FINZOOPAY SOLUTIONS LLP

1. PURPOSE

This Policy establishes a risk-based framework for setting, implementing, monitoring and reviewing transaction limits and related controls for FINZOOPAY SOLUTIONS LLP's payment, gift-card, gift-voucher and related transaction activities, subject to applicable law, partner requirements and the Company's authorised business model.

2. OBJECTIVES

• Control financial, fraud and operational exposure.
• Prevent excessive transaction velocity or concentration.
• Apply appropriate limits by customer, product, channel and risk level.
• Support fraud detection and transaction monitoring.
• Provide controlled escalation and approval for limit changes.
• Maintain accurate records of limits, exceptions and reviews.

3. SCOPE

This Policy applies to relevant customer transactions, voucher issuance and redemption, payments, refunds, reversals, accounts, merchants, channels, APIs, partners and transaction systems operated or supported by the Company.

4. RISK-BASED LIMIT FRAMEWORK

Transaction limits shall be determined using relevant risk factors including product type, customer profile, transaction value, transaction frequency, fraud risk, KYC status where applicable, partner requirements, operational capacity and applicable legal or contractual requirements.

5. TYPES OF LIMITS

• Per-transaction limit
• Daily / weekly / monthly aggregate limit
• Transaction velocity limit
• Customer or account-level limit
• Voucher issuance limit
• Voucher redemption limit
• Refund / reversal limit
• Channel or API limit
• Partner / merchant limit

6. CUSTOMER / ACCOUNT RISK

Where appropriate, transaction limits may vary according to customer or account risk, verification status, transaction history, product characteristics and other approved risk factors.

7. VELOCITY CONTROLS

The Company may restrict unusually frequent transactions, repeated attempts, rapid purchase/redemption cycles or other patterns that indicate elevated fraud or operational risk.

8. PRODUCT & CHANNEL CONTROLS

Limits may be configured separately for different products, voucher types, payment methods, customer channels, APIs, merchants or partner integrations according to risk and system capability.

9. FRAUD-BASED CONTROLS

Fraud alerts, suspicious patterns, compromised accounts, device or network indicators and other risk signals may result in temporary or permanent transaction restrictions consistent with applicable procedures.

10. AML / KYC CONSIDERATIONS

Where applicable, transaction controls shall consider KYC status, customer risk classification, transaction profile and financial-crime indicators in accordance with the Company's AML/CFT & KYC Policy and relevant partner requirements.

11. LIMIT CONFIGURATION

Transaction limits shall be configured through controlled systems and shall be accessible only to authorised personnel. Changes shall be subject to appropriate approval and audit logging.

12. LIMIT CHANGE APPROVAL

Material changes to transaction limits shall be supported by documented rationale, risk assessment and appropriate approval. Emergency changes shall be documented retrospectively where immediate action is necessary to protect customers or the Company.

13. EXCEPTION MANAGEMENT

Temporary or customer-specific exceptions shall be risk-assessed, time-bound, approved by authorised personnel and recorded. Exceptions shall be reviewed and closed when no longer required.

14. MONITORING & ALERTS

Systems may generate alerts when transactions approach or exceed thresholds, exhibit abnormal velocity or trigger risk rules. Alerts shall be reviewed according to severity and available evidence.

15. LIMIT BREACH

Where a transaction exceeds an applicable limit, the system may decline, hold, block or route the transaction for review. Any override shall follow the approved exception process.

16. REFUND & REVERSAL CONTROLS

Refunds and reversals shall be subject to appropriate limits, authorisation, transaction matching, reconciliation and fraud controls to prevent abuse or duplicate processing.

17. VOUCHER / GIFT CARD CONTROLS

Voucher issuance, activation, redemption, cancellation and refund limits shall be established according to product design, partner rules, fraud exposure and applicable requirements.

18. PARTNER & THIRD-PARTY LIMITS

Where transaction processing depends on banks, gateways, processors or other partners, the Company shall consider partner-imposed limits and ensure that system configurations do not knowingly conflict with applicable contractual or operational requirements.

19. RECONCILIATION

Transaction-limit events, blocks, overrides, refunds and reversals shall be capable of reconciliation with relevant transaction and settlement records.

20. MANAGEMENT INFORMATION

• Transaction volumes and values
• Limit breaches and blocked transactions
• Overrides and exceptions
• Fraud-related restrictions
• High-risk transaction patterns
• Refund and reversal activity
• Material limit changes

21. TESTING

Transaction-limit configurations shall be tested periodically and following material system changes to confirm that limits, velocity rules, blocks, overrides and audit logs operate as intended.

22. CUSTOMER COMMUNICATION

Where appropriate, customers may be informed of applicable transaction restrictions, subject to security, fraud-prevention and legal considerations. Internal fraud-detection thresholds shall not be disclosed where doing so could facilitate circumvention.

23. DATA PROTECTION

Transaction and risk information used for limit management shall be processed, accessed and retained in accordance with applicable privacy, security and record-keeping requirements.

24. RESPONSIBILITY MATRIX

25. POLICY EXCEPTIONS

Exceptions shall be documented, risk-assessed and approved by authorised management. No exception may override a mandatory legal, regulatory or contractual requirement.

26. REVIEW & AMENDMENT

This Policy shall be reviewed at least annually and whenever there is a material change to products, transaction patterns, fraud risks, partner requirements, systems or applicable requirements.

27. APPROVAL