TERMS AND CONDITIONS

TERMS AND CONDITIONS

These Terms and Conditions, read together with the ePayhub Privacy Policy (issued as a separate document) and all other Parts of this document, govern the use of the website www.epayhub.in and the ePayhub mobile application.

1.Preamble and Acceptance

This document is an electronic record within the meaning of Section 4 of the Information Technology Act, 2000 ("IT Act") and rules made thereunder, and is published in accordance with Rule 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ("IT Rules"). It does not require any physical or digital signature to be valid or enforceable, consistent with Section 10A of the IT Act.

These Terms and Conditions ("Terms") constitute a legally binding agreement between the User and M/s. F‌l‌e‌x‌y‌P‌a‌y‌ ‌S‌o‌l‌u‌t‌i‌o‌n‌s‌ ‌P‌r‌i‌v‌a‌t‌e‌ ‌L‌i‌m‌i‌t‌e‌d, a company incorporated under the Companies Act, 2013, bearing CIN: U74999TG2019PTC130085 and having its registered office at 91Springboard, LVS Arcade, Jubilee enclave, Hitec City, Hyderabad, Telangana- 500081 (hereinafter "Flexypay", "ePayhub", "Company", "Platform", "we", "us" or "our"), which owns and operates the website www.epayhub.in and its associated mobile application (together, the "Platform"). The Platform is owned and operated by M/s. F‌l‌e‌x‌y‌P‌a‌y‌ ‌S‌o‌l‌u‌t‌i‌o‌n‌s‌ ‌P‌r‌i‌v‌a‌t‌e‌ ‌L‌i‌m‌i‌t‌e‌d and is made available to Users under its brand name "ePayhub"; all references in this document to "ePayhub" are references to M/s. F‌l‌e‌x‌y‌P‌a‌y‌ ‌S‌o‌l‌u‌t‌i‌o‌n‌s‌ ‌P‌r‌i‌v‌a‌t‌e‌ ‌L‌i‌m‌i‌t‌e‌d.

By accessing, browsing, registering on, or undertaking any Transaction through the Platform, the User unconditionally accepts these Terms and every other policy referenced herein (including the ePayhub Privacy Policy, Buyer Onboarding Policy, Tutor/Freelancer Onboarding Policy, Anti Money Laundering Policy, Service Delivery Verification Policy, Chargeback, Dispute and Refund Policy, and Transaction Monitoring Policy), each of which is incorporated by reference under Section 10A of the IT Act and forms a single, composite agreement with the User within the meaning of Section 2(h) of the Indian Contract Act, 1872.

If the User does not agree with these Terms in their entirety, the User must immediately discontinue use of the Platform.

These Terms apply in addition to, and not in derogation of, any separate contract that a User, Biller, or Payee may have entered into directly with ePayhub.

ePayhub reserves the right to amend, modify, add to, or delete any provision of these Terms at any time, at its sole discretion, by posting the updated Terms on the Platform. Material changes will be notified to Users at least 15 days prior to becoming effective through the Platform, email, or SMS, as appropriate. Continued use of the Platform after such notice constitutes acceptance of the amended Terms; Users who object should discontinue use immediately.

2.Definitions

"Applicable Law" includes the Information Technology Act, 2000 and rules made thereunder; the Payment and Settlement Systems Act, 2007 ("PSS Act"); the Reserve Bank of India's Master Direction/Directions on Regulation of Payment Aggregators (as consolidated and amended from time to time) ("PA Directions"); the Bharat Bill Payment System framework operated by NPCI Bharat BillPay Limited ("NBBL"), to the extent applicable; the Prevention of Money Laundering Act, 2002 ("PMLA") and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 ("PMLA Rules"); the Digital Personal Data Protection Act, 2023 ("DPDP Act") and rules made thereunder; the Foreign Exchange Management Act, 1999; the RBI's Master Direction Know Your Customer, 2016 ("KYC Master Direction"); the Consumer Protection Act, 2019; and all other statutes, regulations, master directions, and circulars applicable to ePayhub's business, each as amended or re-enacted from time to time.

"Biller"/"Merchant"/"Institution" means the third party to whom a payment is remitted through the Platform, including utility companies, educational institutions, landlords, housing societies, government bodies, subscription and service providers, or any other payee designated by a User, irrespective of whether such Biller directly accepts the Payment Instrument used by the User.

"Buyer"/Payer"/"User"/"You" means any natural or juristic person who registers on the Platform to initiate a Transaction.

"Payee"/"Service Provider"/"Seller"/"Beneficiary" means a tutor, freelancer, Vendor or other individual or entity onboarded on the Platform, in accordance with Part B, to receive payments from Users.

"Transaction" means any bill payment, recharge, subscription payment, tuition, freelance fee payment, Payment to Vendor or other remittance initiated by a User through the Platform.

"Payment Instrument" means debit cards, credit cards, net-banking, UPI, wallets, or such other instrument as may be enabled on the Platform from time to time.

"Convenience Fee"/"Service Fee" means the fee, charge, or commission payable by a User to ePayhub for facilitating a Transaction, as disclosed on the Platform prior to completion of the Transaction, consistent with the price-disclosure requirements under the Consumer Protection (E-Commerce) Rules, 2020, to the extent applicable.

"Self-Financing Transaction" means a Transaction where a User uses the Platform, directly or indirectly, to fund their own account, an account of a relative or associate, or an account in which the User has a beneficial interest, under the guise of a bona fide bill payment or service fee, including payment against a fake, inflated, or fraudulent invoice, or transfer of funds to a self-owned or related-party account not representing a genuine underlying transaction between unrelated parties.

"RBI" means the Reserve Bank of India, and "NPCI"/"NBBL" mean the National Payments Corporation of India and NPCI Bharat BillPay Limited, respectively.

3.Nature and Scope of Services

ePayhub is a technology-driven platform that facilitates the payment of bills, recharges, subscriptions, tuition/freelance fees, and other permitted expenses through Payment Instruments, including in circumstances where the relevant Biller does not directly accept the Payment Instrument selected by the User. ePayhub remits such payments to the Biller through payment rails and methods accepted by that Biller for example, receiving a card payment from the User and remitting the corresponding amount to the Biller via NEFT/IMPS/UPI/BBPS or such other rail as the Biller accepts.

ePayhub acts solely as a facilitator/intermediary of payments within the meaning of Section 2(1)(w) of the IT Act. ePayhub does not itself issue Payment Instruments, extend credit facilities, accept public deposits, or act as a bank, and nothing on the Platform shall be construed as banking, deposit-taking, or lending business within the meaning of the Banking Regulation Act, 1949. ePayhub is a technology platform only. ePayhub is not a payment system operator, payment aggregator, payment gateway, or other entity authorised or regulated by the Reserve Bank of India under the PSS Act, the PA Directions, or otherwise, and it neither holds nor intends to seek any such authorisation. All collection, processing, and settlement of funds in respect of a Transaction is undertaken by the regulated entities engaged by ePayhub, including scheduled commercial banks, RBI-authorised payment aggregators and payment gateways, NPCI, and NBBL, on whose authorised infrastructure Transactions are effected. Nothing in this document or on the Platform shall be construed as a representation that ePayhub holds any licence, authorisation, or registration from the RBI or any other regulator.

All Transactions are processed strictly in accordance with Applicable Law, including the extant RBI regulatory framework governing payment aggregation/BBPS, and ePayhub reserves the right to decline, delay, hold, or reverse any Transaction that it reasonably believes may violate Applicable Law, card network operating rules, or this Agreement.

The User acknowledges that ePayhub does not guarantee that any specific Biller will accept payment through any specific Payment Instrument or rail, and that such acceptance remains subject to the Biller's own systems, third-party payment rails, and Applicable Law from time to time.

The contractual relationship in respect of the underlying bill, fee, subscription, or other obligation for which payment is made subsists exclusively between the User and the relevant Biller/Payee. ePayhub is not a party to, and assumes no responsibility for, such underlying relationship, including its quality, timeliness, or genuineness.

4.Role as Intermediary; Partner-Routed Transactions

Transactions on the Platform are routed through ePayhub's banking, payment gateway, card network, and BBPS/NPCI ecosystem partners (collectively, "Partners"). The User acknowledges that ePayhub is only a facilitator connecting the User with the relevant Biller/Payee and its Partners, and is not a party to, and shall not be liable in respect of, the underlying transaction, or the acts, omissions, conduct, or service quality of any Biller, Payee, or Partner.

Where a Biller, Payee, or Partner shares information with ePayhub that is subsequently found to be false or misleading, and ePayhub relays that information to the User in good faith, ePayhub shall not be responsible for such inaccuracy, without prejudice to the User's right to raise a dispute under Part F.

The User shall not initiate, and ePayhub shall not facilitate, any payment for a purpose that is illegal, immoral, unethical, unlawful, or unsafe, or that otherwise violates these Terms or Applicable Law. ePayhub reserves the right to refuse to process any Transaction that it, at its sole discretion, considers to fall within this Clause, whether on the grounds of ePayhub's internal policy or a restriction imposed on ePayhub under a contract with a Partner.

The User acknowledges that use of a Partner's payment rail (for example, a specific bank's NEFT/IMPS corridor or a specific card network) may itself be subject to that Partner's own terms and conditions, which apply in addition to these Terms; in the event of an irreconcilable conflict between the two on a matter within that Partner's exclusive operational control, the Partner's terms shall govern solely in respect of that operational aspect.

5.Eligibility

The Platform is available only to individuals who are at least 18 (eighteen) years of age and competent to contract under Section 11 of the Indian Contract Act, 1872, and to juristic entities duly authorised to transact in accordance with their constitutional documents. Persons who are "incompetent to contract" within the meaning of Section 11, including undischarged insolvents, are not eligible to use the Platform.

The User represents and warrants that: (a) all information, documents, and Payment Instruments provided to ePayhub belong to the User, or the User is otherwise duly authorised to use them; (b) the User is not a "Politically Exposed Person" within the meaning of the KYC Master Direction, unless disclosed and accepted subject to enhanced due diligence; (c) the User is not restricted, debarred, or disqualified by any legal, regulatory, judicial, or quasi-judicial authority from accessing the Platform; and (d) use of the Platform will not violate any right of a third party or any Applicable Law.

A User shall not hold more than one active account on the Platform at any time, and shall not sell, trade, transfer, or permit any other person to use the User's account, or impersonate any other person for the purpose of creating an account. The User shall further not access the Platform or initiate any Transaction from a device that is shared with, or used by, any other person, and shall access the Platform only from a device in the User’s own exclusive possession and control.

6.Registration and KYC

Use of certain features of the Platform requires registration and completion of Know Your Customer ("KYC")/Customer Due Diligence formalities in accordance with the KYC Master Direction and ePayhub's Buyer Onboarding Policy (Part C) and Anti Money Laundering Policy (Part D).

The User shall provide accurate, current and complete information at all times and shall promptly notify ePayhub of any change. ePayhub may suspend or restrict access to the Platform pending verification of any information provided, or where ePayhub has reasonable grounds to suspect that information provided is untrue, inaccurate, incomplete, or not current.

The User is solely responsible for maintaining the confidentiality of login credentials, OTPs, and authentication factors, and for all activity that occurs through the User's account. ePayhub shall not be responsible for any unauthorised transaction or access resulting from the User's failure to safeguard such credentials, without prejudice to the User's rights under the RBI's Circular on Customer Protection Limiting Liability of Customers in Unauthorised Electronic Banking Transactions, to the extent applicable to the relevant Payment Instrument.

Payment Instruments (cards) added to a User's account shall be tokenised in accordance with the RBI's card-on-file tokenisation framework, and ePayhub does not store the full card number, CVV, or expiry date in a manner inconsistent with RBI's data-storage norms. All card Transactions shall be subject to Additional Factor of Authentication as mandated by RBI under the PSS Act.

7.Accuracy of Payment Instructions; Threshold Documentation

The User is solely responsible for the correctness of: (a) the Beneficiary's bank account or other payment-instrument details to whom payment is intended; (b) the payment instrument selected (or chosen from the User's saved instruments) to make the payment; and (c) the amount of the payment. Where the User inputs any of these details incorrectly, the User shall be responsible for the resultant Transaction and any charges arising therefrom; ePayhub may, at its discretion and without obligation to do so, assist in reversing such a Transaction where technically feasible.

ePayhub may require additional information from time to time to verify the underlying Transaction, including the Beneficiary's PAN, the User's own PAN, or supporting agreements (such as a rental agreement, Proof of delivery, Invoice ), and the User's failure to provide such information may result in the User being unable to use the relevant feature. At our sole discretion, in respect of a category of payment designated by ePayhub as requiring such verification (for example, rent), submission of the Beneficiary's PAN shall be mandatory, and the payment will not be processed without it.

Where a Transaction appears suspicious, ePayhub may request additional supporting documentation from the User, in accordance with the ePayhub Service Delivery Verification Policy (Part E); failure to provide such documentation within 72 (seventy-two) hours may result in the Transaction failing and, at ePayhub's sole discretion, the User's access to the Platform being restricted.

The User shall not, and shall not attempt to, in connection with use of the Platform or the Services, host, display, upload, modify, publish, transmit, update, or share any information, or otherwise engage in conduct, that:

• Is used for any unlawful purpose, including tax evasion, circumvention of foreign exchange control under the Foreign Exchange Management Act, 1999, or structuring of transactions to evade reporting thresholds ("smurfing");
• Constitutes or facilitates a Self-Financing Transaction, as defined in Clause 2 above;
• Uses a Payment Instrument that does not belong to the User or that the User is not authorised to use;
• Routes funds for money laundering, terror financing, or any activity prohibited under the PMLA or the Unlawful Activities (Prevention) Act, 1967;
• Misrepresents the nature, purpose, or Biller/Payee of a Transaction, or is grossly harmful, harassing, defamatory, obscene, invasive of privacy, or otherwise unlawful within the meaning of Rule 3(1)(b) of the IT Rules;
• Infringes any patent, trademark, copyright, or other proprietary right of any third party;
• Contains software viruses, worms, trojans, or other code designed to interrupt, damage, or limit the functionality of the Platform or any connected system, which may also attract liability under Sections 43 and 66 of the IT Act;
• Impersonates any person or entity, or falsely states or misrepresents identity, age, or affiliation with any person or entity;
• Uses any deep-link, robot, spider, scraper, or other automated device to access, monitor, or copy any part of the Platform, or attempts to gain unauthorised access to the Platform, its servers, or any User account, which may attract liability under Section 66 of the IT Act;
• Interferes with or disrupts the Platform, the Services, or the servers or networks used to provide them;
• Violates any operating rule of the applicable card network, PA, bank, NPCI, or BBPS ecosystem participant; or
• Violates any Applicable Law for the time being in force, or threatens the unity, integrity, defence, security, or sovereignty of India within the meaning of Rule 3(1)(b) of the IT Rules.

ePayhub reserves the right to refuse, cancel, reverse, suspend, or report any Transaction reasonably suspected of violating this Clause 7, without prejudice to its rights under Applicable Law, including reporting to the Financial Intelligence Unit India ("FIU-IND") as set out in Part D and Part G.

8.Prohibited Categories of Payment

Without limiting Clause 7, ePayhub shall not facilitate, and reserves the right to decline, reverse, or block, any Transaction connected with the following categories, which list is illustrative and subject to updation by ePayhub based on instructions received from its banking/card network partners and the RBI's guidance on high-risk merchant categories:

• Gambling, betting, lottery tickets, or online gaming/gaming credits involving real-money stakes, to the extent restricted under the Public Gambling Act, 1867 and State-level gaming legislation;
• Adult goods and services, including pornography (regulated under the Information Technology Act, 2000 and the Indecent Representation of Women (Prohibition) Act, 1986) or escort services;
• Virtual digital assets, cryptocurrency, non-fungible tokens, or other crypto-products;
• Narcotics or drug paraphernalia regulated under the Narcotic Drugs and Psychotropic Substances Act, 1985;
• Firearms, ammunition, explosives, or other weapons regulated under the Arms Act, 1959;
• Counterfeit goods, or goods/services infringing third-party intellectual property;
• Money laundering services, chit funds regulated under the Chit Funds Act, 1982, nidhi companies, or unregistered/unlicensed money service businesses;
• Multi-level marketing, pyramid schemes, or matrix sites, to the extent covered by the Prize Chits and Money Circulation Schemes (Banning) Act, 1978;
• Any product, service, or category prohibited under Applicable Law, or under the operating rules of ePayhub's partner banks, card networks, or NPCI/BBPS from time to time.

9.Payment Processing and Settlement

Transactions are processed through empanelled banks, payment gateways, and card networks. ePayhub acts as a payment facilitator and not as a collection agent for any Biller or Payee. ePayhub does not maintain any escrow or nodal account and does not hold, pool, or exercise control over User funds. All funds are collected from Users and settled to Billers/Payees by the regulated entities engaged by ePayhub, including RBI-authorised payment aggregators, payment gateways, and partner banks, through accounts maintained and operated by those entities in accordance with the RBI norms applicable to them. ePayhub’s own operating funds are at no stage co-mingled with amounts payable to a Biller or Payee.

Where ePayhub offers Users a choice of settlement speed, such settlement to the Biller/Payee shall ordinarily be made available as per available models, in each case subject to a corresponding Convenience Fee differential disclosed on the Platform. Settlements in the selected tier shall be processed on the applicable banking day, using such fund-transfer mechanism (IMPS, NEFT, RTGS, or other) as ePayhub considers appropriate for that tier and amount.

ePayhub shall not be responsible for any failure, delay, or shortfall in settlement within the selected tier where such failure, delay, or shortfall arises from circumstances not within ePayhub's reasonable control, including the acts or omissions of a Partner, bank, or payment system, without prejudice to any RBI-mandated compensation for delay under Part F.

ePayhub has no obligation to verify the authenticity of a Transaction beyond confirming that it was generated through a valid, authenticated login to the Platform, and ePayhub's Transaction records shall constitute conclusive evidence of Transactions carried out, absent manifest error, subject to the User's rights to dispute under Part F.

ePayhub is not liable for delay or failure in settlement caused by the Biller's, Payee's, or a third-party bank's, card networks, or NPCI/BBPS ecosystem participant's acts or omissions.

10.Fees and Charges

ePayhub may levy a Convenience Fee, platform fee, or processing charge, as displayed to the User prior to confirmation of the Transaction, in accordance with the price-transparency obligations applicable to online service providers. All applicable taxes, including GST under the Central Goods and Services Tax Act, 2017, shall be additionally payable by the User. By proceeding with a Transaction after such disclosure, the User is deemed to have consented to the fee displayed.

Fees paid in respect of a successfully completed and verified Transaction are non-refundable, save as expressly provided in the Chargeback, Dispute and Refund Policy (Part F).

11.Communications

By registering on the Platform, the User expressly consents to receive transactional and (where separately opted-in) promotional communications from ePayhub, its partner banks, and service providers, via SMS, email, WhatsApp, push notification, or telephone call, notwithstanding the User's registration under the National Do Not Call/National Customer Preference Registry, to the extent such consent is permitted under the Telecom Commercial Communications Customer Preference Regulations, 2018 issued by the Telecom Regulatory Authority of India. A User may opt out of promotional communications at any time by writing to h‌e‌l‌p‌@‌e‌p‌a‌y‌h‌u‌b‌.‌i‌n; this shall not affect transactional communications necessary for the operation of the Services.

12.Ratings, Feedback and Geo-Location

Where applicable, the Platform may, upon completion of a Transaction, prompt the User with an option to rate or leave feedback regarding a Payee or the Services. ePayhub and its affiliates reserve the right to use, aggregate, and display such ratings and feedback in connection with ePayhub's business, without attribution to the User beyond what the User has consented to, and reserve the right to edit or remove any feedback that is obscene, defamatory, discloses another individual's personal information without consent, or otherwise violates Applicable Law or ePayhub's content policies.

The User acknowledges that geo-location information is collected solely for fraud-prevention and Transaction-risk-scoring purposes under the ePayhub Transaction Monitoring Policy (Part G), and consents to such collection. ePayhub may share the User's geo-location information with a Partner solely to the extent necessary to detect or prevent fraud in connection with a specific Transaction. Geo-location information is not collected or used for any other purpose, and access to the Services is not conditional upon the User permitting continuous geo-location tracking.

13.Credit Information / Credit Bureau Consent

Where ePayhub's Services involve accessing a User's credit information report, credit score, or related inferences from a Credit Information Company authorised by the RBI under the Credit Information Companies (Regulation) Act, 2005 ("CICRA") (collectively, "Credit Information"), THE USER EXPRESSLY AGREES TO ACCESS THE CREDIT BUREAU CREDIT Information Report and Credit Score, and irrevocably and unconditionally consents to such Credit Information being provided to ePayhub by the relevant Credit Information Company for the limited purpose of the specific Service availed by the User. ePayhub shall not sell, or rent such Credit Information beyond that limited purpose, and shall keep the same confidential in accordance with CICRA and the ePayhub Privacy Policy. ePayhub shall purge such Credit Information promptly upon completion of the purpose for which it was procured, save to the extent continued retention is required under Applicable Law, including the ePayhub Anti Money Laundering Policy (Part D).

14.Finance Partner Information-Sharing and Contact Consent

Where ePayhub has one or more finance partners offering credit or other financial products to Users (each, a "Finance Partner"), the User authorizes Company to share its Finance Partners any information the User provides in connection with a product or service offered by such Finance Partner, for the purposes of verification, underwriting, and servicing of that product.

By clicking "Apply"/"Submit" in connection with a Finance Partner's product, the User separately and specifically consents to being contacted by that Finance Partner via call, SMS, or email for the limited purpose of verifying the User's application and servicing the product applied for; this authorisation is limited to that specific purpose, is revocable by the User at any time by written notice to ePayhub or the Finance Partner, and does not constitute a general waiver of the User's rights under the Telecom Commercial Communications Customer Preference Regulations, 2018.

15.Third-Party Links and Promotions

The Platform may contain links to third-party websites (for example, a Biller's own website). ePayhub does not review, endorse, or warrant the content, products, or services of any such third-party website, and is not responsible for the actions, content, or privacy practices of any such website; access to a linked third-party website is at the User's own risk and subject to that website's own terms. Where ePayhub makes available a promotional offer or contest, whether directly or in partnership with a Partner, such offer or contest shall be governed by its own specific terms and conditions displayed on the Platform, in addition to these Terms, and ePayhub's determination of any winner or outcome of such offer/contest shall, save for manifest error or fraud, be final.

16.Reporting Abuse or Objectionable Content

If a User becomes aware of any abuse, violation of these Terms, or objectionable content on the Platform, the User may report the same to h‌e‌l‌p‌@‌e‌p‌a‌y‌h‌u‌b‌.‌i‌n, in addition to (and independent of) the grievance-redressal mechanism at Clause 22.

17.Intellectual Property

All content, page headers, trademarks, logos, software, and source code comprised in the Platform are the exclusive property of ePayhub or its licensors and are protected under the Copyright Act, 1957, the Trade Marks Act, 1999, and other applicable intellectual property laws. Save for a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform for personal, non-commercial purposes in accordance with these Terms, no right, title, or interest in such content is transferred to the User, and the User may not copy, reproduce, republish, distribute, or create derivative works from any part of the Platform without ePayhub's prior written consent.

18.Intellectual Property Infringement Notice

If a User believes that content on the Platform infringes their intellectual property, the User (or their duly authorised agent) may notify ePayhub in writing at h‌e‌l‌p‌@‌e‌p‌a‌y‌h‌u‌b‌.‌i‌n, providing: (a) identification of the intellectual property claimed to be infringed; (b) identification of the material alleged to be infringing, with sufficient information to locate it on the Platform; (c) a statement of good-faith belief that the use complained of is not authorised by the intellectual property owner, its agent, or Applicable Law; (d) the complainant's contact details; (e) a statement that the information provided is accurate and that the complainant is, or is authorised to act on behalf of, the intellectual property owner; and (f) the complainant's physical or electronic signature. ePayhub reserves the right to take down the identified content pending review, and to take action against a User found to have submitted a knowingly false claim under this Clause.

19.Disclaimer of Warranty and Limitation of Liability

THE PLATFORM AND SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, OR NON-INFRINGEMENT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW. ePayhub does not warrant that the Services will be uninterrupted, timely, secure, or error-free, or that any Biller/Payee will honour, accept, or deliver against any Transaction.

ePayhub shall not be liable for any delay, failure, or loss arising from acts or omissions of a Biller, Payee, issuing/acquiring bank, card network, NPCI/BBPS ecosystem participant, telecom operator, or any event of Force Majeure (Clause 24).

Subject to Applicable Law, ePayhub's aggregate liability to a User in respect of any Transaction shall not exceed the Convenience Fee charged by ePayhub for that Transaction, except in cases of proven fraud or gross negligence directly attributable to ePayhub.

In no event shall ePayhub, its affiliates, directors, officers, employees, or partner banks/service providers be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, including loss of profits, revenue, data, or goodwill, whether based in contract, tort, strict liability, or otherwise, even if advised of the possibility of such damages.

20.Indemnity

The User shall defend, indemnify, and hold harmless F‌l‌e‌x‌y‌p‌a‌y‌ ‌S‌o‌l‌u‌t‌i‌o‌n‌s‌ ‌P‌v‌t‌ ‌L‌t‌d, its directors, officers, employees, affiliates, and agents against any and all claims, demands, actions, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from: (a) the User's breach of these Terms or any ePayhub Policy; (b) the User's violation of Applicable Law; (c) misuse of a Payment Instrument, or any inaccurate or misleading information furnished by the User; or (d) any dispute between the User and a Biller/Payee or other third party. This indemnity shall survive termination of the User's use of the Platform.

21.Suspension and Termination

ePayhub may suspend, restrict, or terminate a User's access to the Platform, with or without prior notice as circumstances reasonably require, where ePayhub: (a) suspects fraud, money laundering, a Self-Financing Transaction, or any activity flagged under Part D or Part G; (b) is directed to do so by a regulator, court, or law enforcement agency; (c) determines that the User has breached these Terms or provided false/misleading information; or (d) determines, at its sole discretion, that the User's activity exposes ePayhub to unacceptable risk.

A User may close their account at any time by written request, subject to completion of any Transaction already in process and retention of records as required under Applicable Law, including Section 12 of the PMLA.

Termination does not relieve the User of obligations or liabilities accrued prior to termination, and clauses relating to indemnity, limitation of liability, intellectual property, confidentiality, and governing law shall survive termination.

22.Grievance Redressal and escalation matrix

At ePayhub, customer satisfaction is our highest priority. We are committed to resolving customer concerns in a fair, transparent, and timely manner.

If you have any complaint regarding your order, payment, refund, product quality, delivery, or any other service-related issue, you may contact us through the following channels:

22.1.Customer Support

Use the chat option available inside the app

Whatsapp: +‌9‌1‌-‌7‌7‌3‌1‌8‌1‌0‌8‌1‌1

Email: h‌e‌l‌p‌@‌e‌p‌a‌y‌h‌u‌b‌.‌i‌n

Phone: 8‌2‌4‌8‌5‌5‌7‌8‌9‌5

Working Hours: Monday to Friday, 9:00 AM to 6:00 PM IST

22.2.Complaint Resolution Timeline

*Complex cases involving third-party logistics, manufacturers, banks, or payment partners may require additional time. Customers will be informed of the progress.

22.3.Escalation Matrix

If your grievance remains unresolved after level 1, you may contact our Grievance Officer.

Name: J‌a‌h‌n‌a‌v‌i‌ ‌V‌a‌l‌m‌i‌k‌i

Designation: Grievance Officer

Email: g‌r‌i‌e‌v‌a‌n‌c‌e‌@‌e‌p‌a‌y‌h‌u‌b‌.‌c‌o‌m

Phone: +‌9‌1‌-‌9‌9‌4‌8‌3‌4‌5‌5‌5‌9

Business Address:

F‌l‌e‌x‌y‌p‌a‌y‌ ‌S‌o‌l‌u‌t‌i‌o‌n‌s‌ ‌P‌v‌t‌ ‌L‌t‌d

91Springboard, LVS Arcade, Jubilee enclave

Hitec City, Hyderabad-500081

Response Time: Within 48 hours

Final Resolution: Within 15 business days

22.4.Information Required While Raising a Complaint

To help us resolve your grievance efficiently, please provide:

• Transaction ID
• Registered email address or mobile number
• Description of the issue
• Relevant screenshots/ videos or supporting documents (if any)
• Preferred resolution

22.5.Closure of Complaint

A complaint shall be considered closed when:

• The customer confirms that the issue has been resolved; or
• The company has provided a final response after completing its investigation in accordance with applicable policies.

22.6.External Escalation

If the User remains dissatisfied after exhausting Levels 1 and 2, the User may, as applicable to the nature of the grievance, approach: (a) the Reserve Bank of India's Complaint Management System (CMS) or the Banking Ombudsman/Ombudsman Scheme for Digital Transactions, for payment-related grievances; (b) the NPCI/BBPS dispute redressal mechanism, for UPI/BBPS-routed Transactions; (c) you may contact your payment instrument issuer (Credit card, wallet, UPI issuer) whose contact information is on their websites and or mobile apps.

22.7.Note

This Grievance Redressal Mechanism applies to all customers purchasing products or services through ePayhub and is subject to our Terms & Conditions, Privacy Policy, Refund Policy, and applicable laws.

23.Governing Law and Jurisdiction

These Terms shall be governed by the laws of India. Subject to Applicable Law, the courts at Hyderabad, Telangana shall have exclusive jurisdiction over any dispute arising out of or in connection with these Terms.

24.Force Majeure

ePayhub shall not be liable for any failure or delay in performance caused by events beyond its reasonable control, including natural disasters, pandemics/epidemics, strikes, lock-outs, failure of telecommunications or banking infrastructure, hacking or illegal usage of the Platform, regulatory action, or other force majeure events; performance shall be suspended only for the duration of such event.

25.Miscellaneous

Severability: If any provision of these Terms is held invalid or unenforceable, the remaining provisions shall continue in full force and effect.

Assignment: The User may not assign or transfer any right or obligation under these Terms without ePayhub's prior written consent. ePayhub may assign these Terms to any successor entity or in connection with a corporate reorganisation, subject to Applicable Law.

Waiver: No failure or delay by ePayhub in exercising any right under these Terms shall operate as a waiver thereof, nor shall a single or partial exercise preclude any other or further exercise.

Entire Agreement: These Terms, together with Parts C through H, the separately issued ePayhub Privacy Policy, and any Annexures, constitute the entire agreement between the User and ePayhub in respect of its subject matter, superseding any prior understanding.

1.Purpose and Applicability

This Policy governs the onboarding, verification, and ongoing compliance of tutors, freelancers, coaching centres, and other independent service providers ("Payees") who register on the Platform to receive payments from Users as "Payees" who receive funds through the Platform. ePayhub operates the Platform as a discovery-and-payment-facilitation model connecting Users with Payees; the payment functionality is ancillary to enabling settlement of fees genuinely owed for services rendered or to be rendered.

2.Eligibility Criteria

The Payee must be at least 18 years of age (or, if an entity, duly constituted under Applicable Law);

be an Indian resident individual or an entity duly registered in India;

hold a bank account or UPI-linked account in their own/the entity's name with a bank operating in India; and

not appear on any sanctions, watchlist, PEP, or debarment list applicable under Part D.

3.Documentation Required

PAN, quoted under Section 139A of the Income Tax Act, 1961 mandatory prior to receiving any payout;

Aadhaar or other officially valid document under the KYC Master Direction, used solely for identity verification through the appropriate consent-based e-KYC/video-KYC mechanism and in accordance with Section 7 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 read with applicable RBI directions on voluntary use of Aadhaar for private entities;

bank account/UPI proof (cancelled cheque/passbook/bank statement) in the Payee's name, verified through a penny-drop or equivalent mechanism; and

At our sole discretion, where relevant, proof of professional qualification or credentials claimed by the Payee (e.g., teaching certification).

4.Tiered Verification Thresholds

For any cumulative payouts to a Payee in a financial year, PAN and bank-account verification (via penny-drop) shall be conducted.

Determined by ePayhub's internal risk assessment, the Payee shall be required to complete Aadhaar-based e-KYC/video-KYC verification, in addition to PAN verification, prior to further payouts.

A Payee must complete the applicable verification prior to the initiation of any payment by a User in favour of that Payee. No Transaction shall be initiated in favour of a Payee whose verification is not complete, and the Platform shall not permit a User to initiate a payment to an unverified Payee. Where, notwithstanding the foregoing, any amount is debited from a User in respect of a Payee whose verification is incomplete, the Transaction shall be treated as failed and the amount automatically refunded to the User’s original source account, in accordance with Part F.

5.Onboarding Agreement, Undertakings, and Consent

Every Payee shall execute/accept an onboarding undertaking ("Payee Service Declaration") confirming that: (a) the information furnished is true and accurate; (b) the amount to be received is genuinely due for services actually rendered or to be rendered to the specific User, and does not constitute a Self-Financing Transaction; (c) the Payee will not impersonate another person or entity; (d) the Payee remains solely responsible for the quality, legality, and delivery of any tutoring/freelance service rendered, independent of ePayhub's role as payment facilitator; and (e) the Payee will comply with Applicable Law, including tax obligations.

The User initiating a payment to a Payee represents that they have obtained the Payee's valid consent, within the meaning of Section 6 of the DPDP Act, to share the Payee's personal and financial information with ePayhub for the purpose of enabling the payment facility; the Payee, by completing onboarding, separately consents to being onboarded as a payee on the Platform.

6.Payment Settlement to Payees

Amounts collected on behalf of a Payee shall be settled to the Payee's verified bank account as per the selected settlement speed while making the payment, subject to the Service Delivery Verification Policy (Part E).

Where applicable, ePayhub shall deduct tax at source under the Income Tax Act, 1961 (including Sections 194-O, 194-C, or 194-J, as applicable to the nature of the arrangement) and issue relevant TDS statements/Form 16A to the Payee. GST compliance in respect of services rendered by the Payee remains the Payee's own responsibility.

7.Conduct Standards and Prohibited Activities

A Payee shall not: (a) solicit Users to make off-platform cash payments to evade ePayhub's fees; (b) make false or misleading claims regarding qualifications or services, which may separately attract liability under the Consumer Protection Act, 2019; (c) use the Platform for any transaction unconnected with a genuine service rendered, or collude with a User to structure a Self-Financing Transaction; or (d) accept payment purporting to be for tutoring/freelance services where no bona fide service relationship exists.

8.Suspension and De-boarding

ePayhub may suspend or de-board a Payee where fraud, repeated User complaints, AML red flags (Part D/H), or a regulatory directive so warrants, following such verification as is reasonably practicable in the circumstances, and without prior notice where ePayhub reasonably believes urgent action is required.

9.Grievance Mechanism

Payees may raise grievances through the two-level mechanism prescribed at Clause 15 of Part A, including escalation to the Grievance Redressal Officer named at Annexure 1.

1.Purpose

This Policy sets out the process by which Users ("Buyers") are onboarded onto the Platform, consistent with the KYC Master Direction and ePayhub's Anti Money Laundering Policy (Part D).

2.Eligibility

A Buyer must be at least 18 years of age, hold a valid Indian mobile number, and possess a Payment Instrument issued in their own name (or be duly authorised to use a corporate Payment Instrument on behalf of an entity). A Buyer must not be a Politically Exposed Person unless disclosed and accepted subject to enhanced due diligence and must not be listed on any applicable sanctions list.

3.Tiered KYC / Customer Due Diligence

Onboarding follows a risk-based, tiered approach consistent with the KYC Master Direction:

Full KYC (PAN + selfie and Aadhaar-based e-KYC/video-KYC, or an equivalent officially valid document) for higher transaction limits and full feature access; and

Enhanced Due Diligence for Buyers categorised as higher risk under Part D.

4.Registration Process

Registration requires mobile number verification via OTP, followed by completion of the applicable KYC tier. ePayhub may request additional documents where necessary to complete verification, and reserves the right to reject or delay onboarding, at its sole discretion, pending satisfactory completion of the above steps.

5.Addition of Payment Instruments

Cards and other Payment Instruments added to the Buyer's account are tokenised in accordance with RBI's tokenisation framework, and all Transactions are subject to Additional Factor of Authentication as mandated by RBI.

6.Risk Categorisation

Every Buyer is risk-categorised (Low/Medium/High) in accordance with the Anti Money Laundering Policy (Part D), based on factors including transaction pattern, geography, and nature of Billers/Payees paid, with periodic re-assessment.

7.Transaction Limits

Transaction and cumulative limits applicable shall be as displayed on the Platform from time to time and shall not exceed limits (if any) prescribed by RBI for the relevant category of payment instrument or KYC tier.

8.Prohibited Use and Consequences

Use of the Platform in violation of Clause 6/7 of Part A or in a manner inconsistent with this Policy may result in suspension, mandatory re-KYC, or termination of the Buyer's account, and reporting under Part D/H where warranted.

9.Account Modification and Closure

A Buyer may update KYC information or request account closure at any time, subject to completion of pending Transactions and record-retention obligations under Applicable Law. ePayhub is not obligated to delete records required to be maintained under Applicable Law, and may retain such records in anonymised or restricted-access form, consistent with the data-minimisation and storage-limitation principles under the DPDP Act as elaborated in the ePayhub Privacy Policy.

ANTI MONEY LAUNDERING (AML) POLICY

This Policy is framed with reference to the Prevention of Money Laundering Act, 2002 ("PMLA") and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 ("PMLA Rules"), the KYC Master Direction, and Financial Action Task Force ("FATF") standards, to the extent applicable to ePayhub's business as a payment facilitator and, if applicable, a "reporting entity"/"financial institution" under Section 2(1)(sa)/2(1)(l) of the PMLA.

1.Objective and Regulatory Basis

This Policy establishes ePayhub's framework for preventing the use of the Platform for money laundering, terror financing, or other financial crime, and for compliance with reporting obligations under Section 12 of the PMLA to the Financial Intelligence Unit India ("FIU-IND").

2.Customer Acceptance Policy

ePayhub shall not onboard: (a) anonymous or fictitious-named Buyers/Payees; (b) individuals or entities appearing on UN Security Council sanctions lists, lists notified under the Unlawful Activities (Prevention) Act, 1967, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") list, or other applicable watchlists; or (c) entities that decline to furnish minimum KYC information required under Applicable Law.

3.Customer Due Diligence (CDD)

CDD is conducted on a risk basis: (a) Simplified/Basic CDD for low-risk, low-value Buyers; (b) Full CDD (identity and address verification through officially valid documents) for standard onboarding; and (c) Enhanced Due Diligence ("EDD") for high-risk categories, including Politically Exposed Persons ("PEPs") and their close relatives/associates, unusually large or complex transactions, and Buyers/Payees flagged under Part G.

4.Self-Financing Transactions and Structuring

ePayhub expressly prohibits Self-Financing Transactions (as defined in Part A, Clause 2) and structuring/smurfing of Transactions to evade CDD or reporting thresholds. ePayhub reserves the right to decline, reverse, or report any Transaction suspected of constituting such conduct, and to suspend or terminate the relevant Buyer's and/or Payee's account.

5.Risk Categorisation

Buyers and Payees are categorised as Low, Medium, or High risk based on factors including nature and value of Transactions, geography, occupation/business, and source of funds, with periodic re-assessment.

6.Politically Exposed Persons

Where a Buyer or Payee is identified as a PEP or a close relative/associate of a PEP, EDD shall apply, including senior management approval for onboarding and ongoing enhanced monitoring, consistent with the KYC Master Direction.

7.Sanctions and Watchlist Screening

All Buyers and Payees are screened at onboarding and periodically thereafter against applicable sanctions lists, including UN Security Council designations, OFAC, and domestic watchlists notified by the Government of India under the Unlawful Activities (Prevention) Act, 1967.

In addition, every Buyer and Payee, by signing up for and using the Services, represents and warrants on a continuing basis that: (a) such person is not a Politically Exposed Person within the meaning of the KYC Master Direction, or, if such person is, that fact has been disclosed to ePayhub in writing at or prior to onboarding; and (b) such person is not designated, listed, or otherwise subject to sanctions imposed by the United Nations Security Council, the Office of Foreign Assets Control of the United States Department of the Treasury, the Government of India, or any other government, regulator, or law-enforcement agency of competent jurisdiction, and is not owned or controlled by, or acting on behalf of, any such person. Each Buyer and Payee shall notify ePayhub immediately upon this representation ceasing to be true, and ePayhub may suspend or terminate access to the Services with immediate effect, and make such report to the competent authority as Applicable Law may require, upon becoming aware of any breach of this Clause.

8.Record Keeping

Records of Transactions, KYC documentation, and correspondence shall be maintained for a minimum period of 5 (five) years from the date of the transaction or the end of the business relationship, whichever is later, in accordance with Section 12(1)(e) of the PMLA read with the PMLA Rules, and shall be made available to the RBI, FIU-IND, or other competent authority upon lawful request.

9.Monitoring, Reporting, and Confidentiality (Tipping-Off Prohibition)

Transactions are monitored in accordance with the Transaction Monitoring Policy (Part G). Suspicious Transaction Reports ("STRs") shall be filed with FIU-IND within the timelines prescribed under the PMLA Rules (ordinarily within 7 working days of the suspicion being finalised), and Cash Transaction Reports/other prescribed reports shall be filed within statutorily mandated timelines, to the extent applicable to ePayhub's business. ePayhub, its officers, and employees shall maintain strict confidentiality regarding any STR filed or proposed to be filed and shall not disclose the fact of such filing to the relevant Buyer, Payee, or any other person, except as permitted under Applicable Law a violation of which may itself constitute an offence under Section 12 read with Section 13 of the PMLA.

10.Designated Director and Principal Officer

ePayhub shall designate a Principal Officer responsible for AML compliance and liaison with FIU-IND, and a Designated Director with overall responsibility for AML/CFT compliance. Contact details are set out at Annexure 1.

11.Employee Training

ePayhub shall conduct periodic AML/KYC training for relevant personnel and maintain records of such training.

12.Internal Audit and Review

This Policy shall be reviewed at least annually, or upon a material change in Applicable Law or business model, and shall be subject to periodic internal/independent audit.

1.Objective

This Policy ensures that, before a Transaction is treated as complete, ePayhub verifies on a reasonable-efforts basis and to the extent technically feasible that the underlying bill payment, recharge, subscription, or service to the Biller/Payee has in fact been credited/delivered or is genuinely owed, so as to protect Users, Billers, and Payees against fraud, misdirected funds, or Self-Financing Transactions. This Policy is a risk-mitigation measure and does not constitute a warranty by ePayhub as to the quality, timeliness, or genuineness of the underlying goods or services, and does not derogate from ePayhub's position as an intermediary under Section 79 of the IT Act.

2.Verification Mechanisms

real-time API acknowledgment from the Biller or the Biller's aggregator/BBPS, for automated categories (utility bills, recharges, subscriptions);

SMS/email confirmation received from the Biller;

manual verification (call-back/document confirmation) for categories without automated confirmation;

completion of Payee onboarding/verification under Part B, for the tutor/freelancer/Vendor category, including the 24-hour verification window and the Payee Service Declaration;

For Categories without automated confirmations, we send notification/ communication to the Payer and Payee with the UTR nos, amount, Date of fund transfer and account to which the funds were settled to; and

risk-based, sample, or post-disbursal documentary verification (invoices, tuition receipts, proof of service) requested from a Buyer or Payee, particularly for high-value or first-time Transactions between a given Buyer-Payee pair.

3.Verification Timelines

Verification shall be completed in real time or near-real time for automated categories, and within 48 hours for manually verified categories. Where ePayhub requests supporting documentation on a risk basis, failure to provide such documentation within 72 (seventy-two) hours may result in the Transaction being flagged for further investigation and the relevant account being placed under review or restriction.

4.Evidence and Record Retention

Transaction logs, API acknowledgments, and confirmation receipts shall be retained for a minimum period consistent with Part D (Clause 8) and for such longer period as may be required for dispute resolution under Part F.

5.Handling Verification Failure

Where the Biller/Payee does not confirm receipt or complete verification within the applicable timeline, ePayhub shall investigate and, where appropriate, initiate an automatic reversal/refund to the User in accordance with Part F, or place the Transaction on hold pending investigation where fraud or a Self-Financing Transaction is suspected.

6.Limits of Verification

ePayhub does not, and is not obligated to, independently verify the quality, adequacy, or actual performance of the underlying goods or services in respect of which a payment is made. Disputes regarding the quality, delivery, or performance of the underlying service (as opposed to the genuineness of the payment obligation) shall be resolved directly between the Buyer and the Payee, without recourse to ePayhub, save as expressly provided in Part F.

7.Escalation

Discrepancies indicating possible fraud, money laundering, or a Self-Financing Transaction shall be escalated to the AML/Transaction Monitoring team under Parts E and H.

1.Scope

This Policy governs the raising, processing, and resolution of disputes, chargebacks, cancellations, and refunds arising from Transactions on the Platform, and is intended to operate consistently with the RBI's harmonised turnaround-time framework for failed transactions and the "right to seek redressal" recognised under Section 2(9) of the Consumer Protection Act, 2019.

2.Raising a Dispute

A User may raise a dispute regarding a Transaction through the Platform's support channel within 3 (three) days of the Transaction date, or within such shorter period as may be prescribed by the applicable card network (Visa/Mastercard/RuPay/NPCI) or bank, whichever is earlier. Disputes raised beyond this window may, at ePayhub's sole discretion, not be entertained, save where required to be considered under Applicable Law or card network rules. ePayhub shall acknowledge a dispute within 24 (twenty-four) hours and endeavour to resolve it within 7 (seven) business days, subject to cooperation from the relevant Biller, Payee, bank, or NPCI/BBPS ecosystem participant.

3.Cancellations

Once a Transaction has been successfully initiated, authenticated, and settled, the User may not seek cancellation of that Transaction, and ePayhub bears no liability in respect of such a request, as the instruction to remit funds is, in most cases, irrevocable once processed through the applicable payment rail.

ePayhub may, prior to settlement, cancel a Transaction initiated by a User where: (a) the designated account or Beneficiary details provided by the User are outside ePayhub's serviceable zone or the relevant Biller/Payee's accepted rails; (b) ePayhub is unable to obtain the User's response via phone or another communication channel at the time of confirming the Transaction, where such confirmation is sought; (c) the Transaction involves an illegal or offensive purpose, or otherwise violates these Terms; (d) the information, instructions, or authorisations provided by the User are incomplete or insufficient to execute the Transaction; (e) no payment gateway or rail is available to complete the Transaction; or (f) the Transaction cannot be completed for a reason outside ePayhub's reasonable control.

Where a Transaction fails prior to remittance to the Biller/Payee for any of the above reasons, or due to a technical failure or non-completion of Payee verification within the prescribed window under Part B, the Transaction Amount shall be automatically reversed to the User's original source account.

4.Chargeback Process

A "Chargeback" means the amount of a Transaction that is reversed because it is: (a) disputed by the cardholder; (b) reversed by the issuing bank or card network for any reason; (c) not authorised by the cardholder, or ePayhub or the issuing bank has reason to believe it was not so authorised; or (d) considered unlawful or in breach of these Terms.

Where a dispute is raised through the User's issuing bank/card network as a Chargeback, ePayhub shall cooperate with its acquiring bank, furnish supporting Transaction and delivery-verification records under Part E, and file a representment where the Transaction is demonstrably valid, within the timelines prescribed by the applicable card network. Where ePayhub is intimated by a card issuer, acquiring bank, card network, the RBI, a cyber-crime cell, or any other governmental authority that a Chargeback has been raised, ePayhub shall be entitled to place the corresponding settlement to the Biller/Payee on hold pending investigation and resolution.

Where a Chargeback is upheld, the User shall owe, and shall be liable to promptly pay, ePayhub the amount of the Chargeback together with any associated fee, fine, or penalty assessed by the payment gateway, bank, card network, or processor, save where the Chargeback arose from ePayhub's own fraud or wilful default.

The User agrees to reasonably assist ePayhub, including by providing documentation within 72 (seventy-two) hours of a request, in investigating a Transaction subject to a Chargeback. Failure to provide such timely assistance may result in the Chargeback becoming irreversible, and ePayhub may, at its sole discretion, restrict the User's access to the Platform pending resolution.

5.Refund Processing

Decisions on whether a Transaction qualifies for a refund under this Policy shall be made in accordance with ePayhub's internal refund policy referred to at Annexure 1, applied consistently and in accordance with this Policy; nothing in this Clause shall be read to override a User's minimum entitlement to a refund/compensation under Applicable Law, including RBI's turnaround-time framework set out in the numbered provisions immediately below.

Refunds due to a User, whether pursuant to a successful dispute, verification failure under Part E, or Biller/Payee-side non-delivery, shall be processed to the original Payment Instrument within the timelines prescribed by RBI's turnaround-time (TAT) norms for failed/disputed digital transactions (ordinarily within [T+1 to T+7] working days of resolution, as applicable to the payment mode).

Where a refund is delayed beyond the RBI-prescribed TAT for reasons attributable to ePayhub, ePayhub shall pay compensation to the User at the rate prescribed under the applicable RBI circular, credited to the User along with the refund.

There shall be no refund or reversal of a successfully completed and verified Transaction on account of the User's change of mind, or a dispute solely regarding the quality, adequacy, or timeliness of the underlying goods/services, which shall be resolved directly between the User and the Biller/Payee.

6.Documentation Required

A User raising a dispute shall furnish the Transaction reference number, date, amount, and a description of the grievance, and such supporting evidence as may reasonably be requested.

7.Fraud-Related Chargebacks

Chargebacks arising from suspected unauthorised or fraudulent use of a Payment Instrument shall be referred to the AML/Transaction Monitoring team (Parts E and H), and the relevant Buyer/Payee account may be suspended pending investigation. If the investigation confirms the Transaction as fraudulent, ePayhub reserves the right to recover the amount from the Payee who received it, by set-off against future settlements or otherwise, without prejudice to reporting obligations under Part D.

8.Non-Refundable Situations

Save as required by Applicable Law, amounts are not refundable where: (a) the Transaction was successfully verified as delivered under Part E; (b) the dispute arises from the User's own error in Biller/Payee details; or (c) the applicable Convenience/platform fee has already been earned on a completed Transaction.

9.Chargeback Abuse and Blacklisting

Any User found to have raised a fraudulent, bad-faith, or collusive chargeback or dispute including in connection with a Self-Financing Transaction shall be permanently blacklisted from the Platform, and ePayhub reserves the right to reverse or claw back any amount credited pursuant to such chargeback/dispute, without prior notice, and to pursue recovery of any resulting loss through available legal remedies, including under Sections 415/420 of the Indian Penal Code, 1860 (or the corresponding provisions of the Bharatiya Nyaya Sanhita, 2023), where applicable.

10.Escalation

Unresolved disputes may be escalated to the Grievance Redressal Officer under Clause 15 of Part A, and thereafter to the Payment instrument issuer and thereafter, RBI's Complaint Management System/Ombudsman Scheme for Digital Transactions or the NPCI/BBPS dispute redressal mechanism, as applicable.

1.Objective

This Policy sets out ePayhub's framework for real-time and periodic monitoring of Transactions to detect fraud, money laundering, and other financial crime, in support of the Anti Money Laundering Policy (Part D) and ePayhub's obligations as a reporting entity under Section 12 of the PMLA.

2.Monitoring Systems and Tools

ePayhub employs a rule-based/automated monitoring engine incorporating velocity checks, threshold checks calibrated to KYC tier, device fingerprinting, geolocation analysis, new-Payee/first-time-pairing scrutiny, and pattern-based anomaly detection across Transactions.

3.Red Flag Indicators (illustrative, non-exhaustive)

rapid repeated payments to the same Biller/Payee inconsistent with the stated purpose, or indicative of a Self-Financing Transaction;

multiple Payment Instruments or accounts operated from a single device;

transaction values structured just below reporting/verification thresholds ("smurfing");

mismatched geography between the Payment Instrument issuer and the Biller/Payee;

sudden, unexplained changes in a Buyer's or Payee's transaction pattern;

card-testing patterns, i.e., multiple low-value authorisation attempts in quick succession;

round-tripping or circular payment patterns suggesting funds returning to the originating Buyer or a connected party; and

a Payee/Biller/Buyer flagged on a sanctions or PEP list under Part D.

4.Threshold-Based Alerts and Escalation Matrix

Alerts are escalated in tiers: (a) Level 1 automated hold/flag for review; (b) Level 2 compliance team review within 48 hours; and (c) Level 3 referral to the Principal Officer for a determination on whether a Suspicious Transaction Report is warranted under Section 12 of the PMLA.

5.Reporting to FIU-IND

Suspicious Transaction Reports shall be filed within the timelines prescribed under the PMLA Rules from finalisation of suspicion, and any other prescribed reports (including Cash Transaction Reports, to the extent applicable to ePayhub's business) shall be filed within statutorily mandated timelines.

6.Periodic Review and Independent Audit

The monitoring framework, thresholds, and rules shall be reviewed at least annually, or earlier upon a material change in transaction patterns or Applicable Law, and shall be subject to periodic independent audit. The specific rules, thresholds, and scoring methodology are confidential and shall not be disclosed to Users or third parties.

7.Record Retention

Alert logs, escalation records, and STR filings shall be retained for a minimum of 5 (five) years, consistent with Part D.

8.Interplay with Other Policies

This Policy operates in conjunction with the Anti Money Laundering Policy (Part D) and the Service Delivery Verification Policy (Part E), and any discrepancy identified under either shall be cross-reported to the relevant team.

ENTITY AND CONTACT DETAILS

The following details are to be completed and verified by ePayhub prior to publication. All entries below are placeholders.

Registered Entity Name & CIN: F‌l‌e‌x‌y‌p‌a‌y‌ ‌S‌o‌l‌u‌t‌i‌o‌n‌s‌ ‌P‌v‌t‌ ‌L‌t‌d. CIN: U74999TG2019PTC130085

Registered Office Address: 91 springboard, PLOT NO.71 LVS ARCADE, JUBILEE ENCLAVE, HITEC CITY , HYDERABAD, Telangana, India - 500081.

Response Time: Within 48 hours

Designated Director PMLA Rule 2(ca): G‌a‌d‌d‌e‌ ‌C‌h‌a‌n‌d‌r‌a‌s‌e‌k‌h‌a‌r, l‌i‌s‌t‌e‌n‌@‌f‌l‌e‌x‌y‌p‌a‌y‌.‌i‌n

Grievance Escalation Timeline: Response Time: Within 48 hours

Final Resolution: Within 15 business days