Acceptable Use Policy

1. Purpose

This Acceptable Use Policy ("Policy") defines the permitted and prohibited uses of all services, products, and application programming interfaces ("APIs") provided by Fintra Ltd ("fintrapay," "we," "us," or "our"), a company incorporated in Hong Kong. This Policy applies to all users, merchants, developers, and any other parties ("Users" or "you") who access or interact with fintrapay services in any capacity.

The objective of this Policy is to ensure the safe, lawful, and equitable use of fintrapay services for all participants. By accessing or using fintrapay services, you acknowledge that you have read, understood, and agree to comply with this Policy in its entirety. This Policy supplements and forms part of the fintrapay Terms of Service.

Violation of this Policy may result in immediate suspension or termination of your account, forfeiture of funds, and referral to the appropriate law enforcement or regulatory authorities.

2. Permitted Uses

fintrapay services are intended exclusively for lawful commercial and business purposes. The following activities represent permitted uses of the platform, provided that all such activities comply with applicable laws and regulations in your jurisdiction:

• Legitimate Business Payments — Accepting stablecoin payments from customers for goods and services in the ordinary course of business.
• Payroll and Contractor Payments — Disbursing wages, salaries, or contractor fees to employees or independent contractors via single or batch payout functionality.
• Invoice Settlement — Creating and settling invoices for business-to-business or business-to-consumer transactions using supported stablecoins.
• Treasury Management — Utilising the fintrapay Earn product to manage idle treasury balances and generate yield on deposited stablecoins, subject to the terms governing that product.
• E-Commerce Checkout — Integrating fintrapay as a payment method within online stores, marketplaces, or digital platforms to accept stablecoin payments at checkout.
• Business-to-Business Settlements — Conducting cross-border or domestic settlement of commercial obligations between business entities.
• API Integration for Payment Automation — Building automated payment workflows, recurring payment systems, or custom integrations using the fintrapay API in accordance with our API documentation and developer terms.

3. Prohibited Activities

You shall not use fintrapay services to facilitate, support, or engage in any of the following activities. This list is non-exhaustive, and fintrapay reserves the right to determine, at its sole discretion, whether any activity constitutes a violation of this Policy.

3.1 Illegal Goods and Services

The purchase, sale, distribution, or facilitation of illegal goods or services, including but not limited to controlled substances, narcotics, illegal drugs, weapons, firearms, ammunition, explosives, counterfeit goods, forged documents, stolen property, or any items whose possession, distribution, or sale is prohibited by applicable law.

3.2 Adult Content and Services

Processing payments for adult entertainment, pornographic materials, escort services, or any sexually explicit content or services.

3.3 Gambling and Betting

Processing payments for gambling, betting, lotteries, fantasy sports, or games of chance, unless the operator holds all licences required in its operating jurisdiction and has received prior written approval from fintrapay.

3.4 Money Laundering and Terrorist Financing

Using fintrapay services to launder the proceeds of criminal activity, to disguise the origin or destination of funds, or to finance terrorism or terrorist organisations. Users must not structure transactions in a manner designed to evade reporting thresholds or detection mechanisms.

3.5 Sanctions Evasion

Transacting with individuals, entities, or jurisdictions that are subject to economic or trade sanctions imposed by applicable governmental authorities, including but not limited to sanctions maintained by the United Nations, the European Union, the United States, the United Kingdom, or Hong Kong. Users must not use fintrapay services to circumvent, evade, or facilitate the evasion of any such sanctions.

3.6 Fraud, Phishing, and Identity Theft

Engaging in fraudulent activities of any kind, including but not limited to phishing, social engineering, impersonation, identity theft, creation of false or misleading accounts, submission of falsified verification documents, or any deceptive practice intended to obtain funds, information, or access unlawfully.

3.7 Ponzi Schemes, Pyramid Schemes, and Investment Fraud

Operating, promoting, or facilitating Ponzi schemes, pyramid schemes, multi-level marketing scams, high-yield investment programmes that promise unrealistic returns, or any other form of investment fraud or deceptive financial arrangement.

3.8 Ransomware Payments

Processing, facilitating, or collecting payments related to ransomware attacks, extortion demands, or any form of cyber-extortion.

3.9 Tax Evasion

Using fintrapay services to evade tax obligations in any jurisdiction, including but not limited to concealing taxable income, understating revenue, or structuring transactions to circumvent tax reporting requirements.

3.10 Unauthorized Securities and Derivatives Trading

Using fintrapay services to conduct, facilitate, or settle transactions involving unregistered securities offerings, unauthorised derivatives trading, or any financial instrument that requires regulatory authorisation that the User has not obtained.

3.11 Intellectual Property Infringement

Processing payments for goods or services that infringe upon the intellectual property rights of third parties, including counterfeit goods, pirated software, unauthorised reproductions of copyrighted material, or any items that violate trademark, patent, or copyright protections.

3.12 Jurisdictional Violations

Engaging in any activity through fintrapay services that violates the laws, regulations, or legal requirements of the jurisdiction in which the User operates, resides, or from which the User accesses fintrapay services. It is each User's sole responsibility to ensure compliance with all applicable local, national, and international laws.

4. Prohibited Technical Activities

In addition to the prohibited commercial activities outlined above, the following technical activities are strictly prohibited when using fintrapay services, infrastructure, or APIs:

• Unauthorized Access — Attempting to gain unauthorised access to fintrapay systems, accounts belonging to other Users, internal networks, databases, or any non-public infrastructure components through hacking, brute-force attacks, credential stuffing, or any other method.
• Denial of Service Attacks — Conducting, facilitating, or participating in distributed denial-of-service (DDoS) attacks, deliberate service disruption, resource exhaustion attacks, or any activity intended to degrade, impair, or render fintrapay services unavailable.
• Reverse Engineering — Decompiling, disassembling, reverse engineering, or otherwise attempting to derive the source code, algorithms, data structures, or underlying architecture of the fintrapay platform, API, smart contracts, or any associated software.
• Unauthorized Data Collection — Scraping, crawling, or conducting automated data collection from fintrapay services, APIs, or websites beyond what is explicitly permitted by the API terms of use and rate limits.
• Circumventing Security Measures — Attempting to bypass, circumvent, disable, or interfere with rate limits, authentication mechanisms, access controls, encryption, or any other security measures implemented by fintrapay.
• Sharing or Reselling API Access — Sharing API credentials, reselling access to fintrapay APIs, or allowing third parties to use your account or API keys without prior written authorisation from fintrapay.

5. Transaction Limits

fintrapay reserves the right to establish, modify, and enforce transaction limits at its sole discretion. These limits may apply to individual transactions, daily aggregate volumes, monthly aggregate volumes, or any other timeframe deemed appropriate.

• Transaction limits may vary based on your account verification level, transaction history, risk profile, and compliance status.
• Large transactions or transactions that exceed predefined thresholds may be subject to enhanced verification procedures, including additional identity verification, source of funds documentation, or manual review by our compliance team.
• Batch payout operations are subject to per-batch and per-recipient limits, which may differ from individual transaction limits.
• fintrapay may temporarily reduce or suspend transaction limits for specific accounts or across the platform in response to security concerns, system maintenance, or regulatory requirements.
• Attempts to circumvent transaction limits by structuring transactions, using multiple accounts, or any other means constitute a violation of this Policy.

6. Restricted Industries

Certain industries and business categories are subject to additional review, enhanced due diligence, and ongoing monitoring before and during their use of fintrapay services. Operating within a restricted industry does not automatically preclude you from using fintrapay, but approval is subject to satisfactory completion of our enhanced review process. Restricted industries include but are not limited to:

• Cryptocurrency Exchanges and OTC Desks — Entities operating cryptocurrency exchanges, over-the-counter trading desks, or similar platforms that facilitate the exchange of digital assets.
• Money Service Businesses — Entities providing money transmission, foreign exchange, remittance services, or other financial services that may require specific licensing in their operating jurisdictions.
• Precious Metals Dealers — Businesses engaged in the purchase, sale, or trade of gold, silver, platinum, gemstones, or other precious metals and stones.
• High-Value Goods Dealers — Merchants dealing in luxury goods, fine art, antiques, collectibles, or any goods with a high individual transaction value that may present elevated risk for money laundering or fraud.

If your business falls within a restricted industry, you must disclose this during the registration and verification process. Failure to disclose your industry classification may result in immediate account termination.

7. Enforcement

fintrapay employs a combination of automated systems and manual review processes to monitor platform activity and detect potential violations of this Policy. Our enforcement measures include but are not limited to:

• Transaction Monitoring — Continuous monitoring of transaction patterns, volumes, and counterparties to identify suspicious activity, unusual behaviour, or potential policy violations.
• Account Suspension — fintrapay reserves the right to immediately suspend or restrict account functionality pending investigation of suspected violations, without prior notice where circumstances require.
• Account Termination — Confirmed violations may result in permanent termination of your account and revocation of access to all fintrapay services.
• Reporting to Authorities — Where required by law or where fintrapay determines it is appropriate, we will report suspected violations to the relevant law enforcement agencies, regulatory bodies, or financial intelligence units.
• Fund Freezing — In cases involving suspected illegal activity, fraud, or sanctions violations, fintrapay may freeze funds held in custodial accounts pending the outcome of an investigation or as directed by law enforcement or judicial authorities.

8. Reporting Violations

fintrapay encourages all Users and members of the public to report suspected violations of this Policy. If you become aware of any activity that may contravene this Policy, we urge you to report it promptly.

• Reports may be submitted by email to support@fintrapay.io. Please include as much detail as possible, including relevant transaction identifiers, account information, dates, and a description of the suspected violation.
• All reports will be reviewed by our compliance team and treated with the utmost confidentiality.
• fintrapay prohibits retaliation against any individual who reports a suspected violation in good faith. Whistleblowers are protected under this Policy, and any attempt to intimidate, threaten, or retaliate against a reporting individual will itself be treated as a serious violation.

9. Consequences

Violations of this Policy may result in one or more of the following actions, applied at the sole discretion of fintrapay and proportionate to the severity and nature of the violation:

• Formal Warning — A written notice identifying the violation and requiring immediate corrective action. Minor or first-time infractions may be addressed through a warning, subject to compliance within a specified timeframe.
• Temporary Suspension — Partial or full suspension of account functionality for a defined period. During suspension, you may be unable to initiate transactions, access API services, or withdraw funds.
• Permanent Termination — Irrevocable closure of your account and permanent revocation of access to all fintrapay services. Terminated Users may be prohibited from creating new accounts.
• Fund Freezing — Funds held in custodial accounts may be frozen pending investigation, legal proceedings, or as required by regulatory or law enforcement directives. Frozen funds will be released only upon satisfactory resolution of the matter.
• Reporting to Law Enforcement — Serious violations, including those involving suspected criminal activity, will be reported to the appropriate law enforcement agencies and regulatory authorities, accompanied by all relevant transaction data and account information.

fintrapay may apply multiple consequences simultaneously. The application of one consequence does not preclude the application of others. fintrapay reserves the right to take any additional action necessary to protect the platform, its Users, and the integrity of its services.

10. Appeals

If you believe that an enforcement action has been taken against your account in error, you have the right to appeal. The appeals process is as follows:

• Appeals must be submitted in writing to support@fintrapay.io within thirty (30) calendar days of the date on which you were notified of the enforcement action.
• Your appeal must include your account identifier, a clear description of the enforcement action you are contesting, and any supporting evidence or documentation that you believe demonstrates that the action was taken in error.
• Appeals will be reviewed by the fintrapay compliance team. The review will be conducted by personnel who were not involved in the original enforcement decision to ensure impartiality.
• fintrapay will endeavour to respond to all appeals within fifteen (15) business days of receipt. Complex cases may require additional time, in which case you will be notified of the expected timeline.
• The outcome of the appeal review will be communicated to you in writing. The decision of the compliance review team is final and binding.

11. Updates to This Policy

fintrapay reserves the right to modify, amend, or replace this Policy at any time and at its sole discretion. We may update this Policy to reflect changes in our services, operational practices, legal requirements, or industry standards.

Where we make material changes to this Policy, we will provide notice through one or more of the following channels: email notification to registered account holders, a prominent notice on the fintrapay website, or an in-dashboard notification. The "Last updated" date at the top of this Policy will be revised to reflect the date of the most recent amendment.

Your continued use of fintrapay services following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you must cease using fintrapay services and close your account.

12. Contact

If you have any questions, concerns, or requests regarding this Acceptable Use Policy, please contact us: