Terms of Service

1. Introduction

These Terms of Service (“Terms”) apply to your use of our card-to-card transfer services. By creating an account with us and using our services, you agree to comply with these Terms, which form a legal agreement between you, the user and Clarico Pay Ltd. Please read these Terms carefully before using our services. You can download or request a copy of these Terms at any time.

2. Who We Are

Clarico Pay Lt dis a payment services provider incorporated in the United Kingdom. We are registered with Companies House under registration number 07263512 and authorized by the Financial Conduct Authority (FCA) with registration number 527149.

3. Opening an Account

To access and use our services, you must first register and open an account with Clarico Pay Ltd. The registration process is designed to be simple, yet thorough, to ensure that we comply with legal requirements and provide you with a secure and efficient service.

Eligibility Requirements:

• You must be at least 18 years old to create an account.
• Our services are available to individuals residing in jurisdictions where we are authorised to operate. You must confirm your residency status during registration.
• Our accounts are intended for personal use only. You are not permitted to open an account for business purposes, or to conduct commercial transactions using our services.
• You are allowed only one active account with us at any given time. Multiple accounts for the same individual are not permitted and will be subject to closure.


Registration Process:

• During registration, you will be asked to provide personal information including your full name, date of birth, contact details (such as phone number and email address), and government-issued identification.
As part of our commitment to compliance with AML/CTF regulations, we will verify your identity using the information and documents you provide. This may include verifying your identity against official databases, conducting checks against sanctions lists, and using third-party verification services.
• To ensure the security and integrity of our platform, we may ask for information about the source of your funds, especially for higher-value transactions. This is part of our Enhanced Due Diligence (EDD) measures to prevent money laundering and other illicit activities.
• Before completing your registration, you must read and accept these Terms of Service and our Privacy Policy. 

Account Security:

• During the account setup process, you will be required to create a secure password. It is important that you choose a strong password and keep it confidential. We recommend using a combination of letters, numbers, and special characters to enhance security.
• You must ensure that the information you provide during registration is accurate and up-to-date. If there are any changes to your personal information, such as a change of address or contact details, you must update your account promptly.


Account Activation and Usage:

• Once your account has been successfully created and verified, you will receive a confirmation email. You will then be able to log in and start using our transfer services.
• Your account is for your personal use only. You must not allow others to use your account or share your login credentials with anyone. You are responsible for all activities that occur under your account, including any unauthorised transactions.
• We may review and monitor your account activity to ensure compliance with our Terms of Service and regulatory requirements. This includes monitoring for unusual or suspicious activities that may indicate potential security risks or misuse of our services.


Refusal and Termination of Accounts:

• We reserve the right to refuse the creation of an account if you do not meet the eligibility criteria, if the information provided is incomplete or inaccurate, or if we have reasons to believe that the account may be used for prohibited activities.
• We may terminate your account at any time if you breach these Terms of Service, provide false or misleading information, or engage in activities that violate our policies. We will notify you of such termination and, if applicable, provide instructions on how to withdraw any remaining funds.

4. Using Our Transfer Services

Our transfer service allows you to send money directly from your payment card to another individual quickly and securely. By using our service, you agree to follow the procedures and rules outlined in this section to ensure the smooth and lawful execution of transfers.

• To initiate a transfer, you need to provide the recipient’s card details accurately. It is your responsibility to ensure that all recipient information is correct, as incorrect details can result in delays, failed transfers, or funds being sent to the wrong recipient.
• You must specify the amount you wish to transfer. Please be aware of any minimum or maximum transfer limits that may apply. 
• Transfers can only be funded using a card that is registered in your name. We do not allow the use of third-party cards or anonymous funding sources to prevent fraud and comply with AML/CTF regulations.


Processing and Completion of Transfers:

• Once you initiate a transfer, we will validate the details provided and process the transaction. This includes checking for sufficient funds on the funding card and ensuring the transfer does not exceed any predefined limits.
• After successful validation, the funds will be deducted from your card and transferred to the recipient’s card. Transfer times may vary depending on factors such as the recipient’s card issuer and any intermediary processing times.
• Upon successful completion of the transfer, you will receive a confirmation notification. This will include details of the transfer, such as the amount sent, the recipient’s card details, and any applicable fees.


Fees and Exchange Rates:

• We charge a fee for each transfer, which will be clearly disclosed to you before you complete the transaction. The fee is deducted from the total amount of the transfer. You are responsible for reviewing the fee amount and ensuring you are comfortable with the charge before proceeding.
• If your transfer involves a currency conversion, we will apply our current exchange rate. The rate is based on prevailing market rates and may include a small margin.

Monitoring and Limits:

• For security and compliance reasons, we may impose daily, weekly, or monthly limits on the amount you can transfer. The limits are designed to prevent misuse and to comply with regulatory requirements. You will be informed of any applicable limits when you initiate a transfer.
• We continuously monitor transactions for signs of suspicious or unusual activity. This includes monitoring transfer patterns, recipient details, and the frequency of transactions. If a transfer is flagged for review, we may contact you for additional information or take further action as necessary.


Compliance with AML/CTF Regulations:

• As part of our compliance with regulations, we conduct due diligence on all transactions. This may include verifying the source of funds, assessing the risk of the transfer, and ensuring that the transaction does not involve sanctioned individuals or entities.
• In certain circumstances, we may require additional information or documentation from you to complete a transfer. This could include verifying the purpose of the transfer, providing additional identification, or explaining the relationship with the recipient.


Refusal and Cancellation of Transfers:

• We reserve the right to refuse to process a transfer if it violates our Terms of Service, is suspected to be fraudulent or illegal, or fails to comply with our policies. If a transfer is refused, we will notify you of the reason and, if appropriate, provide instructions on how to proceed.
• Once a transfer is initiated, it is generally not possible to cancel or reverse the transaction. Please ensure that all details are correct before confirming the transfer. In exceptional circumstances, if a transfer can be cancelled, any fees already deducted may not be refundable.


Your Responsibilities:

• You are responsible for providing accurate and complete information when initiating a transfer. Incorrect details can result in failed or misdirected transfers, for which we are not liable.
• You must use our services in accordance with all applicable laws and regulations. You are prohibited from using our services for illegal or fraudulent activities, including but not limited to money laundering, terrorism financing, or transferring funds for illicit purposes.
• If you encounter any issues with a transfer or suspect unauthorised activity on your account, you must notify us immediately. Prompt reporting helps us address and resolve any concerns quickly.

5. Prohibited Use

Our transfer services are designed to provide a secure and reliable platform for personal transactions. To maintain the integrity and security of our services, we strictly prohibit certain uses of our platform. By using our services, you agree to adhere to the following rules and understand that any violation may result in the suspension or termination of your account and potential legal action.

Prohibited Activities:

• You must not use our services for any illegal activities. This includes, but is not limited to:
  
  
  • Money laundering, terrorist financing, fraud, or any other activities that violate local, national, or international laws and regulations.
  • Engaging in human trafficking, exploitation, or any form of abuse.
  • Attempting to use our services to commit or facilitate acts of cybercrime, hacking, or unauthorised access to data or systems.
    
    
• Our transfer services are intended for personal use only. You are prohibited from using our platform for business or commercial purposes, such as:
  
  
  • Paying business partners, suppliers, or contractors.
  • Accepting payments for goods or services.
  • Engaging in affiliate marketing or contextual advertising.
  • Involvement in multi-level marketing (MLM) schemes or similar business opportunities.

    
    
• In compliance with our AML/CTF policy, we do not allow PEPs or individuals with known close associations to PEPs to use our services. If you are or become a PEP, you must inform us immediately, and we will review and, if necessary, close your account in accordance with our policies.
• You must not use our services to pay for or facilitate transactions involving the following goods and services:
   
  • Illegal substances and narcotic, including the sale or purchase of controlled substances, illegal drugs, or drug paraphernalia.
  • Weapons and ammunition, including firearms, ammunition, explosives, fireworks, and other related items.
  • Counterfeit and unauthorized Goods, such as counterfeit goods, pirated software, or unauthorized resale of luxury items.
  • Gambling and betting, including casinos, online gambling platforms, racetrack betting, lotteries, raffles, sweepstakes, or any other forms of unregulated gaming.
  • Adult content and services,  this includes adult entertainment services, pornography, escort services, online sex shops, and any other sexually explicit content.
  • Alcohol and tobacco, involvement in the production, sale, or purchase of alcohol and tobacco products, including bars, nightclubs, and other drinking establishments.
  • Financial services, unauthorsed financial services such as unlicensed money transmission, payday loans, and unregulated cryptocurrency trading or exchanges.
  • Cryptocurrency Firms, involvement with crypto-asset wallet providers, exchanges, or any related cryptocurrency activities, especially if unregulated.
  • Luxury and high-value goods, dealing with high-end watches, jewelry stores, precious metals, and stones, including unauthorized resale or dealing in diamonds and gemstones.
  • Other regulated or prohibited Items, including but not limited to CBD products, electronic cigarettes, nuclear industry activities, shell banks, company formation agents, and dietary supplements.
  • Pseudoscience services, such as clairvoyance, astrology, psychic readings, fortune-telling, and similar services.
  • Government and political activities, engaging in transactions involving government grants, public works contracts, political organizations, or shell companies.
  • Environmental and energy trading, including the trading of carbon credits or involvement in unregulated energy trading markets.

    
    
• You must not use our platform to engage in any form of deceptive or misleading activity. This includes:
  
  
  • Using false or stolen information to open an account.
  • Attempting to disguise the true nature or purpose of a transaction.
  • Impersonating another individual or entity.
  • Engaging in any form of scamming, phishing, or identity theft.

    
    
• Transfers must be funded using a card that is registered in your name. You are prohibited from using third-party cards or funding sources that do not belong to you. This rule is in place to prevent fraud and ensure the security of our services.
• You must not use our services to engage in high-risk activities that are subject to regulatory scrutiny or are not legally regulated in your jurisdiction. This includes activities such as:
  
  
  • Unlicensed money services or remittance businesses.
  • Investment schemes that do not comply with financial regulations.
  • Involvement with energy traders or scrap metal traders.


Consequences of Prohibited Use:

• If we determine that your account is being used for prohibited purposes, we may suspend or terminate your account without prior notice. This includes freezing any pending transactions and, if applicable, preventing further access to our services.
• In cases where prohibited use involves illegal activity or breaches of AML/CTF regulations, we are obligated to report the matter to the appropriate regulatory authorities. This may result in legal action, including but not limited to investigation by law enforcement agencies or regulatory bodies.
• You may be held liable for any losses or damages incurred as a result of your prohibited use of our services. This includes any costs associated with investigation, enforcement actions, or damages to our platform and reputation.

Your Responsibility:

•  It is your responsibility to ensure that you use our services in accordance with these Terms and all applicable laws and regulations. You should regularly review these Terms to stay informed of any updates or changes that may affect your use of our platform.
• If you become aware of any prohibited use or suspect that your account has been used for unauthorised purposes, you must notify us immediately. 
• By adhering to these guidelines and avoiding prohibited activities, you help us create a secure and compliant environment for all users. We take our responsibility to prevent misuse of our services seriously and appreciate your cooperation in maintaining the safety and integrity of our platform.

6. Times When Transfers May Be Refused or Delayed

We are committed to providing a reliable and efficient card-to-card transfer service. However, there are certain situations in which we may need to refuse or delay a transfer to ensure compliance with legal, regulatory, and security requirements. It is important to understand these circumstances to set appropriate expectations and avoid potential disruptions in your transfer experience.

Circumstances for Refusal or Delay:

• A transfer may be refused if the card you are using to fund the transfer does not have sufficient funds or credit available. Additionally, if there are issues with the funding card, such as it being expired, blocked, or reported lost or stolen, the transfer will be automatically declined.
• We impose daily, weekly, and monthly limits on the amount you can transfer for security and regulatory compliance reasons. If the transfer amount exceeds these limits, the transaction may be delayed for review or refused altogether. You will be notified if this occurs, and we may request additional information to proceed.
• Transfers require accurate recipient card details to be processed successfully. If the information you provide is incomplete, incorrect, or cannot be validated, we may refuse the transfer. Common issues include an invalid card number, incorrect recipient name, or expired recipient card.
• We are required to comply with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations, as well as other financial laws. As such, we may refuse or delay transfers if:
  
  
  • The transfer involves a high-risk jurisdiction or a sanctioned country.
  • The transaction appears to be linked to suspicious or prohibited activities.
  • The transfer is flagged for additional due diligence or Enhanced Due Diligence (EDD) review.
  • The recipient is identified as a Politically Exposed Person (PEP) or has ties to PEPs.

• Transfers may be delayed or refused due to technical issues such as system outages, network problems, or maintenance activities. Additionally, if our systems detect any potential security threats, such as unauthorised access, hacking attempts, or unusual transaction patterns, we may temporarily suspend transfer processing while we investigate and address the issue.
• To protect you and our platform from fraud, we actively monitor transactions for signs of fraudulent activity. If a transfer is identified as potentially fraudulent based on our risk assessment criteria, it may be delayed for further investigation. In some cases, we may require you to provide additional verification or documentation before proceeding with the transfer.
• We may be legally obligated to refuse or delay transfers due to court orders, legal disputes, or requests from regulatory or law enforcement authorities. This includes situations where:
  
  
  • There is an ongoing investigation into the source or purpose of the funds.
  • The transfer is associated with a frozen or embargoed account.
  • The transfer is subject to a legal hold or injunction.

Notification and Communication:

• If we refuse or delay a transfer, we will make every effort to notify you promptly, providing the reason for the delay or refusal if it is permissible under the law. In cases where additional information or documentation is required, we will contact you with instructions on how to proceed.
• Our customer support team is available to assist you in resolving any issues related to refused or delayed transfers. If the delay is due to a compliance or security review, please be patient as we work to ensure that your transfer meets all necessary requirements. Your cooperation in providing any requested information will help expedite the process.

Your Responsibilities:

• To minimise the risk of transfer refusal or delay, ensure that you provide complete and accurate information when initiating a transfer. Double-check the recipient’s card details, the transfer amount, and any other required information before submission.
• Familiarise yourself with the regulatory requirements, and prohibited activities outlined in these Terms of Service.
• If we contact you for additional information or verification, respond promptly and provide the requested details. This will assist us in resolving any issues and completing the transfer as quickly as possible.

Our Rights and Limitations:

• We reserve the right to refuse or delay any transfer that we deem to be in violation of our Terms of Service, suspicious, or non-compliant with legal and regulatory obligations. This includes the right to cancel or reverse transactions if necessary.
• While we strive to process transfers efficiently, we are not liable for any losses, damages, or inconveniences arising from refused or delayed transfers. This includes situations where delays occur due to compliance reviews, technical issues, or external factors beyond our control.

7.Keeping Your Account Secure

We employ a range of advanced security measures to protect your personal information and the integrity of our card-to-card transfer services. However, maintaining the security of your account is also a shared responsibility.

• We use industry-standard encryption protocols to protect your personal and financial information during transmission and storage. This ensures that any data exchanged between your device and our servers is encrypted and secure from unauthorised access.
• We continuously monitor account activity for signs of unusual or unauthorised access. This includes tracking login attempts, monitoring transaction patterns, and identifying any anomalies that may indicate potential security threats.
• Our platform uses fraud detection systems that analyse transaction data in real-time to detect and prevent fraudulent activities. 
• For added security, our system automatically logs you out after a period of inactivity. This helps prevent unauthorised access if you leave your device unattended.

To help us maintain the security of your account, you must take the following steps:

• Choose a unique and complex password for your account. It should be at least 8 characters long and include a combination of letters, numbers, and special characters. Avoid using easily guessed information such as your name, birthdate, or common words.
• Do not share your password, or any other account login information with anyone. We will never ask you for your password. Be cautious of phishing attempts or unsolicited communications asking for your account details.
• Change your password periodically and immediately if you suspect it has been compromised. 
• Ensure that the devices you use to access our services are secure. This includes:
  
  
  • Installing the latest software updates and security patches.
  • Using up-to-date antivirus and anti-malware software.
  • Avoiding the use of public or shared computers to access your account.
  • Setting up device locks, such as PINs or biometric authentication, to prevent unauthorised use of your device.
    
    
• Regularly review your account activity and transaction history for any unauthorised transactions or changes. If you notice any suspicious activity, report it to us immediately.

What to Do If You Suspect Unauthorised Access:

• If you suspect that your account has been compromised or if you notice any unauthorised transactions, contact our customer support team immediately. We will take swift action to secure your account, investigate the incident, and assist you in preventing further unauthorised access.
• If you believe your password has been compromised, change it immediately. Make sure to choose a new, unique password that is not similar to your previous passwords.
• Check your account security settings to ensure that no unauthorised changes have been made.

Our Rights and Limitations:

• In case of suspected unauthorised access or suspicious activity, we may temporarily lock your account to prevent further unauthorised use. You will be notified if this occurs and provided with instructions on how to regain access to your account.
• We will investigate any reports of unauthorised access or account compromise. As part of this investigation, we may request additional information from you to verify your identity and the legitimacy of the reported activity.
• While we implement security measures to protect your account, we are not liable for losses resulting from your failure to maintain the security of your account. This includes instances where unauthorised access occurred due to sharing your login information, using weak passwords, or failing to report suspicious activity in a timely manner.

8. Unauthorised or Incorrect Payments

While we strive to ensure that all payments are processed correctly and securely, there may be instances where an unauthorised or incorrect payment occurs.

• An unauthorised payment is any transaction made without your consent. This could occur if someone gains access to your account without your permission and initiates a transfer. Unauthorised payments can result from:
  
  
  • Compromised account credentials (e.g., stolen password).
  • Fraudulent activity or identity theft.
  • Use of your card information without your knowledge or consent.

• An incorrect payment occurs when a transaction is processed in error, either due to:
  
  
  • Incorrect details entered during the transfer (e.g., wrong recipient card number).
  • Errors on our part during the processing of the transfer, resulting in the wrong amount being sent or received.
  • Technical issues that lead to duplicate transactions or other discrepancies.

Your Responsibilities:

To help protect your account and ensure the accuracy of your transactions, it is important that you:

• Regularly monitor your transaction history for any unauthorised or incorrect payments.
• If you believe an unauthorised or incorrect payment has occurred, notify us immediately. The sooner we are informed, the quicker we can take action to investigate and resolve the issue.
• When reporting an unauthorised or incorrect payment, provide as much detail as possible, including:
  
  
  • The date and amount of the transaction.
  • The recipient card details.
  • Any relevant information or circumstances surrounding the transaction.

What to Expect When You Report an Issue:

• Upon receiving your report, we will initiate an investigation to determine whether the payment was unauthorised or incorrect. This process may involve reviewing transaction records, checking account access logs, and verifying with you any recent activity that may appear unusual.
• If we suspect that your account has been compromised, we may temporarily restrict access to your account or disable certain functions to prevent further unauthorised use. This is a precautionary measure to protect your funds while we investigate the matter.
• We aim to resolve issues related to unauthorised or incorrect payments as quickly as possible. The time it takes to complete the investigation may vary depending on the complexity of the case. We will keep you informed of the progress and any actions taken during the investigation.

Our Commitment to Resolving Unauthorised or Incorrect Payments:

• If we determine that a payment was unauthorised and you have taken reasonable steps to secure your account, we will refund the full amount of the unauthorised transaction, including any related fees or charges. The refund will be credited back to your account promptly following the completion of our investigation.
• In cases where an error on our part resulted in an incorrect payment, we will take steps to correct the error. This may involve reversing the transaction or crediting the correct amount to your account. You will be notified of the correction and any related actions taken.
• If an unauthorised payment occurs due to negligence on your part, such as sharing your account login details or failing to promptly report suspicious activity, you may be held partially or fully liable for the loss. Each case will be evaluated on an individual basis, taking into account the circumstances and your adherence to our security guidelines.

Situations Where Refunds May Not Be Granted:

• If you do not report an unauthorised or incorrect payment within a reasonable time frame, typically 13 months from the transaction date, we may not be able to provide a refund. 
• If we find evidence that you have intentionally authorised the payment, attempted to deceive us, or engaged in fraudulent activity, we reserve the right to deny a refund and take further action, including account suspension and reporting to regulatory authorities.

9. Communication and Notifications

We use various methods to keep you informed about your account, transactions, security updates, and any changes to our services. 

– Types of Communications:

• Every time you initiate a transaction or a transaction is completed, you will receive a notification confirming the details of the transfer. This includes information such as the transaction amount, recipient card details (in a masked format), and the date and time of the transaction.
• We take the security of your account seriously. If we detect any unusual or potentially unauthorised activity on your account, such as login attempts from unknown devices or locations, we will send you an immediate security alert. 
• From time to time, we may need to notify you about updates or maintenance activities related to your account or our platform. This includes:
  
  
  • Changes to your account settings or security features.
  • Scheduled maintenance that may affect the availability of our services.
  • Updates to our Terms of Service, Privacy Policy, or other important documents.

• To keep you informed about the latest features and improvements to our services, we may send you notifications about new functionalities, enhancements, or changes that may impact your use of the platform.
• With your consent, we may send you marketing and promotional communications about our services, special offers, and events. You have the option to opt out of these communications at any time if you prefer not to receive them.

Your Responsibilities:

• It is your responsibility to ensure that the contact information you provide to us, including your email address and phone number, is accurate and up-to-date. 
• :Regularly review the communications you receive from us. This includes checking your email and SMS messages. 
• If you receive a security alert regarding unusual account activity or an attempted login from an unrecognised device, take immediate action to review and secure your account. Follow the instructions provided in the alert to protect your account from unauthorised access.

Our Commitment to Your Privacy:

• We are committed to protecting your privacy and will never ask you for sensitive information, such as your password or card details, via email or text message. If you receive any suspicious communication claiming to be from us, do not respond or provide any personal information. Instead, contact us directly to verify the authenticity of the message.
•  We use secure communication channels to ensure the confidentiality and integrity of the information we send you. All emails and notifications are sent from official addresses and are designed to protect your personal information.

Contacting Us:

If you have any questions about the communications you receive, need to update your contact information, or wish to discuss your notification preferences, please contact our customer support team. We are here to assist you and ensure that you stay informed and engaged with all aspects of your account and our services.

10. Closing Your Account

There may come a time when you decide to close your account, or we may need to close your account under certain circumstances. This section outlines the process for closing your account, the conditions under which we may close your account, and the implications of account closure.

How to Close Your Account:

• You have the right to close your account at any time. To initiate the account closure process, you must submit a request through the following methods:
  
  
  • You can request to close your account through the account settings section of our platform. Follow the on-screen instructions to complete the account closure process.
  • Alternatively, you may contact our customer support team via email or phone to request account closure. For security reasons, we may ask you to verify your identity before processing the request.

• Once we receive your request to close the account, we will process it promptly. Before closing your account, we will:
  
  
  • Ensure that all pending transactions have been completed or canceled.
  • Verify that there are no outstanding fees, obligations, or compliance issues associated with your account.
  • Provide you with a final statement summarising your account activity and the closure details.

Outstanding Issues or Disputes:

• If there are any outstanding disputes or issues related to your account at the time of closure, we will work with you to resolve these matters. This may include addressing unauthorised transactions, processing refunds, or providing information to regulatory authorities.
• We are required to comply with all legal and regulatory obligations related to account closure. If your account is involved in an investigation or legal matter, we may retain access to certain information and may be required to provide information to relevant authorities.

11. Our Right to Make Changes

To ensure that our services remain secure, compliant, and aligned with industry standards, we may need to update or modify these Terms of Service from time to time. Types of Changes We May Make:

• Whenever possible, we will provide you with advance notice of any significant changes to the Terms of Service. This notice will include a summary of the changes being made and the date on which they will take effect. The notice period will vary depending on the nature of the changes, but we aim to give you at least 30 days’ notice for significant updates.
• We encourage you to carefully review any changes to the Terms of Service. Understanding the updates helps you stay informed about how our services operate and any new requirements or conditions that may apply to your use of the platform.
• By continuing to use our services after the changes take effect, you are agreeing to the updated Terms of Service. Your continued use indicates your acceptance of and compliance with the new terms, conditions, and policies.
• If you do not agree with the changes, you have the right to decline them by discontinuing your use of our services. You may contact our customer support team to discuss any concerns or to close your account if you choose not to accept the updated Terms.

• In certain situations, we may be required to implement changes to the Terms of Service immediately and without advance notice. This includes scenarios where changes are necessary to comply with urgent legal or regulatory requirements, address security vulnerabilities, or mitigate immediate risks to our platform or users. In such cases, we will notify you of the changes as soon as reasonably possible.

– We are committed to maintaining transparency and trust with our customers. Changes to the Terms of Service are made with careful consideration, keeping your best interests in mind while ensuring compliance with legal and regulatory obligations. Our goal is to provide you with a secure, reliable, and evolving service that adapts to the changing landscape of the financial industry.

Certainly! Here’s an expanded and detailed version of Section 12, focusing on how you can contact us, the support we offer, and the various ways to reach out for assistance or inquiries:

12. Contact Us

We are dedicated to providing exceptional customer support and ensuring that you have a positive experience while using our c services. Whether you have questions, need assistance, or wish to provide feedback, there are multiple ways you can contact us. This section outlines the various methods available for reaching out to us and the types of support we offer.

• – For general inquiries, account-related questions, or issues with transactions, you can contact our customer support team via email at support@clarico.finance. We strive to respond to all email inquiries promptly, typically within 24 hours, depending on the nature and complexity of the request. When contacting us by email, please include any relevant information, such as your account details or transaction reference number, to help us assist you more effectively.

Types of Support We Offer:

• Whether you need help with setting up your account, updating your personal information, or understanding your account settings, our support team is here to assist you. We can guide you through the process of making changes to your account or resolving any account-related issues you may encounter.
• If you have questions or concerns about a specific transaction, such as delays, incorrect payments, or fees, we can provide detailed explanations and work with you to resolve any issues. Our team is trained to handle inquiries related to transaction history, transfer status, and payment disputes.
• Your security is our top priority. If you suspect any unauthorised access or fraudulent activity on your account, contact us immediately. Our security team will investigate the matter, take necessary precautions to protect your account, and assist you in securing your information. We are committed to providing you with a safe and secure platform.
• We value your feedback and are always looking for ways to improve our services. If you have suggestions for new features, enhancements, or ways we can better meet your needs, please let us know..

Escalation and Complaint Resolution:

• If you feel that your inquiry or concern has not been adequately addressed through standard support channels, you can request to escalate the issue. Our support team will escalate your case to a higher level of management or a specialist team for further review and resolution.
• If you wish to file a formal complaint regarding our services or a specific transaction, you can do so by contacting us through any of the methods mentioned above. We take all complaints seriously and have a structured process in place to investigate and respond to complaints in a timely and fair manner. You will receive acknowledgment of your complaint and updates on the investigation’s progress.
• If you are not satisfied with the outcome of our internal complaint resolution process, you have the option to refer your complaint to an external dispute resolution body. We are committed to complying with all applicable regulations and will provide you with the necessary information to pursue external resolution if needed.

13. Governing Law and Jurisdiction

These Terms of Service, along with your use of our services, are governed by and construed in accordance with the laws of England and Wales. This legal framework applies regardless of your location or where you access our services, providing a consistent and reliable set of rules that protect both your interests and ours.

• While the Terms are governed by the laws of England and Wales, you are responsible for complying with any local laws and regulations that may apply to your use of our services in your jurisdiction. This includes, but is not limited to, regulations concerning financial transactions, anti-money laundering and counter-terrorist financing.
• By using our services, you agree that any disputes, claims, or controversies arising out of or relating to these Terms of Service or your use of our services will be subject to the exclusive jurisdiction of the courts of England and Wales. This means that any legal proceedings must be brought in a court located within this jurisdiction, providing a specific legal venue for resolving disputes.
• By agreeing to these Terms, you consent to the jurisdiction of the courts of England and Wales and waive any objection to the venue on the grounds of inconvenient forum or any similar grounds.

Dispute Resolution:

• In the event of a dispute or disagreement, we encourage you to contact our customer support team as your first step. Our goal is to resolve disputes amicably and efficiently through direct communication and negotiation. We are committed to working with you to understand your concerns and find a satisfactory resolution.
• If we are unable to resolve the dispute through initial efforts, either party may request that the matter be escalated to a higher level of management or consider mediation. Mediation is a voluntary and confidential process where a neutral third party assists both parties in reaching a mutually acceptable agreement. Participation in mediation is not mandatory but is often a helpful step in resolving complex disputes.
• If mediation or other informal dispute resolution efforts do not lead to a resolution, you or our Company may pursue formal legal action. Any such action must be filed in the courts of England and Wales, in accordance with the jurisdiction clause outlined above.

Limitations on Claims:

• Any claim or cause of action arising out of or related to these Terms of Service or your use of our services must be filed within one (1) year after such claim or cause of action arose. Failure to file a claim within this period will result in the claim being permanently barred. This limitation period is intended to encourage timely resolution of disputes and ensure that claims are addressed while evidence and witness memories are still fresh.
• Each dispute or claim will be resolved on an individual basis and will not be consolidated with other claims or handled on a class-action basis. This means that you may not seek to litigate or resolve disputes in a joint or collective manner.

Enforcement and Remedies:

• In addition to any other remedies available, we reserve the right to seek injunctive or equitable relief in the courts of England and Wales if you violate or threaten to violate any provision of these Terms of Service. This includes taking legal action to prevent unauthorised use of our services or to protect our intellectual property rights.
• In the event that we are required to take legal action to enforce these Terms of Service, we reserve the right to recover reasonable legal fees and costs incurred in connection with the action, to the extent permitted by law.

Severability and Interpretation:

• If any provision of these Terms of Service is found by a court of competent jurisdiction to be invalid, illegal, or unenforceable, that provision will be enforced to the maximum extent permissible, and the remaining provisions of these Terms will continue in full force and effec
• Any ambiguities in the interpretation of these Terms of Service shall not be construed against the drafting party. The headings used in these Terms are included for convenience only and will not limit or otherwise affect these Terms’ meaning or interpretation.

– By agreeing to these Terms of Service, you acknowledge that you have read, understood, and agree to be bound by the provisions relating to governing law and jurisdiction.

14. Whistleblower Policy

swe are committed to maintaining the highest standards of ethical conduct, compliance, and transparency, especially in areas related to Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). To support this commitment, we have established a Whistleblower Policy that encourages and protects individuals who report suspicious activities, violations, or unethical behavior related to our services.

The primary objective of this policy is to provide a secure and confidential channel for employees, customers, partners, and other stakeholders to report concerns regarding potential violations of laws, regulations, internal policies, or ethical standards. This includes, but is not limited to:

• Suspicious activities or transactions that may indicate money laundering, fraud, or terrorist financing.
• Breaches of AML/CTF policies and procedures.
• Any conduct that is illegal, unethical, or inconsistent with our commitment to compliance and integrity.

Who Can Report:

• All employees and contractors of our Company are encouraged to report any activities they suspect to be in violation of our AML/CTF policies, internal controls, or applicable laws and regulations.
• We also encourage our customers, partners, and third parties to report any suspicious activities or concerns they may have encountered while using our services.

What Can Be Reported:

• Any transaction or series of transactions that appear unusual, inconsistent with a customer’s known activities, or potentially related to illegal activities such as money laundering, terrorist financing, or fraud.
• Any actions that breach our AML/CTF policies, including failures in customer due diligence, failure to report suspicious activity, or non-compliance with transaction monitoring requirements.
• Any conduct by employees, contractors, or partners that is dishonest, illegal, or unethical, including conflicts of interest, corruption, or abuse of position.
• Any activities that compromise the security and confidentiality of customer data or violate our privacy policy.

How to Report a Concern:

• Confidential Reporting Channels: We offer multiple confidential channels for reporting concerns. Whistleblowers can choose the method that is most comfortable and secure for them:
  
  
  • Email: You can report concerns by sending an email support@clarico.finance. Please include as much detail as possible about the incident or behavior, including dates, individuals involved, and any supporting documentation.
    
    

• We are committed to creating an environment where individuals feel safe to report concerns without fear of retaliation. Any form of retaliation, discrimination, or harassment against individuals who report concerns in good faith is strictly prohibited. If you believe you have been retaliated against for reporting a concern, please notify us immediately so that we can take appropriate action.
• We treat all reports with the highest level of confidentiality. The identity of the whistleblower will be protected to the fullest extent possible, consistent with the need to conduct a thorough investigation and comply with legal obligations. Reports can be made anonymously if you prefer not to disclose your identity.
• While we encourage you to provide your contact information to facilitate the investigation process, we understand that anonymity may be important. Anonymous reports are accepted and will be investigated with the same level of diligence and seriousness as reports made openly.

Investigation and Response:

• All reports of suspicious activity or potential violations will be promptly and thoroughly investigated by our compliance team or an independent investigator, as appropriate. The scope and depth of the investigation will depend on the nature of the report and the evidence available.
• Upon completion of the investigation, appropriate action will be taken based on the findings. This may include disciplinary action, policy changes, reporting to regulatory authorities, or other measures as deemed necessary. Where possible and appropriate, we will provide feedback to the whistleblower regarding the outcome of the investigation.
• We are committed to complying with all legal and regulatory requirements related to whistleblowing. This includes cooperating with law enforcement and regulatory agencies in the investigation and prosecution of illegal activities uncovered through whistleblower reports.

15. Politically Exposed Persons (PEPs)

As part of our commitment to maintaining the highest standards of Anti-Money Laundering and Counter-Terrorist Financing compliance, we have established stringent policies and procedures for identifying and managing relationships with Politically Exposed Persons (PEPs). This section outlines what constitutes a PEP, the risks associated with PEPs, and the measures we take to mitigate those risks.

Understanding Politically Exposed Persons (PEPs):

• A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position, either domestically or internationally, and as a result, may be more susceptible to involvement in corruption, bribery, or other financial crimes. PEPs include, but are not limited to:
  
  
  • Heads of state, government ministers, or senior politicians.
  • Senior executives of state-owned enterprises.
  • High-ranking members of the judiciary, military, or law enforcement agencies.
  • Important political party officials.
  • Immediate family members or close associates of the above individuals.
    
    

• PEPs may pose a higher risk of involvement in activities such as money laundering, embezzlement, and corruption due to their potential influence, access to public funds, or connections to powerful networks. These risks necessitate enhanced due diligence (EDD) measures when establishing a business relationship with a PEP.

Our Policy on PEPs:

• We have a strict policy of not establishing or maintaining business relationships with PEPs or individuals who are closely associated with PEPs. This policy applies to all services offered by our platform.
• We employ screening procedures to identify PEPs during the customer onboarding process and on an ongoing basis. These procedures include:
  
  
  • Using reliable databases and screening tools to check customer information against global PEP lists.
  • Conducting risk assessments to identify any connections to PEPs among new and existing customers.
  • Regularly updating our PEP screening processes to incorporate the latest regulatory guidance and best practices.

Responsibilities and Actions Taken:

• If a customer is identified as a PEP during the account registration process or at any point during their relationship with us, we will take immediate action to decline any transactions and terminate the business relationship in accordance with our policy. Any funds associated with the account will be subject to a thorough review and, if necessary, reported to the appropriate regulatory authorities.
• We are committed to complying with all legal and regulatory requirements regarding PEPs. This includes:
  
  
  • Reporting any suspicious activities involving PEPs to the relevant financial intelligence unit or regulatory body.
  • Maintaining detailed records of all screenings, risk assessments, and actions taken in relation to PEPs for a minimum of five years.

Customer Obligations:

• Customers must cooperate with any requests for additional information or documentation related to PEP screening or due diligence. This may include providing details about the source of funds, the nature of the relationship with a PEP, or other relevant information.

16. Record-Keeping and Data Retention

In compliance with regulatory requirements and to ensure the integrity and security of our services, we maintain detailed records of all customer interactions, transactions, and due diligence activities.

Types of Records We Maintain:

• We retain copies of all documents and information obtained during the customer due diligence (CDD) and enhanced due diligence (EDD) processes. This includes identification documents (e.g., passports, driver’s licenses), proof of address, and any additional information collected to verify the customer’s identity.
•  Detailed records of all transactions conducted through our platform are maintained. This includes information such as transaction dates, amounts, recipient and sender details, and the purpose of the transaction.
• We keep records of all communications and correspondence with customers, including emails, chat logs, phone call records, 
• Records of risk assessments, transaction monitoring activities, and any investigations conducted as part of our AML/CTF compliance efforts are maintained. This includes documentation related to the identification of politically exposed persons (PEPs), unusual transaction patterns, and any actions taken in response to identified risks.

Data Retention Period:

• In accordance with regulations and other applicable laws, we retain records for a minimum period of five (5) years from the date of the transaction or the end of the customer relationship, whichever is later. This retention period allows us to provide accurate and complete information in the event of regulatory inquiries or investigations.
• In certain circumstances, we may be required to retain records for a longer period, such as when there is an ongoing investigation, legal proceedings, or a regulatory request. We will extend the retention period as necessary to comply with legal requirements or protect our interests.

Protection of Your Information:

• We take the security and confidentiality of your information seriously. All records are stored securely using industry-standard encryption and access controls to prevent unauthorised access, alteration, or disclosure.
• Access to records is strictly limited to authorized personnel who require the information to perform their duties. Our staff is trained on data protection best practices and is required to adhere to our internal security policies and procedures to ensure the confidentiality and integrity of customer information.
• We conduct regular audits and reviews of our record-keeping and data retention practices to ensure compliance with regulatory requirements and our internal policies
• Under data protection laws, you have the right to request access to the personal information we hold about you. You can make a request by contacting us. We will provide you with a copy of your information, subject to applicable legal restrictions and identification verification.
• If you believe that any information we hold about you is inaccurate or incomplete, you have the right to request a correction. We will review and update your records as needed to ensure accuracy and completeness.
• In certain circumstances, you may have the right to request the deletion of your personal information. However, please note that we may be required to retain certain records to comply with legal, regulatory, or contractual obligations, even after the termination of your account.

Destruction of Records:

• At the end of the retention period, or when records are no longer needed for regulatory compliance or business purposes, we will securely dispose of them.
• Our record destruction procedures are designed to ensure compliance with data protection laws and to safeguard your information throughout its lifecycle. We take great care to ensure that records are disposed of in a manner that protects your privacy and confidentiality.