Awlencan Innovations Malta Limited [C-88318], a Maltese Registered Company with Office Address situated at: 48, Triq Stella Maris, Sliema, SLM 1765, Malta, which owns and operates the ‘Zebpay’ VFA Exchange Platform in Malta, hereinafter referred to as ‘Awlencan’ or ‘Zebpay’ or “company”, which term shall refer to and include its owners, its subsidiaries and affiliated companies, directors, investors, employees, officers, representatives, affiliates, or other related parties.
In order to prevent misuse of the Zebpay Platform, Users are required to strictly comply with the terms contained herein, which forms part and parcel of the User Terms of Service. Terms not defined herein shall carry the same interpretation, as in the User Agreement and in the absence thereof to general usage and parlance.
“User” or “Client” Persons availing of the Zebpay Services (as defined below), directly or indirectly, are referred to herein, as “Users”.
1. Opening of User Account
- A user may create a User Account by first downloading and installing the Zebpay App on their Android or iPhone smartphone by using the Google Play Store or iOS App Store, as applicable, subject to the terms contained herein.
- User shall comply with the procedures prescribed for opening the User Account, including providing a valid and existing email address and mobile number for completing the registration process and shall provide requisite know your customer (KYC) details and documents.
- Zebpay reserves the right to reject registration or validation of a User Account on any grounds as it deems suitable, at its sole discretion, with due regard to legal and regulatory frameworks governing cryptocurrencies.
2. Know Your Customer (KYC) Compliance
In addition to the terms contained herein, Users shall be bound by the terms of Zebpay’s Anti-Money Laundering Policy (“AML Policy”), which is available at AML policy. By virtue of using any part of the Zebpay’s Services, and/or by virtue of accepting and entering into this Agreement, Users are deemed to have accepted and to have agreed to comply at all times with, the terms of the AML Policy. Only Users complying with the following Know Your Customers (“KYC”) procedures, as well as all terms and procedures contained in the AML Policy, would be allowed to avail of the Zebpay’s Services:
- Users shall provide the details, along with digitised copies of supporting documents for such details, simultaneously with the application for a User Account on the Zebpay Platform, failing which the User Account shall not be activated.
- User hereby consents to retention of the above details and documents by Zebpay for its own use, for as long as Zebpay is required under any prevailing laws. Zebpay shall be entitled to retain user details and documents even for of those Users whose registration has been rejected by Zebpay.
3. Verification Process
- Zebpay shall, at its sole discretion activate the User Account upon verification of the details provided through the KYC process included in this Agreement and in the AML Policy. In the event of any factual inaccuracies or discrepancies with the details or documentation provided by a User during this process, Zebpay shall be entitled to terminate the User Account without notice to the concerned User, and such User shall not be permitted to use the User Account or Zebpay Services thereafter. Zebpay is entitled to terminate User Accounts for non–compliance in providing true and correct information.
- Existing Users may be called upon to comply with additional KYC and / or verification process as intimated by Zebpay from time to time.In the event of the User failing to provide additional KYC or comply with the verification process, Zebpay reserves the right to terminate or deactivate an existing User Account. Users shall be duly intimated by Zebpay, along with reasons for such deactivation and the procedures for redress (if any). Delay in termination of such User Accounts shall not amount to a waiver of the mandatory information and documentary requirements contained in this Agreement and in the AML Policy.
- Zebpay may, at its sole discretion, intimate the user of reasons for non-activation their account. Zebpay is not under any obligation, however, to provide such intimation.
- Only natural or legal persons may apply for a User Account and avail of Zebpay’s services.Natural persons must possess a valid passport as proof of identity and a national ID or driving license as proof of address. Legal persons must have valid documents of incorporation and other documents as Zebpay may require from time to time. Upon verification, if any of the documents, information, or representations are found to be falsified, invalid or otherwise inaccurate, Zebpay is entitled to terminate the User Account for non–compliance in providing true and correct information.
- In case of corporates, the antecedents of the company (name and registered office in particular) and of all promoters and directors will be verified by Zebpay or any other third party engaged by Zebpay. An assessment shall be made of the financial worthiness of the user by obtaining appropriate declarations as and when required.
- No users shall be accepted where it is not possible to ascertain the identity of the client, or the information provided is suspected to be false or if there is perceived non-cooperation of the user in providing full and complete information. Zebpay shall not continue to do business with such a person and file a suspicious activity report.
- Zebpay may, if so required under applicable Law, file know-your-customer and transaction records with any law enforcement authorities
Know Your Customer Standards– The objective of the KYC guidelines is to prevent the Zebpay Platform from being used, intentionally or unintentionally, by criminal elements for money laundering activities. KYC procedures enable Zebpay to know / understand their customers and their financial dealings better which in turn help them manage their risks prudently. Zebpay’s KYC policy incorporates the following elements:
- Customer Acceptance Policy (CAP)
- Customer Identification Procedures (CIP)
Customer Acceptance Policy (CAP)– The following Customer Acceptance Policy indicates the criteria for acceptance of customers
- No account shall be opened anonymously or with fictitious names
- No Zebpay user shall be below the age of 18 / cannot be a minor as defined by the law of the resident country.
- All required KYC documents are mandatory.
- User Accounts can be opened through the Zebpay Platform.
- Each User Account is unique and can be activated by providing KYC documents pertaining to that User. Once the account is activated, the same KYC documents cannot be used to open another User Account.
- Additional documents may be sought by Zebpay based on it’s internal risk assessment.
Customer Identification Procedure (CIP)– Customer identification means identifying the person and verifying his/ her identity by using reliable, independent source of documents, data, information or by using third-party services. Zebpay needs to obtain sufficient information necessary to establish, to its satisfaction, the identity of each user. Additional documents may be sought by Zebpay based on it’s internal risk assessment
4. List of KYC documents
Types of Entity
Zebpay accepts any TWO documents from the below list as Proof of Identity:
- National Id
- Driving License
- Bank Statement (Not older than 3 months)
- Utility Bill ( Not older than 3 months and translated into English)
- Employment Card
- Certificate of incorporation and Memorandum & Articles of Association, or any other relevant documents of incorporation.
- Resolution of Board of Directors / Partners to open an account with Zebpay, and identification of those who have authority to operate the account
- Copy of a company telephone landline bill or a recent company bank account statement in the company’s name and bearing the office address.
- A photo ID of all Board of Directors
- ID & Address proof of an Authorised signatory
- ID & Address proofs of beneficial owner with ownership or control of more than 25% of the shares or voting rights..
Note: Zebpay reserves the right to call for additional documents for further verification based on Users volume and trading pattern
- If the User has any complaints, feedback or questions, the Zebpay may be contacted via firstname.lastname@example.org. We will ensure the issue is resolved to the best of our ability and with utmost urgency.All customer queries should be routed through email@example.com ONLY
- These terms may be periodically reviewed and revised. The revised terms will be uploaded on the Zebpay Platform and will reflect the modified date of the terms. The User is required to periodically visit the Zebpay website and review terms and any changes thereto.
- Use of Zebpay Services constitutes the agreement of User to the terms contained herein and any amendments thereto.