This Website is created and operated by M/s Curvelogics Advanced Technology Solutions Private Limited, having its registered address at “2nd Floor, Asiatic Business Center, Kulathur, Trivandrum, Kerala 695586” represented by its Director, hereinafter referred to as the “Company” (where such expression shall unless repugnant to the context thereof, be deemed to include its representatives, administrators, permitted assigns).
This legal agreement is an electronic record in terms of Indian Information Technology Act, 2000 and rules thereunder as applicable and the amended provisions about electronic records in various statutes as amended by the Indian Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
This legal document is published in accordance with the provisions of Rule 3 (1) of the Indian Information Technology (Intermediaries guidelines) Rules, 2011 and Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008 that require publishing the Terms of Services and practices for access or usage
The Company shall comply with the requirements contained in the local Acts on Prevention of Money Laundering and Terrorism Financing, as well as the requirements of other laws and regulations to the extent in which they relate to the Company’s operations.
The Company shall strictly adhere to the policies and procedures outlined in this Know Your Customer Policy (hereinafter referred to as the “Policy”).
The Company has developed this Policy and may introduce amendments and additions to it at its own discretion, and will oversee compliance with its provisions and requirements.
Customer Identification Policy: For the purposes of Customers’ identification, the Company will request the following information and documents from:
- Phone Number
- Email Id
Documentation to be collected from Individuals:
- PAN Card
- Copy of address proof (Driving License/Voter Id/ Aadhar Card/Passport)
- Cancelled cheque of the bank account (original), IFSC Code
From Company and LLP (Information):
- Company/LLP Name:
- Date of Incorporation
- Registered Address
- Company/LLP Status:
- Director/Partner Signatory Details
Documentation to be collected from Company and LLP:
- Authorisation Letter for the Signing Authority duly signed and stamped by at least two Directors / Trustee /Members on the company letterhead
- Copy of Pan Card of the Authorized signatory
- Copy of Address Proof of the Authorized signatory (Driving License/ Voter ID/ Aadhaar Card/ Passport)
- Copy of Company’s PAN Card
- Board Resolution / Authorisation Letter for the Signing Authority duly signed and stamped by at least two Directors / Trustee /Members on the company letterhead
- Copy of Company’s Govt. proof of the firm (Certificate of incorporation mandatory for Private Limited and Public Limited)
Documentation to be collected from Society and Trust:
- Society Registration Certificate for filing status as society
- Trust Act Certificate issued from Government for Trust
- Copy of Form 18, if there is any change in address of the entity
‘Know Your Customer’ Verification Procedures: The Company conducts the Know Your Customer (KYC) verification procedures to avoid the risk of being held liable and to protect itself from a Customer’s attempt to use the Company for carrying out illegal activities. As part of the KYC procedures, the Company evaluates Customers’ transactions, as well as collects and stores information on the essential facts pertaining to Customers, potential customers, and their transactions. After carrying out the identification procedures pertaining to a Customer, the Company stores the information presented in this Customer’s file. The Company is under obligation to carry out the identification procedures pertaining to a Customer once. The Company is committed to protecting Customers’ rights and the confidentiality of their data. The Company collects personal information from Customers only to the extent necessary to ensure the Company is properly providing services to Customers. Such personal information about Customers and former Customers may be disclosed to third parties only in a limited number of circumstances, in accordance with the applicable laws and agreements between the Company and the Customer. The Company shall carefully maintain Customers’ files, including statements, transaction reports, receipts, notes, internal correspondence, and any other documents related to the customer in electronic format for as long as may be required by the underwriting teams at the relevant acquiring banks/processors that the Customer makes use of.
Identification and Detection of Suspicious Activities: Any financial transaction that may be related to money laundering activities shall be considered to be suspicious activities.Grounds for determining that a specific transaction is suspicious may be personal observations and experience of the Company’s employees, as well as the information received or identified. The Merchant Services Officer shall continuously monitor and update the systems used by the Company to detect suspicious activities. In accordance with the applicable laws and the requirements of international organizations, the Company may, where appropriate and without the obligation of obtaining the Customer’s approval or notifying the Customer, notify regulating and/or law enforcement agencies of any suspicious transactions. The Company shall periodically refer to and consult the lists published by the local authorities and international organizations that contain lists of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subject to the OFAC sanctions, jurisdictions that do not provide sufficient level of anti-money laundering procedures, as well as countries subject to sanctions to determine whether the Company’s Customer or potential Customer and/or such Customer’s country of jurisdiction is included in the above lists. The Company shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions’ compatibility with the Company’s knowledge of its customers, their business and, when necessary, their source of funds.
Third Parties: To perform some of its business functions, the Company may use third-party service providers. The Company shall make an effort to determine, during the initial and ongoing due diligence process, to the extent possible whether there are any initiated investigations and filed lawsuits against any such third-party service providers. The Company shall also determine whether a third-party provider has obtained all the necessary licenses, permits, and approvals before establishing a business relationship with such third-party service provider. Concerning its staff, the Company shall carefully review all candidates for employment and determine whether the activities of a new employee fall in the category that is susceptible to money laundering activities. Besides, the Company has prepared and implements a number of personnel training programs on customer identification procedures and prevention of money laundering activities.
Civil and Criminal Penalties: Government authorities of different countries and, in some cases, international organizations, may impose severe civil and criminal penalties against any person that violates the laws and regulations of the Policy. Such civil and criminal legal penalties may include fines in the amount of up to hundreds of thousands or even millions of dollars, and the term of criminal punishment may be several years in prison. Besides, government authorities may confiscate any property involved in criminal violation of these laws and regulations, including companies, bank accounts, or any other assets that may be associated with criminal violations.Under certain circumstances, companies may be deemed criminally responsible for the actions of their employees. In this regard, the employees of our Corporate Customers need to have adequate knowledge in this sphere; it is also important that such Corporate Customers should ensure the compliance of their employees’ actions with the said laws and regulations.
Compliance Statement: The Corporate Customer ( or the Corporate Customer’s authorized employee) certifies that they have read and understood this Policy and that they (or their Company) shall operate in full compliance with the requirements and standards outlined in the Policy and comply with all applicable laws and other regulations and requirements governing its activities as a Corporate Customer. The Corporate Customer (the Corporate Customer’s authorized employee) acknowledges that they are responsible for their actions in accordance with the effective laws in the field discussed in this Policy and shall bear responsibility pertaining to failure to comply with such laws.