Last Updated: December 25, 2025
1. GENERAL TERMS
1.1 DEFINITIONS
These Terms ("Terms") constitute a legal agreement between Roogoo Inc. ( "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 or USA 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 or USA 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
You acknowledge and agree that Roogoo reserves the right to adjust fees and risk control measures due to differences in card types, issuing banks, jurisdictions, policy changes, or market conditions. Please stay informed via platform announcements, user card guides, or instruction manuals.
5.1 FEE STRUCTURE
5.1.1 TRANSACTION-RELATED FEES
Transaction Fee: [X]% per transaction.
Cross-Border Fee: A currency conversion fee of [X]% for cross-border transactions.
Refund Processing Fee: Bank charges incurred by transaction refunds, at a rate of [X]% of the refund amount.
Decline Fee: Bank charges incurred by transaction failures due to insufficient card balance or transaction reversals.
Transaction Reversal Fee: Bank charges incurred by transaction cancellations (initiated by the user or merchant).
Dispute Handling Fee: Costs associated with bank intervention in cases of transaction disputes between the user and the merchant or payment platform.
Foreign Exchange (FX) Spread: Not exceeding [X]% of the transaction value.
Fiat-Stablecoin Spread: The price difference applied during the conversion between fiat currency and stablecoins for card top-ups and withdrawals.
5.1.2 MANAGEMENT OR USAGE FEES
Card Issuance Fee: Fee for applying for a virtual or physical card.
Card Cancellation Fee: Bank charges incurred upon the cancellation of a card.
Monthly Management Fee: A monthly management fee of $0.50 USD per card.
5.1.3 FEE WAIVERS OR REFUNDS
Roogoo may waive or refund certain fee items based on actual operational data.
Roogoo may waive or refund certain fee items based on the user's membership tier or benefits.
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 paying any fees, taxes, or blockchain network fees (Gas fees) charged by intermediary banks or third-party service providers.
5.4 COMPLIANCE VIOLATIONS AND TERMINATION OF CARD USAGE
Debt Recovery: If any of a user’s card accounts incur a debt or negative balance, Roogoo reserves the right, without prior notice, to deduct the corresponding amount directly from any other accounts under the user's name (including but not limited to Asset Accounts, other card accounts, and linked wallets) to offset the debt until the balance is cleared.
Risk Control Termination: In the event of multiple consecutive declines, repeated high-risk transactions, or any other behavior that triggers the risk control systems of Roogoo, the bank, or the card scheme, Roogoo and its partners reserve the right to suspend, freeze, or cancel the card. In such cases, the remaining balance will not be refunded.
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 or USA law.
11.2 DISPUTE RESOLUTION
Disputes will be resolved through arbitration at the Hong Kong or USA 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 or USA 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.