SeamlessPay Acceptable Use Policy

This Acceptable Use Policy (“AUP”) governs use of Seamless Payments, Inc. & BCAP Holdings, LLC (“SeamlessPay,” “Processor,” “we,” “us,” or “our”) payment infrastructure platform, including payment orchestration, authentication services, tokenization services, fraud prevention tools, reporting systems, APIs, dashboards, documentation, and related technology (collectively, the “Services”).

This AUP forms part of the SeamlessPay Services Agreement. Capitalized terms not defined here have the meanings given in that Agreement.

SeamlessPay may update this AUP at any time to reflect regulatory requirements, Payment Network rules, risk management practices, or operational considerations. Continued use of the Services constitutes acceptance of updates.

1. Purpose of This Policy

Because SeamlessPay operates within regulated payment ecosystems involving Financial Institutions, Payment Networks, authentication providers, fraud vendors, and global regulatory frameworks, certain uses of the Services present unacceptable financial, legal, security, or reputational risks.

This AUP establishes restrictions designed to:

• Protect the integrity of the payment ecosystem;
• Prevent fraud, abuse, and illegal activity;
• Maintain compliance with regulatory and network obligations;
• Protect SeamlessPay, merchants, financial institutions, and consumers.

2. General Prohibited Conduct

You may not use the Services in a manner that:

• Violates applicable laws or regulations;
• Violates Payment Network rules or Financial Institution requirements;
• Facilitates fraud, money laundering, or deceptive practices;
• Interferes with security, performance, or integrity of the Services;
• Circumvents risk controls or authentication mechanisms;
• Attempts unauthorized access to systems or data;
• Causes reputational or regulatory risk to SeamlessPay or ecosystem partners.

SeamlessPay may determine violations at its reasonable discretion.

3. Prohibited Businesses and Activities

Unless expressly approved in writing by SeamlessPay, the Services may not be used in connection with:

Illegal or Regulated Activities

• Illegal goods or services;
• Unlicensed financial services;
• Sanctioned jurisdictions or individuals;
• Money laundering or terrorist financing;
• Controlled substances or illegal pharmaceuticals.

Fraud-Prone or High-Risk Activities

• Pyramid schemes or deceptive marketing;
• Unauthorized subscription billing;
• Excessive chargeback businesses;
• Identity theft or synthetic identity activity;
• Transaction laundering.

Harmful or Exploitative Activities

• Exploitation of minors;
• Human trafficking;
• Non-consensual adult content;
• Violence-promoting activities.

Restricted Financial Services
Without explicit approval:

• Cryptocurrency exchanges or wallets;
• High-risk lending or credit repair;
• Investment schemes;
• Payment aggregation without authorization.

Products Creating Excessive Network Risk
Examples include:

• Counterfeit goods;
• Unregulated supplements;
• Weapons or controlled equipment;
• Certain digital goods associated with fraud risk.

Designation as “high risk” does not guarantee approval.

4. Compliance and Verification Requirements

SeamlessPay may require:

• Business verification documentation;
• Compliance certifications;
• Transaction monitoring cooperation;
• Fraud mitigation controls;
• Enhanced due diligence.

Failure to cooperate may result in suspension.

5. Security and Platform Integrity

You may not:

• Reverse engineer or interfere with the Services;
• Introduce malicious code;
• Circumvent authentication mechanisms;
• Abuse APIs or system limits;
• Conduct security testing without authorization.

Security responsibilities are shared between Merchant and SeamlessPay.

6. Data Protection Obligations

You must:

• Comply with Data Protection Laws;
• Provide appropriate privacy disclosures;
• Secure customer data;
• Avoid unauthorized data collection or misuse.

SeamlessPay does not assume responsibility for Merchant data compliance.

7. High-Risk Designation and Monitoring

SeamlessPay may designate any Merchant as high risk based on:

• Transaction behavior;
• Fraud indicators;
• Chargeback levels;
• Regulatory exposure;
• Industry classification.

This designation may result in:

• Enhanced monitoring;
• Reserve requirements;
• Pricing adjustments;
• Suspension or termination.

8. Enforcement and Remedies

If SeamlessPay reasonably believes a violation has occurred, it may:

• Suspend or restrict Services;
• Terminate access immediately;
• Require corrective actions;
• Report activity to regulators or networks;
• Cooperate with law enforcement.

Notice may not be provided where risk mitigation requires immediate action.

9. No Guarantee of Approval

Compliance with this AUP does not guarantee:

• Continued access to Services;
• Approval by Payment Networks or Financial Institutions;
• Immunity from regulatory scrutiny.

Payment ecosystem participants retain independent authority.

10. Liability and Relationship to Services Agreement

This AUP does not expand SeamlessPay liability beyond the Services Agreement.

Violations may trigger:

• Indemnification obligations;
• Fee adjustments;
• Service suspension;
• Termination rights.

11. Questions or Reporting Concerns

Questions regarding this AUP or permitted uses should be directed to:

• Compliance@SeamlessPay.com