Terms & Conditions

The objectives of these terms of use (“Terms”) are to inform you the reader and user of E1 Tech Finfrastructure services of the terms which apply to the access/use of the E1 Tech Finfrastructure Platform (defined below).

The E1 Tech Finfrastructure Platform enables merchants and businesses to leverage technology to manage their invoicing, payments and collections, banking, accounting, payroll, tax and compliance from a unified dashboard.

These Terms are an electronic record in terms of the Information Technology Act, 2000 and rules thereunder as applicable and as amended from time to time. This electronic record is generated by a computer system and does not require any physical or digital signatures. These Terms governing the E1 Tech Finfrastructure Platform and Services are published in accordance with the provisions of Rule 3(1)(a) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 framed under the Information Technology Act, 2000 (as amended from time to time), and constitute a legally enforceable and binding contract between E1 Tech Finfrastructure and the User (as defined below). These terms of use consist of two parts:

Part A contains the general terms and conditions which governs the access and use of the web link: https://E1high.com and mobile application by the name of ‘E1 Tech Finfrastructure’ (“Website” or “E1 Tech Finfrastructure Platform”, which includes any and all the related mini-links and the Services provided thereunder) offered by E1 Tech Finfrastructure of 1M Global Business Services Private Limited (also referred to as “E1 Tech Finfrastructure”, “Company”, “We”, “Us” and “Our” as the context requires, and includes its affiliates [including but not limited to: E1 Tech Finfrastructure Private Limited and E1 Tech Finfrastructure Financial Technologies, Inc., assigns and Service Providers).

Part B contains specific terms and conditions that govern the use of each of the Services (defined below) to the extent such Services are availed by the User (defined below). The general terms and conditions provided under Part A (“General Terms”) shall be read and understood in conjunction with the Service-specific terms and conditions provided under Part B (“Service Terms”).

General Disclaimer: E1 Tech Finfrastructure is a technology service provider and a payment infrastructure regulated and licensed by the Gift City. It is not a bank and does not hold or claim to hold a banking license. The business current accounts, VISA, Master card and Rupay Cards and allied corporate cards, business loans and other similar banking services/financial services offered on the E1 Tech Finfrastructure platform are provided by the Banks (defined below) and All funds in a Business Current Account (defined below) are normally insured as per limits prescribed by the Deposit Insurance and Credit Guarantee Corporation (DICGC). If in doubt, please make an enquiry with the concerned Bank. Banking services/financial services offered on the E1 Tech Finfrastructure Platform are subject to security standards and legal requirements prescribed by the Bank, in accordance with extant RBI regulations.

PART A (General Terms & Conditions)

These General Terms govern the User’s use and/or access to the Website. These Terms form an integral part of, and will be read in conjunction with:

The privacy policy governing the use of the Website or provided to the User in any other manner or form, which is hosted at www.E1high.com/privacy/ (“Privacy Policy”).

Terms and conditions stipulated by Server Providers (including Banks), which are specifically applicable to the Service(s) availed by You.

Definitions

Unless the context otherwise requires, the following capitalized words shall have the meaning assigned to them below.

“Admin Verified” refers to the approval provided by the administrator at E1 Tech Finfrastructure the User to use a particular Service or set of Services subject to the User information submitted, KYC, risk assessment and execution of any other controls or protocols that may be required to verify and authenticate the User in accordance with applicable laws, including but not limited to the RBI Guidelines.

“Acquiring Bank” shall mean any bank which receives funds as sent by the User to the Customer.

“Bank” refers to any bank or financial institutions that are licensed and regulated by the Reserve Bank of India (“RBI”), which E1 Tech Finfrastructure has partnered with towards offering the Services. It is hereby clarified that the term “Bank” also includes any sponsor banks that E1 Tech Finfrastructure has partnered with, by establishing software protocols and direct integrations via API.

“Business Days” means any day on which banks are E1 Tech Finfrastructure for business in Mumbai, New Delhi and Bengaluru, India.

“Business Current Account” refers to a bank account that is linked by the User to the E1 Tech Finfrastructure Platform for settlement of proceeds. The Business Current Account can either be E1 Tech Finfrastructureed afresh with any Bank and linked to the E1 Tech Finfrastructure Platform for settlements or by completing KYC verification and linking an existing bank account to the E1 Tech Finfrastructure Platform. Usage of the Business Current Account by any User is subject to the terms stipulated by the concerned bank.

“Card Payment Network” includes Visa, Mastercard, the National Payments Corporation of India, American Express, Diner’s Club and any other card payment network designated as an authorized payment system as per RBI Guidelines.

“Card Payment Network Rules” refer to the written rules, regulations, releases, guidelines, processes, interpretations and other requirements (whether contractual or otherwise) imposed and adopted by the Card Payment Network.

“Confirmation of Delivery” refers to the confirmation by the User provided to E1 Tech Finfrastructure confirming delivery of goods or services to the Customer, which also authorizes E1 Tech Finfrastructure to settle funds collected in the Escrow Account to the Business Current Account belonging to the User in accordance with the RBI Guidelines. This authorization will remain in full force and effect until specifically terminated by the User in writing.

“Customer” shall mean any individual or entity that transacts with the User resulting in transference of funds to the User.

“Escrow Account” shall refer to the nodal account or escrow account maintained by E1 Tech Finfrastructure with the Bank in accordance with the RBI Guidelines.

“Know Your Customer” or “KYC” shall mean the various norms, orders, rules, regulations, laws, and statutes as per applicable laws, including the RBI Guidelines issued from time to time according to which E1 Tech Finfrastructure procure personal identification details from the User desiring to access/use the E1 Tech Finfrastructure Platform.

“E1 Tech Finfrastructure Pay” or “User Account” refers to the online account E1 Tech Finfrastructure by the User in accordance with the onboarding requirements stipulated on the E1 Tech Finfrastructure Platform.

“Payee” means any person to whom a payment is made, using the Services, (and the term includes a User who uses the Services to receive payment).

“Payer” means any person who makes a payment, using the Services (and the term includes a User who uses the Services to make payment).

“Prohibited Business” refers to any businesses, business activities, or business practices that are expressly prohibited by Us and/or our Service Providers, deemed illegal/unethical by the applicable laws, regulations, or commonly accepted business standards, and includes the business activities listed on this link.

“RBI Guidelines” refers to the extant rules, regulations, orders, directions, notifications and guidelines issued by RBI, including but not limited to - the Payment & Settlement Systems Act, 2007, the Guidelines on Regulation of Payment Aggregators and Payment Gateways dated March 17, 2020 and the Master Directions for Know Your Customer (KYC), 2016, as amended from time to time.

“Service(s)” means and includes the following services provided by E1 Tech Finfrastructure to the User at the request of the User:

E1 Tech Finfrastructure Pay for payment collections;

Payment Gateway;

Automated Accounting;

Multi-Account Connect;

Tax Filing;

Co-branded prepaid cards

Business Loans;

Apps - E1 Tech Finfrastructure Tally, Business Connect, E1 Tech Finfrastructure Payroll etc.; and

Includes any other products/services offered by Us on the E1 Tech Finfrastructure Platform, from time to time.

“Service Provider” refers to any entity, association of persons, facility provider, lender, card issuing institution, Bank, card processor, clearing house networks whose facilities or services are utilized in the provision of the Services.

“Transaction” means a payment instruction that results in the successful transfer of funds (a) from a User to a Payee; or (b) from a Payer to a User, as the context requires.

“User”, “You”, “Your” and “Yourself”, as the context requires, refers to and include any natural person or legal person (sole proprietor, partnership firm, company, LLPs, trusts, societies or HUFs) that registers on the E1 Tech Finfrastructure Platform and/or transacts or avails Services. The term ‘User’ shall also include such personnel of the User (including but not limited to any current or former officers, directors or employees of the User) who access the E1 Tech Finfrastructure Platform using the User Account credentials with either full rights or limited rights, as the case may be.

Eligibility

The E1 Tech Finfrastructure Platform must be accessed/used only by persons who can enter into legally binding contracts under the Indian Contract Act, 1872 by virtue of being ‘competent to contract’ within the meaning of Section 11 of the Indian Contract Act, 1872. The E1 Tech Finfrastructure Platform may be accessed and used by Users solely for their legitimate business requirements.

Registration and Access

To access and use the E1 Tech Finfrastructure Platform and Services, You must have a User Account registered on the E1 Tech Finfrastructure Platform. The User Account is provided to you by the Company in partnership with the Service Providers, subject to applicable laws (including the RBI Guidelines). You will provide the Company and the Service Providers (as applicable) with all documents and information required to carry out KYC in accordance with the RBI Guidelines. You must provide true, accurate, current and complete information at all times, failing which, E1 Tech Finfrastructure may at any time reject Your registration and terminate your right to use or access the E1 Tech Finfrastructure Platform and/or Services. For the purpose of conducting KYC on the User, E1 Tech Finfrastructure has the right to seek the self-attested copies of the documents, as submitted during/post the registration process.

You understand and unconditionally agree that even though you may be allowed to execute transactions on the E1 Tech Finfrastructure Platform, the funds shall not be settled to your account if there are any KYC obligations pending on Your part, in accordance with the RBI Guidelines. Further, in the event of non- completion of Your KYC obligations or breach/suspicion of breach of the Terms, to the satisfaction of E1 Tech Finfrastructure, We - 1M Global Business Services Private Limited reserve the right to not release the settlement amounts to You and eventually reverse the funds to the account from where such payment originated.

When you register on the E1 Tech Finfrastructure Platform, a User Account will be created based on the information You have provided. You are advised to keep the User credentials in confidence as you will be solely responsible for anything that happens through Your User Account. You will ensure that the User Account details provided and/or updated are correct and complete at all times. You shall inform E1 Tech Finfrastructure of any change in the User email address, mobile number, address, change in authorization, control or legal status or cessation of the User’s business by writing to Us within 30 (thirty) Business Days of such change or occurrence.

You shall be responsible at all times for maintaining the safety and confidentiality of the username, password and any other information pertaining to the User Account and for preventing unauthorized access to the User Account and devices. E1 Tech Finfrastructure will not be liable for any mistake or misuse of User Account by either the User or by any person authorized by the User, or by any person gaining access to the Services through the User Account.

It shall be your responsibility to review these Terms periodically for updates / changes. Your continued use of the E1 Tech Finfrastructure Platform following any amendments of these Terms is construed as deemed acceptance of such amendments. Subject to the User’s continued compliance with these Terms, E1 Tech Finfrastructure grants the User a personal, non-exclusive, non-transferable, limited privilege to access and use the E1 Tech Finfrastructure Platform.

You will use the E1 Tech Finfrastructure Platform only for lawful business activities and will not carry out any activity which is banned, illegal or immoral, or in any manner facilitate furtherance of any such activities which constitutes a violation of any law or regulation, including but not limited to the RBI Guidelines.

It is hereby clarified that any funds lying in the Business Current Account is held by the relevant Bank and shall be governed by the terms framed by the said Bank. Funds in the Business Current Account shall belong to the account holder registered on the Bank’s records and will be subject to applicable Bank charges.

You will be responsible and shall indemnify E1 Tech Finfrastructure against any liability, costs or damages arising in connection with (a) the User providing false, incorrect or misleading, information; and (b) compromise of the User Account credentials. E1 Tech Finfrastructure reserves the right to refuse access to the E1 Tech Finfrastructure Platform, terminate accounts, remove or edit content at any time without notice to the User concerned if these Terms are violated.

The User unconditionally authorizes E1 Tech Finfrastructure to generate Lightweight Directory Access Protocol (LDAP), the User credentials and subscribe to the API's on the sponsor Bank’s web portal or software platform on behalf of the User to facilitate the Services. The User authorizes E1 Tech Finfrastructure to service the User's Business Current Account on their behalf with regards to queries and complaints raised by the User and/or third party for facilitation of the Services including authorization for raising of queries with the Banks on their behalf.

Aadhaar Offline e-KYC Verification

There are a number of options for you to complete KYC on the E1 Tech Finfrastructure Platform. If you proceed to register on the E1 Tech Finfrastructure Platform using Aadhaar Offline e-KYC, You (the Aadhaar holder), hereby irrevocably:

place a request to E1 Tech Finfrastructure and Perfios Software Solutions Private Limited (“Perfios”) ( erstwhile known as Karza Technologies Private Limited or “Karza”) to access Your Aadhaar Information (defined below) from UIDAI to fetch and verify information regarding Aadhaar Number, Aadhaar XML, Virtual ID, e-Aadhaar, Masked Aadhaar, Aadhaar details, demographic information, identity information, Aadhaar registered mobile number, face authentication details and/or biometric information (collectively referred to as “Aadhaar Information”).

Explicitly authorize E1 Tech Finfrastructure and Perfios to fetch Your Aadhaar Information from UIDAI to make it available to E1 Tech Finfrastructure and/or any third party, as may be required for completing KYC verification.

You agree to take all the necessary actions required for the purpose of authenticating and verifying Your Aadhaar Information.

give a valid, binding, irrevocable and explicit authorization and consent as may be required under applicable laws, rules, regulations and guidelines for availing the Aadhaar API services of Perfios including, but not limited to the transmission and storage of Your Aadhaar Information by E1 Tech Finfrastructure and Perfios.

understand and agree that the Consent has been submitted by You voluntarily and without any coercion from E1 Tech Finfrastructure or Perfios or any other party.

fully understand and accept sole and complete responsibility for any issues, legal suits, damages, losses, penalties, fines or liabilities (“Losses”) arising out of Your sharing of Aadhaar Information and authorizing E1 Tech Finfrastructure or Perfios for fetching Your Aadhar Information and that You will fully hold harmless E1 Tech Finfrastructure and Perfios, its representatives, employees and directors for any Losses arising out of such request and actions.

Understand and agree that E1 Tech Finfrastructure and Perfios do not store or retain any Aadhaar Information including the Aadhaar number belonging to You after it has processed Your request.

Fees and Taxes

Unless otherwise mutually agreed in writing, You will be charged fees on a prepaid basis depending (a) on the Services You have requested or availed; and (b) the pricing/subscription plan that You have opted for (please refer to https://E1high.com/pricing for more details) on the E1 Tech Finfrastructure Platform (“Fee”). The subscription plans will be charged to you on a 30-day monthly or 360-day yearly policy. Your consumption of the Services will continue to be governed by the terms and Fee stipulated for the said subscription plan until you expressly upgrade or opt out of that subscription plan.

E1 Tech Finfrastructure will not make refunds of any amounts charged as Fee unless it is otherwise agreed as per these Terms.

You shall bear all taxes in connection with the levy of all Fee in accordance with applicable laws, including but not limited to – goods and services tax.

Data, Audit & Security

E1 Tech Finfrastructure may monitor all Transactions to flag and prevent high-risk practices and fraudulent transactions. It is understood that E1 Tech Finfrastructure may also engage Service Providers to assist in these efforts. In the event of any suspicious or unusual activity being carried out through the User Account, such account may be temporarily or permanently suspended.

The User and E1 Tech Finfrastructure each represents and covenants to the other that: (a) it does not store card information or any related data within its database or any servers accessed by it, except for limited lawful purposes, compliant with the RBI Guidelines; (b) it will adhere to the data security protocols prescribed under the RBI Guidelines, including the procedures for incident management and reporting; and (c) its systems and infrastructure are compliant with the Payment Card Industry-Data Security Standard (“PCI-DSS”). The User further represents and covenants to E1 Tech Finfrastructure that its systems and infrastructure are compliant with the Payment Application-Data Security Standard (“PA-DSS”), as applicable.

E1 Tech Finfrastructure at its sole and absolute discretion, without providing prior notice, may conduct inspections, risk and security assessments and audits on the User and may impose additional conditions/restrictions on the User Account, including but not limited to: (a) establishing a reasonable reserve amount to cover potential Chargebacks (defined below) and related fees; and (b) withholding Services and directing the User to upgrade its infrastructure in compliance with applicable laws.

The User will not sell, provide, exchange, or otherwise disclose to third parties or use themselves (other than for the purpose of completing a transaction, or as specifically required by law) any personal information about any third party (whether its Customer or otherwise), including the financial details and any personal identification information, without obtaining the prior written consent of such third party.

We employ the use of cookies on the E1 Tech Finfrastructure Platform. Most interactive websites use cookies to enable retrieval of the User details for each visit. Cookies are used in some areas of the E1 Tech Finfrastructure Platform to enable and enhance the functionality and ease of use for the Users. By using the E1 Tech Finfrastructure Platform, the User consents to the use of cookies in accordance with the Privacy Policy. Some of the Service Providers may also use cookies.

Content

Unless specifically permitted by the User, usage of the Services does not grant E1 Tech Finfrastructure the license to use, reproduce, adapt, modify, publish or distribute the content created and/or stored in the User Account. Notwithstanding the above, the User grants E1 Tech Finfrastructure permission to access, copy, distribute, store, transmit, reformat, or disclose the data /content of the User Account for the purpose of providing the Services requested/availed by the User.

The User may transmit or publish content created by using any of the Services or otherwise. However, the User shall be solely responsible for such content and the consequences of its transmission or publication. Any content that the User may receive from third-parties while using the Services, is provided to the User ‘AS IS’ for their information and personal use only and thus agree not to use, copy, reproduce, distribute, transmit, broadcast, display, sell, license or otherwise exploit such content for any purpose, without the express written consent of the person who owns the rights to such content.

We are not responsible if information made available on the E1 Tech Finfrastructure Platform is not accurate, complete or correct. The material on the E1 Tech Finfrastructure Platform is provided for general information only and should not be relied upon or used as the sole basis for making decisions without consulting primary, more accurate, more complete or more timely sources of information. Any reliance on the material on the E1 Tech Finfrastructure Platform is at the User’s own risk. The E1 Tech Finfrastructure Platform may contain certain historical information. Historical information, necessarily, is not current and is provided for the User’s reference only. We reserve the right to modify the contents of the E1 Tech Finfrastructure Platform at any time, but we have no obligation to update any information on the E1 Tech Finfrastructure Platform. The User agrees that it is the User’s responsibility to monitor changes on the E1 Tech Finfrastructure Platform.

Third-Party Links

The E1 Tech Finfrastructure Platform may refer to or may contain, links to third-party websites, applications, services and resources but it does not mean that we are endorsing such channels. We provide these links only as a convenience to the User to avail certain services, the Company makes no representation or warranty of any kind regarding the accuracy, reliability, effectiveness, or correctness of any aspect of any third-party services, and consequently, the Company is not responsible for the content, products or services that are available from third-party services. The User is responsible for reading and understanding the terms and conditions and privacy policy that applies to the User’s use of any third-party services, and the User acknowledges sole responsibility and assumes all risks arising from User’s use of any third-party services.

Intellectual Property Rights

All copyrights, patents, trade secrets, trademarks, service marks, trade names, moral rights and other intellectual property and proprietary rights (“IPR”) in the E1 Tech Finfrastructure Platform and Services shall remain the sole and exclusive property of E1 Tech Finfrastructure and its licensors, as applicable. The IPR may not be copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, uploaded, or otherwise exploited without the prior written consent of E1 Tech Finfrastructure.

Relationship:

You understand and agree that nothing contained in these Terms shall be deemed or construed as creating a partnership or joint venture between the User and E1 Tech Finfrastructure or deemed to cause any party to be responsible in any way for the debts and obligations of the other party.

You will not describe (whether online or otherwise) Yourself as agent or representative of E1 Tech Finfrastructure or make any representations to any User or any third party or give any warranties which may require E1 Tech Finfrastructure or Service Provider to undertake to or be liable for, whether directly or indirectly, any obligation and/or responsibility to the User or any third party.

Confidentiality

The User agrees not to disclose or attempt to use or personally benefit from any non-public information that it may learn or discover on the Website or through the Services. This obligation shall continue until such time as the non-public information has become publicly known through any action of the User. If the User is compelled by order of a court or other governmental or legal body (or have notice that such an order is being sought) to divulge any such non-public information, the User agrees to promptly and diligently notify E1 Tech Finfrastructure and cooperate fully with E1 Tech Finfrastructure in protecting such information to the extent possible under applicable law.

E1 Tech Finfrastructure may access, preserve and disclose any of User’s information if such information is required for the facilitation of any Services to the User as per the User’s request, or to ensure compliance with applicable law, or if We believe in good faith that it is reasonably necessary to (i) respond to claims asserted against E1 Tech Finfrastructure or to comply with legal process, (ii) for fraud prevention, risk investigation, User support, product development and de-bugging purposes, or (iii) protect the rights, property or safety of E1 Tech Finfrastructure, its Users or members of the public.

Disclaimer of Warranties & Limitation of Liability

In processing Transactions, E1 Tech Finfrastructure shall be entitled to rely upon all electronic communications, orders or messages sent to E1 Tech Finfrastructure through the Service Providers including and to the extent this is in compliance with the processing mechanism of the Service Providers and any applicable laws and the RBI Guidelines. E1 Tech Finfrastructure shall not be obligated to verify or make further inquiry into the identity of the sender, or the message integrity, of any communications, orders or messages.

E1 Tech Finfrastructure will endeavour to ensure that access to and availability of the Services remains uninterrupted and error free. However, access to the application may occasionally be suspended or restricted to allow for repairs, maintenance, or for the introduction of new facilities and Services and in such cases E1 Tech Finfrastructure shall not be liable for any disruption of any Services. We reserve the right to determine the timing and content of software updates, which may be automatically downloaded and installed by an application without prior notice to the User anytime.

The Services are provided on an as-is and as-available basis. E1 Tech Finfrastructure expressly disclaims all warranties of any kind, whether express or implied, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose. E1 Tech Finfrastructure makes no warranty that the Services will be uninterrupted, timely, secure, or error free. To the maximum extent permitted by law, the entire risk arising out of the User’s access of and use of the Website and Services, remains with the User. A separate limitation over liability shall be applicable to each of the Services.

E1 Tech Finfrastructure shall not be liable for any breach of these Terms due to any force-majeure event that prevents or delays performance of its obligations under these Terms such as lockdown, act of god, fire, lightning, explosion, flood, adverse weather conditions, power failures, failure in any communication systems, equipment breakdown, strikes, lock-out or any other cause beyond the control of E1 Tech Finfrastructure.

Indemnity

The User shall keep E1 Tech Finfrastructure indemnified from and against any and all liability (including but not limited to liabilities, judgments, damages, losses, claims, costs and expenses,) or any other loss that may occur, arising from or relating to any claim, suit or proceeding brought against E1 Tech Finfrastructure by another User/ Service Provider/ third party for reasons including, but not limited (i) a breach, non-performance, non- compliance or inadequate performance by the User of any of the terms, conditions, representations, obligations or warranties made by him; (ii) any acts, errors, misrepresentations, willful misconduct or negligence of the User, or his employees, subcontractors and agents in performance of their obligations under these Terms.

Communication Policy

As part of User’s use of the Services, User may receive notifications, offers, discounts and general information from E1 Tech Finfrastructure via text messages or by emails, for the purpose of collecting feedback regarding User’s services. The User understands that receipt of non-service-related communications can be deactivated from User Account settings or by sending an email to connect@E1high.com and by ab-initio consents to receive such communications. The User acknowledges that the SMS service provided by E1 Tech Finfrastructure is an additional facility provided for the User’s convenience and that it may be susceptible to error, omission and/ or inaccuracy.

Customer Complaints

If We receive any general complaint against the User in connection with the use of the E1 Tech Finfrastructure Platform, We will forward the complaint to User’s registered email address. The User must respond to the complaint directly within 36 (thirty-six) hours of receiving the complaint as forwarded by E1 Tech Finfrastructure and copy E1 Tech Finfrastructure in its communications. If the User does not respond to the complainant within 36 (thirty-six) hours from the date of E1 Tech Finfrastructure’s email to the User, We may at our sole discretion opt to disclose the User’s contact information to the complainant for enabling the complainant to take legal action against the User. The User understands that its failure to respond to the forwarded complaint within the 36 (thirty- six) hours’ time limit will be construed as the User’s consent to disclosure of the User’s name and contact information by E1 Tech Finfrastructure. Notwithstanding the foregoing, the User acknowledges and agrees that (a) E1 Tech Finfrastructure can disclose any information relating to the User if it deems in its sole discretion that such disclosure is required in the interest of justice; and (b) E1 Tech Finfrastructure can withhold or appropriate any settlements due to the Merchants to ensure compliance with applicable laws on reasonable suspicion.

It is understood that a Transaction is solely between the User and its Customer and E1 Tech Finfrastructure does not provide any guarantees or warranties, or delivery level commitment with respect to the User. Use of the E1 Tech Finfrastructure Platform by a User in no way represents any endorsement by E1 Tech Finfrastructure of any User. E1 Tech Finfrastructure will facilitate the mediation of any disputes between the User, Customer, and Payment Participant concerning the Service(s) offered by E1 Tech Finfrastructure through its platform.

Suspension and Termination

In the event (a) the User breaches these Terms; (b) the User engages in or is suspected of engaging in any illegal, fraudulent or abusive activity; or (c) the User provides any information that is untrue, inaccurate, not current or incomplete or We have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, or not in accordance with these Terms, E1 Tech Finfrastructure reserves the right, to suspend/terminate such User’s access to any or all of the E1 Tech Finfrastructure Platform and Services without notice, and this will be without prejudice to E1 Tech Finfrastructure’s right to exercise any other remedy available to it under applicable law.

In the event E1 Tech Finfrastructure identifies any suspicious or unusual activity being carried out by the User on the E1 Tech Finfrastructure Platform, E1 Tech Finfrastructure at its discretion may temporarily or permanently suspend the User’s access to the E1 Tech Finfrastructure Platform and/or take any such actions necessary to mitigate risk including but not limited to withholding of funds or refunding the funds to the source from where such payment originated.

Prohibited Services

The User acknowledges and agrees that the Services shall not be utilized in connection with or to enable/meet the objective(s) of, any Prohibited Services. The User's utilization of the Services is contingent upon the User refraining from the Prohibited Services as stipulated by the Service Providers specific to their offerings. If E1 Tech Finfrastructure reasonably suspects that the User is accessing/using the Services in connection with a Prohibited Service, the User agrees that E1 Tech Finfrastructure may take such action as it deems to mitigate the risk and/or likelihood of risk from the said Prohibited Service, including but not limited to, reporting the User, blocking the User’s funds and refunding the funds collected by the User to source.

Governing Law, Jurisdiction and Disputes

Without prejudice to the provisions mentioned below, these Terms are subject to the laws of India and any disputes arising out of or in connection with the Terms will be subject to the exclusive jurisdiction of the competent courts at Bengaluru, India.

E1 Tech Finfrastructure and the User acknowledge and agree that, in the event of any dispute/claim between arising out of or in connection with the Terms: (a) the transaction logs maintained by E1 Tech Finfrastructure will be the only source of data to verify the accuracy of such transactions; (b) such logs will be fully binding as evidence for the purposes of adjudicating the said dispute/claim; and (c) the said dispute/claim shall be settled by binding arbitration in accordance with the Arbitration and Conciliation (Amendment) Act, 1996 and the rules of the Conciliation and Arbitration Centre, Bengaluru as amended from time to time and the exclusive seat of arbitration shall be at Bengaluru, India.

If any part of these Terms is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations set forth herein, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the Terms shall continue in effect.

Customer Grievance Redressal

You may contact us with any enquiry, complaints or concerns by writing to the Grievance Officer at the coordinates mentioned below:

Grievance Officer - Premjith

E1 Tech Finfrastructure or 1M E1 Fintechnologies Private Limited

Bengaluru, Karnataka - 560010

E-mail: grievances@E1high.com

PART B

(Service Terms & Conditions)

The User represents and agrees that usage of the Services mentioned under this Part B will inherently subject the User to the General Terms governing use of the E1 Tech Finfrastructure Platform as set out under Part A.

E1 Tech Finfrastructure Pay

E1 Tech Finfrastructure Pay can be used to receive collections for any Transaction arising out of the normal course of business of the User.

By proceeding to use E1 Tech Finfrastructure Pay, the User (a) signifies its consent to be bound by these Terms; (b) will be contracting with E1 Tech Finfrastructure; and (c) acknowledges and agrees these Terms will constitute the User’s binding obligations, with E1 Tech Finfrastructure while using E1 Tech Finfrastructure Pay.

Eligibility

To use E1 Tech Finfrastructure Pay, You must: (i) be a tax resident of India; and (ii) be Admin Verified and registered to use E1 Tech Finfrastructure Pay on the E1 Tech Finfrastructure Platform.

Rights and Obligations:

No interest is payable by E1 Tech Finfrastructure on the amounts maintained by the User in E1 Tech Finfrastructure Pay.

A User is permitted to operate only 1 (one) E1 Tech Finfrastructure Pay account.

Any amounts collected by the User into E1 Tech Finfrastructure Pay using Payment Gateway Services (as defined below) will be subject to the provisions in these Terms governing Payment Gateway Services.

The availability of balance on E1 Tech Finfrastructure Pay to the User will be subject to receipt of funds into the Escrow Account and User’s continued compliance with these Terms and the RBI Guidelines at all times.

Subject to fulfilling the KYC requirements, the User may link its Business Current Account to its E1 Tech Finfrastructure Pay in order to settle Transaction proceeds in accordance with the RBI Guidelines. Once linked, the Transaction amount (minus Fees, as applicable) will be settled to the User’s Business Current Account from E1 Tech Finfrastructure Pay within T+1 days where ‘T’ is the date of Confirmation of Delivery by the User to E1 Tech Finfrastructure. The User shall be solely responsible for providing the updated and correct details of their Business Current Account so linked with the E1 Tech Finfrastructure Pay Account.

Notwithstanding anything, the User acknowledges and agrees that where E1 Tech Finfrastructure has no control over incoming funds and its delay thereof, E1 Tech Finfrastructure will transfer the funds to the merchant in accordance with the RBI Guidelines and the settlement clock of T +2 or as the case may be will commence only after fund realization in E1 Tech Finfrastructure's Escrow account.

In circumstances where as a User, you require E1 Tech Finfrastructure to settle the monies collected by E1 Tech Finfrastructure in the Escrow Account on your behalf to a third party, E1 Tech Finfrastructure will allow this feature and carry out the settlement solely based on your written instructions only if the following conditions and eligibility criteria are met:

You have an online presence with an annual turnover above ₹ 40,00,000/- (Rupees Forty Lakhs Only);

successfully completed full KYC process as per the policy of E1 Tech Finfrastructure

the third party is the payee that interfaces with the payer for purchase / delivery of goods, services or investment products, for the underlying transaction; and

You shall also be required to ensure that complete KYC records of the third party are maintained by you and made available to E1 Tech Finfrastructure upon request.

Usage:

The User authorizes E1 Tech Finfrastructure to rely on and act upon any instructions provided by the User in respect of its E1 Tech Finfrastructure Pay account and such instructions shall be conclusively presumed for E1 Tech Finfrastructure’s benefit to be duly authorized by and legally binding on the User.

The User will access and operate its E1 Tech Finfrastructure Pay account solely for the debits and credits permitted under the RBI Guidelines.

E1 Tech Finfrastructure shall be entitled to require any instruction/document in any form to be authenticated by the User of any password, identification code or authentication test as may be specified by E1 Tech Finfrastructure from time to time and the User shall ensure the secrecy and security of such password, code or test. All payments made by the User will be subject to the two-factor authentication system envisaged under the RBI Guidelines.

The User acknowledges that there are inherent risks involved in sending the instructions/communications/documents to E1 Tech Finfrastructure via electronic communications/instructions and accordingly agrees and confirms that all risks in this regard, shall be fully borne by the User.

Termination:

E1 Tech Finfrastructure reserves the right to suspend/discontinue E1 Tech Finfrastructure Pay for the User for any reason whatsoever. This includes the following grounds, based on suspicion or otherwise:

Violation of the RBI Guidelines;

Violation of any of these Terms;

Discrepancy in the information and KYC documentation provided by the User;

To prevent potential fraud, sabotage, willful destruction or threat to national security; or

Where E1 Tech Finfrastructure in its sole opinion and discretion believes that cessation/ suspension of the E1 Tech Finfrastructure Pay is necessary to meet the ends of justice.

Payment Gateway

The E1 Tech Finfrastructure Platform enables the User to accept payments from multiple Customer sources including credit/debit cards, net-banking, e-wallets and UPI (“Payment Gateway Services”) subject to continued compliance with these Terms.

Authorization:

The User understands that the Payment Gateway Services are provided on the E1 Tech Finfrastructure Platform by integrating with various Service Providers in order to provide a single solution for all payment acceptance.

The User authorizes E1 Tech Finfrastructure to hold, receive, disburse and settle funds on, the User’s behalf subject to these Terms. The User authorization permits E1 Tech Finfrastructure to generate an electronic funds transfer between the payment system providers and the Escrow Account to process each Transaction. The User acknowledges that its continued use of the Payment Gateway Services will be subject to its compliance with the RBI Guidelines. The authorizations provided hereunder by the User will remain in full force and effect until the User Account is closed or terminated in accordance with the provisions contained hereunder.

All risk, loss or liability associated with delivery undertaken by the User to its Customers will be solely and absolutely attributable the User. Also, all disputes regarding quality, merchantability, non-delivery, delay in delivery or otherwise will be directly handled between the User and the Customer without any reference to E1 Tech Finfrastructure as a party to such disputes.

Card Payment Network Rules:

The Card Payment Networks have provided the infrastructure and processes to enable Transaction authorization. The Card Payment Network requires the User to comply with the Card Payment Network Rules. The Card Payment Network reserves the right to amend their guidelines, rules and regulations. We may be required to amend modify or change these terms of use pursuant to amendments to the Card Payment Network Rules and such amendments, if any, shall be deemed to be binding on the Users with immediate effect.

Notwithstanding our assistance in understanding the Card Payment Network Rules, the User expressly acknowledges and agrees that the User is assuming the risk of compliance with all provisions of the Card Payment Network Rules, regardless of whether the User is aware of or have access to those provisions. RuPay, MasterCard, Visa and American Express make excerpts of their respective rules available on their internet sites.

In the event that, the User’s non-compliance of Card Payment Network Rules, results in any fines, penalties or other amounts being levied on or demanded of Us by a Card Payment Network, then without prejudice to Our other rights hereunder, the User shall forthwith reimburse Us in an amount equal to the fines, penalties or other amount so levied or demanded or spent by Us in any manner in relation to such fines, penalties and levies. If the User fails to comply with the User’s obligations towards the Card Payment Network, We may suspend settlement or suspend/terminate the Services or any part thereof forthwith or freeze and appropriate incoming funds to the User Account.

Settlement:

All Transactions settled to the User shall be subject to the Fees payable to E1 Tech Finfrastructure.

The availability of balance on E1 Tech Finfrastructure Pay to the User will be subject to receipt of funds into the Escrow Account and User’s continued compliance with the RBI Guidelines at all times.

Subject to fulfilling the KYC requirements, the User may link its Business Current Account to its E1 Tech Finfrastructure Pay in order to settle Transaction proceeds in accordance with the RBI Guidelines. Once linked, the Transaction amount (minus the Fees, as applicable) will be settled to the User’s Business Current Account from E1 Tech Finfrastructure Pay within T+1 days where ‘T’ is the date of Confirmation of Delivery by the User to E1 Tech Finfrastructure. The User shall be solely responsible for providing the updated and correct details of their Business Current Account so linked with the E1 Tech Finfrastructure Pay Account. Notwithstanding anything, the User acknowledges and agrees that where E1 Tech Finfrastructure has no control over incoming funds and its delay thereof, E1 Tech Finfrastructure will transfer the funds to the merchant in accordance with the RBI Guidelines.

If the User requests, E1 Tech Finfrastructure at its sole discretion may provide early settlement services with respect of the receivables of the User, to the E1 Tech Finfrastructure Pay account or Business Current Account, as applicable at such additional Fees that E1 Tech Finfrastructure informs to the User in writing.

The User understands and unconditionally acknowledges that even if the User is allowed to receive payment using E1 Tech Finfrastructure Pay, funds from such transactions will not be settled to the User’s E1 Tech Finfrastructure Pay / Business Current Account or any other account until KYC obligations are completed by the User in accordance with the RBI Guidelines. If the User continues to default on KYC obligations, as mentioned above, E1 Tech Finfrastructure at its sole and absolute discretion may refrain from releasing the settlement amounts to the User and accordingly reverse the funds to the source from where such payment originated.

Transaction Dispute:

The User shall adhere to the refund policy stipulated by the User’s website, as reviewed and approved by E1 Tech Finfrastructure (as applicable). The User agrees that transactions involving the Card Payment Networks may be disputed at any time up to 180 (one hundred eighty) days, from the date of transaction by the Customer as per the Card Payment Network Rules. Disputes resolved in favour of the Customer may result in reversal of payments to the Customers (“Chargeback”). In the event of rejection/suspension of payments to the User, Chargebacks, refunds and/or any other dispute relating to the Transactions contemplated under these Terms ("Transaction Dispute") on any grounds whatsoever, E1 Tech Finfrastructure will forthwith notify the User of the same.

On such notification the User will conduct an internal review of such matter and will, within the time frame prescribed by E1 Tech Finfrastructure in the notification, revert to Us in writing either:

Requesting Us to refund ("Refund Request") the payment received by the Customer in respect of such Transaction Dispute ("Refund Monies"); or

Providing Us with a statement explaining how the Disputed Transaction is not warranted, together with all documentary evidence in support of contesting such Transaction Dispute.

In the event that the User provides a Refund Request to Us or fails to contest such Transaction Dispute within the aforesaid timeframe prescribed by E1 Tech Finfrastructure or contests Transaction Dispute without providing supporting documentation to the satisfaction of E1 Tech Finfrastructure, the Service Provider and/or Card Payment Network and/ or issuing Bank, E1 Tech Finfrastructure will be entitled to recover the Refund Monies from settlements subsequently made to the User Account.

The User will be liable to make payment of the Refund Monies or part thereof which has not been returned to E1 Tech Finfrastructure forthwith. It is hereby agreed and acknowledged by the Parties that the Fees charged by E1 Tech Finfrastructure in respect of the Transaction Dispute will not be refunded, compensated or paid by us to the User, Customer or any other person. Further, the Chargeback will be effected within 1 (one) week of the Transaction and maximum amount of the Chargeback payable by us to the Customer will be the value of the transaction only.

The User also acknowledges and agrees that E1 Tech Finfrastructure may route the failed Chargeback/refund amounts back to the concerned customer outside the payment aggregator escrow account using payment mechanisms it deems fit, subject to ensuring compliance with applicable laws at all times.

Fees and Charges

The User acknowledges and agrees that the operation of the Payment Gateway Services includes the deduction of amounts owed for service fees and/or refund monies (if applicable) by the Service Provider offering Payment Gateway Services. Consequently, the amounts receivable by a User from a Customer for a Card Transaction will be reduced by the deducted fees and refunds.

Miscellaneous

In the event that the User acts in violation of applicable laws or breaches the Terms, the Service Provider offering Payment Gateway Services reserves the right to discontinue the availability of Payment Gateway Services to the User or take such other action as it deems fit in its sole discretion, without prior notice or intimation to the User.

The User acknowledges and agrees to prominently display on its website(s) any policies, notices, disclaimers, warranties, and indemnities as may be requested in writing by the Service Provider offering Payment Gateway Services, at its sole discretion, periodically. Failure to adhere to these requirements concerning the specified website may result in such Service Provider exercising its discretion to cease the provision of Payment Gateway Services to the User.

Should the User engage in Prohibited Services while utilizing the Services, the Service Provider offering Payment Gateway Services reserves the right, without prejudice to its other rights under the Terms, to instruct the User through E1 Tech Finfrastructure to promptly discontinue the Prohibited Services. Additionally, such Service Provider may impose fines for such violations as it deems appropriate, at its sole discretion. This action is independent of such Service Provider’s right to cease providing Services to the User if E1 Tech Finfrastructure has not terminated the User's access to the E1 Tech Finfrastructure Platform and Services.

The User acknowledges and agrees that the Service Provider offering Payment Gateway Services, during the User onboarding process and continuously thereafter, may request and acquire necessary details pertaining to the User. This includes but is not limited to, information regarding the User's turnover and any other details deemed essential by such Service Provider.

The User agrees to incorporate the following elements on its website: (a) privacy statements; (b) identifiers that clearly associate the User’s website with the User's trade name for easy recognition; and (c) the User will display a statement encouraging its Customers to retain a copy of the transaction record for their records.

Multi-Account Connect, Automated Accounting and Tax filing

Scope

This Service allows the User to track their Customer payments and transaction history across various banks under a unified dashboard (“Multi-Account Connect”) and equips the User with automatically generated book-keeping records and reports (“Automated Accounting”).

You note and agree that E1 Tech Finfrastructure is only acting as a technology aggregator for these purposes wherein the role of E1 Tech Finfrastructure is limited to the extent of providing the E1 Tech Finfrastructure Platform to You.

E1 Tech Finfrastructure has partnered with Service Providers who are authorized ERI and Application Service Providers (ASP) as per the Electronic Furnishing of Return of Income Scheme, 2007 and Goods and Services Tax Act, 2017 and may offer ERI Services and ASP Services in the near future. “ERI Services” include (i) income return filing and ancillary activities by adding you as a client on the Income Tax Department’s web portal to submit your Income-Tax Return (“ITR”), and retrieve information, such as your ITR-V, refund status, 26AS, etc.; (ii) easy filing of ITRs by automatically recognizing the data from the Form-16 uploaded by you; and (iii) manual filing of ITRs by allowing you to fill the requisite data in the ITR. “ASP Services” include taking the User’s raw data on sales and purchases and converting it into the GST returns (“GSTR”). These GSTRs will then be filed on behalf of the filer with GSTN via the GST Suvidha Provider. The User agrees to such terms stipulated by E1 Tech Finfrastructure and its Service Providers, from time to time, if the User undertakes ERI Services and ASP Services from the E1 Tech Finfrastructure Platform. The provision of the ERI services through the E1 Tech Finfrastructure Platform and display of such information received from the Service Provider shall not in any manner constitute any recommendation, advice, opinion or any service being given by E1 Tech Finfrastructure.

Exclusion of Liability

User understands, covenants and confirms that E1 Tech Finfrastructure shall not be liable in case any unauthorized or incorrect instruction is executed by the User or concerned Service Provider resulting in any wrongful amount being debited or credited from the User. Consequently, E1 Tech Finfrastructure expressly excludes any and all direct as well as indirect liability whatsoever which may arise in this regard.

Internet Frauds and Technology Risks

The internet is susceptible to a number of frauds, misuses, hacking and other actions, which could affect use of these Services. Whilst E1 Tech Finfrastructure shall aim to provide security to prevent the same, it does not guarantee the User complete protection from such internet frauds, hacking and other actions, which could affect the use of these Services. There can be instances where the Services may require maintenance and during such time it may not be possible to process the request of the Users. This could result in delays in the processing of requisite instruction or failure in processing of instructions. The User understands and acknowledges that E1 Tech Finfrastructure disclaims all and any liability, arising out of any failure or inability by E1 Tech Finfrastructure to honour any Customer instruction.

Collection of User Data

The information collected for performing these Services (“Data”) will be based on the details submitted by the User. The User must provide true, accurate, current and complete Data at all times, failing which, the output from this Data will tend to be false, inaccurate, redundant or incomplete.

Use of User's Data

The information collected may be used for personalizing the User’s experience and better Our responses to match the User’s requirements, wherever possible, improve the E1 Tech Finfrastructure Platform and/or application based on the information, their exact requirements, improving User experience based on feedback.

Request for Consent

The consent for the collection of Data and also for the subsequent use of the Data is deemed to be given by the User when the User decides to avail the Services.

Malicious Behavior

The E1 Tech Finfrastructure Platform shall not allow any party and/or entity that steal data, secretly monitor or harm Users, or are otherwise malicious. Therefore, the following are expressly prohibited:

viruses, trojan horses, malware, spyware or any other malicious software.

apps/ websites that link to or facilitate the distribution or installation of malicious software.

apps/ websites that introduce or exploit security vulnerabilities.

apps/ websites that steal User’s authentication information (such as usernames or passwords) or that mimic other apps or websites to trick Users into disclosing personal or authentication Data.

apps/ websites that install other apps on a device without the User’s prior consent.

apps/ websites designed to secretly collect device usage, such as commercial spyware apps.

E1 Tech Finfrastructure Credit

The terms and conditions hosted on the URL: https://E1high/tnc-E1TechFinfrastructurecredit (“E1 Tech Finfrastructure Credit Terms”) shall govern the credit and business loans facilities offered, by E1 Tech Finfrastructure’s partners banks/financial institutions regulated by RBI, on the E1 Tech Finfrastructure Platform as a part of the Services (hereinafter referred to as “E1 Tech Finfrastructure Credit”). By proceeding to use E1 Tech Finfrastructure Credit, the User signifies its consent to be bound by these E1 Tech Finfrastructure Credit Terms which shall be read in conjunction with these Terms and the Privacy Policy.

Business Connect

The terms and conditions hosted on the URL: https://E1 Tech Finfrastructure.money/tnc-E1 Tech Finfrastructurehub (“Business Connect Terms”) shall govern the marketplace offered on the E1 Tech Finfrastructure Platform as a part of the Services (hereinafter referred to as “Business Connect”). By proceeding to use Business Connect, the User signifies its consent to be bound by the Business Connect Terms which shall be read in conjunction with these Terms and Privacy Policy.

E1 Tech Finfrastructure Payroll

E1 Tech Finfrastructure offers the Users payroll management solutions on the E1 Tech Finfrastructure Platform (“E1 Tech Finfrastructure Payroll”). The terms and conditions hosted on the URL: https://E1 Tech Finfrastructure.money/tnc-E1 Tech Finfrastructurepayroll (“E1 Tech Finfrastructure Payroll Terms”) shall govern access and usage of E1 Tech Finfrastructure Payroll and any services provided thereunder. By proceeding to use E1 Tech Finfrastructure Payroll, the User signifies its consent to be bound by the E1 Tech Finfrastructure Payroll Terms which shall be read in conjunction with these Terms at all times.

AML / CFT Policy

1. Policy Statement & Commitment

At E1 Tech Finfrastructure , we are committed to the highest standards of compliance with all applicable laws and regulations relating to Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) .

We recognize that money laundering and terrorist financing pose significant threats to the integrity of the financial system, national security, and global economic stability. As a responsible fintech payment platform operating in India, we adhere to the Prevention of Money Laundering Act (PMLA), 2002, the rules framed thereunder, the Reserve Bank of India's (RBI) KYC Directions, and the global compliance standards expected by our payment partners including ICICI and SBI.

Our policy is designed to:

Prevent our platform from being exploited by criminals or malicious actors.

Comply with all regulatory obligations under Indian law and international sanctions frameworks.

Protect our customers, partners, and the broader financial ecosystem.

2. Scope & Applicability

This policy applies to:

E1 Tech Finfrastructure and all its subsidiaries.

All products and services offered on our platform.

All directors, officers, employees, contractors, and agents of E1 Tech Finfrastructure . This subject to regulatory oversight, and we are required to maintain effective controls proportionate to our risk exposure. We recognize that non-compliance with relevant laws could expose our company to civil and criminal liability, reputational damage, business restrictions, and other serious consequences.

Where differences exist between local Indian regulatory requirements and global policies, the stricter requirements shall be followed.

3. Legal & Regulatory Framework

Our AML/CFT compliance program is built upon the following key legal and regulatory frameworks:

We are committed to complying with all applicable AML, CFT, sanctions, and export control laws in every jurisdiction where we operate.

4. Our Financial Crimes Program

Our AML/CFT program is based on a Risk-Based Approach (RBA) and utilizes controls at both the user level and transaction level.

4.1 Customer Due Diligence (CDD) & KYC

We maintain robust Know Your Customer (KYC) standards and procedures, including:

Identification: We verify the identity of our customers using reliable, independent source documents, data, or information.

Verification: We conduct Video KYC (V-CIP) and Aadhaar-based authentication as permitted by the RBI.

Beneficial Ownership: For legal entities, we identify and verify the natural person who ultimately owns or controls the customer (25% ownership threshold for companies, 15% for partnerships/trusts).

Customer Risk Categorization: We classify customers into risk categories (Low, Medium, High) based on their profile, geography, transaction behavior, and nature of business.

4.2 Transaction Monitoring

We maintain continuous transaction monitoring systems designed to:

Detect suspicious or unusual patterns of activity.

Identify structuring (smurfing) or attempts to avoid reporting thresholds.

Flag transactions involving high-risk jurisdictions or sanctioned entities.

Monitor Non-Profit Organizations (NPOs) for potential terror financing risks.

4.3 Sanctions Screening

We conduct continuous screening of all customers and transactions against:

United Nations Security Council (UNSC) Sanctions Lists (1267/1989 Committee).

U.S. Office of Foreign Assets Control (OFAC) lists.

European Union, United Kingdom, and Canadian sanctions lists.

RBI's list of designated individuals/entities under UAPA, 1967.

Any match to a designated terrorist or sanctioned entity will result in immediate freezing of funds without prior notice to the customer, as required under Section 51A of the UAPA, 1967.

4.4 Prohibited Jurisdictions & Activities

We do not support businesses or transactions directly or indirectly involving :

Jurisdictions classified as high-risk: Cuba, Iran, North Korea, Syria, and the regions of Crimea, Donetsk, and Luhansk.

Restricted Persons: Individuals or entities appearing on any sanctions list maintained by the UN, US, UK, EU, or Canada.

Prohibited Goods & Services: Any trade involving goods prohibited by law (e.g., luxury goods) with Russia or Belarus, or the export of certain professional services to Russia.

E1 Tech Finfrastructure reserves the right to decline services to any individual, entity, or jurisdiction deemed high-risk, even if such activity is not explicitly prohibited by local law.

5. Reporting Obligations

We are registered as a Reporting Entity under the PMLA, 2002, and adhere to all reporting requirements to the Financial Intelligence Unit-India (FIU-IND) .

Confidentiality: All information furnished to FIU-IND is strictly confidential. "Tipping-off" (informing a customer that they are being reported) is a criminal offense under PMLA.

6. Politically Exposed Persons (PEPs)

If a customer is identified as a Politically Exposed Person (PEP) — a current or former senior foreign or domestic public official, their family members, or close associates — we will:

Obtain senior management approval before establishing or continuing the business relationship.

Conduct Enhanced Due Diligence (EDD) , including establishing the source of funds and source of wealth.

Implement enhanced ongoing monitoring on the relationship.

7. Record Keeping

We maintain all records (transaction data, CDD documents, account files, STR evidence) for a minimum period of:

5 years from the date of transaction; OR

5 years after the business relationship ends (whichever is later), as required under Section 12 of PMLA.

Records are stored securely with restricted access to authorized personnel only.

8. Employee Training & Awareness

All employees of [Your Company Name] must complete mandatory AML/CFT training:

Induction Training: For all new hires covering PMLA obligations, KYC norms, and red flag indicators.

Annual Refresher: Updates on regulatory changes, emerging typologies, and case studies.

Specialized Training: For compliance and risk teams on advanced transaction monitoring and STR filing.

Employees are protected from retaliation for reporting suspicious activity in good faith.

9. Role of Principal Officer

We have designated a Principal Officer as required under Rule 2 of the PML Rules. The Principal Officer is:

An officer at the managerial level (Head of Compliance/Risk).

The central point of contact with law enforcement agencies (FIU-IND, Police, Enforcement Directorate).

Responsible for receiving and reporting Suspicious Transaction Reports (STRs).

Contact for AML/CFT inquiries: compliance@e1high.com

10. Policy Review & Updates

This policy is effective immediately and will be reviewed:

Annually by the Compliance Department.

Upon any material change in Indian regulations (PMLA/RBI updates) or partner requirements (ICICI/SBI policy changes).

Following any enforcement action or regulatory finding.

We reserve the right to amend this policy without prior notice to customers; however, updated versions will be posted on this page with a new effective date.

11. Comprehensive declarations

Security & Data Protection Clause

1. Banking-Grade Security Commitment

We at M/s 1M Global Business Services Private Limited[Company Name] ("the Company," "we," "us") is committed to protecting the confidentiality, integrity, and availability of all client data, financial transactions, and digital assets. We implement and maintain security measures that meet or exceed the standards required of licensed banking and financial institutions globally.

2. Regulatory & Compliance Frameworks

Our security infrastructure is designed in alignment with the following internationally recognized standards and regulatory frameworks:

PCI-DSS Level 1: All payment card data is processed, stored, and transmitted in strict compliance with the Payment Card Industry Data Security Standard (PCI-DSS) Level 1, the highest level of certification available in the payments industry.

ISO/IEC 27001 & 27017: Our Information Security Management System (ISMS) is architected in accordance with ISO/IEC 27001 (Information Security Management) and ISO/IEC 27017 (Cloud Security Controls).

SOC 2 Type II: Our operational processes, system availability, processing integrity, confidentiality, and privacy are subject to independent third-party audits under the Service Organization Control (SOC) 2 Type II framework.

GDPR & DPDP Compliance: We adhere to the General Data Protection Regulation (GDPR) and the Digital Personal Data Protection Act (DPDP), ensuring lawful processing, data minimization, and the protection of personal data for all users.

FIPS 140-2 Level 3: Cryptographic key generation, storage, and management are secured using Hardware Security Modules (HSMs) certified to FIPS 140-2 Level 3 standards.

3. Encryption & Data Protection

Data in Transit: All data transmitted between users, servers, and third-party financial institutions is encrypted using Transport Layer Security (TLS) 1.3 or higher protocols. No sensitive data is transmitted over unencrypted channels.

Data at Rest: All sensitive client data, transaction records, and digital asset metadata are encrypted at rest using AES-256 (Advanced Encryption Standard) or equivalent military-grade encryption algorithms.

Key Management: Cryptographic keys are generated, stored, and rotated using secure Hardware Security Modules (HSMs). Private keys controlling digital assets are never stored in plaintext, on hot servers, or in a single geographic location.

4. Digital Asset & Wallet Security

For clients utilizing our digital asset custody, wallet infrastructure, and programmable asset services, we implement the following additional safeguards:

Multi-Party Computation (MPC): Private keys are fragmented using Multi-Party Computation protocols. No single entity, server, or employee has access to a complete private key. Transactions require collaborative cryptographic signing across multiple secure nodes.

Deep Cold Storage: The majority of client digital assets are held in air-gapped, geographically distributed cold storage facilities. Physical access to these facilities requires multi-factor biometric authentication and is restricted to authorized personnel only.

Programmable Security Rules: Where applicable, digital assets are secured using programmable smart contract logic, including transaction time-locks, address whitelisting, and multi-signature authorization requirements at the asset layer, rendering unauthorized access mathematically ineffective.

Regular Penetration Testing: Our wallet infrastructure, cross-chain bridges, and smart contracts undergo regular, independent penetration testing and security audits by reputable third-party blockchain security firms.

5. Access Control & Monitoring

Principle of Least Privilege: Employee and system access to sensitive data and infrastructure is granted on a strict need-to-know basis. All access rights are reviewed and recertified quarterly.

Multi-Factor Authentication (MFA): MFA is mandatory for all internal systems, administrative panels, and client-facing account access.

24/7 Security Operations Center (SOC): Our infrastructure is monitored continuously by a dedicated Security Operations Center using AI-driven anomaly detection, intrusion detection systems (IDS), and intrusion prevention systems (IPS).

Immutable Audit Logs: All administrative actions, transaction events, and system changes are recorded in tamper-evident, immutable audit logs to ensure full traceability and accountability.

6. Business Continuity & Disaster Recovery

Redundancy: All critical systems are deployed across multiple, geographically separated data centers to ensure zero single points of failure.

Disaster Recovery: We maintain a comprehensive Disaster Recovery Plan (DRP) with a Recovery Time Objective (RTO) of less than [X] hours and a Recovery Point Objective (RPO) of less than [X] minutes for critical financial and operational data.

Regular Testing: Disaster recovery and incident response plans are tested, reviewed, and updated at least annually.

7. Incident Response & Notification

In the unlikely event of a security breach or data incident that may affect client data or digital assets, the Company will:

Immediately activate its Incident Response Plan to contain, investigate, and remediate the breach.

Notify affected clients and relevant regulatory authorities within the timeframes mandated by applicable law (e.g., within 72 hours under GDPR).

Provide transparent communication regarding the nature of the incident, the data affected, and the steps being taken to resolve the issue.

8. Limitation of Liability & Shared Responsibility

While the Company undertakes all commercially reasonable and industry-standard measures to secure client data and digital assets, clients acknowledge that:

Credential Security: Clients are responsible for maintaining the confidentiality of their own login credentials, API keys, and multi-factor authentication devices. The Company shall not be liable for losses resulting from a client's failure to protect their own access credentials.

Blockchain Irreversibility: Transactions executed on public or private blockchain networks are immutable. Once a transaction is confirmed on the ledger, it cannot be reversed, frozen, or recovered by the Company. Clients are solely responsible for verifying wallet addresses and transaction details prior to execution.

Standardization: Our systems are bi quarterly audited under STQC Directorate and maintains standard compatibility and adherence to ISO/IEC 27001 by undergoing bi quarterly vulnerability assessments.

Programmable Asset Rules: For programmable digital assets, clients are responsible for correctly configuring and reviewing their own security rules (e.g., whitelists, time-locks, multi-signature thresholds) prior to deployment. The Company provides the infrastructure but does not assume liability for losses resulting from client-configured smart contract logic.

Force Majeure: The Company shall not be directly or indirectly liable for security failures or service interruptions caused by events beyond its reasonable control, including but not limited to natural disasters, acts and results of war, government sanctions, or global internet infrastructure failures.

9. ISO 20022 Compliance & Interoperability Clause

9.1. Commitment to Global Financial Messaging Standards

[Company Name] ("the Company," "we," "us," "our") is committed to building institutional-grade infrastructure that seamlessly bridges decentralized networks, Central Bank Digital Currencies (CBDCs), and traditional global finance. To ensure maximum interoperability, transparency, and straight-through processing (STP), our payment orchestration engines, settlement layers, and cross-chain data protocols are architected in alignment with the ISO 20022 international standard for electronic data interchange.

9.2. Structured Data & Message Formats

Our platform utilizes structured, data-rich messaging formats (including ISO 20022 XML and JSON) to facilitate the exchange of financial information between our infrastructure and external financial institutions. Depending on the service utilized, our systems are designed to generate, parse, and transmit standard ISO 20022 message types, including but not limited to:

pain.001 (Customer Credit Transfer Initiation): For corporate payment initiation and automated fiat on/off-ramp routing via our Chainpay Gateway.

pacs.008 (Financial Institution to Financial Institution Customer Credit Transfer): For high-value, interbank, and wholesale CBDC (wCBDC) settlement routing.

camt.052 / camt.053 (Bank to Customer Account Report/Statement): For real-time reconciliation, providing clients with structured, end-of-day, or intraday ledger reports that integrate directly with core banking and ERP systems (e.g., SAP, Oracle, Finacle).

9.3. Straight-Through Processing (STP) & Reconciliation

By utilizing ISO 20022 data envelopes, our infrastructure ensures that payment instructions, remittance data, purpose codes, and ultimate beneficiary details travel alongside the transaction value. This enables automated, straight-through processing (STP), significantly reducing manual intervention, minimizing reconciliation errors, and accelerating settlement times across both fiat and blockchain rails.

9.4. Enhanced Compliance & AML Screening

We recognize that structured data is critical for modern financial compliance. Our ISO 20022-compliant payloads are designed to carry comprehensive originator and beneficiary information. This allows for highly accurate, automated Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and international sanctions screening in real-time, without delaying the finality of the underlying asset transfer or smart contract execution.

9.5. Interoperability with Legacy and Central Bank Networks

As the global financial system undergoes migration to ISO 20022, our platform is designed to act as a translation and routing layer between heterogeneous systems. Our architecture supports interoperability with:

The SWIFT Network: Facilitating the transition from legacy MT (unstructured text) messages to MX (ISO 20022) structured messaging.

Central Bank Settlement Systems: Ensuring compatibility with national Real-Time Gross Settlement (RTGS) systems, including but not limited to the Reserve Bank of India (RBI) SFMS/NEFT/RTGS networks, the Bank of Japan (BOJ-NET), and other major central bank infrastructures.

Datachain Interoperability Protocols: Wrapping cross-chain smart contract events in ISO 20022 data envelopes to ensure that value moving between disparate ledgers (e.g., Hyperledger Fabric, Corda, public chains) maintains institutional-grade data integrity and auditability.

9.6. Limitation of Liability & Third-Party Network Dependencies

While the Company employs commercially reasonable efforts to maintain ISO 20022 compliance, Clients acknowledge and agree that:

Third-Party Bank Rejection: The Company is not liable for transaction delays, failures, or rejections caused by a receiving bank, intermediary bank, or Central Bank failing to correctly parse, accept, or process ISO 20022 messages due to their own legacy system limitations or configuration errors.

Standard Evolution: The ISO 20022 standard is maintained by the ISO 20022 Registration Authority (RA) and is subject to continuous updates, versioning changes, and regional implementation guidelines (e.g., HVPS+ for high-value payments). The Company reserves the right to update its APIs and message schemas to comply with new standard versions. We will provide reasonable notice of any breaking changes, but we shall not be held liable for service interruptions required to maintain compliance with evolving global standards.

Data Accuracy: Clients are solely responsible for ensuring the accuracy, completeness, and legality of the data fields (including remittance information, tax details, and purpose codes) they input into the Chainpay Gateway or sovereign currency infrastructure prior to the generation of the ISO 20022 message.

9.7. Continuous Certification & Auditing

The Company actively monitors updates from the ISO 20022 Registration Authority, SWIFT, and regional Central Banks. Where applicable, our integration partners and payment processors undergo regular compliance testing to ensure ongoing adherence to global messaging standards.

10. Third-Party Services

Our platform may integrate with third-party services, including but not limited to payment processors, blockchain networks, cloud infrastructure providers, and identity verification vendors. While we conduct rigorous security due diligence on all third-party partners, the Company is not responsible for the security practices or data handling policies of these external providers. Clients are encouraged to review the security policies of any third-party services integrated with their account.

11. Updates to This Security Policy

The Company reserves the right to update, modify, or enhance this Security Clause at any time to reflect changes in our security infrastructure, regulatory requirements, or industry best practices. Material changes will be communicated to clients via email or a prominent notice on our website at least [30] days prior to taking effect. Continued use of our services following the effective date of any changes constitutes acceptance of the updated Security Policy.