Acceptable Use Policy

1. Purpose of this Policy

Nordgate provides merchant of record, payment, billing, compliance, onboarding, risk management, and related services for approved businesses. This Policy is designed to:

1. protect buyers, vendors, Nordgate, payment providers, banks, card schemes, local payment methods, and other financial partners;
2. prevent fraud, scams, money laundering, terrorist financing, sanctions evasion, illegal activity, and consumer harm;
3. ensure that products and services sold through Nordgate are lawful, transparent, and accurately described;
4. ensure compliance with applicable laws, regulations, payment provider rules, card scheme rules, banking requirements, AML/CTF obligations, sanctions requirements, and Nordgate's internal risk policies;
5. define which business activities are approved, prohibited, restricted, or require prior written approval.

2. Scope

This Policy applies to:

1. products and services sold through Nordgate;
2. websites, applications, landing pages, checkout pages, and sales flows connected to Nordgate;
3. vendors and submerchants applying to use Nordgate;
4. existing vendors and submerchants using Nordgate;
5. transactions processed through Nordgate;
6. buyer conduct during checkout or support interactions;
7. use of Nordgate's APIs, dashboards, checkout, support tools, and integrations;
8. any activity that Nordgate reasonably believes may create legal, regulatory, financial, reputational, payment, compliance, or consumer protection risk.

3. Approved use of Nordgate

Nordgate is intended for approved and lawful businesses selling eligible digital products, software, SaaS, online services, and similar low-risk digital offerings. Nordgate may support, subject to review and approval:

1. software products;
2. SaaS subscriptions;
3. digital tools;
4. developer tools and APIs;
5. online platforms;
6. digital content;
7. online services;
8. digital licences;
9. educational digital products;
10. creator digital products.

All vendors and submerchants must be reviewed and approved by Nordgate before using the platform. Approval is not automatic. Nordgate may approve, reject, suspend, or terminate any vendor, submerchant, website, product, service, payment method, market, or transaction at its discretion.

4. General prohibited activities

You may not use Nordgate for any product, service, transaction, business model, or activity that is:

1. illegal or unlawful in any applicable jurisdiction;
2. fraudulent, deceptive, misleading, unfair, or abusive;
3. connected to money laundering, terrorist financing, sanctions evasion, tax evasion, or financial crime;
4. harmful to consumers or designed to exploit vulnerable persons;
5. infringing or misappropriating intellectual property rights;
6. designed to hide the true seller, product, service, customer, transaction purpose, or source of funds;
7. prohibited by Nordgate's payment providers, banks, card schemes, local payment methods, or financial partners;
8. inconsistent with Nordgate's merchant of record model, compliance obligations, risk policies, or contractual obligations;
9. likely to cause excessive refunds, disputes, chargebacks, complaints, fraud losses, regulatory scrutiny, or reputational harm.

5. Prohibited products, services, and business categories

The categories below are prohibited, restricted, or require prior written approval as described. Where this Policy allows prior approval, approval must be expressly given in writing by Nordgate and, where required, supported by Nordgate's payment partners. Nordgate may reject any activity even if it is legally permitted.

5.1 Illegal goods, services, or content

You may not use Nordgate for illegal goods or services, products or services that violate criminal law, stolen goods, hacking tools or illegal access services, trafficking, exploitation, abuse, coercive services, products or services designed to facilitate illegal conduct, or instructions, tools, or services primarily intended to commit crimes or evade law enforcement.

5.2 Fraud, scams, and deceptive practices

You may not use Nordgate for scams, fraudulent schemes, fake products or services, misleading trials, subscriptions, pricing, billing or cancellation practices, pyramid schemes, Ponzi schemes, matrix schemes, get-rich-quick schemes, fake reviews, fake engagement, fake traffic, impersonation, deceptive checkout flows, hidden fees, misleading refund or cancellation terms, or products or services relying on false claims, false urgency, or misleading guarantees.

5.3 Money laundering, sanctions, and financial crime

You may not use Nordgate for money laundering, terrorist financing, sanctions evasion, transactions involving sanctioned persons or prohibited jurisdictions, hiding or disguising the source, destination, ownership or purpose of funds, transaction laundering, processing payments for another business that has not been approved by Nordgate, nominee or shell arrangements, pass-through or front business arrangements, or activity designed to avoid KYC, KYB, AML, sanctions, risk, fraud, tax, or payment controls.

5.4 Regulated financial services

Regulated financial services clients are prohibited by default. Nordgate does not support vendors or submerchants that themselves provide regulated financial services unless the activity is lawful, properly licensed or registered, fully disclosed to Nordgate, and expressly approved in writing by Nordgate and its payment partners.

Regulated or financial services activities include, without limitation:

1. money transmission, remittance, and currency exchange;
2. e-wallets, stored value, prepaid access, or banking-like services;
3. lending, credit services, debt collection, factoring, or financing products;
4. investment services, securities, brokerage, trading, crowdfunding, or financial advice;
5. insurance or insurance intermediation;
6. payment aggregation or undisclosed payment facilitation for third parties.

5.5 Virtual currency, crypto, and digital assets

Virtual currency, cryptocurrency, digital asset, NFT, token, exchange, wallet, custody, mining, staking, yield, coin offering, token sale, crypto investment, crypto trading signal, or similar activities are prohibited by default unless expressly approved in writing by Nordgate and its payment partners.

Nordgate's own registrations, licences, and payment partner permissions, including any that cover virtual currency services, do not mean that vendors or submerchants are automatically permitted to conduct virtual currency or digital asset activities through Nordgate.

5.6 Gambling, betting, lottery, and games of chance

Nordgate does not support gambling, betting, casinos, lotteries, raffles, sweepstakes, games of chance, gambling tips, gaming skins betting, fantasy sports with monetary prizes, prediction markets, or prize competitions requiring regulatory approval. These activities are prohibited.

5.7 Adult content and adult services

Adult content and adult services are prohibited. This includes adult entertainment, pornography, sexually explicit content, escort services, sexual services, adult live streaming, sexually explicit subscriptions, adult dating, fetish services, and products or services involving sexual exploitation, coercion, abuse, or minors.

5.8 Drugs, controlled substances, medical, pharmaceutical, wellness, and supplement products

You may not use Nordgate for illegal drugs, controlled substances, drug paraphernalia, recreational cannabis, THC or similar products, unlicensed pharmaceuticals, prescription medicines sold without proper authorization, counterfeit medicines, steroids, products designed to evade drug testing, or products making unlawful medical claims.

Pharmaceutical, prescription-related, medical, or medical-claim products are prohibited by default unless Nordgate expressly approves them in writing and the vendor provides evidence of lawful authorization, licences, registrations, product approvals, and payment partner support.

Supplements, wellness products, and similar products may be considered only if the vendor provides evidence of lawful product certification or registration, trade or commercial registration, accurate product labelling, compliant marketing claims, and any other documentation requested by Nordgate. Approval is not guaranteed.

5.9 Alcohol, tobacco, vaping, cannabis, and age-restricted products

Alcohol, tobacco, nicotine products, vaping products, cannabis or cannabis-related products, and similar age-restricted or regulated products are prohibited unless Nordgate expressly approves a specific lawful, properly documented, and payment-partner-supported use case in writing. As a default rule, Nordgate does not support these categories.

5.10 Weapons, dangerous goods, and regulated items

You may not use Nordgate for firearms, ammunition, explosives, weapons, knives primarily designed as weapons, tactical weapons, weapon accessories, firearm parts, fireworks, hazardous chemicals, toxic substances, restricted military or surveillance equipment, or products designed to cause harm.

5.11 Hate, violence, abuse, and exploitation

You may not use Nordgate for products, services, or content that promote hatred, violence, harassment, discrimination, extremist organizations, terrorist activity, child exploitation or abuse, self-harm, suicide, glorification of violence, doxing, threats, human trafficking, forced labour, or exploitation.

5.12 Intellectual property infringement and counterfeit goods

You may not use Nordgate for counterfeit goods, pirated software, cracked software, illegal streaming, unauthorized IPTV, stolen licence keys, unauthorized digital downloads, copyright infringement, trademark infringement, fake branded goods, circumvention tools, or products that infringe another party's intellectual property rights. Vendors must have all rights, licences, permissions, and authorizations necessary to sell their products or services.

5.13 High-risk marketing, deceptive subscriptions, and negative-option billing

You may not use Nordgate for misleading free trials, hidden recurring billing, forced continuity billing, difficult cancellation flows, undisclosed renewal terms, deceptive upsells, misleading discount claims, unclear refund policies, products primarily promoted through misleading advertising, or aggressive or abusive affiliate marketing. All subscription terms must be clearly disclosed before purchase, including price, billing interval, renewal terms, cancellation method, refund rules, and trial conditions.

5.14 Unauthorized reselling and third-party processing

You may not use Nordgate to process payments for products or services that belong to another person or business not approved by Nordgate. You may not act as an undisclosed payment intermediary, process payments for unapproved third parties, submit transactions for another business, resell payment processing services without written approval, hide the true seller or product provider, or route transactions through Nordgate on behalf of prohibited or rejected merchants.

5.15 Data abuse, cybercrime, and unauthorized access

You may not use Nordgate for malware, spyware, ransomware, phishing, credential theft, botnets, spam tools, account takeover tools, unauthorized scraping, illegal surveillance, illegal hacking services, stolen data, unauthorized databases, personal data sold without lawful basis, or products designed to bypass security controls.

6. Restricted activities requiring prior written approval

Some activities may be considered only if they are lawful, transparent, properly documented, supported by Nordgate's payment partners where required, and approved in writing by Nordgate before processing begins.

Restricted activities may include:

1. online education with certification claims;
2. gaming-related digital goods;
3. AI tools, especially where used in regulated industries;
4. cybersecurity tools, provided they are lawful and not designed for unauthorized access, malware, credential theft, illegal surveillance, or abuse;
5. marketplaces or platforms onboarding third-party sellers;
6. high-volume subscription businesses;
7. health, wellness, supplement, or medical-adjacent software and products;
8. legal, tax, insurance-adjacent, or other regulated professional software or services;
9. cross-border services in higher-risk jurisdictions;
10. products with elevated refund, complaint, fraud, or chargeback risk;
11. other software, platform, or digital service categories that Nordgate or its payment partners consider higher risk.

Approval may include additional due diligence, enhanced monitoring, reserves, transaction limits, settlement delays, contractual restrictions, or payment method limitations. Approval may be withdrawn at any time if risk conditions change.

7. Sanctions and prohibited jurisdictions

You may not use Nordgate in connection with any person, entity, country, region, product, transaction, or activity prohibited by applicable sanctions, export controls, AML/CTF laws, financial crime laws, payment partner restrictions, card scheme rules, bank requirements, or Nordgate's internal risk policies.

Nordgate does not publish a fixed list of prohibited countries or regions in this Policy because sanctions, legal restrictions, and payment partner restrictions may change. Nordgate may block, reject, refund, suspend, freeze, or report transactions where sanctions or prohibited jurisdiction risk is identified.

8. Website, checkout, and disclosure requirements

Vendors and submerchants must maintain accurate, transparent, and accessible websites, applications, landing pages, checkout flows, or sales pages. Each vendor website or sales flow must clearly disclose:

1. legal or trading name;
2. product or service description;
3. pricing and currency;
4. taxes or fees where applicable;
5. subscription terms, if applicable;
6. refund policy and cancellation process;
7. customer support contact;
8. delivery method and timing;
9. licence terms, if applicable;
10. privacy policy and terms of service, if applicable;
11. any material limitations, exclusions, or eligibility requirements.

Vendors may not use hidden, misleading, incomplete, or deceptive sales pages. Nordgate may require vendors to update their websites, checkout flows, terms, refund policies, disclosures, or customer communications before approval or continued processing.

9. Merchant of Record transparency and checkout wording

Where Nordgate acts as Merchant of Record, vendors must not misrepresent Nordgate's role, hide the identity of the product provider, or mislead buyers regarding who is responsible for payments, refunds, invoices, disputes, chargebacks, or product delivery.

Where displayed, wording such as "Pay with Nordgate" or "Secure payment via Nordgate" identifies Nordgate's branded checkout and merchant of record payment flow. Underlying payment services, acquiring, wallets, cards, local payment methods, fraud checks, and related infrastructure may be provided by third-party payment providers, banks, card schemes, local payment method providers, or other payment partners. Such partners are referred to generically in this Policy unless Nordgate separately chooses or is permitted to name them publicly.

Nordgate may display a Merchant of Record notice at checkout, including language such as:

10. Statement descriptor

The intended customer statement descriptor is NORDGATE FINANCIAL. The exact descriptor shown to a buyer may vary or be shortened depending on the payment method, card scheme, bank, wallet, payment provider, region, currency, and transaction type. Nordgate may use a related descriptor where required or permitted by the relevant payment infrastructure.

11. Compliance with laws and payment partner rules

You must comply with all applicable laws, regulations, rules, licences, permits, and authorizations that apply to your business, products, services, customers, jurisdictions, and transactions. You must also comply with:

1. Nordgate's Terms of Service;
2. this Acceptable Use Policy;
3. Nordgate's Privacy Policy;
4. Nordgate's Refund Policy;
5. any vendor or submerchant agreement with Nordgate;
6. card scheme rules;
7. bank requirements;
8. payment provider and payment partner rules;
9. local payment method rules;
10. AML, sanctions, tax, consumer protection, data protection, and advertising laws.

Nordgate does not publicly name specific payment partners in this Policy unless required or appropriate. References to payment providers, payment partners, banks, card schemes, and local payment methods are intended to remain general.

12. Due diligence and information requests

Nordgate may request information and documents at any time to assess compliance with this Policy. This may include:

1. business registration documents;
2. ownership and UBO information;
3. director and representative information;
4. proof of address;
5. website or domain ownership proof;
6. product descriptions;
7. licences, permits, certificates, product registrations, trade registrations, or market authorizations;
8. financial statements or projections;
9. AML, KYC, compliance, or risk policies;
10. supplier, fulfilment, or product certification information;
11. customer support records;
12. refund and chargeback data;
13. transaction records;
14. marketing materials;
15. source of funds or source of wealth information;
16. any other information Nordgate reasonably requests.

Failure to provide requested information may result in rejection, suspension, delayed settlement, reserve requirements, refunding of transactions, or termination.

13. Monitoring and enforcement

Nordgate may monitor vendors, submerchants, buyers, websites, products, transaction patterns, refunds, disputes, chargebacks, complaints, and risk signals. Nordgate may take action if it identifies or suspects a violation of this Policy. Actions may include:

1. requesting additional information;
2. requiring website or disclosure changes;
3. limiting transaction volume;
4. limiting payment methods;
5. delaying settlement;
6. applying reserves;
7. suspending processing;
8. refunding transactions;
9. blocking buyers or transactions;
10. terminating vendor access;
11. reporting activity to payment providers, banks, regulators, financial intelligence units, law enforcement, or other competent authorities;
12. taking legal action.

Nordgate may take action immediately and without prior notice where required for legal, regulatory, payment, fraud, sanctions, AML, security, consumer protection, or risk reasons.

14. Reporting violations

If you believe that a vendor, buyer, product, website, transaction, or other activity violates this Policy, please contact Nordgate at info@nordgate.financial. Please include as much detail as possible, including:

1. website URL;
2. product or service name;
3. vendor name;
4. transaction ID, if available;
5. screenshots;
6. description of the concern;
7. any supporting evidence.

Nordgate may review and investigate reports at its discretion.

15. Changes to this Policy

Nordgate may update this Policy from time to time. The updated version will be posted on the Nordgate website with a revised effective date or last updated date. Continued use of Nordgate after the updated Policy becomes effective means that you accept the updated Policy. Nordgate may also notify vendors of material changes by email, dashboard notice, or other reasonable means.

16. Contact

For questions about this Acceptable Use Policy, contact:

• EMPYRA LTD, trading as Nordgate
• Company number: 14984613 (England and Wales)
• Email: info@nordgate.financial
• Website: https://www.nordgate.financial
• Registered office: 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom