Client Disclosure Notice

This Client Disclosure Notice ("Disclosure") is issued by Aspora Money Services Limited, a company incorporated in the Dubai International Financial Centre (DIFC) and regulated by the Dubai Financial Services Authority ("DFSA") under registration number 10541 ("Company", "Aspora", "we", or "us").

This Disclosure applies to any person who accesses or uses our Services (as defined hereinbelow) (“you”, “your”, “client” or “user”).

The services we provide (the "Services") include money services such as issuing stored value and payment instruments, payment initiation services, as well as arranging custody and arranging deals in investments, all of which are strictly provided under a restricted Innovation Testing License (ITL) issued by the DFSA (referred here in as the "License").

This particular Disclosure ONLY relates to payment transfers / remittances made from the UAE to India under the License.

This Disclosure contains important regulatory, legal and operational information concerning:

1. the restricted and temporary nature of our Licence and the implications of operating within a regulatory testing environment;
2. limitations on certain DFSA requirements and client protections that may apply during the Testing Period;
3. your obligations to safeguard Payment Instruments and personalised security credentials;
4. mandatory reporting timelines and conditions applicable to unauthorised or incorrectly executed transactions;
5. the treatment of Stored Value and Payment Account balances, including the non-payment of interest and the absence of deposit protection;
6. applicable maximum Stored Value and transactional limits; and
7. the scope, role, and limitations of the payment initiation services we provide.

You are strongly encouraged to read this Disclosure carefully and in full before accessing or using the Services.

By accessing, registering for, or using the Services, you confirm that you have read, understood, and expressly accepted the contents of this Disclosure and acknowledge that your use of the Services is subject to the limitations and conditions described herein.

IMPORTANT DISCLOSURES

1. Restricted License – Testing Only: The Company is authorised under a restricted Innovation Testing License, which permits the provision of services solely for a testing period of 24 (twenty-four) months ("Testing Period"). Upon expiry of this Testing Period, the Company is required either to apply for and obtain an unrestricted License from the DFSA or to withdraw its License and discontinue its operations. The Services are therefore provided within a regulatory testing environment and may be subject to limitations or modifications in accordance with the DFSA-approved test plan.

2. Limitations in Client Protections: As the Company operates under a restricted License, certain DFSA requirements and client protection measures may not be fully applicable. Consequently, the rights available to you as a client may be more limited than those afforded to clients of firms holding a full and unrestricted DFSA licence. In the event that you incur a financial loss during the Testing Period, your ability to pursue redress may likewise be constrained. Clients should carefully consider these limitations before using the Services.

3. Reporting deadline for Unauthorized or Incorrectly Executed Transactions: If you believe that a transaction has been unauthorized or incorrectly executed, you must notify the Company without undue delay and in any event no later than six (6) months from the date of the transaction. Failure to notify the Company within the aforementioned timeline may result in the loss of your right to redress, reimbursement, correction or other remedial action, except where otherwise required under applicable law. Notification must be made in writing to compliance@aspora.com.

4. Interest and Return Disclosures: Any amounts held in Aspora's third-party accounts in connection with a Payment transfer are safeguarded under applicable laws.

5. Implications for clients: By accessing or utilizing the Company's Services, clients acknowledge and accept that they are engaging in a regulatory testing environment. Clients should consider carefully the restricted nature of the Company's License, the temporary status of the authorisation, and the limitations on rights and protections which may arise as a result of participation in Services offered during the Testing Period.

6. Commitment to Transparency: Notwithstanding the restricted scope of its authorisation, the Company affirms its commitment to transparency, good faith, and adherence to all conditions of its DFSA-approved test plan. The Company will ensure that clients are kept informed of any material developments relating to its regulatory status.

7. Further Information: Clients or prospective clients who require clarification regarding the nature of this Disclosure or the scope of the Company's authorisation may contact the Company directly at compliance@aspora.com.

8. Language of Communication: All communications between the Company and clients, including this Disclosure, contractual documentation, notices, statements, and ongoing correspondence, shall be conducted in the English language. By accessing or using the Services, you confirm that you understand and agree to receive all communications in English.

9. Disclosure: This Disclosure is issued pursuant to the requirements of the DFSA, and forms part of the conditions attached to the Company's restricted Innovation Testing License.

10. Service Availability: The Services described in these Terms reflect the scope of Financial Services the Company is authorised to provide under its License. However, not all Services, features, or functionalities may be available at all times. Certain Services may be introduced, modified, restricted, suspended, or withdrawn during the Testing Period in accordance with the Company's DFSA-approved Test Plan, regulatory requirements, operational considerations, or risk management policies.