Our Policies

Terms & Conditions

We understand you want to know what you can expect from us, and that is why we have drawn up these Terms and Conditions (T&Cs). We aim to be transparent, however if anything is unclear, please let us know.

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Where You have agreed to other terms with Us, those terms will take precedence over these T&Cs where they conflict

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These T&Cs are an agreement between Trustflow Pay (Trustflow, Us, We, or Our) and You (User, You, or Your). This Agreement sets forth the general terms and conditions of Your use of the trustflowpay.com website (Platform). Any of its products or services (Services) will be covered under a separate Service Agreement provided by our sales or onboarding team.

About Us

Trustflow Pay is a trading name of Trustflow Technologies Limited

13 John Prince's Street, London, England, EC1N 8UN

Contact details: https://trustflowpay.com

Use Terms for our Website

The Website, Trustflowpay.com, is a marketing website for our services. In time we hope to develop our technology to provide a full online service through customer dashboards however this is not currently in place.

Accuracy of information

Occasionally there may be information on the Platform that contains typographical errors, inaccuracies or omissions that may relate to promotions and offers. We reserve the right to correct any errors, inaccuracies or omissions, and to change or update information or cancel orders if any information on the Platform or on any related Services are inaccurate at any time without prior notice (including after You have submitted Your order). We undertake no obligation to update, amend or clarify information on the Platform including, without limitation, pricing information, except as required by law. No specified update or refresh date applied on the Platform should be taken to indicate that all information on the Website or on any related Services have been modified or updated.

Prohibited uses

In addition to other any other terms agreed to, You are prohibited from using the Platform, Content, or Services: (a) for any unlawful purpose; (b) to solicit others to perform or participate in any unlawful acts; (c) to violate any international, federal, provincial or state regulations, rules, laws, or local ordinances; (d) to infringe upon or violate our intellectual property rights or the intellectual property rights of others; (e) to harass, abuse, insult, harm, defame, slander, disparage, intimidate, or discriminate based on gender, sexual orientation, religion, ethnicity, race, age, national origin, or disability; (f) to submit false or misleading information; (g) to upload or transmit viruses or any other type of malicious code that will or may be used in any way that will affect the functionality or operation of the Service or of any related website, other websites, or the Internet; (h) to collect or track the personal information of others; (i) to spam, phish, pharm, pretext, spider, crawl, or scrape; (j) for any obscene or immoral purpose; or (k) to interfere with or circumvent the security features of the Services and Platform or any related website, other websites, or the Internet. We reserve the right to terminate your use of the Services or any related website for violating any of the prohibited uses unconditionally.

Disclaimer of warranty

You agree that Your use of our Platform and Services is solely at Your own risk. The Platform and Services and information obtained through the Platform are provided on an “as is” and “as available” basis.

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We do not provide tax, legal, or accounting advice and are not permitted to engage in the practice of law. We do not act as your attorney, and information given by Us is made for informational purposes only and is not a substitute for the advice of an attorney if such is needed to make decisions about compliance with applicable laws. We take every reasonable effort to ensure our Services are provided to reflect our best understanding of compliance matters related to employment, the information on the platform is not legal advice and is not guaranteed to be correct, complete, or up-to- date.

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We expressly disclaim all warranties of any kind, whether express or implied, including but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement. We make no warranty that the Services will meet Your requirements, or that the Services will be uninterrupted, timely, secure, or error-free; nor do We make any warranty as to the results that may be obtained from the use of the Services or as to the accuracy or reliability of any information obtained through the Services or that defects in the Services will be corrected. You understand and agree that any material and/or data downloaded or otherwise obtained through the use of the Platform and Services is done at Your own discretion and risk and that You will be solely responsible for any damage to Your computer system or loss of data that results from the download of such material and/or data. We make no warranty regarding any goods or services purchased or obtained through the Services or any transactions entered into through the Services. No advice or information, whether oral or written, obtained by You from Us or through the Services shall create any warranty not expressly made herein. You are advised to consult with an attorney, tax advisor, or accountant before accepting these Terms & Conditions.

Limitation of liability

To the fullest extent permitted by applicable law, in no event will We, Our affiliates, officers, directors, employees, agents, suppliers or licensors be liable to any person for any indirect, incidental, special, punitive, cover or consequential damages (including, without limitation, damages for lost profits, revenue, sales, goodwill, use or content, impact on business, business interruption, loss of anticipated savings, loss of business opportunity) however caused, under any theory of liability, including, without limitation, contract, tort, warranty, breach of statutory duty, negligence or otherwise, even if Remote, has been advised as to the possibility of such damages or could have foreseen such damages. To the maximum extent permitted by applicable law, the aggregate liability of Our and Our affiliates, officers, employees, agents, suppliers and licensors, relating to the services will be limited to any amounts actually paid by You to Us for the one month period prior to the first event or occurrence giving rise to such liability. The limitations and exclusions also apply if this remedy does not fully compensate You for any losses or fails of its essential purpose.

Our Sustainability Commitment

We have the intention to combine economic success with ecological, human, governance, and social sustainability success. In this context, We are committed to evaluating our business practices and taking responsible action in regards to its environmental, social, and corporate governance (ESG) implications.

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Therefore, We are committing to:

• Measuring the carbon footprint of our business activities by using an appropriate assessment framework.
• Evaluating and implementing measures to reduce our carbon footprint as much as possible. Preferably with yearly targets, that include the business model / product implications.
• Achieving Net Zero in a reasonable time frame, compensating for the not reduced calculated emissions.

Severability

All rights and restrictions contained in these T & Cs may be exercised and shall be applicable and binding only to the extent that they do not violate any applicable laws and are intended to be limited to the extent necessary so that they will not render these T&Cs illegal, invalid or unenforceable. If any provision or portion of any provision of these T&Cs shall be held to be illegal, invalid or unenforceable by a court of competent jurisdiction, it is the intention of the parties that the remaining provisions or portions thereof shall constitute their agreement with respect to the subject matter hereof, and all such remaining provisions or portions thereof shall remain in full force and effect.

Dispute resolution

The formation, interpretation, and performance of these T&Cs and any disputes arising out of it shall be governed by the laws of England and Wales. The exclusive jurisdiction and venue for actions related to the subject matter hereof shall be subject to arbitration or mediation in England and Wales, and You shall submit to the arbitration rules of such jurisdiction. The United Nations Convention on Contracts for the International Sale of Goods does not apply to this Agreement.

Changes and amendments

We reserve the right to modify these T&Cs and any policies relating to the Platform or Services at any time. Continued use of the Platform after any such changes shall constitute your consent to such changes.

Contact us

For inquiries or requests, please contact us at help@trustflowpay.com.

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Privacy Policy

Your privacy is of vital importance to us. You have confidence in our payment systems and share important personal data with us. We provide you with easy insights and overview into what data we collect, what we use this data for and with whom we may share your data.

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What do we collect?

What personal data do we collect?

At Trustflow Pay, we collect a range of personal data from our users. This may include information such as name, contact details, and financial information. For the full list see:

• Call title
• First name, initials and surname
• Address details
• Telephone number (phone)
• E-mail address
• Identity card
• Bank account with name
• Unique address of your device (IP)
• Unique hardware data (Mac)
• Unique software data (Version)
• Payment transaction data

What is the data used for?

The personal data we collect is mainly used to provide our users with the best possible experience on our platform and connected services. This data may be used to help improve our services, and to better understand the people using our platform.

• We may share information with other parties, but only if necessary (e.g. name and address for the payment and shipment of a product).
• We may share information with other parties for which you have given express permission.
• We may share information with the police or government agencies in case of suspicion of fraud, violations or crimes.
• And we may share information with other parties If we are legally obliged to provide data.

Which control do you have?

We believe that people should have control over their personal data. Therefore we are commited to help you understand the data we have, and delete it when needed.

• You can ask us what information we have registered about you. You can do by emailing us at help@trustflowpay.com
• You can update your details with us.
• You can ask us to remove your data, we will then only remove the data that we do not have to keep in accordance with our legal obligation. Please email us at help@trustflowpay.com

How we handle your data

We have implemented industry-standard security measures to protect our users' data. We also regularly review our security procedures to ensure that our users' data is always protected.

• We encrypt and store your personal data in a secure environment that is monitored 24/7.
• Only our employees who need your information for their work can view it.
• All our employees who work with your personal data have been checked for reliability.

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KYC Policy

The purpose of this KYC Policy is to ensure compliance with regulatory requirements and to mitigate risks related to money laundering, terrorist financing, fraud, and other illegal activities. By implementing this policy, Trustflow Pay aims to establish and maintain a robust framework for identifying and verifying customers and managing ongoing customer relationships.

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1. Scope

This policy applies to all employees, contractors, and agents of Trustflow Pay involved in customer onboarding, account management, and compliance functions.

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2. Customer Identification Program (CIP)

• Customer Identification:
  • Customers must provide reliable identification documents as per regulatory requirements.
  • Acceptable documents include but are not limited to government-issued IDs, passports, and utility bills.
• Verification Procedures:
  • Employees must verify the authenticity of documents provided.
  • Use reliable sources and databases to verify customer information where applicable.

3. Risk Assessment

• Risk-Based Approach:
  • Classify customers based on risk profiles (e.g., low, medium, high).
  • Conduct enhanced due diligence for high-risk customers.
• Ongoing Monitoring:
  • Regularly review customer transactions and activities.
  • Update customer information periodically and as required by law.

4. Customer Due Diligence (CDD)

• Initial Due Diligence:
  • Gather sufficient information to understand the nature of the customer’s business and the purpose of the relationship.
  • Identify the beneficial owners of legal entity customers.
• Enhanced Due Diligence:
  • Conduct enhanced due diligence for politically exposed persons (PEPs) and high-risk customers.
  • Obtain senior management approval for high-risk customers.

5. Record Keeping

• Documentation:
  • Maintain accurate records of customer identification and verification processes.
  • Retain records for the period required by applicable laws and regulations.

6. Compliance Monitoring

• Internal Controls:
  • Regularly review the effectiveness of the KYC program.
  • Conduct periodic audits and assessments of compliance with this policy.

7. Training and Awareness

• Employee Training:
  • Provide regular training to employees on KYC procedures and updates.
  • Ensure employees understand their roles and responsibilities in implementing this policy.

8. Reporting

• Suspicious Activity Reporting:
  • Establish procedures for reporting suspicious activities to the relevant authorities.
  • Maintain confidentiality and protect whistleblowers in accordance with applicable laws.

9. Amendments and Updates

• Policy Review:
  • Periodically review and update this policy to reflect changes in regulatory requirements and business practices.
  • Obtain approval from senior management for any amendments.

10. Responsibilities

• Senior Management:
  • Oversee the implementation and effectiveness of the KYC program.
• Compliance Officer:
  • Designate a Compliance Officer responsible for overseeing compliance with this policy.
  • Ensure prompt action on any deficiencies identified.

11. Conclusion

Trustflow Pay is committed to maintaining the highest standards of integrity and regulatory compliance. This KYC Policy serves as a cornerstone in our efforts to safeguard our business from illicit activities and to build trust with our customers and stakeholders.

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