This User Agreement ("Agreement") is effective as of May 26th, 2023, and was most recently updated on May 17th, 2022. It describes the terms by which you will be bound when you use the services accessible through Jawudi’s application available through iOS and Android and via links on Jawudi’s website (www.Jawudi.com) ( "Service"). Do not use the Service if you do not agree to be bound by these terms. By using the Service you are agreeing to the terms of this Agreement. As used throughout this Agreement, the terms "Jawudi", "we", "us", and "our" refer to Jawudi, Inc., a Delaware U.S.A. corporation, together with its employees, directors, successors, and assignees. The terms "you" and "your" refer to users of the Service, whether as Senders or Recipients.

We recommend you use the Service to send money to individuals and businesses known to you and, therefore, you should not use the Service to send money to strangers. The Service allows users to send international money transfers from the United States to other countries served by Jawudi. A "Sender" uses the Service to send money and a "Recipient" receives money through the Service. A "Transaction" refers to an order to send or request money through the Service. The "Transaction Amount" is the amount of the local currency that the Sender provides to Jawudi for transmission to the Recipient. The " ‘Payout’ or ‘Cash Out’ Amount" is the amount paid out to the Recipient.

1. Age and Capacity. You must be at least eighteen (18) years old to create an account, access, or use the Service as a Sender. You must be able to form legally binding contracts under applicable law. Other restrictions may apply. 

2. Others. You may not submit or receive a Transaction on behalf of any other person. 

3. Residence. The Service is available to residents of countries within which Jawudi is licensed to operate; limited to the countries available within Jawudi’s mobile application. 

4. Offer and Acceptance. If you submit a Transaction, you are requesting that we process your Transaction, an offer that we may accept or reject at our sole discretion. 

5. Geographic Restrictions. The service is only available in countries where it is licensed. As a result, the Service may not be available for use in all countries.

6. Multiple Accounts. Senders may only have one active account. If we determine that a Sender is using multiple accounts we reserve the right to merge or terminate one or more of the accounts, limit the Sender's use of the Service, or refuse their continued use of the Service.

1. Charges. With each Transaction you submit you are agreeing to pay fees associated with processing your chosen form of payment (“Transaction Fee”) and to pay us a service fee ("Service Fee'') for the use of our application, in addition to the Transaction Amount. Payment in your local currency is due at the time the transaction is submitted for processing. If you submit a transaction that results in us being charged NSF fees, chargeback fees, or other similar costs, you agree to reimburse Jawudi for all such fees. 

2. Payment. In order for us to process your transaction you authorize us to charge any of the payment instruments included in your payment profile ("Payment Instrument" includes any credit card, debit card, bank account, or any other legal payment instrument that exists or may come to be in the future). If your payment fails you authorize us to re-try one or more times using the same Payment Instrument. You warrant that you are an authorized and lawful user of the Payment Instrument(s). 

3. Other Charges. We are not responsible for fees that may be imposed by financial institutions associated with your Payment Instruments. For example, some credit card issuers may treat the use of your credit card to use the Service as a "cash advance" and may impose additional fees and interest cost for the transaction. Jawudi is not responsible for any NSF fees, chargeback fees, or other, similar charges that might be imposed on you by your bank, credit card issuer, or other provider. 

1. Service Providers. We work with local banks and other third party outlets (each, a "Service Provider '') to make funds available to Recipients. As a Sender, you are appointing your Recipient as your agent for the purpose of receiving funds transmitted through the Service. We try to provide current information on our website about the location, availability, and hours of our Service Providers. However, we are not responsible for any inaccurate or incomplete information that may be posted on the website. 

2. Verification. Recipients will be required to prove their identities before receiving funds by presenting valid identification and going through an identification verification process in order for us to comply with KYC rules. Also, Recipients may be required to provide a confirmation code or another similar identifier associated with their Transactions.

1. General. We may refuse any Transaction or limit the amount to be transferred, either on a per transaction or aggregated basis. These limits may be imposed on individual accounts or linked accounts. We reserve the right at any time to modify or discontinue all or any part of the Service. 

2. Delays. Your Transaction may be delayed by our effort to verify your identity and validate your Payment Instruments and otherwise comply with laws or manage our financial risk. You may be entitled to a refund in certain circumstances and you may cancel your transaction at any time while it is pending. 

3. Commercial Transactions. You should not use the Service to send money except to people and businesses that you know. We are not responsible for the quality or delivery of goods or services that you pay for using the Service. You accept that using the Service to pay for goods and services is at your own risk. 

4. Unauthorized Transactions. You may not use the Service in violation of this Agreement or applicable laws, rules or regulations. It is a violation of the Agreement to use the Service for any of the following: sexually-oriented materials or services, gambling activities , fraud, money-laundering, the funding of terrorist organizations, or the purchase or sale of tobacco, tobacco related paraphernalia, frearms, prescription drugs, or other controlled substances; or to send money to a Recipient that has violated the Agreement. If you use the Service in connection with illegal conduct, Jawudi will report you to law enforcement. 

5. Ineligibility. Your Payment Instrument must be issued by a licensed financial institution. We may refuse Transactions from certain Senders and to certain Recipients that are included on the Specially Designated Nationals list, Non-cooperative Countries and Territories list, and such other lists as issued by different government agencies. 

6. No Changes. We generally do not let you change the details of your Transaction once it's submitted to us for processing. It is your responsibility to make sure your Transaction details are accurate. 

7. Restricted Activities. In connection with your use of our website or the Service, or in the course of your interactions with Jawudi, a user or a third party, you will not: 

1. Breach this Agreement, or any other agreement between you and Jawudi; 

2. Provide false, inaccurate, or misleading information; 

3. Refuse to cooperate in an investigation or provide confirmation of your identity; 

5. Provide yourself a cash advance from your credit card (or help others to do so); 

6. Use any automatic device, or manual process to monitor or copy our website. 

6. HOW AND WHY WE COLLECT PERSONAL INFORMATION

1. Privacy Policy. By agreeing to this Agreement, you acknowledge and consent to our Privacy Policy (https://www.Jawudi.com/terms&conditions). 

2. Customer Identification Program. U.S. law requires we obtain, verify, and record information about you. We may require that you provide us with nonpublic, personal, identifying information. We may also lawfully obtain information about you from other sources without your knowledge, including non-personal identifying information that we may obtain while you visit this website. Please see our Privacy Policy (https://www.Jawudi.com//terms&conditions). 

3. Government Disclosures. We may provide information about you and your Transactions to government authorities and law enforcement agencies, as described in our Privacy Policy. 

4. Verifying information. You authorize us to make any inquiries, to you or to others, which are necessary to validate the information that you provide to us. This may include asking you for additional information, requiring you to take steps to confirm ownership of your email address or financial instruments, verifying your information against third party databases, or through other sources.

5. Third party API access & permissions. We collect geolocation data for the purpose of compliance with local financial regulations, security and to identify distribution points for your service. We do not retain or monitor your location data beyond these specific purposes. Please consult our Privacy Policy for details on how we safeguard your data (https://www.Jawudi.com/terms&conditions).

7. ERROR RESOLUTION, CANCELLATIONS AND REFUNDS

1. Error Resolution. Let us know at any time if you have any problems with the Service. You can contact us using the contact information at the bottom of this Agreement.

2. Refunds. You can cancel your transaction at any time prior to its completion. Completion means that your financial institution approved the transaction and the transaction amount has been deposited in your recipient’s wallet, even if the transaction amount has not been cashed out or transferred to another financial services provider (a bank account for example). Upon receipt of a cancellation request, we may confirm with our Service Providers to determine whether the transaction has been completed prior to initiating a refund. 

The Transaction Amount will not be refunded after completion. If, however, you are not satisfied with our service for any reason we will always refund the fee amount. All refunds will be credited to your Jawudi in-app balance. Refunds are only made in the currency of the transaction and will not be adjusted to account for changes in foreign exchange rates from the time your Transaction was submitted. Please note that residents of certain jurisdictions in the U.S. may have certain refund rights and complaint procedures, as described here: 

• Washington. As a Sender located in the state of Washington, you are entitled to a refund of all moneys received for transmittal within ten days of receipt of a written request for refund unless any of the following occurs: 

• The monies have been transmitted and delivered to the recipient prior to receipt of the written request for a refund; 

• Instructions have been given committing an equivalent amount of money to the person designated by the customer prior to receipt of a written request for a refund; 

• Jawudi, or its authorized delegate has reason to believe that a crime has occurred, is occurring, or may potentially occur as a result of transmitting the money as requested by the customer or refunding the money as requested by the customer; or 

• Jawudi is otherwise barred by law from making a refund. 

• Texas. As a Sender located in the state of Texas, you are entitled to cancel a transaction, and receive an immediate refund of all money charged for the remittance, including any fees paid to Jawudi, within thirty minutes of receiving a receipt, unless the intended recipient of the transaction has received the funds, or its equivalent. 

• If you have a complaint first contact the consumer assistance division of Jawudi, Inc at hello@jawudi.com, if you still have an unresolved complaint regarding the company's money transmission or currency exchange activity, please direct your complaint to: 

2601 North Lamar Boulevard, Austin, Texas 78705, 

[www.dob.texas.gov](http:// www.dob.texas.gov). 

3. Complaints. Although we encourage you to share with us any concerns or questions you may have about our service, including your account or a specific transaction, you may also want to contact the money transmitter licensing authority in your state. [Information about how best to do that can be found here](https:// www.Jawudi.com/licenses). 

If your issue is unresolved by Jawudi, Inc at hello@jawudi.com, please submit formal complaints with the State of Alaska, Division of Banking & Securities. 

Formal complaints must be in writing, please download the form [here](https:// www.commerce.alaska.gov/web/portals/3/pub/ DBSGeneralComplaintFormupdated.pdf) 

Formal complaint forms may be submitted via: 

3. Mail: Division of Banking & Securities PO Box 110807 Juneau, AK 99811-0807 

If you have questions regarding formal complaints, please call 907-465-2521

You acknowledge that the Service, including the content of this website, text, graphics, logos, and images, as well as all other Jawudi copyrights, trademarks, logos, and product and service names are owned exclusively by Jawudi, Inc. (the "Jawudi Intellectual Property''). 

You agree not to display, use, copy, or modify the Jawudi Intellectual Property in any manner. You are authorized solely to view and retain a copy of the pages of this website for your own personal, non-commercial use. You further agree not to: (i) use any robot, spider, scraper or other automated device to access the Service; (ii) remove or alter any author, trademark or other proprietary notice or legend displayed on this website (or printed pages thereof); or (iii) infringe Jawudi or any third party's copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or privacy.. 

If you provide us with any suggestions, feedback, reviews or input (“Customer Input”) related to our Services, we (and our corporate group entities) will own all right, title and interest in and to the Customer Input, even if you have designated the Customer Input as confidential. We and our corporate group entities will be entitled to use the Customer Input without restriction, including for marketing or business purposes. You assign to us all right, title and interest in and to the Customer Input and agree to provide us with any assistance we may require to document, perfect and maintain our rights in the Customer Input. For this purpose the word: “assign” is a legal term which means legally transferring the benefit, such as you legally transferring the benefit of the Customer Input to us.

We make reasonable efforts to ensure that Transactions are processed in a timely manner, but we make no representations or warranties regarding the time needed to complete processing because the Service is dependent on many factors outside our control. Some jurisdictions do not allow the disclaimer of implied warranties, so the foregoing disclaimer may not apply to you. This warranty gives you specific legal rights and you may also have other legal rights that vary from country to country and state to state within a given country. In any event, you may have a right to a refund as expressly described herein.

You agree to indemnify and hold Jawudi, Service Providers, and their respective subsidiaries, officers, agents, partners, and employees harmless from any claim or demand, including reasonable attorneys' fees, made by any third party due to or arising out of your use of the Service, your connection to the Service, your violation of the Agreement, or your violation of any rights of another.

IN NO EVENT SHALL JAWUDI, SERVICE PROVIDERS, OR THEIR RESPECTIVE SUBSIDIARIES, OFFICERS, AGENTS, PARTNERS, OR EMPLOYEES BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES BEYOND THE SUM OF $500.00 (IN ADDITION TO REFUNDING THE TRANSACTION AMOUNT AND SERVICE FEES), INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF JAWUDI HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES) RESULTING FROM NEGLIGENCE ON THE PART OF JAWUDI, DISBURSEMENT PARTNERS, OR THEIR RESPECTIVE SUBSIDIARIES, OFFICERS, AGENTS, PARTNERS, OR EMPLOYEES.

Jawudi, Inc., a Delaware B-corporation, is serious about protecting your privacy. This Privacy Policy ("Policy") covers how Jawudi collects and uses the personal information you provide on our application and website and in conjunction with any of the services hosted at [www.Jawudi.com](https://www.Jawudi.com) ("Service" and "Website"), including money transfer and payment services accessed by internet enabled devices. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Policy also applies if you participate in our research projects. The Policy was last updated on March 26, 2023. This Policy explains what personal information we collect about you, with whom we share it, and how you can elect in certain situations to not share information with third parties. "Personal Information" refers to information such as name and email that can be used to identify you individually. We may amend this Policy at any time, and whenever we do so we will notify you by posting a revised version on the Website. If, however, we plan to make a material change in the way we collect, use, or store your personal information, we will provide prior notice on our website, and by email. You will then have the chance to decide whether or not we will use or disclose your information in that new manner, whether through an "opt-out" procedure or by ending your relationship with us. Such changes will become effective, at the earliest, 30 days after the date of the email notifications. We ask that minors refrain from using our Service or submitting any personal information to us. Minors (those under the age of 18 years) are not eligible to use our Service. If you have questions or concerns regarding this Policy, you should [contact us](https:// www.jawudi.com/contact).

We will collect the following information about you, which may include non-public personal information: 

1. Personal and financial Information you give us as a result of using the Service, such as your address, e-mail address, date of birth, telephone number, all or part of your Social Security number (or its equivalent in your jurisdiction), bank account online login information, bank account number, credit/debit card number and/or credentials to access any other sources of your funds. Under certain circumstances we will also collect and save information obtained from (i) copies of official identification documents, including your Passport or Drivers' License, and (ii) your picture, video/ audio recording, or other evidence of yourself with your identification documentation. 

2. Third party personal information you provide in order for us to facilitate funds transfers, such as your recipient's full name, physical address, email address, and phone number. However, we will not contact your recipients except as instructed by you or as required to complete a transaction. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.

3. Information about your usage of the Service, including your transaction history, and how and to whom you use the Service to pay, send or receive money; 

4. Information that we lawfully obtain from third parties, such as identity verification services, electronic database services, and credit reporting agencies; 

5. Information that we indirectly obtain from you, such as information about the hardware and software you use when accessing the Service, your IP address, and the pages you access on this website, and other websites that you visit prior to accessing the Service. 

Technologies such as: cookies, beacons, tags and scripts are used by Jawudi, Inc. and our marketing, analytics and risk partners or affiliates. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. 

We may use cookies for site functionality, remembering user's settings (e.g. source & destination country), and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies some features or areas of our site will be limited. As is true of most websites and mobile applications, we gather certain information automatically and store it in log files. 

This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you. 

We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site and mobile application or to display advertising based upon your browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. We may partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by updating your cookies settings on any site you browse. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

We collect Personal and Non-Personal information for the following purposes: 

3. To collect payment for your use of the Service. 

4. To track, improve and personalize our Services, content and advertising 

5. To troubleshoot problems with the Service.

6. To comply with applicable laws and regulations, such as those relating to "know-your-customer," and anti-money laundering requirements. 

7. To detect and prevent fraud and other illegal uses of the Service. 

8. To create an account connection between your Jawudi account and a third party account or platform (such as your online bank account); 

9. To send you marketing notices, service updates, and promotional offers 

10. To collect survey information that will be used to monitor or improve the use of our Service and overall customer satisfaction. 

We will retain your information for as long as your account is active or as needed to provide you Service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell or rent the information we collect to third parties for their promotional purposes. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us. 

Nevertheless, we may share information about you (including nonpublic, personal information) with: 

1. Third-party service providers under contract with Jawudi that help us with our business operations, such as transaction processing, fraud prevention, marketing, market research, and validation of information provided. These third parties are prohibited from using your information for their own separate business purposes. 

2. In the event of the sale, acquisition or merger of some or all of our assets, your personal information might be a part of the transferred assets. We shall notify you in the event of such an occurrence, as well as any choices you may have regarding your personal information, by placing a notice on our website. 

3. Law enforcement, government officials or other third parties, but only 

• in connection with a formal request, subpoena, court order, or similar legal procedure; and, 

• when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our User Agreement. 

4. Other third parties that you consent or direct, which may include you authorizing an account linking for a third party service, account and/or platform.

• For the purposes of this privacy policy, an "account linking" with such a third party is a connection you authorize or enable between your Jawudi account and a non-Jawudi account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Jawudi and the third-party will exchange your personal information and other information directly. Examples of account connections include: connecting your Jawudi account to a third-party data aggregation or financial services company, if you provide such company with your account log-in credentials; 

• If you connect your Jawudi account to other banking or similar accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account linkage, we may receive information from the third-party about you and your use of the third-party’s service. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy. 

• Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection.

You can access, modify, delete or update your personal information submitted on our application by logging into your account and changing your preferences, by emailing our Customer Support at hello@jawudi.com.com. We will respond to your request to access within a reasonable timeframe.

Personal information we collect: If you participate in any research projects for us (by phone, in-person, electronic survey or otherwise), we will hold your name, contact details and any other personal information you choose to give us when taking part in our research projects. Using your personal information: We will use this information for our legitimate interests namely to conduct our research projects which may also help us to improve and/or develop our products and services. Sharing your personal information: We will share this information with: 

• our staff (but their use shall be limited to the performance of their duties and in line with the reason for processing); 

• other companies that we create in the future within our group, including affiliates in other countries where we operate in order to facilitate cross-border transfers and transactions (namely Jawudi GN, S.A.R.L. and Jawudi SN, S.A.R.L); 

• our platform, database, and application/website hosting suppliers to enable them to maintain, protect, support and host those solutions which are used to store our research; 

• various third parties who provide software and tools which are used to operate our business (including email, instant messaging, document/contract management and file-sharing); 

• third parties in the event of the sale, acquisition or merger of some or all of our assets if your personal information is part of the transferred assets (we shall notify you in the event of such an occurrence, as well as any choices you may have regarding your personal information, by placing a notice on our Site). 

Retaining your personal information: We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider (amongst other things): 

• obligations and/or retention periods imposed on us by applicable laws and/or our regulators 

• the amount, nature, and sensitivity of the personal information 

• the potential risk of harm from unauthorized use or disclosure of your personal information, and 

• the purposes for which we process your personal information and whether we can achieve those purposes through other means.

Notice to Customers who reside in California

The California Consumer Privacy Act (CCPA) exempts certain nonpublic personal information which is covered by the Gramm-Leach Bliley Act (GLBA), a federal privacy law that applies to financial institutions, like Jawudi. What this means is that your nonpublic personal information that you provide to us to obtain our Service, that results from any transaction you make using our Service, or that we otherwise obtain about you in connection with us providing our Service to you (GLBA Personal Information), is not subject to the various requirements set out in the CCPA. We do not collect nonpublic personal information about you that is outside a Transaction or the provision of our Services. 

Please be assured that we take the privacy of your GLBA Personal Information very seriously. Your GLBA Personal Information is protected under the GLBA which places certain obligations on us, and affords you certain rights, all of which are set out in this Policy. The rights you have in the event that your non-encrypted or non-redacted GLBA Personal Information is subject to unauthorized access and exfiltration, theft, or disclosure as a result of our failure to implement and maintain reasonable and appropriate security procedures and practices remain.

We employ industry accepted standards in protecting the information you submit to us on our Application and Website. 

We have put in place SSL (Secure Socket Layer) encryption technology to protect your sensitive information that you share with us on our website. We also use a firewall protected microservices based software architecture with encrypted access keys and databases, wherever possible, to protect sensitive information such as bank account number, credit card number, date of birth and Social Security Number, transmitted through our Application. To increase the security of your data we do not use passwords, we instead make use of a timed passcode that is sent to your registered phone number everytime you sign into our Application. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. 

If you have any questions about security on our application, you can contact us at [Customer Service](hello@jawudi.com.com).

Choices You Can Make About Our Use Of Your Information

Federal and state laws allow you to restrict the sharing of your personal information in certain instances. However, these laws also state that you cannot restrict all types of sharing. Because we have chosen to refrain from certain types of data sharing, the only type of sharing of your personal information that you may restrict is as follows: 

1. You may opt-out from promotional emails to you by selecting the "Unsubscribe" function present in each email we send you.

Our Site includes links to other web sites whose privacy practices may differ from those of Jawudi, Inc. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

Parts of the Jawudi Service uses Mapping service providers, including the Google Maps API(s). Use of these features is subject to Google Maps Additional Terms of Use and the Google Privacy Policy.

We may use a chat feature to answer questions about our service and assist you with our application’s and/or website's functionality. If our chat feature is offline we will collect your name and email address so that we may reply to your request. 

Our application and website include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it. 

You can import contacts from your address book or mail provider to invite them to become members of Jawudi. We do not collect the username and password for the email account you wish to import your contacts from as you provide it directly to your provider and after your approval they send us the details of your contacts. At your instruction we will send an email or text message invite and at most two reminder emails or text messages in addition to the original invite. Each invite will have an “opt-out” or “unsubscribe” option.

If you choose to use our referral service to tell a friend about our site, we will ask you for your friend's name, phone number and/or email address. We will automatically send your friend an invitation by email or text message, to visit our site or download our application, and at most two reminder emails or text messages. Jawudi, Inc. stores this information for the sole purpose of sending these communications and tracking the success of your referral. Your friend may request that we remove this information from our database with the “opt-out” or “unsubscribe” feature embedded in every email or text message.

If you have a complaint, contact Jawudi Customer Service by email at [Complaints](hello@jawudi.com)

You can [contact us](https://www.Jawudi.com/home/contact) with any questions or concerns at: Jawudi, Inc., 3 West 123 Street, #6, New York NY 10027; Email: [Customer Service](hello@jawudi.com.com)

Jawudi, Inc. (or Company) is a financial services technology company that uses cutting edge products to deliver money transmission services to, from and within select African countries and the United States. The Company has a zero-tolerance approach regarding fraud and corruption and expects all members of staff to share this commitment. The objective of this policy is to promote a culture which deters fraudulent activity, facilitate the prevention and detection of fraud and develop procedures which will aid in the investigation and appropriate actions to be taken. 

The Company is committed to achieving and maintaining full compliance with laws, regulations, and policies governing the conduct of the business in which we engage. 

The Identity Theft and Fraud Red Flags Policy (“Red Flags Policy”) sets forth the framework, respective roles and responsibilities of business units and Jawudi in managing identity theft and fraud red flags appropriately.  This Policy institutes a firm-wide approach to identify and define the various identify (“ID theft”) and fraud red flags, establish processes to manage and investigate if appropriate and oversee those risks across the entire organization in accordance with the Policy.

The Board of Directors of Jawudi are committed to conducting business in conformity with the highest standard in adherence to all applicable laws and regulations and joining with the government agencies to identify and mitigate fraud related to risk and illegal activity.  This Policy outlines the framework for the Red Flags Program and applies to all of Jawudi including all employees, agents, contractors and other third-parties acting on Jawudi’s behalf, legal entities business units as well as all third-party personnel/contractors/agents, as applicable that act on behalf of Jawudi unless specifically exempted by the Director (or Manager) of Compliance or her/his designee.

Fraud, including ID theft which is a type of fraud, is a global issue which costs companies including financial institutions millions of dollars and carries the risk of harming the reputation of a company.  Fraud is typically perceived as a crime that yields an isolated impact, but in reality, it has a cascading effect on a financial technology company and the industry as a whole.  Although companies maintain vigilant practices in their efforts to reduce risk, the scale and frequency of fraud attacks are growing particularly during the current pandemic.

ID theft and fraud red flags (“red flags”) point to potential occurrence of fraudulent activity and are defined as a set of circumstances (actions committed/created) that are unusual in nature or vary from expected activity.  Red flags can be a single event/action or a combination of actions that could indicate unusual or potentially suspicious activity.  Red flags signal that something is out of the ordinary, unusual in nature and therefore, may need to be investigated further.

The following terminology and key concepts are relevant to this Policy:

Overall, Jawudi defines fraud as any acts performed by a party with the intention to defraud, misappropriate property or circumvent the law against Jawudi and/or its clients.  These acts, which can include the intentional omission of information, are designed to deceive others, resulting in Jawudi suffering a loss and/or the perpetrator achieving a gain.

For purposes of this Policy, Jawudi organized fraud into two main categories, internal fraud and external fraud.  These two categories of fraud are further defined as:

Internal fraud – occurs when a Company employee commits fraud against Jawudi clients, vendors, third-parties, and other trusted business relationships.  Internal fraud typically occurs in the following categories:

External fraud – is defined as a financial loss incurred due to acts performed by an external party with the intention to defraud, steal or misappropriate property from Jawudi clients or from Jawudi.  Generally, the Company categorizes external fraud into two categories, either fraud that occurs in a product or fraud that occurs by actions taken by an external party:

The following provides additional context and clarity for nuances associated with external fraud to assist in Jawudi’s ability to identify red flags and address mitigation strategies. These external fraud types can be further distinguished as perpetrator (1st party) fraud, family (2nd party) fraud and victim (3rd party) fraud. 

1st party fraud occurs when an individual (e.g., perpetrator) misrepresents aspects of his/her identity – other than their own core personally identifying information (“PII”) – or gives false information that is relied upon when applying for a product with a promise of future repayment, but without willful intent to repay.

2nd party fraud occurs when an individual knowingly gives their identity or personal information to another individual to commit fraud or fraud is perpetrated on their behalf	and there is some knowledge of the person who obtained this information (i.e., someone	other than the consumer applies for a lending product, however, the consumer knows the perpetrator: a spouse, a friend, a family member, a work colleague, etc.).

3rd party fraud occurs without the knowledge of a person whose identity is used to commit the fraud. Traditional ID theft, a form of 3rd party fraud, occurs when an individual(s), uses another person’s (victim) identity or personal details to open (True Name-ID Theft) or takeover an account (Account TakeOver (“ATO”)) without the consent or knowledge of the person whose identity is being used (i.e., a lending product is applied for or used to someone without the knowledge of the person whose identity is used).

Employees are expected to report any suspected or known instance of fraud, inclusive of the 

Fraud types noted above.  In the event suspected or known instances of fraud are noted, employees should raise that to their manager or through the appropriate reporting method.

Mitigation of these fraud types, and the actions by which they are committed, requires very different and specific strategies.  When strategy is set, it should address nuances of the above in both proactive and reactive measures as appropriate.

As a result of the increased risk associated with fraud and ID Theft, Jawudi recognizes that it is critical to establish a Fraud Program designed to detect, prevent, and mitigate fraud and related schemes. 

2. Elements & Standards - Overview of the Jawudi Fraud Program

Setting the proper tone at the top and the manner in which management reinforces its message regarding fraud have a significant impact on Jawudi.  Adopting a strong policy and relating procedures, ensuring strong and effective governance, enhancing the culture to reflect the risk appetite of the organization, creating mechanisms to raise the awareness of fraud issues, and educating Jawudi employees and clients on how to prevent, detect, and monitor against egregious acts are the key elements of this overall component of the Fraud Program.

The proactive elements of the Fraud Program allow management to actively assess which fraud types Jawudi is susceptible to identify controls to prevent and detect those risks so that clients, vendors, employees, and other related parties are protected from fraudulent acts. 

The final component of the Fraud Program is the establishment of reactive measures.  The strongest tone at the top and proactive components will not prevent all fraud.  Therefore, the reactive component is critical.  Maintaining processes to respond to matters that occur, effective reporting to raise awareness, and remediation efforts to respond to matters that occur are the cornerstones of an effective overall reactive component of the Fraud Program.

The Red Flags Program aligns closely with key elements of the Fraud Program.  And, the Red Flag Program addresses the requirements outlined in the Fair and Accurate Credit Transaction Act (“FACTA”).  FACTA requires financial institutions to implement and maintain a fraud and ID theft program to detect, prevent, and mitigate fraud and ID theft in connection with certain account types.  The Jawudi Red Flags Program outlines its approach in addressing red flags and adhering to the FACTA regulatory guidance and is discussed in detail in the policy elements section of this document. 

2.1. Reporting and Administration of the Program – Tone at the Top

Jawudi Compliance oversees the implementation of the Policy as well as the overall Red Flags Program and provides guidance to business units in the administration of this Program. 

The Red Flags Policy establishes the respective roles and responsibilities of the business units across Jawudi that are responsible for managing red flags, escalating issues, and providing oversight and governance on the administration and reporting of the Program to the Board of Directors or a committee thereof.  In addition, the Red Flags Policy establishes procedures to manage and oversee the red flags process across Jawudi.

Red flags are defined as a set of circumstances (e.g., actions committee/created) that are unusual in nature or vary from expected activity.  The red flags can be a single event/action or a combination of actions that could indicate unusual or potentially suspicious activity.  Red flags signal that something is out of the ordinary, unusual in nature, and therefore, may require further investigation.

Training is required for employees of business units who have covered accounts identified as relevant to this process.  Jawudi also offers security awareness training that emphasizes the importance of protecting client information, which is instrumental in preventing fraud, including identity theft.

2.1.d. Red Flags Reporting Requirements 

Compliance provides annual reporting to the Jawudi Board and/or a committee thereof on red flags compliance.  This report includes metrics regarding red flags and summaries of material issues discussed in Compliance. This report addresses material matters related to the Program and evaluates issues such as:

An overall update on the status of the Program, including compliance with applicable regulatory requirements and this Policy;

Critical/significant incidents involving red flags and management’s response; and, 

Recommendations for material changes to the Program.


2.2. Identifying Covered Accounts – Proactive Measures

Jawudi’s red flags process ensures that red flags are identified, beginning with an assessment of covered accounts across Jawudi.  A covered account can be defined as:

A consumer account for personal, family, or household purposes that involves or allows multiple payments or transactions such as a credit card account. 

Any other account that Jawudi offers or maintains for which there is a reasonably foreseeable risk to clients or to the safety and soundness of Jawudi from identity theft, including financial, operational, compliance, reputation, or litigation risks.  

Once covered accounts have been identified, then red flags can be assessed relevant to covered accounts.

2.3. Assessing/Identifying/Refining Red Flags – Proactive Measures

Jawudi Compliance is responsible for maintaining and updating, on a periodic basis a red flag inventory as follows: 

External fraud related red flags, including identity red flags.

Areas outside of EFM that may be susceptible to identity theft are responsible for their respective external fraud related red flags.

Corporate Cyber Security is responsible for cyber risks that may be indicators of identity theft related risks.

Red flags are determined by each of the above based on unique operations and associated risks.  Red flags are identified from internal and external sources.  The red flags inventory is updated based on identification of red flags from these sources.  These sources could include emerging trends identified from activity occurring within Jawudi, external insights of emerging trends happening in the industry, and insights from third-party suppliers involved in aspects involving the covered accounts.  Finally, insights gathered from government and regulatory agencies can provide valuable perspectives on red flags.

2.4. Detection of Identified Red Flags- Proactive Measures

Jawudi business units are responsible for ensuring that mechanisms are in place to detect the red flags that have been identified.  Mechanisms for the detection of red flags identified are designed to identify undesirable events and attempts in the earliest stages of occurrences.

2.5. Prevention and Mitigation of Red Flags – Reactive Measures

When detecting red flags, it is essential for Jawudi to put mechanisms in place to prevent and/or mitigate the red flag from continuing and/or fraud being realized.

In the event that a red flag becomes realized (i.e., attempted or successful fraud or identity theft), Jawudi immediately follows established fraud procedures to respond to such events/incidents, and in effect, mitigates the potential impact of said events/incidents.

2.6. Continuous Monitoring of Red Flags – Reactive Measures

Jawudi proactively and continuously monitors detected red flags in a manner that contributes to future insights aimed at preventing future fraudulent acts.

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