This Transaction and User Verification Policy ("T&U Policy") is testimony to the Company’s commitment to maintaining a clean system and preventing use of CRED services for illegal activities. It describes the Company's policies and procedures instituted to ensure that the Services offered by the Company are not being used by the Users to facilitate commission of any criminal offences, including but not limited to those under any applicable money laundering laws together with the rules issued thereunder and the rules and regulations prescribed by the regulators. The Company has prepared this T&U Policy to ensure the transparency of trading and to ensure the prevention of money laundering and other illegal activities.

The terms "We", "Our", "Company" and "Us" refer to the Company, and the terms "User", "You" and "Your" refer to a User of our Online Platforms.

This T&U Policy applies uniformly to any User desirous of availing the Services or otherwise using or benefitting from the use of the Online Platforms and may be read as a part of the User Terms and Conditions. It is imperative that you read this T&U Policy before using the Online Platforms or submitting any personal information. By using the Online Platforms, you are expressly consenting to be bound by the User Terms and Conditions and consequently this T&U Policy.

The Company may change and update this T&U Policy from time to time. Such changes may be made without prior notice, but any changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review this T&U Policy whenever you access the Online Platforms.

1. YOUR OBLIGATIONS

• You acknowledge that it is your duty to ensure compliance with the terms and conditions described in this T&U Policy and accord your consent to not using the Services and the Online Platforms in any manner which results in committing/attempting to commit any criminal offences. You also agree and consent to any changes made to this Privacy Policy in due course and without notice.
• You must ensure that any personal information and/or Identification Documents submitted by you belong to you.
• In case you are acting on behalf of a juridical person, you must identify the Beneficial Owner and also assist in verification of the identity of such Beneficial Owner and any individual who purports to act on behalf of such juridical person.

2. PURPOSE OF THE POLICY

In order to mitigate its risks relating to money laundering and other illegal activities, the Company intends to put in place this policy which has the following elements:

1. - Customer Acceptance Terms; and
2. - Customer Verification Procedure; and
3. - Transaction Monitoring Terms.

3. CUSTOMER ACCEPTANCE TERMS

• The Company may either at the time of opening the User Account, or while undertaking any transactions, or during Periodic Updates, or for any other reason, ensure your compliance with the following:
  1. Require that you undergo a verification process during the activation process of your User Account by submitting your Identification Documents and such other details, as mandated under Clause 4 (Customer Verification Procedure) of this T&U Policy.
  2. Require you to furnish such other details as may be deemed necessary by the Company to verify your identity.
  3. Require you to submit such additional information and/or data as may be directed by a competent enforcement authority.
  4. Require you to certify that your Linked Bank Account is held only with a scheduled commercial bank compliant with all Know Your Customer (KYC) procedures mandated under the applicable laws.
• The Company may, in its sole discretion, refuse to open any new accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Online Platforms if it is unable to ensure compliance with any of the aforementioned conditions, either due to non- cooperation by the User or due to the details provided by the User being unreliable or unverifiable to the Company’s satisfaction.

4. CUSTOMER VERIFICATION PROCEDURE

• The Company, during activation of User Accounts or while undertaking any transactions or for any other reason, may require for the purposes of verification of any User’s identity – one copy of any Identification Document containing their identity and address details; one recent photograph; any other documents pertaining to business/financial status of such individual as may be prescribed by the Company from time to time.
• For the purposes of verification of any User’s identity, the Company may rely on appropriate and licensed third-party service providers (such as Credit Bureaus) to authenticate the Identification Documents and other incidental details provided by the User.
• If the Company finds any User information obtained in accordance with the procedure described under this Clause to be inadequate or insufficient, the Company may in its discretion either refuse or terminate (as the case may be) the registration of such User Account or require verification of such User’s Identification Documents again.

5. TRANSACTION MONITORING TERMS

• All transactions executed and/or attempted to be executed through the CRED App are regularly monitored by the Company, in order to promptly identify and highlight certain kinds of transactions which are deemed suspicious by the Company.
• The Company may, from time to time, undertake necessary investigation in order to identify and examine transactions inconsistent with any User’s risk profile, sophistication, and expected usage pattern.
• The extent of monitoring shall depend on various factors including upon each User’s risk profile.
• In case the Company requires, it can take any of the following steps to regulate the use of the CRED App by any User:
  1. Negative Name Checks: Name checks to ensure that the user doesn’t transfer the funds to his own account.
  2. PAN Check: For each transaction, Company may require the user to enter the PAN Card of the person to whom the payment is being made.
  3. Block payments to CC accounts to avoid balance transfer(s) for a user between different Credit Cards.
  4. The Company may also put transaction limits meaning each account may have a limit on the total number of transactions and/or the size of the transaction. These limits may be finalised on a per transaction basis as well as a monthly basis.
  5. In addition to the above, Company may also limit the total number of recipients per user.

6. MAINTENANCE OF RECORDS

The Company will maintain and preserve the following information and/or data:

• Records of all such suspicious transactions executed through the CRED App, for a period of at least 5 (Five) years from the date of each transaction.
• Records of all and any suspicious transactions identified under Clause 5 (Transaction Monitoring Terms) above for a period of at least 5 (Five) years, including but not limited to the information about the nature, value and parties to such transactions, and their date of remittance.
• Identification records of Users, during the subsistence of and for a period of at least 7 (Seven) years from the date of termination of such User Account.