative lists.Post screening and merchant acceptance, the Company shall proceed to establish a process to on-board the merchant on its platform. For this purpose, the Company shall obtain necessary identity documents of the merchant along with information pertaining to the nature, financials and other relevant details of the business of the merchant. For this purpose, the Company shall prepare an appropriate onboarding form outlining the requisite information and supporting documentation and shall obtain a duly filled-in copy from the merchant.

  • The Company shall undertake background and antecedent check of the merchants, to ensure that such merchants do not have any malafide intention of duping customers, do not sell fake services, etc. Depending on the risk categorization of merchants, the Company will undertake enhanced due diligence of high-risk merchants.

  • The information and documents sought from the merchant shall include (which shall be customized based on the country specific regulatory requirements):

    • 1. Identity and address details of the merchant, including supporting documents
    • 2. Charter documents (Certificate of Incorporation, Memorandum and Articles of Association or other relevant document specific to the country)
    • 3. Business license/ registration certificate
    • 4. Certificates/licenses issued by regulators (if any)
    • 5. Tax certificate
    • 6. Shareholding details
    • 7. Director details
    • 8. Board resolution authorizing its officials to transact on its behalf
    • 9. Brief write up on the business of the merchant
    • 10. Signed Merchant Agreement with the Company
    • 11. Bank Statements or other documents evidencing bank account details of the merchants
    • 12. Other relevant information
  • The Company shall ensure that these documents are collected basis the type of the entity which the merchant is operating. To state an example, within local and global requirement of KYC document for LLP, Private Limited Company, Trust etc. are different and the Company shall ensure that such requirements are adhered to.

  • The Company shall verify all the information received from the merchant in line with the pre-agreed terms with the Citi Bank set out in this regard.

On-going due diligence

  • The Company shall undertake on-going due diligence of merchants to ensure that their transactions are consistent with their knowledge about the merchants, merchants’ business and risk profile; and the source of funds. The extent of monitoring shall be aligned with the risk category of the merchant.

  • For this purpose, the Company shall monitor the following types of transactions:

    • 1. Suspicious transactions having inconsistent patterns of transactions, including but not limited to velocity, volume and threshold checks
    • 2. Sudden surge in transactions for a specific country by multiple merchants or by a merchant to different countries
    • 3. Fraud reporting cases or any non-compliance in terms of behavior, information sharing
    • 4. Stricter monitoring for customers identified as high-risk customers
    • 5. Monitoring against the negative news on companies/ individuals
    • 6. Gateway level checks
    • 7. Increase in chargebacks cases

Record management

The Company shall ensure maintenance, preservation and reporting of merchant information in line with the agreed terms with Citi bank as part of the engagement.

  • Periodic updation

    • ‘Periodic Updation’ means steps taken to ensure that documents, data or information collected under the due diligence process is kept up-to-date and relevant by undertaking reviews of existing records at periodicity prescribed by the local and global supervisor institutions or as per agreed terms with Citi Bank.
  • Record upation

    • Basis the periodic risk assessment carried by the Company, the Company shall review the documents sought at the time of establishing the merchant relationship and obtain additional and fresh documents from the merchants.

Reporting requirements

The Company shall collect, compile and report all such requisite data and information to Citibank, relating to transactions and merchants, in such format as may be outlined as per a pre-determined arrangement with Citibank for the purpose of onward reporting to such authorities, regulators.

Review of the Policy

The Policy will be reviewed at least annually, or earlier, if needed, in the event of any significant change in business operations. All updates / changes to the Policy will be communicated to the relevant staff / relevant stakeholders on a periodic basis.

Annexure 1

Online Merchants: Negative Category that cannot be considered – Table I

Sr. NoCategory
1Adult goods and services which includes pornography and other sexually suggestive materials & related herbal products (including literature, tablets, injection, vaccination imagery and other media); escort or prostitution services; Website access and/or website memberships of pornography or illegal sites
2Body parts which includes organs or other body parts
3Bulk marketing tools which includes email lists, software, or other products enabling unsolicited email messages (spam)
4Cable descramblers and black boxes which includes devices intended to obtain cable and satellite signals for free
5Child pornography which includes pornographic materials involving minors
6Copyright unlocking devices which includes Mod chips or other devices designed to circumvent copyright protection
7Copyrighted media which includes unauthorized copies of books, music, movies, and other licensed or protected materials
8Copyrighted software which includes unauthorized copies of software, video games and other licensed or protected materials, including OEM or bundled software
9Counterfeit and unauthorized goods which includes replicas or imitations of designer goods; items without a celebrity endorsement that would normally require such an association; fake autographs, counterfeit stamps, and other potentially unauthorized goods
10Drugs and drug paraphernalia which includes illegal drugs and drug accessories, including herbal drugs like salvia and magic mushrooms
11Drug test circumvention aids which includes drug cleansing shakes, urine test additives, and related items
12Endangered species which includes plants, animals or other organisms (including product derivatives) in danger of extinction
13Government IDs or documents which includes fake IDs, passports, diplomas, and noble titles
14Hacking and cracking materials which includes manuals, how-to guides, information, or equipment enabling illegal access to software, servers, website, or other protected property
15Illegal goods which includes materials, products, or information promoting illegal goods or enabling illegal acts
16Offensive goods which includes literature, products or other materials that:
a. Defame or slander any person or groups of people based on race, ethnicity, national origin, religion, sex, or other factors
b. Encourage or incite violent acts
c. Promote intolerance or hatred.
17Offensive goods, crime which includes crime scene photos or items, such as personal belongings, associated with criminals
18Prescription drugs or herbal drugs or any kind of online pharmacies which includes drugs or other products requiring a prescription by a licensed medical practitioner.
19Pyrotechnic devices, combustibles, corrosives and hazardous materials which includes explosives, fireworks and related goods; toxic, flammable, and radioactive materials and substances
20Regulated goods which includes air bags; batteries containing mercury; Freon or similar substances/refrigerants; chemical/industrial solvents; government uniforms; car titles; license plates; police badges and law enforcement equipment; lock-picking devices; pesticides; postage meters; recalled items; slot machines; surveillance equipment; goods regulated by government or other agency specifications
21Tobacco and cigarettes which includes cigarettes, cigars, chewing tobacco, and related products
22Traffic devices which includes radar detectors/jammers, license plate covers, traffic signal changers, and related products
23Weapons which includes firearms, ammunition, knives, brass knuckles, gun parts, and other armaments
24Wholesale currency which includes discounted currencies or currency exchanges
25Any product or service which is not in compliance with all applicable laws and regulations whether federal, state, local or international including the laws of India.
26The Merchant providing services that have the potential of casting the Bank/ TranServ and/ or Payment Service Providers in a poor light and/ or that may be prone to – Buy & Deny attitude of the cardholders when billed (e.g. Adult material/ Mature content/ Escort services/ friend finders) and thus leading to chargeback and fraud losses.
27Businesses out-rightly banned by law (e.g. Betting & Gambling/ publications or content that is likely to be interpreted by the authorities as leading to moral turpitude or decadence or incite caste/communal tensions, lotteries/sweepstakes & games of chance.
28Bulk marketing tools which includes email, lists, software, or other products enabling unsolicited email messages (spam)
29Web-based telephony/ SMS/Text/ Facsimile services or Calling Cards. Bandwidth or Data transfer/ allied services. Voice process/ knowledge process services.
30Mailing lists
31Multi-Level Marketing collection fees/Matrix sites/Pyramid Marketing
32Businesses which involved in any kind of production or services of Fireworks are prohibited.
33Drop Shipment

Introduction of the Policy

This Grievance Redressal Policy (Policy) has been formulated to provide customers and merchants adequate facilities to lodge and escalate their grievances, concerns and queries with the Company and to provide a speedy and effective redressal mechanism for the same. The operations team of the Company will be responsible for effective implementation of this policy.

Objective of the Policy

The Policy has been prepared to achieve the following objectives:

  • 1. To establish two distinct grievance redressal frameworks for the implementation of complaint receipt and redressal for the benefit of customers and merchants;

  • 2. To provide adequate modes of lodging complaints with the Company;

  • 3. To effect speedy and satisfactory redressal of complaints;

  • 4. To establish an appropriate matrix of authorities for escalating grievances;

  • 5. To ensure periodic reporting to ensure minimisation of complaints;

  • 6. To regularly review the Policy and procedures herein to ensure its effectiveness.

Modes of lodging complaints (for merchants)

To lodge any compliance, details like on line queries form, Email, etc. will be available on the website page of the Company. And each merchant will be assigned an account manager to handle the queries or dissatisfaction from merchants. In case of any dissatisfaction, queries or feedback, merchants may contact the Company through the following modes:

ModeContact detailsAvailability
Emailservice@payermax.com24x7

Modes of lodging complaints (for customers)

To lodge any compliance, details like phone number (toll free number), Email, etc. will be available on the website page of the Company. In case of any dissatisfaction, queries or feedback, customers may contact the Company through the following modes:

Sr. NoModeContact detailsAvailability
1Emailservice@payermax.com24x7
2Online chatAuto link in payment SDKWorking days and 9am-6pm

Complaints resolution timelines

The Company shall endeavor to resolve all complaints and queries within the resolution timelines outlined below:

Sr. NoComplaint typeResolution timeline
1Remittance related issues5 working days
2Technical issues2 working days
3Transaction related issues2 working days
4Operational5 working days
5Finance related issues7 working days
6Terms of service7 working days
7Refunds3 working days
8Others7-10 working days

The time proposed to be taken to dispose customer complaints

AuthorityTurn-around time for complaint resolution (From time of receipt of complaint)
AcknowledgementImmediately
Level 1 AuthorityWithin 48 hours
Level 2 AuthorityWithin 7 days
Level 3 AuthorityWithin 30 days

Reporting requirements

The Company shall collect, compile and report all such requisite complaint-related data and information to the bank in such format as may be outlined as per a pre-determined arrangement with Citibank for the purpose of onward reporting to such authorities, regulators.

Display of the Policy

The Company shall publicly display the Policy on the Company’s website/app.

Review of the Policy

The Policy will be reviewed at least annually, or earlier, if needed, in the event of any change in the regulatory framework or in business operations. All updates / changes to the Policy will be communicated to the relevant staff / relevant stakeholders on a periodic basis.