1. GENERAL TERMS
1.1 DEFINITIONS
These Terms ("Terms") constitute a legal agreement between Roogoo ( "Roogoo", "we") and you ("Client", "you"), governing your use of our money services ("Services"), including payment processing, foreign exchange, and related technology products.
AML Laws: Anti-money laundering, counter-terrorist financing, and sanctions regulations (e.g., AMLO, UN Security Council sanctions).
CDD (Customer Due Diligence): Procedures to verify identity, business registration, and Ultimate Beneficial Owners (UBOs).
Multi-Currency Account: A virtual account for holding funds in USD, EUR, HKD, etc., with segregated storage at licensed financial institutions.
1.2 LEGAL BINDING
By registering for or using the Services, you confirm your agreement to these Terms, which, together with our Privacy Policy and Fee Schedule, form a legally binding contract.
2. ELIGIBILITY AND REGISTRATION
2.1 CLIENT REQUIREMENTS
You must be a legally registered business entity (e.g., limited company, partnership) for commercial use only.
Individual users are eligible only for trial services with limited functionality, subject to Roogoo's approval.
2.2 KYC AND CDD PROCEDURES
Provide valid business registration documents, UBO identification (for 25%+ ownership), and other information as required for AML compliance.
Failure to provide accurate information may result in account suspension.
3. SERVICE OPERATIONS
3.1 SERVICE SCOPE
Roogoo provides regulated money services including:
Payment collection and payout for registered entities.
Foreign exchange dealing for non-speculative purposes.
Business payment administration (e.g., invoicing, fund distribution).
3.2 MULTI-CURRENCY ACCOUNT
Support for transactions in USD, EUR, HKD, and other currencies at Roogoo's discretion.
Funds are held in segregated accounts with licensed financial institutions and do not bear interest.
3.3 PAYMENT OPERATIONS
Inbound Payments: Provide verified payment credentials; Roogoo may screen transactions for regulatory compliance.
Outbound Payment Orders: Specify payee details (including invoices for third-party transactions). Processing times typically range from 1–15 Business Days.
3.4 PROHIBITED USES
Do not use Services for:
Transactions over HK$120,000 without updated CDD information.
Activities involving sanctioned parties or restricted lists.
Stored value functions, deposit-taking, or illegal purposes (see Schedule I).
4. COMPLIANCE OBLIGATIONS
4.1 IDENTITY VERIFICATION
Individuals: Valid Hong Kong Identity Card/passport and proof of address.
Entities: Business registration certificate, articles of association, and UBO documentation.
Provide transaction-specific documents for high-value (over HK$120,000) or suspicious transactions.
4.2 SANCTIONS SCREENING
Roogoo screens all customers against:
UN Security Council sanctions lists.
Hong Kong Monetary Authority restricted parties databases.
Other regulatory blacklists as required by law.
4.3 AML/CTF OBLIGATIONS
You warrant that:
Funds derive from lawful sources and do not involve politically exposed persons (PEPs) without prior disclosure.
You will promptly report changes to UBO information or business structure.
4.4 SUSPICIOUS TRANSACTION REPORTING
Roogoo may suspend services and report to the Joint Financial Intelligence Unit (JFIU) if:
Transactions appear to involve money laundering or terrorist financing.
You fail to provide required CDD information within 2 Business Days.
5. SERVICE FEES AND PAYMENT PROCEDURES
5.1 FEE STRUCTURE
Transaction Fees: Outlined in our public Fee Schedule, based on currency, amount, and service type.
Foreign Exchange Spread: Not exceeding [X]% of transaction value.
Monthly Maintenance Fees: Roogoo charges a monthly maintenance fee of 1 USD for accounts with asset valuations below 20 USD for three consecutive months and no deposit or transaction activities. This fee will continue to be charged until the account balance reaches 0 USD, at which point the service will be terminated.
5.2 FUNDS PROCESSING
All funds are segregated from Roogoo's operational funds and held in Hong Kong-licensed financial institutions.
Roogoo may adjust fees with 30 days’ notice; unpaid fees may result in service suspension.
5.3 THIRD-PARTY FEES
You are responsible for any fees charged by correspondent banks or third-party service providers.
6. DATA PROTECTION AND PRIVACY
6.1 PERSONAL DATA COLLECTION
For AML/CTF compliance, we collect:
Name, date of birth, identification numbers, and business registration details.
Transaction history (retained for at least 5 years as required by AMLO).
6.2 PDPO COMPLIANCE
Your data will not be used for direct marketing without explicit consent.
Access or correct your data by contacting our Data Protection Officer at [email protected] .
7. ACCOUNT SECURITY
7.1 ACCESS CONTROL
You are responsible for maintaining the confidentiality of account credentials.
Notify Roogoo immediately of unauthorized access or security breaches.
7.2 Roogoo LIABILITY
Roogoo is not liable for unauthorized access due to your negligence.
8. TERMINATION AND SUSPENSION
8.1 CLIENT TERMINATION
You may terminate these Terms with 30 days’ written notice, provided no outstanding transactions exist.
8.2 Roogoo TERMINATION/SUSPENSION
We may terminate or suspend services immediately if:
You fail to comply with AMLO or CDD requirements.
Transactions are flagged as high-risk by our AML system.
You are listed on regulatory sanctions lists.
You engage in fraudulent activity or prohibited uses.
Your account is inactive for over 12 months.
8.3 POST-TERMINATION PROCEDURES
Funds will be refunded after deducting outstanding fees and withholding amounts for potential disputes (up to 180 days).
9. LIABILITY LIMITATION
9.1 DAMAGES EXCLUSION
Roogoo’s liability is limited to the aggregate fees paid by you in the 12 months prior to the claim.
We are not liable for indirect losses (e.g., lost profits, third-party disputes).
10. INTELLECTUAL PROPERTY
10.1 LICENSE GRANT
Roogoo grants you a non-exclusive, revocable license to use the platform for Service-related purposes.
10.2 RESTRICTIONS
You may not modify, reverse-engineer, or reproduce Roogoo’s technology without prior written consent.
11. GOVERNING LAW AND DISPUTE RESOLUTION
11.1 LEGAL FRAMEWORK
These Terms are governed by Hong Kong law.
11.2 DISPUTE RESOLUTION
Disputes will be resolved through arbitration at the Hong Kong International Arbitration Centre.
12. COMPLAINTS HANDLING
Submit complaints to our Compliance Department at [email protected].
We will acknowledge within 5 Business Days and provide a written response within 30 days.
Unresolved complaints may be referred to the Hong Kong Customs and Excise Department.
13. SCHEDULE I: PROHIBITED ACTIVITIES
Arms, nuclear, or defense-related transactions.
Gambling, pornography, or illegal substances.
Money laundering, terrorist financing, or unregulated financial services.
Counterfeit goods or fraudulent businesses.
Transactions with sanctioned parties or entities on restricted lists.