Terms of Service

Terms and conditions for companies, partnerships, and other legal

1 Introduction

These Business Terms of Service ("Terms") apply if you are opening or using a Jillionpay account on behalf of a company, partnership, sole proprietorship, or other legal entity ("Customer", "you", "your"). If you are an individual using our services for personal purposes, please refer instead to our Individual Terms of Service.

These Terms form a legally binding agreement between the Customer and JILLION GROUP INTERNATIONAL TRADING LIMITED, trading as Jillionpay ("Jillionpay", "we", "us", "our").

The individual accepting these Terms on the Customer's behalf confirms that they have authority to bind the Customer, and that the Customer has read, understood, and agrees to these Terms, our Privacy Policy, and our Cookie Policy.

2 Eligibility and Representations

By accepting these Terms, the Customer represents and warrants on a continuing basis that:

• it is duly incorporated or established, validly existing, and in good standing under the laws of its jurisdiction of formation;
• entering into and performing under these Terms does not breach its constitutional documents or any law applicable to it;
• it is not, and none of its directors, officers, ultimate beneficial owners, or authorised signatories are, subject to sanctions administered by the United Nations, Hong Kong, or any other authority applicable to us;
• it will not use our services for, or in connection with, virtual asset or cryptocurrency-related activity of any kind; and
• all information provided to us, including in respect of its beneficial ownership and control structure, is true, accurate, and complete, and will be kept up to date.

3 Sanctions

The Customer represents and warrants, on a continuing basis, that neither the Customer, nor any of its directors, officers, authorised signatories, or ultimate beneficial owners:

We screen the Customer, its principals, its transactions, and its counterparties against sanctions lists on an ongoing basis. We may block, delay, or reject a transaction, or suspend or close the Customer's account, without liability to us, where we reasonably believe it may involve a sanctioned person, country, or territory. Because this reflects external law rather than our own policy choice, we may update the countries and lists referred to in this Section without amending these Terms.

• is named on a sanctions, asset-freeze, or watch list maintained by the United Nations, Hong Kong, the United States (including OFAC), the European Union, the United Kingdom, or any other authority applicable to us;
• is incorporated, organised, or ordinarily resident in a country or territory subject to comprehensive sanctions (currently including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine, as such list may change from time to time); or
• intends to use our services in a manner that would breach sanctions, export control, or anti-terrorist-financing laws administered by any of these authorities.

4 Prohibited Industries and Activities

We do not provide our services to the Customer, and the Customer must not use our services, in connection with any business or activity involving:

We may decline to onboard the Customer, decline to process a transaction, or may suspend or close the Customer's account, if we reasonably believe the Customer's business relates to a prohibited industry or activity listed in this Section, whether or not this was disclosed to us at onboarding.

• virtual assets, cryptocurrency, or crypto-asset exchange, custody, trading, or transfer of any kind;
• adult content or adult entertainment services;
• gambling, betting, lottery, or gaming services, other than where operated under a valid Hong Kong licence and disclosed to us in advance;
• weapons, ammunition, military or paramilitary equipment, or related brokering services;
• counterfeit or unauthorised goods, or the infringement of third-party intellectual property rights;
• unlicensed money services, unlicensed remittance, or unlicensed deposit-taking of any kind;
• shell banks, bearer share companies, or structures where the Customer's beneficial ownership cannot be reliably traced;
• pyramid schemes, multi-level marketing structures that primarily reward recruitment rather than the sale of genuine goods or services, or unregistered investment or securities schemes; and
• any other business or transaction that falls outside our risk appetite, having regard to our own policies, our banking partners' policies, or the policies of participants in the payment networks we rely on.

5 Corporate Due Diligence

Before onboarding, and periodically thereafter, we are required under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and our Money Service Operator licence conditions to conduct due diligence on the Customer, which includes:

Where the Customer, its ownership structure, or its activities present a higher money-laundering or terrorist-financing risk, we will apply enhanced due diligence, which may include senior management approval before onboarding, more frequent monitoring, and more detailed source-of-funds evidence. We may decline to onboard, or may suspend, a Customer where required due diligence cannot be completed.

• verifying the Customer's legal existence, registered address, and constitutional documents;
• identifying and verifying directors, authorised signatories, and ultimate beneficial owners holding, directly or indirectly, 25% or more of the Customer (or such lower threshold as we determine appropriate to the risk presented);
• understanding the nature, purpose, and expected activity of the business relationship and the source of funds and wealth; and
• screening the Customer and its principals against sanctions, politically exposed persons, and adverse media lists.

6 Notification of Changes

The Customer must notify us promptly, and in any event within 14 days, of any change to:

The Customer is liable for any loss arising from its failure to notify us of a material change.

• its legal name, registered address, or constitutional documents;
• its directors, authorised signatories, or ultimate beneficial owners;
• its business activities, in particular any expansion into activities involving virtual assets; or
• its financial position, where material to its ability to meet its obligations to us.

7 Our Services

Subject to these Terms, Jillionpay provides business customers with:

Jillionpay does not offer, and this account may not be used for, virtual asset or cryptocurrency-related transactions of any kind, regardless of any such capability offered by other members of our corporate group in other jurisdictions.

• customer accounts for submitting remittance and payment instructions;
• domestic and international money remittance;
• currency exchange incidental to a payment or remittance;
• multi-user account access with configurable authorisation controls, where available; and
• such other services as we may make available from time to time, which may be subject to separate terms.

8 Authorised Signatories and Account Users

The Customer is responsible for designating its authorised signatories and account users, for ensuring their access is limited to what is appropriate for their role, and for promptly removing access for anyone who ceases to be authorised. We are entitled to rely on instructions given by anyone the Customer has notified to us as an authorised signatory, until we receive written notice withdrawing that authority.

9 Orders and Payment Instructions

An order is authorised once submitted by an authorised signatory in accordance with our security procedures. We may decline or delay an order where instructions are unclear, where we suspect fraud, money laundering, or unauthorised use, where required by law, or where completing the order would breach applicable sanctions.

10 Fees and Exchange Rates

Fees for business accounts are set out on our fees page, in a commercial agreement with the Customer, or disclosed before the Customer confirms a transaction. Currency conversions use the exchange rate we display at the time of the transaction, inclusive of our margin. We may amend fees on 30 days' notice, or as otherwise agreed in a separate commercial agreement.

11 Suspending or Restricting the Account

We may suspend, restrict, or block the Customer's account or a transaction where we reasonably believe:

We will notify the Customer of the reason where legally permitted, and lift the restriction once the underlying reason no longer applies.

• the Customer, a beneficial owner, or a counterparty is connected to money laundering, terrorist financing, fraud, sanctions evasion, or other financial crime;
• the Customer has provided false or materially incomplete information;
• required due diligence information has not been provided within a reasonable time; or
• we are required to do so by law, a court, or a regulator.

12 Liability and Indemnity

We are liable to the Customer only for direct losses that are a direct result of our material breach of these Terms, and only to the extent such losses were reasonably foreseeable. We are not liable for indirect or consequential losses, including loss of profit, business, or goodwill, except where such exclusion is not permitted by law.

The Customer will indemnify and hold Jillionpay harmless from claims, losses, and reasonable costs (including legal costs) arising from the Customer's breach of these Terms, breach of Applicable Laws, or from any information the Customer has provided to us that is false or misleading.

13 Complaints

If the Customer is unhappy with our service, please contact us so we can try to resolve it:

We will acknowledge a complaint within 5 business days and aim to provide a full response within 30 days as a service commitment; these timeframes are not a statutory requirement and may be extended for complex cases, in which case we will keep the Customer updated on progress.

• Email: support@jillionpay.com
• Telephone: +852 6268 0821
• Post: Compliance Department, Jillionpay, Workshop A2, G/F, Morlite Building, 40 Hung To Road, Kwun Tong, Kowloon, Hong Kong

14 Changes to These Terms

We may update these Terms to reflect changes in law, regulation, our services, or how we operate. We will give the Customer at least 30 days' notice of any change that is not clearly in the Customer's favour.

15 Suspension and Termination

The Customer may close its account at any time by contacting us. We may close the account by giving 60 days' notice, or immediately without notice where we reasonably believe the Customer has breached these Terms, used our services unlawfully, or where we are required to act by law or a regulator, or where the Customer is dissolved, wound up, or otherwise ceases to exist.

16 Data Protection

We process personal data relating to the Customer's directors, authorised signatories, and beneficial owners in accordance with our Privacy Policy and the Personal Data (Privacy) Ordinance (Cap. 486). This includes disclosure to regulators and law enforcement where legally required for anti-money laundering and counter-terrorist financing purposes. The Customer is responsible for ensuring that the individuals whose data it provides to us have been informed of this.

17 Governing Law and Jurisdiction

These Terms are governed by the laws of Hong Kong, and the courts of Hong Kong have exclusive jurisdiction over any dispute arising out of or in connection with these Terms.

18 Definitions

"Account" the Customer's profile with Jillionpay used to submit remittance, money-changing, and payment instructions. Jillionpay does not issue electronic money or any stored value facility, and does not hold Customer funds as an ongoing balance or deposit; funds are held only for as long as reasonably necessary to execute an instruction.

"Applicable Laws" the Money Service Operators Ordinance (Cap. 645), the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), the Personal Data (Privacy) Ordinance (Cap. 486), the Companies Ordinance (Cap. 622), and any other law, rule, or guideline issued by the Hong Kong Customs and Excise Department or other competent authority applicable to Jillionpay.

"Authorised Signatory" an individual the Customer has notified to us as authorised to give instructions on its behalf.

"Beneficial Owner" an individual who ultimately owns or controls the Customer, whether directly or indirectly, including through ownership, voting rights, or other means of control.

"Business Day" a day other than a Saturday, Sunday, or public holiday in Hong Kong on which banks in Hong Kong are open for business.

"Customer" the company, partnership, or other legal entity that has agreed to these Terms.

"Services" the money-changing, remittance, and payment services Jillionpay makes available to business customers under these Terms.

Regulatory Information

• Jillionpay is the trading name of JILLION GROUP INTERNATIONAL TRADING LIMITED, a company incorporated in Hong Kong (Company Registration Number: 2590405).
• Registered address: Unit 9B, 17/F., China Merchants Tower, Shun Tak Centre, 168-200 Connaught Road Central, Hong Kong.
• Principal place of business (as licensed): Workshop A2, G/F, Morlite Building, 40 Hung To Road, Kwun Tong, Kowloon, Hong Kong.
• Jillionpay is licensed as a Money Service Operator (MSO) under the Hong Kong Customs and Excise Department, licence number 18-01-02313, authorising us to provide money changing and remittance services.
• Jillionpay does not issue electronic money, does not operate a stored value facility, and does not hold customer funds as an ongoing balance or deposit. We are not licensed or authorised by the Hong Kong Monetary Authority.
• Jillionpay's Money Service Operator licence does not extend to, and Jillionpay does not provide, virtual asset / cryptocurrency services. Any reference on our website or marketing materials to affiliated companies is not a reference to services provided by Jillionpay under this licence.
• We comply with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), the Money Service Operators Ordinance (Cap. 645), the Personal Data (Privacy) Ordinance (Cap. 486), the Companies Ordinance (Cap. 622), and applicable FATF-aligned standards.