{"data":[{"id":6,"attributes":{"title":"Terms of service","createdAt":"2023-03-26T19:28:28.243Z","updatedAt":"2026-10-02T06:34:04.935Z","publishedAt":"2026-10-02T06:34:04.930Z","slug":"tos","position":1,"tosType":null,"content":[{"id":1,"__component":"ui.list","type":null,"title":"Preambule","isolated":null,"item":[{"id":1,"content":"1.1 These Terms of Service (the “Terms”) set out the principal provisions governing the use of the PSTNET platform (the “System”) operated by ADV Summit Advisors Limited, a company incorporated in the Turks and Caicos Islands with its registered office at Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands (the “Administrator”, “PSTNET”, “we”, “us” or “our”), and the relationship between the Administrator and each person who registers an Account and uses the System (the “Customer” or “you”).","parentId":null},{"id":3,"content":"1.2 These Terms constitute the Administrator’s public offer addressed to eligible individuals and eligible legal entities regarding the opportunity to use the System and the System Services. By clicking the “Register” (or equivalent) button during the Registration process, or by otherwise accessing or using the System, the Customer accepts these Terms in full and enters into a binding agreement with the Administrator on the basis set out herein.","parentId":null},{"id":4,"content":"1.3 Matters not expressly regulated by these Terms are addressed in the Administrator’s Internal Policies, each of which is published on the Website and forms an integral part of these Terms. The Internal Policies currently comprise: <a href =\"https://pst.net/legal/aml\" target=\"blank\">the AML Policy</a> ; <a href =\"https://pst.net/legal/privacy\" target=\"blank\">the Privacy Policy</a> ; <a href =\"https://pst.net/legal/cookie\" target=\"blank\">the Cookie Policy</a>; <a href =\"https://pst.net/legal/affiliate\" target=\"blank\">the Affiliate Program Terms and Conditions</a> (applicable to Customers participating in the Administrator’s referral or affiliate program); and the Restrictions (being the section of the Website setting out Restricted Countries, restricted merchants, supported and restricted Merchant Category Codes, and transactional limits and restrictions). The Administrator may publish additional Internal Policies on the Website from time to time, which shall form part of these Terms upon publication. In the event of any conflict between these Terms and an Internal Policy, these Terms prevail unless the relevant Internal Policy expressly states otherwise.","parentId":null},{"id":6,"content":"1.4 IMPORTANT NOTICE ON REGULATORY STATUS. THE ADMINISTRATOR IS A TECHNOLOGY AND INFRASTRUCTURE PROVIDER. THE ADMINISTRATOR IS NOT A BANK, A CREDIT INSTITUTION, A MONEY TRANSMITTER UNDER THE MONEY TRANSMITTERS ORDINANCE 2007 OF THE TURKS AND CAICOS ISLANDS, AN INVESTMENT DEALER, A TRUST COMPANY, A CUSTODIAN, A FIDUCIARY, A PAYMENT INSTITUTION OR AN ELECTRONIC MONEY INSTITUTION, IN THE TURKS AND CAICOS ISLANDS OR IN ANY OTHER JURISDICTION. FUNDS HELD IN A WALLET ARE NOT BANK DEPOSITS AND ARE NOT PROTECTED BY ANY DEPOSIT-INSURANCE OR INVESTOR-COMPENSATION SCHEME. ANY PAYMENT, ISSUING, BANKING, SAFEGUARDING OR SETTLEMENT FUNCTION SUPPORTING THE SYSTEM SERVICES IS PROVIDED BY REGULATED THIRD-PARTY PARTNERS (THE “FINANCIAL PARTNERS”) ENGAGED BY THE ADMINISTRATOR TO SUPPORT THE SYSTEM SERVICES. THE IDENTITY AND ROLES OF THE FINANCIAL PARTNERS MAY CHANGE DURING THE TERM OF THESE TERMS.","parentId":null},{"id":7,"content":"1.5 VIRTUAL ASSETS NOTICE. VIRTUAL ASSETS AND VIRTUAL ASSET SERVICES ARE NOT CURRENTLY REGULATED IN THE TURKS AND CAICOS ISLANDS, AND ACCORDINGLY NO LOCAL REGULATORY PROTECTION APPLIES TO PERSONS USING DIGITAL CURRENCY FUNCTIONALITY WITHIN THE SYSTEM. THE CUSTOMER ACKNOWLEDGES THAT THE VALUE OF DIGITAL CURRENCY IS VOLATILE AND THAT THE CUSTOMER ASSUMES ALL RISK ASSOCIATED WITH DEPOSITING, HOLDING, CONVERTING OR WITHDRAWING DIGITAL CURRENCY THROUGH THE SYSTEM.","parentId":null},{"id":338,"content":"1.6 The content of the Website, and any commercial or informational materials issued by the Administrator (including blog posts, FAQs, marketing materials and dashboards such as PST Pulse), is provided on an “as is” basis for information purposes only. The Administrator makes no express or implied warranty that such content is accurate, current or complete, and it shall not be relied upon as the sole basis for any business, financial or legal decision.","parentId":null},{"id":339,"content":"1.7 In these Terms, words denoting any gender include all genders, and words denoting the singular include the plural (and vice versa), unless the context requires otherwise. References to “including” mean “including, without limitation”. References to any statute or regulation include any amendment, consolidation or replacement of it. Headings are for convenience only and do not affect interpretation.","parentId":null}]},{"id":2,"__component":"ui.list","type":null,"title":"Definitions","isolated":null,"item":[{"id":5,"content":"In these Terms, the following capitalized terms have the meanings set out below. Additional defined terms may appear in specific sections and are used with the meanings given where they first appear.","parentId":null},{"id":8,"content":"**Account** — the virtual profile of a Customer in the System registered in accordance with these Terms and the Internal Policies. References to “Account” include, as applicable, an Individual Account and a Business Account.","parentId":null},{"id":9,"content":"**Administrator’s Contact Details** — email — customersupport@pst.net; registered office — Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands.","parentId":null},{"id":10,"content":"**AML Policy** — the Administrator’s Anti-Money Laundering and Counter-Terrorist Financing Policy published on the Website, as amended from time to time, reflecting the Administrator’s obligations under the Proceeds of Crime Ordinance, the Proceeds of Crime (Anti-Money Laundering and Prevention of Terrorist Financing) Regulations 2010 and the AML/CFT Code 2011 of the Turks and Caicos Islands and equivalent international standards.","parentId":null},{"id":11,"content":"**Applicable Law** — any applicable law, statute, ordinance, regulation, rule, order, directive, guidance, code of practice, or binding instruction issued by any competent governmental, regulatory, tax or supervisory authority, including the rules of any applicable payment network and any sanctions regime.","parentId":null},{"id":12,"content":"**Applicant** — a person (being an individual or a legal entity) that has submitted a registration application via the System and wishes to create an Account.","parentId":null},{"id":13,"content":"**Authorized Representative** — a natural person authorized by a Business Customer to act on its behalf in relation to the Account, as designated during Registration or by subsequent written notice to the Administrator.","parentId":null},{"id":14,"content":"**Authorization** — the process of authenticating a person by means of the Authorization Details and, where applicable, a second factor (including one-time passwords, SMS codes or biometrics).","parentId":null},{"id":15,"content":"**Authorization Details** — the combination of the Login, the Password and, where required, any additional authentication factor enabled on the Account.","parentId":null},{"id":16,"content":"**Beneficial Owner** — a natural person who ultimately owns or controls a Business Customer, or on whose behalf a transaction is being conducted, determined in accordance with the AML Policy and, as a default threshold, any natural person who directly or indirectly holds more than twenty-five percent (25%) of the shares, voting rights, ownership interests or control of the relevant entity.","parentId":null},{"id":17,"content":"**Business Account** — an Account created in the name of a legal entity acting in the course of its business, subject to the KYB procedure described in Section 5.","parentId":null},{"id":18,"content":"**Business Customer** — a Customer holding a Business Account.","parentId":null},{"id":19,"content":"**Business Day** — any day other than a Saturday, Sunday or public holiday in the Turks and Caicos Islands.","parentId":null},{"id":20,"content":"**Chargeback** — the procedure of cancelling a bank card payment initiated by the cardholder or the cardholder’s bank or card scheme, and any fine, fee, assessment or other cost associated with that procedure.","parentId":null},{"id":21,"content":"**Collateral** — fiat funds and Digital Currency that the Customer transfers to the Administrator in accordance with Section 8, which are held by the Administrator on the commercial basis described in Section 8 and in respect of which the Customer is credited with Funds in the relevant Wallet.","parentId":null},{"id":22,"content":"**Contact Details** — the email address and mobile telephone number submitted by the Customer in the System for the purposes of communication and account security.","parentId":null},{"id":23,"content":"**Cookie Policy** — the Administrator’s cookie policy published on the Website, describing the use of cookies and similar tracking technologies on the Website and the System.","parentId":null},{"id":24,"content":"**Customer** — a person (being an individual or a legal entity) that has completed Registration and holds an Account, and that is entitled to use the System in accordance with these Terms and the Internal Policies.","parentId":null},{"id":25,"content":"**Customer Support** — the support function of the Administrator, reachable via live chat on the Website and by email at customersupport@pst.net.","parentId":null},{"id":340,"content":"**Digital Currency** — a virtual asset (including, where expressly supported by the System, Bitcoin (BTC), Ether (ETH) and regulated stablecoins such as USDT and USDC) accepted by the Administrator as a deposit or withdrawal method, on the blockchain networks expressly supported by the System from time to time.","parentId":null},{"id":341,"content":"**Dormant Account** — an Account in respect of which the Customer has not logged in, initiated a Transaction or otherwise taken any action for twelve (12) consecutive months.","parentId":null},{"id":342,"content":"**eKYC** — the electronic Know-Your-Customer procedure performed by the Administrator or its third-party verification partner (including Sumsub), comprising automated identity-document verification, liveness detection and database screening.","parentId":null},{"id":343,"content":"**Fees** — the remuneration charged by the Administrator for the System Services, as displayed to the Customer in the Account dashboard at or before the time of the relevant Transaction, as updated from time to time in accordance with Section 13.","parentId":null},{"id":344,"content":"**Financial Partners** — the regulated third parties with which the Administrator contracts to support the System Services, including issuing banks, the Issuer, BIN sponsors, program managers, acquirers, card networks (such as Visa and Mastercard), payment processors, digital-asset exchanges and on-ramp/off-ramp providers.","parentId":null},{"id":345,"content":"**Force Majeure Event** — has the meaning given in Section 22.","parentId":null},{"id":346,"content":"**Funds** — book-entry balances recorded in the Customer’s Wallet, representing a contractual claim of the Customer against the Administrator for the return of Collateral of equivalent value (net of amounts owed to the Administrator), in accordance with Section 8 and Section 18.","parentId":null},{"id":347,"content":"**Individual Account** — an Account created by a natural person for use in the course of independent professional activity, including affiliate marketing, independent media buying, performance marketing, content creation, app publishing and other self-employed or sole-trader activity, to manage advertising, marketing-tools and related business expenditure through the System. An Individual Account is not available for personal, consumer or household use.","parentId":null},{"id":348,"content":"**Individual Customer** — a Customer holding an Individual Account.","parentId":null},{"id":349,"content":"**Internal Policies** — the Administrator’s internal documents governing the operation of the System, as listed in clause 1.3 and as published on the Website.","parentId":null},{"id":350,"content":"**Issuer** — the third-party card issuer that issues the PSTNET Card under a program arranged by the Administrator.","parentId":null},{"id":351,"content":"**KYB** — the Know-Your-Business procedure applicable to Business Customers under Section 5, including the identification and verification of the entity, its directors, its Authorized Representatives and its Beneficial Owners.","parentId":null},{"id":352,"content":"**Login** — the Customer’s email address or the alphanumeric identifier chosen by the Customer and used together with the Password to access the Account.","parentId":null},{"id":353,"content":"**Parties** — the Administrator and the Customer; “Party” means either of them.","parentId":null},{"id":354,"content":"**Password** — the alphanumeric combination chosen by the Customer during Registration (or subsequently reset by the Customer) and used together with the Login to access the Account.","parentId":null},{"id":355,"content":"**Payment Order** — an instruction to execute a Transaction given by the Customer in electronic form through the System.","parentId":null},{"id":356,"content":"**Private** — the subscription tier of the System offering bundled virtual-card issuance and cashback, with benefits, eligibility and pricing as described on the Website.","parentId":null},{"id":357,"content":"**Privacy Policy** — the Administrator’s data-protection notice published on the Website, describing how the Administrator processes personal data.","parentId":null},{"id":358,"content":"**Prohibited Activities** — the activities described in Section 16 and in Appendix 1 (List of Prohibited Goods, Works and Services).","parentId":null},{"id":359,"content":"**PSTNET Card** — a virtual, non-physical payment card issued to the Customer by the Issuer through a card program arranged by the Administrator and made available to the Customer through the System. A PSTNET Card may be issued under the “PSTNET” brand or under another brand (including the brand of the Issuer, the BIN sponsor, a co-brand partner or a white-label brand) at the Administrator’s discretion and depending on the card program, Financial Partner, BIN range and card product selected. The issuance and use of a PSTNET Card are governed by these Terms, together with any scheme rules, Issuer conditions or product-specific terms published on the Website at the time of issuance. References in these Terms to the “PSTNET Card” apply to all such cards, whether or not they carry the PSTNET brand. For the avoidance of doubt, the Administrator does not offer a physical PSTNET Card.","parentId":null},{"id":360,"content":"**PST Pulse** — the analytics and reporting dashboard made available to Customers via pulse.pst.net, forming part of the System.","parentId":null},{"id":361,"content":"**Rates** — the Fees, foreign-exchange margins and other pricing parameters applicable to the System Services, displayed to the Customer in the Account dashboard at or before the time of the relevant Transaction, as updated from time to time in accordance with Section 13.","parentId":null},{"id":362,"content":"**Registration** — the process of creating an Account as described in Section 4.","parentId":null},{"id":363,"content":"**Restricted Jurisdiction** — a country or territory listed in the Restrictions as one in respect of which the Administrator does not provide the System Services. The list may be amended from time to time by publication on the Website.","parentId":null},{"id":364,"content":"**Restrictions** — the restrictions section of the Website setting out, as updated from time to time: (i) Restricted Jurisdictions (the countries and territories in respect of which the System Services are not offered); (ii) restricted merchants; (iii) supported and restricted Merchant Category Codes (MCCs); and (iv) transactional limits and other operational restrictions applicable to the System Services.","parentId":null},{"id":365,"content":"**Sanctions** — economic or financial sanctions, trade embargoes, export controls or similar restrictive measures administered or enforced by the United Nations Security Council, the Turks and Caicos Islands, the United Kingdom (including His Majesty’s Treasury), the European Union, the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury, or any other relevant authority.","parentId":null},{"id":366,"content":"**Settlement Reserve** — the reasonable reserve the Administrator may retain in accordance with Section 18 to account for delayed settlement events, Chargebacks, refunds, network adjustments and similar contingent liabilities following the closure of a PSTNET Card or termination of these Terms.","parentId":null},{"id":367,"content":"**Supported Country** — a country or territory from which the Administrator is willing to accept Applicants, as listed on the Website under the heading “Supported countries”.","parentId":null},{"id":368,"content":"**Suspension of Account** — the temporary restriction of the Customer’s access to the Account and to some or all System Services, imposed in accordance with Section 17.","parentId":null},{"id":369,"content":"**System** — the PSTNET platform operated by the Administrator, comprising the Website, the Customer dashboard, PST Pulse, the API, the browser extension and any related interfaces, together with the associated back-office infrastructure.","parentId":null},{"id":370,"content":"**System Services** — the services provided by the Administrator to the Customer through the System, including the opening and maintenance of Accounts and Wallets, the acceptance and recording of Collateral, the execution of Transactions, the facilitation of the issuance and servicing of PSTNET Cards (together with the Issuer), cashback accounting and reporting, API access and related technical and informational services.","parentId":null},{"id":371,"content":"**Transaction** — any operation recorded in a Wallet, including Collateral deposits, withdrawals of Funds, currency conversions, internal transfers, payments made with a PSTNET Card, Chargebacks and Fee charges.","parentId":null},{"id":372,"content":"**Ultimate Beneficial Owner (UBO)** — the same meaning as “Beneficial Owner”.","parentId":null},{"id":373,"content":"**Verification** — the identity-verification procedure carried out in accordance with Section 5 and the AML Policy, including eKYC, KYB (for legal entities), proof of address and, where applicable, enhanced due diligence.","parentId":null},{"id":374,"content":"**Verified Account** — an Account in respect of which the Customer has successfully completed Verification.","parentId":null},{"id":375,"content":"**Wallet** — a sub-ledger within the Account denominated in a supported currency (including fiat and, where expressly supported, Digital Currency), reflecting the balance of Funds of the Customer in that currency.","parentId":null},{"id":376,"content":"**Website** — the website located at https://pst.net and its sub-domains (including blog.pst.net and pulse.pst.net), operated by the Administrator.","parentId":null}]},{"id":49,"__component":"ui.list","type":null,"title":"Role of PSTNET; Financial Partners; No Custody","isolated":false,"item":[{"id":330,"content":"3.1 The Administrator operates the System as a technology platform that enables Customers to deposit Collateral, maintain Wallets, convert between supported currencies, instruct Transactions and use PSTNET Cards issued by the Issuer. The Administrator does not itself issue payment cards, does not operate as a bank, does not take deposits, does not issue electronic money, does not carry on money-transmission business and does not act as a custodian of fiat or Digital Currency.","parentId":null},{"id":331,"content":"3.2 The PSTNET Card is issued by the Issuer, not by the Administrator. The Administrator acts as a technical and operational intermediary between the Customer and the Issuer in relation to the PSTNET Card. Card authorizations, clearing, settlement, freezes, limits, disputes and refunds are determined by the Issuer, the relevant card scheme and the merchant’s acquiring bank, in accordance with these Terms and applicable scheme rules.","parentId":null},{"id":332,"content":"3.3 Where a Financial Partner (including the Issuer, a partner bank, a card scheme or an acquirer) freezes, blocks, limits or otherwise restricts Funds, a PSTNET Card or any Transaction, the Administrator shall follow the lawful instructions of that Financial Partner and shall inform the Customer to the extent permitted by law. The Administrator is not liable for the acts or omissions of Financial Partners, save as expressly set out in these Terms or required by mandatory law.","parentId":null},{"id":377,"content":"3.4 The Administrator partners with industry providers (including Sumsub for eKYC and regulated partners for card issuance, transaction monitoring and on-ramp/off-ramp services) to deliver the System Services. The Customer acknowledges that the provision of the System Services necessarily involves the sharing of Customer data with such partners, in accordance with the Privacy Policy.","parentId":null},{"id":378,"content":"3.5 Nothing in these Terms creates, or shall be construed as creating, a fiduciary, trust, custodial, escrow, safeguarding, agency, banking, deposit-taking, money-transmission or joint-venture relationship between the Administrator and the Customer. The Administrator does not hold Customer funds on trust, in a client-money account or in any other segregated or fiduciary capacity. Collateral transferred by the Customer represents advance payment for the Customer’s access to the System Services and for the Administrator’s facilitation of Transactions, and does not constitute custodial funds, escrow funds, trust funds, safeguarded funds or client funds held on behalf of the Customer.","parentId":null},{"id":379,"content":"3.6 The Administrator may inform the Customer of changes to the System, the System Services, supported currencies, supported funding rails, Merchant Category Code coverage, Transaction limits and other operational parameters either by sending notifications to the email address registered in the Account, by posting updates on the Website or within the Account dashboard, or by any combination of these channels. The Customer shall regularly review the Website and the Account dashboard for such updates. Changes that take effect without notice are limited to those necessary to address security, fraud, compliance or regulatory risk, or to reflect changes imposed by a Financial Partner. Amendments to these Terms themselves are governed by Section 20.","parentId":null}]},{"id":3,"__component":"ui.list","type":null,"title":"Registration and Categories of Customer","isolated":null,"item":[{"id":51,"content":"4.1  **Categories**. The Administrator onboards each Applicant into one of the following categories, and the Customer’s rights, obligations, applicable Verification procedures and available Transaction limits shall be determined by that category:\n\n- **Individual Customer** — a natural person onboarded to use the Account in the course of independent professional activity (such as affiliate marketing, independent media buying, performance marketing, content creation or app publishing) carried on as a sole trader or self-employed person, to manage advertising, marketing-tools and related business expenditure through the System. The Account is not available for personal, consumer or household use.\n- **Business Customer** — a legal entity (company, partnership or similar body corporate) onboarded to manage its business-related expenditure through the System. A natural person carrying on business in their own name without a separate legal entity (sole trader) may elect to onboard as an Individual Customer or, where the Administrator supports such onboarding on the Website, as a Business Customer.\n\nThe Administrator may, acting reasonably and on the basis of the Customer’s actual or intended use of the System, require an Individual Customer to provide additional information or documents as set out in clause 5.1, or to re-categorize as a Business Customer (for example, where the Account is used to manage expenditure on behalf of a legal entity rather than on the Individual Customer’s own account, or where the Account’s activity is more consistent with that of a legal entity than an independent professional).","parentId":null},{"id":52,"content":"4.2 **Individual Customer registration.** Registration of an Individual Account is completed online in two steps:\n\n- **Step 1 — Account creation.** The Applicant submits an email address and Password (and such other information as the registration form may require from time to time) and accepts these Terms and the Internal Policies through the click-wrap mechanism on the registration page. Upon acceptance, the Account is automatically created, these Terms enter into force between the Administrator and the Applicant, and the Applicant becomes an Individual Customer. At this stage, the Account is an Unverified Account and its functionality is limited in accordance with clause 4.4.\n- **Step 2 — Verification.** To obtain access to System Services that require a Verified Account (including the issuance of virtual cards and the making of Transactions above the limits applicable to Unverified Accounts), the Individual Customer shall complete the Verification procedure set out in clause 5.1 through the Administrator’s eKYC provider (currently Sumsub). During Registration or Verification the Applicant shall indicate the intended use of the Account (for example, affiliate marketing, independent media buying, performance marketing, content creation or app publishing). The scope of the information and documents required under clause 5.1 shall be calibrated to the intended use of the Account and to the Applicant’s risk profile.","parentId":null},{"id":53,"content":"4.3 **Business Customer registration**. Registration of a Business Account is completed online in two steps:\n\n- **Step 1 — Account creation.** A natural person who is duly authorized to bind the entity, and who represents and warrants that such authority exists, submits an email address and Password (and such other information as the registration form may require from time to time), identifies themselves as an Authorized Representative, and accepts these Terms and the Internal Policies through the click-wrap mechanism on the registration page. Upon acceptance, the Account is automatically created, these Terms enter into force between the Administrator and the entity, and the entity becomes a Business Customer. At this stage, the Account is an Unverified Account and its functionality is limited in accordance with clause 4.4.\n- **Step 2 — Verification.** To obtain access to System Services that require a Verified Account (including the issuance of virtual cards and the making of Transactions above the limits applicable to Unverified Accounts), the Customer shall complete the KYB Verification procedure set out in clause 5.2, including the identification and verification of the entity, its directors, its Authorized Representatives and its Beneficial Owners, through the Administrator’s eKYC provider (currently Sumsub) and such other channels as the Administrator may require.\n\nAn Individual Customer may not use the Account on behalf of any third party, including any employer, agency, client or legal entity; use of the System on behalf of a legal entity requires a Business Account.","parentId":null},{"id":380,"content":"4.4  **Unverified and Verified Accounts.** Upon Account creation under clause 4.2 or 4.3, the Account is an Unverified Account. An Unverified Account does not permit the issuance of virtual cards or the execution of Transactions other than those expressly enabled by the Administrator on the Website for Unverified Accounts. To obtain the issuance of a virtual card and full access to the System Services, the Customer shall successfully complete Verification under Section 5 and the AML Policy, following which the Account becomes a Verified Account. The Administrator may withdraw Verified Account status where the circumstances giving rise to Verification change, or where Verification documents are or become inaccurate, incomplete or out of date.","parentId":null},{"id":381,"content":"4.5  **Applicant representations and warranties.** By submitting the Registration, the Applicant represents and warrants that:\n- it has full legal right, authority and capacity to enter into these Terms (and, in the case of a legal entity, is duly incorporated and validly existing in good standing under the laws of its jurisdiction of incorporation);\n- it is acting on its own behalf, and not on behalf of or in the interest of any undisclosed third party;\n- in the case of an Individual Customer, the Applicant is at least eighteen (18) years old and has full legal capacity under the laws of the Applicant’s country of residence;\n- in the case of an Individual Customer using the Account in the course of independent professional activity, the Applicant is lawfully carrying on that activity as a self-employed or sole-trader person (or equivalent status) in the Applicant’s country of residence, is responsible for its own registration and taxation in that country, and is not using the Account to disguise an employment relationship or to evade legal obligations of any third party;\n- it is not a citizen or resident of, incorporated in or otherwise located in a Restricted Jurisdiction, and (in the case of a legal entity) none of its Beneficial Owners, directors or Authorized Representatives is so located or listed;\n- neither it nor any of its Beneficial Owners, directors or Authorized Representatives is the subject of Sanctions or otherwise listed on any applicable sanctions, terrorist-financing or politically-exposed-person watchlist that would prohibit the Administrator from providing the System Services;\n- the creation of the Account does not violate any law or regulation applicable to it; and\n- the information submitted is accurate, complete and up-to-date, and it will keep it up-to-date for as long as the Account exists.","parentId":null},{"id":382,"content":"4.6  **One Account.** Each Customer may hold only one Account of a given category. The Administrator reserves the right to identify duplicate Accounts as fraudulent and to suspend or terminate all Accounts created by or attributable to the same individual or entity. A Business Customer may operate multiple Authorized Representatives and sub-users under a single Business Account, subject to the KYB procedure in clause 5.2 and to any additional conditions published on the Website.","parentId":null},{"id":383,"content":"4.7  **Refusal of Registration.** The Administrator may refuse to open an Account, refuse to complete Verification or impose conditions on the Account, at its reasonable discretion, including where the Applicant does not satisfy the eligibility criteria, presents an unacceptable risk profile, or fails to provide information or documents requested during Registration or Verification.","parentId":null}]},{"id":4,"__component":"ui.list","type":null,"title":"Verification (KYC and KYB)","isolated":null,"item":[{"id":92,"content":"5.1  **Individual Customer KYC.** To obtain full access to the System Services available to Verified Accounts, an Individual Customer shall provide to the Administrator:\n\n- a clear image of a valid government-issued identity document containing a unique identification number and the Customer’s photograph;\n- a liveness check (selfie or short video) performed through the Administrator’s eKYC provider;\n- the Customer’s mobile telephone number, confirmed by one-time password;\n- proof of address issued no earlier than three (3) months before submission (for example, a utility bill, bank statement or tax notice); and\n- such additional information as may be required by the AML Policy, including information on the purpose and intended use of the Account, source of funds and, where applicable, source of wealth, occupation and employer.\n\nWhere the Individual Customer indicates that the Account will be used in the course of independent professional activity (for example, affiliate marketing, media buying, content creation or app publishing), or where the Administrator determines on a risk-based assessment that such activity is material to the Account, the Administrator may additionally require any of the following:\n\n- a description of the professional activity, including the verticals, advertising platforms, networks or affiliate programs through which the Customer operates;\n- evidence of genuine and lawful professional activity, which may include self-employed or sole-trader registration (or local equivalent), tax-residency confirmation, a VAT or tax identification number (where applicable), invoices, contracts, affiliate-network dashboards, publisher statements or payout confirmations, or screenshots of advertising-platform accounts;\n- an estimate of expected monthly Transaction volumes and the source of funds that will be used to deposit Collateral into the Account (for example, personal bank account held in the Customer’s own name, affiliate-network payouts or stable coin payouts from publishers or networks); and\n- confirmation that the Customer acts on their own account and that Collateral deposited into the Account is owned by the Customer in their personal or sole-trader capacity and is not derived from or held on behalf of any employer, client or other third party.","parentId":null},{"id":93,"content":"5.2  **Business Customer KYB.** To obtain full access to the System Services available to Verified Accounts, a Business Customer shall provide to the Administrator:\n\n- certificate of incorporation (or equivalent formation document) and, where issued, certificate of good standing dated no earlier than three (3) months before submission;\n- constitutional documents (memorandum and articles of association, bylaws, partnership agreement or equivalent);\n- a current register of directors and a current register of members (shareholders), or equivalent documentation sufficient to establish the ownership and control structure of the entity;\n- a corporate resolution or written authorization naming each Authorized Representative and confirming their authority to act on behalf of the entity in relation to the Account;\n- proof of the entity’s registered business address (for example, utility bill, bank statement or tax notice) issued no earlier than three (3) months before submission;\n- identification and verification documentation for each Authorized Representative, director and Beneficial Owner equivalent to that required of an Individual Customer under clause 5.1, including identity document, liveness check and proof of address;\n- an ownership and control structure chart identifying all direct and indirect Beneficial Owners to the applicable threshold, and a signed UBO declaration;\n- information on the entity’s business activities, intended use of the System, expected Transaction volumes, source of funds and source of wealth;\n- where applicable, copies of any licenses, registrations or authorizations required by the entity to carry on its business; and\n- such additional information or documents as the Administrator may require in accordance with the AML Policy.","parentId":null},{"id":94,"content":"5.3  **Enhanced due diligence.** The Administrator may, for fraud-prevention or enhanced-due-diligence purposes, require the Customer (or any Authorized Representative, director or Beneficial Owner) to complete a live video call with the Administrator or its third-party providers, to submit additional documents (such as invoices, contracts, financial statements, tax returns, bank statements or evidence of source of funds or source of wealth), or to undergo any other reasonable additional check.","parentId":null},{"id":95,"content":"5.4  **Completion.** Verification is usually completed within twenty-four (24) hours of the Customer submitting the requested data. This period may be extended where the Administrator has reasonable grounds to perform enhanced due diligence, in which case the Customer will be informed. Verification is deemed complete at the moment the Customer receives confirmation from the Administrator via email or SMS.","parentId":null},{"id":96,"content":"5.5  **Failure and updates.** Verification shall be deemed failed if any data required under this Section 5 is not provided, or is found to be inaccurate, incomplete or outdated, in whole or in part. The Customer shall notify the Administrator without undue delay of any change in the information provided for the purposes of Verification (including any change of director, Authorized Representative or Beneficial Owner of a Business Customer), and shall provide updated supporting documents upon request.","parentId":null},{"id":98,"content":"5.6  **Periodic refresh.** The Administrator may, at any time and at its reasonable discretion, require the Customer to confirm that the documents and data previously provided remain accurate, complete and up-to-date, and may request additional supporting documents or data. The Customer shall respond to such requests within fourteen (14) days of the date on which the request is sent. If the Customer fails to respond within that period, the Administrator may (i) decline to complete or maintain Verification and/or (ii) apply a Suspension of Account until the requested information is provided.","parentId":null}]},{"id":5,"__component":"ui.list","type":null,"title":"Account and Wallets","isolated":null,"item":[{"id":106,"content":"6.1  The Account is created upon Account creation under clause 4.2 or 4.3 and holds one or more Wallets, each denominated in a currency supported by the System. The functionality available in the Account depends on whether the Account is an Unverified Account or a Verified Account, in accordance with clause 4.4.","parentId":null},{"id":107,"content":"6.2  All Funds credited to the Customer are recorded in the corresponding Wallet as a book-entry balance representing the Customer’s contractual claim against the Administrator for the return of the corresponding Collateral (net of amounts owed to the Administrator). Funds may be held in a Wallet for an indefinite period, subject to Section 18, and no interest accrues on Funds held in a Wallet.","parentId":null},{"id":108,"content":"6.3  Limits may apply to deposits into, payments from and withdrawals from a Wallet. Applicable limits depend on the Customer’s category, Verification status, the type of Wallet, the Customer’s risk profile and any applicable regulatory requirement. Current limits are published on the Website and within the Account dashboard, and form part of these Terms.","parentId":null},{"id":109,"content":"6.4  The Customer is responsible for keeping the Authorization Details (and, in the case of a Business Customer, all Authorized Representative credentials) confidential. Any action carried out using valid Authorization Details is deemed to have been carried out by the Customer, unless the Customer has notified the Administrator of suspected unauthorized or fraudulent use in accordance with clause 6.7.","parentId":null},{"id":110,"content":"6.5  If the Customer enters incorrect Authorization Details several times in succession, the System will apply a temporary lockout for security reasons. The Customer may unlock access by completing the password-reset flow or by contacting Customer Support.","parentId":null},{"id":111,"content":"6.6  If the Customer loses access to the Authorization Details, the Customer shall contact Customer Support and follow the account-recovery procedure, which may include (i) a password-reset link sent to the registered email address, (ii) a one-time SMS code sent to the verified mobile number and/or (iii) additional identity checks consistent with the AML Policy.","parentId":null},{"id":112,"content":"6.7  The Customer shall notify the Administrator without undue delay (and in any event within two (2) Business Days of becoming aware) of any suspected loss, theft, misappropriation or unauthorized use of the Authorization Details or of the Account. Until such notification is received, the Administrator is entitled to treat Transactions performed with valid Authorization Details as authorised by the Customer.","parentId":null},{"id":113,"content":"6.8  A Business Customer is responsible for all actions taken through the Account by any of its Authorized Representatives, employees, contractors or other persons to whom it has granted access (directly or indirectly), and for promptly removing access rights when such persons cease to be authorized.","parentId":null}]},{"id":6,"__component":"ui.list","type":null,"title":"Virtual Cards; Role of the Issuer","isolated":null,"item":[{"id":126,"content":"7.1  All cards made available through the System (whether branded “PSTNET” or issued under another brand) are provided exclusively in virtual, non-physical form. The Administrator does not issue, ship or otherwise make available any physical card.","parentId":null},{"id":127,"content":"7.2  The PSTNET Card is issued by the Issuer under these Terms and the rules of the relevant card scheme. The Administrator acts as a program and technology partner to the Issuer and does not itself issue the PSTNET Card, hold the underlying card account or provide regulated payment services in relation to the PSTNET Card. These Terms are the agreement between the Customer and the Administrator in relation to the PSTNET Card; no separate cardholder agreement is entered into between the Customer and the Issuer.","parentId":null},{"id":128,"content":"7.3  When applying for a PSTNET Card, the Customer may be required to provide additional information to the Administrator and/or the Issuer. The Customer authorizes the Administrator to share such information with the Issuer and other Financial Partners for the purposes of card issuance, servicing, monitoring, fraud prevention and compliance.","parentId":null},{"id":129,"content":"7.4  The PSTNET Card balance and transaction history are displayed in the Account dashboard. By using the PSTNET Card, the Customer authorizes the Administrator to deduct from the available Wallet balances the amount of each PSTNET Card Transaction, together with any applicable Fees, taxes, Chargebacks and network costs.","parentId":null},{"id":130,"content":"7.5  PSTNET Card Transactions are settled in United States Dollars (USD) by default. Where a Transaction is conducted in another currency, the Issuer or card scheme converts the Transaction into USD at its applicable rate, and a foreign-transaction Fee may apply as reflected in the Rates.","parentId":null},{"id":131,"content":"7.6  Where a PSTNET Card Transaction is attempted against an insufficient USD balance, the System will normally decline the Transaction. If, exceptionally, such a Transaction is nonetheless authorized by the Issuer, the Customer authorizes the Administrator to (i) debit balances in other fiat currencies in the Account at the then-current rate displayed in the System, or (ii) where Digital Currency is supported and held by the Customer as Collateral, purchase from the Customer Digital Currency equivalent to the USD value of the Transaction at the rate displayed in the System at that time. The Customer shall immediately settle any remaining shortfall on first written demand.","parentId":null},{"id":132,"content":"7.7  The Customer is liable for all PSTNET Card Transactions initiated using the Customer’s PSTNET Card, subject to clause 7.8 and to Section 15 and to any mandatory consumer-protection rules applicable in the Customer’s jurisdiction.","parentId":null},{"id":133,"content":"7.8  If the Customer suspects that the PSTNET Card is being or may be misused, the Customer shall immediately freeze the PSTNET Card from the Account dashboard or by contacting customersupport@pst.net. The freeze takes effect when applied by the System or the Issuer. Transactions authorized before the freeze takes effect remain the responsibility of the Customer, save where applicable consumer-protection law provides otherwise.","parentId":null},{"id":134,"content":"7.9  The Administrator may instruct the Issuer to block, cancel or limit the use of the PSTNET Card where the Administrator has reasonable grounds to suspect a violation of these Terms, the AML Policy, Sanctions, card-scheme rules or Applicable Law, or where Financial Partners require it to do so.","parentId":null},{"id":135,"content":"7.10  Upon the cancellation, suspension or freezing of a PSTNET Card for any reason, any remaining balance associated with the card shall be made available in the Account, subject to the deduction of any amounts owed by the Customer to the Administrator or the Issuer, and subject to Section 18.","parentId":null}]},{"id":7,"__component":"ui.list","type":null,"title":"Collateral; Funding of Wallets","isolated":null,"item":[{"id":147,"content":"8.1  **Pre-funded model.** All spending capacity through the System (including on PSTNET Cards) operates strictly on a pre-funded basis. The Administrator does not extend consumer credit or commercial credit to the Customer, and these Terms do not constitute a regulated credit agreement. A PSTNET Card will only be loaded with spending capacity once the Customer has transferred Collateral of sufficient value to the Administrator and the corresponding Funds have been credited to the Wallet.","parentId":null},{"id":148,"content":"8.2  **Approved funding methods.** The Customer may deposit Collateral only through the funding methods approved by the Administrator and displayed in the Account dashboard. Approved funding methods may include bank wire, SEPA, ACH, card-funded deposit, and supported Digital Currency rails, and may be updated, added to or removed by the Administrator from time to time.","parentId":null},{"id":149,"content":"8.3  **Legal characterization of Collateral.** Collateral transferred by the Customer to the Administrator represents advance payment for the Customer’s access to the System Services and for the Administrator’s facilitation of Transactions, and does not constitute custodial funds, escrow funds, trust funds, safeguarded funds or client funds held on behalf of the Customer. Without limiting the generality of the foregoing, the Customer agrees and expressly acknowledges that:\n\n- (a) fiat funds transferred to the Administrator as Collateral are not deposits, are not client money, are not electronic money and are not held on trust or in any safeguarded, segregated, custodial or escrow capacity; they are received by the Administrator as commercial Collateral in the course of a commercial arrangement and become the property of the Administrator subject to the Customer’s contractual right to receive Funds of equivalent value in the relevant Wallet and subsequently to withdraw those Funds under Section 18;\n- (b) Digital Currency transferred to the Administrator as Collateral is not held by the Administrator in a custodial capacity; the Administrator is not a virtual asset service provider acting on behalf of the Customer; and\n- (c) upon receipt and confirmation of Collateral, the Administrator credits the Customer’s Wallet with corresponding Funds. Funds are a book-entry unit of account representing the Customer’s contractual claim against the Administrator and do not constitute fiat currency, electronic money, a deposit, a security, a financial instrument or client money.","parentId":null},{"id":150,"content":"8.4  **Settlement of Collateral.** Collateral will be credited to the Wallet, and corresponding Funds made available, only after the relevant funding transfer has been received and confirmed by the Administrator or its Financial Partners. Posting timelines vary by rail and are subject to the processing times and operational practices of the banks, payment networks and blockchains concerned. The Administrator may apply reasonable risk-based holds before confirming Collateral.","parentId":null},{"id":151,"content":"8.5  **Source of funds warranty.** The Customer represents and warrants, on and as of the date of each Collateral deposit, that all Collateral is derived from legitimate sources, is not the proceeds of crime, is not subject to any claim or encumbrance, is not controlled by any sanctioned person, and has not been obtained through any activity that would breach Applicable Law or the AML Policy. The Administrator may at any time request documentation evidencing the source of funds or source of wealth, and may decline, freeze, return or delay any Collateral pending receipt of satisfactory evidence.","parentId":null},{"id":152,"content":"8.6  **Digital Currency risk.** The Customer acknowledges that the value of Digital Currency is volatile, that Digital Currency may be subject to blockchain reorganizations, network delays, congestion, forks, airdrops or other events that may affect its value or availability, and that the Administrator is not responsible for any loss arising from such events. The rate at which Digital Currency is converted into a fiat-denominated Funds balance is the rate displayed in the System at the time of the relevant Transaction, which includes the Administrator’s spread as disclosed in the Rates.","parentId":null},{"id":153,"content":"8.7  **Sufficient funding.** The Customer is solely responsible for maintaining sufficient Funds (and therefore sufficient Collateral) to cover all Transactions, Fees, Chargebacks and contingent liabilities. The Customer acknowledges that banking and blockchain settlement timelines may vary and that deposits may not be processed outside standard banking hours, on weekends or on public holidays, and shall plan funding accordingly.","parentId":null},{"id":154,"content":"8.8  **Third-party funding.** Where a Wallet is funded by a third party, all rights and obligations in respect of the Funds credited shall be those of the Customer, and the deposit shall be treated as made by a third party on the Customer’s behalf and for the Customer’s benefit, subject to any additional due diligence that the Administrator may require in respect of the third party.","parentId":null}]},{"id":8,"__component":"ui.list","type":null,"title":"Transactions","isolated":null,"item":[{"id":158,"content":"9.1  The Customer may deposit Collateral into, and withdraw Funds from, a Wallet by logging into the Account and following the instructions for the selected method. Available deposit and withdrawal methods (including bank transfers, card-funded deposits, Digital Currency and partner payment systems) are listed in the Account dashboard and may vary depending on the Customer’s location, category and Verification status.","parentId":null},{"id":159,"content":"9.2  Deposits and withdrawals are payment services provided by third-party payment service providers, acquiring banks and (where applicable) virtual-asset service providers. Those services are not System Services. Additional fees, timing rules and limits set by those third parties may apply in addition to the Administrator’s Fees.","parentId":null},{"id":160,"content":"9.3  The Administrator may set deposit, payment and withdrawal limits (including minimum and maximum amounts per Transaction or per period) for security, risk-management and compliance reasons. Current limits are visible in the Account dashboard for each available method.","parentId":null},{"id":161,"content":"9.4  A Transaction is initiated by the Customer submitting a Payment Order electronically through the System. Upon receipt of a Payment Order, the Administrator authenticates the Customer using the Authorization Details and may require additional authentication steps before executing the Payment Order.","parentId":null},{"id":162,"content":"9.5  All Transactions initiated through the System with valid Authorization Details shall be deemed to have been initiated by the Customer, unless the Administrator has received a notification under clause 6.7 before the Transaction is executed.","parentId":null},{"id":163,"content":"9.7  The Customer may exchange Funds between supported currencies within the Account at the exchange rate displayed in the System at the time of the Transaction, which includes the Administrator’s foreign-exchange margin as set out in the Rates.","parentId":null},{"id":384,"content":"9.8  The Customer may transfer Funds between its own Wallets, and (where permitted) to the Wallets of other Customers within the System.","parentId":null},{"id":385,"content":"9.9  The Customer may download electronic reports of executed Transactions for any period directly from the Account dashboard, and may export such reports in the formats made available by the System (including CSV).","parentId":null},{"id":386,"content":"9.10  Except where required by Applicable Law or where a Transaction has been classified as fraudulent, executed Transactions are final, irrevocable and not subject to dispute, reversal or cancellation by the Administrator. This clause does not affect the Customer’s Chargeback rights against third-party card issuers or payment providers.","parentId":null},{"id":387,"content":"9.11  Where a deposit is refunded because Verification has not been completed, the refund shall be initiated automatically to the original funding source. Processing times are determined by the relevant third party.","parentId":null}]},{"id":9,"__component":"ui.list","type":null,"title":"Chargebacks, Reversals and Network Costs","isolated":null,"item":[{"id":165,"content":"10.1  The Customer is solely liable for any Chargeback, dispute, representment fee, network assessment, issuer fee, scheme fine, fraud claim, penalty or other cost that arises from or relates to any Transaction initiated through the Account or any PSTNET Card, regardless of when such cost is assessed or imposed.","parentId":null},{"id":388,"content":"10.2  The Customer authorizes the Administrator to deduct any such amount from the Wallet, from any other Funds held in the Account, or from the Collateral. Where the available balances are insufficient, the Customer shall reimburse the Administrator on first written demand within five (5) Business Days. Any unreimbursed amount shall accrue interest at a commercially reasonable rate of the lesser of (i) ten percent (10%) per annum and (ii) the maximum rate permitted by Applicable Law, from the date of demand until the date of payment in full.","parentId":null},{"id":389,"content":"10.3  The Administrator may retain a Settlement Reserve in accordance with Section 18 to account for contingent Chargeback liability and related costs following termination or card closure.","parentId":null}]},{"id":10,"__component":"ui.list","type":null,"title":"11. API, Browser Extension and PST Pulse","isolated":null,"item":[{"id":166,"content":"11.1  The Administrator makes available a RESTful API and a browser extension, through which the Customer may integrate the System with its own tools and workflows. Use of the API and the extension is subject to the technical documentation and any additional terms published on the Website.","parentId":null},{"id":167,"content":"11.2  The Customer shall keep API credentials and extension authentication tokens confidential and shall treat them as Authorization Details for the purposes of these Terms. The Customer is responsible for all actions performed through the API or the extension using its credentials.","parentId":null},{"id":168,"content":"11.3  PST Pulse (pulse.pst.net) provides analytics, BIN information and reporting features. The content of PST Pulse is informational only and does not constitute financial, legal or business advice. The Administrator may update, add or remove PST Pulse features at any time.","parentId":null}]},{"id":11,"__component":"ui.list","type":null,"title":"Private Tier and Cashback","isolated":null,"item":[{"id":175,"content":"12.1  The Administrator may offer subscription tiers of the System (including “Private”) that bundle a defined number of complimentary virtual cards per period and a cashback accrual on qualifying spend. The specific benefits, qualifying spend categories (for example, qualifying advertising platforms), cashback rate and any caps are published on the Website in the “Private” section and form part of these Terms.","parentId":null},{"id":176,"content":"12.2  Cashback is accrued only on qualifying Transactions as defined on the Website. Cashback is credited to the Customer’s Account in accordance with the schedule published on the Website and can be used to fund further Transactions. The Administrator may, acting reasonably, adjust, delay or reverse cashback accruals in cases of refunds, Chargebacks, fraud or abuse of the subscription program.","parentId":null},{"id":177,"content":"12.3  Subscription fees are charged in advance on a monthly or other basis disclosed at checkout. The Customer may cancel the subscription at any time; cancellation takes effect at the end of the then-current billing period. No pro-rata refunds are provided for the unused portion of a billing period, save where applicable consumer-protection law provides otherwise.","parentId":null}]},{"id":12,"__component":"ui.list","type":null,"title":"Fees and Rates","isolated":null,"item":[{"id":181,"content":"13.1  The Administrator charges Fees for the System Services as set out in the Rates, which are displayed to the Customer in the Account dashboard at or before the time of each Transaction (and, for recurring charges such as subscription fees or inactivity fees, at the point of the event giving rise to the charge). The Rates form part of these Terms. Fees may vary by product, Customer category, volume, jurisdiction and Financial Partner, and may include per-card issuance fees, monthly maintenance fees, Transaction fees, deposit fees, foreign-exchange margins, refund fees, withdrawal fees and inactivity fees.","parentId":null},{"id":182,"content":"13.2  Any promotional pricing, discount or offer communicated by the Administrator on the Website or through marketing channels is available only in accordance with its published terms and only to the extent reflected in the Rates displayed in the Account dashboard at the time of the relevant Transaction. The Rates displayed in the Account dashboard at the time of a Transaction are definitive and prevail over any inconsistent pricing information communicated elsewhere. The Administrator does not warrant any particular Fee level except as expressly reflected in the Rates at the time of the Transaction.","parentId":null},{"id":183,"content":"13.3  All Fees are calculated in the currency of the underlying Transaction and rounded to the nearest whole cent (or equivalent smallest unit of the relevant currency). Fees are deducted from the Customer’s Wallet upon completion of the relevant Transaction or, where no Transaction is associated with the Fee, upon the event giving rise to the Fee (for example, monthly subscription billing).","parentId":null},{"id":390,"content":"13.4  If the Wallet balance is insufficient to cover a Fee, the Administrator may (i) decline the Transaction, (ii) debit a balance in another supported currency at the rate then displayed in the System, or (iii) request the Customer to top up the Wallet within a reasonable period before retrying the Transaction.","parentId":null},{"id":391,"content":"13.5  The Administrator may amend the Rates subject to the notice rules set out in Section 20. Changes to Fees will be notified to the Customer at least two (2) months before they take effect, except where a shorter notice period is permitted by mandatory law (for example, in respect of changes that are more favorable to the Customer, such as reductions in Fees, which may take effect immediately).","parentId":null},{"id":392,"content":"13.6  Customer responsibility for taxes. The System Services are not subject to VAT or other turnover taxes in the Turks and Caicos Islands. The Customer is solely responsible for determining, calculating, withholding, reporting, filing and paying any taxes, duties, levies, social-security contributions or similar charges that may apply to the Customer, to Transactions conducted through the Account, to Fees paid to the Administrator or to any cashback or other benefit received under these Terms, in each case under the laws of its country of residence, incorporation or activity, or any other jurisdiction that may claim taxing rights. The Administrator does not provide tax advice and makes no representation as to the tax treatment of any Transaction or of the Customer’s use of the System.","parentId":null}]},{"id":13,"__component":"ui.list","type":null,"title":"Data Protection","isolated":null,"item":[{"id":186,"content":"14.1  The Administrator processes personal data in accordance with the Privacy Policy, which forms part of these Terms. The Privacy Policy describes the categories of personal data processed, the purposes and legal bases of processing (including compliance with AML obligations, contract performance and legitimate interests), recipients of personal data, international transfers, retention periods and the rights of data subjects.","parentId":null},{"id":187,"content":"14.2  Where the Customer is located in a jurisdiction that grants rights in respect of personal data (including the European Union, the United Kingdom, Brazil, California and other jurisdictions with equivalent regimes), those rights — including access, rectification, erasure, restriction, portability and objection — may be exercised in accordance with the Privacy Policy and Applicable Law, by contacting the Administrator at the email address set out in the Privacy Policy.","parentId":null},{"id":188,"content":"14.3  The Administrator shares personal data with its verification, card-issuance, payment and fraud-prevention partners (including Sumsub for eKYC and the Issuer for card issuance and monitoring) to the extent necessary to perform the System Services and to comply with legal obligations.","parentId":null},{"id":189,"content":"14.4  A Business Customer shall, where applicable, provide to its Authorized Representatives, directors, employees and Beneficial Owners the Privacy Policy, and any further data-protection notices required under the law applicable to such individuals, so that those individuals may exercise their data-protection rights.","parentId":null}]},{"id":14,"__component":"ui.list","type":null,"title":"Liability; Disclaimers","isolated":null,"item":[{"id":193,"content":"15.1  **General.** Each Party shall be liable to the other for breach of these Terms in accordance with these Terms, the Internal Policies and Applicable Law. The Customer shall take reasonable steps to comply with the laws of its country of residence, incorporation or activity in connection with its use of the System, and shall be liable for any breach of such law caused by its use of the System.","parentId":null},{"id":194,"content":"15.2  **Indemnity.** The Customer shall, on first written demand, indemnify and hold harmless the Administrator, its affiliates and their respective officers, directors, employees, agents, Financial Partners and contractors against any claims, liabilities, fines, penalties, damages, losses, costs and reasonable expenses (including reasonable legal and professional fees, and the full amount of any Chargeback, dispute or network assessment) arising out of or related to: (i) the Customer’s business operations, advertising, content, products or services; (ii) the Customer’s use or misuse of the System, the PSTNET Card or any Transaction; (iii) the Customer’s breach of these Terms, the Internal Policies or Applicable Law; (iv) any claim by a third party that the Customer’s content, targeting or product infringes or violates such third party’s rights; and (v) any audit, investigation or enforcement action by any governmental, regulatory or tax authority relating to the Customer’s activity. This indemnity shall survive termination of these Terms; it shall not apply to the extent that such claims arise out of the Administrator’s own fraud or wilful misconduct.","parentId":null},{"id":195,"content":"15.3  **DISCLAIMERS.** TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SYSTEM AND THE SYSTEM SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE”, WITHOUT WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, AVAILABILITY, ACCURACY OR UNINTERRUPTED OR ERROR-FREE OPERATION. THE ADMINISTRATOR DOES NOT WARRANT THAT ANY PAYMENT WILL BE AUTHORIZED, THAT ANY PARTICULAR MERCHANT WILL ACCEPT A PSTNET CARD, OR THAT ANY ADVERTISING PLATFORM WILL PERMIT THE USE OF A PSTNET CARD.","parentId":null},{"id":196,"content":"15.4  **EXCLUDED DAMAGES.** TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, NEITHER PARTY SHALL BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFIT, REVENUE, GOODWILL, OPPORTUNITY, DATA OR BUSINESS INTERRUPTION, ARISING OUT OF OR RELATING TO THESE TERMS OR THE SYSTEM SERVICES, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), BREACH OF STATUTORY DUTY OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.","parentId":null},{"id":197,"content":"15.5  **LIABILITY CAP.** SUBJECT TO CLAUSE 15.7, THE ADMINISTRATOR’S AGGREGATE LIABILITY TO THE CUSTOMER UNDER OR IN CONNECTION WITH THESE TERMS, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE) OR OTHERWISE, SHALL NOT EXCEED THE GREATER OF (I) THE TOTAL FEES PAID BY THE CUSTOMER TO THE ADMINISTRATOR IN THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE FIRST EVENT GIVING RISE TO THE CLAIM OR SERIES OF RELATED CLAIMS, AND (II) ONE THOUSAND UNITED STATES DOLLARS (USD 1,000).","parentId":null},{"id":198,"content":"15.6  **Third-party causes.** The Administrator shall not be liable for any interruption, delay, failure, error, loss or damage caused by any Financial Partner or other third party, including the Issuer, issuing banks, card networks, acquirers, processors, exchanges, advertising platforms, blockchain networks, telecommunications providers or hosting providers. In particular, subject to clause 15.7 and to any mandatory consumer-protection law, the Administrator shall not be liable for loss or damage resulting from:\n\n- the Customer transferring data to any third party, deliberately providing access to its Wallet or Account, or otherwise disclosing Authorization Details to a third party or failing to keep them confidential, save where the Customer has complied with clause 6.7;\n- unlawful activities of any third party, including activities involving the use of the Customer’s registration data, email, Authorization Details or other credentials, where such use is not caused or contributed to by the Administrator;\n- the presence of any virus, malware, stalkerware or other malicious software on the hardware or software used by the Customer to access the System;\n- disputes pertaining to any Transactions between Customers made through the System, or between the Customer and a merchant or any other third party;\n- violation of Applicable Law by the Customer in relation to the use of the System, and any claim, complaint, audit, investigation or enforcement action brought against the Customer by a tax, regulatory or law-enforcement authority regarding reporting documentation, taxation or other matters relating to the Customer’s Transactions;\n- the Customer not having access to the software or hardware that enables use of the System;\n- the Administrator’s inability to reach the Customer via the Contact Details, in particular because the Customer has provided unreliable data or has failed to update it in a timely manner;\n- any payment service provided to the Customer by a third party (including the Issuer, card schemes, acquiring banks, digital-asset service providers or other payment processors);\n- any acts or omissions of third parties whose websites or services the Customer accessed by following a link, integration or piece of information made available through the Website or the System;\n- temporary inoperability of the System, or malfunctions or errors in the operation of hardware or software (including interruption or damage to electricity supply, communications or payment-system networks, software malfunctions, interruption of mail services, outages affecting an internet service provider, a payment-system operator or another third-party network), in each case not through the Administrator’s fault; or\n- a Force Majeure Event.","parentId":null},{"id":393,"content":"15.7  **Unexcludable liability.** Nothing in these Terms limits or excludes the liability of either Party for (i) fraud or fraudulent misrepresentation, (ii) death or personal injury caused by negligence, (iii) any liability that cannot be limited or excluded under Applicable Law, or (iv) in the case of the Customer, any outstanding Fees, Chargebacks or Transaction-related amounts due to the Administrator.","parentId":null},{"id":394,"content":"15.8  **Consumer rights.** Where the Customer is a consumer under mandatory law, nothing in these Terms shall affect the Customer’s statutory rights.","parentId":null},{"id":395,"content":"15.9  **Default interest.** If the Customer defaults on a payment obligation to the Administrator, the Administrator may charge default interest at the statutory rate applicable under the governing law of these Terms, or at such other rate as is permitted under Applicable Law. Interest shall accrue from the due date until the date of actual payment.","parentId":null},{"id":396,"content":"15.10  **System availability.** The Administrator shall use reasonable endeavours to ensure the continuous availability of the System, but does not guarantee uninterrupted or error-free operation. The Administrator may perform scheduled maintenance, announced in advance where reasonably practicable, during which some or all System Services may be unavailable.","parentId":null}]},{"id":15,"__component":"ui.list","type":null,"title":"Acceptable Use; Prohibited Activities; Anti-Circumvention","isolated":null,"item":[{"id":200,"content":"16.1  **Acceptable use.** The Customer shall use the System, the PSTNET Card and any other System Service only for lawful business purposes permitted under these Terms, the Internal Policies (including the Restrictions), Applicable Law and the rules of the relevant card scheme and Financial Partners. The System Services are provided exclusively for business use — including media buying, marketing tools, advertising-platform funding and related business expenditure — and not for personal, consumer or household use, regardless of whether the Customer is an Individual Customer or a Business Customer.","parentId":null},{"id":397,"content":"16.2  **Prohibited Activities.** The Customer shall not use the System, the PSTNET Card or any other System Service:\n\n- in connection with any activity that constitutes a criminal offense or otherwise violates Applicable Law in the Customer’s country of residence or incorporation, or in any country where the Transaction is initiated, processed or received;\n- in connection with the sale or distribution of any goods, works or services listed in Appendix 1;\n- in connection with any Restricted Jurisdiction, or with any sanctioned person, entity, vessel or aircraft;\n- to carry out, facilitate or conceal money laundering, terrorist financing, proliferation financing, fraud, tax evasion or other financial crime;\n- to circumvent the rules of any card scheme, payment network or advertising platform, or to evade bans, restrictions, Merchant Category Code controls or risk controls imposed by such third parties;\n- to impersonate the Administrator or any other person, to submit falsified Transaction IDs, Wallet IDs, screenshots or other materials, or to create clones of, or misleading references to, the Website;\n- to damage the reputation of the Administrator, including by making materially misleading public statements about the Administrator or the System Services;\n- to test, probe, scan, reverse engineer, decompile, stress, overload or otherwise compromise the integrity or availability of the System;\n- for personal, consumer or household purposes (the System Services are provided exclusively for business use, including media buying, marketing tools and related business expenditure, regardless of the Customer’s category); or\n- in any manner that contradicts generally accepted standards of ethics and morality.","parentId":null},{"id":398,"content":"16.3  **Anti-circumvention.** The Customer shall not, directly or indirectly, contact, solicit, engage with, onboard with or otherwise attempt to establish a relationship with any Financial Partner (including the Issuer, any BIN sponsor, any programme manager, any card scheme, any acquiring bank or any on-ramp/off-ramp provider) introduced to the Customer through the System, for the purpose of replicating, substituting for or circumventing the System Services, without the Administrator’s prior written consent. This clause 16.3 shall survive termination of these Terms for a period of two (2) years.","parentId":null},{"id":399,"content":"16.4  **Multiple Accounts.** The Customer shall not register multiple Accounts. If the Administrator identifies duplicate Accounts linked to the same individual or entity, it may, acting reasonably, suspend or terminate all such Accounts and mark related Transactions as fraudulent.","parentId":null},{"id":400,"content":"16.5  **Transaction monitoring.** The Administrator operates real-time transaction monitoring and may request additional information, block Transactions or report suspicious activity to competent authorities as required by the AML Policy and Applicable Law. The Customer shall comply with such requests promptly.","parentId":null},{"id":401,"content":"16.6  **Source of funds and source of wealth.** Without limiting clause 8.5, the Administrator may at any time — whether before, during or after Transactions — request the Customer to provide documentation and information evidencing the source of funds and, where applicable, the source of wealth used to fund the Account, together with any supporting documentation (including bank statements, payout confirmations from advertising networks or affiliate programs, invoices, contracts, tax returns, financial statements and evidence of ownership of the originating account or wallet). The Administrator may decline, freeze, return, delay or reverse any Transaction, or apply a Suspension of Account, pending receipt of satisfactory evidence. The Customer shall respond to any such request promptly and in any event within the period specified by the Administrator.","parentId":null}]},{"id":16,"__component":"ui.list","type":null,"title":"Suspension of Account","isolated":null,"item":[{"id":201,"content":"17.1  **Grounds for Suspension.** The Administrator, at its sole discretion and without prior notification of the Customer, may apply a Suspension of Account where any of the following circumstances arises:\n\n- objectively justified reasons relating to the security of the Account, the System or any Financial Partner’s infrastructure;\n- the Administrator reasonably suspects unauthorized or fraudulent use of the Account;\n- the activities of the Customer are suspicious or are, or appear to be, in conflict with these Terms, the Internal Policies, any other agreement between the Customer and the Administrator, or Applicable Law;\n- the Administrator reasonably suspects fraud, money laundering, terrorist financing, sanctions evasion or other Prohibited Activity;\n- authorization decline rates, dispute rates, Chargeback rates or suspicious-activity patterns exceed thresholds set by the Administrator or any Financial Partner;\n- the Customer’s activity poses financial, compliance, operational, reputational or BIN-reputation risk to the Administrator or any Financial Partner, or the actions of the Customer could harm the reputation of the Administrator or cause losses or other negative consequences to the Administrator;\n- a Financial Partner instructs the Administrator to restrict or terminate the Customer’s access;\n- Suspension is required by a court order, by a regulatory request, by command of a competent authority, or by Applicable Law;\n- the Account is the subject of a governmental proceeding, criminal investigation or other pending litigation;\n- the Customer has failed to confirm that the documents and data previously provided remain accurate, complete and up-to-date, or has failed to provide additional documents or data upon request, under clause 5.6;\n- the Customer has created multiple Accounts in violation of clause 16.4; or\n- the Account is a Dormant Account.","parentId":null},{"id":202,"content":"17.2  **Notification.** Where lawful to do so, the Administrator shall notify the Customer of the Suspension of Account and the reason therefor via the email address registered in the System. Where notification would be unlawful (for example, because it would tip off a suspect under AML rules) or would pose a security risk, the Administrator may defer or omit the notification.","parentId":null},{"id":203,"content":"17.3  **Lifting.** The Administrator shall lift the Suspension as soon as reasonably practicable after the reasons giving rise to it have ceased to exist. Where the Suspension arises from a third-party or regulatory instruction, the timing of lifting shall be determined by that instruction.","parentId":null},{"id":204,"content":"17.4  **During Suspension.** During a Suspension, the Customer remains liable for the performance of any obligations that accrued before the Suspension took effect. The Administrator is not liable for losses that the Customer may incur as a result of a Suspension imposed in accordance with this Section 17.","parentId":null},{"id":205,"content":"17.5  **Partial suspension.** The Administrator may also restrict, suspend or disable specific Wallets, PSTNET Cards or features (instead of the whole Account) where reasonably necessary to address operational, compliance, risk or infrastructure requirements.","parentId":null}]},{"id":17,"__component":"ui.list","type":null,"title":"Term, Termination, Refunds and Settlement Reserve","isolated":null,"item":[{"id":208,"content":"18.1  **Term.** These Terms enter into force at the moment the Applicant clicks the “Register” button and are concluded for an indefinite term. They remain in force until terminated in accordance with this Section 18.","parentId":null},{"id":209,"content":"18.2  **Termination by Customer.** The Customer may terminate these Terms at any time by deleting the Account from the Account dashboard or by written notice to Customer Support, provided that the Customer has no outstanding Payment Orders, PSTNET Card balances, pending settlements or other obligations to the Administrator. Upon termination by the Customer, the Customer shall withdraw the remaining Funds, net of any applicable deductions under clause 18.6, within a reasonable period by providing the payment details required by the Administrator.","parentId":null},{"id":402,"content":"18.3  **Termination by Administrator for convenience.** The Administrator may terminate these Terms for convenience by giving the Customer at least two (2) months’ prior written notice, sent to the email address registered in the System.","parentId":null},{"id":403,"content":"18.4  **Termination by Administrator for cause.** The Administrator may terminate these Terms with immediate effect and close the Account where:\n\n- the Customer has materially breached these Terms, the Internal Policies or Applicable Law, and (where the breach is capable of remedy) has failed to remedy the breach within fourteen (14) days of a written notice requiring it to do so;\n- the Customer, or any of its Beneficial Owners, directors or Authorized Representatives, is listed on an applicable Sanctions list, or the continuation of the relationship would cause the Administrator to breach Sanctions or Applicable Law;\n- the Customer is using the System in connection with any Prohibited Activity;\n- a Financial Partner has required the Administrator to terminate the Customer’s access;\n- the Customer becomes insolvent, enters into administration, liquidation, receivership or an equivalent process, or is unable to pay its debts as they fall due;\n- the Account has remained suspended under Section 17 for more than twelve (12) consecutive months; or\n- the Customer objects to an amendment of these Terms in accordance with clause 20.2, in which case termination takes effect on the date on which the amendment enters into force.","parentId":null},{"id":404,"content":"18.5  **Forfeiture of Fees on termination for cause.** Where the Administrator terminates these Terms under clause 18.4, or otherwise closes the Account following a breach of these Terms or the Internal Policies by the Customer, the Customer shall forfeit all rights to refund of Fees, subscription payments, cashback accruals or any other remuneration already paid or accrued to the Administrator in respect of System Services rendered prior to termination, and all such amounts shall be retained by the Administrator as earned. This clause 18.5 does not permit the Administrator to retain Collateral, Funds or prefunded card balances beyond the amounts genuinely and reasonably required to satisfy (i) outstanding Fees, (ii) Chargebacks, reversals, fraud claims and network costs attributable to the Customer, (iii) any Settlement Reserve under clause 18.8, (iv) any indemnity due under clause 15.2, and (v) any other quantified amount owed to the Administrator; any remaining balance shall be refunded to the Customer in accordance with clause 18.6. Customers are encouraged to review these Terms and the Internal Policies regularly to ensure continued compliance and to avoid potential Account termination and forfeiture of Fees.","parentId":null},{"id":405,"content":"18.6  **Refund of remaining Funds.** Upon termination of these Terms, any unused Funds remaining in the Wallet (after any forfeiture under clause 18.5) may be refunded to the Customer, net of (a) any applicable Fees and amounts owed to the Administrator; (b) any Chargebacks, reversals, refunds and network costs attributable to the Customer; (c) any amount retained as Settlement Reserve under clause 18.8; and (d) any exchange-rate adjustment to reflect the rate displayed in the System at the time of withdrawal. Refunds will, where reasonably practicable, be issued to the same bank account or blockchain address from which the relevant Collateral was originally received; the Administrator may refuse to refund to any other destination and may convert between fiat and Digital Currency where reasonably necessary.","parentId":null},{"id":406,"content":"18.7  **Refund processing conditions.** Before a refund can be processed: (i) all PSTNET Cards associated with the Account must be closed, and all pending authorizations, settlements and disputes must be finalized; (ii) a minimum settlement period of thirty (30) days shall elapse from the date the final PSTNET Card was closed, to allow for delayed settlements, reversals and Chargebacks; and (iii) the Customer must have provided any information or documents reasonably requested by the Administrator or a Financial Partner to complete the refund in accordance with the AML Policy and Applicable Law.","parentId":null},{"id":407,"content":"18.8\t**Settlement Reserve.** The Administrator may retain a Settlement Reserve for a reasonable period following termination (typically up to one hundred and eighty (180) days) to account for delayed settlement events, reversals, Chargebacks, fraud claims, network fees and related adjustments. The Settlement Reserve shall be released to the Customer, net of any amounts due to the Administrator, once the reserve period has expired without incident. ","parentId":null},{"id":408,"content":"18.9  **Unclaimed Funds.** Where Funds remain in a closed or long-suspended Account and the Administrator has made reasonable efforts (including two written reminders sent to the Customer’s last known email address, no less than sixty (60) days apart) to return those Funds to the Customer, but the Funds remain unclaimed for a period of six (6) years from the date of the Suspension or termination giving rise to the unclaimed status, the Administrator may treat those Funds in accordance with the law applicable to unclaimed balances in the Turks and Caicos Islands or under any other applicable escheatment or dormancy law, without prejudice to the Customer’s right to reclaim such Funds where such right is preserved under Applicable Law.","parentId":null},{"id":409,"content":"18.10  **Record retention.** Upon termination of these Terms, the Administrator shall retain Account and Transaction data as required by the AML Policy, the Privacy Policy and Applicable Law (typically for a period of five (5) years from the date of termination, or such longer period as is required by Applicable Law).","parentId":null},{"id":410,"content":"18.11  **Survival.** Termination of these Terms does not affect any rights or obligations that have accrued before the date of termination, and does not affect provisions which by their nature are intended to survive termination (including Sections 10, 14, 15, 16.3, 18, 19, 21 and 23).","parentId":null},{"id":483,"content":"18.12 **Dormant Accounts.** An Account is \"Inactive\" if, for a continuous period of more than three hundred and sixty-five (365) days, the Customer has not logged in to the Account and no Transaction (including funding of any Wallet, successful PSTNET Card Transaction, internal transfer, withdrawal or other Customer-initiated activity) has been executed through the Account. Where an Account has become Inactive, the Administrator may, in its reasonable discretion: (a) temporarily lock the Account; and (b) transfer the remaining Funds in the Wallets to a separate non-customer-facing ledger maintained by the Administrator for the purpose of holding balances of Inactive Accounts (the \"Dormancy Holding Account\"). The Administrator shall use reasonable efforts to notify the Customer of the impending lock and transfer by email to the address registered in the Account at least thirty (30) days before the lock takes effect, but the lock and transfer shall not be invalidated by any failure of such notification (including bounced email or unread messages). The transfer of Funds to the Dormancy Holding Account does not constitute custody, escrow, trust or safeguarding of Customer funds in any regulated sense (consistent with clauses 3.5 and 8.3 of these Terms); it is an internal book-entry measure for the orderly handling of Inactive Accounts. While the Account is locked under this clause 18.12, no Transactions may be executed, no PSTNET Cards may be issued or used, and no Account features will be accessible to the Customer. The Customer may reactivate the Account at any time within a reasonable period (and in any event before the Funds become Unclaimed Funds under clause 18.9) by contacting the Administrator and completing an updated Verification in accordance with Section 5 of these Terms and the AML Policy; on successful reactivation, the locked Funds will be transferred back from the Dormancy Holding Account to the Customer's Wallets, net of any Fees, Chargebacks, reversals or other amounts owed to the Administrator. Where reactivation cannot be completed (for example, because the Customer cannot be reached, Verification cannot be successfully completed, or the Customer has become subject to Sanctions or other circumstances that prevent the Administrator from re-establishing the business relationship), the Funds shall continue to be held in the Dormancy Holding Account and shall be subject to clause 18.9 in due course. Nothing in this clause 18.12 affects the Administrator's rights under Section 17 (Suspension), Section 18.4 (Termination by Administrator for cause), or any other provision of these Terms.","parentId":null}]},{"id":18,"__component":"ui.list","type":null,"title":"Confidentiality and Intellectual Property","isolated":null,"item":[{"id":210,"content":"19.1  **Confidentiality.** Each Party shall keep confidential all non-public information of the other Party disclosed in connection with these Terms, including commercial terms, technical information, Customer data and business plans (“Confidential Information”). Confidential Information may be disclosed only (i) to a Party’s personnel, affiliates, Financial Partners and professional advisers who need to know it and are bound by equivalent confidentiality obligations; (ii) as required by Applicable Law or by a competent authority; or (iii) to the extent the information is already in the public domain through no breach of these Terms. This clause does not limit the Administrator’s right to share Customer data with Financial Partners, authorities and other recipients as described in the Privacy Policy.","parentId":null},{"id":211,"content":"19.2  **Intellectual property.** As between the Parties, all intellectual-property rights in and to the System, the Website, the Account dashboard, PST Pulse, the Administrator’s software, databases, content, trademarks, logos, documentation and any derivative works thereof are and shall remain the exclusive property of the Administrator or its licensors. The Customer is granted a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the System solely for the purposes contemplated by these Terms. The Customer shall not copy, modify, reverse-engineer, decompile, distribute, republish, create derivative works from or sub-license any part of the System, save to the extent such restriction is expressly prohibited by Applicable Law.","parentId":null}]},{"id":32,"__component":"ui.list","type":null,"title":"Amendments","isolated":null,"item":[{"id":411,"content":"20.1  The Administrator may amend these Terms and the Internal Policies from time to time. Material amendments shall be notified to the Customer at least two (2) months before they take effect, by (i) posting an informational message inside the Account dashboard and (ii) sending an email to the address registered in the System. The notice shall indicate the scheduled effective date and make available the updated text.","parentId":null},{"id":412,"content":"20.2  The Customer may object to a notified amendment by contacting Customer Support before the scheduled effective date. An objection operates as notice of termination by the Customer, and these Terms shall terminate on the date on which the amendment would otherwise have entered into force. No fees or penalties shall apply to such termination, and the Customer shall be entitled to withdraw its remaining Funds in accordance with Section 18.","parentId":null},{"id":413,"content":"20.3  Continued use of the System Services after the effective date of an amendment constitutes acceptance of the updated Terms.","parentId":null},{"id":414,"content":"20.4  The two-month notice period in clause 20.1 does not apply to (i) amendments required by law, regulation or an order of a competent authority, which may take effect as required by that law, regulation or order; (ii) amendments addressing a material security, fraud or compliance risk, which may take effect immediately with notice to the Customer as soon as reasonably practicable; and (iii) amendments that are purely in the Customer’s favor, such as reductions in Fees or improved cashback, which may take effect immediately.","parentId":null}]},{"id":51,"__component":"ui.list","type":null,"title":"Governing Law and Jurisdiction","isolated":false,"item":[{"id":415,"content":"21.1  These Terms, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them, their subject matter or their formation, are governed by and shall be construed in accordance with the laws of the Turks and Caicos Islands.","parentId":null},{"id":416,"content":"21.2  The Parties shall first attempt to resolve any dispute by good-faith negotiations. Either Party may initiate the negotiation process by sending a written complaint (including a description of the dispute and the relief sought) to the other Party, using the Administrator’s Contact Details in the case of complaints addressed to the Administrator. Each Party shall review and respond to such complaints within thirty (30) days of receipt.","parentId":null},{"id":417,"content":"21.3  If the dispute is not resolved through negotiations within sixty (60) days of the initial complaint, the courts of the Turks and Caicos Islands shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms, their subject matter or their formation (including non-contractual disputes or claims). The Parties irrevocably submit to the exclusive jurisdiction of those courts. This clause 21.3 operates subject to clause 21.4.","parentId":null},{"id":418,"content":"21.4  Nothing in clauses 21.1 or 21.3 deprives a Customer who is a consumer of the protection of mandatory consumer-protection rules of the law of the country in which the Customer habitually resides, including the right to bring proceedings in, or to have the dispute decided under the law of, that country where Applicable Law so permits.","parentId":null}]},{"id":52,"__component":"ui.list","type":null,"title":"Force Majeure","isolated":false,"item":[{"id":419,"content":"22.1  Neither Party shall be liable for any failure to perform, or delay in performing, its obligations under these Terms (other than an obligation to pay money) to the extent that such failure or delay is caused by an event beyond that Party’s reasonable control, including acts of God, acts of civil or military authorities, civil disturbances, strikes or other labour disputes, fires, transportation incidents, interruptions in telecommunications, utilities, internet or network-provider services, acts or omissions of third parties (including denial-of-service attacks, infiltration of services and outages of card schemes or banking partners), cyber incidents, and software viruses or similar intentionally disruptive code (each a “Force Majeure Event”).","parentId":null},{"id":420,"content":"22.2  The Party affected by a Force Majeure Event shall notify the other Party of the event, its expected impact and its anticipated duration within ten (10) days of the commencement of the event, and shall use reasonable endeavors to mitigate the impact of the event.","parentId":null},{"id":421,"content":"22.3  A Force Majeure Event does not release the Customer from payment obligations (including Fees, Chargebacks, interest and indemnities) or from the obligation to return goods, property or services after the Force Majeure Event has ended.","parentId":null}]},{"id":53,"__component":"ui.list","type":null,"title":"23. Miscellaneous","isolated":false,"item":[{"id":422,"content":"23.1  **Communication.** The Administrator and the Customer communicate in English. The Administrator may, at its discretion, provide additional language versions on the Website for convenience; in the event of any inconsistency between language versions, the English version prevails. Notices may be delivered by email to the address associated with the Account, via the Account dashboard, via verified support channels on electronic messaging platforms designated by the Administrator from time to time, or by any other written electronic means agreed between the Parties.","parentId":null},{"id":423,"content":"23.2  **Electronic documents and signatures.** Document flow between the Customer and the Administrator takes place in electronic form via the Account. Entering valid Authorisation Details is deemed equivalent to the Customer’s handwritten signature for the purposes of these Terms, save where Applicable Law requires a specific form.","parentId":null},{"id":424,"content":"23.3  **Assignment.** The Customer may not assign, transfer, sub-contract or encumber any rights or obligations under these Terms without the prior written consent of the Administrator. The Administrator may assign these Terms, in whole or in part, to an affiliate or to a successor in connection with a reorganization or sale of all or a substantial part of the Administrator’s business, provided that such assignment does not reduce the Customer’s rights under these Terms.","parentId":null},{"id":425,"content":"23.4  **Severability.** If any provision of these Terms is held to be invalid, illegal or unenforceable, that provision shall be deemed modified to the minimum extent necessary to render it enforceable or, failing that, severed from these Terms. The remaining provisions shall continue in full force and effect.","parentId":null},{"id":426,"content":"23.5  **No waiver.** No failure or delay by either Party in exercising any right or remedy under these Terms shall operate as a waiver of that right or remedy, nor shall any single or partial exercise of any right or remedy prevent any further exercise of that right or any other right.","parentId":null},{"id":427,"content":"23.6  **No partnership; Administrator not responsible for Customer’s business.** The Parties are independent contractors. Nothing in these Terms creates any partnership, joint venture, agency, employment or fiduciary relationship between the Administrator and the Customer, and neither Party has authority to bind the other, to make representations on the other’s behalf, or to incur liabilities in the other’s name. The Administrator is not a partner, agent, joint-venturer or principal in, and does not participate in, the Customer’s business. The Administrator has no responsibility for, and does not endorse, guarantee, warrant or assume liability in respect of, the Customer’s business model, business strategy, business activities, advertising content, marketing practices, products, services, counterparties, suppliers, end-customers, profits, losses, operational outcomes, compliance with laws applicable to the Customer, or any dispute between the Customer and any third party. The Customer is solely responsible for the Customer’s business and for the lawfulness, accuracy, quality and commercial outcome of the Customer’s activities, regardless of whether those activities are conducted using the System.\nThe Administrator has no association, affiliation, endorsement, sponsorship, joint venture, agency or other relationship of any kind with any third-party platform, merchant, advertising network, social-media service, e-commerce marketplace or other counterparty at which the Customer may use the PSTNET Card or the System. Any product name, card designation, marketing description or dashboard label that references a Third-Party Platform is used solely to describe the intended use case, MCC configuration or platform-payment scenario for which the card has been optimised, and does not indicate any partnership, endorsement, licensing arrangement, technical integration or other relationship between the Administrator and the Third-Party Platform. All third-party names, logos, trademarks, service marks and other proprietary designations remain the property of their respective owners and are used only for nominative, descriptive purposes. Any recommendations, suggestions, guidance or information that the Administrator may provide to the Customer regarding Merchant Category Codes, Third-Party Platforms, campaign types, ad accounts or other operational choices (whether through the Website, the dashboard, customer-support communications or otherwise) are informational only, are provided as a courtesy without warranty of any kind, and do not constitute (i) endorsement of, or a recommendation to use, any particular Third-Party Platform, (ii) advice on the Customer’s business, marketing or commercial strategy, or (iii) any assumption of responsibility by the Administrator for the Customer’s choice of platform, MCC, campaign, creative, targeting, budget or outcome. The Customer’s contractual relationship with any Third-Party Platform is exclusively between the Customer and that Third-Party Platform, and is governed by that platform’s own terms of service, advertising policies and community standards. The Administrator is not a party to that relationship, has no ability to influence the Third-Party Platform’s decisions in respect of the Customer’s account, campaigns or content, and has no liability for the Third-Party Platform’s acts or omissions (including account suspensions, ad rejections, refund decisions, policy changes, service interruptions or any other action taken by the Third-Party Platform).","parentId":null},{"id":428,"content":"23.7  **Third-party rights.** Except for Financial Partners and other persons entitled to enforce the indemnity in clause 15.2 or the limitations in clause 15.3 to 15.6 directly, a person who is not a Party has no right to enforce any term of these Terms. The Parties may rescind or vary these Terms without the consent of any third party.","parentId":null},{"id":429,"content":"23.8  **Entire agreement.** These Terms, together with the Internal Policies and any additional terms expressly referenced in them (including the Rates), constitute the entire agreement between the Administrator and the Customer in relation to the System Services and supersede any prior understanding, agreement, representation or statement on the same subject matter.","parentId":null},{"id":430,"content":"23.9  **Appendices.** Any appendix to these Terms forms an integral part of these Terms.","parentId":null},{"id":431,"content":"23.10  **Acknowledgement.** The Customer acknowledges that the Customer has read and understood these Terms and the Internal Policies, that the provisions hereof are clear, and that the Customer agrees to be bound by them.","parentId":null}]},{"id":127,"__component":"ui.paragraph","content":"The Customer may not use the System, the PSTNET Card or any other System Service in connection with the sale, purchase, distribution, promotion or financing of the goods, works or services listed below. The list is non-exhaustive and may be supplemented by the Administrator from time to time by publication on the Website.\n","title":"Appendix 1. List of Prohibited Goods, Works and Services"},{"id":33,"__component":"ui.list","type":"disc","title":null,"isolated":null,"item":[{"id":218,"content":"Weapons, arms, ammunition and defense products; firearms, replicas of firearms and cold-steel weapons.","parentId":null},{"id":219,"content":"Illegal drugs, drug-like substances and plants (including marijuana and cannabis where such sale is illegal in the relevant jurisdiction), their precursors and ingredients, and instructions or descriptions of methods for their production.","parentId":null},{"id":220,"content":"Prescription-only medicines and medical devices, and raw materials or instructions for their unauthorized production.","parentId":null},{"id":221,"content":"State awards, military decorations and official distinguishing badges.","parentId":null},{"id":222,"content":"Identification documents and government-issued documents (including falsified documents), and anything connected with the creation, sale or obtaining of false or counterfeit identification or government-issued documents.","parentId":null},{"id":223,"content":"Uniforms of government agencies, police or armed forces.","parentId":null},{"id":224,"content":"Specialty items restricted to police, military or other law-enforcement agencies.","parentId":null},{"id":225,"content":"Electronic equipment whose sale or use is prohibited in the country or region where the Transaction is made.","parentId":null},{"id":226,"content":"Devices used for hacking, tampering with locks, skimming or similar unlawful purposes.","parentId":null},{"id":227,"content":"Personal data, databases or information suitable for carrying out unlawful activities (including bulk spam lists).","parentId":null},{"id":228,"content":"Information or materials containing state, banking or trade secrets.","parentId":null},{"id":229,"content":"Goods, works or services whose sale infringes any third party’s copyright, related rights, trademark rights or patents.","parentId":null},{"id":230,"content":"Information that violates a person’s privacy or dignity, or that infringes upon the honour, dignity or business reputation of individuals or legal entities.","parentId":null},{"id":231,"content":"Archaeological heritage items and items of artistic or historical value that constitute cultural property of a country under Applicable Law.","parentId":null},{"id":232,"content":"Precious metals, where the seller is not authorized to trade in them under Applicable Law.","parentId":null},{"id":233,"content":"Items or services that violate public morality, including child sexual abuse material, Nazi or other extremist memorabilia, escort services, prostitution and adult content where prohibited by Applicable Law.","parentId":null},{"id":234,"content":"Items with serial numbers that have been removed, defaced or altered.","parentId":null},{"id":235,"content":"Online gambling, betting, casino operations and lotteries, where provided without the necessary license in the relevant jurisdiction.","parentId":null},{"id":236,"content":"Malicious software, spyware, stalkerware or similar code.","parentId":null},{"id":237,"content":"Goods or services that directly or indirectly incite unlawful acts, including the promotion of social, racial, religious or ethnic hatred, discrimination, violence, harassment, or the propaganda of terrorism or physical harm.","parentId":null},{"id":238,"content":"Perishable goods requiring temperature-controlled logistics not supported by the relevant payment method.","parentId":null},{"id":239,"content":"Counterfeit or fake goods.","parentId":null},{"id":240,"content":"Items and equipment intended for the unlawful circumvention of copyright protection or regional restrictions (including software or devices designed to remove technical protection measures).","parentId":null},{"id":241,"content":"Dangerous goods, including explosives, toxic, poisonous, flammable or radioactive materials.","parentId":null},{"id":242,"content":"Information about the production of explosives, pyrotechnic, incendiary or other similarly dangerous substances or devices.","parentId":null},{"id":243,"content":"Human organs, human remains and tissues.","parentId":null},{"id":244,"content":"Goods or services that have no value in use and are structured so as to facilitate financial fraud or money laundering.","parentId":null},{"id":245,"content":"Goods or services that have no value in use and are structured so as to facilitate financial fraud or money laundering.","parentId":null},{"id":246,"content":"Financial or payment instruments whose accounting systems do not ensure proper identification of the owner, where such identification is required for the purpose of combating illegal trade, financial fraud or money laundering.","parentId":null},{"id":247,"content":"Asset-management and investment services provided by unlicensed businesses, and any intermediary activity facilitating the transfer of funds between parties entering into a transaction prohibited under this Appendix 1.","parentId":null}]},{"id":233,"__component":"ui.paragraph","content":"**Contact**\n\nADV Summit Advisors Limited\n\nSuite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands\n\nEmail: customersupport@pst.net ","title":null}]}},{"id":8,"attributes":{"title":"Cookie policy","createdAt":"2023-03-26T20:39:42.579Z","updatedAt":"2026-04-24T16:36:53.438Z","publishedAt":"2023-03-26T20:39:44.221Z","slug":"cookie","position":4,"tosType":null,"content":[{"id":50,"__component":"ui.paragraph","content":"1.1\tThis Cookie Policy explains how ADV Summit Advisors Limited (the “Administrator”, “PSTNET”, “we”, “us” or “our”) uses cookies and similar technologies on the website located at https://pst.net and its sub-domains (including blog.pst.net and pulse.pst.net) (together, the “Website”), and in the Administrator’s browser extension and customer dashboard (together with the Website, the “System”). ","title":"Who We Are and Scope of This Policy "},{"id":51,"__component":"ui.paragraph","content":"1.2\tThe Administrator is the data controller in respect of personal data processed through cookies and similar technologies deployed on the System. Our registered office is at Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands. ","title":null},{"id":52,"__component":"ui.paragraph","content":"1.3\tThis Cookie Policy is an Internal Policy and forms an integral part of the Terms of Service published at https://pst.net/legal/tos  (the “Terms”). It should be read together with the Privacy Policy published at https://pst.net/legal/privacy  (the \n“Privacy Policy”), which describes in more detail how we process personal data, the legal bases of processing, international transfers, retention periods and the rights of data subjects. Capitalised terms used but not defined in this Cookie Policy have the meaning given to them in the Terms. ","title":null},{"id":53,"__component":"ui.paragraph","content":"1.4\tFor questions about this Cookie Policy or the use of cookies on the System, please contact our Data Protection Officer at dpo@pst.net. ","title":null},{"id":54,"__component":"ui.paragraph","content":"2.1\tCookies are small text files that are placed on your device (computer, laptop, smartphone, tablet or other connected device) by the website, application or service you use. Cookies are stored in your browser’s storage and are sent back to the originating site (or to a third party that set them) each time you revisit the site, so that the site can recognise your device, remember your preferences and measure how you interact with the site. ","title":"What Are Cookies and Similar Technologies? "},{"id":55,"__component":"ui.paragraph","content":"2.2\tWhere we refer to “cookies” in this Cookie Policy, we also mean comparable technologies that store or access information on your device, including web beacons, pixel tags, local storage (LocalStorage, SessionStorage), IndexedDB, software development kits (SDKs), fingerprinting techniques and similar technologies. The same rules apply regardless of the specific technology used. ","title":null},{"id":56,"__component":"ui.paragraph","content":"2.3\n\n-\tBy origin: “first-party” cookies are set by the Website itself (pst.net domain). “Third-party” cookies are set by a different domain (for example, an analytics or advertising provider we work with). \n-\tBy duration: “session” cookies are deleted when you close your browser. “Persistent” cookies remain on your device for a defined period or until you delete them. ","title":null},{"id":57,"__component":"ui.paragraph","content":"3.1\tThe placing of cookies and the reading of information from your device are regulated under the ePrivacy framework (in the European Union, Directive 2002/58/EC as transposed into national law; in the United Kingdom, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”)). Any personal data collected through cookies is additionally processed in accordance with Regulation (EU) 2016/679 (“EU GDPR”), the United Kingdom General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, as applicable to each user depending on their location. ","title":"Legal Framework "},{"id":58,"__component":"ui.paragraph","content":"3.2\tUnder this framework, cookies that are strictly necessary for the delivery of a service requested by the user do not require prior consent. All other cookies (performance, functional and targeting) require the user’s prior, freely given, specific, informed and unambiguous consent, which can be withdrawn at any time and must be as easy to withdraw as to give. ","title":null},{"id":59,"__component":"ui.paragraph","content":"4.1\tThe first time you visit the Website, you will see a cookie banner. Through the banner and the Cookie Settings panel, you can accept all cookies, reject all non-essential cookies, or make granular choices by category. Strictly necessary cookies are always active, as they are required for the Website to function. ","title":"Consent and Your Control "},{"id":60,"__component":"ui.paragraph","content":"4.2\tYou can change your cookie choices at any time by opening the Cookie Settings panel available from the cookie banner and via the “Cookie Settings” link in the Website footer. Withdrawing consent is as easy as giving it; withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal. ","title":null},{"id":61,"__component":"ui.paragraph","content":"4.3\tYou can also manage cookies directly through your browser settings, including deleting cookies already stored on your device and blocking new cookies from being placed. Instructions vary by browser; most browsers provide help pages describing how to do this. Please note that if you block or delete strictly necessary cookies, parts of the Website may not function correctly. ","title":null},{"id":62,"__component":"ui.paragraph","content":"4.4\tThe Website does not currently respond to “Do Not Track” signals, because there is no common industry standard for how to interpret them. The Website honours the Global Privacy Control (GPC) signal where we are required to do so under Applicable Law. ","title":null},{"id":63,"__component":"ui.paragraph","content":"5.1\tStrictly necessary cookies. Strictly necessary cookies are required to navigate the Website and operate basic functions, including logging you into your Account, remembering your cookie preferences, authenticating API calls, securing form submissions, preventing fraud and maintaining session integrity. Without these cookies the Website cannot be provided. These cookies are placed without consent. Where any information processed in connection with strictly necessary cookies qualifies as personal data, the legal basis is our legitimate interest under Article 6(1)(f) of the UK GDPR and EU GDPR in operating and securing the Website. ","title":"Categories of Cookies We Use "},{"id":64,"__component":"ui.paragraph","content":"5.2\tPerformance cookies. Performance cookies (also called analytics cookies) help us understand how visitors interact with the Website — for example, which pages are visited most often, how long visitors spend on each page, and whether users encounter errors. We use this information to measure and improve the performance of the Website. Information collected through performance cookies may include IP address (typically truncated), device and browser identifiers, operating system, pages visited and referrer URL. Where this information constitutes personal data, it is pseudonymous rather than fully anonymous. The legal basis for placing performance cookies and processing related personal data is your consent (Article 6(1)(a) of the UK GDPR and EU GDPR). ","title":null},{"id":67,"__component":"ui.paragraph","content":"5.3\tFunctional cookies. Functional cookies enable the Website to store choices you have already made (for example, language, currency, layout, saved filters) in order to offer a more personalised experience. They are also used to enable certain requested functions, such as video playback and chat widgets. The legal basis for placing functional cookies and processing related personal data is your consent (Article 6(1)(a) of the UK GDPR and EU GDPR). ","title":null},{"id":65,"__component":"ui.paragraph","content":"5.4\tTargeting cookies. Targeting cookies (also called advertising or marketing cookies) are used to deliver advertising that is more relevant to you, to limit the number of times you see an advertisement, and to measure the effectiveness of our advertising campaigns. They record whether you have visited a promoted page and what content you interacted with. Information collected through targeting cookies may be shared with our advertising partners. The legal basis for placing targeting cookies and processing related personal data is your consent (Article 6(1)(a) of the UK GDPR and EU GDPR). ","title":null},{"id":66,"__component":"ui.paragraph","content":"6.1\tThe table below lists the main cookies and similar technologies deployed on the Website. The list is not exhaustive; it may change as we add or remove services. Users can see the complete, up-to-date list of cookies, grouped by category, in the Cookie Settings panel available from the cookie banner and the Website footer. \n\n\n| Cookie / Service|     Provider |  Category|  Purpose|  Duration|\n|----------|:-------------:|:-------------:|:-------------:|------:|\n| Session cookie (PSTNET authentication)|  PSTNET (firstparty)| Strictly necessary | Keeps you logged into the Account; maintains session state and CSRF protection | Session / up to 30 days |\n| Cookie-consent record|  PSTNET (firstparty)| Strictly necessary | Records your cookie preferences so the banner is not shown on every page load. | Up to 12 months|\n| Security / antifraud cookie |  PSTNET (firstparty)| Strictly necessary | Protects the Website and Account against fraud, bot traffic and abuse.| Session / up to 12 months |\n| Google Analytics (_ga, _ga_*, _gid) |  Google LLC / Google Ireland Limited (thirdparty) | Performance | Measures Website traffic, pages visited and user journeys, to help us improve the Website. |  Up to 24 months|\n| Google Tag Manager|  Google LLC / Google Ireland Limited (thirdparty) | Strictly necessary (loader) — does not itself store user data; deploys other tags subject to your consent | Deploys and manages other tags (including Google Ads and Google Analytics) in accordance with your cookie choices. | Session |\n| Google Ads (IDE, DSID, _gcl_*, conversion pixels)|   Google LLC / Google Ireland Limited (thirdparty)  | Targeting | Measures the effectiveness of our advertising campaigns, tracks clickthroughs from advertisements and supports interest-based advertising | Up to 13 months |","title":"Cookies We Use "},{"id":68,"__component":"ui.paragraph","content":"6.2\tSome of our third-party providers — in particular Google — are located outside the United Kingdom and the European Economic Area. Where personal data is transferred to such providers, we rely on the safeguards described in the Privacy Policy, which may include the European Commission’s standard contractual clauses, the UK International Data Transfer Agreement (or the International Data Transfer Addendum to the European Commission standard contractual clauses) and additional supplementary measures where appropriate. ","title":null},{"id":229,"__component":"ui.paragraph","content":"6.3\tOur third-party providers may act as our processors or, in some cases, as independent controllers or joint controllers. For further information about each provider’s role and the safeguards applied, please refer to the relevant provider’s privacy notice: \n\n- Google Ads, Google Analytics and Google Tag Manager — https://policies.google.com/privacy \n","title":null},{"id":230,"__component":"ui.paragraph","content":"7.1\tWe may update this Cookie Policy from time to time to reflect changes in our use of cookies, in the applicable legal framework or in industry best practice. The updated version will be published on the Website together with the revised “Last updated” date. Where the change is material, we will notify you through the Cookie Settings panel, the cookie banner or the Account dashboard, and (where required by Applicable Law) we will seek your renewed consent. ","title":"Changes to This Cookie Policy "},{"id":50,"__component":"ui.list","type":"disc","title":"Contact ","isolated":false,"item":[{"id":335,"content":"Data Protection Officer: dpo@pst.net ","parentId":null},{"id":336,"content":"Customer Support: customersupport@pst.net ","parentId":null},{"id":337,"content":"Postal address: ADV Summit Advisors Limited, Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands. ","parentId":null}]},{"id":231,"__component":"ui.paragraph","content":"8.1  If you are located in the United Kingdom or the European Economic Area and you believe our use of cookies does not comply with Applicable Law, you have the right to lodge a complaint with your national data-protection supervisory authority (for example, the Information Commissioner’s Office in the United Kingdom: https://ico.org.uk/make-acomplaint/).","title":null}]}},{"id":9,"attributes":{"title":"Anti-Money Laundering and Counter-Terrorist Financing Policy","createdAt":"2023-03-26T20:40:33.513Z","updatedAt":"2026-09-24T07:18:47.070Z","publishedAt":"2023-04-19T08:22:31.774Z","slug":"aml","position":3,"tosType":null,"content":[{"id":128,"__component":"ui.paragraph","content":"1.1\tThis Anti-Money Laundering and Counter-Terrorist Financing Policy (the “AML \nPolicy”) sets out the framework and procedures that ADV Summit Advisors Limited (the “Administrator”, and together with its affiliates, “PSTNET”, “we”, “us” or “our”) applies in order to prevent the use of the PSTNET platform (the “System”) for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud and other financial crime.","title":"Introduction and Scope "},{"id":129,"__component":"ui.paragraph","content":"1.2 This AML Policy is an Internal Policy and forms an integral part of the Terms of Service published at https://pst.net/legal/tos (the “Terms”). Capitalized terms used but not defined in this AML Policy have the meaning given to them in the Terms. In the event of any conflict between this AML Policy and the Terms, the Terms prevail unless this AML Policy expressly states otherwise. \n","title":null},{"id":130,"__component":"ui.paragraph","content":"1.3\tThis AML Policy applies to the Administrator, its directors, officers and employees, and to all Customers using the System, regardless of category. Customers are required to comply with the provisions of this AML Policy that apply to them as a condition of their use of the System. ","title":null},{"id":131,"__component":"ui.paragraph","content":"1.4\tThe current version of this AML Policy is available on the Website at https://pst.net/ legal/aml. The Administrator may amend this AML Policy from time to time by publication on the Website, in accordance with Section 20 of the Terms. ","title":null},{"id":133,"__component":"ui.paragraph","content":"2.1\tThe Administrator is established in the Turks and Caicos Islands and conducts its business in accordance with the AML/CFT legal framework of the Turks and Caicos Islands, including in particular: \n\n-\tthe Proceeds of Crime Ordinance (as amended); \n-\tthe Proceeds of Crime (Anti-Money Laundering and Prevention of Terrorist Financing) Regulations 2010 (as amended); \n-\tthe Anti-Money Laundering and Prevention of Terrorist Financing Code 2011 (as amended) (the “AML/CFT Code”); \n-\tapplicable guidance issued by the Turks and Caicos Islands Financial Services Commission and the Financial Intelligence Agency of the Turks and Caicos Islands (the “FIA”); and \n-\tsanctions and counter-terrorism legislation in force in the Turks and Caicos Islands and, where applicable, in other jurisdictions from which the Administrator accepts Customers. \n","title":"Regulatory Context "},{"id":134,"__component":"ui.paragraph","content":"2.2\tThe Administrator is not a bank, a credit institution, a money transmitter under the Money Transmitters Ordinance 2007 of the Turks and Caicos Islands, an investment dealer, a trust company, a custodian, a fiduciary, a payment institution or an electronic money institution. The Administrator is a technology and infrastructure provider. Any regulated payment, issuing, banking, safeguarding or settlement function supporting the System is performed by the Administrator’s Financial Partners. The Administrator applies AML/CFT standards commensurate with the nature of its business and consistent with international best practice, including the recommendations of the Financial Action Task Force (FATF). ","title":null},{"id":135,"__component":"ui.paragraph","content":"2.3\tIn addition, the Administrator contractually supports, and cooperates with, the AML/CFT programs of its Financial Partners (including issuing banks, card networks, acquirers, processors, exchanges and onramp/off-ramp providers), whose own regulators and supervisory frameworks apply to the regulated services they perform. ","title":null},{"id":136,"__component":"ui.paragraph","content":"3.1\tCompliance Officer. The Administrator has appointed a Compliance Officer (who performs the functions of Money Laundering Reporting Officer for the purposes of the AML/CFT Code) responsible for: \n\n-\toverseeing the implementation and day-to-day operation of this AML Policy; \n-\treviewing suspicious activity reports (internal and external), investigating suspicious activity, and making disclosures to the FIA and to other competent authorities where required; \n-\tensuring that the Administrator’s employees receive appropriate training on AML/CFT obligations; \n-\tliaising with the Administrator’s Financial Partners on AML/CFT matters; and \n-\tmaintaining records required by Applicable Law and this AML Policy. \n\nThe Compliance Officer may be contacted at compliance@pst.net for matters relating to this AML Policy or to suspected financial crime. \n","title":"Compliance Function "},{"id":137,"__component":"ui.paragraph","content":"3.2\tBoard oversight. The board of directors of the Administrator has ultimate responsibility for AML/ CFT compliance. The Compliance Officer reports to the board on AML/CFT matters at appropriate intervals and at any time where a material matter arises. ","title":null},{"id":138,"__component":"ui.paragraph","content":"3.3\tIndependent review. The Administrator shall procure an appropriately resourced independent review of the effectiveness of the AML Policy and the Administrator’s AML/CFT controls, to be conducted periodically by a person independent of the compliance function (which may be an internal audit function or an external professional firm). ","title":null},{"id":139,"__component":"ui.paragraph","content":"3.4\tTraining. The Administrator provides AML/CFT training to all employees upon joining and at appropriate intervals thereafter. Training covers the applicable legal framework, typologies of money laundering and terrorist financing, red flags, the Administrator’s procedures for dealing with suspicious activity, sanctions and the consequences of non-compliance. Training records are retained by the Compliance Officer. ","title":null},{"id":140,"__component":"ui.paragraph","content":"4.1\tThe Administrator applies a risk-based approach to AML/CFT, meaning that the intensity of Verification, ongoing monitoring and record-keeping applied to a given Customer or Transaction is proportionate to the AML/CFT risk that the Customer or Transaction presents to the Administrator and its Financial Partners. ","title":"Risk-Based Approach "},{"id":141,"__component":"ui.paragraph","content":"4.2\tThe Administrator maintains a written AML/CFT risk assessment that considers, at a minimum, the following risk dimensions: \n\n-\tCustomer risk — the risk arising from the identity, business profile, occupation, expected behavior, beneficial ownership and control structure of the Customer (and, for Business Customers, its directors, Authorized Representatives and Beneficial Owners), including whether the Customer or any connected person is a politically exposed person (PEP). \n-\tGeographic risk — the risk arising from the countries and territories with which the Customer is connected (by residence, incorporation, activity or counterparty), including whether any such country is a Restricted Jurisdiction, a country subject to Sanctions or a jurisdiction identified by the FATF as high-risk or non-cooperative. \n-\tProduct and service risk — the risk arising from the features of the System, including virtualcard issuance, cross-border spending, Digital Currency deposits and withdrawals, and cashback. \n-\tDelivery-channel risk — the risk arising from the remote, non-face-to-face nature of Registration and Verification. \n-\tTransaction risk — the risk arising from Transaction value, frequency, counterparties, corridors, Merchant Category Codes, patterns and velocity. \n","title":null},{"id":142,"__component":"ui.paragraph","content":"4.3\tOn the basis of the risk assessment, each Customer is assigned a risk rating (typically low, medium or high). The risk rating determines the Verification procedure, the ongoing monitoring intensity, any Transaction limits, and whether enhanced due diligence (EDD) is required. ","title":null},{"id":143,"__component":"ui.paragraph","content":"4.4\tThe risk rating is not static. It is reviewed when the Administrator becomes aware of circumstances that may change the rating, including changes in the Customer’s activity, changes in beneficial ownership, adverse media findings, alerts from the Administrator’s monitoring systems or matches against sanctions or PEP lists. Customers are expected to notify the Administrator of material changes to their circumstances without undue delay. ","title":null},{"id":150,"__component":"ui.paragraph","content":"5.1\tVerification under the Terms. The Administrator performs Customer due diligence (CDD) in accordance with Section 5 of the Terms and this AML Policy. The Terms describe the two-step onboarding workflow, under which an Account is created on Registration (Step 1, producing an Unverified Account) and Verification is required to obtain a Verified Account and access to the issuance of virtual cards (Step 2). ","title":"Customer Due Diligence "},{"id":151,"__component":"ui.paragraph","content":"5.2\teKYC provider. The Administrator conducts eKYC through a third-party verification partner (currently Sumsub). eKYC comprises automated identity-document verification, liveness detection, biometric matching and screening of the Customer (and, for Business Customers, its directors, Authorized Representatives and Beneficial Owners) against sanctions, PEP and adverse-media databases. ","title":null},{"id":209,"__component":"ui.paragraph","content":"5.3\tStandard CDD — Individual Customers. For Individual Customers, standard CDD collects and verifies, at a minimum, the items set out in clause 5.1 of the Terms, namely: \n\n-\ta clear image of a valid government-issued identity document containing a unique identification number and the Customer’s photograph; \n-\ta liveness check (selfie or short video) performed through the Administrator’s eKYC provider; \n-\tthe Customer’s mobile telephone number, confirmed by one-time password; \n-\tproof of address issued no earlier than three (3) months before submission (for example, a utility bill, bank statement or tax notice); and \n-\tinformation on the purpose and intended use of the Account, source of funds and, where applicable, source of wealth, occupation and employer. \n\nWhere the Individual Customer indicates that the Account will be used in the course of independent professional activity (for example, affiliate marketing, media buying, content creation or app publishing), additional information and evidence of the professional activity, expected monthly Transaction volumes and source of funds may be required, as set out in clause 5.1 of the Terms. \n","title":null},{"id":210,"__component":"ui.paragraph","content":"5.4\tStandard CDD — Business Customers. For Business Customers, standard CDD collects and verifies, at a minimum, the items set out in clause 5.2 of the Terms, namely: \n\n-\tcertificate of incorporation (or equivalent formation document) and, where issued, certificate of good standing dated no earlier than three (3) months before submission; \n-\tconstitutional documents (memorandum and articles of association, bylaws, partnership agreement or equivalent); \n-\ta current register of directors and a current register of members (shareholders), or equivalent documentation sufficient to establish the ownership and control structure of the entity; \n-\ta corporate resolution or written authorization naming each Authorized Representative and confirming their authority to act on behalf of the entity in relation to the Account; \n-\tproof of the entity’s registered business address issued no earlier than three (3) months before submission; \n-\tidentification and verification documentation for each Authorized Representative, director and Beneficial Owner equivalent to that required of an Individual Customer under clause 5.1 of the Terms; \n-\tan ownership and control structure chart identifying all direct and indirect Beneficial Owners to the applicable threshold, and a signed UBO declaration; \n-\tinformation on the entity’s business activities, intended use of the System, expected Transaction volumes, source of funds and source of wealth; \n-\twhere applicable, copies of any licenses, registrations or authorizations required by the entity to carry on its business. \n","title":null},{"id":152,"__component":"ui.paragraph","content":"5.5\tBeneficial ownership threshold. A natural person is treated as a Beneficial Owner of a Business Customer where that person directly or indirectly holds more than twenty-five percent (25%) of the shares, voting rights, ownership interests or control of the entity, or otherwise ultimately owns or controls the entity or on whose behalf a transaction is being conducted. The Administrator reserves the right to apply a lower threshold where the risk profile of the Customer so requires. ","title":null},{"id":153,"__component":"ui.paragraph","content":"5.6\tEnhanced Due Diligence (EDD). EDD is applied in higher-risk situations, including where: \n\n-\tthe Customer, a Beneficial Owner, a director or an Authorized Representative is a PEP (a person entrusted with prominent public functions in any jurisdiction), a family member or a close associate of a PEP; \n-\tthe Customer is connected (by residence, incorporation, activity or counterparty) with a high-risk jurisdiction identified by the FATF, the European Union, the United States, the United Kingdom, the Turks and Caicos Islands or another relevant authority; \n-\tthe Customer presents adverse media findings, regulatory sanctions, criminal convictions or other reputational concerns; \n-\tthe expected or actual volume of Transactions is significantly higher than would be anticipated for the Customer’s stated activity, or there are unusual or complex Transaction patterns without an apparent economic or lawful purpose; \n-\tthe source of funds or source of wealth cannot be satisfactorily explained on the basis of standard evidence; or \n-\tany other factor reasonably determined by the Compliance Officer to warrant enhanced scrutiny. \n\nEDD may include any or all of: obtaining senior management approval to establish or continue the business relationship; obtaining additional information on the Customer’s business, source of funds, source of wealth and purpose of Transactions; requiring additional documentation (invoices, contracts, financial statements, tax returns, bank statements, affiliate-network payout confirmations); conducting a live video call; lowering Transaction limits; and applying more intensive ongoing monitoring. \n","title":null},{"id":154,"__component":"ui.paragraph","content":"5.7\tSimplified Due Diligence (SDD). The Administrator does not generally apply simplified due diligence. In limited circumstances where the risk of money laundering or terrorist financing is demonstrably low, the Compliance Officer may approve a reduced-intensity CDD measure consistent with Applicable Law; in no case will SDD be applied where doing so would breach the AML/CFT Code or a Financial Partner’s requirements. ","title":null},{"id":155,"__component":"ui.paragraph","content":"5.8\tReliance on third parties. The Administrator may rely on CDD performed by third parties only where permitted by Applicable Law and where the Administrator is satisfied that the third party is subject to equivalent regulation and supervision. Ultimate responsibility for CDD remains with the Administrator. ","title":null},{"id":211,"__component":"ui.paragraph","content":"5.9\tRefusal or termination. The Administrator will refuse to establish (or will terminate) the business relationship, and will not execute any Transaction, where: CDD cannot be satisfactorily completed; the Customer refuses to provide requested information or documents; the Customer, a Beneficial Owner, a director or an Authorized Representative is subject to Sanctions; or continuing the relationship would cause the Administrator to breach Applicable Law or the rules of any Financial Partner. Refusal and termination are implemented in accordance with Sections 17 and 18 of the Terms. ","title":null},{"id":212,"__component":"ui.paragraph","content":"6.1 The Administrator screens Customers, Beneficial Owners, directors, Authorized Representatives, Transaction counterparties and, where practicable, merchants against applicable sanctions lists at onboarding, on an ongoing basis, and prior to the execution of material Transactions. The lists screened against include: \n\n-\tconsolidated list of financial sanctions targets maintained by His Majesty’s Treasury of the United Kingdom (OFSI); \n-\tthe consolidated list of persons, groups and entities subject to EU financial sanctions; \n-\tthe Specially Designated Nationals and Blocked Persons (SDN) list and other sanctions lists maintained by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury; \n-\tthe United Nations Security Council Consolidated Sanctions List; \n-\tsanctions lists applicable in the Turks and Caicos Islands; and \n-\tsuch other sanctions lists as the Administrator considers relevant in light of its risk assessment and the requirements of its Financial Partners. \n","title":"Sanctions Screening "},{"id":213,"__component":"ui.paragraph","content":"6.2\tA positive sanctions match (or a potential match that cannot be excluded) results in an immediate hold on the relevant Customer or Transaction, escalation to the Compliance Officer, reporting to competent authorities where required, and, where confirmed, termination of the business relationship. The Administrator will not execute a Transaction that it knows or suspects would breach Sanctions. ","title":null},{"id":214,"__component":"ui.paragraph","content":"6.3\tThe Administrator does not provide the System Services to persons located in, resident in or incorporated in a Restricted Jurisdiction, as listed in the Restrictions published on the Website. ","title":null},{"id":215,"__component":"ui.paragraph","content":"7.1\tThe Administrator operates automated and manual Transaction monitoring designed to identify Transactions or patterns of Transactions that are unusual, inconsistent with the Customer’s profile, potentially linked to money laundering, terrorist financing, sanctions evasion, fraud or other financial crime, or otherwise suspicious. ","title":"Transaction Monitoring and Suspicious Activity "},{"id":216,"__component":"ui.paragraph","content":"7.2\tMonitoring parameters include (without limitation) Transaction value, frequency, velocity, geography, Merchant Category Code, counterparty, declined-authorization rates, Chargeback rates, use of prohibited categories, deviations from the Customer’s expected activity, structuring indicators and other red flags. ","title":null},{"id":217,"__component":"ui.paragraph","content":"7.3\tNon-exhaustive examples of activity that the Administrator treats as suspicious include: \n-\tTransactions or patterns of Transactions that have no apparent economic or lawful purpose; \n-\tTransactions that appear structured to avoid Transaction, Verification or reporting thresholds; \n-   unexplained inconsistencies between Transaction activity and the Customer’s stated business or source of funds; \n-\tuse of the Account or PSTNET Card in connection with a Prohibited Activity listed in Section 16 of the Terms, Appendix 1 to the Terms or the Restrictions; \n-\tattempts to circumvent Merchant Category Code restrictions, scheme rules or sanctions; \n-\tindications that a third party (other than the Customer) is controlling or benefiting from the Account or PSTNET Card; and \n-\tadverse intelligence received from Financial Partners, authorities or open-source checks. \n","title":null},{"id":218,"__component":"ui.paragraph","content":"7.4\tWhere activity is flagged as suspicious, the Compliance Officer will investigate without undue delay. The Administrator may, pending and following investigation, request additional information and documents (including evidence of source of funds and source of wealth under clause 16.6 of the Terms), suspend Transactions or the Account under Section 17 of the Terms, freeze, return or reverse Transactions, and/or terminate the business relationship under Section 18 of the Terms. ","title":null},{"id":219,"__component":"ui.paragraph","content":"7.5\tWhere the Administrator knows, suspects or has reasonable grounds to know or suspect that property is the proceeds of crime or is connected with terrorist financing, or where a Transaction involves a sanctioned person, the Compliance Officer will make a report to the Financial Intelligence Agency of the Turks and Caicos Islands and to such other competent authority as may be required by Applicable Law. The Administrator and its personnel are prohibited from “tipping off” the Customer or any other person that a report has been or may be made. ","title":null},{"id":220,"__component":"ui.paragraph","content":"7.6\tReporting to authorities may be made without prior notification to the Customer. The Administrator may also cooperate with lawful requests for information from competent authorities and Financial Partners in accordance with Applicable Law and the Privacy Policy. ","title":null},{"id":221,"__component":"ui.paragraph","content":"8.1\tThe Administrator retains, for a minimum period of five (5) years from the date on which the business relationship with a Customer ends (or such longer period as is required by Applicable Law): \n\n-\tcopies of all identification documents and information obtained during Verification; \n-\trecords of all Transactions and Payment Orders; \n-\tinternal and external suspicious activity reports, and the records of investigations conducted in connection with them; \n-\trecords of sanctions-screening results and alerts; \n-\trecords of correspondence with Customers, Financial Partners and competent authorities in connection with AML/CFT matters; and \n-\ttraining records and records of independent reviews of the Administrator’s AML/CFT program. \n","title":"Record Keeping "},{"id":222,"__component":"ui.paragraph","content":"8.2\tRecords are stored in a manner that allows them to be retrieved promptly upon request by the Compliance Officer, an auditor, a Financial Partner or a competent authority. Records are protected in accordance with the Privacy Policy and Applicable Law relating to the protection of personal data. ","title":null},{"id":223,"__component":"ui.paragraph","content":"9.1\tThe Customer acknowledges and agrees that, in addition to the obligations set out in the Terms, the Customer shall: \n\n-\tprovide true, accurate, complete and up-to-date information during Registration, Verification and at any time when requested by the Administrator; \n-\tnotify the Administrator without undue delay of any change in the information provided for the purposes of Verification (including any change of director, Authorized Representative or Beneficial Owner of a Business Customer); \n-\tuse the System only for the lawful business purposes permitted under the Terms, and not for any Prohibited Activity; \n-\tnot use the Account or PSTNET Card on behalf of an undisclosed third party or to disguise the true economic beneficiary of a Transaction; \n-\tensure that all Collateral deposited and all Transactions executed through the Account are derived from legitimate sources and are not the proceeds of crime or connected with terrorist financing; \n-\tprovide, upon the Administrator’s request and within the period specified, documentation evidencing source of funds, source of wealth, purpose of a Transaction or economic rationale for a Transaction; and \n-\tcooperate with the Administrator’s investigations and with lawful requests from Financial Partners and competent authorities. \n","title":"Customer Obligations "},{"id":224,"__component":"ui.paragraph","content":"9.2\tFailure by the Customer to comply with this Section 9 may result in Suspension of Account under Section 17 of the Terms, termination under Section 18 of the Terms, forfeiture of Fees under clause 18.5 of the Terms, and reporting to competent authorities. Nothing in this AML Policy limits any other right or remedy available to the Administrator under the Terms or Applicable Law. ","title":null},{"id":225,"__component":"ui.paragraph","content":"10.1\tBreach of AML/CFT laws and sanctions regimes can give rise to severe civil and criminal penalties (including fines, confiscation of property and imprisonment) against the persons involved, whether individuals or legal entities. ","title":"Civil and Criminal Penalties "},{"id":226,"__component":"ui.paragraph","content":"10.2\tA legal entity may, in certain circumstances, be held liable for the actions of its directors, officers, employees or agents. Business Customers are therefore expected to implement their own policies, procedures and training so that their Authorised Representatives, directors, officers, employees and agents act in compliance with AML/ CFT laws, sanctions and the Terms when using the System. ","title":null},{"id":227,"__component":"ui.paragraph","content":"11.1\tBy accepting the Terms, the Customer acknowledges that the Customer has read, understood and will comply with this AML Policy, and that the Administrator is entitled to take the measures described in this AML Policy and in the Terms to give effect to its AML/CFT obligations. ","title":"Acknowledgement "},{"id":228,"__component":"ui.paragraph","content":"11.2\tIn the case of a Business Customer, the Authorised Representative accepting the Terms on behalf of the entity represents and warrants that the entity and its directors, officers, employees, agents and Beneficial Owners will use the System in full compliance with this AML Policy, the Terms and Applicable Law.","title":null}]}},{"id":14,"attributes":{"title":"Privacy policy","createdAt":"2023-03-28T11:14:54.773Z","updatedAt":"2026-04-28T07:57:32.858Z","publishedAt":"2023-03-28T11:14:57.515Z","slug":"privacy","position":2,"tosType":null,"content":[{"id":23,"__component":"ui.list","type":"decimal","title":"Introduction","isolated":null,"item":[{"id":54,"content":"This Privacy Policy describes how ADV Summit Advisors Limited (the “Administrator”, “PSTNET”, “we”, “us” or “our”) collects, uses, stores, discloses and otherwise processes personal data in connection with the PSTNET platform (the “System”), including the Website located at https://pst.net and its sub-domains, the Account dashboard, the browser extension, the API and PST Pulse.","parentId":null},{"id":55,"content":"This Privacy Policy is an Internal Policy and forms an integral part of the Terms of Service published at https://pst.net/legal/tos  (the “Terms”). It should be read together with the AML Policy, the Cookie Policy, the Restrictions and the Affiliate Program Terms and Conditions. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Terms.","parentId":null},{"id":432,"content":"The Administrator is established in the Turks and Caicos Islands. The Turks and Caicos Islands does not currently have comprehensive data-protection legislation of the kind found in the United Kingdom or the European Union. The Administrator therefore processes personal data by reference to the following frameworks, each to the extent applicable to the Administrator’s processing and to the relevant data subject:\n\n- the common-law duty of confidence as applicable in the Turks and Caicos Islands (a British Overseas Territory and common-law jurisdiction), and the constitutional protection of private and family life under section 9 of the Turks and Caicos Islands Constitution Order 2011;\n- the Electronic Transactions Ordinance of the Turks and Caicos Islands, to the extent it addresses the processing of personal data in connection with electronic transactions;\n- Regulation (EU) 2016/679 (the EU General Data Protection Regulation, or “EU GDPR”), to the extent applicable to the Administrator’s processing of personal data of data subjects in the European Economic Area;\n- the United Kingdom General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, to the extent applicable to the Administrator’s processing of personal data of data subjects in the United Kingdom;\n- Brazil’s Lei Geral de Proteção de Dados (“LGPD”), Switzerland’s Federal Act on Data Protection (“revFADP”), and United States state privacy laws (including the California Consumer Privacy Act and California Privacy Rights Act (together, “CCPA/CPRA”)), in each case to the extent applicable to the relevant data subject; and\n- any other data-protection law applicable to the Administrator or the relevant data subject.","parentId":null},{"id":433,"content":"Where the legal frameworks above set different standards, the Administrator applies the higher standard to the relevant processing. In this Privacy Policy, references to legal bases, data-subject rights and similar concepts are made by reference to the UK GDPR and EU GDPR as a descriptive benchmark; those references should be read, for data subjects outside the United Kingdom and the European Economic Area, as the equivalent concept under the data-protection law applicable to that data subject.","parentId":null}]},{"id":24,"__component":"ui.list","type":"decimal","title":"Data Controller, DPO and Representatives","isolated":null,"item":[{"id":56,"content":"Data Controller. The data controller in respect of personal data processed through the System is ADV Summit Advisors Limited, a company registered in the Turks and Caicos Islands with its registered office at Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands.","parentId":null},{"id":57,"content":"Data Protection Officer. The Administrator has designated a Data Protection Officer (“DPO”) as the point of contact for questions and requests relating to the processing of personal data. The DPO may be contacted by email at dpo@pst.net.","parentId":null},{"id":58,"content":"UK and EU Representatives. Where required under Article 27 of the UK GDPR or the EU GDPR, the Administrator has appointed (or will appoint) a representative in the United Kingdom and/or the European Union in relation to the processing of personal data of data subjects located there. The identity and contact details of any such representative will be published on the Website and made available through the DPO email address in clause 2.2 once appointed.","parentId":null}]},{"id":25,"__component":"ui.list","type":"disc","title":"Personal Data We Collect","isolated":null,"item":[{"id":60,"content":"We collect personal data directly from you when you interact with the System, and we receive personal data from third parties (such as Financial Partners and Verification providers) in connection with the System Services. For the purposes of this Privacy Policy, “personal data” means any information relating to an identified or identifiable natural person.","parentId":null},{"id":61,"content":"Information collected during Registration (Step 1). When you register an Account, we collect: your first name and surname; your email address; your chosen password (stored as a cryptographic hash, not in readable form); and your acceptance of these Terms and the Internal Policies.","parentId":null},{"id":62,"content":"Information collected during Verification (Step 2). When you complete Verification under Section 5 of the Terms, we (acting through our eKYC provider, currently Sumsub) collect and verify:\n\n- a clear image or scan of a valid government-issued identity document, and data extracted from that document (document type, issuing country, document number, expiry date, MRZ data, data embedded in document barcodes or chips, security-feature data);\n- a liveness check in the form of a selfie, short video or facial-recognition scan;\n- biometric data derived from your facial image (such as facial-feature vectors) for the purpose of verifying that the person presenting the document is its genuine holder;\n- your mobile telephone number, confirmed by one-time password;\n- a proof of address issued no earlier than three (3) months before submission (utility bill, bank statement, tax notice or equivalent);\n- where applicable, a document confirming your citizenship or residence permit;\n- information on the purpose and intended use of the Account, source of funds and, where applicable, source of wealth, occupation and employer;\n- where you are a Business Customer, additional information about the entity and its directors, Authorized Representatives and Beneficial Owners, as described in clause 5.2 of the Terms.","parentId":null},{"id":63,"content":"Information collected in connection with Transactions. When you fund the Account and execute Transactions, we collect:\n\n- details of the source account or wallet (bank account number, sort code, IBAN, BIC/SWIFT, blockchain address, as applicable);\n- Transaction details, including date, time, amount, currency, counterparty, merchant, Merchant Category Code, payment method, device used, and geolocation information associated with the Transaction;\n- PSTNET Card details (card program identifier, cardholder name, expiry date, the first six and last four digits of the card number, and Transaction-level authorization data);\n- Chargeback, dispute, reversal and refund information; and\n- information we receive from Financial Partners in connection with the Transaction.","parentId":null},{"id":64,"content":"Information collected when you contact us. When you contact Customer Support or other PSTNET functions, we collect your email address, the content of your communications and any files you attach, a ticket identifier, and technical data relating to your message (date, time, time zone, device environment). Customer-support calls and chats may be recorded for the purposes set out in clause 4.5.","parentId":null},{"id":434,"content":"Information from your device. When you use the System, we automatically collect technical information from your device, including IP address, device identifiers, browser type and settings, operating system, time zone, screen size, mobile-network information, and the date, time and duration of your visit. Cookies and similar technologies are used as described in the Cookie Policy.","parentId":null},{"id":435,"content":"Information from third parties. We may receive personal data relating to you from:\n\n- Financial Partners, including the Issuer, issuing banks, card networks, acquirers, processors, digital-asset exchanges and on-ramp/off-ramp providers;\n- Verification and fraud-prevention providers (including Sumsub), sanctions-screening providers and adverse-media databases;\n- public authorities and law-enforcement agencies;\n- public sources (such as company registries and sanctions/PEP lists); and\n- persons who refer you to PSTNET or who are referred by you under the Affiliate Program.","parentId":null}]},{"id":26,"__component":"ui.list","type":"decimal","title":"Purposes and Legal Bases of Processing","isolated":null,"item":[{"id":65,"content":"We process personal data only where we have a lawful basis to do so. The table below summarizes the principal purposes for which we process personal data and the corresponding legal bases under the UK GDPR and EU GDPR (which are used in this Privacy Policy as a descriptive benchmark, to be read as the equivalent concept under the data-protection law applicable to the relevant data subject).\n\n| Purpose|     Legal basis| \n|----------|:-------------:|\n| Creating and administering the Account; authenticating you; executing Payment Orders; facilitating the issuance and servicing of PSTNET Cards; providing Customer Support.|  Performance of a contract to which you are a party, namely the Terms (Article 6(1)(b) UK GDPR / EU GDPR). | \n| Verifying your identity (KYC and KYB); screening against sanctions and PEP lists; ongoing due diligence; transaction monitoring; suspicious-activity reporting to the FIA and other competent authorities; record retention under the AML Policy. | Compliance with a legal obligation to which the Administrator is subject (Article 6(1)(c)), including under the Proceeds of Crime Ordinance and the AML/CFT Regulations 2010 and Code 2011 of the Turks and Caicos Islands, and equivalent obligations applicable to our Financial Partners.| \n|Processing biometric data in the course of the liveness check and facial-match verification, where the purpose is to uniquely identify a natural person.| Your explicit consent to the processing of special-category data (Article 9(2)(a)). You may withdraw consent at any time, though doing so will prevent us from completing Verification and from providing System Services that require a Verified Account.| \n|Preventing and detecting fraud, financial crime, abuse and unauthorised use of the System; securing the System; enforcing the Terms, Internal Policies and Restrictions; pursuing or defending legal claims.| Our legitimate interests in operating a secure and compliant service, and in protecting the Administrator, Financial Partners and Customers from financial and operational loss (Article 6(1)(f)). Where the data processed is special-category data (for example, in investigations), we rely on the establishment, exercise or defence of legal claims (Article 9(2)(f)).|\n|Analytics, product improvement and measuring the quality and usability of the System, using pseudonymised data where feasible. | Our legitimate interests in understanding how the System is used and in improving our services (Article 6(1)(f)).|\n| Marketing communications about PSTNET products and services (including newsletters and in-product promotions).| Your consent, given through the Account dashboard, the cookie banner or a specific sign-up form (Article 6(1)(a)). You may withdraw consent at any time.|\n|Operating the Affiliate Program, including recording referrals, calculating commissions and making payments to Affiliates. | Performance of a contract to which the Affiliate is a party, namely the Affiliate Program Terms and Conditions (Article 6(1)(b)), and/or our legitimate interests in operating a lawful referral programme (Article 6(1)(f)).|\n|Cooperating with public authorities, law-enforcement agencies, courts and regulators in response to lawful requests. | Compliance with a legal obligation (Article 6(1)(c)), and/or our legitimate interests in cooperating with such bodies (Article 6(1)(f)).|\n\n","parentId":null},{"id":66,"content":"Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal may, however, prevent us from continuing to provide the relevant System Service.","parentId":null},{"id":67,"content":"4.3  Where processing is based on our legitimate interests, we carry out a balancing assessment to ensure that those interests are not overridden by your interests or fundamental rights and freedoms. You have the right to object to such processing; see Section 10.","parentId":null}]},{"id":27,"__component":"ui.list","type":"decimal","title":"Automated Decision-Making","isolated":null,"item":[{"id":68,"content":"As part of Verification, Transaction monitoring and fraud prevention, the Administrator uses automated systems to screen, score and flag Accounts and Transactions. These systems evaluate factors such as identity-document authenticity, liveness-check outcome, sanctions and PEP matches, device and network indicators, Transaction patterns, chargeback and decline rates, and deviations from expected behavior.","parentId":null},{"id":69,"content":"Where an automated check produces a result that would materially affect you (for example, a decline of Verification, a Suspension of Account or a refusal to execute a Transaction), a qualified member of the Administrator’s compliance or risk team reviews the case before a final decision is taken, except where the decision is required by Applicable Law or by the rules of a card scheme or Financial Partner. In those cases, you have the right to request human review of the decision, to express your point of view and to contest the decision, by contacting our DPO at dpo@pst.net.","parentId":null}]},{"id":28,"__component":"ui.list","type":"decimal","title":" How We Share Personal Data","isolated":null,"item":[{"id":72,"content":"We share personal data with the following categories of recipients, in each case only to the extent necessary and subject to appropriate contractual and technical safeguards:\n\n- **Financial Partners** — the Issuer, issuing banks, BIN sponsors, programme managers, card networks (including Visa and Mastercard), acquirers, processors, digital-asset exchanges and on-ramp/off-ramp providers. These recipients use personal data to issue and service the PSTNET Card, authorise and settle Transactions, perform their own compliance obligations, and manage fraud and risk. Depending on the arrangement, a Financial Partner may act as our processor, as an independent controller or as a joint controller.\n- **Verification and compliance providers** — including Sumsub (eKYC), sanctions and PEP screening providers, adverse-media database providers and fraud-prevention services. These recipients typically act as our processors.\n- **Technology providers** — cloud hosting, email, messaging, customer-support tooling, analytics, security monitoring and other SaaS providers that support the System. These recipients typically act as our processors.\n- **Professional advisers** — legal counsel, auditors, accountants and insurers, where necessary for the establishment, exercise or defense of legal claims or for compliance with legal obligations.\n- **Public authorities** — the Financial Intelligence Agency of the Turks and Caicos Islands, the Turks and Caicos Islands Financial Services Commission, tax authorities, law-enforcement agencies, courts, data-protection supervisory authorities (such as the UK Information Commissioner’s Office) and other regulators, where we are required to disclose personal data by Applicable Law, by a lawful request or to cooperate with an investigation.\n- **Business transfers** — where the Administrator or its business is involved in a merger, acquisition, reorganization, financing, sale of assets or insolvency proceeding, personal data may be transferred to the counterparties and their advisers, subject to the continued application of this Privacy Policy (or an equivalent notice) to the transferred data.","parentId":null},{"id":73,"content":"We do not sell personal data, and we do not share personal data for behavioral advertising except to the extent that targeting cookies are enabled by you under the Cookie Policy.","parentId":null}]},{"id":29,"__component":"ui.list","type":"decimal","title":"International Data Transfers","isolated":null,"item":[{"id":75,"content":"The Administrator is established in the Turks and Caicos Islands. Some of our Financial Partners, technology providers and Verification providers are established outside the Turks and Caicos Islands, the United Kingdom and the European Economic Area, including in the United States.","parentId":null},{"id":436,"content":"Where we transfer personal data of UK or EEA data subjects to a country that has not been the subject of an adequacy decision, we rely on one or more of the following safeguards under Article 46 of the UK GDPR and EU GDPR:\n\n- the Standard Contractual Clauses adopted by the European Commission (Decision (EU) 2021/914), with such supplementary measures as are necessary in light of the importing jurisdiction;\n- the United Kingdom International Data Transfer Agreement, or the International Data Transfer Addendum to the European Commission Standard Contractual Clauses issued by the UK Information Commissioner’s Office;\n- participation by the recipient in an applicable certification scheme (such as the EU-US Data Privacy Framework, where the recipient is certified); or\n- any other transfer mechanism permitted under applicable data-protection law.","parentId":null},{"id":437,"content":"You may request a copy of the relevant safeguards by contacting the DPO at dpo@pst.net. Certain information may be redacted to protect commercial confidentiality or the rights of third parties.","parentId":null}]},{"id":30,"__component":"ui.list","type":"decimal","title":"Retention","isolated":null,"item":[{"id":76,"content":" We retain personal data only for as long as necessary for the purposes for which it was collected, or for such longer period as is required by Applicable Law. In particular:\n\n- data collected for the purposes of AML/CFT compliance (including identification documents, Verification records, Transaction records, suspicious-activity reports and sanctions-screening records) is retained for a minimum of five (5) years following the end of the business relationship, consistent with Section 8 of the AML Policy and clause 18.10 of the Terms;\n- communications with Customer Support are retained for a reasonable period following the closure of the relevant ticket, to resolve recurring issues and to defend against potential disputes;\n- marketing-consent records and evidence of consent are retained for as long as the consent remains active, and for a reasonable period after withdrawal to demonstrate compliance;\n- pseudonymous analytics data is retained for the periods set out in the Cookie Policy.","parentId":null},{"id":77,"content":"When the retention period expires, personal data is deleted or irreversibly anonymized, except where continued retention is required by Applicable Law, or where the data is necessary for the establishment, exercise or defense of legal claims.","parentId":null}]},{"id":31,"__component":"ui.list","type":"decimal","title":"Security","isolated":null,"item":[{"id":80,"content":"We implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data. These measures include encryption in transit (using TLS) and at rest where appropriate, access control based on the principle of least privilege, multi-factor authentication for privileged access, logging and monitoring, regular vulnerability testing, staff confidentiality undertakings and AML/CFT and data-protection training.","parentId":null},{"id":81,"content":"Payment-card data is handled in accordance with the applicable Payment Card Industry Data Security Standard (PCI DSS) requirements by our Financial Partners. The Administrator does not itself store full card numbers or card verification values.","parentId":null},{"id":82,"content":"In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of data subjects, the Administrator will notify the competent supervisory authority within the timeframes required by Applicable Law, and will notify affected data subjects where Applicable Law so requires.","parentId":null},{"id":83,"content":"You play an important role in protecting your own personal data. We recommend using a strong, unique password, enabling multi-factor authentication where available, keeping your Contact Details up to date, and reporting any suspicious communication to the Administrator at once. We never ask for your password or other Authorization Details. If you receive a communication that purports to be from the Administrator and asks for such information, do not respond to it; notify us immediately at dpo@pst.net.","parentId":null}]},{"id":54,"__component":"ui.list","type":"decimal","title":" Your Rights","isolated":false,"item":[{"id":438,"content":"Subject to the conditions and exceptions set out in applicable data-protection law, you have the following rights:\n\n- **Right to be informed** — to receive information about the personal data we process and the purposes of processing, including through this Privacy Policy.\n- **Right of access** — to confirm whether we process your personal data and, if we do, to obtain a copy of it and information about the processing.\n- **Right to rectification** — to have inaccurate or incomplete personal data corrected or completed.\n- **Right to erasure** (“right to be forgotten”) — to have your personal data deleted, where one of the grounds in Article 17 of the UK GDPR or EU GDPR applies. The right does not apply to the extent we are required or permitted by law to retain the data (for example, for AML/CFT purposes).\n- **Right to restriction of processing** — to have the processing of your personal data restricted in certain circumstances.\n- **Right to object** — to object to processing based on our legitimate interests, and to object at any time to processing for direct marketing.\n- **Right to data portability** — to receive, in a structured, commonly used and machine-readable format, personal data that you have provided to us on the basis of consent or performance of a contract, and to have it transmitted to another controller where technically feasible.\n- **Right to withdraw consent** — where processing is based on consent, you may withdraw it at any time by contacting dpo@pst.net or (for marketing emails) by using the unsubscribe link in any such email.\n- **Right not to be subject to a solely automated decision** — as described in clause 5.2.\n- **Right to lodge a complaint** — with a competent data-protection supervisory authority; see clause 10.5.","parentId":null},{"id":439,"content":"Rights for specific jurisdictions. In addition to the rights listed in clause 10.1, you may have further rights under the data-protection law of your jurisdiction, including: under the LGPD (anonymization, blocking or elimination of unnecessary data; information about public- and private-sector entities with which we have shared data); under the revFADP (rights equivalent to access, rectification and objection under Swiss law); and under the CCPA/CPRA (rights to know, to delete, to correct, to opt out of sale or sharing, and to limit the use of sensitive personal information). We do not sell personal data within the meaning of the CCPA/CPRA. Sharing for cross-context behavioural advertising takes place only where targeting cookies are enabled by you under the Cookie Policy.","parentId":null},{"id":440,"content":"How to exercise your rights. You may exercise your rights by contacting the DPO at dpo@pst.net. We may ask you to verify your identity before acting on a request (for example, by sending the request from the email address associated with your Account, or by completing a Sumsub verification in exceptional cases). We will respond within thirty (30) days of receiving a verifiable request, and in any event within the timeframes required by Applicable Law. If a response will take longer (because the request is complex or numerous), we will let you know within that period.","parentId":null},{"id":441,"content":"Unfounded or excessive requests. Where a request is manifestly unfounded or excessive (in particular because it is repetitive), we may charge a reasonable fee to cover the administrative cost of responding, or refuse to act on the request. Where permitted by law, we may also refuse a request where we are legally required or permitted not to disclose the data (for example, to avoid tipping off a person subject to AML/CFT investigation).","parentId":null},{"id":442,"content":"Complaints. If you believe that our processing of your personal data does not comply with Applicable Law, you have the right to lodge a complaint with a competent data-protection supervisory authority in a jurisdiction that has one (the Turks and Caicos Islands does not currently have a dedicated data-protection supervisory authority). In particular:\n\n- in the United Kingdom, the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/);\n- in the European Economic Area, your national supervisory authority (a list is available on the European Data Protection Board website at https://edpb.europa.eu/about-edpb/about-edpb/members_en);\n- in Brazil, the Autoridade Nacional de Proteção de Dados (ANPD);\n- in California, the California Privacy Protection Agency or the Attorney General.\n\nWe would appreciate the opportunity to address your concerns before you contact a supervisory authority; please feel free to contact our DPO at dpo@pst.net first.","parentId":null}]},{"id":55,"__component":"ui.list","type":"decimal","title":"Children","isolated":false,"item":[{"id":443,"content":"The System is intended for persons aged 18 or over. We do not knowingly collect personal data from children. If you believe that a child has provided personal data to us, please contact the DPO at dpo@pst.net and we will take appropriate steps to delete that data.","parentId":null}]},{"id":56,"__component":"ui.list","type":"decimal","title":"Cookies and External Links","isolated":false,"item":[{"id":444,"content":"Our use of cookies and similar technologies is described in the Cookie Policy published on the Website.","parentId":null},{"id":445,"content":"The Website may contain links to third-party websites, services or integrations. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third party whose services you use.","parentId":null}]},{"id":57,"__component":"ui.list","type":"decimal","title":"Changes to This Privacy Policy","isolated":false,"item":[{"id":446,"content":"We may update this Privacy Policy from time to time to reflect changes in our processing, in Applicable Law or in industry best practice. The updated version will be published on the Website with a revised “Last updated” date. Where the change is material, we will notify you by email to the address registered in the Account and/or through the Account dashboard, in accordance with clause 3.6 of the Terms. Continued use of the System after the change takes effect constitutes acceptance of the updated Privacy Policy, to the extent acceptance is legally required.","parentId":null}]},{"id":58,"__component":"ui.list","type":null,"title":"Contact","isolated":false,"item":[{"id":447,"content":"Data Protection Officer: dpo@pst.net\n\nPostal address: ADV Summit Advisors Limited, Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands.","parentId":null}]}]}},{"id":15,"attributes":{"title":"Affiliate Program Terms and Conditions ","createdAt":"2023-04-25T07:13:25.324Z","updatedAt":"2026-09-24T07:19:35.651Z","publishedAt":"2023-04-27T09:33:50.454Z","slug":"affiliate","position":7,"tosType":"none","content":[{"id":156,"__component":"ui.paragraph","content":"These Affiliate Program Terms and Conditions (the “Affiliate Terms”) constitute a legally binding agreement between ADV Summit Advisors Limited (the “Administrator”, “PSTNET”, “we”, “us” or “our”) and any natural person or legal entity that applies to participate, or participates, in the PSTNET affiliate program (the “Affiliate” or “you”). ","title":"Introduction"},{"id":157,"__component":"ui.paragraph","content":"By clicking “I agree” (or the equivalent) on the Affiliate Program registration form, or by otherwise accessing or using the Program (as defined below), you confirm that you have read, understood and accepted these Affiliate Terms. If you do not agree, you must not register for, or participate in, the Program. ","title":null},{"id":158,"__component":"ui.paragraph","content":"These Affiliate Terms are an Internal Policy and form an integral part of the Terms of Service published at https://pst.net/legal/tos (the “Terms”). They should be read together with the AML Policy, the Privacy Policy, the Cookie Policy and the Restrictions. \nCapitalized terms used but not defined in these Affiliate Terms have the meaning given to them in the Terms. In the event of any conflict between these Affiliate Terms and the Terms, the Terms prevail unless these Affiliate Terms expressly state otherwise. ","title":null},{"id":159,"__component":"ui.paragraph","content":"Participation in the Program is subject to approval by the Administrator. Any natural person, legal entity or website applying to become an Affiliate must be approved by the Administrator before being given access to Program campaigns. The Administrator may, in its reasonable discretion, decline an application, require additional information (including KYC or KYB Verification in accordance with Section 5 of the Terms and the AML Policy), or revoke prior approval. ","title":null},{"id":160,"__component":"ui.paragraph","content":"“Affiliate” means the natural person or legal entity that has submitted an application to participate in the Program and has been approved by the Administrator, and that participates in the Program on the basis of these Affiliate Terms and the Affiliate Program Registration Form. ","title":"A. Definitions"},{"id":161,"__component":"ui.paragraph","content":"“Affiliate Account” means the account held in the name of the Affiliate with PSTNET to which Tagged Accounts are linked for the purpose of tracking Commission. ","title":null},{"id":208,"__component":"ui.paragraph","content":"“Affiliate Website” means any website, blog, social-media channel, application or other digital property operated or controlled by the Affiliate on which Tracking Links or other approved marketing materials are displayed. ","title":null},{"id":162,"__component":"ui.paragraph","content":"\"Affiliate Website\" means the internet websites operated by the Affiliate which shall contain the Tracking Link.","title":null},{"id":163,"__component":"ui.paragraph","content":"“Commission” means the fee payable by the Administrator to the Affiliate in respect of Qualified Transactions by Qualified Customers, calculated in accordance with Section C. \n","title":null},{"id":164,"__component":"ui.paragraph","content":"“Data Protection Legislation” means any data-protection law applicable to the processing of personal data in connection with the Program, including (as applicable) Regulation (EU) 2016/679 (“EU GDPR”), the United Kingdom General Data Protection Regulation, the \nData Protection Act 2018, and any successor or equivalent legislation. The Turks and Caicos Islands does not currently have comprehensive data-protection legislation; common-law confidentiality and any applicable enabling provisions under the Electronic Transactions Ordinance of the Turks and Caicos Islands apply in that jurisdiction. ","title":null},{"id":165,"__component":"ui.paragraph","content":"“Net Revenue” means in respect of a Qualified Customer in any calendar month, the gross Fees actually received and retained by the Administrator from that Qualified Customer in respect of Qualified Transactions in that month, less: (i) any cashback, rebates and Administrator-funded incentives credited to that Qualified Customer; (ii) Chargebacks, reversals, refunds, fraud reversals, scheme fines and network costs attributable to that Qualified Customer; (iii) foreign-exchange spreads or other amounts passed through to Financial Partners; and (iv) applicable taxes and withholdings. Net Revenue is calculated by the Administrator in good faith based on its records. The categories of activity that generate Net Revenue may be updated by the Administrator from time to time by publication on the Website. ","title":null},{"id":166,"__component":"ui.paragraph","content":"“New Customer” means a person (natural or legal) that, at the time of the referral by the Affiliate to the Administrator, does not hold an Account with the Administrator and has not previously held an Account with the Administrator. ","title":null},{"id":167,"__component":"ui.paragraph","content":"“PEP” means a politically exposed person, being a person entrusted with prominent public functions (and the family members and close associates of such a person) as described in the AML Policy. ","title":null},{"id":168,"__component":"ui.paragraph","content":"“Permitted Territories” means the countries and territories in which the Program is available, being those listed as Supported Countries in the Restrictions and not listed as Restricted Jurisdictions in the Restrictions, as updated from time to time. A New Customer or Affiliate located in a Restricted Jurisdiction is not eligible for the Program. ","title":null},{"id":169,"__component":"ui.paragraph","content":"“PPC” means pay-per-click advertising. ","title":null},{"id":170,"__component":"ui.paragraph","content":"“Program” means the PSTNET affiliate and referral program operated by the Administrator under these Affiliate Terms. ","title":null},{"id":171,"__component":"ui.paragraph","content":"“PSTNET Brands” means the trademarks, service marks, trade names, logos, design rights, domain names, goodwill and other intellectual-property rights of the Administrator and its affiliates, in each case whether registered or unregistered, including the mark “PSTNET”. ","title":null},{"id":172,"__component":"ui.paragraph","content":"“PSTNET Systems” means the System (as defined in the Terms), being the PSTNET platform operated by the Administrator, comprising the Website, the Customer dashboard, the API, the browser extension, PST Pulse and any related interfaces, together with the associated back-office infrastructure. ","title":null},{"id":173,"__component":"ui.paragraph","content":"“PSTNET Wallet” means the Wallet (as defined in the Terms) held in the Affiliate Account through which the Administrator pays Commission to the Affiliate. ","title":null},{"id":174,"__component":"ui.paragraph","content":"“PSTNET Websites” means the websites owned, operated or maintained by the Administrator, including https://pst.net and its sub-domains. ","title":null},{"id":175,"__component":"ui.paragraph","content":"“Qualified Customer” means a New Customer who (i) is referred to the Administrator by the Affiliate through a Tracking Link, (ii) is not located in, or a resident of, a Restricted Jurisdiction, (iii) is not the Affiliate itself (including any related account held by or for the benefit of the Affiliate), (iv) completes Registration and Verification in accordance with the Terms, (v) accepts the Terms and the Internal Policies, and (vi) meets the conditions set out in Section C.7. ","title":null},{"id":176,"__component":"ui.paragraph","content":"“Qualified Transaction” means a Transaction executed by a Qualified Customer that meets the conditions set out in Section C.7 and is not reversed, refunded, charged back or otherwise unwound within the Reserve Period. ","title":null},{"id":177,"__component":"ui.paragraph","content":"“Reserve Period” means the period of thirty (30) days following the end of the calendar month in which a Qualified Transaction is executed, during which the Administrator may adjust Commission to reflect Chargebacks, reversals, refunds, fraud reversals or other adjustments, as described in clause C.4. ","title":null},{"id":178,"__component":"ui.paragraph","content":"“SEM” means search-engine marketing. ","title":null},{"id":179,"__component":"ui.paragraph","content":"“Services” means the System Services (as defined in the Terms), being the services provided by the Administrator through the System to Customers, including the opening and maintenance of Accounts and Wallets, the acceptance and recording of Collateral, the execution of Transactions, the facilitation of the issuance and servicing of PSTNET Cards, cashback accounting and reporting, API access and related technical and informational services. ","title":null},{"id":180,"__component":"ui.paragraph","content":"“Tagged Account” means the Account of a Qualified Customer that has been tagged to the Affiliate Account for the purpose of tracking Commission. ","title":null},{"id":181,"__component":"ui.paragraph","content":"“Tracking Link(s)” means unique referral link(s) generated by the Administrator for the Affiliate and used to attribute a Qualified Customer (and their Qualified Transactions) to the Affiliate Account. ","title":null},{"id":40,"__component":"ui.list","type":"decimal","title":"B. Engagement","isolated":true,"item":[{"id":264,"content":"To enroll in the Program, the Affiliate must complete the Affiliate Program Registration Form and register an Affiliate Account through the Website. The Affiliate shall provide such information and documents as the Administrator may request, including (where required under the AML Policy) identity Verification of the Affiliate and, for an Affiliate that is a legal entity, KYB Verification of the entity and its directors, Authorized Representatives and Beneficial Owners. ","parentId":null},{"id":265,"content":"The Affiliate has no authority to accept New Customers, to make contracts, or to give any promise, representation, warranty or guarantee on behalf of the Administrator. The Affiliate shall not hold itself out as an employee, agent, partner or joint-venturer of the Administrator. The relationship between the Parties is that of independent contractors. ","parentId":null},{"id":266,"content":"The rights granted to the Affiliate under these Affiliate Terms are non-exclusive. Nothing in these Affiliate Terms restricts the Administrator from entering into affiliate, referral or marketing arrangements with other persons, or from promoting, marketing or selling the Services directly.","parentId":null},{"id":267,"content":"The Administrator may take legal action and may withhold, set off or deduct amounts from Commission due to the Affiliate where the Affiliate (or any person acting with or on behalf of the Affiliate) manipulates the Program, abuses the PSTNET Brands, or otherwise acts in breach of these Affiliate Terms, the Terms or Applicable Law. The Administrator may also terminate these Affiliate Terms with immediate effect in such cases, as described in Section I. ","parentId":null}]},{"id":41,"__component":"ui.list","type":null,"title":"C. Commission","isolated":null,"item":[{"id":268,"content":"Commission rates. The Affiliate is entitled to a Commission calculated as a percentage of the Net Revenue generated by each of the Affiliate’s Qualified Customers in each calendar month. The applicable percentage depends on the type of activity generating the Net Revenue, as set out in the table below. \n\n| Activity generating Net Revenue|     Commission (% of Net Revenue)| \n|----------|:-------------:|\n| Currency-exchange and foreign-exchange margin earned on Transactions by the Qualified Customer|  90% | \n| PSTNET Card issuance Fees paid by the Qualified Customer|  30% | \n|Deposit Fees and funding-related Fees paid by the Qualified Customer (including any top-up or card-loading fees)|  10% | \n","parentId":null},{"id":269,"content":"Three-tier referral structure. The Program operates on a three-tier referral basis. \nCommission is payable to the Affiliate in respect of Qualified Customers at three levels: \n\n| Tier|     Description |  Commissions|\n|:----------|:-------------|:------|\n| F-referrals (direct)|  Qualified Customers who register through the Affiliate’s own Tracking Link. | 70% of Net Revenue |\n| FF-referrals (second tier))|  Qualified Customers who register through the Tracking Link of one of the Affiliate’s F-referrals. | 20% of Net Revenue |\n| FFF-referrals (third tier)|  Qualified Customers who register through the Tracking Link of one of the Affiliate’s FF-referrals. | 10% of Net Revenue |\n\nFor illustration: where a Qualified Customer is an F-referral of Affiliate A, an FF-referral of \nAffiliate B and an FFF-referral of Affiliate C, the Commission in respect of that Qualified Customer’s Net Revenue is allocated 70% to A, 20% to B and 10% to C, subject in each case to the activity-specific rates in clause C.1 and to the qualifications in clause C.7. \n","parentId":null},{"id":270,"content":"Changes to Commission structure. The Administrator may amend the Commission structure (including the activity-specific rates in clause C.1, the tier percentages in clause C.2, and any promotional discount referenced in clause C.1) at any time by publication on the Website, in accordance with clause 3.6 of the Terms. Changes apply to Net Revenue generated on or after the effective date of the change and do not affect Commission already accrued and payable. ","parentId":null},{"id":271,"content":"Accrual, Reserve Period and payment. Commission accrues in respect of Net Revenue generated from Qualified Transactions in each calendar month. Following the end of each calendar month, the Administrator calculates the gross Commission accrued for that month, deducts any Chargebacks, reversals, refunds, fraud reversals or other adjustments (including adjustments arising during the Reserve Period), and pays the net Commission into the Affiliate’s PSTNET Wallet within fifteen (15) calendar days after the end of that month. A further Reserve Period of thirty (30) days applies, during which the \nAdministrator may reverse or adjust Commission already paid to reflect subsequent Chargebacks, reversals or fraud unwinds; any resulting negative balance may be recovered under clause C.9. No interest is payable on Commission amounts held or delayed. ","parentId":null},{"id":272,"content":"One Tagged Account per Qualified Customer. Each Qualified Customer has only one Tagged Account, being the Account created when the Qualified Customer first registers through a Tracking Link. No Commission is payable in respect of any other Account held by the same Qualified Customer. ","parentId":null},{"id":273,"content":"Commission basis. Commission is payable only in respect of Qualified Transactions by Qualified Customers. No Commission is payable in respect of Transactions by the Affiliate itself, Transactions by any Account held by or for the benefit of the Affiliate, or Transactions that do not meet the conditions in clause C.7. ","parentId":null},{"id":274,"content":"Qualification conditions. For Commission to become payable in respect of a New Customer and a Transaction, all of the following conditions must be met: \n\n- the New Customer is a Qualified Customer as defined in Section A; \n- the New Customer reached PSTNET through the Affiliate’s Tracking Link, without manipulation of the Tracking Link or any cookie, device or identifier used to attribute the referral; \n- the New Customer has submitted accurate and complete information required by the Terms and the AML Policy, has successfully completed Verification, and has accepted the Terms and the Internal Policies; \n- the New Customer remains in compliance with the Terms, the AML Policy and the other Internal Policies at the time Commission is calculated and paid; \n- the Transaction is a genuine arms-length Transaction by the Qualified Customer; it is not subject to refund, reversal, cancellation or Chargeback at the time Commission is calculated; it has not been suspended or restricted under the Terms; and it is not the result of fraud, manipulation, self-dealing, deception or any unlawful or improper activity (as determined by the Administrator, acting reasonably); \n- the New Customer was not previously a Customer of PSTNET under any prior Account (regardless of whether that prior Account was active at the time of the referral); and \n- the Tracking Link has not been transferred to, or used by, any third party in a manner that would disguise the true origin of the referral. ","parentId":null},{"id":275,"content":"Adjustment and clawback. Any past, present or future Commission in respect of a Qualified Customer or Transaction that the Administrator later determines, acting reasonably, does not meet the conditions in clause C.7, or that is affected by a Chargeback, reversal, refund, fraud unwind or similar adjustment, may be withheld, cancelled or (if already paid) recovered by the Administrator. The Administrator may set off such amounts against current or future Commission payable to the Affiliate, and may demand repayment where the Commission already paid exceeds the Commission properly payable. ","parentId":null},{"id":276,"content":"Negative balance. If at any time the Affiliate’s Commission balance becomes negative as a result of adjustments under clauses C.4 or C.8, the Affiliate shall on first written demand reimburse the Administrator the negative balance. The Administrator may, at its option, recover the negative balance by deducting it from future Commission, demanding payment from the Affiliate, or (where the Affiliate is also a Customer) debiting the Affiliate’s PSTNET Wallet or Collateral balance in accordance with clause 10.2 of the Terms. ","parentId":null},{"id":277,"content":"Anti-manipulation. The Administrator may, in its sole discretion, withhold or reclaim Commission where the Administrator reasonably believes that: (i) the Affiliate’s actions breach Applicable Law or regulation; (ii) the Affiliate has breached these Affiliate Terms, the Terms, the AML Policy, the Privacy Policy or any other Internal Policy; (iii) the Affiliate has engaged in fraud, referral stuffing, cookie stuffing, self-referral, incentivized-fraud schemes, or other manipulation; or (iv) a Qualified Customer or a Qualified Transaction fails to meet the qualifications in clause C.7. ","parentId":null},{"id":278,"content":"Affiliate must monitor Commission. The Affiliate is responsible for monitoring the Commission calculated, paid, withheld, adjusted or reclaimed under these Affiliate Terms. The Administrator will endeavor to notify the Affiliate of material adjustments through the Affiliate Account but is not obliged to give individual notice. If the Affiliate disputes a Commission calculation or adjustment, the Affiliate shall raise the dispute in writing with the Administrator within thirty (30) days of the date on which the Commission was (or should have been) paid; failing such notice, the relevant Commission calculation is deemed accepted by the Affiliate. ","parentId":null},{"id":279,"content":"Taxes. The Affiliate is solely responsible for determining, calculating, withholding, reporting, filing and paying any taxes, duties, levies, social-security contributions or similar charges that may apply to the Affiliate or to the Commission, under the laws of the Affiliate’s country of residence, incorporation or activity, or any other jurisdiction that may claim taxing rights. The Administrator does not provide tax advice. This clause C.12 is consistent with clause 13.6 of the Terms. ","parentId":null},{"id":280,"content":"Affiliate contact information. The Affiliate shall keep its postal address, email address, contact telephone number, tax identification number, wallet address and other information necessary for the payment of Commission up to date. The Administrator is not responsible for Commission that cannot be paid because the Affiliate has provided inaccurate or out-of-date information. ","parentId":null}]},{"id":42,"__component":"ui.list","type":null,"title":"D. Tracking","isolated":null,"item":[{"id":281,"content":"The Administrator tracks Qualified Customers and Qualified Transactions through \nTracking Links and other tracking technologies selected by the Administrator. The Administrator may provide the Affiliate with instructions, Tracking Links and, where necessary, access to tracking dashboards, restricted to the Affiliate’s own activity. \n","parentId":null},{"id":282,"content":"Commission is payable only in respect of Qualified Transactions generated through the Administrator’s tracking technology. The Administrator is not responsible for Commission that cannot be attributed because Tracking Links were modified, obscured, stripped by ad blockers or intermediate redirects, or otherwise used in a manner inconsistent with these Affiliate Terms. ","parentId":null},{"id":283,"content":"The Affiliate shall cooperate with the Administrator in the establishment, operation and maintenance of the tracking infrastructure, and shall use Tracking Links only in accordance with these Affiliate Terms. ","parentId":null},{"id":284,"content":"The Affiliate shall not transfer, sub-license, resell or otherwise make its Tracking Links available to any other affiliate or third party. Breach of this clause may result in the forfeiture of up to one hundred percent (100%) of the Commission otherwise payable in respect of the affected Tracking Link, and is a material breach of these Affiliate Terms. ","parentId":null},{"id":285,"content":"","parentId":null}]},{"id":43,"__component":"ui.list","type":null,"title":"E. Affiliate Obligations ","isolated":null,"item":[{"id":286,"content":"The Affiliate shall cooperate with the Administrator in good faith to promote and refer the Services to Qualified Customers in accordance with these Affiliate Terms. The Administrator may, in its reasonable discretion, decide whether or not to accept a New Customer as a Qualified Customer. ","parentId":null},{"id":287,"content":"The Administrator may notify the Affiliate of territorial, marketing, product or regulatory restrictions from time to time (including through updates to the Restrictions). The Affiliate shall comply with such restrictions within three (3) days of notification, or sooner where required by the nature of the restriction. ","parentId":null},{"id":288,"content":"The Affiliate represents and warrants, on and as of the date of application and on an ongoing basis while the Affiliate participates in the Program, that: \n\n- the Affiliate has full legal right, authority and capacity to enter into these Affiliate Terms (and, where the Affiliate is a legal entity, is duly incorporated and validly existing under the laws of its jurisdiction of incorporation); \n- where the Affiliate is a natural person, the Affiliate is at least eighteen (18) years of age and has full legal capacity under the laws of its country of residence; \n- the Affiliate is not a citizen or resident of, or incorporated, registered or located in, a Restricted Jurisdiction (and, where the Affiliate is a legal entity, no director, Authorized Representative or Beneficial Owner is so located); \n- neither the Affiliate nor (where applicable) any of its directors, Authorized Representatives or Beneficial Owners is subject to Sanctions, listed on any applicable sanctions list, or is a PEP for whom the provision of the Program would be prohibited or restricted; \n- the Affiliate’s participation in the Program does not breach any law or regulation applicable to it, or any contractual obligation it owes to a third party; \n- the Affiliate shall comply with all laws, regulations and industry codes applicable to its promotional and marketing activities, including anti-spam laws (such as CAN-SPAM, PECR and the ePrivacy Directive, as applicable), consumer-protection laws, advertising standards and tax laws; and \n- the information the Affiliate submits is accurate, complete and up-to-date, and the Affiliate shall keep it up-to-date while it participates in the Program. \n","parentId":null},{"id":289,"content":"The Affiliate shall comply with all applicable requirements of Data Protection Legislation in respect of any personal data that the Affiliate collects, handles or discloses in connection with the Program. The Affiliate acts as an independent controller in respect of its own marketing data (including mailing lists and audience data) and shall have its own lawful basis for each processing activity. Section F below sets out additional data-protection obligations.","parentId":null},{"id":290,"content":"The Affiliate shall not promote the Services to persons under 18 years of age, to persons who are not eligible to use the Services, or to persons located in a Restricted Jurisdiction. ","parentId":null},{"id":291,"content":"The Affiliate shall not directly or indirectly use, post or promote PSTNET content, the Services or the PSTNET Brands in association with any content or material that is (or that the Administrator, acting reasonably, considers may be) illegal, unlawful, infringing, deceptive, misleading, obscene, defamatory, or harmful to the PSTNET Brands, credibility, image or reputation. ","parentId":null},{"id":292,"content":"The Affiliate may market the Services only in accordance with these Affiliate Terms and with any additional conditions, format requirements or brand guidelines issued by the Administrator. The Affiliate shall use only advertising creative (banners, mailers, editorial copy, images, logos) approved by the Administrator, and shall not alter such creative without the Administrator’s prior written consent. The Administrator may update approved creative; the Affiliate shall implement updates within three (3) days of receipt of the updated creative. ","parentId":null},{"id":293,"content":"No brand other than the PSTNET Brands and the Affiliate’s own brand shall be displayed on Affiliate marketing material promoting the Services without the Administrator’s prior written consent. ","parentId":null},{"id":294,"content":"Each Customer may hold only one Account. An Affiliate is entitled to Commission only in respect of the original Tagged Account of a Qualified Customer; a Qualified Customer cannot be re-tagged to a different Affiliate. Customers who sign up without using a Tracking Link will not be tagged to any Affiliate at any time, even if they subsequently click a Tracking Link. ","parentId":null},{"id":295,"content":"The Affiliate shall not offer cash back, rebates, incentives or kickbacks to any New Customer or Qualified Customer in consideration for the referral, except in accordance with a written arrangement pre-approved by the Administrator. ","parentId":null},{"id":296,"content":"The Affiliate shall not, in connection with search-engine marketing (SEM) or pay-per-click advertising (PPC) on any platform including Google and Bing: (i) use the PSTNET Brands, trademarks or domain variations (including misspellings and typographic variants) in ad copy, URLs, ad paths or keywords; or (ii) bid on PSTNET-branded search queries. Affiliates must direct PPC and SEM traffic through Affiliate Websites and must not redirect traffic directly to PSTNET Websites. Landing pages provided by the Administrator may be used on Affiliate Websites only, and the Affiliate shall not operate any URL containing the word “PSTNET” or a confusingly similar variant. ","parentId":null},{"id":297,"content":"The Affiliate shall not advertise the Services on social-media platforms, where the Administrator is running paid promotion of the Services on the same platform, except with the Administrator’s prior written consent.","parentId":null},{"id":298,"content":"The Affiliate shall not conduct email-marketing activity in relation to the Services unless expressly agreed in writing with the Administrator, and in any case shall do so only in compliance with Data Protection Legislation and anti-spam laws. All marketing emails must include a functioning unsubscribe mechanism, and the Affiliate shall not contact recipients who have not consented (where consent is the required legal basis) or who have unsubscribed. ","parentId":null},{"id":299,"content":"The Affiliate shall not engage in SMS, fax, broadcast, telemarketing or offline directmarketing activity in relation to the Services without the Administrator’s prior written consent, and shall not use malware, spyware, adware, cookie stuffing, peer-to-peer distribution, iframes or doorway pages to promote the Services.","parentId":null},{"id":300,"content":"The Affiliate is responsible for the accuracy and lawfulness of content on the Affiliate Websites and for keeping such content up to date. The Affiliate shall not copy, mimic or present confusingly similar versions of the PSTNET Websites or PSTNET Brands. ","parentId":null},{"id":301,"content":"The Affiliate shall remove or update material relating to PSTNET within twenty-four (24) hours of a request from the Administrator.","parentId":null},{"id":302,"content":"The Affiliate is responsible for its own advertising and promotional costs and any other expenses arising in connection with its participation in the Program. ","parentId":null},{"id":303,"content":"The Affiliate shall not open more than one Affiliate Account without the Administrator’s prior written consent. The Affiliate shall not earn Commission in respect of its own activity as a Customer. ","parentId":null},{"id":304,"content":"The Affiliate shall, at Registration and thereafter upon reasonable request, list the websites, social-media channels, mailing lists and other promotional assets through which it intends to promote the Services. The Administrator may, acting reasonably, decline or revoke approval of any such asset if it does not meet the Administrator’s requirements. ","parentId":null},{"id":305,"content":"The Affiliate warrants that it will not open more than one Affiliate Account without our prior written consent and acknowledges that it will not earn Commission on its own transactions through the Services.","parentId":null},{"id":306,"content":"Participation in the Program is intended for the Affiliate’s direct use. The Affiliate shall not open an Affiliate Account on behalf of an undisclosed third party, broker an Affiliate Account, or transfer the Affiliate Account to another beneficial owner. Where the Affiliate wishes to transfer the Affiliate Account (for example, following a corporate reorganization or a change of sole trader to legal entity), the Affiliate shall request the Administrator’s written approval; approval is at the Administrator’s discretion and may be conditional on re-Verification. ","parentId":null},{"id":307,"content":"The Affiliate shall not, directly or indirectly, circumvent or attempt to circumvent the Administrator’s Financial Partners in accordance with clause 16.3 of the Terms (anticircumvention), and shall not introduce Qualified Customers for the purpose of establishing a direct relationship with any Financial Partner outside of the System. ","parentId":null}]},{"id":44,"__component":"ui.list","type":null,"title":"F. Intellectual Property and Data Protection ","isolated":null,"item":[{"id":308,"content":"License to use PSTNET Brands. The Administrator grants the Affiliate a limited, royalty-free, non-exclusive, personal, non-transferable, non-assignable and non-sublicensable license to display the PSTNET Brands on Affiliate Websites solely for the purpose of promoting and marketing the Services in accordance with these Affiliate Terms. The license terminates automatically on termination of these Affiliate Terms. ","parentId":null},{"id":309,"content":"Affiliate acknowledgements. The Affiliate acknowledges and agrees that: (i) it shall use the PSTNET Brands only as permitted by these Affiliate Terms and in accordance with the brand guidelines issued by the Administrator from time to time; (ii) the PSTNET Brands are and shall remain the sole property of the Administrator, and all goodwill arising from the Affiliate’s use of the PSTNET Brands shall inure to the Administrator; (iii) these Affiliate Terms do not grant the Affiliate any right of ownership in the PSTNET Brands; and (iv) the Affiliate shall not register, or attempt to register, any PSTNET Brand, confusingly similar mark, or domain name incorporating any PSTNET Brand, and shall not contest the validity of any PSTNET Brand. ","parentId":null},{"id":333,"content":"Data protection. To the extent the Affiliate processes personal data in connection with the Program (including personal data of its own subscribers, audience members or referred New Customers before they complete Registration), the Affiliate acts as an independent controller in respect of that personal data. The Parties are not joint controllers. The Affiliate shall: (i) have a lawful basis under Data Protection Legislation for each processing activity; (ii) provide appropriate notice to data subjects; (iii) implement appropriate technical and organizational security measures; (iv) respect datasubject rights; and (v) notify the Administrator without undue delay of any personal data breach that affects personal data shared with, or received from, the Administrator. The Administrator’s processing of personal data received from the Affiliate is governed by the Privacy Policy. ","parentId":null}]},{"id":45,"__component":"ui.list","type":"decimal","title":"G. Confidentiality","isolated":true,"item":[{"id":310,"content":"Each Party undertakes that it shall not at any time disclose to any person any non-public information concerning the business, affairs, customers, clients, suppliers, Financial Partners or pricing of the other Party that it receives in connection with these Affiliate Terms (“Confidential Information”), except as permitted by clause G.2. ","parentId":null},{"id":311,"content":"Each Party may disclose the other Party’s Confidential Information: (i) to its employees, officers, representatives, professional advisers and Financial Partners who need to know such information for the purposes of the Program and who are bound by equivalent confidentiality obligations; (ii) as required by Applicable Law, by a court of competent jurisdiction or by a competent governmental or regulatory authority; or (iii) to the extent the information is already in the public domain through no breach of these Affiliate Terms. \n","parentId":null},{"id":312,"content":"Neither Party shall use the other Party’s Confidential Information for any purpose other than to perform its obligations or exercise its rights under these Affiliate Terms. ","parentId":null}]},{"id":46,"__component":"ui.list","type":null,"title":"H. Limitation of Liability","isolated":null,"item":[{"id":313,"content":"The Administrator shall not be responsible for the Affiliate’s marketing activities, the content of Affiliate Websites, or any act or omission of a New Customer, Qualified Customer or third party. The Administrator shall not be liable to the Affiliate for loss of profits, loss of revenue, loss of or damage to reputation or goodwill, loss of opportunity, or loss or liability under any other contract, in each case arising out of or in connection with these Affiliate Terms, whether in contract, tort (including negligence) or otherwise. ","parentId":null},{"id":314,"content":"Subject to clause H.3, the Administrator’s total aggregate liability to the Affiliate under or in connection with these Affiliate Terms, in contract, tort (including negligence) or otherwise, shall not exceed the greater of (i) the total Commission paid by the Administrator to the Affiliate in the three (3) months immediately preceding the first event giving rise to the claim or series of related claims, and (ii) one thousand United States dollars (USD 1,000). This cap is consistent with clause 15.5 of the Terms. ","parentId":null},{"id":315,"content":"Nothing in these Affiliate Terms limits or excludes liability for fraud, fraudulent misrepresentation, death or personal injury caused by negligence, or any other liability that cannot be excluded or limited under Applicable Law. ","parentId":null}]},{"id":47,"__component":"ui.list","type":null,"title":"I. Termination","isolated":null,"item":[{"id":317,"content":"Either Party may terminate these Affiliate Terms with immediate effect, with or without cause, by giving written notice to the other Party. The Administrator may in particular terminate with immediate effect (and without any obligation to provide an opportunity to cure) on any breach by the Affiliate of these Affiliate Terms, the Terms or Applicable Law. ","parentId":null},{"id":318,"content":"On termination, the Affiliate shall immediately: (i) cease promoting PSTNET and the Services; (ii) remove all Tracking Links, PSTNET Brands and Administrator-provided marketing materials from all Affiliate Websites and channels; and (iii) destroy or return to the Administrator any Confidential Information in its possession (subject to any retention required by Applicable Law). ","parentId":null},{"id":319,"content":"No Commission is payable in respect of Qualified Transactions generated after termination, and no Commission is payable in respect of New Customers reaching PSTNET through Tracking Links after termination. Termination does not affect rights, remedies, obligations or liabilities (including Commission accrued) that arose before the date of termination, save that where the Administrator terminates for breach by the Affiliate, the Administrator may withhold unpaid Commission and apply it against amounts owed by the Affiliate, including under clauses C.8 and C.9. ","parentId":null},{"id":320,"content":"The following sections shall survive termination of these Affiliate Terms: Section A (Definitions), Section C.8 (Adjustment and clawback), Section C.9 (Negative balance), Section F (Intellectual Property and Data Protection), Section G (Confidentiality), Section H (Limitation of Liability), this Section I and Section J (General). \n","parentId":null}]},{"id":48,"__component":"ui.list","type":null,"title":"J. General","isolated":true,"item":[{"id":321,"content":"Governing law and jurisdiction. These Affiliate Terms (and any dispute or claim arising out of or in connection with them or their subject matter, including noncontractual disputes or claims) are governed by and construed in accordance with the laws of the Turks and Caicos Islands, without regard to conflict-of-laws principles. The courts of the Turks and Caicos Islands have exclusive jurisdiction to settle any such dispute or claim. This clause J.1 is consistent with clause 21 of the Terms. ","parentId":null},{"id":322,"content":"Third-party rights. No person who is not a Party has any right to enforce any term of these Affiliate Terms. ","parentId":null},{"id":323,"content":"Independent contractors. These Affiliate Terms do not create, and shall not be construed as creating, any partnership, joint venture, agency, employment or fiduciary relationship between the Parties. ","parentId":null},{"id":324,"content":"Entire agreement. These Affiliate Terms (as amended from time to time), together with the Terms, the Internal Policies and the Affiliate Program Registration Form, constitute the entire agreement between the Parties in relation to the Program and supersede any prior understanding, representation or statement on the same subject matter. ","parentId":null},{"id":325,"content":"Amendments. The Administrator may amend these Affiliate Terms from time to time by publication on the Website, with notice given in accordance with clause 3.6 of the Terms. Continued participation in the Program after an amendment takes effect constitutes acceptance of the amended Affiliate Terms. ","parentId":null},{"id":326,"content":"Waiver. A waiver of any term or right under these Affiliate Terms is effective only if given in writing and signed (or electronically signed) by the Party giving the waiver, and only in respect of the particular instance and for the particular purpose for which it is given. A failure or delay in exercising any right or remedy does not constitute a waiver of that or any other right or remedy. Rights and remedies under these Affiliate Terms are cumulative and do not exclude rights and remedies available at law. ","parentId":null},{"id":327,"content":"Severability. If any provision of these Affiliate Terms is held by a court of competent jurisdiction to be invalid, illegal or unenforceable (in whole or in part), the remaining provisions shall continue in full force and effect. The Parties shall in good faith negotiate a valid, legal and enforceable replacement provision that reflects the commercial intent of the original provision as closely as possible. ","parentId":null},{"id":328,"content":"Assignment. The Affiliate shall not assign, transfer or sub-contract any of its rights or obligations under these Affiliate Terms without the prior written consent of the Administrator. The Administrator may assign, transfer or sub-contract its rights or obligations under these Affiliate Terms without the Affiliate’s consent, including to an affiliate of the Administrator or in connection with a merger, reorganization or sale of assets. ","parentId":null},{"id":334,"content":"Notices. Notices under these Affiliate Terms may be given by email to the addresses registered in the Affiliate Account and the Administrator’s customer-support address (customersupport@pst.net), or through the Affiliate Account dashboard, in accordance with clause 23.1 of the Terms. ","parentId":null}]}]}},{"id":16,"attributes":{"title":"Restrictions","createdAt":"2023-05-05T06:34:47.071Z","updatedAt":"2026-10-16T13:44:59.181Z","publishedAt":"2023-05-05T08:06:59.218Z","slug":"restrictions","position":null,"tosType":null,"content":[{"id":59,"__component":"ui.list","type":"decimal","title":"Purpose and Scope","isolated":false,"item":[{"id":448,"content":"This Restrictions document (the “Restrictions”) sets out the Supported Countries, Restricted Jurisdictions, restricted merchants, supported and restricted Merchant Category Codes (MCCs), and the transactional and usage restrictions that apply to the use of the PSTNET platform (the “System”) operated by ADV Summit Advisors Limited (the “Administrator”, and together with its affiliates, “PSTNET”, “we”, “us” or “our”).","parentId":null},{"id":449,"content":"These Restrictions are an Internal Policy and form an integral part of the Terms of Service published at https://pst.net/legal/tos  (the “Terms”). They should be read together with the AML Policy, the Privacy Policy, the Cookie Policy and the Affiliate Program Terms and Conditions. Capitalized terms used but not defined in these Restrictions have the meaning given to them in the Terms. In the event of any conflict between these Restrictions and the Terms, the Terms prevail unless these Restrictions expressly state otherwise.","parentId":null},{"id":450,"content":"The lists and parameters set out in these Restrictions may be updated by the Administrator from time to time by publication on the Website, in particular (but not only) where required by Applicable Law, by the rules of a card scheme, or by a Financial Partner. The version published on the Website at any given moment is the version that applies at that moment. The Administrator encourages Customers to review these Restrictions regularly.","parentId":null},{"id":451,"content":"Three concepts are used in these Restrictions and should not be confused:\n\n- **Supported Countries** — countries and territories in which the PSTNET Card may be used to make payments to merchants registered there. Being a Supported Country does not mean that a resident of that country can onboard as a Customer. It means only that Customers (wherever based) may transact with merchants located there.\n- **Restricted Jurisdictions** — countries and territories whose citizens or residents, and legal entities incorporated or established there, are not eligible to register as Customers or to use the System. The list of Restricted Jurisdictions is independent of the list of Supported Countries, and some countries appear on both lists (for example, the United States, Canada and Serbia — where PSTNET Card Transactions can be processed to merchants registered there, but individuals and entities resident, located or incorporated there cannot onboard as Customers).\n- **Limited-Service Jurisdictions** — countries whose residents and entities may register as Customers but to whom certain System Services, in particular those involving Digital Currency, are not available because of local regulation. The list of Limited-Service Jurisdictions and the applicable limitations are set out in clause 3.4.","parentId":null}]},{"id":60,"__component":"ui.list","type":"decimal","title":"Supported Countries (Merchant Jurisdictions)","isolated":false,"item":[{"id":452,"content":"The PSTNET Card may be used to make payments to merchants legally registered in the following countries and territories. ISO 3166-1 alpha-3 country codes are shown in parentheses.\n\n| List of Countries|    |  | \n|:---|:---|:---|\n| American Samoa (ASM)| Andorra (AND) | Anguilla (AIA)|\n|Argentina (ARG) | Aruba (ABW)| Australia (AUS)|\n| Austria (AUT) | Bahamas (BHS) | Barbados (BRB)|\n|Belgium (BEL) | Belize (BLZ)| Bermuda (BMU)|\n| Bonaire (BES-BON)| Brazil (BRA) | British Virgin Islands (VGB)|\n| Bulgaria (BGR)| Canada (CAN)| Cayman Islands (CYM)|\n| Chile (CHL)| Colombia (COL)| Costa Rica (CRI)|\n|Croatia (HRV)| Curaçao (CUW)| Cyprus (CYP)|\n| Czech Republic (CZE)| Denmark (DNK)| Egypt (EGY)|\n| Estonia (EST)| Falkland Islands (FLK)| Finland (FIN)|\n| France (FRA)| Germany (DEU)| Gibraltar (GIB)|\n|Greece (GRC)| Guam (GUM)| Guernsey (GGY)|\n|Hong Kong (HKG) | Hungary (HUN)| Iceland (ISL)|\n| India (IND)| Ireland (IRL)| Isle of Man (IMN)|\n| Israel (ISR)| Italy (ITA)| Japan (JPN)|\n| Jersey (JEY)| Latvia (LVA)| Liechtenstein (LIE)|\n| Lithuania (LTU)| Luxembourg (LUX)| Macau (MAC)|\n| Malaysia (MYS)| Maldives (MDV)| Malta (MLT)|\n| Mauritius (MUS)| Mexico (MEX)| Moldova (MDA)|\n|Monaco (MCO)| Montserrat (MSR)| Netherlands (NLD)|\n| Nevis (KNA) | New Zealand (NZL)| Northern Mariana Islands (MNP)|\n| Norway (NOR)| Oman (OMN) | Panama (PAN)|\n| Pitcairn Islands (PCN)| Poland (POL)| Portugal (PRT)|\n| Puerto Rico (PRI) | Qatar (QAT) | Romania (ROU)|\n| Saba (BES-SAB)| Saint Helena, Ascension and Tristan da Cunha (SHN)| San Marino (SMR)|\n| Saudi Arabia (SAU)| Serbia (SRB)| Seychelles (SYC)|\n| Singapore (SGP)| Sint Eustatius (BES-EUS)| Sint Maarten (SXM)|\n| Slovakia (SVK)| Slovenia (SVN)| South Korea (KOR)|\n| Spain (ESP)| Sweden (SWE)| Switzerland (CHE)| \n| Taiwan (TWN)| Thailand (THA) | Turkey (TUR)|\n| United Arab Emirates (ARE)| United Kingdom (GBR)| United States (USA)|\n| Uruguay (URY)| US Virgin Islands (VIR)| |","parentId":null},{"id":453,"content":"The list above may be updated from time to time. The Administrator does not warrant that every merchant in a Supported Country will accept or correctly process a PSTNET Card Transaction; acceptance depends on the merchant, the acquirer and the relevant card-scheme rules.","parentId":null}]},{"id":61,"__component":"ui.list","type":"decimal","title":"Restricted Jurisdictions (Customer Onboarding)","isolated":false,"item":[{"id":454,"content":"The Administrator does not accept Applicants, and does not provide the System Services, to natural persons who are citizens, residents or nationals of, or to legal entities incorporated, registered, established or having a place of business in, any of the following countries and territories (each a “Restricted Jurisdiction”). Where a person has a connection to a Restricted Jurisdiction (by residence, incorporation, activity or beneficial ownership), the Administrator may decline Registration, decline to complete Verification or terminate the business relationship.\n\n| List of Countries|    |\n|:---|:---|\n| Islamic Republic of Afghanistan| Republic of Albania|\n| American Samoa (Territory of the United States) | Republic of Belarus|\n| Bosnia and Herzegovina | Republic of Burundi|\n| Canada | Central African Republic|\n| People’s Republic of China| Republic of Congo|\n| Democratic Republic of the Congo | Republic of Cuba|\n| Guam (Territory of the United States)| Hong Kong Special Administrative Region of the People’s Republic of China|\n| Islamic Republic of Iran| Republic of Iraq|\n| Republic of Kosovo| Lebanese Republic (Lebanon)|\n| Republic of Liberia| State of Libya|\n| Montenegro| Republic of the Union of Myanmar (Burma)|\n| Republic of Nicaragua| Democratic People’s Republic of Korea (North Korea)|\n| Republic of North Macedonia| Commonwealth of the Northern Mariana Islands (Territory of the United States)|\n| Commonwealth of Puerto Rico (Territory of the United States) | Russian Federation (Russia)|\n| Republic of Serbia| Federal Republic of Somalia|\n| Republic of South Sudan| Republic of the Sudan|\n| Syrian Arab Republic| Turks and Caicos Islands|\n| Ukraine | United States of America|\n| United States Virgin Islands (Territory of the United States) | Bolivarian Republic of Venezuela|\n| Republic of Yemen | Republic of Zimbabwe|","parentId":null},{"id":455,"content":"Some countries and territories appear on both the Supported Countries list in Section 2 and the Restricted Jurisdictions list in this Section 3 (including the United States and US territories, Canada, Serbia and Hong Kong). This is intentional: Customers (wherever based) may transact with merchants registered in those countries, but persons connected with those countries may not onboard as Customers. These lists address different concepts, as explained in clause 1.4.","parentId":null},{"id":456,"content":" In addition to the list above, the Administrator applies the Sanctions framework described in the Terms and the AML Policy, which may result in Customers, Beneficial Owners, directors, Authorized Representatives or Transactions being declined, suspended or terminated regardless of whether the relevant country is listed in this Section 3.","parentId":null},{"id":647,"content":"Limited-Service Jurisdictions (European Economic Area and United Kingdom). Certain System Services are not available to persons connected with the following jurisdictions: (a) the member states of the European Union and the European Economic Area — Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden (together, the “EEA”) — in which Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”) applies and the Administrator is not authorised as a crypto-asset service provider; and (b) the United Kingdom (England, Wales, Scotland and Northern Ireland), in which the Administrator is not authorised or registered by the Financial Conduct Authority and does not communicate financial promotions relating to crypto-assets (the EEA and the United Kingdom together, the “Limited-Service Jurisdictions”). Natural persons who are residents of, and legal entities incorporated, registered, established or having a place of business in, a Limited-Service Jurisdiction may register as Customers and use the PSTNET Card, but the following System Services are not offered to, and may not be used by, such persons: (i) the transfer of Digital Currency to the Administrator as Collateral or by way of any other deposit or top-up; (ii) the withdrawal of Funds in Digital Currency; (iii) the Merchant Service; and (iv) any other System Service involving the receipt, holding, conversion or transfer of crypto-assets. Customers connected with a Limited-Service Jurisdiction may fund their Wallets and withdraw Funds only by the fiat-currency methods displayed in the Account dashboard. The Administrator does not market or direct crypto-asset services to persons in the Limited-Service Jurisdictions, will decline any attempt by such a Customer to use a service listed in (i) to (iv), and may suspend the Account under Section 17 of the Terms where such an attempt is made. The Administrator may add countries to, or remove countries from, this clause, and may vary the limitations, by publication on the Website.","parentId":null}]},{"id":62,"__component":"ui.list","type":"decimal","title":"Restricted Merchant Category Codes (MCCs)","isolated":false,"item":[{"id":457,"content":"The PSTNET Card may not be used to make payments to merchants classified under any of the Merchant Category Codes (MCCs) listed below. Attempts to make such payments will generally be declined at authorization. Where a payment is nonetheless processed, it is treated as a breach of these Restrictions and the Terms, and may result in the consequences set out in Section 6.\n\n|MCC | Description|\n|----------|:-------------|\n|**4214**| Motor freight carriers and trucking — local and long-distance, moving and storage companies, local delivery services|\n|**4215**| Courier services — air and ground, freight forwarders|\n|**4812**| Telecommunication equipment and telephone sales|\n|**4814**| Telecommunication services, including local and long-distance calls, credit-card calls, calls through use of magnetic-stripe reading telephones, and fax services|\n|**4829**| Money transfers — transactions in which funds are delivered or made available to a person or account, including not-face-to-face transfers conducted over the internet|\n|**4899**| Cable, satellite and other pay television/radio/streaming services|\n|**5172**| Petroleum and petroleum products (wholesale only)|\n|**5533**| Automotive parts and accessories stores|\n|**5541**| Service stations (with or without ancillary services)|\n|**5542**| Automated fuel dispensers|\n|**5552**| Electric vehicle charging|\n|**5944**| Watch, clock, jewellery and silverware stores|\n|**6012**| Financial institutions — merchandise and services (including balance-inquiry fees, foreign-currency purchases and travellers cheques)|\n|**6051**| Quasi-cash — non-financial institutions (purchase of cheques, foreign currencies, e-wallet top-ups, merchant accounts and other quasi-cash transactions at non-financial institutions) |\n|**6211**| Securities — brokers and dealers (merchants that buy and sell stocks, bonds, commodities and funds)|\n|**6540**| Account funding, stored-value card purchase, prepaid load (non-financial institution)|\n|**7273**| Dating and escort services (including online, personal-video and similar services)|\n|**7297**| Massage parlours|\n|**7800**| State lotteries|\n|**7801**| Internet gambling (merchants licensed to operate an internet gambling system or platform)|\n|**7802**| Horse and dog racing (pari-mutuel and similar)| \n|**7994**| Video-game arcades and entertainment centres|\n|**7995**| Gambling (other than ATM) — betting, lottery, in-flight commercial gaming, purchase of chips or other value used for gambling|\n|**8398**| Charitable and social-service organisations|","parentId":null},{"id":458,"content":"The list of restricted MCCs may be expanded, reduced or otherwise amended by the Administrator from time to time, in particular where required by a card scheme, a Financial Partner or Applicable Law. Approved MCCs may also be opened or closed for particular card products without amendment of these Restrictions.","parentId":null},{"id":459,"content":"Even where a merchant is classified under an MCC that is not listed in clause 4.1, the Administrator reserves the right to decline or reverse a Transaction where the merchant, the Transaction or the Customer’s activity gives rise to compliance, fraud, risk or reputational concerns, in accordance with Sections 16, 17 and 18 of the Terms.","parentId":null}]},{"id":63,"__component":"ui.list","type":"decimal","title":"Merchant and Usage Restrictions","isolated":false,"item":[{"id":460,"content":"In addition to the MCC restrictions in Section 4, the following usage restrictions apply to the PSTNET Card and the System. A breach of any of these restrictions may result in the consequences set out in Section 6 and in Sections 17 and 18 of the Terms.","parentId":null},{"id":461,"content":"Transactions exceeding available balance. Attempting Transactions that materially exceed the available balance (typically by more than forty percent (40%) above the available balance), using merchant accounts or third-party services artificially to reduce chargeback ratios, and engaging in patterns of very small (“micro”) Transactions for purposes other than genuine merchant payments, are prohibited. Such activity may result in card freeze, Suspension of Account and termination under the Terms.","parentId":null},{"id":462,"content":"Product-specific cards. Where the Administrator makes available a PSTNET Card configured for a specific use case, that card may be used only with MCCs for which it has been designated. Use of such a card for any other purpose constitutes a breach of these Restrictions.","parentId":null},{"id":463,"content":"Reversals and refunds. Where the volume of reversed Transactions or refunds associated with the Account exceeds thirty percent (30%) of the total Transaction amount over a measurement period determined by the Administrator, the Account may be subject to the consequences set out in Section 6 (including a reversal-based penalty) and to suspension under the Terms. Where the reversed or refunded proportion exceeds fifty percent (50%), the Administrator may terminate the business relationship in accordance with Section 18 of the Terms.","parentId":null},{"id":464,"content":"Chargebacks. Transactions initiated through the PSTNET Card are settled through the Administrator’s Financial Partners and the applicable card scheme. The Administrator does not itself process chargebacks and will not initiate chargeback requests on behalf of Customers through the System. Any rights that a Customer may have to dispute a Transaction directly with the Issuer, a card scheme or a merchant under Applicable Law or scheme rules are not affected by this clause. Customers remain responsible for all Chargeback-related costs under Section 10 of the Terms.","parentId":null},{"id":465,"content":"In-platform transfers. Where the System supports transfers between Customers (including between Wallets of the same Customer or to Wallets of other Customers), such transfers are final and cannot be reversed through the System once executed. Customers should verify all Transaction details before confirming a transfer.","parentId":null},{"id":466,"content":" Scope of card use. The PSTNET Card is intended solely for direct merchant Transactions. It is not intended for person-to-person (P2P) transfers or to receive incoming funds. Incoming Transactions and P2P credits may be declined by the Administrator’s Financial Partners and may, at the discretion of those Financial Partners, be returned to the originator or held pending investigation. The Administrator is not responsible for the actions of Financial Partners in this respect.","parentId":null},{"id":467,"content":"Resale of cards. Customers may not resell, transfer, lease, licence, sublicense or otherwise make available a PSTNET Card (or any credentials associated with it) to any third party, including an undisclosed beneficial user of the Account. Breach of this clause is treated as a material breach of the Terms and may result in immediate Suspension of Account and termination.","parentId":null},{"id":468,"content":"Postal and delivery services. Use of the PSTNET Card for payments to postal, parcel or delivery services is prohibited, except where expressly permitted by the Administrator in writing.","parentId":null},{"id":469,"content":"Gift cards. Use of the PSTNET Card to purchase gift cards, stored-value cards, loadable prepaid cards or equivalent instruments is prohibited.","parentId":null},{"id":470,"content":"Twitter/X advertising and merchant tools. Use of the PSTNET Card to fund advertising, merchant, business or promoted-content tools on Twitter/X (formerly Twitter), including Twitter Ads, X Ads and any successor or equivalent product, is prohibited unless expressly approved in writing by the Administrator. This clause 5.11 applies only to Twitter/X and does not restrict the use of the PSTNET Card on other advertising platforms supported by the Administrator, the funding of which is a core intended use of the System. Unauthorised use in breach of this clause may result in card freeze and Suspension of Account.","parentId":null},{"id":471,"content":"Telecommunications. Transactions involving Voice-over-Internet-Protocol (VoIP) systems, mobile-communication services and remote-management software are prohibited.","parentId":null},{"id":472,"content":"Illegal or political activity. The PSTNET Card and the System may not be used for any activity that is illegal under Applicable Law in any jurisdiction relevant to the Customer or the Transaction. In particular, the PSTNET Card may not be used for political advertising, political fundraising, political campaign finance, lobbying, or any Transaction the purpose of which is to influence a political process or public official. This restriction is in addition to the Administrator’s obligations in respect of politically exposed persons under the AML Policy.","parentId":null},{"id":473,"content":"Compliance generally. The Customer shall comply with all card-scheme rules, Financial Partner requirements and other applicable rules that apply to the PSTNET Card and the System. The Administrator may update these Restrictions to reflect such rules and requirements from time to time.","parentId":null},{"id":481,"content":"Dormant card support limit. Where a PSTNET Card has remained inactive (without any Transaction, top-up or other Customer-initiated activity) for a continuous period of more than one hundred and eighty (180) days, the Administrator shall have no obligation to provide support, investigation, refund, reconciliation or merchant-dispute assistance in respect of any Transaction made on, or any other activity associated with, that PSTNET Card before the start of that period of inactivity. This clause 5.15 is an operational limitation on the Administrator's support obligations only. It does not affect (i) any right the Customer may have to dispute a Transaction directly with the Issuer, a card scheme or a merchant under Applicable Law or scheme rules, (ii) the Customer's right to a refund of any unused balance in accordance with Sections 18.6 to 18.9 of the Terms, or (iii) the Administrator's obligations under Applicable Law that cannot be excluded by contract.","parentId":null},{"id":482,"content":"Incoming amounts on voluntarily deactivated cards. Where the Customer has voluntarily deactivated a PSTNET Card through the Account dashboard (the \"Deactivation Date\"), and an incoming amount of any kind (including a merchant refund, reversal, chargeback credit, adjustment or other inbound credit) is received in respect of that PSTNET Card more than thirty (30) days after the Deactivation Date, the Customer shall be deemed to have abandoned that incoming amount, and the amount shall be forfeited to the Administrator as compensation for the operational, reconciliation, compliance and Financial-Partner costs of receiving and handling the late inbound amount on a closed card. The Administrator may (but is not obliged to) notify the Customer at the email address registered in the Account of the receipt of such an incoming amount. For the purposes of this clause 5.16, a PSTNET Card shall also be treated as voluntarily deactivated by the Customer where: (a) the Customer's card subscription expires without renewal; or (b) the Administrator deactivates the PSTNET Card because the Customer has failed to pay the applicable monthly card fee or any other Fee that is a precondition to the continued operation of the card. In each such case, the Deactivation Date shall be the date on which the subscription expired or the date on which the card was deactivated for non-payment, as applicable. This clause 5.16 applies only to PSTNET Cards deactivated voluntarily by the Customer (or treated as so deactivated under paragraph (a) or (b) above); PSTNET Cards deactivated by the Administrator for compliance, risk, fraud or other reasons unrelated to non-payment of Fees are governed by Section 18 of the Terms. This clause 5.16 does not affect (i) any right the Customer may have to dispute a Transaction directly with the Issuer, a card scheme or a merchant under Applicable Law or scheme rules, (ii) the Customer's right under Sections 18.6 to 18.9 of the Terms to a refund of any unused balance on termination of the Account, or (iii) the Administrator's obligations under Applicable Law that cannot be excluded by contract.","parentId":null},{"id":484,"content":"Merchant abuse. Any abuse of a merchant with which the Customer transacts using the PSTNET Card or the System is strictly prohibited. This applies to all merchants (whether social-media platforms, advertising platforms, e-commerce merchants, service providers or any other counterparty) and includes, without limitation: (a) initiating or threatening chargebacks, disputes or reversals in bad faith, including where the goods or services were in fact delivered and consumed (commonly known as “friendly fraud” or “first-party misuse”); (b) misrepresenting the Customer’s identity, business, purpose or the nature of a Transaction to the merchant; (c) using the PSTNET Card in a manner that violates the merchant’s own terms of service, advertising policies, community standards or acceptable-use rules; (d) using cloaking, dark patterns, deceptive creative, misappropriated content or other techniques designed to circumvent a merchant’s review, moderation or enforcement systems; (e) harassing, abusing, defrauding or attempting to intimidate a merchant, its personnel, its support channels or its dispute-resolution processes; (f) creating multiple merchant accounts to evade a merchant’s enforcement action, rate limits or account bans; and (g) any pattern of Transactions the purpose or effect of which is to extract value from a merchant without providing lawful consideration, or to damage the merchant’s platform standing, systems or reputation. Any breach of this clause 5.17 may result in immediate deactivation of the relevant PSTNET Card and immediate Suspension or Termination of the Account under Sections 17 and 18 of the Terms, in addition to the other consequences set out in Section 6.","parentId":null}]},{"id":64,"__component":"ui.list","type":"decimal","title":"Consequences of Breach","isolated":false,"item":[{"id":474,"content":"Where the Administrator determines that a Customer has breached these Restrictions, one or more of the following consequences may apply, in addition to any other right or remedy the Administrator may have under the Terms, any other Internal Policy or Applicable Law:\n\n- the relevant PSTNET Card may be frozen or deactivated;\n- the relevant Transaction may be declined, reversed or voided;\n- a Suspension of Account may be applied under Section 17 of the Terms;\n- the business relationship may be terminated under Section 18 of the Terms;\n- Fees already earned may be retained by the Administrator under clause 18.5 of the Terms; and/or\n- the Administrator may report the breach to competent authorities and to relevant Financial Partners in accordance with the AML Policy, the Privacy Policy and Applicable Law.","parentId":null},{"id":475,"content":"Breach penalty. In addition to the consequences set out in clause 6.1, where a Customer has breached clauses 5.2, 5.3, 5.4, 5.7, 5.8, 5.9, 5.10, 5.11, 5.12 or 5.13, or has executed a Transaction with a merchant classified under a restricted MCC in Section 4, the Administrator may deduct from the Account or from the relevant PSTNET Card balance, as liquidated damages for costs incurred by the Administrator and its Financial Partners as a consequence of the breach, an amount equal to thirty percent (30%) of the Transaction value, subject to a minimum deduction of five United States dollars (USD 5) per breach. The Parties agree that the amount is a genuine pre-estimate of the costs reasonably expected to arise from such a breach (including card-scheme, issuer, acquirer and compliance costs) and is not a penalty. Nothing in this clause 6.2 limits the Administrator’s right to recover any additional amounts properly owed to it under the Terms (including unpaid Fees, Chargebacks, reversals, network costs and indemnification amounts) or to apply clause 18.5 of the Terms.","parentId":null},{"id":476,"content":"Dormancy on closed cards. Where a PSTNET Card has been deactivated, Customers are encouraged to transfer any remaining balance to the Wallet or, if the Account has been closed, to claim a refund in accordance with Sections 18.6 to 18.8 of the Terms. Amounts that remain unclaimed following termination of the Account are treated in accordance with clause 18.9 of the Terms (Unclaimed Funds).","parentId":null},{"id":477,"content":"Review of enforcement actions. A Customer who believes that an action taken under these Restrictions is based on incorrect facts, including where the Customer has been incorrectly identified as being in breach, may contact Customer Support at customersupport@pst.net to request a review. The Administrator shall consider the request in good faith and, where the determination is found to be incorrect, shall reverse the relevant action. Nothing in this clause limits the Administrator’s right to take protective action in the meantime.","parentId":null}]},{"id":65,"__component":"ui.list","type":"decimal","title":"Merchant-Specific Restrictions","isolated":false,"item":[{"id":478,"content":"In addition to the Merchant Category Code restrictions in Section 4, the Administrator may restrict Transactions with specific merchants (identified by merchant identifier, acquirer reference, domain, BIN or other identifying data) where past incidents, fraud intelligence, scheme-rule requirements or Financial Partner requirements so require. Such merchant-level restrictions may be applied without prior notice and without updating these Restrictions.","parentId":null}]},{"id":66,"__component":"ui.list","type":"decimal","title":"Updates and Contact","isolated":false,"item":[{"id":479,"content":"The Administrator may update these Restrictions from time to time by publication of a revised version on the Website, with the “Last updated” date updated accordingly. Where the change is material, the Administrator will notify Customers in accordance with clause 3.6 of the Terms. Continued use of the System after an update takes effect constitutes acceptance of the updated Restrictions.","parentId":null},{"id":480,"content":" For questions about these Restrictions, please contact Customer Support at customersupport@pst.net. For AML or compliance questions, please contact the Compliance Officer at compliance@pst.net.","parentId":null}]}]}},{"id":17,"attributes":{"title":"Merchant Terms of Service","createdAt":"2026-09-30T07:26:34.681Z","updatedAt":"2026-10-23T13:03:37.892Z","publishedAt":"2026-09-30T08:43:33.045Z","slug":"merchant","position":16,"tosType":null,"content":[{"id":67,"__component":"ui.list","type":null,"title":null,"isolated":false,"item":[{"id":485,"content":"_including the Merchant AML & KYC Policy (Part B) and the Merchant Privacy Notice (Part C)_","parentId":null},{"id":486,"content":"**IMPORTANT — PLEASE READ CAREFULLY.** This document governs the PSTNET Merchant Service, which lets eligible business Customers accept crypto-asset payments from their own customers. Before the Merchant Service can be enabled you must complete Merchant Verification, which includes a live face verification of your authorised representative (Part B). Funds received through the Merchant Service accumulate in your Merchant Balance — in US dollars, in USDT/USDC or in the coins actually received, depending on the conversion setting (Settlement Mode) you choose when you create your merchant, which cannot be changed afterwards — and can be transferred to your PSTNET Wallet and used anywhere on the platform, including to issue and fund PSTNET Cards, or withdrawn (Section 11). Crypto-asset transactions are irreversible and cannot be charged back (Section 10). PSTNET has no relationship with, and no responsibility to, your customers (Payers): they are your customers, and you alone are responsible to them for your goods, services, deliveries, refunds and disputes (Section 3.7). PSTNET is a technology intermediary: it connects, through their APIs, to third-party platforms that perform the conversion of crypto-assets; it does not set or control the conversion rates and accepts no responsibility for them; it is not a bank, custodian or exchange, and balances in your Wallet are an unsecured contractual entitlement (Sections 3 and 8). PSTNET holds no MiCA or equivalent authorisation and the Merchant Service is not available where one would be required (Section 4). Merchants and platforms that use PSTNET’s solutions are independent customers, not partners, affiliates or agents of PSTNET, and PSTNET does not endorse or vouch for them (Section 3.9). PSTNET may carry out compliance checks on any Merchant at any time, at random and without giving reasons, and may suspend, restrict or close the Merchant Service at its discretion without giving reasons (Sections 4.5 and 16.2). These Merchant Terms are governed by the laws of the Turks and Caicos Islands under the exclusive jurisdiction of its courts (Section 16).\n\n\n\n**Structure.** Part A sets out the Merchant Terms of Service. Part B is the Merchant AML & KYC Policy, which governs verification, screening and monitoring for the Merchant Service. Part C is the Merchant Privacy Notice, which explains how personal data of Merchants, their representatives and Payers is processed. Parts A, B and C together form a single agreement (the “Merchant Terms”).","parentId":null}]},{"id":68,"__component":"ui.list","type":null,"title":"PART A — MERCHANT TERMS OF SERVICE","isolated":false,"item":[{"id":487,"content":"**1. About these Terms**","parentId":null},{"id":488,"content":"**1.1**  These Merchant Terms are issued by ADV Summit Advisors Limited, a company incorporated in the Turks and Caicos Islands with its registered office at Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands (the “Administrator”, “PSTNET”, “we”, “us” or “our”), and govern the Merchant Service made available through the PSTNET platform (the “System”) to each Customer that enables it (the “Merchant”, “you” or “your”).","parentId":null},{"id":489,"content":"**1.2  Relationship with the General Terms.** These Merchant Terms supplement the PSTNET Terms of Service published at https://pst.net/legal/terms (the “General Terms”) and the Internal Policies, which continue to apply to the Merchant and its Account. In relation to the Merchant Service, these Merchant Terms prevail over the General Terms and the Internal Policies to the extent of any inconsistency; Part B prevails over the platform AML Policy and Part C prevails over the platform Privacy Policy in relation to the Merchant Service. In all other respects the General Terms prevail.","parentId":null},{"id":490,"content":"**1.3  Acceptance.** By clicking “Create merchant” (or any equivalent button), enabling the Merchant Service in the Account dashboard, generating an API key for the Merchant Service, or otherwise using the Merchant Service, the Merchant accepts these Merchant Terms. A person accepting on behalf of an entity represents that they are authorised to bind it. If you do not agree, do not enable or use the Merchant Service.","parentId":null},{"id":491,"content":"**1.4  Business use only.** The Merchant Service is provided only to persons acting in the course of a trade, business or profession and not to consumers. Payers may be consumers; the Merchant’s obligations to them are the Merchant’s sole responsibility.","parentId":null},{"id":492,"content":"**2. Definitions and Interpretation**","parentId":null},{"id":493,"content":"**2.1**  Capitalised terms not defined here have the meanings given in the General Terms, including “Account”, “Applicable Law”, “Authorised Representative”, “Customer”, “Customer Support”, “Digital Currency”, “Financial Partner”, “Funds”, “Internal Policies”, “PSTNET Card”, “Restricted Jurisdiction”, “Sanctions”, “Settlement Reserve”, “Suspension”, “Verification”, “Wallet” and “Website”. In addition:\n\n\n-\t**“API”** means the interfaces, SDKs, plugins, webhooks, sandbox and documentation made available for the Merchant Service.\n-\t**“Checkout”** means any Payer-facing interface through which an Invoice is presented, including the hosted payment page, embeddable widget, payment links and the Telegram bot integration.\n-\t**“Confirmed”** means, in relation to a Payment, that the Conversion Provider has reported the Payment to the Administrator as received and confirmed on the relevant Network in accordance with the Conversion Provider’s own confirmation and finality requirements.\n-\t**“Conversion Provider”** means one or more third-party platforms or service providers whose services the Administrator accesses through their APIs to receive Payment Assets and/or convert them into the Settlement Currency and to provide related pricing, liquidity and settlement services. The Administrator may change Conversion Providers at any time and need not disclose their identity.\n-\t**“Dashboard”** means the Merchant-facing area of the Account dashboard for the Merchant Service, including its settings, reports, fee displays, limits and tools.\n-\t**“Exchange Rate”** means the rate for converting a Payment Asset into the Settlement Currency (or vice versa) determined under Section 8.2.\n-\t**“Infrastructure Provider”** means any third party on which the Administrator relies to deliver the Merchant Service, including Conversion Providers, node operators, wallet-technology and key-management providers, blockchain-analytics providers, the identity-verification provider and Financial Partners.\n-\t**“Invoice”** means a payment request created through the Dashboard, the API or a Checkout, specifying the amount requested by the Merchant and its currency, the Payment Asset and Network, the Payment Address and any Memo/Tag. The requested amount is informational only: the Administrator does not verify that the amount received corresponds to it (Section 8.3).\n-\t**“Memo/Tag”** means a destination tag, memo or similar identifier required on certain Networks (including XRP and TON) for a transfer to be attributed to an Invoice.\n-\t**“Merchant Balance”** means the balance or balances maintained for the Merchant in the Dashboard, denominated in the Settlement Currency, in which Merchant Proceeds accumulate pending transfer to the Wallet or withdrawal under Section 11.\n-\t**“Merchant Fee”** means the fee payable on each Successful Payment, expressed as a percentage of the Received Amount, at the rate displayed in the Dashboard and the API.\n-\t**“Merchant Proceeds”** means, for a Successful Payment, the Received Amount, converted where the Settlement Mode so requires into the Settlement Currency at the Exchange Rate, less the Merchant Fee and any Network Costs or other amounts deductible under these Merchant Terms.\n-\t**“Merchant Service”** means the crypto-asset payment-acceptance service described in Section 3, including the Dashboard, Checkout and API.\n-\t**“Merchant Verification”** means the verification and due-diligence process described in Part B, including live face verification.\n-\t**“Miner Fee”** means the transaction, gas or network fee payable to Network participants to broadcast and confirm a transfer.\n-\t**“Network”** means a blockchain or distributed ledger on which a Supported Cryptocurrency is transferred (for example Bitcoin, Ethereum (ERC-20), TRON (TRC-20), BNB Smart Chain (BEP-20), TON, Solana, XRP Ledger).\n-\t**“Network Costs”** means the Administrator’s costs of aggregating and moving crypto-assets received at Payment Addresses, based on Miner Fees.\n-\t**“Payer”** means any person who makes or attempts a Payment to the Merchant in respect of an Invoice.\n-\t**“Payer Notice”** means the notice the Administrator displays, or requires to be displayed, to Payers at the Checkout.\n-\t**“Payment”** means a transfer of a Payment Asset to a Payment Address in respect of an Invoice; “Payment Address” means the address (with any Memo/Tag) generated for an Invoice; “Payment Asset” means the Supported Cryptocurrency, on the relevant Network, selected for a Payment.\n-\t**“Payment Exception”** means any Payment that is not a Successful Payment (Section 9).\n-\t**“Received Amount”** means the amount of the Payment Asset actually received at the Payment Address in respect of a Payment, as reported by the Conversion Provider, whether or not it corresponds to the amount requested in the Invoice.\n-\t**“PSTNET Marks”** means the PSTNET name, logos and payment marks made available to Merchants under the brand guidelines published on the Website.\n-\t**“Refund”** means a transfer of crypto-assets to a Payer under Section 10; “Refund Reserve” has the meaning in Section 10.5.\n-\t**“Settlement Currency”** means the currency or Supported Cryptocurrency in which Merchant Proceeds are credited to the Merchant Balance under the Settlement Mode: United States dollars under Convert to USD; USDT or USDC under Keep Stablecoin; and the Payment Asset itself under No Conversion.\n-\t**“Settlement Mode”** means the conversion setting selected by the Merchant when a merchant profile is created in the Dashboard, being Convert to USD, Keep Stablecoin or No Conversion as described in Section 11.1 (or any other mode the Administrator offers from time to time), and which cannot be changed once the merchant profile has been created.\n-\t**“Successful Payment”** has the meaning in Section 8.4.\n-\t**“Supported Cryptocurrency”** means each crypto-asset, on each Network, listed in the Dashboard as available for the Merchant Service.\n-\t**“Travel Rule Information”** means originator and beneficiary information required to accompany crypto-asset transfers under Applicable Law (including FATF Recommendation 16 and Regulation (EU) 2023/1113 where applicable).","parentId":null},{"id":494,"content":"**2.2**  Headings are for convenience; “including” is illustrative; the singular includes the plural; references to Sections are to Part A unless stated, and to Parts B and C by their lettered numbering. Operational parameters displayed in the Dashboard (fees, limits, Supported Cryptocurrencies, minimum amounts, thresholds) form part of these Merchant Terms, and the value displayed at the relevant time prevails. “Merchant” in these Merchant Terms means the Customer using the Merchant Service; “merchant” (lower case) in the Restrictions means a third party paid with a PSTNET Card, and nothing here affects the Restrictions as they apply to PSTNET Cards.","parentId":null},{"id":495,"content":"**3. The Merchant Service**","parentId":null},{"id":496,"content":"**3.1  What it does**. The Merchant Service enables the Merchant to create Invoices, present a Checkout to Payers, receive Payments in Supported Cryptocurrencies at Payment Addresses generated by the System (or by a Conversion Provider on the Administrator’s behalf), have Payment Assets converted into the Settlement Currency through a Conversion Provider where the Settlement Mode selected by the Merchant so requires (Section 11.1), and have the resulting Merchant Proceeds credited to its Merchant Balance, from which they may be transferred to the Merchant’s Wallet or withdrawn. Once transferred to the Wallet, Merchant Proceeds are Funds and may be used for any purpose available in the System, including issuing and funding PSTNET Cards, paying Fees and subscriptions and making internal transfers, as set out in Section 11.","parentId":null},{"id":497,"content":"**3.2  Role of the Administrator.** The Administrator provides the Merchant Service as a technology intermediary between the Merchant, the Payer and the Conversion Provider. The conversion of Payment Assets is carried out by a Conversion Provider and not by the Administrator, which does not itself exchange crypto-assets for funds or other crypto-assets, does not use its own capital to buy crypto-assets from Payers or Merchants, and is not a counterparty to any conversion. The Administrator is not a bank, deposit-taker, electronic-money or payment institution, trustee, custodian, escrow agent, crypto-asset exchange, trading platform, broker or adviser, is not authorised as any of these in any jurisdiction, and does not provide custody of crypto-assets for Merchants or Payers.","parentId":null},{"id":498,"content":"**3.3  Limited agency for receipt.** Solely for the purpose of receiving Payments in respect of Invoices, the Merchant appoints the Administrator as its limited agent. Receipt of a Successful Payment at the Payment Address (whether controlled by the Administrator or by a Conversion Provider on its behalf) discharges the Payer’s obligation to the Merchant to the extent of the amount received, and the Merchant shall not seek to recover it from the Payer again. This agency extends to nothing else; neither Party may otherwise bind the other.","parentId":null},{"id":499,"content":"**3.4  No proprietary interest; nature of Merchant Proceeds.** The Merchant acquires no right, title or interest in any crypto-asset received at a Payment Address, whether held by the Administrator or a Conversion Provider, or in the proceeds of its conversion before Merchant Proceeds are credited. The Merchant’s sole entitlement in respect of a Successful Payment is the credit of Merchant Proceeds to its Merchant Balance. Amounts in the Merchant Balance, whether denominated in United States dollars or in a Supported Cryptocurrency and whether or not the Administrator or a Conversion Provider holds corresponding crypto-assets, and Merchant Proceeds once transferred to the Wallet as Funds, are subject to Section 8.3 of the General Terms: a contractual entitlement against the Administrator that is not a deposit, is not held in trust, escrow or as client money, is not safeguarded, segregated or insured under any deposit-guarantee, investor-compensation or e-money scheme, and confers no proprietary interest in any asset of the Administrator. On the Administrator’s insolvency the Merchant would be an unsecured creditor.","parentId":null},{"id":500,"content":"**3.5  Dependence on the Conversion Provider.** The receipt, conversion and settlement of Payment Assets depend on the Conversion Provider and on public Networks that the Administrator does not control. The Administrator’s obligation to credit Merchant Proceeds is conditional on the Payment being received and, where the Settlement Mode requires conversion, on the converted amount being settled to the Administrator by the Conversion Provider. If a Conversion Provider fails to settle, the Administrator’s obligation in respect of that Payment is limited to using reasonable efforts to recover the amount and crediting the Merchant with the amount actually recovered, net of reasonable recovery costs.","parentId":null},{"id":501,"content":"**3.6  Declining Payments; availability.** The Administrator may decline, delay, hold, return or report any Payment, and decline to credit any amount, in accordance with Sections 8 and 9, Part B and Applicable Law. The Administrator may modify, suspend or discontinue the Merchant Service or any feature, Supported Cryptocurrency, Network, Settlement Mode, Settlement Currency or API version at any time, giving reasonable advance notice through the Dashboard or by email where practicable, except where immediate action is required by Applicable Law, Sanctions, an Infrastructure Provider, security or a Network event. No service-level or availability commitment applies unless agreed in writing.","parentId":null},{"id":502,"content":"**3.7  No responsibility to Payers.**  Payers are customers of the Merchant, not of the Administrator. The Administrator has no contractual relationship with, and assumes no responsibility or liability to, any Payer in respect of the Merchant or its goods or services, including their description, price, quality, fitness, lawfulness, delivery or non-delivery, warranties, after-sales support, cancellations, refunds, consumer rights or any dispute between a Payer and the Merchant. The Administrator’s only functions in relation to a Payer are the technical receipt of Payments under Section 3.3, the handling of Payment Exceptions and of Refunds under Sections 9 and 10, and the verification, screening and data processing required under Parts B and C. The Merchant is solely responsible to Payers for every obligation of a seller or supplier under Applicable Law, shall not state or imply that the Administrator is the seller, a party to the sale, a guarantor, an escrow agent or a dispute-resolution body, and shall ensure that its own terms and the Checkout make clear that the Administrator provides payment technology only. Any claim by a Payer arising from the Merchant’s goods, services or business is a matter for the Merchant, which shall indemnify the Administrator under Section 15.1. Nothing in this Section excludes any obligation of the Administrator to a Payer that cannot be excluded under Applicable Law.","parentId":null},{"id":503,"content":"**3.8  Technology intermediary; third-party conversion platforms; no responsibility for rates.** The Administrator acts solely as a technology intermediary between the Merchant and one or more third-party platforms whose crypto-asset conversion services it accesses through their APIs, providing the connectivity, Invoice, Checkout and ledger functions through which those services are made available to the Merchant. The Administrator does not itself convert crypto-assets and does not determine, set, quote, negotiate or influence any Exchange Rate, spread, execution price or conversion fee applied by those platforms; it passes through to the Merchant the rate made available to it, together with any margin of its own displayed in the Dashboard. The Administrator accepts no responsibility or liability for any Exchange Rate, including its accuracy, competitiveness, availability or timing, any spread or slippage, any difference between it and rates available on other venues or at other times, or any loss resulting from movements in rates between the creation of an Invoice, receipt, conversion, credit, Refund and withdrawal. No rate is quoted, locked or guaranteed when an Invoice is created: the Merchant accepts the Exchange Rate actually applied by the platform at the time of each conversion, Refund or withdrawal as final and binding, and acknowledges that the Administrator’s only obligation in respect of rates is to pass through the rate so applied in accordance with Section 8.","parentId":null},{"id":504,"content":"**3.9  Merchants and platforms using PSTNET solutions are not partners of the Administrator.** Any Merchant, website, application, marketplace, bot, platform or other business that integrates or uses the Merchant Service or any other PSTNET solution does so as an independent customer of the Administrator and not as a partner, affiliate, agent, franchisee, representative or (other than under Section 12) licensee of the Administrator. The Administrator does not endorse, sponsor, certify, vet, recommend, guarantee or vouch for any Merchant or its goods, services, content, conduct or solvency, and neither the availability of the Merchant Service to a Merchant, its listing in any directory, its use of the PSTNET Marks, the display of the Checkout on its channels nor any reference to it in the Administrator’s materials implies otherwise. The Merchant shall not describe itself as a partner, affiliate or associate of the Administrator, or as “partnered with”, “backed by”, “verified by” or “approved by” PSTNET, and shall not make any statement to Payers, platforms, regulators or the public implying such a relationship. The Administrator’s relationship with each Merchant is non-exclusive, and the Administrator may provide its services to any other person, including the Merchant’s competitors. Section 23.6 of the General Terms applies.","parentId":null},{"id":505,"content":"**4. Eligibility, Merchant Verification and Regulatory Position**","parentId":null},{"id":506,"content":"**4.1  Eligibility.** The Merchant Service may be enabled and used only by a Customer that at all times: (a) holds an Account that has completed Verification and is in good standing; (b) is a legal entity, or a natural person acting as a sole trader in the course of a business, using the Merchant Service solely for business purposes; (c) has completed Merchant Verification and been approved under Part B; (d) sells only goods or services that are lawful in its own and its Payers’ jurisdictions and that are not Prohibited Businesses; (e) maintains a functioning website, application or other sales channel accurately describing the Merchant, its contact details and its goods or services; and (f) is not connected with a Restricted Jurisdiction; is not resident or established in, or operating from, a Limited-Service Jurisdiction as defined in clause 3.4 of the Restrictions (the European Economic Area and the United Kingdom), in which the Merchant Service is not available because the Administrator is not authorised under Regulation (EU) 2023/1114 (“MiCA”) or by the UK Financial Conduct Authority, or any other jurisdiction in which providing the Merchant Service would require a licence, registration or authorisation that the Administrator does not hold; and is not, and is not owned, controlled by or acting for, a person subject to Sanctions. The Administrator may publish in the Dashboard or on the Website a schedule of jurisdictions in which the Merchant Service is unavailable or from which Payments are not accepted.","parentId":null},{"id":507,"content":"**4.2  Mandatory Merchant Verification.** The Merchant Service will not be enabled until Merchant Verification under Part B has been completed and approved. Merchant Verification includes verification of the business, of its directors and beneficial owners, and of the identity of the Merchant’s Authorised Representative (and, where required, of each beneficial owner) by means of a government-issued identity document and a live face verification (liveness check) conducted through the Administrator’s identity-verification provider. The Administrator may require Merchant Verification to be repeated or updated at any time, including periodically, on a change of ownership, control, business or sales channel, on reactivation after inactivity, or where risk indicators arise, and may suspend the Merchant Service until it is completed. Approval may be granted subject to limits, conditions, a Settlement Reserve or a Refund Reserve, and the Merchant may be assigned to a risk tier that determines the limits displayed in the Dashboard.","parentId":null},{"id":508,"content":"**4.3  Regulatory position.** The Administrator is incorporated in and operates under the laws of the Turks and Caicos Islands, including the anti-money-laundering framework described in Part B. It is not authorised, licensed or registered as a crypto-asset or virtual-asset service provider, payment or electronic-money institution, or money-transmission business in the European Union, the European Economic Area, the United Kingdom, the United States or elsewhere, and nothing on the Website or in the Dashboard is a representation to the contrary. The Merchant is solely responsible for determining whether, and on what conditions, it may lawfully accept crypto-assets as payment in each jurisdiction in which it operates or sells, including licensing, disclosure, consumer-protection, tax, foreign-exchange and reporting requirements; the Administrator gives no advice on these matters.","parentId":null},{"id":509,"content":"**4.4  Information, cooperation and review.** All information provided by the Merchant must be true, accurate, complete and not misleading, and the Merchant shall notify the Administrator within ten (10) Business Days of any change, including any change of ownership or control, business activity, goods or services, website or sales channel, jurisdiction or regulatory status. The Merchant shall cooperate promptly with any request from the Administrator, an Infrastructure Provider, an auditor or a competent authority for information or documents concerning the Merchant, its owners, its Payers or any Payment, including evidence of supply. The Administrator may review the Merchant’s website, application, channels, Checkout implementation and marketing at any time and require changes. Failure to comply may result in holds, Suspension or termination.","parentId":null},{"id":510,"content":"**4.5  Compliance checks at the Administrator’s discretion.** The Administrator may at any time, whether at random, periodically or on a risk basis, with or without prior notice and without being obliged to give any reason, carry out a compliance check on the Merchant. A compliance check may include any or all of the following: a request for documents and information (including invoices and receipts issued to Payers, proof of delivery, contracts, bank and wallet statements, source-of-funds and source-of-wealth evidence, licences and registrations, and details of Payers or transactions); a repeat or update of Merchant Verification under Part B, including a further live face verification of the Authorised Representative or of any owner; a review of the Merchant’s websites, applications, channels, Checkout implementation and marketing; test purchases through the Checkout; a video interview with the Authorised Representative or owners; and an on-site visit by the Administrator or its agents on reasonable notice. The Merchant shall respond fully and accurately within the period specified (which will not be less than five (5) Business Days unless Applicable Law or an Infrastructure Provider requires otherwise). During a compliance check the Administrator may suspend or restrict the Merchant Service, hold Merchant Proceeds and decline withdrawals. Failure to cooperate, or the discovery of any inaccuracy, breach or unacceptable risk, may result in Suspension or termination under Section 16.2. The Administrator is not obliged to explain the basis, selection criteria or outcome of any compliance check, and Part B Section B7.2 applies.","parentId":null},{"id":511,"content":"**5. Merchant Representations and Undertakings**","parentId":null},{"id":512,"content":"**5.1**  The Merchant represents and warrants, on the Effective Date and on each day it uses the Merchant Service, that: (a) it is duly organised and in good standing (or, if a sole trader, lawfully carrying on business) and has authority to enter into and perform these Merchant Terms; (b) it uses the Merchant Service solely for business purposes and is not a consumer; (c) neither it nor any director, beneficial owner or Authorised Representative is connected with a Restricted Jurisdiction or subject to Sanctions; (d) its business is lawful wherever it operates or sells, it holds all required licences and permissions, and its goods and services are not Prohibited Businesses and, where Restricted Businesses, have been approved in writing; (e) the goods and services invoiced are genuine, accurately described and supplied in accordance with its published terms; (f) all information provided to the Administrator is accurate and complete; (g) it acts for its own account and does not accept Payments for others; (h) no Payment represents the proceeds of crime or funds for terrorism or Sanctions evasion; (i) it complies with all Applicable Law, including anti-money-laundering, sanctions, tax, consumer-protection, e-commerce, advertising, data-protection and intellectual-property law; and (j) it holds all rights needed to sell its goods and services and to use the content and marks it displays.","parentId":null},{"id":513,"content":"**5.2**  The Merchant undertakes to: (a) publish and honour refund, delivery, privacy and complaints policies that comply with Applicable Law; (b) display the Checkout disclosures required by Section 7.5; (c) keep complete records of Invoices, Payments, deliveries, Refunds and Payer communications for at least five (5) years and produce them on request; (d) not misrepresent its relationship with the Administrator or use the PSTNET Marks otherwise than under Section 12; (e) keep its systems, credentials and API keys secure and notify the Administrator immediately of any suspected compromise; (f) handle Payer complaints in accordance with Section 10.6; (g) not split Invoices or structure Payments to evade limits, thresholds, verification or reporting; (h) not operate more than one Merchant profile, or profiles in other names, to evade any limit, restriction, Suspension or termination; and (i) not engage in any Prohibited Use.","parentId":null},{"id":514,"content":"**6. Prohibited and Restricted Businesses; Prohibited Uses**","parentId":null},{"id":515,"content":"**6.1  Prohibited Businesses.** The Merchant Service may not be used to accept Payments in connection with any of the following (non-exhaustive, and updatable by the Administrator at any time):\n\n-\tillegal drugs, controlled substances, drug paraphernalia, unlicensed pharmaceuticals and substances mimicking illegal drugs; weapons, ammunition, explosives and unlicensed military or dual-use goods; toxic, hazardous or radioactive materials; endangered species; human organs;\n-\tchild sexual abuse material and any content sexualising minors; non-consensual sexual content; human trafficking; prostitution and escort services;\n-\tterrorism and its financing; laundering the proceeds of crime; evasion of Sanctions or export controls; darknet marketplaces and goods or services sold primarily through anonymity networks for illicit purposes;\n-\tunlicensed gambling, betting, lotteries, casinos, prediction markets and games of chance, and gambling directed at jurisdictions where it is unlawful;\n-\tPonzi, pyramid, matrix and high-yield investment schemes; guaranteed-return schemes; public offerings of unregistered securities, tokens or investment products;\n-\tunlicensed money services, including crypto-asset exchange, OTC, peer-to-peer trading, remittance, mixing, tumbling or other origin-obscuring services, and acceptance of Payments on behalf of third parties (payment facilitation, aggregation or sub-merchant arrangements) without written approval;\n-\tcounterfeit goods and intellectual-property infringement; unlicensed software or media; stolen or leaked data; stolen, hacked or unauthorised account credentials; malware, hacking tools, exploit kits, botnets, denial-of-service, phishing, spam, fake-review, engagement-farming, ad-fraud and click-fraud services; hosting marketed for illegal content;\n-\tresale or rental of advertising accounts, social-media accounts, verified profiles or business-manager access, and services designed to circumvent the policies or enforcement systems of any third-party platform;\n-\tfraudulent, deceptive or misleading businesses, including fake technical support, advance-fee schemes, forged documents, fake identification, diploma mills and impersonation; content or organisations promoting hatred, violence, discrimination or violent extremism; and\n-\tanything else unlawful in the Turks and Caicos Islands, in the Merchant’s jurisdiction or in any Payer’s jurisdiction, or designated as prohibited by the Administrator, an Infrastructure Provider or a competent authority.","parentId":null},{"id":516,"content":"**6.2  Restricted Businesses.** The following may be conducted only with the Administrator’s prior written approval, which may be refused or made subject to conditions, enhanced due diligence, limits, a Settlement Reserve, additional representations or fees: lawful and age-verified adult content and services; licensed gambling, gaming and fantasy-sports operators; licensed financial-services businesses, including crypto-asset service providers, brokers, lenders and wallet providers; token sales, NFT marketplaces and decentralised-finance interfaces; charities, non-profit, political and religious organisations, crowdfunding and donation platforms; pharmaceuticals, supplements, cannabidiol, tobacco, vaping and alcohol; telecommunications, VoIP and prepaid calling; travel, airline and timeshare; precious metals, jewellery, vehicles, real estate and other high-value goods; dating services; debt collection, credit repair and lending; multi-level marketing; subscription or negative-option billing; and any business with elevated complaint, refund or fraud rates or otherwise designated by the Administrator.","parentId":null},{"id":517,"content":"**6.3  Prohibited Uses.** The Merchant shall not, and shall not permit anyone to: (a) make or procure Payments to its own Invoices from itself, its affiliates, personnel, owners or agents, other than genuine purchases or expressly permitted test transactions; (b) use the Merchant Service to convert its own crypto-assets into Funds or to fund its Wallet or PSTNET Cards other than with the proceeds of genuine sales, or otherwise as an exchange, on-ramp or transfer service; (c) accept Payments for third parties or operate as a payment facilitator, aggregator or marketplace without written approval; (d) split orders or structure Payments to evade any limit, threshold, verification, screening or reporting requirement; (e) knowingly accept Payments from Sanctioned persons, from jurisdictions from which Payments are not accepted, or from addresses associated with mixers, darknet markets, ransomware, theft or fraud; (f) alter, obscure or interfere with any Payment Address, Memo/Tag, amount, Payer Notice or other element of a Checkout or Invoice; (g) misrepresent its identity, its goods or services, its prices or its relationship with the Administrator; (h) collect or store Payers’ private keys, seed phrases or wallet credentials; (i) accept Payments for goods or services materially different from those disclosed at onboarding without notifying the Administrator; (j) interfere with, reverse-engineer, scrape, overload or attempt unauthorised access to the System, the API, the Checkout or any Infrastructure Provider; or (k) use the Merchant Service in or from any jurisdiction described in Section 4.1(f), for personal purposes, or in any manner that would cause the Administrator or an Infrastructure Provider to breach Applicable Law or Sanctions.","parentId":null},{"id":518,"content":"**6.4  Determination and consequences.** Whether an activity is a Prohibited Business, a Restricted Business or a Prohibited Use is determined by the Administrator in its reasonable discretion; uncertain Merchants should ask Customer Support before enabling the Merchant Service. Breach of this Section 6 is a material breach and may result in immediate disabling of the Merchant Service, holding, return or reporting of Payments, Suspension, termination under Section 16, retention of a Settlement Reserve and recovery of the Administrator’s losses under Section 15. Section 3 of the Restrictions (Restricted Jurisdictions) applies to Merchants; Sections 4 and 5 of the Restrictions concern PSTNET Cards and do not determine which Payments may be received, which is governed by this Section 6.","parentId":null},{"id":519,"content":"**7. Integration, Checkout and Security**","parentId":null},{"id":520,"content":"**7.1  Integration**. The Merchant may integrate through the hosted payment page, embeddable widget, payment links, Telegram bot integration, API or plugins. The Merchant is solely responsible for the design, implementation, testing and operation of its own website, application, bot, systems and integration, and for compliance with the terms of any third-party platform, messaging service, content-management system or hosting provider it uses, with which the Administrator has no affiliation.","parentId":null},{"id":521,"content":"**7.2  API licence.** The Administrator grants the Merchant a limited, revocable, non-exclusive, non-transferable, non-sublicensable licence to use the API and the Checkout solely for the Merchant Service in its own business. The Merchant shall not resell, sublicense or white-label them; copy, modify, reverse-engineer or decompile them; exceed rate limits or overload the System; extract data other than through the documented API; or use them to build a competing service. The Administrator may version, deprecate or withdraw parts of the API, giving at least thirty (30) days’ notice of non-backwards-compatible changes where practicable; the Merchant is responsible for updating its integration.","parentId":null},{"id":522,"content":"**7.3  Credentials.** The Merchant is responsible for the confidentiality of all API keys, secrets, webhook signing secrets and login credentials and for all activity conducted with them, authorised or not. It shall follow the security measures recommended in the API documentation (including IP allow-listing and key rotation where available), restrict access to personnel who need it, and notify customersupport@pst.net immediately of any suspected compromise. The Administrator may revoke or rotate credentials where it suspects compromise or misuse.","parentId":null},{"id":523,"content":"**7.4  Webhooks and reconciliation.** Webhooks may be delayed, duplicated or lost. The Merchant shall verify every webhook signature, treat notifications as idempotent, not release goods or services on the basis of an unverified notification, and confirm each Invoice’s status through the API or Dashboard before treating it as paid. The status in the Dashboard and API is authoritative.","parentId":null},{"id":524,"content":"**7.5  Checkout requirements and Payer disclosures.** The Merchant shall present the Checkout as generated by the System, without altering the Payment Address, Memo/Tag, requested amount, Payment Asset, Network or Payer Notice; display, at or before the Checkout, its legal or trading name, a description of the goods or services, the price, its refund policy and its contact details; present the Checkout only on channels disclosed to and, where required, approved by the Administrator; not remove or contradict any disclosure the Administrator includes; and not suggest that the Administrator is the seller. The Merchant shall ensure Payers are clearly informed that the amount requested must be sent in the Payment Asset and on the Network shown, to the Payment Address shown with any Memo/Tag; that the Administrator does not verify the amount sent and that whatever amount is actually received will be credited to the Merchant, so that any shortfall or excess is a matter between the Payer and the Merchant; that transfers of any other asset, on any other Network, or without the required Memo/Tag may be lost; that crypto-asset transfers are irreversible; that any return of a Payment Exception is made only net of fees and at the Exchange Rate applied at the time of return; and that the Administrator provides payment technology only, is not the seller, and has no responsibility for the goods or services, their delivery, refunds or any dispute, all of which are the Merchant’s responsibility (Section 3.7).","parentId":null},{"id":525,"content":"**7.6  Sandbox and security.** Any sandbox or test mode may be used only with test data and test assets; real crypto-assets sent to sandbox addresses are lost. The Administrator maintains technical and organisational security measures but does not guarantee that the Merchant Service will be secure or free from unauthorised access; the Merchant is responsible for the security of its own systems. Each Party shall notify the other within seventy-two (72) hours of becoming aware of a security incident reasonably likely to affect the other’s data, Payers or use of the Merchant Service.","parentId":null},{"id":526,"content":"**8. Invoices, Exchange Rates and Payment Completion**","parentId":null},{"id":527,"content":"**8.1  Invoices.** To accept a Payment the Merchant (or a Payer using a Checkout) creates an Invoice stating the amount requested and its currency and, where applicable, an order reference. The System generates the Payment Address and any Memo/Tag and displays the Payment Asset and Network selected. The requested amount is shown to the Payer to indicate what the Merchant expects, but it is informational only: the Administrator does not verify that the amount sent corresponds to it, does not reject, hold or adjust a Payment because the amount differs, and does not decide whether an order has been paid. The Merchant is solely responsible for the information it supplies; the Administrator does not verify goods, services, prices or delivery. An Invoice is a payment request, not a tax invoice, and remains open until the Merchant cancels it in the Dashboard or the Payment Address ceases to be monitored, as displayed in the Dashboard.","parentId":null},{"id":528,"content":"**8.2  Exchange Rate.** Where the Settlement Mode requires conversion into the Settlement Currency, no rate is quoted, locked or guaranteed when an Invoice is created. Conversion is initiated automatically once the Payment is Confirmed, and the Exchange Rate is the rate applied by the Conversion Provider at the time the Received Amount is actually converted (which may include the Conversion Provider’s spread), together with any margin displayed in the Dashboard; it is shown in the Dashboard and the API once the conversion has been executed. Any indicative rate shown before or during a Payment is for information only. No conversion takes place under No Conversion, or under Keep Stablecoin where the Payment Asset is already USDT or USDC. The Administrator does not set, make a market in, guarantee or accept any responsibility for any Exchange Rate (Section 3.8).","parentId":null},{"id":529,"content":"**8.3 No rate lock, payment window or amount check.** The Administrator does not operate a rate lock, a payment window or an amount tolerance. A Payment may be made at any time while the Invoice is open and in any amount, and the Received Amount — whether equal to, less than or greater than the amount requested — is treated in accordance with Section 8.4 and credited in the amount actually received. The Merchant alone decides whether the Received Amount satisfies the Payer’s order, whether to supply the goods or services, and whether to seek any balance from, or return any excess to, the Payer. The Administrator takes no part in that decision and has no liability in respect of it.","parentId":null},{"id":530,"content":"**8.4  Successful Payment.** A Payment is a “Successful Payment” when: (a) a Payment Asset has been received at the correct Payment Address on the correct Network, with any required Memo/Tag, in any amount at or above the minimum displayed in the Dashboard; (b) the Payment is Confirmed; (c) it has passed screening under Part B and is not a Flagged Payment; and (d) it has been credited to the Merchant’s ledger with the status “completed”. Whether, when and in what amount a Payment is received and Confirmed is determined by the Conversion Provider’s systems and relayed by the Administrator through the Dashboard and the API; the Administrator does not independently verify it and the Conversion Provider’s confirmation requirements may vary by Network, amount and conditions without notice. The Merchant shall rely only on the status and the Received Amount shown in the Dashboard or returned by the API, and not on the amount requested in the Invoice, Network explorers, wallet notifications or Payer statements.","parentId":null},{"id":531,"content":"**8.5 Supply before completion; Network events; records.** A Merchant that supplies goods or services before a Payment becomes a Successful Payment does so at its own risk, and the Administrator has no obligation to credit a Payment that never completes. Transfers may be delayed, reorganised, replaced, double-spent, frozen by a token issuer or otherwise invalidated after appearing confirmed; where a credited Payment is subsequently invalidated, reversed, frozen or clawed back, the Administrator may reverse the credit and any negative balance is payable under Section 11.6. The Administrator’s records are conclusive absent manifest error; the Merchant shall notify any suspected error within thirty (30) days of the ledger entry.","parentId":null},{"id":532,"content":"**8.6  Rate risk.** The Merchant bears all risk of movements in the value of the Payment Asset between the creation of an Invoice and conversion, in the Exchange Rate applied at conversion, in the value of the Settlement Currency after credit (including crypto-assets held in the Merchant Balance under Keep Stablecoin or No Conversion), and on any transfer, Refund or withdrawal. The Administrator assumes no exchange-rate risk and passes through the rate applied by the Conversion Provider (Section 3.8).","parentId":null},{"id":533,"content":"**8.7  Supported Cryptocurrencies.** The assets and Networks available are those listed in the Dashboard, which as at the Effective Date may include Bitcoin, Ether, USDT and USDC on one or more Networks, BNB, XRP, TRX, Litecoin, Bitcoin Cash, Dogecoin, Dash, Solana, Cardano and Polygon. The Merchant may enable or disable assets for its Checkout where that function is available. The Administrator may add, suspend or remove any asset or Network at any time, with immediate effect where required by Applicable Law, Sanctions, an Infrastructure Provider, a token issuer, a Network event, a security concern, a loss of liquidity or a Conversion Provider ceasing to support the asset; open Invoices may be cancelled and later Payments are Unsupported Payments. Stablecoins and issued tokens depend on their issuers and may de-peg, be frozen, blacklisted or seized; the Administrator is not affiliated with any issuer and is not obliged to credit a Payment in an impaired token or one it cannot convert. The Merchant has no entitlement to assets arising from forks, airdrops or migrations. Networks that use shared addresses (including XRP and TON) require a Memo/Tag; a Payment without a correct Memo/Tag is an Unidentified Payment.","parentId":null},{"id":534,"content":"**9. Payment Exceptions**","parentId":null},{"id":535,"content":"**9.1  General.** Any Payment that is not a Successful Payment is a Payment Exception and is handled under this Section. Returns may be effected by the Administrator or by a Conversion Provider on its behalf, net of the applicable Miner Fee, Network Costs and any exception-handling or recovery fee displayed in the Dashboard, and at the Exchange Rate applied at the time of return. The Administrator has no liability for loss arising from a Payment Exception except to the extent caused by its fraud or wilful misconduct. The Administrator may contact Payers directly to resolve Payment Exceptions, and the Merchant shall assist.","parentId":null},{"id":536,"content":"**9.2  Amount differences are not Payment Exceptions.** Because the Administrator does not verify amounts, a Received Amount that is less than or greater than the amount requested is not a Payment Exception: it is credited to the Merchant as a Successful Payment in the amount actually received, and any shortfall or excess is a matter between the Merchant and the Payer, to be resolved by the Merchant under its own terms and, where appropriate, by a Refund under Section 10. The same applies to a Payment received after the Merchant regards the order as cancelled, provided the Invoice remains open and the Payment is attributable to it.","parentId":null},{"id":537,"content":"**9.3  Unidentified Payments.** A Payment that cannot be attributed to an Invoice — including one sent to a Payment Address after the Invoice has been cancelled or the Payment Address has ceased to be monitored, one on a Memo/Tag Network without a correct Memo/Tag, or one sent to an address not generated for the Merchant — is an “Unidentified Payment”. On request accompanied by the transaction hash, sending address, amount and other information reasonably required, the Administrator will use reasonable efforts for ninety (90) days from receipt to identify and attribute it, subject to the recovery fee. An Unidentified Payment not attributed within one hundred and eighty (180) days is treated under the unclaimed-funds provisions of the General Terms as if the Payer were the person entitled.","parentId":null},{"id":538,"content":"**9.4 Unsupported Payments.** A transfer to a Payment Address of any asset other than the Payment Asset, of the Payment Asset on the wrong Network (for example USDT on Ethereum to an address generated for USDT on TRON), of an asset that is not a Supported Cryptocurrency, by an internal or contract call not recognised by the Conversion Provider’s systems, or below the minimum amount displayed, is an “Unsupported Payment” and may be permanently irretrievable. The Administrator has no obligation to detect, recover, credit or return it, may attempt recovery in its discretion for the recovery fee plus actual costs, and has no liability for it.","parentId":null},{"id":539,"content":"**9.5  Flagged Payments.** A Payment that screening under Part B associates with a Sanctioned person, a Restricted Jurisdiction or a jurisdiction from which Payments are not accepted, a mixing or anonymising service, a darknet market, ransomware, theft, fraud or other illicit activity, or that otherwise presents unacceptable risk, is a “Flagged Payment”. It is not credited. The Administrator may hold, freeze, return, report or otherwise deal with it as Part B and Applicable Law require, is not obliged to give reasons or disclose any report, and has no liability to the Merchant or any Payer in respect of it.","parentId":null},{"id":542,"content":"**10. Refunds and Payer Disputes**","parentId":null},{"id":543,"content":"**10.1  No chargebacks.** Crypto-asset transfers are irreversible and no scheme or network exists through which a Payer can reverse a Payment or the Administrator can be compelled to return one. Section 10 of the General Terms (Chargebacks and Network Costs) does not apply to Payments. Any dispute between a Payer and the Merchant about goods, services, delivery, quality, price or entitlement to a refund is solely between them; the Administrator is not a party, and Section 3.7 applies.","parentId":null},{"id":544,"content":"**10.2  Refund policy.** The Merchant shall publish and honour a refund policy that complies with Applicable Law wherever it sells, is shown to Payers before payment, and states whether refunds are made in the Payment Asset or another asset, whether they are calculated by reference to the pricing currency or the amount received, and whether Miner Fees are deducted. The Administrator is not responsible for the content or lawfulness of that policy.","parentId":null},{"id":545,"content":"**10.3  Refunds instructed by the Merchant.** Where the Refund tool is available, the Merchant may instruct a full or partial Refund of a Successful Payment through the Dashboard or API. Refunds are funded from the Merchant Balance or, where it is insufficient, from the Merchant’s Wallet (in each case after any Settlement Reserve and Refund Reserve); if both are insufficient the Merchant must fund the Wallet first. Unless otherwise agreed, Refunds are made in the Payment Asset on the original Network or, where no longer supported, in a Supported Cryptocurrency determined by the Administrator; amounts expressed in the pricing currency are converted at the Exchange Rate when the Refund is processed. The Payer must supply a valid return address (and Memo/Tag) on the correct Network, and the Administrator has no liability for a Refund sent to an address supplied by the Payer or the Merchant. The Miner Fee is deducted from the Refund unless the Merchant elects in the Dashboard to bear it. The Merchant Fee on the original Payment is not refunded.","parentId":null},{"id":546,"content":"**10.4  Refunds effected by the Administrator.** The Administrator may, without instruction and after notice to the Merchant where practicable, make a Refund from the Merchant Balance or the Merchant’s Wallet where required by Applicable Law, a court, a competent authority or Sanctions; where the Payment is a Payment Exception; where it reasonably believes the Payment was procured by fraud, mistake or unauthorised use of a Payer’s wallet; where the Merchant has failed to deal with a complaint under Section 10.6; or where it reasonably considers the Refund necessary to protect the Administrator, an Infrastructure Provider or the integrity of the System. Any negative balance is payable under Section 11.6.","parentId":null},{"id":547,"content":"**10.5  Refund Reserve.** The Merchant may elect, and the Administrator may require, that part of the Merchant’s Funds be designated a “Refund Reserve” to meet Refunds. It remains Funds subject to Section 3.4, is not held in trust or segregated, and is a contractual instruction to apply those Funds to Refunds up to the designated amount; subsequent Merchant Proceeds first replenish it.","parentId":null},{"id":548,"content":"**10.6  Payer complaints.** The Administrator will forward Payer complaints to the Merchant, which shall acknowledge them within five (5) Business Days and use reasonable efforts to resolve them within fifteen (15) Business Days. The Administrator may monitor complaint, Refund and Payment Exception rates, set thresholds in the Dashboard, and hold Merchant Proceeds, impose or increase a Settlement Reserve, suspend the Merchant Service or terminate where thresholds are exceeded or complaints are not handled. Complaints by the Merchant about the Merchant Service may be sent to customersupport@pst.net (or compliance@pst.net for compliance matters); the Administrator will acknowledge within five (5) Business Days and respond substantively within thirty (30) days.","parentId":null},{"id":549,"content":"**11. Merchant Proceeds, Use of Funds, Withdrawals and Fees**","parentId":null},{"id":648,"content":"**11.1  Settlement Mode.** When creating a merchant profile in the Dashboard (“Create merchant”), the Merchant selects one of the following Settlement Modes, which determines how each Successful Payment is treated and the Settlement Currency in which Merchant Proceeds accumulate in the Merchant Balance:\n\n-\t**Convert to USD** — every Received Amount is converted automatically into United States dollars through the Conversion Provider at the Exchange Rate applied when the Payment is Confirmed (Section 8.2), and Merchant Proceeds accumulate in a United States dollar Merchant Balance that the Merchant may transfer to its Wallet under Section 11.3;\n-\t**Keep Stablecoin** — Received Amounts in Supported Cryptocurrencies other than USDT and USDC are converted automatically into USDT or USDC (as offered in the Dashboard) at the Exchange Rate applied when the Payment is Confirmed; Received Amounts already in USDT or USDC are credited as received, without conversion; and Merchant Proceeds accumulate in USDT and USDC Merchant Balances on the Networks available in the Dashboard;\n-\t**No Conversion** — no conversion takes place; each Received Amount is credited as received, in the Payment Asset and on the Network on which it was received, and Merchant Proceeds accumulate in a separate Merchant Balance for each Supported Cryptocurrency.\n\n\n\nThe Settlement Mode is fixed when the merchant profile is created and cannot be changed afterwards; a Merchant that wishes to settle differently may, where the Dashboard so permits and subject to Section 4 and the Administrator’s approval, create a new merchant profile with a different Settlement Mode. The Administrator may add, withdraw or rename Settlement Modes, Settlement Currencies, stablecoins or Networks for new merchant profiles at any time and, where reasonably necessary for legal, Infrastructure Provider, Conversion Provider, liquidity or risk reasons, may withdraw a Settlement Mode or Supported Cryptocurrency for existing merchant profiles on reasonable notice, require settlement in a particular currency, or convert a Merchant Balance into another Settlement Currency at the prevailing Exchange Rate. The Merchant bears all risk arising from its choice of Settlement Mode and from movements in the value of its Settlement Currency; the Administrator provides no hedging, rate lock or value guarantee of any kind.","parentId":null},{"id":550,"content":"**11.2  Credit of Merchant Proceeds.** When a Payment becomes a Successful Payment and, where the Settlement Mode requires conversion, the converted amount has been settled to the Administrator by the Conversion Provider (Section 3.5), the Administrator credits the Merchant Proceeds to the Merchant Balance in the Settlement Currency: the Received Amount, converted where required at the Exchange Rate applied at conversion, less the Merchant Fee and any Network Costs or other deductible amounts displayed in the Dashboard. The Merchant Balance is shown in the Dashboard; amounts in it are subject to Section 3.4 and to any Settlement Reserve, Refund Reserve or hold under this Section.","parentId":null},{"id":551,"content":"**11.3  Transfer to the Wallet and use on the platform.** The Merchant may at any time instruct, through the Dashboard, the transfer of all or part of its available Merchant Balance to its Wallet, subject to the minimums, limits and any fees displayed in the Dashboard. A United States dollar Merchant Balance is credited to the Wallet as Funds without conversion; a Merchant Balance held in a Supported Cryptocurrency is converted into Funds at the Exchange Rate applied at the time of the transfer, in the same way as a deposit of Digital Currency under the General Terms. Once transferred, Merchant Proceeds are Funds and are available to the Merchant for every purpose for which Funds may be used under the General Terms, including: (a) issuing PSTNET Cards and funding them for advertising, subscriptions and other business spend; (b) paying Fees, subscriptions and other amounts due to the Administrator; (c) making internal transfers where that function is available; and (d) withdrawal under Section 11.4. Merchant Proceeds may be used and withdrawn notwithstanding any statement on the Website or in the FAQ that only funds originating from a Customer’s own deposits may be withdrawn, subject always to Part B and to any Settlement Reserve, Refund Reserve or hold under this Section.","parentId":null},{"id":552,"content":"**11.4  Withdrawals.** The Merchant may withdraw from its Merchant Balance, in the Settlement Currency, or from its Wallet. Withdrawals are made by the methods, in the currencies or assets, to the destination types and subject to the minimums, limits and review periods displayed in the Dashboard. Crypto-asset withdrawals are made only to addresses the Merchant confirms it controls and, where address whitelisting is available, only to whitelisted addresses; the Administrator has no liability for a withdrawal sent to an address, Network or Memo/Tag supplied by the Merchant. No withdrawal fee is charged by the Administrator unless displayed; Miner Fees and Network Costs are shown before confirmation and deducted from the amount withdrawn or from the Wallet. All withdrawals are subject to the monitoring and review procedures in Part B and may be delayed or declined under them.","parentId":null},{"id":553,"content":"**11.5  Settlement Reserve, holds and delayed settlement.** The Administrator may at any time establish or adjust a Settlement Reserve, as a fixed amount or a rolling percentage of Merchant Proceeds, having regard to the Merchant’s industry, history, Refund, complaint and Payment Exception rates, delivery timescales, regulatory risk and any investigation or dispute. Reserved amounts remain subject to Section 3.4, are unavailable while held, and are released net of amounts due once the reserve period (ordinarily not exceeding one hundred and eighty (180) days from the relevant Successful Payment or from termination, whichever is later) expires without incident; Section 18.8 of the General Terms applies after termination. The Administrator may also delay crediting, restrict use, transfer or withdrawal, or hold any amount where required by Applicable Law, Sanctions, a court, a competent authority or an Infrastructure Provider; where an investigation is pending; where it reasonably suspects a breach; or where reasonably necessary to manage fraud, credit, legal or reputational risk, informing the Merchant where permitted and lifting the hold once resolved, without liability for loss so caused.","parentId":null},{"id":554,"content":"**11.6  Negative balances and set-off.** If Refunds, reversed credits, fees, costs or other amounts due exceed the Merchant’s available Merchant Balance and Funds, the negative balance is a debt payable on demand. The Administrator may set off any amount due from the Merchant against any Merchant Balance, Funds, Settlement Reserve, Refund Reserve, PSTNET Card balance or other amount in any Account of the Merchant, and the negative-balance provisions of the General Terms apply. The Administrator may apply minimums and rounding conventions displayed in the Dashboard; amounts too small to process on a Network may be aggregated or retained as Network Costs.","parentId":null},{"id":555,"content":"**11.7  Fees.** The Merchant Fee is payable on each Successful Payment and is deducted at credit. No set-up, monthly or minimum fee applies unless displayed in the Dashboard; any exception-handling, recovery, Restricted Business, transfer, conversion or other fee is displayed there, and Section 13 of the General Terms applies to fees generally. The Payer bears the Miner Fee on a Payment; Miner Fees on Refunds and withdrawals are borne under Sections 10.3 and 11.4; Network Costs are deducted or charged as displayed and vary with Network conditions. Increases in the Merchant Fee take effect thirty (30) days after notice through the Dashboard or by email, continued use constituting acceptance; reductions and fees for new assets or features may apply on display. Fees are exclusive of applicable taxes, are calculated in the Settlement Currency or converted at the prevailing Exchange Rate, and are deducted at source.","parentId":null},{"id":557,"content":"**12. Intellectual Property and PSTNET Marks**","parentId":null},{"id":558,"content":"**12.1**  The Administrator and its licensors own all rights in the System, the Merchant Service, the API, the Checkout, the Dashboard, the PSTNET Marks and the Website; no rights are granted except as expressly stated. While the Merchant Service is enabled, the Merchant may display the PSTNET Marks made available under the brand guidelines solely to indicate that it accepts crypto-asset payments processed by the Administrator, all goodwill accruing to the Administrator, and shall not use them in a way that suggests the Administrator sells the Merchant’s goods, endorses, is partnered or affiliated with the Merchant (Section 3.9), or that damages the Administrator’s reputation. The Administrator may require modification or removal on notice, and the Merchant shall remove the PSTNET Marks from all channels within five (5) Business Days of termination or request. The Merchant grants the Administrator a non-exclusive, royalty-free licence to display the Merchant’s name, logo and marks in the Checkout, Dashboard and Payer communications and, with the Merchant’s written consent, in marketing and any merchant directory, warranting that such use will not infringe third-party rights. Feedback may be used by the Administrator without restriction.","parentId":null},{"id":559,"content":"**13. Taxes**","parentId":null},{"id":560,"content":"**13.1**  The Merchant is solely responsible for determining, collecting, reporting, withholding and remitting all taxes arising from its sales and from its receipt, holding and disposal of crypto-assets and Funds in every relevant jurisdiction, and for issuing tax invoices and receipts to Payers. The Administrator does not calculate, collect or remit tax on the Merchant’s behalf, and nothing it provides is tax, accounting or legal advice. The Administrator may be required under Applicable Law, including automatic-exchange-of-information regimes for crypto-assets such as the OECD Crypto-Asset Reporting Framework and Council Directive (EU) 2023/2226 where applicable, to collect tax-residency and taxpayer-identification information from the Merchant and its beneficial owners and to report the Merchant’s transactions to tax authorities; the Merchant shall provide the information and self-certifications requested and update them on any change.","parentId":null},{"id":561,"content":"**14. Risk Disclosures**","parentId":null},{"id":562,"content":"**14.1**  The Merchant acknowledges and accepts the following material risks of accepting crypto-asset payments and using the Merchant Service:\n\n\n-\tcrypto-assets are not legal tender, are not backed by any government, and balances in them are not protected by any deposit-guarantee or investor-compensation scheme;\n-\ttransfers are irreversible, and losses from fraudulent, mistaken or erroneous transfers may be unrecoverable;\n-\tvalues are volatile and may fall significantly between Invoice creation, receipt, credit, conversion, transfer and withdrawal; no rate is locked when an Invoice is created; Exchange Rates are applied by third-party platforms for which the Administrator has no responsibility (Section 3.8); under Keep Stablecoin and No Conversion the Merchant Balance is held in crypto-assets whose value may fall, while under Convert to USD the Merchant forgoes any later rise; and the Settlement Mode cannot be changed after the merchant profile is created (Section 11.1);\n-\tstablecoins and issued tokens may de-peg, be frozen, blacklisted or seized, and depend on issuers the Administrator does not control;\n-\tNetworks may suffer congestion, outages, forks, reorganisations, protocol changes and attacks that delay, reverse or prevent confirmation and increase Miner Fees and Network Costs;\n-\tthe receipt, conversion and settlement of Payment Assets depend on one or more Conversion Providers, whose failure, insolvency, regulatory action, outage or refusal to honour a quote may delay, reduce or prevent the crediting of Merchant Proceeds (Sections 3.5 and 8.3);\n-\tlegal, regulatory, tax and enforcement developments anywhere, including under MiCA and the Travel Rule, may affect the availability, legality, cost and value of crypto-asset payments and may require the Merchant Service to be suspended or withdrawn at short notice;\n-\tcrypto-assets carry elevated risks of fraud, cyber-attack and theft, including compromise of the Merchant’s or a Payer’s wallet, credentials or systems;\n-\tPayers may send the wrong asset, use the wrong Network, omit a Memo/Tag, send the wrong amount or pay late, and such Payments may be lost or returned only net of fees at a different rate;\n-\tMerchant Proceeds are an unsecured contractual entitlement against the Administrator, and on the Administrator’s insolvency the Merchant may lose some or all of its Funds; and\n-\tthe tax and accounting treatment of crypto-asset receipts is complex and variable, and there is no assurance that any asset or Network will continue to be supported.","parentId":null},{"id":563,"content":"**15. Indemnity, Warranties and Liability**","parentId":null},{"id":564,"content":"**15.1  Indemnity.** The Merchant shall indemnify, defend and hold harmless the Administrator, its affiliates, Infrastructure Providers and Financial Partners and their directors, officers, employees and agents against all claims, losses, liabilities, damages, fines, penalties, costs and expenses (including reasonable legal fees) arising out of or in connection with: any breach by the Merchant of these Merchant Terms, the General Terms or an Internal Policy; the Merchant’s goods, services, website, content, marketing or business, or any dispute with a Payer; any claim by a Payer, tax authority, regulator or other third party relating to the Merchant’s use of the Merchant Service; any Prohibited Business, unapproved Restricted Business or Prohibited Use; any tax for which the Merchant is responsible; infringement of third-party rights; compromise of the Merchant’s credentials, systems or Checkout; or any negligent or wrongful act or omission of the Merchant or its personnel.","parentId":null},{"id":565,"content":"**15.2  No warranties.** EXCEPT AS EXPRESSLY STATED, THE MERCHANT SERVICE, API, CHECKOUT AND DASHBOARD ARE PROVIDED “AS IS” AND “AS AVAILABLE” AND USED AT THE MERCHANT’S OWN RISK. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL WARRANTIES, CONDITIONS AND REPRESENTATIONS, EXPRESS, IMPLIED OR STATUTORY — INCLUDING MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY AND UNINTERRUPTED OR ERROR-FREE OPERATION — ARE EXCLUDED. THE ADMINISTRATOR DOES NOT WARRANT THAT ANY PAYMENT WILL BE RECEIVED, CONFIRMED OR CREDITED WITHIN ANY TIME, THAT ANY EXCHANGE RATE WILL BE AVAILABLE, THAT ANY NETWORK OR ASSET WILL OPERATE AS EXPECTED, OR THAT THE MERCHANT SERVICE WILL MEET THE MERCHANT’S REQUIREMENTS.","parentId":null},{"id":566,"content":"**15.3  Exclusions.** TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE ADMINISTRATOR IS NOT LIABLE, IN CONTRACT, TORT (INCLUDING NEGLIGENCE), BREACH OF STATUTORY DUTY OR OTHERWISE, FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE LOSS, ANY LOSS OF PROFIT, REVENUE, BUSINESS, CONTRACTS, GOODWILL, ANTICIPATED SAVINGS OR DATA, OR ANY LOSS FROM A DECLINE IN THE VALUE OF ANY CRYPTO-ASSET OR CURRENCY. Without limitation, the Administrator is not liable for loss arising from any Network event; any act or omission of a Conversion Provider, token issuer, Infrastructure Provider, wallet provider, exchange or other third party (subject only to Section 3.5); any Exchange Rate, spread, slippage or rate movement (Section 3.8); any Payment Exception; any Payer’s error, fraud or non-payment; any claim by a Payer relating to the Merchant’s goods, services or business (Section 3.7); any compliance check, suspension, restriction or closure under Sections 4.5 or 16.2; any error in the Merchant’s integration, systems, order references or instructions, including any address supplied for a Refund or withdrawal; any hold, delay, decline, return, report, Suspension or termination effected under these Merchant Terms, the General Terms, an Internal Policy, Applicable Law or Sanctions; any change in law or regulatory action; any compromise of the Merchant’s credentials or systems; any fine or penalty imposed on the Merchant by any authority; or any force-majeure event under Section 16.9.","parentId":null},{"id":567,"content":"**15.4  Cap.** TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE ADMINISTRATOR’S AGGREGATE LIABILITY TO THE MERCHANT ARISING OUT OF OR IN CONNECTION WITH THE MERCHANT SERVICE AND THESE MERCHANT TERMS IN ANY TWELVE (12) MONTH PERIOD SHALL NOT EXCEED THE GREATER OF (A) THE MERCHANT FEES PAID BY THE MERCHANT IN THE THREE (3) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM AND (B) ONE THOUSAND UNITED STATES DOLLARS (USD 1,000). This cap is separate from any cap under Section 15 of the General Terms for other System Services.","parentId":null},{"id":568,"content":"**15.5  Non-excludable liability; time limit.** Nothing in these Merchant Terms excludes or limits liability that cannot be excluded or limited under Applicable Law, including for fraud or for death or personal injury caused by negligence. To the extent permitted by Applicable Law, any claim by the Merchant must be brought within twelve (12) months of the date on which the Merchant became, or ought reasonably to have become, aware of the facts giving rise to it, failing which it is waived.","parentId":null},{"id":569,"content":"**16. Term, Termination, Governing Law and General**","parentId":null},{"id":570,"content":"**16.1  Term and termination by the Merchant.** These Merchant Terms take effect on the Effective Date and continue until terminated under this Section or until the General Terms terminate or the Account is closed, whichever is earlier. The Merchant may disable the Merchant Service at any time through the Dashboard or by notice to Customer Support, without affecting Payments already received, Refunds instructed, obligations to Payers or amounts due to the Administrator.","parentId":null},{"id":571,"content":"**16.2  Suspension, restriction and closure by the Administrator.** The Administrator may suspend, restrict or close the Merchant Service, in whole or in part, at any time in its sole discretion, with or without notice, and without being obliged to give any reason. The Administrator will ordinarily give thirty (30) days’ notice of a closure that is not for cause, but may act immediately, without notice and without giving reasons, where any of the following applies or where it otherwise considers immediate action necessary: the Merchant breaches these Merchant Terms, the General Terms or an Internal Policy; engages in a Prohibited Business, unapproved Restricted Business or Prohibited Use; the Merchant, an owner or a Payer becomes subject to Sanctions or connected with a Restricted Jurisdiction; required by Applicable Law, a court, a competent authority or an Infrastructure Provider; Refund, complaint, Payment Exception or Flagged Payment rates exceed the thresholds displayed; the Administrator reasonably suspects fraud, money laundering, terrorist financing, Sanctions evasion or other illicit activity; the Merchant becomes insolvent or ceases business; the Account is suspended or terminated; Merchant Verification is not completed or maintained; or continued provision would expose the Administrator or an Infrastructure Provider to legal, regulatory, financial or reputational risk. The Administrator is never obliged to disclose the reason for a suspension, restriction or closure, in particular where disclosure is prohibited by law, would prejudice an investigation or would compromise its risk controls, and the Merchant waives any claim arising from the exercise of this discretion. A closure under this Section does not of itself forfeit Merchant Proceeds: Funds are dealt with under Section 16.3.","parentId":null},{"id":572,"content":"**16.3  Effect of termination; inactivity.** On termination or suspension: open Invoices are cancelled and Payments subsequently received at their Payment Addresses are treated as Unidentified Payments; the Merchant shall cease presenting any Checkout and remove the Checkout, API integration and PSTNET Marks from all channels within five (5) Business Days; API credentials are revoked; the Administrator may retain a Settlement Reserve under Section 11.5 for up to one hundred and eighty (180) days, or longer while an investigation, dispute or claim is pending; remaining Funds are dealt with under Sections 18.5 to 18.9 of the General Terms (Section 18.5 permitting retention of Fees and quantified amounts due only, not blanket forfeiture of Merchant Proceeds); and the Administrator has no liability for the termination or suspension. Where no Successful Payment has been received for twelve (12) months the Administrator may disable the Merchant Service and revoke API credentials without affecting the Account; re-enablement may require updated Merchant Verification. Section 18.12 of the General Terms (Dormant Accounts) applies to the Account as a whole.","parentId":null},{"id":573,"content":"**16.4  Survival.** Sections 3.4, 3.5, 3.7, 3.8, 3.9, 4.5, 5, 6.4, 7.2 (restrictions), 8.5, 8.6, 9, 10, 11.5, 11.6, 11.7, 12 (removal obligation), 13, 14, 15 and 16, Part B Sections B7 to B9 and Part C survive termination, together with any other provision intended by its nature to survive.","parentId":null},{"id":574,"content":"**16.5  Governing law and jurisdiction.** These Merchant Terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them, their subject matter or formation are governed by the laws of the Turks and Caicos Islands. The courts of the Turks and Caicos Islands have exclusive jurisdiction; the Merchant irrevocably submits to that jurisdiction and waives any objection of venue or inconvenient forum. The Administrator may seek interim, injunctive or protective relief, or enforce a judgment, in any other jurisdiction. Nothing deprives the Merchant of the protection of any provision of law that cannot be derogated from by agreement. These Merchant Terms are drawn up in English, which prevails over any translation.","parentId":null},{"id":575,"content":"**16.6  Notices.** The Administrator may give notice by email to the address registered in the Account, by Dashboard notification or by publication on the Website, deemed received when sent or published; the Merchant shall keep its contact details current and monitor them. The Merchant may give notice by email to customersupport@pst.net (operational matters) or compliance@pst.net (compliance matters), and legal notices shall additionally be sent to the Administrator’s registered office for the attention of the Compliance Officer. Electronic communications satisfy any requirement of writing.","parentId":null},{"id":576,"content":"**16.7  Amendments.** The Administrator may amend these Merchant Terms (including Parts B and C) by publishing the amended version on the Website with an updated “Last updated” date. Material amendments are notified through the Dashboard or by email at least thirty (30) days before taking effect, except where earlier effect is required by Applicable Law, Sanctions, an Infrastructure Provider, security or a Network event. Continued use after an amendment takes effect constitutes acceptance; a Merchant that does not accept must disable the Merchant Service before it takes effect.","parentId":null},{"id":577,"content":"**16.8  General.** The Merchant may not assign or transfer these Merchant Terms without the Administrator’s written consent; the Administrator may assign or transfer them to an affiliate or successor, and subcontract performance, on notice. If any provision is invalid or unenforceable it is modified to the minimum extent necessary or severed, and the remainder continues. No failure or delay in exercising a right is a waiver, and waivers must be in writing. These Merchant Terms, the General Terms, the Internal Policies, the brand guidelines, the API documentation and the parameters displayed in the Dashboard are the entire agreement on the Merchant Service and supersede prior understandings. The Parties are independent contractors; save for the limited agency in Section 3.3, nothing creates a partnership, joint venture, employment, fiduciary or agency relationship, Section 3.9 applies, and Section 23.6 of the General Terms applies. Except for Infrastructure Providers and Financial Partners, which may enforce Section 15 directly, no third party may enforce these Merchant Terms. Acceptance and records may be electronic; no signature is required. Days are calendar days and times are Turks and Caicos Islands time unless stated.","parentId":null},{"id":578,"content":"**16.9  Force majeure.** Neither Party is liable for failure or delay in performance (other than payment obligations) caused by events beyond its reasonable control, including acts of God, war, terrorism, civil unrest, epidemic, governmental or regulatory action, Sanctions, failure of utilities, telecommunications or the internet, failure, congestion, fork, halt or attack affecting any Network, failure or withdrawal of service by any Infrastructure Provider or token issuer, and cyber-attack, provided it uses reasonable efforts to mitigate.","parentId":null},{"id":579,"content":"**16.10  No association with third parties.** The Administrator has no association, affiliation, endorsement, sponsorship or partnership with any Network, protocol, foundation, token issuer (including the issuers of USDT and USDC), wallet provider, exchange, messaging platform (including Telegram), e-commerce platform or other third party referred to in the Dashboard, the Checkout, the API documentation or the Website. Third-party names and marks belong to their owners and are used only descriptively. The Merchant’s relationship with any such third party is exclusively its own, and the Administrator has no responsibility for any third party’s acts, omissions, terms, availability or policies.","parentId":null},{"id":580,"content":"**16.11  Acknowledgement.** The Merchant acknowledges that it has read and understood these Merchant Terms (Parts A, B and C), the General Terms and the Internal Policies; that it has had the opportunity to obtain independent legal, regulatory and tax advice; that the allocation of risk in Sections 3, 8, 9, 10, 11, 14 and 15 is clear and accepted by it as a business user; and that it has enabled the Merchant Service on that basis.","parentId":null}]},{"id":69,"__component":"ui.list","type":null,"title":"PART B — MERCHANT AML & KYC POLICY","isolated":false,"item":[{"id":581,"content":"**B1. Purpose, Scope and Framework**","parentId":null},{"id":582,"content":"**B1.1**  This Merchant AML & KYC Policy (the “Merchant AML Policy”) sets out the measures the Administrator applies to prevent the Merchant Service from being used for money laundering, terrorist financing, proliferation financing, fraud or the evasion of Sanctions. It applies to every Merchant, to the Merchant’s directors, beneficial owners and Authorised Representatives, to Payers, and to every Payment, Refund and withdrawal made through the Merchant Service. It supplements the platform AML Policy published at https://pst.net/legal/aml, which continues to apply to the Account; where they differ in relation to the Merchant Service, this Merchant AML Policy prevails.","parentId":null},{"id":583,"content":"**B1.2**  The Administrator conducts its business under the anti-money-laundering and counter-terrorist-financing framework of the Turks and Caicos Islands, including the Proceeds of Crime Ordinance, the Anti-Money Laundering and Prevention of Terrorist Financing Regulations and the Anti-Money Laundering and Prevention of Terrorist Financing Code, and applies the Recommendations of the Financial Action Task Force, including Recommendation 15 (virtual assets) and Recommendation 16 (the Travel Rule), as standards of good practice. The Administrator’s Compliance Officer, who also acts as Money Laundering Reporting Officer, is responsible for this Merchant AML Policy and may be contacted at compliance@pst.net.","parentId":null},{"id":584,"content":"**B1.3** The Administrator applies a risk-based approach: the extent of verification, monitoring and control applied to a Merchant, a Payer or a Payment is proportionate to the risk it presents, assessed by reference to the Merchant’s industry, business model, ownership, jurisdictions, transaction profile, Payer base, delivery model and history, and to the characteristics of each Payment.","parentId":null},{"id":585,"content":"**B2. Mandatory Merchant Verification**","parentId":null},{"id":586,"content":"**B2.1**  The Merchant Service is enabled only after the Merchant has completed Merchant Verification and the Administrator has approved it. Merchant Verification is in addition to the Verification of the Account under Section 5 of the General Terms and consists of the following, conducted through the Administrator’s identity-verification provider and the Dashboard:\n\n\n-\t**Business verification (KYB).** For a legal entity: certificate of incorporation or equivalent; constitutional documents; evidence of registered and operating addresses; the register of directors and of shareholders or members; an ownership chart identifying every beneficial owner holding or controlling twenty-five per cent (25%) or more (or such lower threshold as the Administrator applies to higher-risk Merchants) and any person exercising control by other means; evidence of the authority of the Authorised Representative; and, where the business is regulated, evidence of its licences or registrations. For a sole trader: evidence of the trading name and of business registration where applicable.\n-\t**Identity verification with live face verification.** The Authorised Representative who enables and operates the Merchant Service, and each beneficial owner and director whom the Administrator designates on a risk basis, must verify their identity by (a) submitting a valid government-issued photographic identity document (passport, national identity card or driving licence); (b) completing a live face verification — a selfie and liveness check captured in real time and matched against the identity document — designed to confirm that the person presenting the document is its genuine holder and is physically present; and (c) providing proof of residential address where required. Identity verification cannot be completed by uploading a pre-recorded image or video, by a third party on the individual’s behalf, or by any means other than the live process provided. An individual who does not complete live face verification cannot act as Authorised Representative for the Merchant Service.\n-\t**Business profile.** A description of the goods or services sold and the industry; the Merchant’s websites, applications, Telegram channels and other sales channels; the target markets and expected geographic distribution of Payers; expected monthly volumes and average and maximum Invoice values; the delivery model and timescales; and the Merchant’s refund, delivery and complaints policies.\n-\t**Source of funds and wealth.** Where the Merchant is assessed as higher-risk, or where volumes, values or patterns so warrant, information and supporting evidence concerning the source of the Merchant’s funds and of its beneficial owners’ wealth.","parentId":null},{"id":587,"content":"**B2.2**  The Administrator screens the Merchant, its directors, beneficial owners and Authorised Representatives against the Sanctions lists described in Section B4, against lists of politically exposed persons (“PEPs”) and their family members and close associates, and against adverse-media sources, and may consult public registers, credit-reference and fraud-prevention databases, blockchain-analytics data and information provided by Infrastructure Providers.","parentId":null},{"id":588,"content":"**B2.3**  Merchant Verification must be refreshed: (a) at intervals determined by the Merchant’s risk rating, and in any event not less than every twenty-four (24) months for standard-risk and twelve (12) months for higher-risk Merchants; (b) on any change of ownership, control, directors, Authorised Representative, business activity, goods or services, sales channel or jurisdiction; (c) on reactivation after the Merchant Service has been disabled for inactivity; (d) on expiry of an identity document relied on; (e) where a risk indicator, Sanctions or PEP match, adverse-media finding or unusual transaction pattern arises; and (f) whenever the Administrator otherwise reasonably requires. A refresh may include a repeat live face verification. The Administrator may suspend the Merchant Service, hold Merchant Proceeds and decline withdrawals until a refresh is completed.","parentId":null},{"id":589,"content":"**B2.4**  The Administrator may decline to enable the Merchant Service, or may terminate it, without giving reasons where Merchant Verification cannot be completed to its satisfaction, where the Merchant is unwilling or unable to provide information requested, where a Sanctions match is confirmed, where the Merchant, an owner or a representative is a PEP and enhanced due diligence is not satisfactory, or where the Administrator otherwise assesses the risk as unacceptable.","parentId":null},{"id":590,"content":"**B3. Risk Rating, Tiers and Enhanced Due Diligence**","parentId":null},{"id":591,"content":"**B3.1** Each Merchant is assigned a risk rating and a tier that determine the transaction, daily and monthly limits, the Supported Cryptocurrencies, the Settlement Reserve and the monitoring intensity applying to it, as displayed in the Dashboard. Limits may be increased only on request and after any additional due diligence the Administrator requires.","parentId":null},{"id":592,"content":"**B3.2**  Enhanced due diligence is applied where the Merchant, an owner, a representative or its business presents higher risk, including where: the Merchant operates a Restricted Business; the Merchant, an owner or a representative is a PEP or is connected with a jurisdiction identified by the FATF or by the Administrator as higher-risk; the ownership structure is complex, opaque or involves nominees, trusts or bearer instruments; expected volumes are large or inconsistent with the business profile; adverse media exists; delivery of goods or services is delayed, intangible or difficult to evidence; or the Merchant sells to Payers in higher-risk jurisdictions. Enhanced due diligence may include senior-management approval, additional documents, source-of-funds and source-of-wealth evidence, site or video interviews, lower limits, a Settlement Reserve and more frequent review.","parentId":null},{"id":593,"content":"**B4. Sanctions and PEP Screening**","parentId":null},{"id":594,"content":"**B4.1**  The Administrator screens Merchants, their directors, beneficial owners and Authorised Representatives, Payers where identified, and the blockchain addresses involved in Payments, Refunds and withdrawals against the consolidated lists of the United Nations Security Council, the Turks and Caicos Islands, the United Kingdom (HM Treasury / OFSI), the European Union and the United States (OFAC), and such other lists as the Administrator or its Infrastructure Providers apply, at onboarding, on each refresh, on each transaction and whenever lists are updated.","parentId":null},{"id":595,"content":"**B4.2**  The Administrator does not onboard, and will terminate, any Merchant that is, or is owned or controlled by or acting on behalf of, a Sanctioned person, and will freeze, reject, return or report, as Applicable Law requires, any Payment, Refund or withdrawal involving a Sanctioned person, a sanctioned address or a comprehensively sanctioned territory. Persons connected with Restricted Jurisdictions are not onboarded. PEPs are subject to enhanced due diligence under Section B3.2 and senior-management approval.","parentId":null},{"id":596,"content":"**B5. Payer Due Diligence and the Travel Rule**","parentId":null},{"id":597,"content":"**B5.1** Payers are not Customers of the Administrator. Nonetheless, the Administrator may, at the Checkout or afterwards, require a Payer to provide identifying information (such as name, email address and wallet address) and, for Payments above the thresholds displayed in the Dashboard or presenting elevated risk, to complete identity verification including a live face verification through the identity-verification provider, before a Payment is accepted or credited. The Administrator may decline or return a Payment where a Payer does not complete these steps, and the Merchant shall not seek to circumvent them.","parentId":null},{"id":598,"content":"**B5.2**  Every sending address is screened using blockchain-analytics tools for exposure to Sanctioned persons, mixers, darknet markets, ransomware, theft, fraud, unlicensed exchanges and other illicit sources, and Payments exceeding the Administrator’s risk tolerance are treated as Flagged Payments under Section 9.5 of Part A.","parentId":null},{"id":599,"content":"**B5.3**  Where Applicable Law requires Travel Rule Information to accompany a transfer, the Administrator may collect originator information from Payers and counterpart service providers, transmit the Merchant’s beneficiary information to counterpart service providers, and decline Payments for which adequate Travel Rule Information is unavailable. The Merchant consents to the transmission of its information for these purposes and shall provide any information reasonably requested.","parentId":null},{"id":600,"content":"**B6. Transaction Monitoring**","parentId":null},{"id":601,"content":"**B6.1**  The Administrator monitors Payments, Refunds, withdrawals and the use of Merchant Proceeds on an ongoing basis, using automated rules, blockchain analytics and manual review, against the Merchant’s expected profile and against typologies including: Payments inconsistent with the stated business, volumes or Payer base; structuring of Invoices below thresholds; rapid movement of Merchant Proceeds to withdrawal or to PSTNET Cards without a commercial rationale; self-payments and round-tripping; Payments from newly created, high-risk or high-velocity addresses; unusual Refund patterns; spikes in Payment Exceptions or complaints; and use of Merchant Proceeds in a manner suggesting third-party funding or layering.","parentId":null},{"id":602,"content":"**B6.2**  Where monitoring raises a concern the Administrator may hold Merchant Proceeds, restrict withdrawals and the funding of PSTNET Cards, request information and documents (including Invoices issued to Payers, proof of delivery, contracts, correspondence and source-of-funds evidence) within a specified period, impose or increase a Settlement Reserve, reduce limits, require a refresh of Merchant Verification, suspend the Merchant Service or terminate it. The Merchant shall respond promptly and fully.","parentId":null},{"id":603,"content":"**B6.3**  In addition to ongoing monitoring, the Administrator conducts compliance checks on Merchants selected at random, periodically or on a risk basis, without prior notice and without giving reasons, as described in Section 4.5 of Part A. Such checks may include a refresh of Merchant Verification (including a further live face verification), document requests, test purchases, interviews and site visits. Selection for a compliance check does not imply suspicion. The Administrator may decline to enable, and may close, the Merchant Service at its discretion without giving reasons, and Sections B2.4 and B7.2 apply.","parentId":null},{"id":604,"content":"**B7. Reporting and Tipping-Off**","parentId":null},{"id":605,"content":"**B7.1**  Where the Administrator knows, suspects or has reasonable grounds to suspect that a Merchant, a Payer, a Payment or any Funds are connected with money laundering, terrorist financing, proliferation financing, fraud or Sanctions evasion, the Compliance Officer will file a suspicious activity report with the Financial Intelligence Agency of the Turks and Caicos Islands and with any other competent authority as Applicable Law requires, may freeze the relevant Payment or Funds pending any consent or direction, and may terminate the business relationship.","parentId":null},{"id":606,"content":"**B7.2**  The Administrator is prohibited from disclosing that a report has been or may be made, or that an investigation is being or may be carried out, and will not give reasons for a hold, freeze, decline, return or termination where doing so would constitute tipping-off. The Merchant acknowledges that the Administrator has no liability for any loss arising from action taken in good faith under this Section B7.","parentId":null},{"id":607,"content":"**B8. Records and Information Sharing**","parentId":null},{"id":608,"content":"**B8.1**  The Administrator retains records of Merchant Verification (including identity documents and live face verification results), risk assessments, Payments, Refunds, withdrawals, screening and monitoring results, correspondence and reports for at least five (5) years after the end of the business relationship or the date of the relevant transaction, whichever is later, and longer where required by a competent authority or for legal proceedings.","parentId":null},{"id":609,"content":"**B8.2**  The Merchant authorises the Administrator to share information about the Merchant, its owners and representatives, its Payers and its Payments with Infrastructure Providers (including the identity-verification, blockchain-analytics and Conversion Providers), with Financial Partners, with competent authorities, law-enforcement agencies, courts and regulators, and with counterpart service providers for Travel Rule purposes, in accordance with this Merchant AML Policy, Part C and Applicable Law.","parentId":null},{"id":610,"content":"**B9. Merchant Obligations and Compliance Statement**","parentId":null},{"id":611,"content":"**B9.1** The Merchant shall: (a) not use the Merchant Service to launder money, finance terrorism or evade Sanctions, and not accept Payments it knows or suspects to be connected with illicit activity; (b) comply with any anti-money-laundering, counter-terrorist-financing and sanctions obligations that apply to it under its own law, and maintain its own controls where required; (c) provide accurate and complete information at onboarding and keep it updated under Section 4.4 of Part A; (d) ensure that only verified individuals operate the Merchant Service and that credentials are not shared; (e) keep the records required by Section 5.2(c) of Part A and produce them on request; (f) cooperate fully and promptly with monitoring, due-diligence and refresh requests; and (g) inform the Administrator promptly if it becomes aware of any Sanctions, PEP, regulatory or criminal matter affecting it, its owners or its representatives.","parentId":null},{"id":612,"content":"**B9.2** The Administrator’s screening and monitoring are conducted for the Administrator’s own compliance purposes and are not a service to the Merchant, do not verify any Payer on the Merchant’s behalf, and do not relieve the Merchant of its own obligations.","parentId":null},{"id":613,"content":"**B9.3**  By enabling the Merchant Service, the Merchant’s Authorised Representative confirms on behalf of the Merchant that the Merchant has read and understood this Merchant AML Policy, will operate in compliance with it and with Applicable Law, and accepts responsibility for any failure to do so. The Administrator reviews this Merchant AML Policy at least annually and updates it as Applicable Law, regulatory guidance, Infrastructure Provider requirements and its own risk assessment require.","parentId":null}]},{"id":70,"__component":"ui.list","type":null,"title":"PART C — MERCHANT PRIVACY NOTICE","isolated":false,"item":[{"id":614,"content":"**C1. Who we are and what this Notice covers**","parentId":null},{"id":615,"content":"**C1.1** This Merchant Privacy Notice (the “Notice”) explains how ADV Summit Advisors Limited (the “Administrator”, “we”, “us”), Suite A210, Regent Village, Grace Bay Road, Providenciales, Turks and Caicos Islands, processes personal data in connection with the Merchant Service. We are the controller of that processing. Our Data Protection Officer can be contacted at dpo@pst.net.","parentId":null},{"id":616,"content":"**C1.2 ** This Notice applies to: (a) individuals connected with a Merchant — sole traders, directors, beneficial owners, Authorised Representatives and other personnel (“Merchant Individuals”); and (b) individuals who make or attempt Payments to a Merchant (“Payers”). It is specific to the Merchant Service and, in relation to it, applies in place of the platform Privacy Policy published at https://pst.net/legal/privacy, which continues to govern the Account and the other System Services. The platform Cookie Policy applies to the Website and the Dashboard. This Notice describes only how we process personal data; it does not create any contractual or other relationship between us and Payers, who remain customers of the Merchant alone (Section 3.7 of Part A).","parentId":null},{"id":617,"content":"**C1.3**  The Turks and Caicos Islands does not have a comprehensive data-protection statute. We nevertheless apply the standards described in this Notice, which are modelled on the EU and UK General Data Protection Regulations, to all personal data we process for the Merchant Service, and we comply with the data-protection laws of other jurisdictions to the extent they apply to us.","parentId":null},{"id":618,"content":"**C2. Personal data we collect**","parentId":null},{"id":619,"content":"**C2.1  Merchant Individuals.** Identity data (name, date of birth, nationality, place of birth); government-issued identity documents and the data they contain; biometric data generated by live face verification (facial images, liveness video and the biometric templates and match results derived from them); residential address and proof of address; contact details; role, ownership percentage and authority; PEP status and Sanctions-screening results; adverse-media results; source-of-funds and source-of-wealth information; tax residency and taxpayer identification numbers; login, device, IP and usage data for the Dashboard; and correspondence with us.","parentId":null},{"id":620,"content":"**C2.2  Payers.** Name, email address and other contact details where provided at the Checkout; wallet addresses, transaction hashes, Payment Asset, Network, amounts, timestamps and Invoice references; IP address, device and browser data collected at the Checkout; where required under Part B, identity documents and live face verification data; blockchain-analytics risk data associated with sending addresses; Travel Rule Information; and correspondence concerning Payment Exceptions, Refunds and complaints.","parentId":null},{"id":621,"content":"**C2.3  Business data.** Information about the Merchant’s business, sales channels, products, volumes and policies, which may include personal data where the Merchant is a sole trader or where individuals are identified within it.","parentId":null},{"id":622,"content":"**C2.4**  We obtain personal data from the Merchant and its representatives, from Payers at the Checkout, from our identity-verification provider, from blockchain-analytics providers, from Conversion Providers and other Infrastructure Providers, from public registers, Sanctions and PEP lists and adverse-media sources, from counterpart service providers under the Travel Rule, and from the public Networks themselves, on which transaction data is permanently and publicly recorded.","parentId":null},{"id":623,"content":"**C3. Why we process personal data and on what basis**","parentId":null},{"id":624,"content":"**C3.1**  We process personal data for the following purposes and on the following legal bases (where a legal basis is required by the law applicable to the individual):\n\n-\t**Providing the Merchant Service** — creating Invoices, receiving and attributing Payments, arranging conversion, crediting Merchant Proceeds, processing Refunds and withdrawals, operating the Dashboard, API and Checkout, and communicating with the Merchant and Payers. Basis: performance of our contract with the Merchant; for Payers, our legitimate interests in operating the service the Merchant has chosen and in discharging the Payer’s obligation to the Merchant.\n-\t**Merchant Verification, Payer verification and AML compliance** — verifying identity and business information, live face verification, Sanctions and PEP screening, blockchain-analytics screening, risk rating, transaction monitoring, Travel Rule compliance, record-keeping and reporting to authorities under Part B. Basis: compliance with our legal obligations under the law of the Turks and Caicos Islands; our legitimate interests in preventing financial crime and meeting the standards expected by our Infrastructure Providers; and, for biometric data, the individual’s explicit consent (Section C4).\n-\t**Fraud prevention and security** — detecting and preventing fraud, account takeover, unauthorised access and abuse of the System. Basis: our legitimate interests and, where applicable, legal obligation.\n-\t**Tax and regulatory reporting** — collecting tax-residency information and reporting where required by automatic-exchange-of-information regimes. Basis: legal obligation.\n-\t**Legal claims and disputes** — establishing, exercising and defending legal claims, and handling complaints. Basis: our legitimate interests.\n-\t**Service communications and improvement** — notifying changes, sending operational and security messages, analysing use of the Merchant Service and improving it. Basis: performance of contract and our legitimate interests. We do not send marketing to Payers, and we send marketing to Merchant Individuals only in accordance with the platform Privacy Policy.","parentId":null},{"id":625,"content":"**C4. Biometric data and live face verification**","parentId":null},{"id":626,"content":"**C4.1**  Live face verification is a mandatory part of Merchant Verification for Authorised Representatives and designated owners, and may be required of Payers for higher-value or higher-risk Payments. It is carried out by our identity-verification provider, which captures a selfie and a short liveness sequence, extracts facial-geometry data and compares it with the photograph on the identity document to confirm that the person is the genuine document holder and is physically present. The provider returns to us the match result, the liveness result, the captured images and associated metadata.","parentId":null},{"id":627,"content":"**C4.2**  Biometric data is special-category data. We process it only to verify identity, prevent impersonation and fraud, and meet our anti-money-laundering obligations. We do not use it for any other purpose, do not use it to identify individuals in other contexts, and do not sell or share it for advertising. Where the law applicable to the individual requires it, we rely on the individual’s explicit consent, which is requested before the live face verification begins. Consent may be withdrawn by contacting dpo@pst.net; withdrawal does not affect processing already carried out, and because live face verification is a mandatory condition of the Merchant Service, withdrawal means that the individual can no longer act as Authorised Representative and the Merchant Service may be suspended or terminated.","parentId":null},{"id":628,"content":"**C4.3** Biometric data and identity documents are retained for the period required by Section B8 of Part B (at least five (5) years after the end of the business relationship) and are then deleted, unless a longer period is required by a competent authority or for legal proceedings. Our identity-verification provider retains data under its own retention rules, which we require to be consistent with ours.","parentId":null},{"id":629,"content":"**C5. Who we share personal data with**","parentId":null},{"id":630,"content":"**C5.1**  We share personal data, to the extent necessary for the purposes above, with: our identity-verification provider; Conversion Providers and other Infrastructure Providers (including node, wallet-technology, key-management and blockchain-analytics providers) and Financial Partners; counterpart crypto-asset service providers for Travel Rule purposes; the Financial Intelligence Agency of the Turks and Caicos Islands, the Turks and Caicos Islands Financial Services Commission, law-enforcement agencies, courts, regulators and tax authorities in any relevant jurisdiction; our professional advisers, auditors and insurers; our group companies; and any actual or prospective purchaser or successor of our business, subject to confidentiality. We share with the Merchant the Payer data necessary for the Merchant to fulfil orders, handle Refunds and complaints and comply with its own obligations. We do not sell personal data.","parentId":null},{"id":631,"content":"**C5.2**  Transaction data recorded on public Networks (wallet addresses, amounts, timestamps and transaction hashes) is public by design, is permanently visible to anyone, and cannot be altered or deleted by us.","parentId":null},{"id":632,"content":"**C6. International transfers**","parentId":null},{"id":633,"content":"**C6.1**  We are established in the Turks and Caicos Islands and our providers operate in various jurisdictions, so personal data is transferred internationally. Where the law applicable to an individual restricts transfers, we rely on appropriate safeguards, including standard contractual clauses approved by the European Commission (Decision (EU) 2021/914), the UK International Data Transfer Agreement or Addendum, or other lawful mechanisms, and we require our providers to protect personal data to a standard consistent with this Notice. Copies of the relevant safeguards may be requested from dpo@pst.net.","parentId":null},{"id":634,"content":"**C7. Retention**","parentId":null},{"id":635,"content":"**C7.1**  We retain Merchant Verification records, biometric data, transaction records, screening and monitoring results and related correspondence for at least five (5) years after the end of the business relationship or the relevant transaction, whichever is later, as required by Part B and the law of the Turks and Caicos Islands, and longer where required by a competent authority or for legal proceedings. Payer data collected at the Checkout is retained for the same period. Dashboard usage and technical logs are retained for up to twenty-four (24) months unless needed for security or legal purposes. When data is no longer required it is deleted or irreversibly anonymised.","parentId":null},{"id":636,"content":"**C8. Your rights**","parentId":null},{"id":637,"content":"**C8.1**  Subject to the law that applies to you, you may ask us to: access the personal data we hold about you; correct inaccurate data; erase data; restrict or object to processing; provide data you gave us in a portable format; and withdraw consent where processing is based on consent. You may also complain to the data-protection authority in your jurisdiction (for example the Information Commissioner’s Office in the United Kingdom or the supervisory authority of an EU member state). Requests may be sent to dpo@pst.net; we will verify your identity before responding and will respond within one (1) month, extendable where permitted.","parentId":null},{"id":638,"content":"**C8.2**  Rights of erasure, restriction and objection are limited where we are required to retain data under Part B or Applicable Law, where the data is needed for legal claims, or where the data is recorded on a public Network and cannot be altered. We will explain any limitation when responding to a request.","parentId":null},{"id":639,"content":"**C9. The Merchant’s responsibilities for Payer data**","parentId":null},{"id":640,"content":"**C9.1**  The Merchant and we are each independent controllers of Payer personal data. The Merchant is responsible for: having a lawful basis for disclosing Payer data to us; informing Payers, in its own privacy notice, that payments are processed by the Administrator and that their data is shared with us for that purpose and is subject to this Notice; providing us only the personal data necessary for the Merchant Service and no special-category data except where required under Part B; keeping Payer data secure; and cooperating with us in responding to data-subject requests and supervisory-authority enquiries. The Merchant shall not use Payer data obtained through the Merchant Service for any purpose other than fulfilling the relevant order, handling Refunds and complaints and complying with its legal obligations, unless it has an independent lawful basis to do so.","parentId":null},{"id":641,"content":"**C10. Security, children and automated decisions**","parentId":null},{"id":642,"content":"**C10.1**  We apply technical and organisational measures appropriate to the risk, including encryption in transit and at rest, access controls, logging, segregation of environments and staff training, and we require our providers to do the same. No system is completely secure; we will notify affected individuals and authorities of a personal-data breach where Applicable Law requires.","parentId":null},{"id":643,"content":"**C10.2** The Merchant Service is not directed at persons under eighteen (18), and we do not knowingly process the personal data of minors as Merchant Individuals or Payers; the Merchant shall not permit minors to use it.","parentId":null},{"id":644,"content":"**C10.3** Merchant Verification, Payer verification, Sanctions screening, blockchain-analytics screening and transaction monitoring involve automated processing, and a Payment may be automatically declined or held on the basis of it. Decisions to refuse or terminate the Merchant Service, to file a report or to freeze Funds are reviewed by our compliance personnel. Where the law applicable to you grants rights in relation to automated decisions, you may exercise them by contacting dpo@pst.net, subject to the limits in Part B.","parentId":null},{"id":645,"content":"**C11. Changes and contact**","parentId":null},{"id":646,"content":"**C11.1** We may update this Notice under Section 16.7 of Part A. Questions about this Notice or our processing may be sent to dpo@pst.net or to our registered office marked for the attention of the Data Protection Officer.","parentId":null}]}]}}],"meta":{"pagination":{"page":1,"pageSize":25,"pageCount":1,"total":7}}}