GetTransfer Know Your Client Policy

1. TERMS

Company - GETTRANSFER LTD, the company registered at 57 Spyrou Kyprianou, Bybloserve Business Center, 2nd floor, 6051, Larnaca, Cyprus, and its payment agents and services operators, as they are defined in the Agreements.

Agreement – GetTransfer Service License Contract or GetTransfer Service Agreement or GetTransfer Service Partnership Agreement, or any other kind of a partnership agreement entered into by the Company. Valid versions of the mentioned documents are available at gettransfer.com

User – any person, providing information in connection with the use of GetTransfer.com Service, including: users, passengers, Carriers (including any representatives, employees and drivers thereof), corporate clients (partners), while using the Service via the website, mobile applications, any additional functions and services throughout the world.

Suspicious Transaction – any User action at GetTransfer.com service, including, but not limited to, placing Requests or Offers in order to conclude a Transportation Contract for Transfer provision.

Unless this Policy expressly states otherwise, any terms used herein, shall have meaning determined in Agreements.

2. INTRODUCTION

2.1. This GetTransfer.com Know Your Client Policy (the “Policy”) has been developed as part of the implementation of the recommendations of the FATF (Financial Action Task Force on Money Laundering) aimed at combating financial abuse, to identify and prevent violations of legislation, and to comply with the legislation on money laundering and terrorism funding, sanction compliance and the User verification.

2.2. This Policy is open and forms an integral part of any Agreement between the Company and the User. The content of this Policy is disclosed without limitation at the request of any concerned parties. At the same time, the Company shall not inform Users and other individuals about the measures taken to counteract the legalization (laundering) of proceeds from crime, the financing of terrorism, the financing of the proliferation of weapons of mass destruction, and the compliance with the sanctions imposed by Cyprus and EU authorities except as provided for by applicable law and this Policy.

2.3. In case of non-compliance of certain provisions of this Policy with any provisions of the Agreement, the provisions of this Policy shall apply unless otherwise follows from the essence of the obligation. This circumstance does not result in the invalidity of other provisions of those documents.

3. OBJECTIVES

To establish the identity of the Users.
To understand the nature of the Users’ activities and ensure that they are legitimate.
To assess the potential risks of illegal activities associated with the Users’.
To comply with the regulatory requirements set forth by EU and Cyprus authorities.

4. SCOPE

4.1. This Policy applies to the Company and all partners of the Company, including payment agents, regional service operators and Company Users. It covers all aspects of client interactions, including client onboarding, ongoing monitoring, and reporting of suspicious activities.

5. USERS’ GUARANTEES AND OBLIGATIONS

5.1. Each User guarantees the legal origin, legal possession, and the right to use or to manage the funds transferred to the Company as the Transfer Prices or on any other grounds. Each User guarantees that he has the necessary and sufficient grounds to carry out independent activities related to commercial transactions for booking or offering Transfers through the Service, or make payments to the Company under any other agreements (including loyalty or other corporate programs). The Company requests the Users to comply with the registration and verification procedures, which may differ for certain User types and may be changed from time to time at the Company’s discretion.

5.2. Each User assumes the following obligations:

5.2.1. Comply with legal regulations, including international, aimed at combating illegal trading, financial fraud, and money laundering.

5.2.2. Avoid direct or indirect complicity in illegal financial activities and any other illegal transactions.

5.2.3. Avoid direct or indirect complicity in financial fraud and other actions contrary to international law and legal regulations.

5.2.4. Avoid in its practical activity the use of the Company's services in any actions that may directly or indirectly harm the effort to fight money laundering.

6. USER IDENTIFICATION

6.1. During the User’s registration, verification or during an investigation, according to this section of the Policy, the Company shall have the right to ask the User to provide identification documents (passport, identity card, registration as a legal entity or individual entrepreneur, powers of a representative (contact person), availability of licenses for passenger transportation, operator or similar activities, availability of driver's licenses and/or licenses for cars registered in the Service, etc.), documents confirming the place of residence, payment, and other documents and bank cards confirming the legal possession and legal origin of funds, and any other documents required by the Company due to applicable, including international, legal regulations and legislation.

7. RISK RECOGNITION

7.1. If any suspicious operations are detected, the Company shall have the right to immediately and unilaterally:

Refuse to carry them out for the User;
Limit or stop the payments to or from the User by any means, at the Company's discretion;
Close the access to the User's Personal Account for the period of investigation;
Terminate the Agreement with the User and refuse to provide access to GetTransfer.com to such User in prospect;
Perform other actions that the Company deems necessary and sufficient to comply with this Policy and applicable legal regulations and legislation.

This list is not exhaustive and may be expanded at the Company's discretion.

7.2. The refusal to process Suspicious Transactions and the termination of the Agreement with the User in connection with the Company's identification of Suspicious Transactions shall not be considered as grounds for the Company's civil liability for breach of the Agreement.

7.3. The Company has the right to close access to the User's Personal Account if the User does not have any transactions on the User's account for 12 (twelve) consecutive months.

8. SUSPICIOUS TRANSACTIONS CRITERIA AND EFFECTS

8.1. The Company may deem a transaction suspicious if:

The User regularly cancels agreed Transfers (in particular, the User has more cancellations than completed Transfers, or the User makes several cancellations in a row).
User’s Requests or Offers make no obvious economic sense or have no obvious legitimate purpose is discovered (i.e. the User sends Request as a passenger and accepts it as a carrier, or accepts several Requests for the same date and time).
The User uses GetTransfer.com Service and/or Transfers not in good faith or in an abusive manner.
Circumstances suggesting that use GetTransfer.com Service and/or Transfers for the purpose of money laundering, or funding terrorism, or sanctions evasion are discovered.
The User does not provide the identification information specified by the Company, provides inaccurate information, and/or cannot be reached at the addresses and telephone numbers indicated.
The User did not provide identification information for the beneficiary, i.e. the person for whose benefit the User is acting (inter alia, on the basis of the agency agreement or booking transfers for the corporate clients).
Counterfeit or invalid documents and documents of substandard quality (black and white, unreadable) are provided for identification.
The User did not provide identification information at the request of the Company, including information for the beneficial owner(s) and/or affiliates of the User.
The User is on international and/or other wanted list or data about the User and/or User’s payment sources received by the Company through verification process indicates that the User does not possess money sources legally or money sources are used for illegal purposes.

8.2. The criteria for identification and attributes of Suspicious Transactions specified in this section of the Policy are not exhaustive. The Company may deem a User’s transaction suspicious on the basis of an analysis of the nature of the transaction, its components, attendant circumstances, and interaction with the User or his representative, even without the formal criteria and attributes described herein.

8.3. If Suspicious Transactions are discovered, the Company decides on its own on further actions in relation to the User, his Personal Account, and his transactions.

9. RESPONSIBLE OFFICER

9.1. The Company’s Director is responsible for overseeing the implementation and enforcement of this Policy (the “Responsible Officer”). The Responsible Officer will ensure that the Company remains compliant with all relevant KYC regulations and will serve as the point of contact for any inquiries or issues.

10. TRAINING AND AWARENESS

10.1. The Company will provide regular training to employees on KYC regulations and the Company's identification and verification procedures. The training program will ensure that employees understand their responsibilities and the importance of adherence to this Policy.

11. REVIEW AND UPDATES

11.1. This Policy will be reviewed and updated periodically to ensure its effectiveness and compliance with current regulations. Any changes to the Policy will be communicated to all relevant employees and stakeholders.

12. CONCLUSION

12.1. By implementing this Policy, the Company aims to protect its clients, itself, and the integrity of the global financial system.

12.2. The Company will consider non-compliance of this Policy as a serious matter warranting disciplinary action, up to and including dismissal, where allowable by law. Violations of KYC regulations can also have legal consequences for individuals involved.