1. Purpose:

   1. This policy outlines the terms and conditions governing Your use of the Platform and its associated Services offered by Zayment Solutions Private Limited (‘Zayment’, ‘Us’, ‘Our’, ‘We’).

   2. This policy serves to inform all users (‘You’, ‘Your’, ‘User’) about their obligations under Applicable Law. This policy is a legally binding agreement between You and Zayment. We reserve the right to modify this policy without prior written notice, and Your continued use of the platform signifies your acceptance of any changes. Capitalised terms not explicitly defined within this policy will adopt the meanings established in our Terms of Service or Privacy Policy. If not defined therein, they will assume the meaning prescribed by Applicable Law.

2. Our obligations: We undertake the following for the prevention of financial crimes:

   1. Identity Verification: We will endeavour to verify the identity and address of Users and their beneficial owners during account creation or trading initiation, either directly or through third-party service providers.

   2. Technology Utilisation: We may deploy software, technology, or other means, directly or via service providers, to establish and verify Your identity and provided documents. Your consent to these identity verification and KYC checks is implied.

   3. Information Requests: We may request any legally and operationally permissible documents and data (including certified copies or e-documents) for KYC and user identification, as detailed in this policy. Discrepancies may necessitate requests for additional documents. All collected data will be used in accordance with this policy, Applicable Law, and our Privacy Policy.

   4. Service Restriction: Your failure to provide requested KYC or identification documents/ information may restrict or completely hinder Your use of the Platform and its associated Services.

   5. Financial Scrutiny: We reserve the right to request additional information to establish Your identity, financial position, sources of funds, and details of Cryptocurrency wallets involved in transfers. Non-compliance may lead to refusal of User Account creation, operation, or transaction execution.

   6. Data Management: User information will be maintained, preserved, and reported according to Our internal policies. Confidentiality, security, and protection against unauthorised access or disclosure of all User information will be maintained in accordance with Applicable Law.

   7. Information Sharing: We may share transaction or KYC information with governmental or regulatory authorities, including taxation authorities or judicial bodies, as required by Applicable Law.

   8. Sanctions under AML: If Your wallet is suspected of or linked to AML-related sanctions as provided in Our AML & CFT Policy, We reserve the right to return deposits and/or disallow withdrawals or further transfers to other wallets.

   9. Data Retention: Information obtained during User identification and due diligence, or relating to any attempted or executed transactions, will be retained for the duration the account is operational and for such further period as required by Applicable Law.

3. User Obligations: As a User of the Platform and its associated Services, You are obliged to:

   1. Provide Relevant Information: Timely provide all required documents and information for KYC checks to create and continue using Your account on the Platform. You must also provide any additional information and assistance required by Us for compliance with Applicable Law.

   2. Lawful Use: Use the Platform solely for lawful and legal purposes, in adherence to this Policy and Applicable Law.

   3. Prohibition of Illegal Activities: Absolutely refrain from using the Platform and its associated Services for any illegal, unlawful, criminal, or anti-national purposes, or for financing such activities, or for violating Applicable Law.

   4. Compliance with Policies: Not engage in any transactions that violate Applicable Law, this KYC Policy, or any other policy or instruction introduced by Us from time to time.

   5. Legitimate Funds: Ensure that funds transferred by You on or via the Platform originate from Your own bank account or exchange/unhosted wallets held in Your name and under Your control, and that they are derived through legitimate means in compliance with Applicable Law.

   6. Accuracy of Data: Represent, warrant, and agree to provide true, correct, complete, and updated KYC documents, information, and data to Us.

4. Customer Due Diligence (‘CDD’) Process:

   1. Eligibility and Access: Any Indian national resident can open an account on the Platform, which can only be accessed within the geographical territory and jurisdiction of India.

   2. KYC Process: In line with Applicable Law, We have implemented a three-tier Know-Your-Customer (KYC) system as part of our CDD process:

      1. Basic KYC: Required for all Platform Users. This involves two steps: entering their phone number and the OTP sent by Zayment, and submitting a government-issued valid identity card (Proof of Identity). We collaborate with third-party vendors to verify these details by comparing user-inputted data against relevant government databases.

      2. Full KYC: May be required based on monthly transaction volumes. This necessitates completing Basic KYC, undertaking a video KYC, and submitting documents verifying the source of funds.

   3. Required Documents for Individuals (Indian Nationals): Before Your account on the Platform can be made operational, the following documents are mandatory:

      1. Permanent Account Number (PAN) issued by Income Tax Authorities.

      2. Officially Valid Documents (OVDs) for identification and proof of residence (e.g., Aadhaar, Voter ID, Passport).

      3. Live picture captured via camera.

   4. Additional Information for Individuals: To establish a profile of expected activities, the following additional details will be collected:

      1. Annual Income

      2. Occupation.

      3. Declaration of whether the User is a Politically Exposed Person (PEP).

   5. Account Operationalisation and Verification: Post account opening, You must add and verify Your bank account/UPI ID for INR deposits/withdrawals. Your account on the Platform will only become operational once all required documents and information are verified to Our satisfaction. We maintain an audit trail for all data and documents shared by all Users.

   6. KYC is undertaken during the onboarding of new customers and will be verified by Our compliance team throughout a User’s engagement with the Platform. To maintain updated User information or as part of randomised checks, Users may be required to undergo any KYC process at any point, potentially needing to submit additional documents, such as income tax returns or bank account statements. All requested and collected information will be stored and processed according to our Privacy Policy.

   7. All submitted user identity documents must be in English. If a document is not in English, a translated version, duly notarised by authorised agencies, must be submitted. It should be noted that the KYC system deployed may vary based on Applicable Law and jurisdiction. As part of CDD, we implement measures to confirm the authenticity of user-submitted documents. We retain the right to investigate users deemed risky or suspicious, and to request up-to-date documents from users, even if they have previously passed identity verification. Such collected information will be processed and stored according to our Privacy Policy.

5. Enhanced Due Diligence (‘EDD’) Process: We undertake the following activities to ensure EDD is implemented:

   1. Frequent review of customers’ profiles and transactions.

   2. Collection of User information from available sources.

   3. Conducting independent enquiries on details provided by the User.

   4. Consulting credible databases.

   5. We are prohibited from transacting with individuals, companies, and countries listed on prescribed sanctions lists. We screen against lists issued by the United Nations, Financial Action Task Force, European Union, UK Treasury, and US Office of Foreign Assets Control (‘OFAC’) sanctions lists across all jurisdictions of our operation. If a User is found to facilitate suspicious transactions, We may file a report with the competent authority, maintaining strict confidentiality as per applicable rules and regulations. Further information on data collection, processing, and storage is available in our Privacy Policy.

   6. For foreign politically exposed persons, in addition to CDD measures, We ensure:

      1. Appropriate risk-management systems to identify if a customer is a politically exposed person.

      2. Senior management approval for establishing or continuing such business relationships.

      3. Reasonable measures to establish the source of wealth or source of funds.

      4. Enhanced ongoing monitoring of the business relationship.

6. Contact and Compliance Officer: Our Principal/ Compliance Officer can be reached at compliance@endl.app. 

For any complaints or queries regarding this Policy, or to report any suspicious or illegal activity known to You, please contact us at compliance@endl.app.