Acceptable Use Policy

1. Purpose

This Acceptable Use Policy ("AUP") sets out the rules governing how users may interact with the ArosaPay platform, including all payment processing, communication, and account-related activities.

This AUP forms part of, and is incorporated by reference into, the Terms of Service. Where this AUP conflicts with the Terms of Service, the Terms of Service prevail unless this AUP explicitly states otherwise. Violation of this AUP constitutes a breach of the Terms of Service.

ArosaPay reserves the right to determine, in its sole discretion, whether any activity violates this policy. Users are responsible for ensuring that their use of the platform complies with all applicable laws and this AUP at all times.

2. Permitted Use

The ArosaPay platform may be used for:

• Processing lawful commercial transactions between Buyers and Merchants.
• Securing funds for goods and services transactions governed by the Transaction State Machine.
• Communicating with counterparties regarding active transactions.
• Submitting and responding to disputes through the platform's resolution process.
• Managing account settings, payout preferences, and verification documents.
• Accessing transaction records, receipts, and reporting tools.

All platform use must be for bona fide commercial purposes. The platform is not designed for personal transfers, charitable donations, or peer-to-peer lending unless explicitly supported by a designated product feature.

3. Prohibited Activities

The following activities are strictly prohibited on the ArosaPay platform:

Financial Crime

• Fraud, including misrepresentation of goods, services, identity, or transaction details.
• Money laundering or structuring transactions to evade reporting thresholds.
• Financing of terrorism or providing material support to designated entities.
• Violations of applicable sanctions, including those imposed by the UN, EU, OFAC, or Kenyan authorities.
• Tax evasion facilitated through the platform.

Illegal Commerce

• Transactions involving counterfeit, pirated, or stolen goods.
• Sale or distribution of illegal substances, including controlled narcotics.
• Transactions for goods or services that violate applicable law in any relevant jurisdiction.
• Unlicensed financial services, including unregistered lending, insurance, or securities offerings.

Platform Abuse

• Attempting to circumvent platform controls, fees, or security measures.
• Exploiting system vulnerabilities, bugs, or errors for personal gain.
• Interfering with platform infrastructure, including denial-of-service attempts.
• Reverse engineering, decompiling, or disassembling any part of the platform.

4. Prohibited Content

The following categories of goods and services may not be listed, advertised, or transacted through the ArosaPay platform:

• Weapons, firearms, ammunition, explosives, or their components.
• Controlled substances, recreational drugs, or drug paraphernalia.
• Stolen property or goods obtained through unlawful means.
• Regulated substances requiring specific licenses (pharmaceuticals, chemicals) without valid documentation.
• Human remains, organs, or body parts.
• Wildlife products protected under CITES or Kenyan wildlife law.
• Gambling services not licensed under applicable law.
• Sexually explicit material involving minors (zero tolerance).
• Content that incites violence, hatred, or discrimination based on protected characteristics.

Merchants operating in regulated industries (e.g., licensed pharmaceuticals, licensed alcohol distribution) must provide valid licenses upon request. Failure to produce required documentation within 48 hours of request may result in immediate account suspension.

5. Transaction Integrity

All transactions must represent genuine commercial exchanges. The following manipulations are prohibited:

• Shill transactions — creating fictitious transactions to inflate volume, ratings, or trust metrics.
• Fake disputes — filing disputes without legitimate basis to delay payouts or extract concessions.
• Price manipulation — artificially inflating or deflating transaction amounts for non-commercial purposes.
• Collusion — coordinating with counterparties to manipulate dispute outcomes, ratings, or platform metrics.
• Wash trading — executing transactions where the Buyer and Merchant are the same beneficial owner.
• Structuring — splitting transactions to avoid monitoring thresholds or fee tiers.

ArosaPay employs automated monitoring to detect patterns indicative of transaction manipulation. Suspicious activity may trigger automated holds, manual review, or referral to the fraud investigation team.

6. Account Conduct

Users must maintain the integrity of their accounts at all times:

Identity & Authentication

• Each individual or entity may maintain only one account unless explicitly authorized by ArosaPay.
• Account information must be accurate, complete, and kept up to date.
• Identity misrepresentation, including the use of fictitious identities or impersonation, is prohibited.
• Account credentials must not be shared with, or transferred to, third parties.

Automated Access

• Automated access to the platform (bots, scrapers, scripts) is prohibited unless using official ArosaPay APIs.
• API access must comply with published rate limits and usage policies.
• Automated tools must not be used to circumvent platform controls or create artificial load.

7. Communication Standards

All communications conducted through the ArosaPay platform — including transaction messages, dispute submissions, and support interactions — must adhere to the following standards:

• No harassment, threats, intimidation, or abusive language directed at any user, counterparty, or ArosaPay staff.
• No spam, unsolicited advertising, or promotional content unrelated to active transactions.
• No phishing attempts, social engineering, or attempts to obtain credentials or personal information from other users.
• No impersonation of ArosaPay staff, administrators, or other users.
• No transmission of malware, viruses, or malicious code through platform messaging or file uploads.

ArosaPay may monitor platform communications for compliance with these standards. Evidence of communication violations may be used in dispute resolution and enforcement proceedings.

8. Reporting Violations

Users who observe or suspect violations of this AUP are encouraged to report them promptly.

How to Report

• Email: Send reports to compliance@arosapay.com with relevant transaction IDs and supporting evidence.
• In-app: Use the report function available on transaction detail and user profile pages.
• For urgent matters involving active fraud or safety concerns, contact support@arosapay.com.

Whistleblower Protections

ArosaPay does not retaliate against users who report violations in good faith. Reports may be submitted anonymously where permitted by applicable law. ArosaPay will make reasonable efforts to protect the identity of reporters, subject to legal obligations.

False or malicious reports — including reports intended to harass counterparties or manipulate dispute outcomes — are themselves violations of this AUP.

9. Enforcement & Consequences

ArosaPay applies graduated enforcement based on the severity, frequency, and intent of violations:

Enforcement Actions

• Warning — written notice identifying the violation and required corrective action.
• Feature restriction — temporary limitation of specific platform capabilities (e.g., transaction limits, payout holds).
• Account suspension — temporary suspension of account access pending investigation.
• Account termination — permanent closure of the account with forfeiture of platform privileges.
• Fund holds — retention of funds pending investigation or resolution of suspected violations.
• Referral to authorities — reporting of suspected criminal activity to relevant law enforcement or regulatory bodies.

Due Process

Where feasible and not contrary to legal obligations, ArosaPay will notify users of enforcement actions and provide an opportunity to respond before permanent measures are applied. However, ArosaPay reserves the right to take immediate action without notice where there is reasonable suspicion of fraud, financial crime, or imminent harm.

Enforcement decisions are made at ArosaPay's sole discretion and are final, except where applicable law provides otherwise. Users may appeal enforcement decisions by contacting legal@arosapay.com within 30 days of the enforcement action.

10. Changes to This Policy

ArosaPay may amend this Acceptable Use Policy at any time. Material changes will be communicated through one or more of the following channels:

• Email notification to the address associated with your account.
• In-app notification upon next login.
• Prominent notice on the ArosaPay website.

Continued use of the platform after the effective date of any amendment constitutes acceptance of the revised policy. If you do not agree with any changes, you must discontinue use of the platform and close your account.

The current version of this policy is always available at arosapay.com/acceptable-use. Previous versions are available upon request by contacting legal@arosapay.com.