Platform Universal Payment & Funds Compliance Policy

Effective Date: -06-01 | Scope of Application: All services on

This Platform Universal Payment & Funds Compliance Policy (hereinafter referred to as the "Policy") applies to all transactions and service purchases made by users on (hereinafter referred to as the "Platform"). This Policy aims to standardize payment processes, ensure fund security, and strictly fulfill statutory obligations regarding anti-money laundering (AML) and judicial cooperation. Clauses involving prohibited conduct, account freezing, and judicial cooperation are highlighted in bold or underlined. Please read them carefully.

I. Supported Payment Methods & Operational Standards

1. Online Payment

• Supported Channels: Alipay, WeChat Pay, UnionPay QuickPass; Visa, MasterCard, PayPal, and Apple Pay for cross-border transactions.
• Real-time Confirmation: Online payment orders are typically synchronized within 3 seconds. If payment is successful but the order status is not updated, please retain your payment receipt and contact customer service. Do not make duplicate payments.
• Transaction Limits: Single/daily transaction limits are set by the issuing bank or third-party payment provider and cannot be adjusted by the Platform. For large orders, we recommend testing your limit in advance or using bank transfer.

2. Bank Transfer / Corporate Remittance

• Applicable Scenarios: Enterprise procurement, bulk services, high-value top-ups, or when online payment is restricted.
• Processing Time: Domestic same-bank transfers are usually instant; cross-bank transfers take 1-3 business days. Cross-border SWIFT remittances take 3-7 business days. Service activation occurs only after financial reconciliation based on actual bank credit time.
• Reference Requirement: You must include "Order No. + Payer Name" in the transfer remarks. The payer shall bear any service delays or refund handling fees caused by failure to provide proper references.
• Same-Name Principle: The corporate bank account name must match the registered entity on the Platform. Third-party payments require a pre-submitted "Payment Authorization Letter" and identity documents from both parties.

3. Other Payment Methods

• Digital Yuan (e-CNY): Payments via e-CNY wallets from authorized operators (ICBC, ABC, BOC, etc.) are accepted with settlement validity equivalent to fiat currency.
• Credit Payment / Installments: Approved users may use "Buy Now, Pay Later" or installment services. Specific quotas, rates, and overdue rules are subject to the separate "Credit Payment Agreement".
• Offline POS / On-site Payment: Available only at official Platform-operated outlets with an officially stamped receipt issued on-site. The Platform does not recognize payments collected by unofficial outlets or individuals; related losses are borne solely by the user.

4. Exchange Rates & Taxes

• Cross-border exchange rates are based on the real-time settlement rate of the payment gateway. The Platform assumes no responsibility for exchange rate fluctuations.
• Unless otherwise stated, all listed prices are tax-inclusive. For VAT special invoices, accurate billing information must be provided before payment. Any tax differential arising from retroactive issuance of special invoices shall be borne by the user.

II. Anti-Money Laundering & Legitimacy of Funds Declaration

1. Zero Tolerance Stance: The Platform strictly prohibits the use of any payment channel for money laundering, terrorist financing, tax evasion, gambling, telecom fraud, illegal fundraising, pyramid schemes, or other criminal activities. Upon discovery or reasonable suspicion, the Platform will immediately impose control measures and report to regulatory authorities.
2. Know Your Customer (KYC): Users must cooperate with the Platform in completing real-name verification, beneficial ownership identification, and transaction background verification. The Platform reserves the right to restrict or terminate payment functions if users refuse to provide information, submit false information, or frequently change key identity details.
3. Suspicious Transaction Monitoring: The Platform deploys an intelligent risk control system to automatically flag and manually review the following scenarios:
   • Frequent small-amount tests followed by sudden large transactions within a short period;
   • Payer has no reasonable connection to the registered entity and cannot justify third-party payment;
   • Transaction amount, frequency, or geography significantly deviates from the user's historical behavior or business scale;
   • Immediate withdrawal or transfer after converting anonymous virtual currencies into fiat;
   • Other circumstances meeting the "Measures for Reporting Large-Value and Suspicious Transactions by Financial Institutions" and the latest AML regulatory guidelines of .
4. Guarantee of Fund Legitimacy: Users warrant that all funds used for payment originate from lawful business activities or legitimate income and do not involve proceeds of crime. If the Platform's accounts are frozen, deducted, or subjected to administrative penalties due to illegal fund sources, the user shall fully indemnify the Platform for all resulting losses (including but not limited to fines, legal fees, and reputational damage).

III. Obligations to Cooperate with Public Security & Judicial Authorities

1. Mandatory Cooperation: The Platform will unconditionally cooperate with public security organs, procuratorates, people's courts, state security organs, supervisory commissions, tax authorities, customs, and other competent authorities in investigations and evidence collection in accordance with law.
2. Data Retrieval Scope: Cooperation includes but is not limited to: user registration data, login logs, IP addresses, device fingerprints, transaction records, payment vouchers, chat histories, contract texts, invoice records, and other electronic data stored on the Platform.
3. Account Control Execution: Upon receipt of legal documents such as "Notices of Assistance in Inquiry/Freezing/Deduction" issued by competent authorities, the Platform will execute account inquiries, fund freezes, deductions, or transaction restrictions within the statutory timeframe without prior notice to or consent from the user.
4. Confidentiality & Immunity: The Platform bears confidentiality obligations regarding judicial cooperation and shall not disclose investigation details to users or third parties. The Platform assumes no liability for breach of contract or tort arising from service interruption, fund freezing, or data disclosure resulting from lawful judicial cooperation.
5. User Remedies: Users objecting to judicial control measures shall file appeals or reconsideration directly with the issuing authority. The Platform acts solely as an assisting party and has no authority to lift controls or adjudicate disputes independently.

IV. Prohibition of Illegal Activities Using the Platform

1. List of Prohibited Conduct: Users shall not use the Platform's payment functions or service interfaces to engage in the following:
   • Fabricating transactions for cash-out, fake order inflation, or fraudulently obtaining platform subsidies/coupons;
   • Providing collection/disbursement or fund aggregation services for illegal trading platforms, gambling sites, or pornographic platforms;
   • Circumventing large transaction reporting or risk control thresholds through order splitting or multi-account operations;
   • Impersonating others' identities, bank cards, or payment accounts for transactions;
   • Conducting malicious attacks, data scraping, or API abuse via automated scripts;
   • Other acts violating the Criminal Law, Anti-Telecom Network Fraud Law, Cybersecurity Law, and latest regulations of .
2. Violation Disposal Measures: Upon discovery or reasonable suspicion of the above conduct, the Platform may, depending on severity, take one or more of the following measures:
   • Suspend payment functions, restrict withdrawals, or freeze account balances;
   • Cancel incomplete orders, revoke granted benefits, or recover unjust enrichment;
   • Permanently ban accounts and add to the Platform blacklist;
   • Report to public security organs, the PBOC Anti-Money Laundering Center, or industry self-regulatory organizations;
   • Initiate civil litigation for damages or assist criminal investigations by providing evidence.
3. Liability Exemption: All consequences arising from user violations—including account controls, fund losses, service termination, or legal liabilities—are borne solely by the user. The Platform assumes no compensation liability for compliance control measures taken.

V. Refunds, Disputes & Policy Amendments

1. Refund Principles: Refunds are returned via the original payment method. If the original account is canceled or frozen, users must provide a same-name bank account and written explanation. Refund processing takes 3-15 business days depending on the payment channel.
2. Suspicious Refund Restrictions: When an order or account is under AML investigation, judicial freeze, or risk control review, the Platform reserves the right to suspend all refund operations until the investigation concludes or controls are lifted.
3. Dispute Resolution: Disputes arising from payment or fund compliance issues shall be subject to the jurisdiction stipulated in the User Service Agreement (People's Court with jurisdiction in Zhongshan City, Guangdong Province).
4. Policy Amendments: The Platform may amend this Policy based on legal updates, regulatory changes, or risk control adjustments. Amended versions will be published on the website/app with effective dates marked. Continued use of payment services after amendments take effect constitutes acceptance of all revised content.

Appendix: Payment Methods & Compliance Key Points Reference Table

Disclaimer: This Policy text is designed according to the latest AML, anti-fraud, and payment regulatory standards as of June . However, local public security organs and PBOC branches may differ in suspicious transaction identification criteria and judicial assistance execution details. Before official launch, it is mandatory to file and communicate with the local PBOC AML department and the Public Security Bureau Cybersecurity Division to ensure full compatibility with local enforcement practices.