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User agreement
TECTRIX SERVICE DMCC operates under the VouWallet brand. This Agreement is concluded between TECTRIX SERVICE DMCC ("VouWallet", "Company", "we", "our") and you ("User", "You", "Your").
VouWallet operates a licensed technical platform to provide Services, and TAKING INTO ACCOUNT that User intends to use Services provided by the Company and has completed all the steps necessary to open an account in accordance with the description given in this Agreement.
In this Agreement, unless otherwise provided by the context, the definitions have the meaning provided for in the section "Definitions". Any definition used in this Agreement and not otherwise interpreted has the meaning assigned to it by Law and/or by any Directive.
Сlause headings are used solely for the convenience of creating links to individual parts of the document and do not affect the content and interpretation of the Agreement. Unless otherwise indicated in the context, the singular implies the plural and vice versa, and one gender implies the other. A reference to any agreement (including this Agreement) or to any other document is considered to include references to them, subject to amendments, additions and revisions, as well as to all agreements and documents, including additional agreements or annexes.
This Agreement includes references to the Acceptable Use Policy, Privacy Policy, and other Company documents ("Rules") that contain terms of service related to the use of the Service.
This Agreement, as well as other documents and information that, according to the law, must be provided to you as a user of the Company's Services, are always available on the Company's website https://vouwallet.io/en_documents (usually in the "Legal information" section). This information may also be sent to you by e-mail or displayed on the Company's website or in some other interface when you use the Services. Any changes/updates to this Agreement and the Rules are published in the "Legal Information" section on the Company's website, and the date of their entry into force is indicated in each separate update. Certain regulatory conditions apply.
To use Company's Services (including transferring and receiving payments) you need to open a VouWallet Account. When registering to access the Services (Account Registration), you must read, agree and accept all the terms and conditions contained in this Agreement by clicking the button under the Account registration form. We recommend that you print or save a copy of the Agreement (including the Rules) in electronic form for your personal archive. Regardless of whether you have followed the above recommendation, you acknowledge that any use of the services by you means your acceptance of the Agreement and Terms of Service. To complete the registration, you need to complete the authorization procedure for the phone number that you specified in the registration form. When executing authorization, follow the instructions given in the appropriate fields of the form on the Company's website. If you fail to complete the authorization procedure, the registration of a VouWallet Account will be rejected.
IMPORTANT NOTIFICATION AND WARNING
You are strongly advised to read and understand this Agreement before accepting its terms and conditions. It is your sole responsibility to understand and comply with all laws, rules and regulations in force in your region of residence that may apply in connection with your use of the services. Request legal advice if you are not sure that you have understood this Agreement correctly. Consider all aspects of this Agreement, Rules, relevant laws and regulations when deciding on the use of the Services. Certain restrictions provided by your local legislation that may apply to you may include, but are not limited to, foreign currency transfers, the import or export of certain goods and/or services, duties, taxes and customs regulations.
Definitions
"Account" or "VouWallet Account" means a Personal account. In the text of this agreement, this definition can mean both a user account when registering in the system, and an electronic wallet (e-wallet) reflecting the balance of electronic money (balance), depending on the context.
"Agreement" means this agreement, including all subsequent amendments and any additional documentation accompanying it, which the User should follow when working with the service.
"Balance" means any electronic funds held in your VouWallet Account.
"Working Days" means days (other than Saturdays, Sundays or public holidays/bank holidays) when banks in Dubai, UAE, are open (except for the sole purpose of round-the-clock electronic banking).
"Calendar year" means the period of each year from January 1 to December 31 inclusive.
"Chargeback" means a reparation of loss by the credit card issuer for damages from a fraudulent or disputed transaction by a Supplier of goods (services).
"Claim" means a disputing against a payment made by the person who transferred the payment directly to the Company.
"Dispute" means a dispute filed directly with the Company.
"Electronic money" means the monetary value presented as a claim to the Company, located on an electronic device, issued upon receipt of funds and accepted as a means of payment by persons other than the Company. Definitions "Electronic money", "money" and "funds" in this Agreement are interchangeable.
"Payment Method" means the payment method used to complete the transaction in accordance with the Agreement.
"Supplier of goods (services)" means an entrepreneur or a legal entity that sells goods and/or services online through its website(s) and accepts Electronic money from Users using Company's platform.
"Payment Order" means a valid payment transaction order sent to us by User.
"Payment service provider" means a payment system, a payment institution, or a financial company.
"Personal data" means any information related to a designated person who can be directly or indirectly identified in accordance with the requirements of the legislation on personal data.
"Company website(s)" means any website, for example, https://vouwallet.io/en_documents, through which we provide Services to you.
"Rules" means any rule and other agreement between you and Company entered into by you on the Company's website(s), or in connection with your use of the Services.
"Restricted activities" means the activities set out in section 11 of this Agreement.
"Services" means all products, services, content, features, technologies offered by Company (including E-Wallet services), as well as all related sites, applications and services.
"Unauthorized Transaction" and "Unauthorized Access to the Account" have the meaning specified in Section 12 of this Agreement.
"User, you, your" means you and any other person entering into this Agreement with Company or using the Services.
"Verified" means that the User has passed the data verification procedure provided by the Company, as a result of which confirmation of the User's identification data has been received.
1. Basis for the provision of Services
1. VouWallet - the brand under which Company offers its services.
Main activity of Company is the issuance of Electronic money and the provision of services directly related to the issuance of Electronic money.
Company gives you the opportunity to make payments to third parties, including Suppliers of goods (services), and accept payments from third parties, including Suppliers of goods (services).
Company also allows you to keep funds (balance) in the account, which cannot be considered either as deposits or investments and are not subject to protection in accordance with the deposit protection plan. No interest is accrued on the balance of User's funds, since VouWallet accounts are not deposit accounts.
Company does not control and is not responsible for the quality of the goods or services that you pay for using the Service, since in this case Company acts as an independent intermediary (Payment Service Provider). Lack of control means that the Company cannot guarantee that Suppliers of goods (services) fulfill their obligations to you and does not assume obligations and potential liability arising from transactions related to the purchase of goods (services) paid for by you using Company's Services.
In addition, Company cannot guarantee the authenticity of User's identification data, as well as guarantee that the transaction between the contracting parties will be successfully completed. Thus, there are natural risks associated with the inability to guarantee the authenticity of User identification data in cases where the User provides deliberately false information. This circumstance may lead to the fact that Services can be used by persons under the age of 18 (minors), despite the Company's requirement that access to the Service is prohibited for users under the age of 18.
2. Protecting your privacy is of great importance to the Company. Please read our Privacy Policy (published on our website) to understand how we intend to protect and use your personal data. Any personal data that we may use will be collected, processed and stored in accordance with the provisions of applicable law.
3. Company's brand, its website(s), URL(s), logos associated with the name, products and services described/used on electronic and paper media are copyrighted or are registered trademarks and other intellectual property of Company or its licensors. In addition, all page titles, customized graphics, button icons and scripts that are copyrighted, trademarks belong to Company. Copying, modification, corrections of any kind are strictly prohibited unless the Company has given its consent to such actions. You are prohibited from changing or modifying the material provided to you in any way, as well as using it in a manner that gives the impression that you are a sponsor of company, or company is your sponsor, changing logos, using them in any way that has a negative impact on Company or Services. All rights to the Company's website and any materials contained on the Company's website are the exclusive property of the Company and its licensors.
When providing us with content or posting content online (in each case for publication, online or offline) in the process of using the Services, you grant the Company a non-exclusive, non-territorial, permanent, irrevocable, royalty-free right to use copyrights, advertising rights, trademarks, rights to the database and other intellectual property rights that you own in relation to the content, on any media currently known or that will be known in the future. In addition, you (to the maximum extent permitted by applicable law) waive your non-proprietary copyrights (the right to authorship) and undertake not to claim such rights against the Company or its legal successors. You represent and warrant that none of the following violates any proprietary right:
4. Official language of interaction is English. Translation of documents or other information into other languages will be available on the Company's website and may be updated periodically by the Company. You agree that the information will be provided to you in the following ways:
Notifications to the Company concerning this Agreement must be sent by e-mail to: support@vouwallet.io.
5. Your transaction history and account balance can be obtained after logging into your account in the "My Transactions" section. Company will not send you transaction reports either by mail or by e-mail. You hereby confirm and agree to view your transaction history through your Account and the corresponding section of the transaction history. If for any reason (for example, limited access) it is not possible to access your transaction history through your account, you can contact our Company representatives with an appropriate request by e-mail support@vouwallet.io.
6. Transferring your account to a third party is strictly prohibited. You may transfer or assign any rights or obligations arising from this Agreement to third parties only with the prior written consent of the Company. Company has and reserves the right to transfer and assign any right or obligation under this Agreement (or this Agreement as a whole) to third parties at any time without your consent. Of course, this right does not prohibit you from closing your account with the Company and terminating this Agreement in accordance with the termination section set out below.
2. Accounts
1. Persons, who entitled to use our services are:
2. Company offers an exclusively Personal account type. Users have the right to open only one Personal account.
3. Opening an account with an unverified status allows you to transfer electronic money ("e-money"), receive electronic money and/or withdraw money from the account, taking into account the established limits. Status of an unverified user is assigned to you immediately after you open an account and fill out a form on the Company's website. To upgrade your status to verified and increase your limit, you need to follow these steps:
In addition, Company has the right to request additional documents from you during the verification process. List of a relevant documents will be provided to you by the Company.
3. Money transfer
1. In accordance with the terms of this Agreement, you agree that the Company will execute your payment order by debiting funds from your account and crediting funds to the account of the person to whom you transfer electronic money issued by the Company on the same day. Payment order can be executed through your account on the Company's website or on the website of a Supplier of goods (services) integrated with the Company's platform. If the recipient's account is with another payment service provider, payment will be executed as quickly as possible, taking into account the conditions provided to the Company by such a provider, which is usually one working day from the date we receive your payment order.
You cannot cancel or revoke a payment order that has already been received by us, just as you cannot revoke your consent to the execution of the transaction. User can cancel the payment order only in the case of a recurrent payment, or if the order to cancel the payment is submitted at least before the end of the workin day preceding the next recurrent payment. Under no circumstances is the Company obliged to execute a payment order if User does not have enough funds in the account. Company reserves the right not to make a payment until it receives a reparation for this payment from the payment service provider (this also means, without limitation, that Company is not obliged to make a refund until it receives a reparation).
2. Certain restrictions (limits) may apply to transactions on your Account due to the requirements of anti-money laundering laws and regulations, or at our reasonable discretion (for example, without limitation, in order to limit the risk of fraud or credit risk). In no case may such restrictions (limits) exceed the maximum permissible limits provided for by the legislation on the prevention of money laundering, or any other legislation or directive of the regulatory authority. Specified restrictions (limits) can be viewed in your account.
3. A number of transfer limits are imposed on all accounts. In order to increase your initial transfer limit, you need to follow the steps below to obtain a verified status. Procedures by which Company will require you to change your status and increase your limits may change from time to time. At the same time, information about these changes will be provided to you.
4. Transactions will be executed only if there is an available balance in your VouWallet account. In order to ensure that there is an available balance, you need to check your account balance and, if necessary, replenish your account by transferring funds using any of the payment methods available to you. After receiving the funds, Company will issue electronic money and save it as a balance on your account or transfer electronic money to the recipient, in each case – according to your instructions and in accordance with the terms of this Agreement.
5. You can choose the payment method at your discretion when replenishing your account balance, when making a regular payment, or when granting a third party the right to debit future payments from your VouWallet account. Your balance will be continuously used as the source of your next payment transaction.
6. Company may limit the payment methods available to you when depositing funds to your account. The reason why Company may impose such a restriction is to manage the potential risk that may result from a payment transaction. Any such restriction will be notified to you before the payment transaction is completed, at which point you will be asked to specify an alternative payment method (for example, another electronic wallet instead of a credit/debit card). Although Company may allow you to continue using the payment method that originally posed a risk, such an action will be executed with your consent and may limit your right to challenge the transaction (you may not be able to challenge the transaction due to the limitations of the payment method).
7. You cannot replenish your VouWallet account using a payment method (bank card, e-wallet or other) that you are not the owner of. Company takes violations of this kind very seriously and will consider any attempt to replenish the account with other people's payment methods as fraud. In case of detection of such actions, or attempts of such actions, your Account will be blocked, and the account balance will be frozen until the investigation of the case is completed.
8. Replenishment of the account with cash is strictly prohibited.
9. It is possible to replenish your VouWallet account using several methods: transfer to a card, cryptocurrency and Binance Pay. User chooses any convenient payment method and follows the instructions provided by the VouWallet service. In order to use the transfer to the card using the provided details, copy the details for the transfer, make a transfer to the required amount and wait for the deposit to be credited. Payment details change with each new deposit. Funds must be sent strictly by intrabank transfer, sending and receiving bank must be the same. Otherwise, the transfer of payment is not guaranteed. In order to execute this operation, you agree that:
10. When using an e-wallet provider to replenish your account balance and execute a payment transaction, you request an electronic transfer from your e-wallet account to your VouWallet account. To execute this operation, you agree that you need to instruct your e-wallet provider to make a payment to the VouWallet account. You contact your e-wallet provider directly in the manner specified by your provider and instruct him to make a payment to the VouWallet account using the provided details, as you would do when making any other payment using an e-wallet.
11. When using a payment service provider (aggregator) of a mobile operator to replenish your VouWallet account, you request a transfer from the payment service provider's account to your VouWallet account. To execute this operation, you agree that in order to replenish your balance, you need to instruct your payment service provider to make a transfer to your VouWallet account. You directly contact the payment service provider using the method established by your provider and instruct him to make a payment using the provided details, as you would do when making any other payment using an electronic wallet.
12. When using a credit or debit card to replenish your VouWallet account, you request a transfer from your credit/debit card issuer's account to your VouWallet account. To execute this operation, you agree that in order to transfer money to the VouWallet account, you need to transfer an order to the issuing bank of your card through our acquiring agent using a token. You contact the issuer of your credit/debit card not directly, but through the acquiring partner of the Company, in the manner and in the manner established by the provider, and instruct him to transfer funds to your VouWallet account. Acquiring agent uses the Token Terminal program, which is one of the ways to tokenize credit/debit card information using cryptographic technology in order to protect your personal data and card data. Company will not store any of your credit/debit card details and will not require their disclosure. Tokens are reusable and can be used to make and receive payments before their expiration date, which is linked to the expiration date of the issuer's credit/debit card.
13. Recipient is not obliged to accept the electronic money transferred to him/her, despite the availability of such an opportunity. Company cannot control such actions, and you agree not to make claims against Company for any damage resulting from the recipient's decision not to accept a payment made through the Company's service. For these purposes, Company may:
14. Currencies in which the user can make transactions are currently euros, US dollars and russian rubles. Other currencies may be added to this list, and relevant information will be posted on the Company's website. Company has the right to add or remove currencies from the list of allowed ones at its discretion. If the currency in which the user had a balance has been removed from the allowed list, the balance is stored in the specified currency until the user withdraws these funds using any of the available methods. However, this balance cannot be used for payments. For certain currencies, there may be restrictions on transfers to certain regions.
15. Upon receipt of funds sent to us using any payment method you choose, we will issue electronic money for the appropriate amount in your VouWallet Account. If we receive funds in a currency other than the Account currency you have chosen, we will not be responsible for your possible losses or expenses if our servicing bank is forced to convert currencies to exchange accepted funds into the currency of your Account.
VouWallet operates a licensed technical platform to provide Services, and TAKING INTO ACCOUNT that User intends to use Services provided by the Company and has completed all the steps necessary to open an account in accordance with the description given in this Agreement.
In this Agreement, unless otherwise provided by the context, the definitions have the meaning provided for in the section "Definitions". Any definition used in this Agreement and not otherwise interpreted has the meaning assigned to it by Law and/or by any Directive.
Сlause headings are used solely for the convenience of creating links to individual parts of the document and do not affect the content and interpretation of the Agreement. Unless otherwise indicated in the context, the singular implies the plural and vice versa, and one gender implies the other. A reference to any agreement (including this Agreement) or to any other document is considered to include references to them, subject to amendments, additions and revisions, as well as to all agreements and documents, including additional agreements or annexes.
This Agreement includes references to the Acceptable Use Policy, Privacy Policy, and other Company documents ("Rules") that contain terms of service related to the use of the Service.
This Agreement, as well as other documents and information that, according to the law, must be provided to you as a user of the Company's Services, are always available on the Company's website https://vouwallet.io/en_documents (usually in the "Legal information" section). This information may also be sent to you by e-mail or displayed on the Company's website or in some other interface when you use the Services. Any changes/updates to this Agreement and the Rules are published in the "Legal Information" section on the Company's website, and the date of their entry into force is indicated in each separate update. Certain regulatory conditions apply.
To use Company's Services (including transferring and receiving payments) you need to open a VouWallet Account. When registering to access the Services (Account Registration), you must read, agree and accept all the terms and conditions contained in this Agreement by clicking the button under the Account registration form. We recommend that you print or save a copy of the Agreement (including the Rules) in electronic form for your personal archive. Regardless of whether you have followed the above recommendation, you acknowledge that any use of the services by you means your acceptance of the Agreement and Terms of Service. To complete the registration, you need to complete the authorization procedure for the phone number that you specified in the registration form. When executing authorization, follow the instructions given in the appropriate fields of the form on the Company's website. If you fail to complete the authorization procedure, the registration of a VouWallet Account will be rejected.
IMPORTANT NOTIFICATION AND WARNING
You are strongly advised to read and understand this Agreement before accepting its terms and conditions. It is your sole responsibility to understand and comply with all laws, rules and regulations in force in your region of residence that may apply in connection with your use of the services. Request legal advice if you are not sure that you have understood this Agreement correctly. Consider all aspects of this Agreement, Rules, relevant laws and regulations when deciding on the use of the Services. Certain restrictions provided by your local legislation that may apply to you may include, but are not limited to, foreign currency transfers, the import or export of certain goods and/or services, duties, taxes and customs regulations.
Definitions
"Account" or "VouWallet Account" means a Personal account. In the text of this agreement, this definition can mean both a user account when registering in the system, and an electronic wallet (e-wallet) reflecting the balance of electronic money (balance), depending on the context.
"Agreement" means this agreement, including all subsequent amendments and any additional documentation accompanying it, which the User should follow when working with the service.
"Balance" means any electronic funds held in your VouWallet Account.
"Working Days" means days (other than Saturdays, Sundays or public holidays/bank holidays) when banks in Dubai, UAE, are open (except for the sole purpose of round-the-clock electronic banking).
"Calendar year" means the period of each year from January 1 to December 31 inclusive.
"Chargeback" means a reparation of loss by the credit card issuer for damages from a fraudulent or disputed transaction by a Supplier of goods (services).
"Claim" means a disputing against a payment made by the person who transferred the payment directly to the Company.
"Dispute" means a dispute filed directly with the Company.
"Electronic money" means the monetary value presented as a claim to the Company, located on an electronic device, issued upon receipt of funds and accepted as a means of payment by persons other than the Company. Definitions "Electronic money", "money" and "funds" in this Agreement are interchangeable.
"Payment Method" means the payment method used to complete the transaction in accordance with the Agreement.
"Supplier of goods (services)" means an entrepreneur or a legal entity that sells goods and/or services online through its website(s) and accepts Electronic money from Users using Company's platform.
"Payment Order" means a valid payment transaction order sent to us by User.
"Payment service provider" means a payment system, a payment institution, or a financial company.
"Personal data" means any information related to a designated person who can be directly or indirectly identified in accordance with the requirements of the legislation on personal data.
"Company website(s)" means any website, for example, https://vouwallet.io/en_documents, through which we provide Services to you.
"Rules" means any rule and other agreement between you and Company entered into by you on the Company's website(s), or in connection with your use of the Services.
"Restricted activities" means the activities set out in section 11 of this Agreement.
"Services" means all products, services, content, features, technologies offered by Company (including E-Wallet services), as well as all related sites, applications and services.
"Unauthorized Transaction" and "Unauthorized Access to the Account" have the meaning specified in Section 12 of this Agreement.
"User, you, your" means you and any other person entering into this Agreement with Company or using the Services.
"Verified" means that the User has passed the data verification procedure provided by the Company, as a result of which confirmation of the User's identification data has been received.
1. Basis for the provision of Services
1. VouWallet - the brand under which Company offers its services.
Main activity of Company is the issuance of Electronic money and the provision of services directly related to the issuance of Electronic money.
Company gives you the opportunity to make payments to third parties, including Suppliers of goods (services), and accept payments from third parties, including Suppliers of goods (services).
Company also allows you to keep funds (balance) in the account, which cannot be considered either as deposits or investments and are not subject to protection in accordance with the deposit protection plan. No interest is accrued on the balance of User's funds, since VouWallet accounts are not deposit accounts.
Company does not control and is not responsible for the quality of the goods or services that you pay for using the Service, since in this case Company acts as an independent intermediary (Payment Service Provider). Lack of control means that the Company cannot guarantee that Suppliers of goods (services) fulfill their obligations to you and does not assume obligations and potential liability arising from transactions related to the purchase of goods (services) paid for by you using Company's Services.
In addition, Company cannot guarantee the authenticity of User's identification data, as well as guarantee that the transaction between the contracting parties will be successfully completed. Thus, there are natural risks associated with the inability to guarantee the authenticity of User identification data in cases where the User provides deliberately false information. This circumstance may lead to the fact that Services can be used by persons under the age of 18 (minors), despite the Company's requirement that access to the Service is prohibited for users under the age of 18.
2. Protecting your privacy is of great importance to the Company. Please read our Privacy Policy (published on our website) to understand how we intend to protect and use your personal data. Any personal data that we may use will be collected, processed and stored in accordance with the provisions of applicable law.
3. Company's brand, its website(s), URL(s), logos associated with the name, products and services described/used on electronic and paper media are copyrighted or are registered trademarks and other intellectual property of Company or its licensors. In addition, all page titles, customized graphics, button icons and scripts that are copyrighted, trademarks belong to Company. Copying, modification, corrections of any kind are strictly prohibited unless the Company has given its consent to such actions. You are prohibited from changing or modifying the material provided to you in any way, as well as using it in a manner that gives the impression that you are a sponsor of company, or company is your sponsor, changing logos, using them in any way that has a negative impact on Company or Services. All rights to the Company's website and any materials contained on the Company's website are the exclusive property of the Company and its licensors.
When providing us with content or posting content online (in each case for publication, online or offline) in the process of using the Services, you grant the Company a non-exclusive, non-territorial, permanent, irrevocable, royalty-free right to use copyrights, advertising rights, trademarks, rights to the database and other intellectual property rights that you own in relation to the content, on any media currently known or that will be known in the future. In addition, you (to the maximum extent permitted by applicable law) waive your non-proprietary copyrights (the right to authorship) and undertake not to claim such rights against the Company or its legal successors. You represent and warrant that none of the following violates any proprietary right:
- your provision of content to us
- your posting of content using the Services
- the use of such content by the Company (including any works derived from it) in connection with the provision of Services.
4. Official language of interaction is English. Translation of documents or other information into other languages will be available on the Company's website and may be updated periodically by the Company. You agree that the information will be provided to you in the following ways:
- Company's website (including posting information available to you after logging into your account)
- e-mail message to the e-mail address provided by you in your account (to receive such an e-mail message, you need to have access to the Internet and to your e-mail account)
- by mail to the postal address specified in your account
Notifications to the Company concerning this Agreement must be sent by e-mail to: support@vouwallet.io.
5. Your transaction history and account balance can be obtained after logging into your account in the "My Transactions" section. Company will not send you transaction reports either by mail or by e-mail. You hereby confirm and agree to view your transaction history through your Account and the corresponding section of the transaction history. If for any reason (for example, limited access) it is not possible to access your transaction history through your account, you can contact our Company representatives with an appropriate request by e-mail support@vouwallet.io.
6. Transferring your account to a third party is strictly prohibited. You may transfer or assign any rights or obligations arising from this Agreement to third parties only with the prior written consent of the Company. Company has and reserves the right to transfer and assign any right or obligation under this Agreement (or this Agreement as a whole) to third parties at any time without your consent. Of course, this right does not prohibit you from closing your account with the Company and terminating this Agreement in accordance with the termination section set out below.
2. Accounts
1. Persons, who entitled to use our services are:
- Residents of any of the countries listed on the Company's website, with the exception of the UAE, Afghanistan, Iran, North Korea, CAR, DR of Congo, Mali, Somalia, Yemen, Libya, Sudan and South Sudan.
- Individuals (natural persons) aged 18 and over
- Persons (exclusively individuals) who have the legal right to conclude an agreement
2. Company offers an exclusively Personal account type. Users have the right to open only one Personal account.
3. Opening an account with an unverified status allows you to transfer electronic money ("e-money"), receive electronic money and/or withdraw money from the account, taking into account the established limits. Status of an unverified user is assigned to you immediately after you open an account and fill out a form on the Company's website. To upgrade your status to verified and increase your limit, you need to follow these steps:
- For account holders who are citizens of other countries: provide (i) a scanned color copy of an official document confirming your identity with your photo; and (ii) a document confirming your permanent residence (for example, a scanned utility bill, bank confirmation, internal passport or other official document that will be considered By the Company as acceptable for customer identification purposes ("know your customer", KYC)). To confirm your identity and address of residence, you must submit two different documents.
In addition, Company has the right to request additional documents from you during the verification process. List of a relevant documents will be provided to you by the Company.
3. Money transfer
1. In accordance with the terms of this Agreement, you agree that the Company will execute your payment order by debiting funds from your account and crediting funds to the account of the person to whom you transfer electronic money issued by the Company on the same day. Payment order can be executed through your account on the Company's website or on the website of a Supplier of goods (services) integrated with the Company's platform. If the recipient's account is with another payment service provider, payment will be executed as quickly as possible, taking into account the conditions provided to the Company by such a provider, which is usually one working day from the date we receive your payment order.
You cannot cancel or revoke a payment order that has already been received by us, just as you cannot revoke your consent to the execution of the transaction. User can cancel the payment order only in the case of a recurrent payment, or if the order to cancel the payment is submitted at least before the end of the workin day preceding the next recurrent payment. Under no circumstances is the Company obliged to execute a payment order if User does not have enough funds in the account. Company reserves the right not to make a payment until it receives a reparation for this payment from the payment service provider (this also means, without limitation, that Company is not obliged to make a refund until it receives a reparation).
2. Certain restrictions (limits) may apply to transactions on your Account due to the requirements of anti-money laundering laws and regulations, or at our reasonable discretion (for example, without limitation, in order to limit the risk of fraud or credit risk). In no case may such restrictions (limits) exceed the maximum permissible limits provided for by the legislation on the prevention of money laundering, or any other legislation or directive of the regulatory authority. Specified restrictions (limits) can be viewed in your account.
3. A number of transfer limits are imposed on all accounts. In order to increase your initial transfer limit, you need to follow the steps below to obtain a verified status. Procedures by which Company will require you to change your status and increase your limits may change from time to time. At the same time, information about these changes will be provided to you.
4. Transactions will be executed only if there is an available balance in your VouWallet account. In order to ensure that there is an available balance, you need to check your account balance and, if necessary, replenish your account by transferring funds using any of the payment methods available to you. After receiving the funds, Company will issue electronic money and save it as a balance on your account or transfer electronic money to the recipient, in each case – according to your instructions and in accordance with the terms of this Agreement.
5. You can choose the payment method at your discretion when replenishing your account balance, when making a regular payment, or when granting a third party the right to debit future payments from your VouWallet account. Your balance will be continuously used as the source of your next payment transaction.
6. Company may limit the payment methods available to you when depositing funds to your account. The reason why Company may impose such a restriction is to manage the potential risk that may result from a payment transaction. Any such restriction will be notified to you before the payment transaction is completed, at which point you will be asked to specify an alternative payment method (for example, another electronic wallet instead of a credit/debit card). Although Company may allow you to continue using the payment method that originally posed a risk, such an action will be executed with your consent and may limit your right to challenge the transaction (you may not be able to challenge the transaction due to the limitations of the payment method).
7. You cannot replenish your VouWallet account using a payment method (bank card, e-wallet or other) that you are not the owner of. Company takes violations of this kind very seriously and will consider any attempt to replenish the account with other people's payment methods as fraud. In case of detection of such actions, or attempts of such actions, your Account will be blocked, and the account balance will be frozen until the investigation of the case is completed.
8. Replenishment of the account with cash is strictly prohibited.
9. It is possible to replenish your VouWallet account using several methods: transfer to a card, cryptocurrency and Binance Pay. User chooses any convenient payment method and follows the instructions provided by the VouWallet service. In order to use the transfer to the card using the provided details, copy the details for the transfer, make a transfer to the required amount and wait for the deposit to be credited. Payment details change with each new deposit. Funds must be sent strictly by intrabank transfer, sending and receiving bank must be the same. Otherwise, the transfer of payment is not guaranteed. In order to execute this operation, you agree that:
- When making any transfer, you must remember that you are solely responsible for following the instructions provided, which may change from time to time. Please make sure (or ask a third party making a bank transfer for help) that when making a user's bank transfer or a third-party bank transfer, the correct bank card details provided are entered, and make sure that after making the transfer, the money is credited to your balance.
- Company does not accept any electronic transfers initiated in banking institutions registered in countries that are classified as high-risk in accordance with the regulatory requirements of FATF, EU, USA and/or United Nations in relation to aiding money laundering and financing of terrorism, including: Afghanistan, Iran, North Korea, Central Asia, DR of Congo, Mali, Somalia, Yemen, Libya, Sudan, South Sudan and UAE. Thus, any transfer initiated from the banking institutions of these countries will be blocked, and the funds will be returned to the banking institution that initiated the transfer.
- Electronic money transfer is not an analogue of online payment. In this regard, the transferred funds will be reflected in your VouWallet e-wallet only after the funds are credited to the Company's bank account.
- Company has the right to charge fees or commissions for making bank transfers in accordance with the tariffs indicated on the Website. Keep in mind that the banking organizations involved in the transaction may charge an additional fee for the execution of this transaction. Company does not control the establishment and collection of such commissions and fees and, therefore, is not responsible for their establishment and collection.
- Maximum amount of each transfer is limited by limits (daily or annual), set depending on the level/type of your VouWallet account. Thus, if the amount transferred exceeds the limit set for your e-wallet, you will be asked to go through the verification procedure. If you refuse to undergo the verification procedure, or if the amount of funds transferred exceeds the established limits, the bank transfer will not be accepted by the Company, and funds will be returned to your bank account at the servicing bank. Please keep in mind that your servicing bank may charge additional fees for such transactions.
10. When using an e-wallet provider to replenish your account balance and execute a payment transaction, you request an electronic transfer from your e-wallet account to your VouWallet account. To execute this operation, you agree that you need to instruct your e-wallet provider to make a payment to the VouWallet account. You contact your e-wallet provider directly in the manner specified by your provider and instruct him to make a payment to the VouWallet account using the provided details, as you would do when making any other payment using an e-wallet.
11. When using a payment service provider (aggregator) of a mobile operator to replenish your VouWallet account, you request a transfer from the payment service provider's account to your VouWallet account. To execute this operation, you agree that in order to replenish your balance, you need to instruct your payment service provider to make a transfer to your VouWallet account. You directly contact the payment service provider using the method established by your provider and instruct him to make a payment using the provided details, as you would do when making any other payment using an electronic wallet.
12. When using a credit or debit card to replenish your VouWallet account, you request a transfer from your credit/debit card issuer's account to your VouWallet account. To execute this operation, you agree that in order to transfer money to the VouWallet account, you need to transfer an order to the issuing bank of your card through our acquiring agent using a token. You contact the issuer of your credit/debit card not directly, but through the acquiring partner of the Company, in the manner and in the manner established by the provider, and instruct him to transfer funds to your VouWallet account. Acquiring agent uses the Token Terminal program, which is one of the ways to tokenize credit/debit card information using cryptographic technology in order to protect your personal data and card data. Company will not store any of your credit/debit card details and will not require their disclosure. Tokens are reusable and can be used to make and receive payments before their expiration date, which is linked to the expiration date of the issuer's credit/debit card.
13. Recipient is not obliged to accept the electronic money transferred to him/her, despite the availability of such an opportunity. Company cannot control such actions, and you agree not to make claims against Company for any damage resulting from the recipient's decision not to accept a payment made through the Company's service. For these purposes, Company may:
- Refund any rejected or reparation payment to your VouWallet account;
- Refund any payment not claimed by the recipient to your VouWallet account from the date you gave order to the Company to execute the payment.
14. Currencies in which the user can make transactions are currently euros, US dollars and russian rubles. Other currencies may be added to this list, and relevant information will be posted on the Company's website. Company has the right to add or remove currencies from the list of allowed ones at its discretion. If the currency in which the user had a balance has been removed from the allowed list, the balance is stored in the specified currency until the user withdraws these funds using any of the available methods. However, this balance cannot be used for payments. For certain currencies, there may be restrictions on transfers to certain regions.
15. Upon receipt of funds sent to us using any payment method you choose, we will issue electronic money for the appropriate amount in your VouWallet Account. If we receive funds in a currency other than the Account currency you have chosen, we will not be responsible for your possible losses or expenses if our servicing bank is forced to convert currencies to exchange accepted funds into the currency of your Account.
4. Receiving money
Transfer of funds to the VouWallet account from any source of the User's funds and using any means of payment provided for in the terms of this Agreement is considered final and irrevocable from the moment the balance of funds (balance) on your VouWallet account increases. From the moment of successful transfer of funds (increase in the balance) to your VouWallet account, Company's obligation to transfer the payment amount is fulfilled in full and cannot be disputed or claimed.
1. Your VouWallet account may be subject to a limit on the amount of incoming funds from time to time in accordance with the anti-money laundering laws or at our reasonable discretion (for example, without limitation, in order to limit the risk of fraud or credit risk). In no case will such limits exceed the maximum permissible limits established by the anti-money laundering laws, as well as any other law or directive related to the jurisdiction of the Company. All current limits can be viewed in your account information.
2. There are at least two limits on the amount of incoming funds imposed on all accounts. In order to increase your initial limit on the amount of incoming funds, you need to execute the following procedures to change your status. Procedures by which Company will require you to change your status and increase your limits may change from time to time. Relevant information about updating the procedures will be provided to you.
3. Company has the right to review all payment transactions and will be entitled to do so in all cases when it considers that there is an operational risk. Such actions will be executed if Company has a reasonable suspicion that the payment transaction may be related to restricted or prohibited activities, or for other reasons determined by the Company. When reviewing the payment, Company will execute User's order for the payment, but at the same time suspend the issuance of electronic money in favor of the specified recipient. This operation means that the specified payment amount will be debited from User's account, but the corresponding amount will not be credited to the recipient's account, resulting in a balance with a deferred obligation. If the transaction involves the purchase of goods, Company will notify the seller of the need to hold the goods until Company completes the verification of the transaction and authorizes the transaction.
If the transaction is deemed unacceptable, Company will reject the payment and return the electronic money to the sender's account. Company will notify you by e-mail. Payment is subject to approval for the sole purpose of minimizing the risk of Company, as well as the risk of transactions of its Users. At the same time, Company does not intend to influence the business relations of the interested parties, their reputation, or discredit the participants in the transaction in any way.
4. Upon receipt of funds, Company increases the balance of electronic funds in the account and makes it available for other payment transactions or debit operations. Notifications from Company that you are the recipient of electronic money are confirmation that balance of electronic funds has been increased and has become available for transactions. You confirm and agree that the payment transaction has been executed and the funds have been received by you upon receipt of the relevant notification from Company, even if the transaction is subject to cancellation for the reasons set out in this Agreement. If funds were credited to your account by mistake, you can contact Company's Support Service to cancel the operation and receive further instructions.
Invalidity of a transaction as a result of cancellation, abolition or suspension does not release you from liability to Company, and you continue to be responsible for any amount owed to Company plus any fees associated with payments.
5. Recipient can receive funds in any currency allowed by the Company, regardless of the currency in the account at the time of the transaction, if the payment is accepted. In this case, Company will credit the amount to your account in the currency in which it was sent. You confirm and agree that if you have accounts in several currencies open at the time of debiting funds, it may be necessary to convert funds in the currency of your account into the currency of the account of another payment method during the transaction.
This may entail additional fees unrelated to Company and its Services, for which Company is not responsible. Contact your payment method provider directly and request information about such potential fees and its currency conversion policy.
6. Company is not responsible for the accrual of any taxes related to your transaction, as well as for the collection, filing of reports and payment of taxes that are levied on any transaction. You agree that it is your sole responsibility to record taxes related to the transaction, as well as to further collect, report and pay taxes related to any transaction to the appropriate tax authority.
5. Information about account balances and transactions
1. User can check his account balance and information about the history of his transactions (including currency exchange transactions) at any time by logging into his account. To do this, you need to log in to your account using your credentials (username and password). After that, you will be asked to enter an SMS code, which you will receive on your mobile phone, for further authorization and access to your account and credentials. Balance will be permanently displayed in the left corner of your account interface. Transaction history contains information about the service, transaction number, currency, transaction amount, fees associated with each transaction, and transaction status.
After logging into your account, you can print hard (paper) copy of the transaction history registry or export the registry in CSV/XLS format. Online operation history for the last 24 months is available to you. If you want to receive an extract for a period earlier than the last 24 months, you need to contact customer support to receive an extract offline. In offline mode, it is possible to receive an extract for a period within the last 60 months (five years), and you may be charged a commission for such a request. Information about the possible collection will be sent to you before you send us an order.
2. Account balance will be displayed continuously, even if it is zero. No interest is paid on the positive balances, since the balance is expressed in electronic money, and account is not a deposit account, therefore no interest is accrued on the account balances.
3. You agree that Company may debit any amounts owed to the Company from the amounts of your VouWallet account. Company will seek to repay any debt owed by User to the Company in euros. If User has a debt to the Company, but does not have an account in euros, Company has the right to use other payment methods. You agree that such potential ways are:
4. As security for any potential amounts owed by User to the Company, User agrees to grant the Company a pre-emptive right of claim ("right of retention") in respect of balances and receipts on your account.
5. Currencies in which Company allows you to carry out transactions are not linked to any other currency, and their exchange rate fluctuates daily. Maintaining accounts in multiple currencies can be risky and lead to potential loss (or profit), which will become apparent on the day you decide to withdraw the account balance in a currency other than your account currency. Company prohibits the maintenance of accounts in several different currencies for the purpose of speculation (playing on exchange rates). You agree not to commit such actions and assume the risk associated with maintaining accounts in multiple currencies.
6. Debiting/repayment of electronic money
1. Debiting is actually a requirement to repay electronic money in your account and convert it into real money. Users can send an order to Company to partially or completely debit the account balance in the currency in which the account is contained, if payment method you choose can accept payments denominated in the currency of your account. Debiting can only be made to a valid payment method that has been confirmed as your own.
2. Debiting limits may be set for your account from time to time to comply with the requirements of anti-money laundering laws and regulations or at our reasonable discretion (for example, without limitation, in order to limit the risk of fraud or credit risk). In no case will such limits exceed the maximum permissible limits established by anti-money laundering laws or any other law or directive related to the jurisdiction under which Company is granted rights. Such limits can be viewed in your personal account.
3. At least two debiting limits are imposed on your accounts. In order to increase your initial debiting limit, you need to follow the steps below in order to obtain the status of a verified user. Procedures during which Company will require you to change your status and raise your limits may change from time to time. Relevant information about updating the procedures will be provided to you.
4. Company has the right to verify all debit transactions from the account and will do so in cases where the probability of risk increases. Such checks will be carried out when Company has a reasonable suspicion that the debiting operation may be related to restricted or prohibited activities, or for another reason, at the discretion of Company. When checking the debit from the account, Company will consider your debiting/repayment order as a future payment order. After Company decides that there is no longer a risk for making a debiting/repayment, it will fulfill it within the time limits provided for in this Agreement. You agree that if your debiting/repayment order is executed, this order will be executed one working day after the restriction is lifted.
5. When using a bank transfer for debiting of electronic funds from your VouWallet account, you need to initiate a bank transfer from your e-wallet to your bank account opened with the servicing bank. To execute such an operation, you agree that:
7. Term and termination of the Agreement - Closing your Account
1. This Agreement begins to take effect from the moment when the potential user receives an electronic message about the e-wallet number, and is valid indefinitely until its termination or termination due to the impossibility of execution.
2. Company reserves the right to make changes to any part of the Agreement, especially if Company considers that such changes are necessary according to the statement of the regulatory authority of the competent jurisdiction or the need to change the list or terms of Service. Thus, User must be notified fifteen (15) working days prior to the application of such changes in writing (including by e-mail) or via the Company's website, and User has the right to accept or reject such changes, except in cases where such amendments are based on the requirement of the law and enter into force immediately or within the period specified in the law. It should be borne in mind that User's consent is not required for the changes to take effect.
3. User reserves the right to terminate this agreement within 15 (fifteen) working days from the date of announcement of changes in accordance with clause 7.2. by sending a notification by registered mail to the Company's Head Office or by e-mail (to the e-mail address specified by the Company in your user profile), provided that User has no outstanding transactions on the account and no obligations to the Company.
4. User reserves the right to terminate this agreement for any reason, except for the case specified in clause 7.3., by sending a written notification to the Company's Head Office 7 (seven) working days in advance by registered mail, provided that User has no unfinished transactions on the account of outstanding obligations to the Company.
5. Company may terminate this Agreement by sending a written notice to the User at least 15 (fifteen) working days in advance indicating the date of termination.
6. User agrees that Company reserves the right to block the account, as well as terminate the Agreement immediately by sending him a written notification, in the event:
7. Termination of this Agreement does not cancel any responsibility of User; the latter, as before, bears obligations to the Company for payment:
8. Upon termination of this Agreement, Company immediately transfers to User the amount available in his e-wallet account, minus the amount owed by User to the Company and taking into account the Company's debt to the User.
9. If clause 7.6. is implemented, Company reserves the right to abolition any transactions that are contrary to the interests of Company or User. If User's e-wallet account is not used for 365 (three hundred and sixty-five) days, Company reserves the right to charge a fine for non-use of the wallet in the amount set on the Company's website (if applicable).
10. If the amount in User's e-wallet account is less than 10 euros (or the equivalent in another currency), Company reserves the right to close the account, notifying the User accordingly, and withhold the appropriate commission.
11. Account cannot be closed if transactions on it have signs of fraud, and Company is conducting an appropriate investigation or for other reasons requiring such actions. Company has the right to withhold the balance on your account for 120 (one hundred and twenty) calendar days from the day when you intend to close your account in order to protect yourself and any third party from potential liability of any kind related to the use of your account or the reasons identified as a result of the investigation. You agree that even after your account is closed, you are obligated to fulfill any obligations related to the use of your account while it was in operation.
8. Fees
1. All stipulated fees charged to Users (commission fee), as well as applicable restrictions (limits) are listed on Company's website.
2. Currently, Company provides a currency conversion service that provides you with the opportunity to transfer funds between your accounts in different currencies. You can find detailed information about this service at any time in the on-screen menu of your VouWallet Account.
9. User responsibility
1. Users are responsible for the following actions (or other actions that Company may periodically inform you about):
10. Company Rights
1. Company has the legal right (and in certain cases the obligation) to take actions necessary to eliminate the consequences of User's actions. Company will take measures to protect its interests, as well as the interests of its Users, dependents and other third parties who may be affected as a result of possible restricted or prohibited activities. List of basic compensation measures includes the following actions:
2. Company may suspend a payment transaction if there is a reasonable suspicion that it violates the rules regarding limited activities and/or our policy related to the acceptable use of the Company's system/services.
3. If user violates the requirements of the law or this Agreement, Company has the right to block User VouWallet account without prior notice and at any time..
4. Suspension of a payment transaction:
6. In order to comply with anti-money laundering laws, Company may require you to provide additional information necessary to identify your identity and determine your financial situation. Set of requested information is more than is usually required when opening an account, however, you agree to fulfill such requests and provide Company with the necessary information by e-mail, fax and any other means and in any form that may be requested. Such information may include identification documents confirming your identity and registration address, as well as (if necessary) provide us with information about your sources of income at your expense. Any personal data that we may use will be collected, processed and stored in accordance with the provisions of the laws of Dubai, UAE.
7. Customer does not have the right to make any changes to the Wallet software and/or any part of it on his own or with the involvement of third parties, as well as use any means of automated access to the Wallet, unless otherwise agreed; does not have the right to execute actions aimed at or resulting in disruption of the normal functioning of equipment and software of the Company's website, does not have the right to use programs and apply other measures that allow Customer to hide technical characteristics of connection to the Internet for using the Wallet from Company.
8. User is obliged to ensure the storage of Authorization data in a way that excludes the possibility of obtaining access to them by third parties, in particular, not to record Authorization data in such a way that it is possible to determine what these Authorization data relate to, not to save them electronically, including in special programs for storing passwords. User is obliged to independently take all necessary measures to preserve confidentiality, prevent unauthorized use and protect his Wallet from unauthorized access by third parties.
9. User is obliged to:
Transfer of funds to the VouWallet account from any source of the User's funds and using any means of payment provided for in the terms of this Agreement is considered final and irrevocable from the moment the balance of funds (balance) on your VouWallet account increases. From the moment of successful transfer of funds (increase in the balance) to your VouWallet account, Company's obligation to transfer the payment amount is fulfilled in full and cannot be disputed or claimed.
1. Your VouWallet account may be subject to a limit on the amount of incoming funds from time to time in accordance with the anti-money laundering laws or at our reasonable discretion (for example, without limitation, in order to limit the risk of fraud or credit risk). In no case will such limits exceed the maximum permissible limits established by the anti-money laundering laws, as well as any other law or directive related to the jurisdiction of the Company. All current limits can be viewed in your account information.
2. There are at least two limits on the amount of incoming funds imposed on all accounts. In order to increase your initial limit on the amount of incoming funds, you need to execute the following procedures to change your status. Procedures by which Company will require you to change your status and increase your limits may change from time to time. Relevant information about updating the procedures will be provided to you.
3. Company has the right to review all payment transactions and will be entitled to do so in all cases when it considers that there is an operational risk. Such actions will be executed if Company has a reasonable suspicion that the payment transaction may be related to restricted or prohibited activities, or for other reasons determined by the Company. When reviewing the payment, Company will execute User's order for the payment, but at the same time suspend the issuance of electronic money in favor of the specified recipient. This operation means that the specified payment amount will be debited from User's account, but the corresponding amount will not be credited to the recipient's account, resulting in a balance with a deferred obligation. If the transaction involves the purchase of goods, Company will notify the seller of the need to hold the goods until Company completes the verification of the transaction and authorizes the transaction.
If the transaction is deemed unacceptable, Company will reject the payment and return the electronic money to the sender's account. Company will notify you by e-mail. Payment is subject to approval for the sole purpose of minimizing the risk of Company, as well as the risk of transactions of its Users. At the same time, Company does not intend to influence the business relations of the interested parties, their reputation, or discredit the participants in the transaction in any way.
4. Upon receipt of funds, Company increases the balance of electronic funds in the account and makes it available for other payment transactions or debit operations. Notifications from Company that you are the recipient of electronic money are confirmation that balance of electronic funds has been increased and has become available for transactions. You confirm and agree that the payment transaction has been executed and the funds have been received by you upon receipt of the relevant notification from Company, even if the transaction is subject to cancellation for the reasons set out in this Agreement. If funds were credited to your account by mistake, you can contact Company's Support Service to cancel the operation and receive further instructions.
Invalidity of a transaction as a result of cancellation, abolition or suspension does not release you from liability to Company, and you continue to be responsible for any amount owed to Company plus any fees associated with payments.
5. Recipient can receive funds in any currency allowed by the Company, regardless of the currency in the account at the time of the transaction, if the payment is accepted. In this case, Company will credit the amount to your account in the currency in which it was sent. You confirm and agree that if you have accounts in several currencies open at the time of debiting funds, it may be necessary to convert funds in the currency of your account into the currency of the account of another payment method during the transaction.
This may entail additional fees unrelated to Company and its Services, for which Company is not responsible. Contact your payment method provider directly and request information about such potential fees and its currency conversion policy.
6. Company is not responsible for the accrual of any taxes related to your transaction, as well as for the collection, filing of reports and payment of taxes that are levied on any transaction. You agree that it is your sole responsibility to record taxes related to the transaction, as well as to further collect, report and pay taxes related to any transaction to the appropriate tax authority.
5. Information about account balances and transactions
1. User can check his account balance and information about the history of his transactions (including currency exchange transactions) at any time by logging into his account. To do this, you need to log in to your account using your credentials (username and password). After that, you will be asked to enter an SMS code, which you will receive on your mobile phone, for further authorization and access to your account and credentials. Balance will be permanently displayed in the left corner of your account interface. Transaction history contains information about the service, transaction number, currency, transaction amount, fees associated with each transaction, and transaction status.
After logging into your account, you can print hard (paper) copy of the transaction history registry or export the registry in CSV/XLS format. Online operation history for the last 24 months is available to you. If you want to receive an extract for a period earlier than the last 24 months, you need to contact customer support to receive an extract offline. In offline mode, it is possible to receive an extract for a period within the last 60 months (five years), and you may be charged a commission for such a request. Information about the possible collection will be sent to you before you send us an order.
2. Account balance will be displayed continuously, even if it is zero. No interest is paid on the positive balances, since the balance is expressed in electronic money, and account is not a deposit account, therefore no interest is accrued on the account balances.
3. You agree that Company may debit any amounts owed to the Company from the amounts of your VouWallet account. Company will seek to repay any debt owed by User to the Company in euros. If User has a debt to the Company, but does not have an account in euros, Company has the right to use other payment methods. You agree that such potential ways are:
- Retention from the amount credited to your account
- Retention from the amount requested for debiting
- Using the amount in another currency in your account. When using this method, you agree to pay any fees related to currency conversion.
4. As security for any potential amounts owed by User to the Company, User agrees to grant the Company a pre-emptive right of claim ("right of retention") in respect of balances and receipts on your account.
5. Currencies in which Company allows you to carry out transactions are not linked to any other currency, and their exchange rate fluctuates daily. Maintaining accounts in multiple currencies can be risky and lead to potential loss (or profit), which will become apparent on the day you decide to withdraw the account balance in a currency other than your account currency. Company prohibits the maintenance of accounts in several different currencies for the purpose of speculation (playing on exchange rates). You agree not to commit such actions and assume the risk associated with maintaining accounts in multiple currencies.
6. Debiting/repayment of electronic money
1. Debiting is actually a requirement to repay electronic money in your account and convert it into real money. Users can send an order to Company to partially or completely debit the account balance in the currency in which the account is contained, if payment method you choose can accept payments denominated in the currency of your account. Debiting can only be made to a valid payment method that has been confirmed as your own.
2. Debiting limits may be set for your account from time to time to comply with the requirements of anti-money laundering laws and regulations or at our reasonable discretion (for example, without limitation, in order to limit the risk of fraud or credit risk). In no case will such limits exceed the maximum permissible limits established by anti-money laundering laws or any other law or directive related to the jurisdiction under which Company is granted rights. Such limits can be viewed in your personal account.
3. At least two debiting limits are imposed on your accounts. In order to increase your initial debiting limit, you need to follow the steps below in order to obtain the status of a verified user. Procedures during which Company will require you to change your status and raise your limits may change from time to time. Relevant information about updating the procedures will be provided to you.
4. Company has the right to verify all debit transactions from the account and will do so in cases where the probability of risk increases. Such checks will be carried out when Company has a reasonable suspicion that the debiting operation may be related to restricted or prohibited activities, or for another reason, at the discretion of Company. When checking the debit from the account, Company will consider your debiting/repayment order as a future payment order. After Company decides that there is no longer a risk for making a debiting/repayment, it will fulfill it within the time limits provided for in this Agreement. You agree that if your debiting/repayment order is executed, this order will be executed one working day after the restriction is lifted.
5. When using a bank transfer for debiting of electronic funds from your VouWallet account, you need to initiate a bank transfer from your e-wallet to your bank account opened with the servicing bank. To execute such an operation, you agree that:
- In order to transfer funds from your VouWallet account, you must place a corresponding request through the VouWallet system for making a transfer from Company's account to your account with the servicing bank. Details of our bank account, as well as detailed instructions on how to make a bank transfer, will be provided to you via the VouWallet website. Thus, before executing any bank transfer, you are solely responsible for following the instructions provided, which may be supplemented from time to time. Company can save your bank account details.
- Company does not accept for execution any orders on bank transfers in favor of banking institutions registered in countries that are classified as high-risk in accordance with the regulatory requirements of FATF, EU, USA and/or United Nations in relation to aiding money laundering and financing of terrorism. Thus, any order to make a transfer in favor of the banking institutions of these countries will be blocked and will not be accepted for execution.
- Bank transfer is not an analogue of an online payment. In this case, the operation of debiting funds from your VouWallet e-wallet will be reflected in it as soon as the corresponding order is placed in the VouWallet system.
- Minimum allowable amount of a bank transfer is indicated on the Company's Website. Maximum amount of each transfer is limited by limits (daily or annual), set depending on the level/type of your VouWallet account. Thus, if the amount transferred exceeds the limit set for your e-wallet, you will be asked to go through the verification procedure. If you refuse to undergo the verification procedure, or if the amount of funds transferred exceeds the established limits or the amount of the current balance of your account plus the amount of any possible bank fees and/or commissions, and/or any commissions charged by the Company for the transaction specified in Section 9 of this Agreement, the transaction will not be carried out. Funds will remain in our customer account until the verification procedure is completed. Please keep in mind that you have the right to cancel the operation before funds are debited from the Company's customer account. Company has the right to charge commissions in the amount indicated on the Company's website.
7. Term and termination of the Agreement - Closing your Account
1. This Agreement begins to take effect from the moment when the potential user receives an electronic message about the e-wallet number, and is valid indefinitely until its termination or termination due to the impossibility of execution.
2. Company reserves the right to make changes to any part of the Agreement, especially if Company considers that such changes are necessary according to the statement of the regulatory authority of the competent jurisdiction or the need to change the list or terms of Service. Thus, User must be notified fifteen (15) working days prior to the application of such changes in writing (including by e-mail) or via the Company's website, and User has the right to accept or reject such changes, except in cases where such amendments are based on the requirement of the law and enter into force immediately or within the period specified in the law. It should be borne in mind that User's consent is not required for the changes to take effect.
3. User reserves the right to terminate this agreement within 15 (fifteen) working days from the date of announcement of changes in accordance with clause 7.2. by sending a notification by registered mail to the Company's Head Office or by e-mail (to the e-mail address specified by the Company in your user profile), provided that User has no outstanding transactions on the account and no obligations to the Company.
4. User reserves the right to terminate this agreement for any reason, except for the case specified in clause 7.3., by sending a written notification to the Company's Head Office 7 (seven) working days in advance by registered mail, provided that User has no unfinished transactions on the account of outstanding obligations to the Company.
5. Company may terminate this Agreement by sending a written notice to the User at least 15 (fifteen) working days in advance indicating the date of termination.
6. User agrees that Company reserves the right to block the account, as well as terminate the Agreement immediately by sending him a written notification, in the event:
- Violations of any part of the Agreement by or on User's behalf
- Filing an application to the court, issuing an order, decision or other declaration of bankruptcy of User
- Company has reason to believe that the current record of Company's service belongs to you and is used to carry out illegal actions, legalization (laundering) of proceeds from crime, theft/concealment of funds or financing of terrorism; In this case, Company has the right, in addition to terminating the agreement, to report the violation to law enforcement agencies, as well as disclaims responsibility for any actions of User in view of violation of the terms of this Agreement.
- Death of User (in case of an individual user)
7. Termination of this Agreement does not cancel any responsibility of User; the latter, as before, bears obligations to the Company for payment:
- Any amount owed to the Company
- Any expenses incurred by the Company as a result of termination of the Agreement
- Any damage caused by the conclusion of an agreement or settlement
8. Upon termination of this Agreement, Company immediately transfers to User the amount available in his e-wallet account, minus the amount owed by User to the Company and taking into account the Company's debt to the User.
9. If clause 7.6. is implemented, Company reserves the right to abolition any transactions that are contrary to the interests of Company or User. If User's e-wallet account is not used for 365 (three hundred and sixty-five) days, Company reserves the right to charge a fine for non-use of the wallet in the amount set on the Company's website (if applicable).
10. If the amount in User's e-wallet account is less than 10 euros (or the equivalent in another currency), Company reserves the right to close the account, notifying the User accordingly, and withhold the appropriate commission.
11. Account cannot be closed if transactions on it have signs of fraud, and Company is conducting an appropriate investigation or for other reasons requiring such actions. Company has the right to withhold the balance on your account for 120 (one hundred and twenty) calendar days from the day when you intend to close your account in order to protect yourself and any third party from potential liability of any kind related to the use of your account or the reasons identified as a result of the investigation. You agree that even after your account is closed, you are obligated to fulfill any obligations related to the use of your account while it was in operation.
8. Fees
1. All stipulated fees charged to Users (commission fee), as well as applicable restrictions (limits) are listed on Company's website.
2. Currently, Company provides a currency conversion service that provides you with the opportunity to transfer funds between your accounts in different currencies. You can find detailed information about this service at any time in the on-screen menu of your VouWallet Account.
9. User responsibility
1. Users are responsible for the following actions (or other actions that Company may periodically inform you about):
- Using Company's services in a manner that causes complaints, disputes, claims, cancellations, chargebacks, fees, fines, penalties and other types of liability to the Company, User or a third party. In this case, you agree to reimburse the Company, User or a third party for any damage caused by your actions and settle with Company for any amounts owed from the available balance on your account. If the amount in your account is insufficient to cover the debt, you agree that Company can use any proceeds to the account from the transaction, and if such amounts do not cover the debt, allow the Company to recover the amount by other legal means.
- In case of disputed amounts related to customer claims, cancellation of a payment received by you or a chargeback, Company will block part of your account funds to cover the full amount of the claim. Blocking will not affect your ability to use the account if your account balance exceeds the disputed blocked amount. If the dispute is resolved in your favor, Company will restore full access to your account and unlock the disputed amount. On the contrary, if the dispute is resolved in favor of the disputing party, the blocked amount will be debited from your account to repay the disputed amount..
10. Company Rights
1. Company has the legal right (and in certain cases the obligation) to take actions necessary to eliminate the consequences of User's actions. Company will take measures to protect its interests, as well as the interests of its Users, dependents and other third parties who may be affected as a result of possible restricted or prohibited activities. List of basic compensation measures includes the following actions:
- Company may suspend, block partially or completely any transaction, restrict use, revoke access or close your account completely. Such a measure will limit or suspend:
- Funds transfer
- Receiving funds
- Debiting/repayment of funds
- Making changes to your account details; and/or
- Access to your account history.
- Company may suspend a payment transaction if there is a reasonable suspicion that it violates the rules regarding limited activities and/or our policy related to the acceptable use of the Company's system/services.
- Company has the right to reject any payment transaction for any reason without limitation. Unless prohibited by applicable law, Company is obliged to provide information on the reasons for taking measures, as well as, if possible, any legal remedies that the affected party has the right to take in order to remove the restriction.
- Company has the right to refuse to provide any of the services at any time.
- In accordance with the law, any information necessary to identify the user must be up-to-date. Company has the right to request that you update the information if it considers it outdated or insufficient. In addition, Company has the right to require that you provide the information necessary to verify your identity, even without your request to increase the limit on transfer, receipt or debit from your account.
- In order to prevent prohibited activities, Company has the right to disclose information related to such activities to third parties, while following the terms of the Rules.
- Company has the right to block the necessary balance of your funds for a period of time, which in any case cannot exceed 180 working days (unless otherwise provided by law, decree or decision of the court/management body), for reasons of protection against the risk of liability.
- Company has the right to bring a lawsuit against you in any competent court..
2. Company may suspend a payment transaction if there is a reasonable suspicion that it violates the rules regarding limited activities and/or our policy related to the acceptable use of the Company's system/services.
3. If user violates the requirements of the law or this Agreement, Company has the right to block User VouWallet account without prior notice and at any time..
4. Suspension of a payment transaction:
- You hereby agree that Company has the right to suspend a payment transaction if, according to the Company, the risk from this transaction exceeds the permissible one. You will be informed about such actions by the Company.
- When security threat is eliminated, Company will resume actions to execute the payment transaction. If the suspension of the operation is not related to acceptable levels of risk or operational risk, but is related to the actions provided for in clause 11.1.1, Company may suspend the operation until the dispute is resolved..
- Company has the right to close the VouWallet account and terminate this Agreement if User objects to the suspension of the operation. In addition, User also has the right to close the VouWallet account if he/she objects to the suspension of any operation. You agree that Company may reasonably request information from you that will reduce or eliminate the risk of suspension of account transactions. If you refuse to provide such information, Company has the right to close your account and terminate the agreement. In case of account closure, Company has the right to block an amount equal to the amount of the corresponding payment transaction in order to cover any potential obligations arising from this transaction.
6. In order to comply with anti-money laundering laws, Company may require you to provide additional information necessary to identify your identity and determine your financial situation. Set of requested information is more than is usually required when opening an account, however, you agree to fulfill such requests and provide Company with the necessary information by e-mail, fax and any other means and in any form that may be requested. Such information may include identification documents confirming your identity and registration address, as well as (if necessary) provide us with information about your sources of income at your expense. Any personal data that we may use will be collected, processed and stored in accordance with the provisions of the laws of Dubai, UAE.
7. Customer does not have the right to make any changes to the Wallet software and/or any part of it on his own or with the involvement of third parties, as well as use any means of automated access to the Wallet, unless otherwise agreed; does not have the right to execute actions aimed at or resulting in disruption of the normal functioning of equipment and software of the Company's website, does not have the right to use programs and apply other measures that allow Customer to hide technical characteristics of connection to the Internet for using the Wallet from Company.
8. User is obliged to ensure the storage of Authorization data in a way that excludes the possibility of obtaining access to them by third parties, in particular, not to record Authorization data in such a way that it is possible to determine what these Authorization data relate to, not to save them electronically, including in special programs for storing passwords. User is obliged to independently take all necessary measures to preserve confidentiality, prevent unauthorized use and protect his Wallet from unauthorized access by third parties.
9. User is obliged to:
- Ensure the antivirus security of the device used to access VouWallet
- Do not use other people's computers or other devices to access VouWallet
- Before entering the password, make sure that it is not monitored, including using technical means
11. Errors and unauthorized operations
1. Company acknowledges that unauthorized or erroneous transactions are possible, and emphasizes that you need to regularly monitor your account by reviewing your transaction history.
List is not exhaustive:
2. If you have any questions or difficulties using VouWallet, you can contact Support Service by sending your request to the email address support@vouwallet.io. You can also use Telegram bot @Wallet_Help_bot, which will be able to answer some questions related to using VouWallet.
3. Company will review the submitted reports and report on the results of the investigation within 15 (fifteen) working days from the date of User's initial request. If the initial request was made by phone, the day of registration of the complaint will be considered the day Company submits a description of the problem in writing. Depending on the complexity of the investigation, Company may take up to 3 (three) additional months for a more complete review of the appeal before coming to a reasonable conclusion. Company will try to correct any error caused by its actions as soon as possible in order to allow User to fully use the account.
After the investigation is completed, the results will be communicated to you in writing by registering the incident in the Company's system and sending it to you. The message will contain the results of the investigation and explanations of the established facts that led to the final results. If Company has previously recognized the transaction as erroneous and credited the corresponding amount to your account, but as a result of the investigation it was found that there was no error, Company has the right to retain the same amount from your account as if the transaction was never considered erroneous. Users who have reported an error can request copies of the materials used for the investigation.
4. Company will correct all errors that may be caused by incorrect operation of its system. Errors are usually detected during the reconciliation of calculations. In the event that a smaller amount was mistakenly credited to your account than the amount that is owed to you, Company will deposit the missing difference to your account. Conversely, if an amount exceeding the required amount has been credited to your account, Company will debit the difference from your account. Company will be responsible for reparation of funds for any transaction that was carried out for an incorrect amount or untimely, as well as for any losses and damages directly related to this transaction, except in cases where:
5. Company will not be responsible for any incomplete/failed operations if User does not report such incomplete/failed operations to Company within 360 calendar days from the date when he/she became aware of the incomplete/failed operation.
12. Disputes and dispute resolution
1. Company understands that disputes may arise between Company and User in connection with the services provided. Company's goal is to resolve disputes in an effective manner, as a result of which Users will be satisfied with their cooperation with Company as a whole. Company also understands that some disputes are difficult to resolve without the participation of an independent party, and in certain cases – without using a special dispute resolution mechanism.
2. If you have any claims related to your account, contact Customer Support and report the problem. Customer support service reviews claims upon your request. You can also file a complaint to Customer Support by e-mail. Detailed information about the procedure for reviewing applications is published on Company's website.
3. In any way you contact Customer Support, you will need to state the essence of the problem in writing.
4. If you have received a response from Customer Support Service, but you believe that the complaint requires additional consideration, you can ask Customer Support Service to forward your complaint to a regulatory compliance department.
5. Company complies with the directives of local regulatory bodies regarding business activities.
6. Following these complaint procedures will not affect your legal rights.
7. Governing law and jurisdiction. This Agreement and the relationship between Company and Users are governed by the laws of Dubai, UAE.
8. Any inaction of Company in connection with User's violation of the terms of this Agreement should not be interpreted as a waiver of Company's right to take action in case of similar or subsequent violations.
9. If it is considered that Company has violated the Agreement, which has led to losses or direct damage to User, its liability will have the following limits:
13. Software Rights and Licenses
1. Company and, where applicable, its Licensors grant you a limited, non-exclusive license to use any software applications that you access or download to your personal computer, mobile device or platform, including Application Programming Interface (API) or Developer tools, as appropriate. In accordance with this Agreement, this software is intended for your personal use only. Transfer of your rights to use or lease this software is strictly prohibited. Any such action serves as the basis for termination of this Agreement, and may also cause further lawsuits by Company. In addition, you agree not to modify, reproduce, adapt, distribute, display, publish, decompile, broadcast, or otherwise attempt to recreate any source code derived from software product. You hereby confirm that all rights to this software belong exclusively to Company or a third-party provider, depending on the contractual relationship between Company and third-party provider.
14. Our website and mobile application
1. General information. The content of our website and mobile application is provided solely for informational purposes. Any information should not be considered as advice or a guide to action. You need to consult with a professional consultant before executeing certain actions or refusing to execute such actions based on the information contained on the website or in the mobile application. Although we take appropriate and reasonable measures to keep the information on the site or in the mobile application up to date, we do not provide any representations or warranties (either express or implied) that any information on the site or in the mobile application is complete and up-to-date.
2. Changes on the website and in the mobile application.
3. We are not responsible for the content of websites linked to which may be present on our site.
If our site contains links to third-party websites and information resources, then such links are for informational purposes only. Psresence of such links should not be interpreted by you as our confirmation of the accuracy of the information posted on these links. We are not responsible for and do not control the content of third-party websites and information resources.
15. Reparation
1. User guarantees reparation at the request of Company, of any costs incurred in issuing electronic money or ancillary services, including, without limitation, (i) violation of this Agreement by User; or (ii) false or misleading information provided by User to Company.
16. General provisions
Non-waiver: the inability or delay of either party in using the rights or remedies established by this Agreement or the law does not constitute a waiver of this (or any other) right or legal remedy and does not prevent its further use. No one-time or partial use of such right or legal remedy shall prevent or restrict the further use of this (or any other) right or legal remedy and shall not be interpreted as a waiver of a right or claim in connection with any subsequent violation or non-performance of the same or any other provisions of this Agreement.
Completeness of the Agreement: This agreement, its annexes and all its constituent documents and documents referred to in this agreement constitute the entire agreement between the parties with respect to its subject matter, replace and cancel all previous agreements, agreements and discussions between them, both oral and written, with respect to this subject matter.
Divisibility: All provisions of this agreement are independent and divisible. If any provision of the Agreement (or part of any provision) is found by a court or other authority of competent jurisdiction to be invalid, unenforceable or illegal, this does not detract from the validity of this agreement and does not affect the other provisions that remain in force.
A person who is not a party to the Agreement has no right to demand fulfillment of the terms of the Agreement.
Regulatory legislation: Agreement and all matters arising in connection with it, as well as any dispute arising between parties in connection with the Agreement, shall be governed by and interpreted in accordance with the laws of Dubai, UAE. Competent courts of Dubai, UAE, have exclusive jurisdiction over legal proceedings arising out of or related to this Agreement, and the parties to this Agreement unconditionally submit to such exclusive jurisdiction. However, this does not deprive the Company of the opportunity to initiate any claim in a court of any other jurisdiction for judicial or similar protection.
Language: When we provide you with a translation of the English version of the agreement, privacy policy or any other document, you agree that the translation is provided only for your convenience and does not change the English version, and you agree that the English version regulates our relationship. Both parties agree to conduct all correspondence related to this Agreement in English. If we send or receive correspondence in another language, this is done only for your convenience and does not constitute a departure from the above or a precedent for further correspondence.
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
1. Company acknowledges that unauthorized or erroneous transactions are possible, and emphasizes that you need to regularly monitor your account by reviewing your transaction history.
List is not exhaustive:
- Access to your account was executed by a person who does not have access rights
- Operation was processed incorrectly
- Your account has been used to make a transaction that you have not confirmed
- Your password has been compromised
2. If you have any questions or difficulties using VouWallet, you can contact Support Service by sending your request to the email address support@vouwallet.io. You can also use Telegram bot @Wallet_Help_bot, which will be able to answer some questions related to using VouWallet.
3. Company will review the submitted reports and report on the results of the investigation within 15 (fifteen) working days from the date of User's initial request. If the initial request was made by phone, the day of registration of the complaint will be considered the day Company submits a description of the problem in writing. Depending on the complexity of the investigation, Company may take up to 3 (three) additional months for a more complete review of the appeal before coming to a reasonable conclusion. Company will try to correct any error caused by its actions as soon as possible in order to allow User to fully use the account.
After the investigation is completed, the results will be communicated to you in writing by registering the incident in the Company's system and sending it to you. The message will contain the results of the investigation and explanations of the established facts that led to the final results. If Company has previously recognized the transaction as erroneous and credited the corresponding amount to your account, but as a result of the investigation it was found that there was no error, Company has the right to retain the same amount from your account as if the transaction was never considered erroneous. Users who have reported an error can request copies of the materials used for the investigation.
4. Company will correct all errors that may be caused by incorrect operation of its system. Errors are usually detected during the reconciliation of calculations. In the event that a smaller amount was mistakenly credited to your account than the amount that is owed to you, Company will deposit the missing difference to your account. Conversely, if an amount exceeding the required amount has been credited to your account, Company will debit the difference from your account. Company will be responsible for reparation of funds for any transaction that was carried out for an incorrect amount or untimely, as well as for any losses and damages directly related to this transaction, except in cases where:
- There were insufficient funds in your account to complete the transaction for a reason independent of Company's actions
- You attempted to execute an operation during a period when Users were aware that Company's system was functioning incorrectly due to maintenance or technical problems;
- Due to circumstances beyond the control of the Company (such as natural disasters or technical problems, for example, with an Internet connection), the operation could not be carried out properly, despite the best efforts of the Company
5. Company will not be responsible for any incomplete/failed operations if User does not report such incomplete/failed operations to Company within 360 calendar days from the date when he/she became aware of the incomplete/failed operation.
12. Disputes and dispute resolution
1. Company understands that disputes may arise between Company and User in connection with the services provided. Company's goal is to resolve disputes in an effective manner, as a result of which Users will be satisfied with their cooperation with Company as a whole. Company also understands that some disputes are difficult to resolve without the participation of an independent party, and in certain cases – without using a special dispute resolution mechanism.
2. If you have any claims related to your account, contact Customer Support and report the problem. Customer support service reviews claims upon your request. You can also file a complaint to Customer Support by e-mail. Detailed information about the procedure for reviewing applications is published on Company's website.
3. In any way you contact Customer Support, you will need to state the essence of the problem in writing.
4. If you have received a response from Customer Support Service, but you believe that the complaint requires additional consideration, you can ask Customer Support Service to forward your complaint to a regulatory compliance department.
5. Company complies with the directives of local regulatory bodies regarding business activities.
6. Following these complaint procedures will not affect your legal rights.
7. Governing law and jurisdiction. This Agreement and the relationship between Company and Users are governed by the laws of Dubai, UAE.
8. Any inaction of Company in connection with User's violation of the terms of this Agreement should not be interpreted as a waiver of Company's right to take action in case of similar or subsequent violations.
9. If it is considered that Company has violated the Agreement, which has led to losses or direct damage to User, its liability will have the following limits:
- Company, its associates, branches and other affiliated structures acting on its behalf, as well as persons with whom Company has concluded contracts, will in no case be liable for any of the following types of losses or damages in connection with this Agreement or otherwise:
- Any loss or damage, directly unrelated to Company's violation of this Agreement; or
- Any lost profits, profits, business activities, intangible assets, contracts or savings, even if Company has been informed of such a possibility; or
- Any loss or distortion of data; or
- Any loss or damage directly related to Company's violation of this Agreement.
- Сompany provides Services to User in strict accordance with this Agreement, without any additional guarantees. Company does not guarantee uninterrupted or secure access to any Services, nor is it responsible for any delay or inability to provide services under this Agreement. Company may carry out maintenance and/or repair of its systems, while User's access to the account may be limited. Company assumes that such scheduled or unscheduled maintenance may continue for a certain period of time, while access to Company's system (including its website) will be limited.
- Company cannot guarantee that the parties entering into a transaction through the Company's services will comply with its terms. Company also does not exercise any control over products and services that are paid for through the Company's services.
- Company will make every possible effort to ensure the accuracy of the information it provides to Users. However, Company cannot guarantee the accuracy of such information, and we warn and urge Users not to rely solely on such information in the decision-making process. User is responsible for knowing and complying with any laws, rules and regulations of his/her specific jurisdiction that may apply to him/her in connection with the use of Service.
- Users agree to protect and release from liability Company, its employees, branches, associates and any persons authorized to act on its behalf for any claims or demands (including legal costs) that may be brought by or against any third party as a result of violation of this Agreement by Users, their employees branches, associates or agents, as well as violations by them of any applicable law and/or rules of use of Services.
- This Agreement (including any Application) as a whole forms the basis of the relationship between Company and its Users. If any provision of this agreement is found to be invalid or unenforceable, it shall be deemed inapplicable to the extent necessary to eliminate such invalidity or unenforceability, and all other provisions of this agreement will remain in full force and effect.
13. Software Rights and Licenses
1. Company and, where applicable, its Licensors grant you a limited, non-exclusive license to use any software applications that you access or download to your personal computer, mobile device or platform, including Application Programming Interface (API) or Developer tools, as appropriate. In accordance with this Agreement, this software is intended for your personal use only. Transfer of your rights to use or lease this software is strictly prohibited. Any such action serves as the basis for termination of this Agreement, and may also cause further lawsuits by Company. In addition, you agree not to modify, reproduce, adapt, distribute, display, publish, decompile, broadcast, or otherwise attempt to recreate any source code derived from software product. You hereby confirm that all rights to this software belong exclusively to Company or a third-party provider, depending on the contractual relationship between Company and third-party provider.
14. Our website and mobile application
1. General information. The content of our website and mobile application is provided solely for informational purposes. Any information should not be considered as advice or a guide to action. You need to consult with a professional consultant before executeing certain actions or refusing to execute such actions based on the information contained on the website or in the mobile application. Although we take appropriate and reasonable measures to keep the information on the site or in the mobile application up to date, we do not provide any representations or warranties (either express or implied) that any information on the site or in the mobile application is complete and up-to-date.
2. Changes on the website and in the mobile application.
- We have the right to update or modify our website and mobile application from time to time when products, business priorities and customer needs change.
- We will strive to send you timely notifications of upcoming major changes, reserving the right to suspend the operation of the website or mobile application.
- Our website and mobile application are provided free of charge.
- We do not guarantee that our website, mobile application or any content will be available at any time and will work smoothly. We have the right to suspend, terminate or restrict the operation of our website (in whole or in part) for operational reasons or due to business necessity. We will strive to inform you in a timely manner about possible suspensions in the operation of the site.
- You are obliged to ensure that all persons who access our website or mobile application using your Internet connection are familiar with and accept the terms of this User Agreement.
3. We are not responsible for the content of websites linked to which may be present on our site.
If our site contains links to third-party websites and information resources, then such links are for informational purposes only. Psresence of such links should not be interpreted by you as our confirmation of the accuracy of the information posted on these links. We are not responsible for and do not control the content of third-party websites and information resources.
15. Reparation
1. User guarantees reparation at the request of Company, of any costs incurred in issuing electronic money or ancillary services, including, without limitation, (i) violation of this Agreement by User; or (ii) false or misleading information provided by User to Company.
16. General provisions
Non-waiver: the inability or delay of either party in using the rights or remedies established by this Agreement or the law does not constitute a waiver of this (or any other) right or legal remedy and does not prevent its further use. No one-time or partial use of such right or legal remedy shall prevent or restrict the further use of this (or any other) right or legal remedy and shall not be interpreted as a waiver of a right or claim in connection with any subsequent violation or non-performance of the same or any other provisions of this Agreement.
Completeness of the Agreement: This agreement, its annexes and all its constituent documents and documents referred to in this agreement constitute the entire agreement between the parties with respect to its subject matter, replace and cancel all previous agreements, agreements and discussions between them, both oral and written, with respect to this subject matter.
Divisibility: All provisions of this agreement are independent and divisible. If any provision of the Agreement (or part of any provision) is found by a court or other authority of competent jurisdiction to be invalid, unenforceable or illegal, this does not detract from the validity of this agreement and does not affect the other provisions that remain in force.
A person who is not a party to the Agreement has no right to demand fulfillment of the terms of the Agreement.
Regulatory legislation: Agreement and all matters arising in connection with it, as well as any dispute arising between parties in connection with the Agreement, shall be governed by and interpreted in accordance with the laws of Dubai, UAE. Competent courts of Dubai, UAE, have exclusive jurisdiction over legal proceedings arising out of or related to this Agreement, and the parties to this Agreement unconditionally submit to such exclusive jurisdiction. However, this does not deprive the Company of the opportunity to initiate any claim in a court of any other jurisdiction for judicial or similar protection.
Language: When we provide you with a translation of the English version of the agreement, privacy policy or any other document, you agree that the translation is provided only for your convenience and does not change the English version, and you agree that the English version regulates our relationship. Both parties agree to conduct all correspondence related to this Agreement in English. If we send or receive correspondence in another language, this is done only for your convenience and does not constitute a departure from the above or a precedent for further correspondence.
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
Procedure for Handling Complaints
Introduction
TECTRIX SERVICE DMCC (“VouWallet”, “Company”, “we”, “our”) operates under the VouWallet brand. VouWallet operates the licensed technical platform to provide Services to Clients.
Interpretation of Terms
Unless indicated otherwise, the terms included in this Complaints Handling Procedure shall have a specific meaning and may be used in the singular or plural as appropriate. VouWallet Client (or “Client”) shall have the same meaning as the “Client” referred to in the Company’s User (Client) Agreements, as amended from time to time.
Scope of the Complaints Handling Procedure
The Complaints Handling Procedure (the “Procedure”) sets out the processes followed by the Company when dealing with complaints received by Clients.
VouWallet aims at responding to the requirements of its Clients, with integrity and a high level of service. If you wish, you may contact us to submit any complaints/suggestions that you may have.
Defining Complaints
A complainant is defined as any person, natural or legal, which is eligible for lodging a complaint to the Company and who has already lodged a complaint.
A complaint is defined as any oral or written (whether received by letter, fax, e-mail, or other electronic means), expression of dissatisfaction, whether justified or not, from, or on behalf of, a client or potential client about the provision of, or failure to provide, a service which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience.
Non-trivial complaints include complaints that involve allegations of a breach of law or regulation, negligence, serious breach of an obligation, a conflict of interest or a leak of confidential or price sensitive information.
A complaint shall include:
VouWallet may, at its discretion, refuse to handle a complaint if requirements contained in this section are not fulfilled.
The Procedure
All complaints must be in writing and shall be addressed, in the first instance, to the Customer Support Department. If the Client receives a response from the Customer Support Department but deems that the complaint needs to be raised further, the Client may ask the Customer Support Department to escalate it to the Compliance Department or directly contact the Compliance Department.
Both the Customer Support Department and the Compliance Department shall thoroughly examine any complaints as required (taking into account any information contained within the books and records of the Institution, including but not limited to the Client’s e-wallet journal) and reach a fair outcome.
Both the Customer Support Department and the Compliance Department shall: o Send an initial response to the Client within fifteen (15) working days of receipt of a complaint; If it is considered that more time is required for the examination of your complaint, the Customer Support Department will acknowledge receipt of your complaint within the time limit set above and will reply to it within one month from the date of receipt thereof
Further Information
Questions regarding this Procedure should be addressed, in the first instance, to the Customer Service Department.
Contacts
Customer Support Department
TECTRIX SERVICE DMCC (“VouWallet”, “Company”, “we”, “our”) operates under the VouWallet brand. VouWallet operates the licensed technical platform to provide Services to Clients.
Interpretation of Terms
Unless indicated otherwise, the terms included in this Complaints Handling Procedure shall have a specific meaning and may be used in the singular or plural as appropriate. VouWallet Client (or “Client”) shall have the same meaning as the “Client” referred to in the Company’s User (Client) Agreements, as amended from time to time.
Scope of the Complaints Handling Procedure
The Complaints Handling Procedure (the “Procedure”) sets out the processes followed by the Company when dealing with complaints received by Clients.
VouWallet aims at responding to the requirements of its Clients, with integrity and a high level of service. If you wish, you may contact us to submit any complaints/suggestions that you may have.
Defining Complaints
A complainant is defined as any person, natural or legal, which is eligible for lodging a complaint to the Company and who has already lodged a complaint.
A complaint is defined as any oral or written (whether received by letter, fax, e-mail, or other electronic means), expression of dissatisfaction, whether justified or not, from, or on behalf of, a client or potential client about the provision of, or failure to provide, a service which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience.
Non-trivial complaints include complaints that involve allegations of a breach of law or regulation, negligence, serious breach of an obligation, a conflict of interest or a leak of confidential or price sensitive information.
A complaint shall include:
- The Client’s name and surname
- The Client’s e-wallet account number
- The affected transaction numbers (if applicable)
- The date and time that the issue arose
- A description of the issue
VouWallet may, at its discretion, refuse to handle a complaint if requirements contained in this section are not fulfilled.
The Procedure
All complaints must be in writing and shall be addressed, in the first instance, to the Customer Support Department. If the Client receives a response from the Customer Support Department but deems that the complaint needs to be raised further, the Client may ask the Customer Support Department to escalate it to the Compliance Department or directly contact the Compliance Department.
Both the Customer Support Department and the Compliance Department shall thoroughly examine any complaints as required (taking into account any information contained within the books and records of the Institution, including but not limited to the Client’s e-wallet journal) and reach a fair outcome.
Both the Customer Support Department and the Compliance Department shall: o Send an initial response to the Client within fifteen (15) working days of receipt of a complaint; If it is considered that more time is required for the examination of your complaint, the Customer Support Department will acknowledge receipt of your complaint within the time limit set above and will reply to it within one month from the date of receipt thereof
- Resolve complaints as soon as reasonably practicable
- Inform the client accordingly.
Further Information
Questions regarding this Procedure should be addressed, in the first instance, to the Customer Service Department.
Contacts
Customer Support Department
- E-mail: support@vouwallet.io
- E-mail: support@vouwallet.io
Privacy Policy
1. Introduction
TECTRIX SERVICE DMCC operates under the VouWallet brand. This Agreement is concluded between TECTRIX SERVICE DMCC ("VouWallet", "Company", "we", "our") and you ("User", "You", "Your").
In order to reduce the risk of fraud, the data controller of VouWallet, must ask you to provide us with information about yourself, including your mobile phone number and/or bank account details. By consenting to, and agreeing the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. VouWallet takes the processing of your information very seriously and will use your information only in accordance with the terms of this Privacy Policy. For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to users of VouWallet, including but not limited to customers and merchants (legal entities) (collectively referred to as “Clients”). This statement applies to all personal data in our possession ("Your Data").
We are committed to respecting your privacy and to complying with all the provisions of the General Data Protection Regulation (GDPR) and all other applicable data protection and privacy laws and regulations. The purpose of this Privacy Policy is to set out how we obtain and use your personal information when you visit VouWallet Website (the “Website”) and when you generally use our product and related services. This Privacy Policy does not apply to websites operated by other organisations and other third parties, therefore we advise you to check the privacy policies of any such websites before providing any data to them.
Privacy Policy forms part of our Terms & Conditions and sets out the basis on which we collect and process Your Data in the course of providing this service. By using such services, you agree that we may process Your Data as set out in those Terms & Conditions.
This Privacy Policy will be reviewed as necessary, at our sole discretion, to keep pace with any applicable laws and regulation. When reissued, changes will be highlighted so that you are aware of the amendments. We may change this Privacy Policy at any time by posting a revised version of it on the Website and will be deemed as received by all Clients. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days' prior notice of the effective date of the revised privacy policy. We will inform you about changes to this Privacy Policy by posting a notice on our website(s) and/or send the notice by e-mail. As of the effective date of the revised privacy policy, you will be considered as having consented to all changes to the Privacy Policy therefore we recommend that you check this page regularly to keep up-to-date. Do not register for any of VouWallet services if you are in disagreement with this Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time by giving us respective notice.
Note:Children are not eligible to use VouWallet services and we ask that minors (persons under the age of 18) do not submit any personal information to us or use the VouWallet services.
2. Information VouWallet Collects from Clients
In order to open an account with VouWallet, you must first complete and submit an online application form by completing the required information. By completing the relevant application form, you are requested to disclose personal information in order to enable us to evaluate your application and comply with relevant rules and regulations. When an application is submitted, we are required by law to verify the client’s identity as well as the rest of the information provided and conduct appropriate research against any possible fraud/money laundering/crime issues and risks.
As part of the registration with VouWallet services, users must provide their name, Country of residence, residential address, date and place of birth, mobile phone number, e-mail address and nationality. We also ask you to choose a security question to answer and provide a password to your account.
We will also require other commercial and/or identification information (for example, a valid passport) if you send or receive certain high-value transactions or high overall payment volumes through the VouWallet services or as is otherwise required in order for us to comply with our anti-money laundering obligations under the legislation framework.
1. Additional Information We Collect from Clients
When you use the VouWallet services to send money to someone else or request money from someone else, we ask you to provide information related to that transaction. This information includes the amount and type of the transaction (purchase of goods, purchase of services, or simple money transfer), other purchase details and the e-mail address, or mobile phone number of the third party. Also, when you send money to another VouWallet customer, you may be asked to provide identification details to that customer to complete the transaction. Those details may also be passed on to us from that customer.
We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your VouWallet account or use VouWallet services, in order to help detect possible instances of unauthorised transactions.
If you send or receive high overall payment volumes (over €1.000 or at a lower amount if the Company is not satisfied with your identification information) through the VouWallet, or if as a merchant have limited selling history, in some circumstances we will conduct a background check on your business by obtaining information about you and your business, and potentially (if legally permitted) also about your directors, shareholders and partners. If you owe us money, we may conduct a check by obtaining additional information about you to the extent permitted by applicable laws. VouWallet, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer report for any account, and reserves the right to close an account based on information obtained during this review process.
Finally, we also collect information for system administration about the client’s computer or device, including where it is available, IP Address, operating system and browser type. This is statistical data about the users’ browsing behaviour (actions and patterns) while visiting the Website and does not identify any individual.
VouWallet исключительно по своему усмотрению, оставляет за собой право периодически запрашивать и проверять сведения о коммерческой деятельности, а также оставляет за собой право закрывать счета на основании информации, полученной в ходе проверки клиента.
Кроме того, мы также осуществляем сбор информации для системного администрирования компьютеров и устройств клиента, включая, при наличии, IP-адреса, типы операционных систем и браузеров. Эта информация представляет собой статистические данные о поиске и просмотре информации клиентом (действия и набор данных) при посещении Вэб-сайта и не идентифицирует физическое лицо.
2. How Information is Collected
We will always ensure that Your Data is obtained lawfully, fairly and in a transparent manner. We will do this by providing you with the necessary information in a clear manner so that you can determine the purposes for which your information will be used at any given time. We will collect Your Data through a number of different channels including, but not limited to, where you directly provide personal details when you:
3. Alternative Methods of Collecting Information
Moreover, information about you may also be collected by any correspondence made with us by phone, e-mail or otherwise; including information which you enter when you register to use our Website, subscribe to our service or any other activities carried out on our Website or any connected applications.
We may also collect Your Data from other sources including, but not limited to:
4. Additional Verification
If we cannot verify the information that you provide, or if you request a withdrawal to a bank account or an address other than your verified ones, we may ask you to upload or send us additional information by post or e-mail or fax (such as your recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. In such assessment process, we may use a variety of information sources that do not violate the provisions of the GDPR or any other applicable personal information privacy rules. Furthermore, Client provided information may be verified with third party providers such as but not limited to payment processors as a measure to enhance the Clients’ protection.
3. Confidentiality and Clients’ Personal Data Protection
Clients accept and consent that VouWallet may contractually engage companies for client verification, statistical and/or other purposes in order to improve VouWallet’s business activities; as a result, some or all of the Clients’ collected data may be transferred to international companies (cross-boarder transfer of personal data) and disclosed. The data that will be used for such purposes would not be in an identifiable form.
1. Storage of Clients’ Personal Data
All information provided by Clients to VouWallet is stored on our secure servers which are located within the European Economic Area (the “EEA”) and other countries according to the applicable legislation. The personal data of Clients from Russia is stored on the secure servers which are located on the territory of the Russian Federation. The EEA consists of all EU members states, plus Norway, Iceland and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards provided by the Law.
As the transmission of information via the internet is not completely secured, we cannot guarantee the security of the data the Clients transmit to the Website and therefore any transmission is at the client’s own risk. Once the client’s information is received, VouWallet will use strict procedures and security features to try to prevent any unauthorized access.
4. How We Use the Information We Collect
We will use Your Data only for the purpose for which it was originally provided and where we intend to use it for any other purpose, we will explicitly notify you and where appropriate to seek your prior consent. Your Data will be used by us for a safe, effective, efficient, and customised experience, as well as routine account maintenance. Your Personal Data will be used for one or all or any of the following ways (not exhaustive list):
Your Personal Data will be used for one or all or any of the following ways (not exhaustive list):
5. How Long we will Keep your Personal Data
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We are however required to keep your personal data for a minimum period of five (5) years after the closing of your account in order for us to comply with our anti-money laundering obligations under the legislation framework.
6. Sharing of your Personal Data
We may share Your Data with any affiliated company, which means any subsidiaries, ultimate holding companies and its respective subsidiaries may receive such information. Where we share your data with our affiliated companies, we ensure that all personal data is protected by requiring all of our affiliates to follow the same rules with respect to personal data usage. We may also share your information with certain third parties including business partners, suppliers and subcontractors.
If you wish to receive more information about these third parties, you can contact our Data Protection Officer at support@vouwallet.io. We use specific contracts with external third parties that are approved by the European Commission (with the use of the ‘’Standard Contractual Clauses’’ as approved by the European Commission) for the transfer of personal data to third countries that are not part of the EEA.
These contracts ensure the same levels of personal data protection that would apply under the GDPR. In the event that VouWallet discloses information to business parties, for instance, card processing companies or banks, in order to effect the services requested by the Clients, such third parties may store your information in order to comply with their legal and other obligations.
1. Sharing Information with Other VouWallet Users
If you are a registered VouWallet user, your name, e-mail address, phone number (if applicable) date of sign-up, or other data are made available to other VouWallet users whom you have paid or senders who are attempting to pay you using the VouWallet services. If you are a merchant, we will also display to other VouWallet users the website address (URL) and customer service contact information that you provide us. In addition, this and other information may also be shared with third parties when you use these third parties to access the VouWallet services. However, any of your financial information (such as your bank account) will not be revealed to anyone whom you have paid or who has paid you through the VouWallet or third parties that use the VouWallet services, except with your express permission or if we are required to do so pursuant to a court order, International Payment Systems and Acquiring rules or other legal process.
If you are buying goods or services and pay through your VouWallet account, we may provide the seller with the delivery address for the goods and your billing address to complete your transaction. If an attempt to pay your seller fails, or is later invalidated, we may also provide your seller with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
If you use VouWallet as means of logging into external websites, we may share your login status with any third party offering this Service as a login method, as well as the personal and other Account Information that you consent to being shared so that the third party can recognize you. VouWallet will not give such third party access to your account and will only make payments from your account to that third party with your specific authorisation. You can access, view and control the settings for any such data sharing with merchants when logged into your VouWallet account.
We work with third parties including merchants to enable them to accept or facilitate payments from or to you using the VouWallet services. In doing so, a third party may share information about you with us such as your e-mail address or mobile phone number, when a payment is sent to you or when you are attempting to pay that third party. We use this information to confirm that you are a registered client and that VouWallet can be enabled to make a payment, or where a payment is sent to you to send you a notification that you have received a payment. Also, if you request that we validate your status as a VouWallet user with a third party, we will do so. Please note that third parties you buy from and contract with may have their own privacy policies, and VouWallet is not responsible for their operations, including but not limited to their information practices.
By accepting this Privacy Policy, you expressly agree and consent that each time you pay or attempt to pay another VouWallet user (including a merchant) using your VouWallet account, we may transfer the aforementioned relevant data to such VouWallet user, who may be located outside the European Economic Area (EEA), in order to process, execute or otherwise deal with and provide information about the payment.
2. Sharing Personal Data with Other Third Parties
We will not sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Privacy Policy. This includes transfers of data to non-EEA member states. Under such circumstances, VouWallet shall expressly inform the third party regarding the confidential nature of the information.
Specifically, VouWallet may disclose Your Data to third parties under the following circumstances:
7. Your Rights Under The GDPR
Under the GDPR, you have the following rights, which we will always work to uphold:
8. How to Access Your Data
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where such personal data is held) This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the following email address support@vouwallet.io. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example if you make repetitive requests) a fee may be charged to cover for administrative costs in responding.
We will respond to your subject access request within 15 days and in any case not more than one month from receiving it. Normally, we aim to provide complete response, including copy of your personal data within that time. In some case however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our process.
9. Cookies
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. The Website uses cookies to distinguish a client from other users of the Website. This helps to provide the client with a good service when browsing the Website. It further allows VouWallet to improve the quality of the service offered.
VouWallet uses both session ID cookies and persistent cookies. A session ID cookie does not expire when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You have the ability to accept or decline cookies. All cookies used by VouWallet on the Pro-Fee site are used in accordance with current cookie Law. Certain features on our website depend on cookies to function. Cookie Law deems these cookies to be strictly necessary. Before cookies are placed on your computer or device you will be shown a message requesting you to consent to set those Cookies. If you decline cookies, some aspects of the Website may not work on your PC and/or device and you may not be able to access areas you want on the Website. Thus, we recommend that you accept cookies. We will not store any sensitive information relating to you or your user account in a cookie.
Some of our business partners use cookies on the Website; VouWallet has no access or control over these cookies.
10. Information Security
The Company is committed to handling your information with high standards of information security. We use computer safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their day-to-day operations.
The security of your VouWallet account also relies on your protection of your VouWallet password. You should not share your VouWallet password with anyone. Our representatives will never ask you for your password, so any e-mail or other communication requesting your password should be treated as unauthorised and suspicious and forwarded to our support team on: support@vouwallet.io.
In the event that you share your VouWallet password with a third party for any reason, the third party will have access to your account and your personal information, you are responsible for any actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact our support team immediately at support@vouwallet.io.
11. Legal Disclaimer
VouWallet reserves the right to disclose your personally identifiable information as required by rules and regulations and when we believe that disclosure is necessary to protect our rights and/or to comply with any judicial and/or other proceedings, court order, legal process served or pursuant to governmental, intergovernmental and/or other regulatory bodies. VouWallet shall not be liable for misuse or loss of personal information and/or otherwise on the company’s website(s) that VouWallet does not have access to or control over. VouWallet will not be liable for unlawful or unauthorized use of your personal information due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise.
The Website may contain links to and from the websites of our partner networks/advertisers/etc. If the client follows a link to any of these websites, we do not accept any responsibility or liability for the privacy policies of these websites.
All communication between the Client and the Company will be recorded and retained for reference purposes when and if required by the Company or the regulatory authority that supervises the operations. In cases where personal information may be collected with the use of optional collection methods such as survey questionnaires and special offers for the creation of a demographic profile and/or assessment of Client specific interests, the Company will inform you how the information may be used before the Client decides to participate.
The information provided to us will be kept by the Company for a period of five years after a Client decides to close the account, for regulatory purposes. We will not use this information after closure of the Client’s account in any way related to its services, but will only use it as necessary to assist with any law enforcement investigation, to honor any court sanctioned warrant, and for the prevention of any fraudulent action.
12. Client’s Rights in Relation to Processing Personal Data for Marketing Purposes
The client has the right to ask VouWallet not to process their personal data for marketing purposes. VouWallet will inform the customer before collecting their data if we intend to use Your Data for such purposes or if we intend to disclose the customer’s information to any third party for such purposes. The customer can also exercise the right, at any time, to prevent such processing by contacting us via e-mail.
13. Contact
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to VouWallet’s support team via e-mail on: support@vouwallet.io.
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
TECTRIX SERVICE DMCC operates under the VouWallet brand. This Agreement is concluded between TECTRIX SERVICE DMCC ("VouWallet", "Company", "we", "our") and you ("User", "You", "Your").
In order to reduce the risk of fraud, the data controller of VouWallet, must ask you to provide us with information about yourself, including your mobile phone number and/or bank account details. By consenting to, and agreeing the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. VouWallet takes the processing of your information very seriously and will use your information only in accordance with the terms of this Privacy Policy. For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to users of VouWallet, including but not limited to customers and merchants (legal entities) (collectively referred to as “Clients”). This statement applies to all personal data in our possession ("Your Data").
We are committed to respecting your privacy and to complying with all the provisions of the General Data Protection Regulation (GDPR) and all other applicable data protection and privacy laws and regulations. The purpose of this Privacy Policy is to set out how we obtain and use your personal information when you visit VouWallet Website (the “Website”) and when you generally use our product and related services. This Privacy Policy does not apply to websites operated by other organisations and other third parties, therefore we advise you to check the privacy policies of any such websites before providing any data to them.
Privacy Policy forms part of our Terms & Conditions and sets out the basis on which we collect and process Your Data in the course of providing this service. By using such services, you agree that we may process Your Data as set out in those Terms & Conditions.
This Privacy Policy will be reviewed as necessary, at our sole discretion, to keep pace with any applicable laws and regulation. When reissued, changes will be highlighted so that you are aware of the amendments. We may change this Privacy Policy at any time by posting a revised version of it on the Website and will be deemed as received by all Clients. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days' prior notice of the effective date of the revised privacy policy. We will inform you about changes to this Privacy Policy by posting a notice on our website(s) and/or send the notice by e-mail. As of the effective date of the revised privacy policy, you will be considered as having consented to all changes to the Privacy Policy therefore we recommend that you check this page regularly to keep up-to-date. Do not register for any of VouWallet services if you are in disagreement with this Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time by giving us respective notice.
Note:Children are not eligible to use VouWallet services and we ask that minors (persons under the age of 18) do not submit any personal information to us or use the VouWallet services.
2. Information VouWallet Collects from Clients
In order to open an account with VouWallet, you must first complete and submit an online application form by completing the required information. By completing the relevant application form, you are requested to disclose personal information in order to enable us to evaluate your application and comply with relevant rules and regulations. When an application is submitted, we are required by law to verify the client’s identity as well as the rest of the information provided and conduct appropriate research against any possible fraud/money laundering/crime issues and risks.
As part of the registration with VouWallet services, users must provide their name, Country of residence, residential address, date and place of birth, mobile phone number, e-mail address and nationality. We also ask you to choose a security question to answer and provide a password to your account.
We will also require other commercial and/or identification information (for example, a valid passport) if you send or receive certain high-value transactions or high overall payment volumes through the VouWallet services or as is otherwise required in order for us to comply with our anti-money laundering obligations under the legislation framework.
1. Additional Information We Collect from Clients
When you use the VouWallet services to send money to someone else or request money from someone else, we ask you to provide information related to that transaction. This information includes the amount and type of the transaction (purchase of goods, purchase of services, or simple money transfer), other purchase details and the e-mail address, or mobile phone number of the third party. Also, when you send money to another VouWallet customer, you may be asked to provide identification details to that customer to complete the transaction. Those details may also be passed on to us from that customer.
We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your VouWallet account or use VouWallet services, in order to help detect possible instances of unauthorised transactions.
If you send or receive high overall payment volumes (over €1.000 or at a lower amount if the Company is not satisfied with your identification information) through the VouWallet, or if as a merchant have limited selling history, in some circumstances we will conduct a background check on your business by obtaining information about you and your business, and potentially (if legally permitted) also about your directors, shareholders and partners. If you owe us money, we may conduct a check by obtaining additional information about you to the extent permitted by applicable laws. VouWallet, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer report for any account, and reserves the right to close an account based on information obtained during this review process.
Finally, we also collect information for system administration about the client’s computer or device, including where it is available, IP Address, operating system and browser type. This is statistical data about the users’ browsing behaviour (actions and patterns) while visiting the Website and does not identify any individual.
VouWallet исключительно по своему усмотрению, оставляет за собой право периодически запрашивать и проверять сведения о коммерческой деятельности, а также оставляет за собой право закрывать счета на основании информации, полученной в ходе проверки клиента.
Кроме того, мы также осуществляем сбор информации для системного администрирования компьютеров и устройств клиента, включая, при наличии, IP-адреса, типы операционных систем и браузеров. Эта информация представляет собой статистические данные о поиске и просмотре информации клиентом (действия и набор данных) при посещении Вэб-сайта и не идентифицирует физическое лицо.
2. How Information is Collected
We will always ensure that Your Data is obtained lawfully, fairly and in a transparent manner. We will do this by providing you with the necessary information in a clear manner so that you can determine the purposes for which your information will be used at any given time. We will collect Your Data through a number of different channels including, but not limited to, where you directly provide personal details when you:
- Purchase products or services (irrespective of the means used for the purchase)
- Register your details to become a client (user of VouWalletservices)
- Submit enquiries to us or contact us in general
- Participate in any promotions, competitions or prize draws
- Use any of our products or services
- Take part in any form of a market research
- Close your account maintained with us
- Visit or browse the Website, related micro-sites or other websites of affiliated companies
3. Alternative Methods of Collecting Information
Moreover, information about you may also be collected by any correspondence made with us by phone, e-mail or otherwise; including information which you enter when you register to use our Website, subscribe to our service or any other activities carried out on our Website or any connected applications.
We may also collect Your Data from other sources including, but not limited to:
- VouWallet’s affiliated companies, other companies (subject to their privacy policy and applicable legislation) and from other accounts we have reason to believe you control (whether partially or fully)
- Business directories and other commercially or publicly available sources
- Other financial or payment institutions
4. Additional Verification
If we cannot verify the information that you provide, or if you request a withdrawal to a bank account or an address other than your verified ones, we may ask you to upload or send us additional information by post or e-mail or fax (such as your recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. In such assessment process, we may use a variety of information sources that do not violate the provisions of the GDPR or any other applicable personal information privacy rules. Furthermore, Client provided information may be verified with third party providers such as but not limited to payment processors as a measure to enhance the Clients’ protection.
3. Confidentiality and Clients’ Personal Data Protection
Clients accept and consent that VouWallet may contractually engage companies for client verification, statistical and/or other purposes in order to improve VouWallet’s business activities; as a result, some or all of the Clients’ collected data may be transferred to international companies (cross-boarder transfer of personal data) and disclosed. The data that will be used for such purposes would not be in an identifiable form.
1. Storage of Clients’ Personal Data
All information provided by Clients to VouWallet is stored on our secure servers which are located within the European Economic Area (the “EEA”) and other countries according to the applicable legislation. The personal data of Clients from Russia is stored on the secure servers which are located on the territory of the Russian Federation. The EEA consists of all EU members states, plus Norway, Iceland and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards provided by the Law.
As the transmission of information via the internet is not completely secured, we cannot guarantee the security of the data the Clients transmit to the Website and therefore any transmission is at the client’s own risk. Once the client’s information is received, VouWallet will use strict procedures and security features to try to prevent any unauthorized access.
4. How We Use the Information We Collect
We will use Your Data only for the purpose for which it was originally provided and where we intend to use it for any other purpose, we will explicitly notify you and where appropriate to seek your prior consent. Your Data will be used by us for a safe, effective, efficient, and customised experience, as well as routine account maintenance. Your Personal Data will be used for one or all or any of the following ways (not exhaustive list):
Your Personal Data will be used for one or all or any of the following ways (not exhaustive list):
- Process transactions and provide the VouWallet service
- Carry out any other obligation arising from any contracts entered into between the client and VouWallet
- Verify that you are an authorised user for security purposes
- Identification procedures
- Combat money laundering and terrorist financing
- Assist us with crime and fraud prevention
- Provide you with customer support services
- Improve our services by customising your user experience
- Manage and protect our information technology infrastructure
- Resolve disputes, collect fees, and troubleshoot problems
- Analyse markets and produce reports, perform research and statistical analysis and to monitor user behaviour to improve our technologies and services
- Inform you of any products and services offered by other companies that we think may be of interest to you (given that you have consented to be contacted for such purposes)
- Notify the client about changes to VouWallet’s service and/or changes made to this Privacy Policy
5. How Long we will Keep your Personal Data
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We are however required to keep your personal data for a minimum period of five (5) years after the closing of your account in order for us to comply with our anti-money laundering obligations under the legislation framework.
6. Sharing of your Personal Data
We may share Your Data with any affiliated company, which means any subsidiaries, ultimate holding companies and its respective subsidiaries may receive such information. Where we share your data with our affiliated companies, we ensure that all personal data is protected by requiring all of our affiliates to follow the same rules with respect to personal data usage. We may also share your information with certain third parties including business partners, suppliers and subcontractors.
If you wish to receive more information about these third parties, you can contact our Data Protection Officer at support@vouwallet.io. We use specific contracts with external third parties that are approved by the European Commission (with the use of the ‘’Standard Contractual Clauses’’ as approved by the European Commission) for the transfer of personal data to third countries that are not part of the EEA.
These contracts ensure the same levels of personal data protection that would apply under the GDPR. In the event that VouWallet discloses information to business parties, for instance, card processing companies or banks, in order to effect the services requested by the Clients, such third parties may store your information in order to comply with their legal and other obligations.
1. Sharing Information with Other VouWallet Users
If you are a registered VouWallet user, your name, e-mail address, phone number (if applicable) date of sign-up, or other data are made available to other VouWallet users whom you have paid or senders who are attempting to pay you using the VouWallet services. If you are a merchant, we will also display to other VouWallet users the website address (URL) and customer service contact information that you provide us. In addition, this and other information may also be shared with third parties when you use these third parties to access the VouWallet services. However, any of your financial information (such as your bank account) will not be revealed to anyone whom you have paid or who has paid you through the VouWallet or third parties that use the VouWallet services, except with your express permission or if we are required to do so pursuant to a court order, International Payment Systems and Acquiring rules or other legal process.
If you are buying goods or services and pay through your VouWallet account, we may provide the seller with the delivery address for the goods and your billing address to complete your transaction. If an attempt to pay your seller fails, or is later invalidated, we may also provide your seller with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
If you use VouWallet as means of logging into external websites, we may share your login status with any third party offering this Service as a login method, as well as the personal and other Account Information that you consent to being shared so that the third party can recognize you. VouWallet will not give such third party access to your account and will only make payments from your account to that third party with your specific authorisation. You can access, view and control the settings for any such data sharing with merchants when logged into your VouWallet account.
We work with third parties including merchants to enable them to accept or facilitate payments from or to you using the VouWallet services. In doing so, a third party may share information about you with us such as your e-mail address or mobile phone number, when a payment is sent to you or when you are attempting to pay that third party. We use this information to confirm that you are a registered client and that VouWallet can be enabled to make a payment, or where a payment is sent to you to send you a notification that you have received a payment. Also, if you request that we validate your status as a VouWallet user with a third party, we will do so. Please note that third parties you buy from and contract with may have their own privacy policies, and VouWallet is not responsible for their operations, including but not limited to their information practices.
By accepting this Privacy Policy, you expressly agree and consent that each time you pay or attempt to pay another VouWallet user (including a merchant) using your VouWallet account, we may transfer the aforementioned relevant data to such VouWallet user, who may be located outside the European Economic Area (EEA), in order to process, execute or otherwise deal with and provide information about the payment.
2. Sharing Personal Data with Other Third Parties
We will not sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Privacy Policy. This includes transfers of data to non-EEA member states. Under such circumstances, VouWallet shall expressly inform the third party regarding the confidential nature of the information.
Specifically, VouWallet may disclose Your Data to third parties under the following circumstances:
- If we are required to do so by a regulatory authority of a competent jurisdiction; the police and other law enforcement agencies; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organizations and other third parties, including companies affiliated to VouWallet, that we have reason to believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Terms & Conditions (including without limitation, your funding source or credit or debit card provider).
- We will attempt, to make such disclosures on a ‘need-to-know’ basis, unless otherwise instructed by a regulatory authority. We and other organisations, including parties that accept VouWallet, may also share, access and use (including from other countries) necessary information (including, without limitation the information recorded by fraud prevention agencies) to help us and them assess and to manage risk (including, without limitation, to prevent fraud, money laundering and terrorist financing).
- In response to requirements of the credit card associations or a civil or criminal legal process.
- If you as a merchant use a third party to access or integrate VouWallet, we may disclose to any such partner necessary information for the purpose of facilitating and maintaining such an arrangement (including, without limitation, the status of your VouWallet integration, whether you have an active VouWallet account and whether you may already be working with a different VouWallet integration partner).
- Disclose necessary information to the payment processors, auditors, customer services providers, credit reference and fraud agencies, financial products providers, commercial partners, marketing and public relations companies, operational services providers, group companies, agencies, marketplaces and other third parties listed here. The purpose of this disclosure is to allow us to provide VouWallet services to you.
- Disclose necessary information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- Disclose aggregated statistical data with our business partners or for public relations. For example, we may disclose the location of a specific percentage of our users, or the industry that is mostly used by our customers to conduct payments. However, this aggregated information is not tied to personal information and cannot lead to any user being identified.
- If VouWallet sells or buys any business or assets in which case, we may disclose Your Data to the prospective seller or buyer of such business or assets.
- If VouWallet or substantially all of S VouWallet’s assets are acquired by, or merged with, a third party in which case any personal data held about Clients will be considered as one of the transferred assets. If such an acquisition/merger occurs, we will inform you and accordingly obtain your consent to the successor company having access to Your Data maintained by us, including customer Account Information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.
7. Your Rights Under The GDPR
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more to ask any questions using the contact details provided for at the end of this privacy policy.
- The right to access your personal data we hold about you. Part 8 below will tell you how to do this.
- The right to have your personal data rectified of any of your personal data held by us is inaccurate or incomplete. To do this, please make use of the contact details provided for this purpose at the end of this privacy policy.
- The right to be forgotten, i.e. the right to ask as to delete or otherwise dispose of any of your personal data that we have. Again, you may use the contact details provided at the end of this privacy policy to learn more about this right and to ask for your personal data to be deleted. We are unable to proceed with erasure requests prior to the expiry of the five (5) year period following the closing of your account and/or the termination of our contract with you, as such action will affect our ability to comply with our anti-money laundering obligations under the legislation framework.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means if you have provided personal data to us directly, or we are using it with your consent or for the performance of your contract with us, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. How to Access Your Data
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where such personal data is held) This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the following email address support@vouwallet.io. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example if you make repetitive requests) a fee may be charged to cover for administrative costs in responding.
We will respond to your subject access request within 15 days and in any case not more than one month from receiving it. Normally, we aim to provide complete response, including copy of your personal data within that time. In some case however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our process.
9. Cookies
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. The Website uses cookies to distinguish a client from other users of the Website. This helps to provide the client with a good service when browsing the Website. It further allows VouWallet to improve the quality of the service offered.
VouWallet uses both session ID cookies and persistent cookies. A session ID cookie does not expire when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You have the ability to accept or decline cookies. All cookies used by VouWallet on the Pro-Fee site are used in accordance with current cookie Law. Certain features on our website depend on cookies to function. Cookie Law deems these cookies to be strictly necessary. Before cookies are placed on your computer or device you will be shown a message requesting you to consent to set those Cookies. If you decline cookies, some aspects of the Website may not work on your PC and/or device and you may not be able to access areas you want on the Website. Thus, we recommend that you accept cookies. We will not store any sensitive information relating to you or your user account in a cookie.
Some of our business partners use cookies on the Website; VouWallet has no access or control over these cookies.
10. Information Security
The Company is committed to handling your information with high standards of information security. We use computer safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their day-to-day operations.
The security of your VouWallet account also relies on your protection of your VouWallet password. You should not share your VouWallet password with anyone. Our representatives will never ask you for your password, so any e-mail or other communication requesting your password should be treated as unauthorised and suspicious and forwarded to our support team on: support@vouwallet.io.
In the event that you share your VouWallet password with a third party for any reason, the third party will have access to your account and your personal information, you are responsible for any actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact our support team immediately at support@vouwallet.io.
11. Legal Disclaimer
VouWallet reserves the right to disclose your personally identifiable information as required by rules and regulations and when we believe that disclosure is necessary to protect our rights and/or to comply with any judicial and/or other proceedings, court order, legal process served or pursuant to governmental, intergovernmental and/or other regulatory bodies. VouWallet shall not be liable for misuse or loss of personal information and/or otherwise on the company’s website(s) that VouWallet does not have access to or control over. VouWallet will not be liable for unlawful or unauthorized use of your personal information due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise.
The Website may contain links to and from the websites of our partner networks/advertisers/etc. If the client follows a link to any of these websites, we do not accept any responsibility or liability for the privacy policies of these websites.
All communication between the Client and the Company will be recorded and retained for reference purposes when and if required by the Company or the regulatory authority that supervises the operations. In cases where personal information may be collected with the use of optional collection methods such as survey questionnaires and special offers for the creation of a demographic profile and/or assessment of Client specific interests, the Company will inform you how the information may be used before the Client decides to participate.
The information provided to us will be kept by the Company for a period of five years after a Client decides to close the account, for regulatory purposes. We will not use this information after closure of the Client’s account in any way related to its services, but will only use it as necessary to assist with any law enforcement investigation, to honor any court sanctioned warrant, and for the prevention of any fraudulent action.
12. Client’s Rights in Relation to Processing Personal Data for Marketing Purposes
The client has the right to ask VouWallet not to process their personal data for marketing purposes. VouWallet will inform the customer before collecting their data if we intend to use Your Data for such purposes or if we intend to disclose the customer’s information to any third party for such purposes. The customer can also exercise the right, at any time, to prevent such processing by contacting us via e-mail.
13. Contact
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to VouWallet’s support team via e-mail on: support@vouwallet.io.
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
VouWallet Acceptable Use Policy
TECTRIX SERVICE DMCC operates under the VouWallet brand. This Agreement is concluded between TECTRIX SERVICE DMCC ("VouWallet", "Company", "we", "our") and you ("User", "Client", "You", "Your").
As a Client you hereby agree to act in a manner acceptable to the terms and conditions of the Agreement you enter with VouWallet. You hereby acknowledge and agree that it is your sole responsibility to comply with all applicable laws in using the VouWallet services irrespective of the reasons behind the use of these services. You further agree that you must adhere to this policy of Acceptable Use.
Permitted types of services when paying from the wallet balance
Prohibited Activities
VouWallet does not permit and you hereby agree, not to use the VouWallet services for activities that are in violation of any law, regulation, directive, act, and decree. VouWallet also prohibits the use of its services for transactions that relate to the following list of items described in the table below:
Prohibited Items/Services transaction list
VouWallet has the right as per the Terms and Conditions of the Agreement to prohibit any transaction that it deems potentially fraudulent, illegal or illicit.
Approval Requiring Activities
Certain services may not be prohibited but due to their higher risk nature will require VouWallet’s approval prior to VouWallet accepting any payment transactions that relate to such services. The list of such services can be found in the table below.
Violations Report and Enquiries
VouWallet encourages its clients to report any potential violations of this Policy immediately. For such reporting and to submit any other compliance specific query to VouWallet, kindly send an email to support@vouwallet.io.
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
As a Client you hereby agree to act in a manner acceptable to the terms and conditions of the Agreement you enter with VouWallet. You hereby acknowledge and agree that it is your sole responsibility to comply with all applicable laws in using the VouWallet services irrespective of the reasons behind the use of these services. You further agree that you must adhere to this policy of Acceptable Use.
Permitted types of services when paying from the wallet balance
- Selling digital goods on Steam or similar video game platforms
- Top up balance of mobile operators
- Top up your balance on social media platforms
Prohibited Activities
VouWallet does not permit and you hereby agree, not to use the VouWallet services for activities that are in violation of any law, regulation, directive, act, and decree. VouWallet also prohibits the use of its services for transactions that relate to the following list of items described in the table below:
Prohibited Items/Services transaction list
- Stolen Goods (including digital and virtual goods)
- Narcotics and drug paraphernalia
- Steroids, Controlled Substances and other products that pose a threat to consumer safety
- Cigarettes/electronic cigarettes/tobacco products/vapes
- Any item that infringes on a patent or violates any trademark, copyright, right of publicity or privacy and any other proprietary right under the law of any jurisdiction
- Sexually oriented material or services that are or offensive nature
- Weapons or knives that are regulated under jurisdictional laws, embargos and other international export/import controls. Also any firearms, ammunition and other firearm accessories that may be prohibited by law
- Weapons or knives that are regulated under jurisdictional laws, embargos and other international export/import controls. Also any firearms, ammunition and other firearm accessories that may be prohibited by law
- Anything that promotes racial intolerance, hate and violence
- Anything that allows for financial gains from of a crime
- Anything that exposes the personal information of third parties in violation of applicable laws
- Anything that relates to transactions that are associated with purchases of annuities or lottery contracts, layaway systems, off-shore banking or transactions to finance or refinance debts funded by a credit card
- Anything that relates to transactions that are for the sale of certain items before the seller has control or possession of the item
- Support Ponzi schemes and other such schemes that promise quick profits and substantial wealth
- Money orders and sale of travelers cheques
- Anything that relates to corruption and bribery
- Prescription drugs and personal medical devices
- Involve the sales of products or services identified by government agencies to have a high likelihood of being fraudulent
- Alcohol sales via Internet
- Manufacture and wholesale distribution of chemicals and allied products
- Fortune-tellers, tarot card readers and mystics services
- Support of political organizations and parties
- Support of religious organizations
- Sexual Encounter/Escort services
- Manufacture and wholesale distribution of counterfeit goods
VouWallet has the right as per the Terms and Conditions of the Agreement to prohibit any transaction that it deems potentially fraudulent, illegal or illicit.
Approval Requiring Activities
Certain services may not be prohibited but due to their higher risk nature will require VouWallet’s approval prior to VouWallet accepting any payment transactions that relate to such services. The list of such services can be found in the table below.
- Selling stored value cards and vouchers
- Provision of escrow and companion services
- Selling of transferable securities (including forex contracts) and other investment type instruments (such as stocks, bonds, options, futures) including interests in any private entity or property
- Crowd funding investments
- File sharing and Peer to Peer transfers
- Newsgroups access
Violations Report and Enquiries
VouWallet encourages its clients to report any potential violations of this Policy immediately. For such reporting and to submit any other compliance specific query to VouWallet, kindly send an email to support@vouwallet.io.
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
AML/CTF Compliance Program
TECTRIX SERVICE DMCC ("VouWallet", "Company", "we", "our") operates under the VouWallet brand. This AML/CTF Compliance Program shall apply to all branches and subsidiaries of VouWallet.
VouWallet maintains full cooperation with law and regulatory authorities in legislations, investigations and inquiries.
This AML/CTF Compliance Program is a subject to an annual review.
VouWallet adopts appropriate, sufficient measures aimed to preventing its operations from being used as means to conceal, manage, invest or use any form of money – or other assets – due to illicit activities, or to give the appearance of legality to such activities.
The company adopts a risk-based approach in the design and implementation of the AML/CTF Policy with a view to managing and mitigating ML/TF risks.
VouWallet 5 Key AML/CTF Principles:
VouWallet AML/CTF Compliance Program:
Prevention of Money Laundering & Terrorist Financing
The term “money laundering” (ML) means an act intended to have the effect of making any property:
(a) that is the proceeds obtained from the commission of an indictable offence or of any conduct which would constitute an indictable offence
(b) that in whole or in part, directly or indirectly, represents such proceeds, not to appear to be or so represent such proceeds
There are three common stages in the laundering of money, and they frequently involve numerous transactions. These stages are:
The term “terrorist financing” (TF) means:
Terrorists or terrorist organisations require financial support in order to achieve their aims. There is often a need for them to obscure or disguise links between them and their funding sources. It follows then that terrorist groups must similarly find ways to launder funds, regardless of whether the funds are from a legitimate or illegitimate source, in order to be able to use them without attracting the attention of the authorities.
FATF defines “proliferation of weapons of mass destruction” as the transfer and export of nuclear, chemical or biological weapons, their means of delivery and related materials.
The Financial Action Task Force (the FATF) is an inter-governmental body formed in 1989. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating of ML, TF, PF, and other related threats to the integrity of the international financial system. The FATF has developed a series of Recommendations that are recognised as the international standard for combating of ML, TF and PF. They form the basis for a co-ordinated response to these threats to the integrity of the financial system and help ensure a level playing field. In order to ensure full and effective implementation of its standards at the global level, the FATF monitors compliance by conducting evaluations on jurisdictions and undertakes stringent follow-up after the evaluations, including identifying high-risk and other monitored jurisdictions which could be subject to enhanced scrutiny by the FATF or counter-measures by the FATF members and the international community at large.
VouWallet has established its AML/CTF Compliance Program to ensure that any money laundering risks identified by VouWallet are appropriately managed and mitigated. This means having adequate systems and controls in place to mitigate the risk of the company being used to facilitate any financial crimes. This program is designed to represent the basic standards of Anti-Money Laundering and Combating Terrorism Financing procedures and standards, which will be strictly observed by VouWallet.
The AML/CTF Compliance Program is based upon applicable AML/CTF laws and regulations. This program is further designed to comply with the Financial Action Task Force (FATF) Standards on combating money laundering and the financing of terrorism and proliferation. It also follows the AML principles of the Wolfsberg Group.
AML / CTF SYSTEMS
VouWallet firmly believes that a reputation for integrity and openness, both in its business model and in its management systems and procedures - are crucial to achievement of its commercial goals and plans, and also to the fulfilment of its corporate responsibilities. The company is, therefore, committed to the highest standards of Money Laundering and Combating Terrorism financing (AML/CTF) measures in its operations, and it adheres to both established and recommended international standards to prevent the use of its services for the above purposes.
Effective Controls
To ensure proper implementation of AML/CTF procedures and controls, VouWallet has effective controls covering:
The Director of VouWallet is responsible for managing the business effectively and for the oversight of internal AML/CTF controls and systems. Director appoints the Compliance Officer/MLRO who has overall responsibility for the establishment and maintenance of VouWallet' AML/CTF systems
Three Lines of Defence
VouWallet follows the three lines of defense framework when managing ML/TF risks. The three lines of defense is an industry model for managing risk. It is used to structure roles, responsibilities and accountabilities for decision making, risk and control management, and independent assurance. The three lines of defense are used as the fundamental guiding principle when performing the AML/CTF review.
Audit Function
Audit function shall be established to perform regularly reviews of the AML/CTF systems, e.g. sample testing, to ensure effectiveness. The frequency and extent of the review should be commensurate with the risks of ML/TF and the size of VouWallet business. Where appropriate, VouWallet will seek a review from external auditors.
Independent Audit Functions include:
Know Your Employee
The best way to reduce insider abuse is to stop it before it starts. It starts during the hiring process, with VouWallet exercising the same precautions as it does when opening an account. VouWallet performs due diligence on employees verifying any information supplied.
Integrity of Staff
Integrity is one of the fundamental values that VouWallet seeks in the employees it is going to hire. Integrity involves moral judgment and character, honesty and leadership values.
Counter-Checking of Work Completed by Staff
VouWallet performs occasional spot checks on work done by staff at all levels. Usually, these checks are undertaken by senior management to ensure that VouWallet policies and procedures are being followed and everything is in the correct order.
VouWallet has a “Zero Tolerance” policy regarding intentional violation of applicable laws prohibiting money laundering, terrorist financing and related financial crimes. VouWallet will require the immediate discharge of an employee who commits such violations, and will refer such cases to the appropriate regulatory bodies.
Procedures for Employees engaged in a Suspicious Activity
If an employee is suspected of engaging in any type of unusual or questionable activity, this must be brought to the attention of both Senior Management and the Compliance officer immediately. Senior Management and/or the Compliance officer will jointly investigate the actions of the employee in the most discreet manner. All actions taken to conduct the investigation must be documented.
Senior Management determines that the employee’s activity was prejudicial to the interests of the Company, it will determine whether disciplinary action is necessary. Senior Management may seek advice from legal counsel in such action.
In order to know its employees VouWallet conducts:
AML/CTF Training
VouWallet has a clear policy towards staff training with respect to AML/CTF issues. Staff is being made aware of:
The training is assigned for all groups of VouWallet' staff:
Training program provides staff with an understanding of the process of money laundering, the laws and regulations that make it illegal, and the responsibilities of employees to help detect and prevent it. The training on AML/CTF issues raises awareness of financial crime risks, global laws and regulations, laws and regulations applicable to VouWallet.
Annual AML Seminar
Designed for all operational staff and includes:
Ad-hoc Training
Provided regularly to all employees based on, but not limited to, changes in government regulations, changes/amendments in VouWallet’ AML/CFT policies and procedures.
VouWallet uses mix of training techniques and tools in delivering training, depending on the available resources and learning needs of its staff. These techniques and tools include visiting external seminars of Mastercard academy, on-line learning systems, focused classroom training, relevant videos as well as paper- or intranet-based procedures manuals.
VouWallet also includes available FATF papers and typologies as part of its the training materials. All materials are kept up-to-date and in line with current requirements and standards. The effectiveness of training is being monitored by testing the staff’s understanding of AML/CTF issues and its ability to recognise suspicious activity. To achieve this VouWallet’s Compliance Department conducts random testing sessions on a quarterly basis.
All training related records and documents are kept throughout the employment relationship with the employee and for a period of at least five years after the end of the employment.
RISK-BASED APPROACH (RBA)
By adopting a risk-based approach, financial institutions are able to ensure that measures to prevent or mitigate money laundering and financing threats are commensurate to the risks identified. This will allow resources to be allocated in the most efficient ways. The resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
The inherent risk is assessed in course of identification of the specific products, services, customers, entities, and geographic locations. Depending on the specific characteristics of the particular product, service, or customer, the risks are not always the same. Various factors, such as the number and volume of transactions, geographic locations, and nature of the customer relationships, should be considered.
Risk assessment on the stage of on-boarding of a new customer is an opportunity for the management of VouWallet to gain an insight into the type and nature of its potential customers, their geographic locations and business activities. Verifying identities, making sure they’re real, confirming they’re not on any prohibited lists, and assessing their risk factors—ensures that VouWallet keeps money laundering, terrorism financing, and more run-of-the-mill fraud schemes at bay.
VouWallet determines the extent of its CDD measures and ongoing monitoring, using a risk-based approach (RBA) depending upon the background of the customer and the product, transaction or service used by that customer, so that preventive or mitigating measures are commensurate to the risks identified.
The RBA enables VouWallet to subject its customers to proportionate controls and oversight by determining:
An RBA involves identifying and categorising ML/TF risks at the customer level and establishing reasonable measures based on risks identified. An RBA does not refrain VouWalletfrom engaging in transactions with customers or establishing business relationships with potential customers, but rather it assists VouWallet to effectively manage potential ML/TF risks.
Non-acceptable Customers
VouWallet does not accept clients from the industries as stated below:
The detailed information on prohibited business types is captured in Appendix hereto.
Prohibition of Anonymous Accounts
VouWallet does not maintain anonymous accounts or accounts in fictitious names for any new or existing customer.
Prohibition of Shell Banks
VouWallet does not maintain correspondent relationships with shell banks, which are defined as non-resident banks that have no permanent executive bodies in the countries in which they have been registered, and has not entered into correspondent relationships with banks that allow their accounts to be used by shell banks.
Customer Due Diligence
Customer due diligence (CDD) is central to an effective anti-money laundering and counter-terrorism financing (AML/CTF) regime. VouWallet takes measures to identify and verify each of its customers so it can:
CUSTOMER DUE DILIGENCE (CDD)
Identification and Verification of the Customer’s Identity
VouWallet applies the following CDD measures:
If a person purports to act on behalf of the customer, VouWallet take s measures to: identify the person and take reasonable measures to verify the person’s
Identification and Verification of a Beneficial Owner
A beneficial owner is normally an individual who ultimately owns or controls the customer or on whose behalf a transaction or activity is being conducted. VouWallet verifies the identity of beneficial owner(s) owning or controlling 25% or more of the voting rights or shares of the legal entity, taking reasonable measures based on ML/ TF risks, so that VouWallet knows who the beneficial owner(s) is.
When an individual is identified as a beneficial owner, VouWallet obtains the following identification information:
VouWallet obtains the residential address (and permanent address if different) of the beneficial owners and adopts a risk-based approach to determine the need to verify the address, taking in account the number of beneficial owners, the nature and distribution of the interests in the entity and the nature and extent of any business, contractual or family relationship.
Identification and Verification of a Person who Purports to Act on Behalf of the Customer
If a person purports to act on behalf of the customer, VouWallet:
In general, VouWallet identifies and verifies the identity of those authorized to give instructions for the movement of funds or assets. VouWallet obtains written authority in order to verify that the individual purporting to represent the customer is authorised to do so.
Purpose and Intended Nature of Business Relationship
Unless the purpose and intended nature are obvious, VouWallet obtains satisfactory information from all new customers as to the intended purpose and reason for opening the account or establishing the business relationship, and records the information on the account opening documentation.
Depending on the VouWallet risk assessment of the situation, information required may include:
Keeping Customer’s Information Up-to-Date
VouWallet takes steps from time to time to ensure that the customer information that has been obtained is up- to-date and relevant. To achieve this, VouWallet undertakes periodic reviews of existing records of customers.
An appropriate time to do so is upon certain trigger events such as:
KNOW YOUR CUSTOMER / CUSTOMER ON-BOARDING
Identification and verification of natural persons
VouWallet requests identity document( Passport or ID Card), specifying:
Address identification and verification
VouWallet verifies the residential address (and permanent address if different) of a direct customer with whom it establishes a business relationship.
Methods for verifying residential addresses may include obtaining:
Identification of a Legal Entity
With respect to legal entities, VouWallet pays special attention when looking behind the customer to identity those who have ultimate control or ultimate beneficial ownership over the business and the customer’s assets. Verifying the identity of the beneficial owner(s) is being carried out using reasonable measures based on a risk-based approach. For a customer other than a natural person, VouWallet ensures that it fully understands the customer’s legal form, structure and ownership, and additionally obtains information on the nature of its business, and the reasons for seeking the product or service unless the reasons are obvious.
VouWallet conducts reviews from time to time to ensure the customer information held is up-to-date and relevant; methods by which a review could be conducted include conducting company searches, seeking copies of resolutions appointing directors, noting the resignation of directors, or by other appropriate means.
VouWallet obtains and verifies the following information in relation to a customer which is a legal entity:
If the business address of the customer is different from the registered office address in the place of incorporation, VouWallet obtains information on the business address and verifies it.
In the course of verifying the customer’s identity, VouWallet obtains the following data and documents:
VouWallet shall also:
Beneficial Owners
VouWallet identifies and records the identity of all beneficial owners, and takes reasonable measures to verify the identity of
For companies with multiple layers in their ownership structures, VouWallet takes measures to ensure that it has an understanding of the ownership and control structure of the company.
ENHANCED CUSTOMER DUE DILIGENCE (EDD)
VouWallet applies an Enhance Due Diligence where the customer and product/service combination is considered to be a greater risk. This higher level of due diligence is required to mitigate the increased risk. A high risk situation generally occurs where there is an increased opportunity from money laundering or terrorist financing through the service and product VouWallet provides or from a customer of VouWallet.
What the enhanced due diligence actually entails will be dependent on the nature and severity of the risk.
High-Risk Situations
In any situation that by its nature presents a higher risk of ML/TF, VouWallettakes additional measures to mitigate the risk of ML/TF.
Additional measures or EDD may include:
Politically Exposed Persons (PEPs)
Politically Exposed Persons:
A PEP’s close associate is:
In order to reduce possible risks VouWallet conducts EDD at the outset of the business relationship and ongoing monitoring where it knows or suspects that it has business relationship with a PEP.
For that purpose VouWallet:
In relation to PEPs, VouWallet applies the following EDD measures:
Source of Wealth vs Source of Funds
Establishing the customer’s source of wealth or source of funds is a core requirement of EDD. Source of wealth refers to the origin of an individual’s entire body of wealth (i.e. total assets). This information will usually give an indication as to the size of wealth the customer would be expected to have, and a picture of how the individual acquired such wealth.
Although VouWallet may not have specific information about assets not deposited with or processed by it, it may be possible to gather general information from the individual, commercial databases or other open sources. Source of funds refers to the origin of the particular funds or other assets which are the subject of the business relationship between an individual and VouWallet (e.g. the amounts being invested, deposited, or wired as part of the business relationship). Source of funds information should not simply be limited to knowing from which the funds may have been transferred, but also the activity that generates the funds.
The information obtained should be substantive and establish a provenance or reason for the funds having been acquired.
VouWallet collects information relating to the source of wealth or source of funds of its customers and, according to the level of risk involved, takes reasonable steps to verify that information. The types of data and documents that can be used for verification will vary depending on the circumstances and the information that the customer provides to VouWallet.
The following documents, data, or information could be considered reliable and independent:
High-risk jurisdictions
VouWallet gives particular attention to, and exercises extra care in respect of:
The Financial Action Task Force (“FATF”) has published a list of countries/jurisdictions classified as being “non-cooperative in the international fight against money laundering”. The list may be modified and updated as needed. The FATF list is kept current by the Compliance officer/MLRO.
In addition to ascertaining and documenting the business rationale for establishing a relationship, VouWallet takes reasonable measures to establish the source of funds of such customers.
In determining which jurisdictions do not apply, or insufficiently apply the FATF Recommendations, or may otherwise pose a higher risk, VouWallet considers, among other things:
In addition to the FATF and FATF-style regional bodies, such sources may include, but are not limited to, supra- national or international bodies such as the International Monetary Fund, and the Egmont Group of Financial Intelligence Units, as well as relevant national government bodies and non-government organisations. The information provided by these credible sources does not have the effect of law or regulation and should not be viewed as an automatic determination that something is of higher risk. VouWallet will make a reference to publicly available information or relevant reports and data bases on corruption risk, e.g. Transparency International Corruption Perceptions Index.
SANCTIONS POLICIES
With a view to ensure that there are no payments to or from a person on a sanctions list issued by an overseas jurisdiction, VouWallet conducts screening against lists of FATF not-compliant countries, in addition to the lists of sanctioned countries, entities and persons.
VouWallet takes measures to thoroughly screen its customers and gather as much information as possible about them and their accounts. This helps to ensure that the customers are not involved in financial crimes.
Many transactions that are completed in order to send money to terrorist organisations are small and innocuous. Terrorist financiers purposefully do not send large amounts of money at once, as they wish to avoid the attention of both governments and financial institutions. Additionally, individuals who finance terrorism also use trade-based money laundering schemes in order to get their money across borders. This is becoming much more common, and it is a difficult problem to track down.
VouWallet takes measures to ensure compliance with the relevant regulations and legislation on terrorist financing. It is particularly vital that VouWallet is able to identify and report transactions with terrorist suspects and designated parties.
VouWallet maintains a database of names and particulars of terrorist suspects and designated parties which consolidates the various lists that have been made known to it. Alternatively, VouWallet makes arrangements to access to such a database maintained by third party service providers.
VouWallet screens customers and transactions against following lists:
To avoid establishing business relationship or conducting transactions with any terrorist suspects and possible designated parties, VouWallet implements an effective screening mechanism, which includes:
UNATMO is an ordinance to further implement a decision under UNSCR 1373 (2001) relating to measures for prevention of terrorist acts and a decision under UNSCR 2178 (2014) relating to the prevention of travel for the purpose of terrorist acts or terrorist training; as well as to implement certain terrorism-related multilateral conventions and certain FATF Recommendations. All UN member states are required to freeze any funds, or other financial assets, or economic resources of any person(s) named in these lists and to report any suspected name matches to the relevant authorities.
Where a person or property is designated by a Committee of the UNSC as a terrorist/terrorist associate or terrorist property respectively, the Chief Executive may publish a notice in the Gazette specifying the name of the person or the property. Besides, the Chief Executive may make an application to the Court of First Instance for an order to specify a person or property as a terrorist/terrorist associate or terrorist property respectively, and if the order is made, it will also be published in the Gazette.
A number of provisions in the UNATMO are of particular relevance to VouWallet, and are listed below:
VouWallet, operating internationally, is aware of the scope and focus of relevant sanctions regimes in those jurisdictions. Where these sanctions regimes may affect its operations, VouWallet considers what implications exist for its procedures and takes appropriate measures, such as including relevant overseas designations in its database for screening purpose, where applicable.
OFAC Compliance
It is the policy of VouWallet to comply with all OFAC requirements and directives that restrict providing services, conducting business with, maintaining accounts for, or handling transactions or monetary transfers for foreign countries or foreign nationals listed on the Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals (SDNs) and Blocked Entities.
VouWallet shall not open a relationship for, handle a transaction or monetary transfer for, or do business with any person, government or other entity on the OFAC list of Specially Designated Nationals and Blocked Entities. Through screening and monitoring, the Company will identify such customers or transactions, and if it is found, contact OFAC immediately and all directives as to rejecting, restricting, blocking or seizing will be followed.
As per new relationship opening procedure, no new relationship will be established without passing through the steps indicated and obtain the necessary approvals. As part of the relationship opening procedure, the Compliance Department will check the names of all, business owners, and authorized signers against OFAC’s master list of "Specially Designated Nationals and Blocked Persons" (SDN list), and check the prospective customer’s geographical location for embargoed countries and cities by putting the information through the system prior to opening the relationship.
The system will check names against the OFAC list and prior to approving the relationship. The system checks the entered name for matching spelling, close matches, name variations and phonetically. If the name of the prospective customer is a match or possible match to a name in the OFAC list, the system will displays the potential match, and maintain an electronic record of such a match to be included in the documentation.
The Company’s staff is trained to recognize false positive matches and can continue with the transaction in the event a false positive match is displayed. The system will prompt the Compliance Staff to document the reason for the false positive, and will maintain that record in an electronic file. Any close matches that cannot be easily categorized as a false positive must be immediately brought to the attention of the Compliance Officer for validation.
Appendix. Prohibited Business Types
VouWallet maintains full cooperation with law and regulatory authorities in legislations, investigations and inquiries.
This AML/CTF Compliance Program is a subject to an annual review.
VouWallet adopts appropriate, sufficient measures aimed to preventing its operations from being used as means to conceal, manage, invest or use any form of money – or other assets – due to illicit activities, or to give the appearance of legality to such activities.
The company adopts a risk-based approach in the design and implementation of the AML/CTF Policy with a view to managing and mitigating ML/TF risks.
VouWallet 5 Key AML/CTF Principles:
- to comply with AML/CTF legislation in the countries in which it operates
- to strive to fulfil international standards as detailed by the Financial Action Task Force (FATF) recommendations
- to work in conjunction with the governments of the countries VouWallet operates in, as well as support their objectives in relation to the prevention, detection and control of ML/TF
- VouWallet may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility
- to comply with primary legislation on AML/CTF
VouWallet AML/CTF Compliance Program:
- forms part of its wider compliance regime, and is designed to meet the requirements of its legislative environment
- ensures that VouWallet is able to detect suspicious activities associated with money laundering, fraud, and terrorist financing, and report them to the appropriate authorities
- focuses not only on the effectiveness of internal systems and controls developed to detect money laundering, but on the risk posed by the activities of customers with which VouWallet does business
- is built on a strong foundation of regulatory understanding and overseen by personnel who are experienced and knowledgeable enough to create a climate of compliance at every level of their organisation
Prevention of Money Laundering & Terrorist Financing
The term “money laundering” (ML) means an act intended to have the effect of making any property:
(a) that is the proceeds obtained from the commission of an indictable offence or of any conduct which would constitute an indictable offence
(b) that in whole or in part, directly or indirectly, represents such proceeds, not to appear to be or so represent such proceeds
There are three common stages in the laundering of money, and they frequently involve numerous transactions. These stages are:
- Placement — the physical disposal of cash proceeds derived from illegal activities
- Layering — separating illicit proceeds from their source by creating complex layers of financial transactions designed to disguise the source of the money, subvert the audit trail and provide anonymity
- Integration — creating the impression of apparent legitimacy to criminally derived wealth. In situations where the layering process succeeds, integration schemes effectively return the laundered proceeds back into the general financial system and the proceeds appear to be the result of, or connected to, legitimate business activities.
The term “terrorist financing” (TF) means:
- the provision or collection, by any means, directly or indirectly, of any property
- with the intention that the property be used
- knowing that the property will be used, in whole or in part, to commit one or more terrorist acts (whether or not the property is actually so used)
- the making available of any property or financial (or related) services, by any means, directly or indirectly, to or for the benefit of a person knowing that, or being reckless as to whether, the person is a terrorist or terrorist associate
- the collection of property or solicitation of financial (or related) services, by any means, directly or indirectly, for the benefit of a person knowing that, or being reckless as to whether, the person is a terrorist or terrorist associate
Terrorists or terrorist organisations require financial support in order to achieve their aims. There is often a need for them to obscure or disguise links between them and their funding sources. It follows then that terrorist groups must similarly find ways to launder funds, regardless of whether the funds are from a legitimate or illegitimate source, in order to be able to use them without attracting the attention of the authorities.
FATF defines “proliferation of weapons of mass destruction” as the transfer and export of nuclear, chemical or biological weapons, their means of delivery and related materials.
The Financial Action Task Force (the FATF) is an inter-governmental body formed in 1989. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating of ML, TF, PF, and other related threats to the integrity of the international financial system. The FATF has developed a series of Recommendations that are recognised as the international standard for combating of ML, TF and PF. They form the basis for a co-ordinated response to these threats to the integrity of the financial system and help ensure a level playing field. In order to ensure full and effective implementation of its standards at the global level, the FATF monitors compliance by conducting evaluations on jurisdictions and undertakes stringent follow-up after the evaluations, including identifying high-risk and other monitored jurisdictions which could be subject to enhanced scrutiny by the FATF or counter-measures by the FATF members and the international community at large.
VouWallet has established its AML/CTF Compliance Program to ensure that any money laundering risks identified by VouWallet are appropriately managed and mitigated. This means having adequate systems and controls in place to mitigate the risk of the company being used to facilitate any financial crimes. This program is designed to represent the basic standards of Anti-Money Laundering and Combating Terrorism Financing procedures and standards, which will be strictly observed by VouWallet.
The AML/CTF Compliance Program is based upon applicable AML/CTF laws and regulations. This program is further designed to comply with the Financial Action Task Force (FATF) Standards on combating money laundering and the financing of terrorism and proliferation. It also follows the AML principles of the Wolfsberg Group.
AML / CTF SYSTEMS
VouWallet firmly believes that a reputation for integrity and openness, both in its business model and in its management systems and procedures - are crucial to achievement of its commercial goals and plans, and also to the fulfilment of its corporate responsibilities. The company is, therefore, committed to the highest standards of Money Laundering and Combating Terrorism financing (AML/CTF) measures in its operations, and it adheres to both established and recommended international standards to prevent the use of its services for the above purposes.
Effective Controls
To ensure proper implementation of AML/CTF procedures and controls, VouWallet has effective controls covering:
- Effective AML/CTF compliance program
- Senior management oversight
- Appointment of Compliance Officer / Money Laundering Reporting Officer (MLRO)
- Compliance and audit function
- Staff screening and training
The Director of VouWallet is responsible for managing the business effectively and for the oversight of internal AML/CTF controls and systems. Director appoints the Compliance Officer/MLRO who has overall responsibility for the establishment and maintenance of VouWallet' AML/CTF systems
Three Lines of Defence
VouWallet follows the three lines of defense framework when managing ML/TF risks. The three lines of defense is an industry model for managing risk. It is used to structure roles, responsibilities and accountabilities for decision making, risk and control management, and independent assurance. The three lines of defense are used as the fundamental guiding principle when performing the AML/CTF review.
Audit Function
Audit function shall be established to perform regularly reviews of the AML/CTF systems, e.g. sample testing, to ensure effectiveness. The frequency and extent of the review should be commensurate with the risks of ML/TF and the size of VouWallet business. Where appropriate, VouWallet will seek a review from external auditors.
Independent Audit Functions include:
- Compliance and audit functions are independent in practice
- The regular review is performed at a frequency of once a year
- External party is leveraged to perform the auditing
- Availability of direct communication to senior management through regular committees (compliance committee) or other means of direct communication
Know Your Employee
The best way to reduce insider abuse is to stop it before it starts. It starts during the hiring process, with VouWallet exercising the same precautions as it does when opening an account. VouWallet performs due diligence on employees verifying any information supplied.
Integrity of Staff
Integrity is one of the fundamental values that VouWallet seeks in the employees it is going to hire. Integrity involves moral judgment and character, honesty and leadership values.
Counter-Checking of Work Completed by Staff
VouWallet performs occasional spot checks on work done by staff at all levels. Usually, these checks are undertaken by senior management to ensure that VouWallet policies and procedures are being followed and everything is in the correct order.
VouWallet has a “Zero Tolerance” policy regarding intentional violation of applicable laws prohibiting money laundering, terrorist financing and related financial crimes. VouWallet will require the immediate discharge of an employee who commits such violations, and will refer such cases to the appropriate regulatory bodies.
Procedures for Employees engaged in a Suspicious Activity
If an employee is suspected of engaging in any type of unusual or questionable activity, this must be brought to the attention of both Senior Management and the Compliance officer immediately. Senior Management and/or the Compliance officer will jointly investigate the actions of the employee in the most discreet manner. All actions taken to conduct the investigation must be documented.
Senior Management determines that the employee’s activity was prejudicial to the interests of the Company, it will determine whether disciplinary action is necessary. Senior Management may seek advice from legal counsel in such action.
In order to know its employees VouWallet conducts:
- a criminal conviction search in jurisdictions where it is possible
- credit checks
- a private investigation, if thought necessary
- an internet check before they are hired
AML/CTF Training
VouWallet has a clear policy towards staff training with respect to AML/CTF issues. Staff is being made aware of:
- VouWallet and their own personal statutory obligations and the possible consequences for failure to report suspicious transactions under the DTROP, the OSCO and the UNATMO
- any other statutory and regulatory obligations that concern VouWallet and themselves under the DTROP, the OSCO, the UNATMO, and the possible consequences of breaches of these obligations
- the VouWallet' policies and procedures relating to AML/CTF
- any new and emerging techniques, methods and trends in ML/TF to the extent that such information is needed by the staff to carry out their particular roles in VouWallet with respect to AML/CTF
The training is assigned for all groups of VouWallet' staff:
- all new staff, irrespective of seniority
- to the Compliance Officer/ MLRO
- back-office staff, depending on their roles
- managerial staff
Training program provides staff with an understanding of the process of money laundering, the laws and regulations that make it illegal, and the responsibilities of employees to help detect and prevent it. The training on AML/CTF issues raises awareness of financial crime risks, global laws and regulations, laws and regulations applicable to VouWallet.
Annual AML Seminar
Designed for all operational staff and includes:
- General information: the background and history pertaining to money laundering controls, what money laundering and terrorist financing is
- Legal framework: how AML/CFT laws and regulations apply to VouWallet and its employees
- Penalties for anti-money laundering violations, including criminal and civil penalties, fines, jail terms, as well as internal sanctions, such as disciplinary action up to and including termination of employment
- How to react when faced with a suspicious client or activity
- Internal policies, such as customer identification and verification procedures and CDD policies
- What the legal record keeping requirements are
- Duties and accountability of employees
Ad-hoc Training
Provided regularly to all employees based on, but not limited to, changes in government regulations, changes/amendments in VouWallet’ AML/CFT policies and procedures.
VouWallet uses mix of training techniques and tools in delivering training, depending on the available resources and learning needs of its staff. These techniques and tools include visiting external seminars of Mastercard academy, on-line learning systems, focused classroom training, relevant videos as well as paper- or intranet-based procedures manuals.
VouWallet also includes available FATF papers and typologies as part of its the training materials. All materials are kept up-to-date and in line with current requirements and standards. The effectiveness of training is being monitored by testing the staff’s understanding of AML/CTF issues and its ability to recognise suspicious activity. To achieve this VouWallet’s Compliance Department conducts random testing sessions on a quarterly basis.
All training related records and documents are kept throughout the employment relationship with the employee and for a period of at least five years after the end of the employment.
RISK-BASED APPROACH (RBA)
By adopting a risk-based approach, financial institutions are able to ensure that measures to prevent or mitigate money laundering and financing threats are commensurate to the risks identified. This will allow resources to be allocated in the most efficient ways. The resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
The inherent risk is assessed in course of identification of the specific products, services, customers, entities, and geographic locations. Depending on the specific characteristics of the particular product, service, or customer, the risks are not always the same. Various factors, such as the number and volume of transactions, geographic locations, and nature of the customer relationships, should be considered.
Risk assessment on the stage of on-boarding of a new customer is an opportunity for the management of VouWallet to gain an insight into the type and nature of its potential customers, their geographic locations and business activities. Verifying identities, making sure they’re real, confirming they’re not on any prohibited lists, and assessing their risk factors—ensures that VouWallet keeps money laundering, terrorism financing, and more run-of-the-mill fraud schemes at bay.
VouWallet determines the extent of its CDD measures and ongoing monitoring, using a risk-based approach (RBA) depending upon the background of the customer and the product, transaction or service used by that customer, so that preventive or mitigating measures are commensurate to the risks identified.
The RBA enables VouWallet to subject its customers to proportionate controls and oversight by determining:
- the extent of the due diligence to be performed on the direct customer
- the extent of the measures to be undertaken to verify the identity of any beneficial owner and any person purporting to act on behalf of the customer
- the level of ongoing monitoring to be applied to the relationship
- measures to mitigate any risks identified
An RBA involves identifying and categorising ML/TF risks at the customer level and establishing reasonable measures based on risks identified. An RBA does not refrain VouWalletfrom engaging in transactions with customers or establishing business relationships with potential customers, but rather it assists VouWallet to effectively manage potential ML/TF risks.
Non-acceptable Customers
VouWallet does not accept clients from the industries as stated below:
- Trade /production/mediation in the trade of weapons
- Trade of antiques works of art, numismatic values
- Trade of ferrous, non-ferrous and rare metals and their wares, precocious stones
- Production/recycling of explosive and nuclear fuel
- Unregulated charities and other unregulated organisations
- Dealers of high-value precious goods
- Adult industries
- Wholesale trade of alcohol and tobacco products
- Unlicensed financial institutions / money service businesses
The detailed information on prohibited business types is captured in Appendix hereto.
Prohibition of Anonymous Accounts
VouWallet does not maintain anonymous accounts or accounts in fictitious names for any new or existing customer.
Prohibition of Shell Banks
VouWallet does not maintain correspondent relationships with shell banks, which are defined as non-resident banks that have no permanent executive bodies in the countries in which they have been registered, and has not entered into correspondent relationships with banks that allow their accounts to be used by shell banks.
Customer Due Diligence
Customer due diligence (CDD) is central to an effective anti-money laundering and counter-terrorism financing (AML/CTF) regime. VouWallet takes measures to identify and verify each of its customers so it can:
- determine the money laundering and terrorism financing risk posed by each customer
- decide whether to proceed with a business relationship or transaction
- assess the level of future monitoring required
CUSTOMER DUE DILIGENCE (CDD)
Identification and Verification of the Customer’s Identity
VouWallet applies the following CDD measures:
- identification of the customer and verification of the customer’s identity using reliable, independent source documents, data or information
- identification and taking reasonable measures to verify the beneficial owner’s identity so that VouWallet is satisfied that it knows who the beneficial owner is, including in the case of a legal person or trust, measures to enable VouWallet to understand the ownership and control structure of the legal person or trust
- obtaining an information on the purpose and intended nature of the business relationship unless the purpose and intended nature are obvious
If a person purports to act on behalf of the customer, VouWallet take s measures to: identify the person and take reasonable measures to verify the person’s
- identity using reliable and independent source documents, data or information
- verify the person’s authority to act on behalf of the customer CDD requirements should apply:
- at the outset of a business relationship
- before performing any occasional transaction
- when VouWallet suspects that the customer or the customer’s account is involved in ML/TF irrespective of the amount of transaction
- when VouWallet doubts the veracity or adequacy of any information previously obtained for the purpose of identifying the customer or for the purpose of verifying the customer’s identity
Identification and Verification of a Beneficial Owner
A beneficial owner is normally an individual who ultimately owns or controls the customer or on whose behalf a transaction or activity is being conducted. VouWallet verifies the identity of beneficial owner(s) owning or controlling 25% or more of the voting rights or shares of the legal entity, taking reasonable measures based on ML/ TF risks, so that VouWallet knows who the beneficial owner(s) is.
When an individual is identified as a beneficial owner, VouWallet obtains the following identification information:
- full name
- date of birth
- nationality
- identity document type and number
VouWallet obtains the residential address (and permanent address if different) of the beneficial owners and adopts a risk-based approach to determine the need to verify the address, taking in account the number of beneficial owners, the nature and distribution of the interests in the entity and the nature and extent of any business, contractual or family relationship.
Identification and Verification of a Person who Purports to Act on Behalf of the Customer
If a person purports to act on behalf of the customer, VouWallet:
- identifies the person and takes reasonable measures to verify the person’s identity on the basis of documents, data or information provided by:
- a governmental body
- the relevant authority or any other relevant authority
- any other reliable and independent source that is recognised by the relevant authority
- verifies the person’s authority to act on behalf of the customer.
In general, VouWallet identifies and verifies the identity of those authorized to give instructions for the movement of funds or assets. VouWallet obtains written authority in order to verify that the individual purporting to represent the customer is authorised to do so.
Purpose and Intended Nature of Business Relationship
Unless the purpose and intended nature are obvious, VouWallet obtains satisfactory information from all new customers as to the intended purpose and reason for opening the account or establishing the business relationship, and records the information on the account opening documentation.
Depending on the VouWallet risk assessment of the situation, information required may include:
- nature and details of the business/occupation/employment
- the anticipated level and nature of the activity that is to be undertaken through the relationship (e.g. what the typical transactions are likely to be)
- location of customer
- the expected source and origin of the funds to be used in the relationship
- initial and ongoing source(s) of wealth or income
Keeping Customer’s Information Up-to-Date
VouWallet takes steps from time to time to ensure that the customer information that has been obtained is up- to-date and relevant. To achieve this, VouWallet undertakes periodic reviews of existing records of customers.
An appropriate time to do so is upon certain trigger events such as:
- when a significant transaction (not only of a big amount, but also unusual) is to take place
- when a material change occurs in the way the customer’s account is operated
- when the customer’s documentation standards change substantially
- when VouWallet is aware that it lacks sufficient information about the customer concerned
KNOW YOUR CUSTOMER / CUSTOMER ON-BOARDING
Identification and verification of natural persons
VouWallet requests identity document( Passport or ID Card), specifying:
- full name
- date of birth
- nationality
- identity document type and number
Address identification and verification
VouWallet verifies the residential address (and permanent address if different) of a direct customer with whom it establishes a business relationship.
Methods for verifying residential addresses may include obtaining:
- a recent utility bill issued within the last 3 months
- recent correspondence from a Government department or agency (i.e. issued within the last 3 months)
- a statement, issued by an authorized institution, a licensed corporation or an authorized insurer within the last 3 months.
Identification of a Legal Entity
With respect to legal entities, VouWallet pays special attention when looking behind the customer to identity those who have ultimate control or ultimate beneficial ownership over the business and the customer’s assets. Verifying the identity of the beneficial owner(s) is being carried out using reasonable measures based on a risk-based approach. For a customer other than a natural person, VouWallet ensures that it fully understands the customer’s legal form, structure and ownership, and additionally obtains information on the nature of its business, and the reasons for seeking the product or service unless the reasons are obvious.
VouWallet conducts reviews from time to time to ensure the customer information held is up-to-date and relevant; methods by which a review could be conducted include conducting company searches, seeking copies of resolutions appointing directors, noting the resignation of directors, or by other appropriate means.
VouWallet obtains and verifies the following information in relation to a customer which is a legal entity:
- full name
- date and place of incorporation
- registration or incorporation number
- registered office address in the place of incorporation
- web-site requirements
- Cross-reference of the web-site and the Company (Merchant’s web-site as well as their Terms & Conditions (User Agreement) are to contain the following information about the Company: address, register number, license (if applicable).
- Terms & Conditions (User Agreement)
- Payment&Refund Policy
- Privacy Policy
If the business address of the customer is different from the registered office address in the place of incorporation, VouWallet obtains information on the business address and verifies it.
In the course of verifying the customer’s identity, VouWallet obtains the following data and documents:
- a copy of the certificate of incorporation and business registration (where applicable)
- a copy of the company’s memorandum and articles of association which evidence the powers that regulate and bind the company
- details of the ownership and structure control of the company, e.g. an ownership chart
- the names of all directors
VouWallet shall also:
- confirm the company is still registered and has not been dissolved, wound up, suspended or struck off
- independently identify and verify the names of the directors and shareholders recorded in the company registry in the place of incorporation
- verifiy the company’s registered office address in the place of incorporation
Beneficial Owners
VouWallet identifies and records the identity of all beneficial owners, and takes reasonable measures to verify the identity of
- all shareholders holding 25% of the voting rights or share capital (the threshold shall be lowered to 10% for each high-risk relationship)
- any individual who exercises ultimate control over the management of the corporation
- any person on whose behalf the customer is acting
For companies with multiple layers in their ownership structures, VouWallet takes measures to ensure that it has an understanding of the ownership and control structure of the company.
ENHANCED CUSTOMER DUE DILIGENCE (EDD)
VouWallet applies an Enhance Due Diligence where the customer and product/service combination is considered to be a greater risk. This higher level of due diligence is required to mitigate the increased risk. A high risk situation generally occurs where there is an increased opportunity from money laundering or terrorist financing through the service and product VouWallet provides or from a customer of VouWallet.
What the enhanced due diligence actually entails will be dependent on the nature and severity of the risk.
High-Risk Situations
In any situation that by its nature presents a higher risk of ML/TF, VouWallettakes additional measures to mitigate the risk of ML/TF.
Additional measures or EDD may include:
- obtaining additional information on the customer (e.g. connected parties, accounts or relationships) and updating more regularly the customer profile including the identification data
- obtaining additional information on the intended nature of the business relationship (e.g. anticipated account activity), the source of wealth and source of funds
- obtaining the approval of senior management to commence or continue the relationship
- conducting enhanced monitoring of the business relationship, by increasing the number and timing of the controls applied and selecting patterns of transactions that need further examination
Politically Exposed Persons (PEPs)
Politically Exposed Persons:
- an individual who is or has been entrusted with a prominent public function and includes a head of state, head of government, senior politician, senior government, judicial or military official, senior executive of a state-owned corporation and an important political party official
- a spouse, a partner, a child or a parent of an individual falling within paragraph above, or a spouse or a partner of a child of such an individual
- a close associate of an individual falling within paragraph above
A PEP’s close associate is:
- an individual who has close business relations with a person falling under the definition of PEP, including an individual who is a beneficial owner of a legal person or trust
- an individual who is the beneficial owner of a legal person or trust that is set up for the benefit of a person falling under the definition of PEP
In order to reduce possible risks VouWallet conducts EDD at the outset of the business relationship and ongoing monitoring where it knows or suspects that it has business relationship with a PEP.
For that purpose VouWallet:
- makes reference to publicly available information
- screens against commercially available databases for determining whether a customer or a beneficial owner of a customer is a PEP
- uses publicly available information or refer to relevant reports and databases on corruption risk published by specialised national, international, non-governmental and commercial organisations to assess which countries are most vulnerable to corruption
In relation to PEPs, VouWallet applies the following EDD measures:
- obtaining approval from VouWallet' senior management
- taking reasonable measures to establish the customer’s or the beneficial owner’s source of wealth and the source of the funds
- applying enhanced monitoring to the relationship in accordance with the assessed risks
Source of Wealth vs Source of Funds
Establishing the customer’s source of wealth or source of funds is a core requirement of EDD. Source of wealth refers to the origin of an individual’s entire body of wealth (i.e. total assets). This information will usually give an indication as to the size of wealth the customer would be expected to have, and a picture of how the individual acquired such wealth.
Although VouWallet may not have specific information about assets not deposited with or processed by it, it may be possible to gather general information from the individual, commercial databases or other open sources. Source of funds refers to the origin of the particular funds or other assets which are the subject of the business relationship between an individual and VouWallet (e.g. the amounts being invested, deposited, or wired as part of the business relationship). Source of funds information should not simply be limited to knowing from which the funds may have been transferred, but also the activity that generates the funds.
The information obtained should be substantive and establish a provenance or reason for the funds having been acquired.
VouWallet collects information relating to the source of wealth or source of funds of its customers and, according to the level of risk involved, takes reasonable steps to verify that information. The types of data and documents that can be used for verification will vary depending on the circumstances and the information that the customer provides to VouWallet.
The following documents, data, or information could be considered reliable and independent:
- government-issued or registered documents or data
- full bank and other investment statements
- full payslip or wage slip or other documents confirming salary
- inheritance (stamped grant of probate, stamped grant of letters of administration)
- audited financial accounts from a chartered accountant or Charities Services
- letter from an agent of the customer confirming they have knowledge of and established business relationships with the customer
- a copy of a will
- sales and purchase agreements
High-risk jurisdictions
- Countries-subject to OFAC sanctions
- Countries identified as supporting international terrorism
- Jurisdictions, determined to be of primary money laundering concern and subject to special measures
- Offshore financial centres
- Jurisdictions with deficiencies in combating money laundering and terrorist financing identified by FATF
VouWallet gives particular attention to, and exercises extra care in respect of:
- business relationships and transactions with persons (including legal persons and other financial institutions) from or in jurisdictions that do not or insufficiently apply the FATF Recommendations
- transactions and business connected with jurisdictions assessed as higher risk.
The Financial Action Task Force (“FATF”) has published a list of countries/jurisdictions classified as being “non-cooperative in the international fight against money laundering”. The list may be modified and updated as needed. The FATF list is kept current by the Compliance officer/MLRO.
In addition to ascertaining and documenting the business rationale for establishing a relationship, VouWallet takes reasonable measures to establish the source of funds of such customers.
In determining which jurisdictions do not apply, or insufficiently apply the FATF Recommendations, or may otherwise pose a higher risk, VouWallet considers, among other things:
- circulars issued by relevant authorities
- whether the jurisdiction is subject to sanctions, embargoes or similar measures issued by, for example, the United Nations (UN)
- whether the jurisdiction is identified by credible sources as lacking appropriate AML/CTF laws, regulations and other measures
- whether the jurisdiction is identified by credible sources as providing funding or support for terrorist activities and has designated terrorist organisations operating within it
- whether the jurisdiction is identified by credible sources as having significant levels of corruption, or other criminal activity
In addition to the FATF and FATF-style regional bodies, such sources may include, but are not limited to, supra- national or international bodies such as the International Monetary Fund, and the Egmont Group of Financial Intelligence Units, as well as relevant national government bodies and non-government organisations. The information provided by these credible sources does not have the effect of law or regulation and should not be viewed as an automatic determination that something is of higher risk. VouWallet will make a reference to publicly available information or relevant reports and data bases on corruption risk, e.g. Transparency International Corruption Perceptions Index.
SANCTIONS POLICIES
With a view to ensure that there are no payments to or from a person on a sanctions list issued by an overseas jurisdiction, VouWallet conducts screening against lists of FATF not-compliant countries, in addition to the lists of sanctioned countries, entities and persons.
VouWallet takes measures to thoroughly screen its customers and gather as much information as possible about them and their accounts. This helps to ensure that the customers are not involved in financial crimes.
Many transactions that are completed in order to send money to terrorist organisations are small and innocuous. Terrorist financiers purposefully do not send large amounts of money at once, as they wish to avoid the attention of both governments and financial institutions. Additionally, individuals who finance terrorism also use trade-based money laundering schemes in order to get their money across borders. This is becoming much more common, and it is a difficult problem to track down.
VouWallet takes measures to ensure compliance with the relevant regulations and legislation on terrorist financing. It is particularly vital that VouWallet is able to identify and report transactions with terrorist suspects and designated parties.
VouWallet maintains a database of names and particulars of terrorist suspects and designated parties which consolidates the various lists that have been made known to it. Alternatively, VouWallet makes arrangements to access to such a database maintained by third party service providers.
VouWallet screens customers and transactions against following lists:
- Consolidated United Nations Security Council Sanctions List
- OFAC Specially Designated Nationals And Blocked Persons List (SDN)
- Other OFAC sanctions lists
- EEAS-consolidated list of persons, groups and entities subject to EU financial sanctions
To avoid establishing business relationship or conducting transactions with any terrorist suspects and possible designated parties, VouWallet implements an effective screening mechanism, which includes:
- screening its customers and any beneficial owners of the customers against current database at the establishment of the relationship
- screening its customers and any beneficial owners of the customers against all new and any updated designations to the database as soon as practicable
- screening all relevant parties in a cross-border wire transfer against current database before executing the transfer
UNATMO is an ordinance to further implement a decision under UNSCR 1373 (2001) relating to measures for prevention of terrorist acts and a decision under UNSCR 2178 (2014) relating to the prevention of travel for the purpose of terrorist acts or terrorist training; as well as to implement certain terrorism-related multilateral conventions and certain FATF Recommendations. All UN member states are required to freeze any funds, or other financial assets, or economic resources of any person(s) named in these lists and to report any suspected name matches to the relevant authorities.
Where a person or property is designated by a Committee of the UNSC as a terrorist/terrorist associate or terrorist property respectively, the Chief Executive may publish a notice in the Gazette specifying the name of the person or the property. Besides, the Chief Executive may make an application to the Court of First Instance for an order to specify a person or property as a terrorist/terrorist associate or terrorist property respectively, and if the order is made, it will also be published in the Gazette.
A number of provisions in the UNATMO are of particular relevance to VouWallet, and are listed below:
- section 6 empowers the Secretary for Security (S for S) to freeze suspected terrorist property
- section 7 prohibits the provision or collection of property for use to commit terrorist acts
- section 8 prohibits any person from making available or collecting or soliciting property or financial (or related) services for terrorists and terrorist associates
- section 8A prohibits any person from dealing with any property knowing that, or being reckless as to whether, the property is specified terrorist property or property of a specified terrorist or terrorist associate
- section 11L prohibits any person from providing or collecting any property to finance the travel of a person between states with the intention or knowing that the travel will be for a specified purpose, i.e. the perpetration, planning or preparation of, or participation in, one or more terrorist acts (even if no terrorist act actually occurs); or the provision or receiving of training that is in connection with the perpetration, planning or preparation of, or participation in, one or more terrorist acts (even if no terrorist act actually occurs as a result of the training)
VouWallet, operating internationally, is aware of the scope and focus of relevant sanctions regimes in those jurisdictions. Where these sanctions regimes may affect its operations, VouWallet considers what implications exist for its procedures and takes appropriate measures, such as including relevant overseas designations in its database for screening purpose, where applicable.
OFAC Compliance
It is the policy of VouWallet to comply with all OFAC requirements and directives that restrict providing services, conducting business with, maintaining accounts for, or handling transactions or monetary transfers for foreign countries or foreign nationals listed on the Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals (SDNs) and Blocked Entities.
VouWallet shall not open a relationship for, handle a transaction or monetary transfer for, or do business with any person, government or other entity on the OFAC list of Specially Designated Nationals and Blocked Entities. Through screening and monitoring, the Company will identify such customers or transactions, and if it is found, contact OFAC immediately and all directives as to rejecting, restricting, blocking or seizing will be followed.
As per new relationship opening procedure, no new relationship will be established without passing through the steps indicated and obtain the necessary approvals. As part of the relationship opening procedure, the Compliance Department will check the names of all, business owners, and authorized signers against OFAC’s master list of "Specially Designated Nationals and Blocked Persons" (SDN list), and check the prospective customer’s geographical location for embargoed countries and cities by putting the information through the system prior to opening the relationship.
The system will check names against the OFAC list and prior to approving the relationship. The system checks the entered name for matching spelling, close matches, name variations and phonetically. If the name of the prospective customer is a match or possible match to a name in the OFAC list, the system will displays the potential match, and maintain an electronic record of such a match to be included in the documentation.
The Company’s staff is trained to recognize false positive matches and can continue with the transaction in the event a false positive match is displayed. The system will prompt the Compliance Staff to document the reason for the false positive, and will maintain that record in an electronic file. Any close matches that cannot be easily categorized as a false positive must be immediately brought to the attention of the Compliance Officer for validation.
Appendix. Prohibited Business Types
TECTRIX SERVICE DMCC, a company incorporated in Dubai, UAE, with registration number DMCC196324 and registered address at Unit No: BA1170 DMCC Business Centre, Level № 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
Public offer for the issuance and use of virtual cards
1. General provisions
This document is a public offer (hereinafter referred to as the "Offer") of TECTRIX SERVICE DMCC (hereinafter referred to as the "Offeror") and contains the terms and conditions for the issuance and use of a virtual card.
The Offer is addressed to an unlimited number of persons wishing to issue and use a virtual card (hereinafter referred to as the "User").
Acceptance of the terms of the Offer is carried out by submitting an application for the issuance of a virtual card and subsequent use of the card.
The card is intended exclusively for non-cash payments for goods and services and does not support cash withdrawals or transfers to other accounts.
The card is virtual and is linked to the payment systems specified by the User.
2. Subject of the offer
The Offeror provides the User with a virtual card for making non-cash payments within the established limits and restrictions.
The user has access to three categories of cards ( Air , Light and Speed ), the terms of issue and use of which you can find in the VouWallet mobile application.
The Offeror has the right to suspend or restrict the use of the card in the event of violation of the terms of this Offer or the law.
The Offeror shall not be liable for technical failures on the part of issuing banks, payment systems, and other third parties.
If the issued virtual card is not used within 90 calendar days from the date of the last successful transaction, the Offeror has the right to close the card on its own initiative. Upon card closure, the remaining funds (balance) are forfeited and cannot be restored or refunded.
If the User's account is not used (no login/authorization to the account/account) for 360 calendar days from the date of the last successful transaction, the account is subject to automatic deletion, in which case the virtual card is cancelled, and the remaining funds (balance) cannot be restored or returned.
3. Rights and responsibilities of the parties
The Offeror undertakes to: a) Ensure the issuance of the card after the User’s application has been approved; b) Ensure the processing of payments within the established terms and conditions; c) Inform the User of changes to the terms and conditions of use of the card.
The User undertakes to: a) Use the card only for lawful purposes and within the framework of this Offer; b) Not disclose card details to third parties; c) Comply with established limits and restrictions.
4. Restrictions and prohibited operations
It is prohibited to use the card for payment: a) Narcotics, tobacco products, weapons, money transfers, securities, some pharmaceutical products; b) Cryptocurrency exchanges, exchangers, casinos, forex platforms, binary options, dating sites (partially), the porn industry, webcam services; c) MCC categories 5816 (digital goods - games, including Steam , Microsoft Store, etc.); d) MCC categories 5411 (grocery stores and supermarkets) - with the exception of BIN-supported (Apple Pay or Google pay ); e) MCC Categories 5812 (Restaurants and Food Service Establishments) – excluding BIN-enabled (Apple Pay or Google Pay) pay ); f) Payments to government agencies of foreign states (taxes, fines, etc.).
The card cannot be used in Russia, Afghanistan, Belarus, Cuba, Iran, North Korea, Syria, Venezuela, Myanmar, Somalia, Ukraine, or Yemen.
5. Limits and rates
The virtual card has the following established limits: a) The maximum amount of a single transaction is USD 10,000; b) The total amount of transactions on the card may not exceed USD 2,000,000. If this limit is reached, the card must be reissued.
A chargeback (a procedure for disputing a bank card payment with which the User does not agree) is possible subject to the terms of the payment systems and is carried out for an additional fee of at least 30 US dollars, regardless of the outcome of the request.
There is no monthly fee for servicing the virtual card.
By accepting this Offer (including by completing the actions aimed at issuing and using the virtual card), the User confirms that they have read and agree to the fees specified on the application page (or website) prior to issuing the virtual card, including transaction fees, card issuance and closure fees, and the amount of the initial payment.
6. Liability of the parties
The Offeror shall not be liable for any unlawful actions of third parties in relation to the card.
The Offeror shall not be liable for the impossibility of carrying out a transaction due to reasons beyond its control.
In the event of a violation of the terms of the Offer by the User, the Offeror has the right to block the card without prior notice.
The offeror reserves the right to refuse to issue a card without explanation.
7. Dispute resolution procedure
All disputes shall be resolved through negotiations between the Offeror and the User.
If it is impossible to resolve the dispute out of court, it shall be referred to the court for consideration in accordance with the applicable legislation at the location (registration) of the Offeror.
8. Other conditions
The Offeror reserves the right to change the terms of the Offer unilaterally by notifying the User.
Use of the card constitutes full agreement with the terms of the Offer.
9. Contact information
Company Name: TECTRIX SERVICE DMCC
Registration number: DMCC196324
Registered address: Unit No: BA1170 DMCC Business Centre, Level No. 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
E - mail address: manager@tectrixservice.com
This document is a public offer (hereinafter referred to as the "Offer") of TECTRIX SERVICE DMCC (hereinafter referred to as the "Offeror") and contains the terms and conditions for the issuance and use of a virtual card.
The Offer is addressed to an unlimited number of persons wishing to issue and use a virtual card (hereinafter referred to as the "User").
Acceptance of the terms of the Offer is carried out by submitting an application for the issuance of a virtual card and subsequent use of the card.
The card is intended exclusively for non-cash payments for goods and services and does not support cash withdrawals or transfers to other accounts.
The card is virtual and is linked to the payment systems specified by the User.
2. Subject of the offer
The Offeror provides the User with a virtual card for making non-cash payments within the established limits and restrictions.
The user has access to three categories of cards ( Air , Light and Speed ), the terms of issue and use of which you can find in the VouWallet mobile application.
The Offeror has the right to suspend or restrict the use of the card in the event of violation of the terms of this Offer or the law.
The Offeror shall not be liable for technical failures on the part of issuing banks, payment systems, and other third parties.
If the issued virtual card is not used within 90 calendar days from the date of the last successful transaction, the Offeror has the right to close the card on its own initiative. Upon card closure, the remaining funds (balance) are forfeited and cannot be restored or refunded.
If the User's account is not used (no login/authorization to the account/account) for 360 calendar days from the date of the last successful transaction, the account is subject to automatic deletion, in which case the virtual card is cancelled, and the remaining funds (balance) cannot be restored or returned.
3. Rights and responsibilities of the parties
The Offeror undertakes to: a) Ensure the issuance of the card after the User’s application has been approved; b) Ensure the processing of payments within the established terms and conditions; c) Inform the User of changes to the terms and conditions of use of the card.
The User undertakes to: a) Use the card only for lawful purposes and within the framework of this Offer; b) Not disclose card details to third parties; c) Comply with established limits and restrictions.
4. Restrictions and prohibited operations
It is prohibited to use the card for payment: a) Narcotics, tobacco products, weapons, money transfers, securities, some pharmaceutical products; b) Cryptocurrency exchanges, exchangers, casinos, forex platforms, binary options, dating sites (partially), the porn industry, webcam services; c) MCC categories 5816 (digital goods - games, including Steam , Microsoft Store, etc.); d) MCC categories 5411 (grocery stores and supermarkets) - with the exception of BIN-supported (Apple Pay or Google pay ); e) MCC Categories 5812 (Restaurants and Food Service Establishments) – excluding BIN-enabled (Apple Pay or Google Pay) pay ); f) Payments to government agencies of foreign states (taxes, fines, etc.).
The card cannot be used in Russia, Afghanistan, Belarus, Cuba, Iran, North Korea, Syria, Venezuela, Myanmar, Somalia, Ukraine, or Yemen.
5. Limits and rates
The virtual card has the following established limits: a) The maximum amount of a single transaction is USD 10,000; b) The total amount of transactions on the card may not exceed USD 2,000,000. If this limit is reached, the card must be reissued.
A chargeback (a procedure for disputing a bank card payment with which the User does not agree) is possible subject to the terms of the payment systems and is carried out for an additional fee of at least 30 US dollars, regardless of the outcome of the request.
There is no monthly fee for servicing the virtual card.
By accepting this Offer (including by completing the actions aimed at issuing and using the virtual card), the User confirms that they have read and agree to the fees specified on the application page (or website) prior to issuing the virtual card, including transaction fees, card issuance and closure fees, and the amount of the initial payment.
6. Liability of the parties
The Offeror shall not be liable for any unlawful actions of third parties in relation to the card.
The Offeror shall not be liable for the impossibility of carrying out a transaction due to reasons beyond its control.
In the event of a violation of the terms of the Offer by the User, the Offeror has the right to block the card without prior notice.
The offeror reserves the right to refuse to issue a card without explanation.
7. Dispute resolution procedure
All disputes shall be resolved through negotiations between the Offeror and the User.
If it is impossible to resolve the dispute out of court, it shall be referred to the court for consideration in accordance with the applicable legislation at the location (registration) of the Offeror.
8. Other conditions
The Offeror reserves the right to change the terms of the Offer unilaterally by notifying the User.
Use of the card constitutes full agreement with the terms of the Offer.
9. Contact information
Company Name: TECTRIX SERVICE DMCC
Registration number: DMCC196324
Registered address: Unit No: BA1170 DMCC Business Centre, Level No. 1 Jewellery & Gemplex 3, Dubai, United Arab Emirates.
E - mail address: manager@tectrixservice.com
Public offer for participation in the "Refer a Friend" bonus program
TECTRIX SERVICE DMCC operates under the brand VouWallet. This Offer is addressed by TECTRIX SERVICE DMCC ("VouWallet," "Company," "we," "our") to an unlimited number of individuals ("User," "You," "Your") and constitutes a public offer within the meaning of applicable law.
This Offer is an appendix to the User Agreement and forms an integral part of it. Terms not defined in this Offer are used in the meaning established by the User Agreement. In the event of a discrepancy between this Offer and the User Agreement with respect to the Program, this Offer shall prevail.
This Offer governs the Company's "Refer a Friend" bonus program (the "Program").
1. Definitions
"VouCoin" means a conditional unit of internal accounting used by VouWallet, credited to a User for fulfilling the conditions of the Program. VouCoin is not electronic money, funds, a means of payment, cryptocurrency, a digital financial asset, a token, a security, or any other financial instrument; it is not issued using distributed ledger technology and does not circulate outside the VouWallet service.
"Personal Account" means the section of a User's account in the mobile application or on the VouWallet website that displays the status of participation in the Program and the VouCoin balance.
"Qualifying Transaction" means a successfully completed and non-reversed outgoing payment from a VouWallet Account to a third party — a transfer of funds or a payment for goods, works, or services — made within the limits established by the Company for the relevant payment method. The following do not constitute Qualifying Transactions: funding of the Account; transfers of funds to payment instruments belonging to the User themselves; transfers between Accounts of Related Persons; and transactions cancelled or reversed after completion.
"Referrer" means a VouWallet User who invites another person to use the Company's Services using a Referral Link or Promo Code.
"Referral" means an individual who has registered a VouWallet Account using a Referrer's Referral Link or Promo Code.
"Referral Link" and "Promo Code" mean unique identifiers generated by the Company in the Referrer's Personal Account, allowing a connection to be established between the Referrer and the Referral.
"Settlement Period" means the calendar month following the end of which the Company calculates the amounts accruable under the Program.
"Related Persons" means Users in respect of whom, according to the Company's record-keeping systems, indicators of transactions being in fact carried out by a single person or of common control have been established, including a match of device identifier, IP address, payment method, identity document, mobile phone number, or email address, or cohabitation of the participants, provided that transactions on the relevant Accounts are in fact carried out by a single person or under common control.
Threshold and calculation amounts stated in this Offer in Russian roubles, apply to transactions and values expressed in other currencies at their rouble equivalent, determined at the currency exchange rate applied by the Company as at the date of calculation of the relevant credit.
2. Subject of the Offer and Procedure for Acceptance
The Company credits Users with VouCoin for fulfilling the conditions of the Program in the manner established by Section 5.
The Program is incentive-based in nature and does not constitute a lottery, gambling, a public competition, or a financial pyramid scheme. Rewards under the Program are credited solely in respect of transactions actually carried out on Accounts and are conditional upon the persons introduced completing Qualifying Transactions. Participation in the Program is voluntary and free of charge.
A Referrer is not an agent, representative, or employee of the Company, does not act on its behalf, and has no right to create obligations for the Company toward third parties.
Acceptance of this Offer is deemed to occur upon the first, in chronological order, of the following actions: activation of participation in the Program in the Personal Account; registration of an Account using a Program link or promo code, a Referral Link, or a Promo Code; or the Referrer passing a Referral Link or Promo Code to a third party, as evidenced by that person's registration using it.
By performing any of the above actions, You confirm that You have read this Offer, the User Agreement, the Acceptable Use Policy, and the Privacy Policy, and accept them without reservation.
Participation in the Program does not create an obligation for the Company to open an Account for a specific person and does not limit the Company's rights under the User Agreement, including the right to refuse to open an Account, suspend transactions, or terminate the agreement.
3. Nature and Use of VouCoin
VouCoin does not represent a claim by the User against the Company for the payment of funds. VouCoin may not be withdrawn, exchanged for cash, transferred to another User, inherited, or assigned to third parties.
No interest accrues on VouCoin. VouCoin is not taken into account when calculating the Account balance and does not participate in debit or settlement transactions involving electronic money.
VouCoin may be used to reduce the Company's fees and to pay for the Company's Services. The list of Services and fees in respect of which VouCoin may be used, and the terms of such use, including the amount of VouCoin required to reduce a fee or pay for the relevant Service, are published on the Company's website, apply in the version in force at the time of use, and may be amended by the Company unilaterally from the moment of publication without prior notice.
Amendments to the terms of use of VouCoin apply from the moment of publication, including to VouCoin credited before the date of publication, and do not apply to uses of VouCoin completed before that date.
VouCoin is valid for 365 days from the date of crediting. Upon expiry, unused VouCoin is forfeited without compensation.
VouCoin credited to the User in different Settlement Periods is recorded in a single balance in the Personal Account and is spent in order from the earliest expiry date to the latest.
Upon closure of the Account or termination of the User Agreement for any reason, unused VouCoin is forfeited and is not subject to monetary compensation.
5. "Refer a Friend" Program
5.1. Eligibility
A Referrer may be a User who has reached the age of 18, holds an active VouWallet Account with a confirmed mobile phone number or email address, and has no restrictions on the Account imposed by the Company.
A Referral may be an individual who has reached the age of 18, has not previously held a VouWallet Account, and is not a Related Person in relation to the Referrer.
The residency requirements set out in Section 2 of the User Agreement apply to both participants. A Referrer may not charge Referrals any fee for providing a Referral Link or Promo Code.
5.2. Qualification Conditions for a Referral
A Referral is deemed qualified upon the sequential fulfillment of all of the following conditions:
The connection between a Referrer and a Referral is established at the moment the Referral's Account is registered and cannot subsequently be changed. If a Referral registered without using a Referral Link or Promo Code, the connection will not be assigned retroactively. Rewards are paid only for first-level referrals; invitations made by a Referrer's Referrals do not generate rewards.
5.3. Amount and Procedure for Crediting
The Referrer is credited 500 VouCoin for each qualified Referral. The current reward amount is published on the Company's website and in the Personal Account.
The reward is calculated following the end of the Settlement Period in which the Referral became qualified. The reward is credited within 5 business days of the end of that Settlement Period. The Company may extend this period to 15 business days when conducting a review under Section 6.
The maximum number of qualified Referrals for which a reward is credited is 50 per calendar month and 500 over the entire period of participation.
Crediting is reflected in the Personal Account. The Company does not disclose the Referral's personal data to the Referrer, except for the anonymized status of the invitation.
5.4. Reward Based on Referral Turnover
In addition to the reward under Section 5.3, the Referrer is credited a monthly reward calculated on the aggregate volume of Qualifying Transactions of their qualified Referrals during the Settlement Period. Qualifying Transactions completed by a Referral after the date on which they were deemed qualified are included in the calculation. Transactions completed before that date, including those that gave rise to qualification, are excluded from the calculation.
The amount of VouCoin credited is calculated on a progressive scale based on the aggregate volume of Qualifying Transactions expressed in Russian roubles, with the applicable rate applied to the portion of volume falling within each band: up to and including RUB 100,000 — 0.5%; above RUB 100,000 and up to and including RUB 1,000,000 — 0.75%; above RUB 1,000,000 — 1%. Amounts are stated in Russian roubles or the equivalent in another currency.
The calculated amount of VouCoin is rounded down to a whole number.
Crediting occurs within 5 business days of the end of the Settlement Period. The Company may extend this period to 15 business days when conducting a review under Section 6.
No reward is credited in respect of transactions cancelled or reversed after completion. Where a transaction is cancelled or reversed after the reward has been credited, the Company may debit the corresponding amount of VouCoin from the Referrer's balance and, if the balance is insufficient, reduce the next credits under the Program by the corresponding amount.
5.5. Rules for Distributing the Referral Link
The Referrer agrees not to use the Company's trademarks, logos, brand identity, or other intellectual property except in the form of official materials provided by the Company, and in a manner that does not create the impression that the Referrer is acting on behalf of the Company.
The Referrer is solely responsible for compliance with advertising and personal data laws when distributing the Referral Link and agrees to compensate the Company for any losses arising from a violation.
6. Restrictions, Verification, and Abuse
The Company may verify compliance with the conditions of the Program and the validity of credits, including through the use of data on devices, IP addresses, payment methods, and behavioral characteristics of accounts, in accordance with the Privacy Policy. Data from the Company's record-keeping systems constitutes proper and sufficient evidence of fulfillment or non-fulfillment of the Program's conditions.
Abuse includes, in particular:
If abuse is identified, the Company may, without prior notice, refuse to credit a reward, cancel previously credited VouCoin of the User and Related Persons, disable the Referral Link, exclude the User from the Program, suspend transactions on the Account, and terminate the User Agreement. Such a decision does not deprive the User of the right to contact Support in accordance with Section 10.
If VouCoin has been credited in error or on the basis of inaccurate data, the Company may debit the corresponding amount of VouCoin and, if insufficient, make a claim for reimbursement.
7. Personal Data and Taxes
The processing of personal data of Program participants is carried out in accordance with the Privacy Policy. By passing on a Referral Link to third parties, a Referrer does not transfer those persons' personal data to the Company; the Company receives a Referral's data directly from them at the time of registration.
A participant is solely responsible for determining, calculating, declaring, and paying any taxes and duties that may arise in connection with participation in the Program in the jurisdiction of their tax residence. The Company is not the participant's tax agent and does not provide tax advice.
8. Term, Amendment, and Termination of the Program
The "Refer a Friend" Program is valid indefinitely until terminated by the Company.
The Company may unilaterally amend the terms of the Program, the reward amount, limits, and deadlines, or terminate the Program, by giving notice on the Company's website and/or in the Personal Account no less than 10 calendar days before the changes take effect, unless a different period is required by law. Amendments to the list of Services and fees in respect of which VouCoin may be used, and to the terms of such use, are made in accordance with Section 3 of this Offer; the notice requirements of this Section do not apply to such amendments.
Changes do not apply to rewards for which the right to receive them arose before the changes took effect.
Continued participation in the Program after the changes take effect constitutes the User's agreement to the new version of the Offer.
A User's participation in the Program terminates upon termination of the Program or upon closure of the Account.
9. Liability
The Company does not guarantee the uninterrupted operation of the Program's interfaces and is not liable for the inability to fulfill its conditions caused by circumstances beyond its reasonable control, including actions of payment service providers and communication failures.
The Company is not liable for the relationship between a Referrer and a Referral.
The Company's liability is limited in the manner and to the extent established by the User Agreement.
10. Support, Governing Law, and Language
Inquiries regarding the Program should be directed to Support at support@vouwallet.io or via the Telegram bot @Wallet_Help_bot. The procedure for handling inquiries is established by the Complaints Handling Procedure.
This Offer and all relationships arising in connection with it are governed by the laws of Dubai, UAE. The competent courts of Dubai, UAE, have exclusive jurisdiction over disputes arising from this Offer.
The official language of interaction is English. Translations of this Offer into other languages are provided solely for the User's convenience; in the event of a discrepancy in interpretation, the English-language version shall prevail.
If any provision of this Offer is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
TECTRIX SERVICE DMCC, a company registered in Dubai, UAE, with registration number DMCC196324, located at Unit No: BA1170, DMCC Business Centre, Level No. 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates.
This Offer is an appendix to the User Agreement and forms an integral part of it. Terms not defined in this Offer are used in the meaning established by the User Agreement. In the event of a discrepancy between this Offer and the User Agreement with respect to the Program, this Offer shall prevail.
This Offer governs the Company's "Refer a Friend" bonus program (the "Program").
1. Definitions
"VouCoin" means a conditional unit of internal accounting used by VouWallet, credited to a User for fulfilling the conditions of the Program. VouCoin is not electronic money, funds, a means of payment, cryptocurrency, a digital financial asset, a token, a security, or any other financial instrument; it is not issued using distributed ledger technology and does not circulate outside the VouWallet service.
"Personal Account" means the section of a User's account in the mobile application or on the VouWallet website that displays the status of participation in the Program and the VouCoin balance.
"Qualifying Transaction" means a successfully completed and non-reversed outgoing payment from a VouWallet Account to a third party — a transfer of funds or a payment for goods, works, or services — made within the limits established by the Company for the relevant payment method. The following do not constitute Qualifying Transactions: funding of the Account; transfers of funds to payment instruments belonging to the User themselves; transfers between Accounts of Related Persons; and transactions cancelled or reversed after completion.
"Referrer" means a VouWallet User who invites another person to use the Company's Services using a Referral Link or Promo Code.
"Referral" means an individual who has registered a VouWallet Account using a Referrer's Referral Link or Promo Code.
"Referral Link" and "Promo Code" mean unique identifiers generated by the Company in the Referrer's Personal Account, allowing a connection to be established between the Referrer and the Referral.
"Settlement Period" means the calendar month following the end of which the Company calculates the amounts accruable under the Program.
"Related Persons" means Users in respect of whom, according to the Company's record-keeping systems, indicators of transactions being in fact carried out by a single person or of common control have been established, including a match of device identifier, IP address, payment method, identity document, mobile phone number, or email address, or cohabitation of the participants, provided that transactions on the relevant Accounts are in fact carried out by a single person or under common control.
Threshold and calculation amounts stated in this Offer in Russian roubles, apply to transactions and values expressed in other currencies at their rouble equivalent, determined at the currency exchange rate applied by the Company as at the date of calculation of the relevant credit.
2. Subject of the Offer and Procedure for Acceptance
The Company credits Users with VouCoin for fulfilling the conditions of the Program in the manner established by Section 5.
The Program is incentive-based in nature and does not constitute a lottery, gambling, a public competition, or a financial pyramid scheme. Rewards under the Program are credited solely in respect of transactions actually carried out on Accounts and are conditional upon the persons introduced completing Qualifying Transactions. Participation in the Program is voluntary and free of charge.
A Referrer is not an agent, representative, or employee of the Company, does not act on its behalf, and has no right to create obligations for the Company toward third parties.
Acceptance of this Offer is deemed to occur upon the first, in chronological order, of the following actions: activation of participation in the Program in the Personal Account; registration of an Account using a Program link or promo code, a Referral Link, or a Promo Code; or the Referrer passing a Referral Link or Promo Code to a third party, as evidenced by that person's registration using it.
By performing any of the above actions, You confirm that You have read this Offer, the User Agreement, the Acceptable Use Policy, and the Privacy Policy, and accept them without reservation.
Participation in the Program does not create an obligation for the Company to open an Account for a specific person and does not limit the Company's rights under the User Agreement, including the right to refuse to open an Account, suspend transactions, or terminate the agreement.
3. Nature and Use of VouCoin
VouCoin does not represent a claim by the User against the Company for the payment of funds. VouCoin may not be withdrawn, exchanged for cash, transferred to another User, inherited, or assigned to third parties.
No interest accrues on VouCoin. VouCoin is not taken into account when calculating the Account balance and does not participate in debit or settlement transactions involving electronic money.
VouCoin may be used to reduce the Company's fees and to pay for the Company's Services. The list of Services and fees in respect of which VouCoin may be used, and the terms of such use, including the amount of VouCoin required to reduce a fee or pay for the relevant Service, are published on the Company's website, apply in the version in force at the time of use, and may be amended by the Company unilaterally from the moment of publication without prior notice.
Amendments to the terms of use of VouCoin apply from the moment of publication, including to VouCoin credited before the date of publication, and do not apply to uses of VouCoin completed before that date.
VouCoin is valid for 365 days from the date of crediting. Upon expiry, unused VouCoin is forfeited without compensation.
VouCoin credited to the User in different Settlement Periods is recorded in a single balance in the Personal Account and is spent in order from the earliest expiry date to the latest.
Upon closure of the Account or termination of the User Agreement for any reason, unused VouCoin is forfeited and is not subject to monetary compensation.
5. "Refer a Friend" Program
5.1. Eligibility
A Referrer may be a User who has reached the age of 18, holds an active VouWallet Account with a confirmed mobile phone number or email address, and has no restrictions on the Account imposed by the Company.
A Referral may be an individual who has reached the age of 18, has not previously held a VouWallet Account, and is not a Related Person in relation to the Referrer.
The residency requirements set out in Section 2 of the User Agreement apply to both participants. A Referrer may not charge Referrals any fee for providing a Referral Link or Promo Code.
5.2. Qualification Conditions for a Referral
A Referral is deemed qualified upon the sequential fulfillment of all of the following conditions:
- registration of a VouWallet Account using the Referrer's Referral Link or Promo Code;
- confirmation of either a mobile phone number or an email address;
- completion of a first Qualifying Transaction of at least RUB 1,000 or the equivalent in another currency, within 48 hours of registration;
- completion of a second Qualifying Transaction of at least RUB 1,000 or the equivalent in another currency, between the 30th and 35th day after the first Qualifying Transaction.
The connection between a Referrer and a Referral is established at the moment the Referral's Account is registered and cannot subsequently be changed. If a Referral registered without using a Referral Link or Promo Code, the connection will not be assigned retroactively. Rewards are paid only for first-level referrals; invitations made by a Referrer's Referrals do not generate rewards.
5.3. Amount and Procedure for Crediting
The Referrer is credited 500 VouCoin for each qualified Referral. The current reward amount is published on the Company's website and in the Personal Account.
The reward is calculated following the end of the Settlement Period in which the Referral became qualified. The reward is credited within 5 business days of the end of that Settlement Period. The Company may extend this period to 15 business days when conducting a review under Section 6.
The maximum number of qualified Referrals for which a reward is credited is 50 per calendar month and 500 over the entire period of participation.
Crediting is reflected in the Personal Account. The Company does not disclose the Referral's personal data to the Referrer, except for the anonymized status of the invitation.
5.4. Reward Based on Referral Turnover
In addition to the reward under Section 5.3, the Referrer is credited a monthly reward calculated on the aggregate volume of Qualifying Transactions of their qualified Referrals during the Settlement Period. Qualifying Transactions completed by a Referral after the date on which they were deemed qualified are included in the calculation. Transactions completed before that date, including those that gave rise to qualification, are excluded from the calculation.
The amount of VouCoin credited is calculated on a progressive scale based on the aggregate volume of Qualifying Transactions expressed in Russian roubles, with the applicable rate applied to the portion of volume falling within each band: up to and including RUB 100,000 — 0.5%; above RUB 100,000 and up to and including RUB 1,000,000 — 0.75%; above RUB 1,000,000 — 1%. Amounts are stated in Russian roubles or the equivalent in another currency.
The calculated amount of VouCoin is rounded down to a whole number.
Crediting occurs within 5 business days of the end of the Settlement Period. The Company may extend this period to 15 business days when conducting a review under Section 6.
No reward is credited in respect of transactions cancelled or reversed after completion. Where a transaction is cancelled or reversed after the reward has been credited, the Company may debit the corresponding amount of VouCoin from the Referrer's balance and, if the balance is insufficient, reduce the next credits under the Program by the corresponding amount.
5.5. Rules for Distributing the Referral Link
The Referrer agrees not to use the Company's trademarks, logos, brand identity, or other intellectual property except in the form of official materials provided by the Company, and in a manner that does not create the impression that the Referrer is acting on behalf of the Company.
The Referrer is solely responsible for compliance with advertising and personal data laws when distributing the Referral Link and agrees to compensate the Company for any losses arising from a violation.
6. Restrictions, Verification, and Abuse
The Company may verify compliance with the conditions of the Program and the validity of credits, including through the use of data on devices, IP addresses, payment methods, and behavioral characteristics of accounts, in accordance with the Privacy Policy. Data from the Company's record-keeping systems constitutes proper and sufficient evidence of fulfillment or non-fulfillment of the Program's conditions.
Abuse includes, in particular:
- self-referral — a Referral registering themselves, as well as inviting Related Persons;
- creating multiple accounts by one person, registering using third parties' data, and providing false, forged, or third-party documents or payment methods;
- concealing connections between accounts, including the use of different devices, payment methods, phone numbers, or IP addresses in order to prevent the identification of indicators of Related Persons;
- using automated tools, emulators, or tools that conceal the technical characteristics of an internet connection;
- transactions with no economic substance carried out solely to fulfill the conditions of the Program, including subsequent cancellation or withdrawal of funds without genuine use of the service;
- inviting persons with no intention of using the Services, including in exchange for payment or other consideration;
- distributing the Referral Link in a manner that violates applicable law or platform rules: mass mailings, spam, search arbitrage on VouWallet brand queries, posting on resources with prohibited content, or using domains and designations confusingly similar to the Company's designations;
- posting the Referral Link together with claims of guaranteed income, investment returns, or other misleading statements made on the Company's behalf;
- using an Account for purposes classified as prohibited activity under the Acceptable Use Policy.
If abuse is identified, the Company may, without prior notice, refuse to credit a reward, cancel previously credited VouCoin of the User and Related Persons, disable the Referral Link, exclude the User from the Program, suspend transactions on the Account, and terminate the User Agreement. Such a decision does not deprive the User of the right to contact Support in accordance with Section 10.
If VouCoin has been credited in error or on the basis of inaccurate data, the Company may debit the corresponding amount of VouCoin and, if insufficient, make a claim for reimbursement.
7. Personal Data and Taxes
The processing of personal data of Program participants is carried out in accordance with the Privacy Policy. By passing on a Referral Link to third parties, a Referrer does not transfer those persons' personal data to the Company; the Company receives a Referral's data directly from them at the time of registration.
A participant is solely responsible for determining, calculating, declaring, and paying any taxes and duties that may arise in connection with participation in the Program in the jurisdiction of their tax residence. The Company is not the participant's tax agent and does not provide tax advice.
8. Term, Amendment, and Termination of the Program
The "Refer a Friend" Program is valid indefinitely until terminated by the Company.
The Company may unilaterally amend the terms of the Program, the reward amount, limits, and deadlines, or terminate the Program, by giving notice on the Company's website and/or in the Personal Account no less than 10 calendar days before the changes take effect, unless a different period is required by law. Amendments to the list of Services and fees in respect of which VouCoin may be used, and to the terms of such use, are made in accordance with Section 3 of this Offer; the notice requirements of this Section do not apply to such amendments.
Changes do not apply to rewards for which the right to receive them arose before the changes took effect.
Continued participation in the Program after the changes take effect constitutes the User's agreement to the new version of the Offer.
A User's participation in the Program terminates upon termination of the Program or upon closure of the Account.
9. Liability
The Company does not guarantee the uninterrupted operation of the Program's interfaces and is not liable for the inability to fulfill its conditions caused by circumstances beyond its reasonable control, including actions of payment service providers and communication failures.
The Company is not liable for the relationship between a Referrer and a Referral.
The Company's liability is limited in the manner and to the extent established by the User Agreement.
10. Support, Governing Law, and Language
Inquiries regarding the Program should be directed to Support at support@vouwallet.io or via the Telegram bot @Wallet_Help_bot. The procedure for handling inquiries is established by the Complaints Handling Procedure.
This Offer and all relationships arising in connection with it are governed by the laws of Dubai, UAE. The competent courts of Dubai, UAE, have exclusive jurisdiction over disputes arising from this Offer.
The official language of interaction is English. Translations of this Offer into other languages are provided solely for the User's convenience; in the event of a discrepancy in interpretation, the English-language version shall prevail.
If any provision of this Offer is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
TECTRIX SERVICE DMCC, a company registered in Dubai, UAE, with registration number DMCC196324, located at Unit No: BA1170, DMCC Business Centre, Level No. 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates.
