KYC and User Verification Policy

This KYC and User Verification Policy ("Policy") describes how [LEGAL ENTITY NAME] ("Nodal Pay", "we", "us") plans to verify the identity of people who register for and use the Nodal Pay platform. Nodal Pay is currently under development, and the verification steps described here are our planned approach rather than a description of a live process. This Policy should be read together with our Terms of Use, Privacy Policy and AML and Prohibited Activities Policy.

1. Purpose of this Policy

User verification is planned as a core part of how Nodal Pay is designed to work, for three reasons:

• Safety. Knowing that each account is linked to a real, identifiable person is designed to deter impersonation, account takeover and fraudulent deal making, and to make the Safe Deal Room a more trustworthy place to transact.
• Consent and clarity. Verification steps are planned to be carried out with your knowledge and consent, with clear in app explanations of what is being requested and why, consistent with the Digital Personal Data Protection Act 2023 and the Information Technology Act 2000.
• Readiness for applicable law. Payment services in India are regulated. The final payment and fund handling structure for Nodal Pay will depend on applicable law and on arrangements with regulated payment partners, and those arrangements are expected to carry their own know your customer ("KYC") requirements, including applicable RBI regulations. This Policy is designed to prepare users for those requirements.

2. Planned verification layers

Nodal Pay is being designed with layered verification, so that the checks applied to an account are proportionate to how the account is used.

2.1 Registered mobile number

At sign up, every user is expected to register a mobile number and confirm control of it through a one time password (OTP). The registered mobile number is planned to serve as the primary account identifier on the platform: it is how other users will find you (see Section 4) and how important account notifications are expected to be delivered. Keeping your registered number active and accessible is expected to be a condition of continued use.

2.2 Identity verification

Beyond the registered mobile number, additional identity verification steps may be required. Whether and when these steps apply is expected to depend on:

• the value or volume of transactions you initiate or receive, and any transaction limits that apply to your account;
• requirements under applicable law; and
• the requirements of the regulated payment partners through whom payments are ultimately processed.

Identity verification may involve confirming your legal name, date of birth and other identifying details against officially valid documents, and may include additional steps such as a photograph or liveness check where required. The exact steps, thresholds and methods have not been finalised and will be published before launch.

3. Documents that may be requested

Where identity verification is required, you may be asked to provide one or more officially valid documents as defined under applicable law, or details from them. Generically, requests may cover:

• proof of identity;
• proof of address; and
• for users transacting in the course of business, documents relating to the business or organisation, where applicable law or a payment partner requires them.

We do not promise that any particular document will be accepted, that verification will complete within a particular time, or that a given document alone will be sufficient. Acceptance criteria are expected to follow applicable law and the requirements of regulated payment partners, and may change.

4. Masked identity display

Nodal Pay is being designed to balance verification with privacy:

• Exact number search. Users are planned to be findable only by their exact registered mobile number. There is no planned facility to browse, list or partially search for users.
• Limited profile exposure before acceptance. Before you accept a deal invitation, the other party is expected to see only a limited, partially masked view of your profile, enough to confirm they have reached the right person, and no more. Fuller deal details are planned to become visible only after both parties agree to proceed.

Verification documents themselves are never intended to be visible to other users.

5. When verification may be re performed

Verification is not expected to be a one time event. We may ask you to repeat or refresh verification steps, for example when:

• you change your registered mobile number or other core account details;
• your transaction activity crosses a limit or changes in a way that requires a higher tier of verification;
• we detect signs of unauthorised access, unusual activity, or a mismatch in the information we hold;
• applicable law or a regulated payment partner requires periodic re verification or updated documents; or
• a document you previously provided expires or is found to be invalid.

6. If verification fails or is refused

If a required verification step fails, cannot be completed, or is refused, we may, depending on the circumstances and on applicable law:

• limit the features available to your account, including the ability to create, accept or complete deals;
• restrict, pause or decline transactions, including holding a transaction pending completion of verification;
• suspend or close the account where verification cannot be completed within a reasonable period; and
• take further steps required under the AML and Prohibited Activities Policy or applicable law.

Where funds are affected by a verification hold, their treatment will follow applicable law, the arrangements with regulated payment partners, and our Refund and Cancellation Policy. If you believe a verification decision is wrong, you can raise it under our Grievance Redressal Policy.

7. Your accuracy obligations

You are expected to:

• provide information and documents that are true, current, complete and your own;
• keep your registered details up to date, and tell us promptly if any verified detail changes; and
• not open or operate an account on behalf of another person, or allow another person to pass verification using your identity.

Submitting false, forged or misleading information is a serious breach of the Terms of Use and the Acceptable Use Policy, and may lead to account closure and reporting where required by applicable law.

8. How verification data is handled

Information and documents collected for verification are personal data. They are planned to be collected only to the extent needed, used only for the purposes described in this Policy and required by applicable law, and protected and retained in line with our Privacy Policy and Data Retention and Deletion Policy. Where applicable law or a regulated payment partner requires verification records to be kept for a minimum period, that requirement will govern retention even after an account is closed.

9. Important status note

Nodal Pay is under development and is not yet live. The final KYC and verification requirements, including which checks apply, at what limits, and through which regulated payment partners, will be determined by applicable law and the regulated partner arrangements we put in place, and will be published before launch. Nothing in this draft is a representation that any regulatory approval, registration or partnership currently exists.

10. Contact

Questions about this Policy or about planned verification steps can be sent to [SUPPORT EMAIL]. You can also visit our Help Centre or see the Contact page for other ways to reach us.