Terms of Service and Privacy Policy
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The “Terms of Service” (TOS) and “Privacy Policy” (PP) are agreements that a user needs to accept during registration via the SMP platform. The TOS specifies the terms and conditions based on which SMP shall provide the service to the user and also the terms under which the user may use the service. Similarly, the Privacy policy contains details on the information collected by the platform from the user and how the company will be using such data during the course of the usage of service by the user.
The format and content of the TOS and PP shall be governed by the FI Partners along with the placement of these documents for the user to view and accept so as to make the user aware of such terms and conditions of the service. The following sections discuss the requirements relating to the content and placement of the TOS and PP.
The terms and conditions of the sections of the platform concerning the provision of money transfer services shall be governed by the FI Partner. The Terms of Service and Privacy Policy for Golden Money Transfer is accessible with the following links:
Golden Money Transfer:
Any Terms or Service or Privacy Policy of the SMP shall not be part of or govern the use of services.
Therefore, SMP may place its own Terms of Service and Privacy in sections like the Landing Page of the website/mobile app where there is no mention of the services, however, the website should present only the Terms of Service and Privacy Policy of the FI Partners in all sections of the website/mobile app concerning the services. Moreover, such Terms of Service and Privacy Policy of SMP shall not provide any terms related to the services and shall refer to the Terms of Service and Policy of the FI Partners for all matters relating to the services.
The access and location of the TOS and PP are the same for both website and mobile app. The location of the TOS and PP will be as follows:
The landing page may have the TOS and PP of SMP. The TOS and PP published in this location could be a simple disclaimer for using the services. The TOS and PP of the SMP shall be reviewed and approved by Machnet’s compliance team. The links to the TOS and PP of the FI Partners should be given in the TOS and PP hosted by SMP.
SMP shall place the TOS and PP of the FI Partners in the sign-up section as a part of the disclaimer for the service provided. This is covered by section 3.1 and 3.2 above in this document.
The TOS and PP of the FI Partners will be used in following locations:
KYC Step 1 (this is handled in case of KYC widgets. SMP shall be required to adhere to this in case they are utilizing API for the KYC)
Transaction authorization
While the users will have to agree to the FI Partners’ TOS and PP at the time of sign-up and KYC step 1, the user should have access to the TOS and PP from the link provided in the authorization text while creating a new transaction as well.