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PAYMENT TRANSACTIONS POLICY

Introduction to The Luupli Group of Companies and the Luupli Platform​

Luupli Limited is a company registered in England and Wales with company number 14407786 and a registered office at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (“Luupli UK”). Luupli Ghana Limited is a company registered in Ghana with company number CS162511023 and a registered office at Topbase,Gbawe, Accra, Ghana. (“Luupli Ghana”). Together Luupli UK and Luupli Ghana form a group of companies which shall be referred to as the “Luupli Group” in this policy. The Luupli Group provide an online social media platform (the “Luupli Platform”) to users throughout the world, including the UK and Africa. In order to be able to use the Luupli Platform, users will enter into an agreement with the Luupli Group (the “Agreement”). A key feature of the Luupli Platform is the ability of users to set and take part in a “Luupli Challenge” (see below for further details). Users, which can include brands and businesses, can set a Luupli Challenge and fund a cash prize which will be paid to the user who successfully completes the challenge.

Policy Overview​

This policy outlines the approach of the Luupli Group to facilitating payment transactions related to its Luupli Challenge feature in order to ensure that the Luupli Group, and in particular Luupli UK, complies with financial services laws and regulations that apply in the UK including rules and guidance set by the Financial Conduct Authority (“FCA”).

Application and Purpose​

This policy applies to all members of the Luupli Group as well as all directors, employees, contractors and agents employed by members of the Luupli Group. The purpose of this policy is to ensure that Luupli UK does not undertake payment services or issue electronic money in the UK when operating a Luupli Challenge on the Luupli Platform and does not, therefore, breach applicable financial services laws

Key Definitions​

  • Payment services: mean payment services as defined under Part 1 of Schedule 1 to the Payment Services Regulations 2017 (“PSR”) which includes, but is not limited to, the execution of payment transactions, the issuance of payment instruments, the acquiring of payment transactions and money remittance services.

  • Electronic money (e-money): is defined in section 2 of the Electronic Money Regulations 2011, as: electronically (including magnetically) stored monetary value as represented by a claim on the electronic money which:

    • is issued on receipt of funds for the purpose of making payment transactions;
    • is accepted by a person other than the electronic money issuer; and
    • is not excluded by regulation 3 [EMR]

Luupli Challenges​

A Luupli Challenge is a promotional feature within the Luupli Platform where users can create, enter, and participate in content-based challenges. The feature is managed and operated by Luupli Ghana and this is made clear to users when they set or enter a Luupli Challenge.

In a Luupli Challenge businesses, brands and other users can set a Luupli Challenge on the Luupli Platform. Eligible users can then attempt to complete a Luupli Challenge and if successful, and subject to the specific criteria of the Luupli Challenge, the winning entry may receive a financial prize set and paid for by the user who set the Luupli Challenge. This payout feature, whereby users can receive a financial reward, will only be open to users based in Ghana, where Luupli Ghana has entered into an arrangement with Paystack who will provide acquiring services enabling users who set a Luupli Challenge to fund the financial prize by paying Luupli Ghana. Luupli Ghana will also work with Paystack to execute a payment transaction to a user when they have successfully completed a Luupli Challenge. Luupli Ghana will also hold such funds in an escrow account with Paystack until a Luupli Challenge is completed and the payment can be made.

While only users based in Ghana can receive payouts, users based outside of Ghana will be able to set and fund challenges. In all cases, payments will be made to Luupli Ghana using acquiring services provided by Paystack. When users set or complete a Luupli Challenge they will agree to Luupli Challenge terms (the “Terms”), which apply in addition to the Agreement, and make it clear that payments related to Luupli Challenges are made to and from Luupli Ghana.

Roles and Responsibilities in relation to Luupli Challenges​

  1. Luupli UK:

    • Luupli UK must make it clear to all users that it can neither accept payments from, nor make payments to, users, and that any payments relating to Luupli Challenges are facilitated by Luupli Ghana who work with Paystack.

  2. Luupli Ghana:

    • Payment Processing: Luupli Ghana, through its partnership with Paystack, is the Luupli entity that receives, holds and sends payments related to Luupli Challenges.
    • Escrow Arrangements: Luupli Challenge funds are deposited and held in escrow by Luupli Ghana (in an account it holds with Paystack) until a Luupli Challenge is complete, ensuring.
    • Licensed Payment Provider: Paystack is a licensed financial institution in the jurisdictions it operates, and as such, Luupli Ghana reliance on Paystack ensures that all payment services adhere to local legal requirements.

  3. Paystack:

    • Third-Party Payment Processor: Paystack facilitates the acceptance, holding and sending of all payments for Luupli Challenges, and as a regulated entity, ensures that all transactions comply with local laws in the countries where payouts are made.
    • Payment Jurisdiction: Currently, only users based in Ghana are eligible to receive payouts. Paystack ensures compliance with the local financial regulations of Ghana.
    • For more details on Paystack and their regulatory status, visit their website here.

User Participation and Payout Conditions​

  1. Separation of Responsibilities:

    • Luupli UK and Luupli Ghana are distinct legal entities. Luupli UK is not involved in handling any funds or conducting any payment-related activity in relation to Luupli Challenges. Payments for Luupli Challenges are made to and from Luupli Ghana who works with Paystack to ensure compliance with local laws.

  2. No UK Payment Services:

    • Provided all payments related to Luupli Challenges are made to and from Luupli Ghana, Luupli UK will not be involved in the provision of payment services.

  3. Payment Data:

    • No Payment Data Storage: Luupli UK does not store any payment data or financial information of users. All such data is securely processed and stored by Paystack, adhering to local regulations.

Summary​

By complying with this policy the Luupli Group shall ensure that Luupli UK will not be involved in providing payment services in the UK.

All Luupli Challenges shall have terms that make it clear:

  • Which users can participate in a Luupli Challenge;
  • Which users are eligible for a payout if they win a Luupli Challenge; and
  • That all payments related to Luupli Challenges are made to and from Luupli Ghana.

This will ensure that no payment services are provided in the UK and, therefore, that Luupli UK is not providing payment services.

Changes to this Policy​

The Luupli Group shall review and update this policy:

  • At least once annually; and
  • If it makes changes to its business, the Luupli Platform or Luupli Challenges may impact this policy.