Terms & Conditions

TransaPay (High-Risk Payment Gateway)

Effective Date: December 11, 2025
Website: https://transa-pay.com

1. COMPANY INFORMATION

TransaPay is operated by:

SES TECHNOLOGY S.P Z.O.O (KRS 0001143888)
Address: ul. Głogowska 82 / 22, 60-741 Poznań, Poland
Email: legal@transa-pay.com

2. NATURE OF SERVICE

TransaPay is a payment orchestration and connectivity technology platform designed for high-risk and complex merchant environments.

TransaPay is:

• NOT a bank

• NOT a credit institution

• NOT an electronic money institution (EMI)

• NOT a money transmitter

• NOT a custodian of funds

• NOT a payment processor or acquirer

We provide technical infrastructure only, including routing, connectivity, risk tooling, and payment orchestration between merchants and third-party licensed payment service providers (PSPs), acquiring banks, and financial institutions.

All payment processing, settlement, custody, and financial regulation compliance is performed exclusively by third-party regulated providers.

3. ACCEPTANCE OF TERMS

By accessing or using TransaPay, the merchant agrees to be legally bound by these Terms, all applicable laws, card scheme rules (Visa, Mastercard, etc.), AML/CTF regulations, and the compliance requirements imposed by downstream acquiring partners.

If you do not agree, you must immediately cease all use of the platform.

4. HIGH-RISK MERCHANT ACKNOWLEDGMENT

The Merchant acknowledges that:

• Services are designed for high-risk industries

• Processing may involve elevated chargeback ratios

• Transactions may be subject to enhanced monitoring, holds, or termination

• Acquirers and PSPs may decline, freeze, or reverse transactions at their discretion

• TransaPay does not guarantee approval, uptime, settlement, or processing continuity

5. PROHIBITED ACTIVITIES

The following activities are strictly prohibited:

• Fraudulent, deceptive, or misleading transactions

• Illegal goods or services under applicable jurisdictions

• Money laundering, terrorist financing, or sanctions evasion

• Unauthorized gambling, betting, or lottery operations (unless explicitly approved per jurisdiction)

• Adult content involving illegal exploitation or non-compliant distribution

• Sale of counterfeit goods

• Unlicensed financial services, investment schemes, or Ponzi structures

• Pharmaceutical or controlled substances without proper licensing

• Any activity violating card scheme rules or acquiring bank policies

TransaPay reserves the right to classify additional activities as prohibited at its sole discretion.

6. KYC / KYB / AML COMPLIANCE

All merchants are subject to full Know Your Business (KYB) and Anti-Money Laundering (AML) screening.

The Merchant agrees to provide:

• Corporate registration documents

• Director and shareholder identification

• Proof of address and business operations

• Website and product/service verification

• Bank account ownership proof

• Transactional and financial documentation upon request

Failure to comply may result in immediate suspension or termination.

TransaPay maintains a zero-tolerance policy for AML/CTF violations.

7. TRANSACTION MONITORING & RISK CONTROL

TransaPay and its partners reserve the right to:

• Monitor all transactions in real-time or post-processing

• Flag, delay, or block suspicious activity

• Request supporting documentation for any transaction

• Implement rolling reserves or security holds

• Adjust processing limits without prior notice

• Suspend processing during risk investigations

Merchant acknowledges that risk-based controls are mandatory and non-negotiable.

8. CHARGEBACKS & FRAUD LIABILITY

The Merchant is fully liable for:

• Chargebacks

• Fraudulent transactions

• Friendly fraud

• Card scheme disputes

• Refund deficits

Excessive chargeback ratios may result in:

• Immediate termination

• Rolling reserve increase up to 100%

• Funds withholding for risk coverage

• Reporting to acquirers and card schemes

TransaPay bears no financial liability for chargeback losses.

9. SETTLEMENTS & FUNDS FLOW

TransaPay does not hold or custody funds.

All settlements are processed by third-party acquiring partners subject to:

• Their own settlement schedules

• Risk delays

• Rolling reserves

• Compliance holds

Settlement timelines are indicative only and not guaranteed.

10. FEES & CHARGES

The Merchant agrees to pay all applicable:

• Processing fees

• Chargeback fees

• Compliance fees

• Rolling reserve deductions

• Cross-border or FX fees (if applicable)

Fees may be updated at any time with or without prior notice depending on risk exposure or acquirer requirements.

11. SUSPENSION & TERMINATION

TransaPay may suspend or terminate access immediately if:

• Fraud or suspicious activity is detected

• Compliance requirements are not met

• Chargeback thresholds are exceeded

• Required documentation is not provided

• Requested by acquiring banks or regulatory bodies

• Business is deemed high-risk beyond acceptable thresholds

Termination may occur without liability or compensation.

12. LIMITATION OF LIABILITY

To the maximum extent permitted by law:

• TransaPay shall not be liable for indirect, incidental, or consequential damages

• TransaPay shall not be liable for loss of revenue, profits, or business interruption

• TransaPay shall not be liable for actions taken by third-party acquirers or PSPs

• TransaPay provides the platform “as is” and “as available”

All financial processing risks are assumed by the Merchant.

13. NO GUARANTEE OF SERVICE

TransaPay does not guarantee:

• Payment approval rates

• Processor uptime

• Settlement timelines

• Continuity of acquiring relationships

• Acceptance of specific business models

High-risk processing is inherently unstable and subject to external financial institution policies.

14. INDEMNIFICATION

The Merchant agrees to fully indemnify and hold harmless TransaPay, its directors, affiliates, and service providers against:

• Any regulatory claims

• Chargeback losses

• Fraud-related disputes

• Legal proceedings

• Third-party claims arising from Merchant activity

15. DATA PROTECTION

TransaPay processes data in accordance with applicable data protection laws (including GDPR where applicable).

Merchant data may be shared with:

• Acquiring banks

• Payment service providers

• Compliance and fraud screening providers

• Regulatory authorities when required

16. GOVERNING LAW

These Terms shall be governed by and interpreted in accordance with the laws applicable to the jurisdiction of incorporation of SES TECHNOLOGY SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, without prejudice to mandatory local regulatory requirements applicable to merchants.

17. FINAL CLAUSE

TransaPay operates in a high-risk financial environment where regulatory, banking, and card network decisions may override any contractual arrangement.

The Merchant acknowledges that stability in high-risk payment processing is never guaranteed, and accepts full operational and financial responsibility for their business activity.