Acceptable Use and Restricted Businesses

1. Purpose and scope

StarPago, a payment acceptance brand of AIDeeGroup provided by Star Pay Tecnología, S.A. de C.V., helps businesses collect payments, make payouts and settle funds across Latin America and Asia. To keep our services safe for merchants, end users, our banking and payment partners, and the communities we serve, we only work with legitimate businesses that operate lawfully and transparently.

This Acceptable Use and Restricted Businesses Policy ("Policy") explains which businesses and activities we do not support ("prohibited"), which ones we support only with additional licences and our separate written approval ("restricted"), what we expect of merchants in relation to their own customers and partners, and what happens if this Policy is breached. It forms part of our Terms and of every merchant agreement.

"StarPago", "we" and "us" refer to Star Pay Tecnología, S.A. de C.V. and its affiliates that provide the services. "You" refers to the merchant and anyone acting on its behalf.

2. How we apply this Policy

• Every product is reviewed. We review each website, app, product and business model before it can use our services. Approval of one product does not extend to another product, brand, domain or business line.
• Substance over labels. We look at what a business actually does, not at how it describes itself. A business that is presented as something else but in practice carries out a prohibited activity is prohibited.
• Market by market. Something that is lawful in one country may be unlawful or require a licence in another. We assess each market separately, and approval in one market does not mean approval in others.
• Partner and scheme rules. Our banks, payment partners, card networks and local schemes have their own rules. They may prohibit or restrict businesses beyond this list, and we will apply those rules.
• Ongoing monitoring. Our review continues after onboarding. We monitor transactions, websites and public information, and may ask for information at any time.

The lists below are examples and are not exhaustive. If you are unsure whether your business is allowed, ask us before you start processing.

3. Prohibited businesses and activities

You must not use StarPago services, directly or indirectly, for any of the following.

3.1 Illegal activity and financial crime

• Any activity that is illegal in the country of the merchant, the end user or the payment method used, or that facilitates such activity.
• Money laundering, terrorist financing, sanctions evasion, or transactions involving sanctioned persons, entities or territories.
• Proceeds of crime, or transactions designed to disguise the source, destination or purpose of funds.
• Bribery, corruption and tax evasion schemes.

3.2 Fraud and deception

• Fraud of any kind, including romance and relationship investment fraud (sometimes called "pig butchering" scams), impersonation, fake shops, fake charities, advance fee schemes and phishing.
• Card fraud, unauthorised use of payment credentials, account takeover, card testing and any use of stolen or compromised payment information.
• Selling goods or services that do not exist, that are not delivered, or that are materially different from what is advertised.
• Deceptive marketing, hidden fees, unclear subscription or billing terms, or practices designed to prevent customers from cancelling or obtaining refunds.

3.3 Ponzi, pyramid and "earn online" schemes

• Ponzi schemes, pyramid schemes, fund pools and any arrangement where returns to earlier participants are paid from money contributed by later participants.
• Investment programmes that promise guaranteed, fixed or unrealistically high returns.
• Task-based or "click to earn" schemes, paid liking, fake reviews, order brushing, fake engagement, and similar arrangements where people pay to join or to unlock tasks in return for promised earnings.
• Multi-level marketing where income depends mainly on recruitment rather than on genuine sales to end customers.

3.4 Unlicensed lending and disguised credit

• Cash loans, payday loans, instalment plans and other consumer lending offered by lenders that do not hold the lending licence required in the relevant market.
• Disguised lending, including rental, pawn, salary advance or membership models that in practice function as an unlicensed loan, upfront fees charged before a loan is granted, and the collection of repayments for such arrangements.
• Debt collection on behalf of unlicensed lenders, and debt reduction or credit repair services that charge fees in advance.

3.5 Misuse of our services

• Processing transactions for any product, website, app or business line that we have not reviewed and approved, or that you have materially changed without telling us.
• Letting another business use your account, credentials or integration, acting as an undisclosed aggregator or payment facilitator, or "renting out" your payment channel.
• Using another business's account or channel to process your own transactions, or mixing your transactions with another merchant's.
• Splitting transactions to avoid limits, using false descriptors, or providing false information about end users, products or transaction purposes.
• Moving funds that are not payment for genuine goods or services, including peer-to-peer transfers, cash-out services, or using collections and payouts to move money between unrelated parties.

3.6 Harmful goods and content

• Illegal drugs, drug paraphernalia, and prescription medicines sold without the required authorisation.
• Weapons, ammunition, explosives and their components, where sold in breach of the law or without required licences.
• Counterfeit goods, and goods or content that infringe intellectual property rights.
• Content involving the sexual exploitation of children, non-consensual intimate content, human trafficking or forced labour.
• Content that promotes violence, terrorism or hatred against people based on protected characteristics.
• Stolen goods, personal data sold without a lawful basis, and tools intended for hacking or unauthorised access.

4. Restricted businesses

The businesses below are regulated in many of our markets. We consider them only if you hold every licence, registration or authorisation required in each market where you operate and where your end users are located, and only after we have given our separate written approval. Approval may include specific conditions, such as limits on markets, payment methods or volumes, enhanced monitoring, additional reserves, or periodic re-certification of licences.

Holding a licence does not by itself entitle a business to use our services. We may decline a restricted business for any reason consistent with our risk policies and partner requirements, and we may withdraw approval if a licence lapses or conditions are not met. You must tell us immediately if any required licence is suspended, revoked, restricted or not renewed.

5. Your responsibility for your customers and partners

You are responsible for how your business, and anyone acting for you, uses our services. In particular, you must:

• Know your end users to the extent required by the law that applies to your business and by your licence conditions, and keep records that allow you to respond to our requests about specific transactions.
• Control your sellers, agents and affiliates. If you operate a marketplace or platform, or use agents, resellers or affiliates, you must have been approved to do so, must screen and monitor them, and must ensure that they comply with this Policy. A breach by them is treated as a breach by you.
• Market responsibly. Your advertising, including advertising by affiliates and influencers acting for you, must be lawful, accurate and not misleading, and must not target minors or vulnerable people for age-restricted or regulated products.
• Protect end users. Display clear terms, prices, contact details and refund policies, honour valid refund requests, and handle complaints promptly.
• Respect payment method rules. Use each payment method only for the purposes allowed by its operator, and do not ask end users to describe payments falsely.
• Report concerns. Tell us promptly if you become aware of fraud, a data breach, misuse of your account, or any activity that may breach this Policy.

6. What happens if this Policy is breached

If we reasonably believe that you have breached this Policy, or that your activity creates an unacceptable risk for end users, partners or StarPago, we may take one or more of the following actions, as permitted by law and your merchant agreement:

• ask for information or corrective action within a set time;
• decline, delay, reverse or refund individual transactions;
• apply or lower transaction limits, or restrict particular payment methods or markets;
• suspend the affected product, website or account;
• hold funds or increase your reserve to cover disputes, refunds, fines and other liabilities, and deduct those amounts from your balance;
• pass on any fines, penalties or assessments imposed by partners, schemes or authorities as a result of your activity;
• terminate your merchant agreement, in some cases with immediate effect;
• report the activity to banks, payment partners, schemes, financial intelligence units, regulators or law enforcement, where required or permitted by law.

After termination, we will settle any remaining balance once pending transactions, disputes and other liabilities have been resolved, as described in our Terms, unless an authority directs otherwise. Where we are legally prohibited from telling you about a report or investigation, we will not do so.

7. Changes and questions

We may update this Policy to reflect changes in the law, partner or scheme rules, or our risk assessment. We will notify merchants of material changes by email or through the dashboard. If a change affects a business we have already approved, we will discuss with you a reasonable period to adapt, unless the change is required immediately by law, a partner or a scheme.

If you have questions about whether your business is allowed, or wish to report suspected misuse of our services, contact us at [compliance@...].